Summary of meeting with local authority software providers: 6 July 2005
Held in Conference Room 145, Aviation House, London WC2B 6NH.
Present
FSA attendees:
Geoff Deville (Chair), FSA Monitoring Branch
Mercy Adebisi, FSA Animal Feed Unit
Michael Jackson, FSA Northern Ireland
Sandie Yeats, FSA Monitoring Branch
Paul Stubbington, FSA Monitoring Branch
Jennifer Reynolds, FSA Monitoring Branch
Steve Wilton, IT Consultant/Project Manager
Software company representatives:
Civica; Tascomi; Caps Solutions; MVM; Consilium; Flare; Masterware; Plantech
Local authority IT representatives ('in-house' systems):
Simon Bacon, Belfast City Council IT Department
Apologies
Assist Applications representative; Swift representative; Masterware representative; Intec for Business representative; MVM representative; Ocella representative; Geobuild representative
Agenda item 1: Welcome and introductions
Geoff Deville began the meeting by welcoming the Group to the second meeting between the IT software suppliers and the Agency. The purpose of the meeting was to update everyone on the state of play of the review of the monitoring system and to discuss the various questions that had come out of the working groups.
Agenda item 2: Note of 28 January 2005 meeting (originally circulated by email on 21 February 2005)
Geoff asked if there were any matters arising from the 28 January 2005 meeting. No comments were put forward. All attendees agreed the formal minutes.
At the January meeting, Clive Horton raised a question regarding outstanding inspections. Geoff clarified that, for trading standards inspections, the Agency's focus was on food standards issues.
Agenda item 3: Responses to FSA email dated 6 June 2005 titled 'FSA Focussed Audit Reports'
Geoff reminded the Group that, on 6 June, an email, on behalf of the Audit branch had been circulated. So far only four software suppliers had responded. Geoff requested that those who had not yet responded would please reply.
Agenda item 4: Oral presentation on the 'state of play' of the review of the food law enforcement monitoring system
Geoff introduced Merci Adebisi who was there to answer any questions surrounding animal feed. Steve Wilton, as the Project Manager whose role is to ensure that the project is delivered on time. Tom O'Hara, the business analyst who is looking into what needs to be done to make the system reliable and easier for all to use.
Geoff then gave a report on the progress to date. The Agency has been involved in a series of meetings with local authorities around the UK: already held in Northern Ireland, Scotland and Wales, and taking place in northern England and in London on 7 July and 13 July. A meeting for the South of England is planned for later in the year. All local authorities had been invited to attend these seminars so that the Agency could hear their views.
Phase 1 of the consultation is now completed. There had been general support for the Matrix with regard to inspections achieved, however, there had been opposition to the section on outcome measures.
The timing for the delivery of the project is that it should be complete by 2006 and to come into operation by April 2007. There must be time for the products to be developed, for local authorities to test with real data, not theoretical data. This will require two systems to run parallel. Local authorities need time to become familiar with the new system. A paper on proposed timings is to be drawn up in the next few weeks, which will be circulated to Software Suppliers and to Monitoring System User Group (MSUG) members inviting comments.
The business analyst's specification emphasises the requirement for standard data definitions to be drawn up, to ensure that there is no misinterpretation.
Steve Wilton confirmed that the XML (Extensible Markup Language) specification would come from the Agency's IT section and that they may have to provide an alternative method as well.
The register of issues drawn up from the MSUG working party was to be available on the website and should have answers to the questions raised in the next month.
Animal Feed requirements are likely to stay when the Official Food and Feed Regulations comes into force in January 2006. This would affect only Trading Standards in Unitary authorities and in English Counties. Geoff explained that he intends to propose that the Monitoring Form be two separate entities. One part for human food and one for animal feed. The animal feed requirement runs to 12 pages. These will be included in the second consultation, which is scheduled to go out at the end of July, for a 12-week consultation period to October. [Secretary's note: the second consultation has subsequently been put back to November.]
Similarly the position on imported food will be covered in the second consultation.
A valid question was raised that if the system was to be in operation by 2007 then did that mean that the local authorities would need to start recording data in 2006. The concerns were that this would leave little time for the systems to be tried and tested. Clarification was sought on whether the revised monitoring data would be for financial year 2006/07, with a return due Spring 2007 or for 2007/08, with the return due Spring 2008.
Action: FSA to clarify whether the revised monitoring data would be for financial year 2006/07, with a return due Spring 2007 or for 2007/08, with the return due Spring 2008.
