Audit feedback meeting: 21 April 2004

Mark Du Val, LACORS (Chair)
Charlotte Meller, LACORS
Yvonne Robinson, Food Standards Agency (Secretariat)
Ron Cheesman, Food Standards Agency
Peter Daley, Allerdale Borough Council
Simon Frow, Barnsley Metropolitan Borough Council
Elizabeth Georgeou, London Borough of Brent
Chris Rowlston, Mansfield District Council
Alan Bennett, Coventry City Council
Tabitha Hosey, Royal Borough of Windsor and Maidenhead
Stephen Headley, East Riding of Yorkshire Council
Mike Hopgood, Somerset County Council
Malcolm Taylor, Cambridgeshire County Council
Tim Farquhar, Southampton City Council
Doug Lindsay, Eastbourne Borough Council
Clare Huppler, Teignbridge District Council
Peter Emmett, Portsmouth City Council
Rob Chapleo, Warwick District Council

Apologies were received from Birmingham City Council and Halton Borough Council.

1.1 Mark DuVal introduced and welcomed everyone to the third of a series of meetings held jointly between LACORS and the Food Standards Agency. These meetings aim to obtain feedback from audited authorities as part of the Agency's commitment to continuous improvement. The feedback at this meeting was invited from authorities who had been subject to full audit (between October 2002 and June 2003) and those that took part in the focused audit programme on formal enforcement activities.

2.1 Feedback from local authorities was given.

Full audits:

Allerdale Borough Council - Peter Daley

Found the audit a positive process, which had raised the prominence of food safety with elected Members. The audit and the need to address the action plan focused minds and this had helped to improve recruitment arrangements. The Authority was, however, disappointed that despite being advised at their opening meeting that the Agency would liaise on press releases, they only knew one had been issued because of a press enquiry. Brent, Teignbridge and Cambridgeshire also had concerns regarding the notification of press releases from the Agency.

Agency action point: To improve liaison arrangements between The Agency and local authorities regarding the issue of press releases.

Barnsley Metropolitan Borough Council - Simon Frow

The impending audit produced a positive benefit in the recruitment of two additional staff in trading standards. The Authority has now also undergone a Best Value audit and did find some differences in the recommendations made by Best Value and the FSA. Found the requirement of the FSA to carry out all low risk inspections particularly onerous, bearing in mind the guidance issued by LACORS on alternative inspection strategies. The audit confirmed what they were doing right and what they improvements needed, which enabled them to focus.

The Agency advised that they would expect local authorities to adhere to the inspection frequencies set out in the Codes of Practice, which will in future embrace alternative inspection strategies.

London Borough of Brent - Elizabeth Georgeou

Preparation for the audit was onerous, but it prompted the completion of a number of previously identified tasks. The time on site was very intensive, including the need to provide database reports on the day. They found the daily detailed feedback useful. The result from the audit was positive, with a subsequent successful bid for growth monies, which has been repeated this year, with the added expectation of providing a good health and safety service.

Mansfield District Council - Chris Rowlston

Agreed that preparation for the audit involved a lot of time, effort and resources. The auditors were found to be professional with good inter-personal skills. Elected Members were involved, which maintained the high profile of the Service, and officer competencies were recognised to the extent that they have been seconded to other corporate priorities.

The Service had been subject to a number of audits that year, which affected the morale and motivation of staff, particularly where it was obvious that mistakes had been made by identifiable officers - the example of a problem with one improvement notice was cited.

The Agency advised that normally where there was a problem with just one notice this would not be mentioned in the report. Clearly, where mistakes are found, the auditors are duty bound to highlight them so that the Authority can make improvements. Issues are raised with the audit liaison officer, who is best placed to decide on the most appropriate means of communicating problems with the individual concerned.

Portsmouth City Council - Peter Emmett

Had a less positive experience, and found the process time consuming, disruptive and intrusive, particularly for a small authority. Felt the need for procedures was questionable. Their elected Members felt that the audit was negative and was just bureaucracy and paperwork and they have lost money as a result. They were also disappointed in the language in the draft report, which they felt undersold the areas where the Authority complied.

The Authority felt that there should have been a TSO on the audit team rather than four EHO's, as there was an apparent lack of understanding of how food standards fitted into a trading standards service.

The authority questioned the value of a full audit and felt that there was benefit in exploring shorter, more frequent meetings.

It was explained that the Agency had been unable to recruit as many food specialist TSO's as they would wish, however all the EHO's on this audit had food standards experience.

The audit process does allow for negotiation on the wording of the draft report and the Agency is open to suggestions on rewording of the content where possible.

Agency action point: To consider providing more detail on auditor backgrounds at the opening meeting to provide more confidence of their breadth of knowledge.

