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8018A Food Control Law Enforcement Service Plan 2023-25 F

Argyll and Bute Council · 18 October 2023
Back to Planning, Protective Services and Licensing Committee — 18 October 2023 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

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FOOD SERVICE PLAN 2023-25 FINAL 091023      
Appendix 1 
Food Control Enforcement Plan 
2023-2025

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1. SERVICE AIMS AND OBJECTIVES   
1.1 Aims and Objectives   
The Council’s Regulatory Services is committed to the aim of protection of public
health.   
The Council is a competent authority under retained Regulation (EU) 2017/625 of the
European Parliament and the Council on Official Controls, a statutory food authority
under the Food Safety Act 1990 and a delegated competent authority under Food
Hygiene (Scotland) Regulations 2006  Therefore, the Council aims to ensure that all
food and drink, intended for sale for human consumption, which is produced, stored,
distributed, handled or consumed within or exported from Argyll and Bute does not
pose a significant risk to the health or safety of the consumer and the consumer is
not prejudiced by it.   
The term Food Control, for the purposes of this plan is integrated and
comprehensively provides for the protection of the consumer, comprising food safety,
food hygiene, food standards, food authenticity and Integrity, food information and
food fraud/crime.   
Regulatory Services, consistent with available resources seeks to achieve protection
of the consumer through the following objectives:- 
 To undertake the statutory enforcement role of a competent body “according
to retained Regulation (EU) 2017/625, in accordance with retained Regulation
(EU) No 2019/627 - and under the Food Hygiene (Scotland) Regulations
2006 an as a Food Authority” under the Food Safety Act 1990 working in
accordance with service standards and specific requirements and guidance
from Food Standards Scotland and DEFRA. This includes particular
reference to the Food Law Code of Practice (hereafter referred to as FLCOP)
and the Interventions Code of Practice (ICP) published by Food Standards
Scotland. 
 To provide an effective food control service focusing limited resources
according to a risk-based approach and ensuring that all enforcement activity
is also risk based, balanced, proportionate, reasonable, evidence based,
consistent with the FLCOP, (notably the compliance spectrum), and is
consistent with the Scottish Regulators' Strategic Code of Practice 
 To develop, a Food Control Service Plan (i.e. this plan) which will confirm the
key priorities, themes and the work to be undertaken. In summary, the key
priorities of this plan focus limited resources upon the highest risk FBOs and
on innovation with the purpose of deploying these resources as effectively as
possible. 
 To work with and support local Food Business Operators (hereafter referred
to as FBO’s) in an open and transparent manner, to improve the safety, the
authenticity and the integrity of food and the level of compliance with relevant
legislation, in line with the Service's Enforcement Policy 
 To provide Food Control advice to FBOs, the consumer and other
stakeholders. Including FBOs applying for approval under regulation (EC)
853/2004 acknowledging that effective impartial advice at the outset is the
most effective preventative approach.

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 To maintain adequate systems including a computer-based inspection
programme and reporting system, designed to improve the quality of food
control enforcement, data, management information and reporting   
1.2 Links to Corporate  Plan 
This plan links to the Council’s corporate policy outcomes of promoting a sustainable
economy; protecting our communities and the wider health protection agenda.   
2. BACKGROUND   
2.1 Profile and the Local Authority   
Argyll and Bute Council is a unitary authority, with a resident population of 86,130
and a geographical area of 690,889 hectares, including 23 inhabited islands, located
within the west Highlands of Scotland.   
2.2 Organisational Structure   
Regulatory Services delivers the Council’s statutory food control law enforcement
role in a team which provides the range of services within environmental health,
animal health, and licensing standards. This service is located within the
Development and Infrastructure Directorate in Development and Economic Growth.   
Regulatory Services is managed at a third-tier level through the Regulatory Services
and Building Standards Manager with operational management being provided by
the Environmental Health Manager (East) and Environmental Health Manager
(West).  There is no specific food control team as officers undertake generic work
relating to their profession, although the lead for the operational management of
Food Control rests with the Environmental Health Manager (West). The lead for the
professional, operational (including enforcement) and technical aspects of Food
Control is taken by the Lead Officer in Food Control, (Environmental Health officer
(Food Control and Service Support) ) responsible for exercising the operational lead
in Food Control and maintaining the interventions, qualifications and enforcement
required by the FLCOP.   
Regulatory Services refers reports to the Planning Protective Services and Licensing
Committee or the full Council as determined by the nature of the report. In addition,
the service has access to the other Committees and the Argyll and Bute Licensing
Board.   
The Councils statutory appointments required under the Food Safety Act 1990
through the FLCOP and in accordance with retained Regulation (EU) 2017/625 are 
Head of Food Safety Regulatory Services and 
Building Standards Manager  
Lead Officer – Food Control Environmental Health Officer 
(Food Control and Service Support)  
Management Lead – Food Control Environmental Health Manager (West)   
A review of these statutory appointments against the requirements of the FLCOP is
ongoing as part of the service redesign process, specified in the Regulatory Services
Service Plan 2023-25.