The Caps Solutions representative asked if the Agency had any views on whether the recording programmes are to be changed to a new process or would there be just an overhaul of the current programme. Steve Wilton explained that there was not to be a huge overhaul. He stressed that the mapping process of information to be recorded on software systems is the important thing to get right. The XML will not be the same as the one used previously. The animal feed form will be entirely different.
The Hampton Report and the Chancellor of the Exchequer's launch of the Better Regulation Action Plan called for a radical change in focus of inspection, from inspecting all premises by risk profile, to dividing good guys from the rogues. These issues were under discussion, but could have a major impact on the project.
Geoff explained that a mailshot to local authorities, asking for details of their IT suppliers, had been sent out. He reassured the Group that this information is not to be published and is purely for the Agency's own records.
Following the Hampton Review and the proposed new national Consumer Trading and Standards Agency (CTSA) , the Flare representative Lum asked what, in practice, will it mean if CTSA are to lead in the inspection of large business. Will local authorities only enforce the smaller local food companies?
Geoff said that the Agency was actively considering all aspects of the proposals, and no decisions had yet been reached.
Agenda item 5: General discussion on issues arising from first consultation exercise and representations made by local authority colleagues at Monitoring System User Group (MSUG) meetings
The MVM representative said that new data definitions/coding tables would give local authorities the guidance they needed. Two sets of codes would be required. Old codes for historical data and new codes for the current requirements. He felt it would be two years before reliable data could be extracted. This is because data needs to be compared 'like with like'. This thread needs to be pulled together before the second consultation. If it is not identical then compatibility is lost. If new 'file cabinets' are required this could be time consuming.
Outcome measures, for food hygiene, focus on the risk rating score. A hazard compliance ratio had been considered in the past, however, local authorities considered this too complex. Local authorities want figures that are valid to them. A system that highlights what's outstanding and needs to be done. Simple definitions, that are easy to understand to avoid inaccuracies. On the Food Standards side the LACORS risk assessment scheme has only one element. The FSA Code of Practice has two elements (compliance and confidence in management). Trading standards tend to use the LACORS scheme. Is there any benefit in managing two different risk assessment schemes?
The '28 day' rule for primary inspections should only be used for exceptional circumstances. local authorities had highlighted that it can cause problems:
- it crosses the boundary of different financial years
- Only count those achieved within the 28 day rule in the financial reporting year
Of the options set out in the paper, software companies said they would be able to cope with either option A or D, if given clear definitions. But there would be problems with option D, as there would easily be confusion over in which year inspections carried out during the 'run-over period' of 28 days should be counted. Much better to go to 'due' against 'achieved' (over dues are dues in the next year).
'28 day' rule is an Audit point and a separate issue from the monitoring form. Option A makes more sense. Audit will ask for the number of visits overdue by more than 28 days.
The Group clarified the position on upgrade paths. There is no need for local authorities to 'go live' at each intervention when up grading from an old version to the newest version. They can move from version 1.2 to 1.5, for example, as long as the integrity checks are carried out at intermediate points (e.g. versions 1.3, and 1.4). Training would only be required on the final version. Implementation is complex.
Drilling Down: Audit Trail: All systems must be able to drill down to historical data (some local authorities use crystal reporting systems to interrogate their data). The data is there and local authorities should be able to get it out. Data entry is often the problem not inadequate software. Systems can only count what has been input not what has been missed.
Manual Correction: The systems are capable of manual correction; however, there could be problems if local authorities could then change inspection dates generally. An exception could be made for seasonal premises only: if a seasonal premises is due in December, but is actually carried out in August, when it is open, the system could allow local authorities to make adjustment to the original due date. Local authorities could also be allowed to make an informed decision to move a date. In both cases, the should be flagged to explain to auditors if need be.
Prosecution: The question regarding recording the number of establishments that have been subject to prosecution is clearly laid down in the Code of Practice. They should not be reported at the launch of the prosecution but reported at completion.
Definitions: New premises or new business
The Agency proposes to keep to the word premises. However, if there is a new owner of a premises, at the same address, it should be counted as a new business with a new file for the premises address. FSA guidance will need to be changed.
Action: FSA Monitoring Branch to change FSA guidance
Agenda item 6: Any Other Business.
Alternative Enforcement Strategy (AES) ' if local authorities opt to inspect, then the frequency would be not less than that laid down in the Code of Practice.
Steve Wilton agreed to send out his email address marked 'commercial in confidence'
Action: Steve Wilton to send out his email address marked 'commercial in confidence'
Software suppliers requested a set of examples for the Data Definitions.
The next meeting will be arranged for the end of October 2005.
Geoff reminded everyone that the current situation was one of continuous change in the proposals as they were developed. He thanked everyone for their attendance and closed the meeting.