Teignbridge District Council - Clare Huppler

Although the audit had a good outcome, the process was stressful, with a lot of work needed to prepare for it. The audit was very motivating for staff, who felt rewarded for doing a good job. The auditors were very professional and informal, but the feedback sessions were unexpectedly intense with very detailed information. They would have preferred to be advised of the audit by letter rather than an unanticipated phone call. The need to locate letters sent out by the Agency was questionable.

The Agency advised that they had tried various means of advising authorities that they had been selected for audit, and the consensus was that a telephone call was the preferred means. The Agency acknowledged that there were issues surrounding correspondence sent to local authorities and this was being reviewed. Audit liaison officers are normally advised that the feedback sessions are by necessity intense.

A discussion took place on the difference between key areas for improvement and recommendations. The Agency clarified that they would expect all the agreed recommendations to be addressed.

Agency action point: To consider the provision of a briefing document for audit liaison officers to provide further detail on the process and their role in it.

Mark DuVal summarised the feedback from authorities subject to full audit, acknowledging that there was a range of experiences. There was a discussion about the need for documented procedures and the level of detail required. It was suggested that procedural templates would be advantageous, however the production of templates was difficult, as authorities' requirements vary greatly, for e.g. what may be suitable for a small District Council would not be adequate for a large Metropolitan Borough Council. Instead LACORS have placed a range of useful procedures on their website.

Mark DuVal then asked colleagues from authorities who had been subject to a focused audit on formal enforcement to provide their feedback:

Enforcement audits:

Birmingham City Council - provided written comments

They had also received a full audit as part of the pilots undertaken by the Agency when developing the audit scheme. They felt that although there was still a lot of work involved, they preferred the focused audit format. They found the auditors to be very professional, and felt that the opportunities for feedback and discussion were helpful. They were however disappointed that the summary report had not yet been published.

Cambridgeshire County Council - Malcolm Taylor

Found the auditors approach to be open and professional, and more positive than those from the Audit Commission. There did appear to be inconsistencies between the two audits, as the Audit Commission said that targets for inspections should be realistic rather than aspirational, whereas the Agency had said that the Authority should aim to achieve all of their inspection programme. There should be more liaison between the Agency and the Audit Commission on approach.

The Agency advised that there is regular liaison with the Audit Commission.

The authority was disappointed in the delay in receiving the final report, as the draft action plan took a long time to negotiate. The audit did result in a budget increase of £70,000, however this was taken away the following year.

Coventry City Council - Alan Bennett

Found the auditors to be well organised, open, professional with good inter-personal skills, which was helpful when negotiating the detail of the action plan. Found that the informal feedback was a useful dynamic process, and the report did not present any surprises. However, they are disappointed that the promised summary report has not appeared, as this meant that the process lost impetus, and they were unable to politicise and raise the profile of the Service as they would have wished.

The Authority was also disappointed that the opportunity to share good practice has been significantly delayed. Overall however, the audit was found to be useful, and having face to face contact with Agency officials was helpful.

The Agency acknowledged that there had been delays in sending out the reports as the original intention was to publish all the final reports and the summary report at one time, as for the first focused audit programme on food sampling. However, there were delays in agreeing all the reports, so for those that were audited at the beginning of the quarter, there were long delays. The decision has now been made to publish individual reports as and when they are agreed. In respect of the overarching report, it became apparent that a summary report was not the most appropriate means of presenting the findings of the audit programme. Instead, a discussion paper was presented to the Enforcement Liaison Group (ELG) in February, which set out issues highlighted from the audits and sought to identify any further work necessary. Any overarching report will now be published to a tighter timescale.

Good practice has been identified throughout the 15 authorities audited and relevant LAs will be contacted in the next couple of weeks to seek agreement for the detail to be published on the Agency and LACORS websites.

East Riding of Yorkshire Council - Stephen Headley

The Authority was pleased with a good outcome from the audit. They would have appreciated knowing their reason for selection before the opening meeting. Although a focused audit, it was comprehensive, and there was insufficient time on site. The auditors were found to be professional throughout, during the audit and in subsequent discussions. Whilst they had policies and procedures developed, they were unsure whether they had been pitched at the right level, and what would be acceptable to the Agency.

There were some suggestions for improvement, including adherence to agreed timescales. They would have appreciated longer for completion of the Pre-visit Questionnaire and more notice for compilation of the files required for audit.

There was a feeling that the food standards element of the service had received less attention and that animal feeding stuffs should have been included.

The audit did have an impact on staff morale - it was clear that problems with improvement notices were attributable to a particular officer, and it would have been helpful if the auditors could have looked at a wider cross selection of files.

A procedural template on the authorisation of offices would be useful.

It was surprising that the interviews concentrated mainly on the overarching aspects of the focused audit rather than anticipated reality checks.

Unlike any other audits that they had been subject to, there are no rankings, either for individual recommendations or how the Authority performed overall. These would have been useful for explaining to elected Members the implications of the report and how they had performed.

There followed a discussion on the benefits and problems of rankings. On the whole the consensus was that they were more trouble than beneficial, however that the Agency could re-explore providing an indication of the importance of the recommendations (e.g. minor/major non-conformances). The Agency advised that this had been looked at a number of times previously.

Eastbourne Borough Council - Doug Lindsay

Agreed fully with the audit findings and the subsequent action plan. Found the audit to be a stressful time, particularly as it was in March with year-end commitments. Once the feedback was received it was a big morale boost for the staff. The Authority found the auditors to be excellent.

Somerset County Council - Mike Hopgood

Found the auditors to be very professional and approachable, any criticism was provided constructively. Preparation time was phenomenal, even for a focused audit. It was questionable whether the effort put in equalled the benefit that came out of it. Were wrongly advised that they were selected for audit because of a low level of enforcement activity, but were actually medium. This was subsequently corrected.

Southampton City Council - Tim Farquhar

The experience of the audit has provided benefits in preparation for their recent port health focused audit. Were unhappy however in the delays in getting the report finalised.

Royal Borough of Windsor and Maidenhead - Tabitha Hosey

Found the auditors to be very personable and human. The report however, was more negative than anticipated and did not reflect any strengths that were fed back during the course of the audit. The Authority did question the report but found the Agency unwilling to make changes. Unfortunately the files that were picked for audit happened to be the worst files and the Authority felt that a different selection of files would have produced a different report. The report was not well received by elected Members and officers and was not able to be used in a positive way to recruit more staff. Due to budget cutbacks the Service in fact lost two posts.

The Agency stressed that the process does allow authorities to question the draft report and highlight areas where positive issues have been omitted.

Warwick District Council - Rob Chapleo

The audit was comprehensive, and relatively painless as the Authority was used to being audited. They found the administrative arrangements to be excellent, time keeping good, and the objectives thorough. The Authority would be disappointed if the Agency's audit scheme was diluted in anyway by Inter-Authority Audits (IAA), and would seek to see a continuing role for FSA audits.

Essex County Council - provided written comments following the meeting

They found the experience a positive one and were pleased with the good outcome of the audit, particularly the positive feedback in recognising the hard work of staff. The auditors were very credible and found it particularly useful that one of the auditors had an appreciation of trading standards work, although there were occasional disagreements over what constituted acceptable 'evidence'. The Authority was, however, disappointed by the short notice of the audit and then the lengthy delay in receiving the final report, which made publicity of the good performance appear to be 'old news'.

Ron Cheesman fed back on the main findings from the audit programme as set out in an ELG discussion paper presented on 26 February (attached as an annex). These were issues surrounding training, resources, internal monitoring, the dissemination of good practice and the effectiveness of different enforcement approaches. Progress on these issues will be discussed at a further meeting of the ELG.

Malcolm Taylor (Cambridge County Council) felt the findings appeared positive, with a wide range of issues raised, and that the focus should be to look at what would help to raise the profile of local authorities and gain improvements.

Tim Farquhar (Southampton City Council) supported the move towards focused audits, and suggested that any IAA training could be linked in with lead assessor training provided by the Agency.

In respect of resources, Stephen Headley (East Riding of Yorkshire) said that a large problem was recruiting officers with appropriate competencies to carry out the work.

4.1 Conflict regarding target setting between FSA and Audit Commission - this had already been discussed during the individual feedback sessions.

4.2 The value placed by the FSA on IAA - the Agency advised that it had been involved in the funding of IAA schemes and had provided training for the East of England Trading Standards Authorities (EETSA) scheme. The schemes do need to be robust, with effective follow up after the audit.

Authorities were not clear what scheme would be acceptable to the FSA to demonstrate a robust scheme. Mark DuVal suggested that the focus should be on ensuring that the scheme resulted in an improvement in service rather than following the FSA's protocols and checklists to the letter.

There will always be an Agency role in auditing local authorities, but IAA schemes could also produce useful information to indicate trends, which could be presented to the Agency's Board.

4.3 The role of the FSA audit in Comprehensive Performance Assessment - the meeting was advised that the Agency has always made the case that regulatory services should be involved in the CPA process.

No other business was raised.

Mark DuVal concluded that it had been a very positive meeting, which had generated some ideas for improvement. He closed the meeting by thanking all those that had attended.