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2.3 The Scope of the Food Service   
Official controls are undertaken principally by authorised Environmental Health staff,
although some work is undertaken by Animal Health and Welfare staff. The Service
continues to review roles and responsibilities in respect of food as far as the FLCOP
allows, to integrate work across disciplines so we can make better use of the wider
service resource.   
The Service recognises that food control management systems operated by FBOs
do occasionally fail. In such situations the Service responds as a priority and will
continue to do so by investigating and controlling communicable disease outbreaks,
investigating incidents, complaints and intelligence reports. Such responses are in
accordance with the Service’s Food Control Enforcement Policy, the FLCOP and
with applicable guidance.   
Animal Health and Welfare Officers undertake primary production activities into the
animal health inspection protocols for targeted businesses   
The service priorities detailed in this Food Plan are determined through statutory
duties, the FLCOP; national, local and service priorities.  The Council’s Enforcement
Policies and food control procedures whilst internal monitoring informs the standards
for this work.   
2.4 Laboratory Arrangements   
The Council has a formal Service Level Agreement with Glasgow Scientific Services
(GSS) for the provision of laboratory services, including the microbiological
examination and the analysis of foodstuffs and feed. The Council requires to make
statutory appointments for specialist support services and this plan seeks approval of
Glasgow Scientific Services and named staff to meet the requirements for a public
analyst, food examiner and agricultural analyst. These appointments are detailed in
Appendix II of this plan. 
2.5 Professional Support Network   
The service works closely with Food Standards Scotland, the Scottish Food
Enforcement Liaison Committee, the Crown Office (Procurators Fiscal) and NHS
Highland.   The service benefits from the support of the Royal Environmental Health
Institute of Scotland, the Society of Chief Officers of Environmental Health in
Scotland, The Lead Officer is an elected fellow and a registered food safety principal
at the Institute of Food Science and Technology and benefits from that network.   
The service values and participates as is appropriate and relevant to do so, within
established inter-authority liaison and professional network mechanisms operating
within Environmental Health in Scotland. Of specific note are Society of Chief
Officers of Environmental Health in Scotland), SFELC, the SFELC Approved
Establishments Working Group, the SFELC/SOCOEHS Methods and Techniques
Working Group, the SFELC Listeria Working Group, and the NHS Highland Liaison
Group.

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2.6 Food Control in Argyll and Bute   
The nature, type and scale of food businesses in Argyll and Bute are influenced by
its geography, particularly its proximity to the sea and infrastructure. These factors
can create a range of difficulties in delivering the statutory work. Examples of these
are:   
 An atypically high number of 55 approved (exporters) and 45 other
manufacturing and processing FBOs are engaged in manufacturing, often
utilising specialist processing techniques and technology without in house
technical support. This generates a high number of Home Authority requests
for assistance, advice and export certification. A significant supply sector
including a large seafood industry comprising the largest wild caught shellfish
sector in the UK and the second largest aquaculture sector in the UK. This
has a significant impact on the work of the service and requires specialist
shellfish waters classification work, which enforces the monitoring
programmes for bio-toxins and classification of shellfish harvesting waters. 
 The geography of Argyll and Bute poses specific challenges in delivering
services and ensuring that there are sufficient arrangements in place to
ensure and promote effectiveness and consistency. This is supported by the
direction of operational work and management direction of staff within the
decentralised area offices, training, specialist support, and the food plan 
 There is significant officer time spent travelling as part of their operational
work (estimated at 20%). This has reduced slightly in the past few years due
to flexible, mobile and remote working, through integrating roles where
possible and practical with other officers, our new Official Controls systems,
and better use of digital technology. This includes the ability to carry out
remote verification inspections via MS Teams and similar platforms. 
 Following the last FSS Audit, Root Cause analysis was applied to the findings
and determined that the state of compliance was due to insufficient
resources, responsibility allocation and management capacity. These issues
remain as issue with a resource gap of 5 FTE between the existing
establishment and that required to deliver the Food Law Code of Practice. 
 The re-start of Food Control following the pandemic, acknowledged the
unique and challenging circumstances of the Service. The options were
finally balanced between establishing a specialist team with the advantages
that provides and involving all Officers with the potential resilience that
provides. Previous experience with wider involvement which had been
attempted twice was not supportive. A focussed working group with all
Officers being trained in Advanced HACCP in Manufacturing and in OCV and
in OCV-Lite was implemented. The wider team now constitute a pool of
Officers which can assist the Working Group and can more quickly move into
the Group if required. The twin goals of specialism and resilience have now
been met. However, the Working Group is comprised of relatively
inexperienced Officers who have only completed only one pilot OCV
inspection cycle. Significant support and resourcing will be required, as there
is a resource gap of 5 FTE authorised food control officers between the
current establishment and that required to deliver the FLCOP. Actions to
address this challenges is detailed in the plan.

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2.7 Uniqueness of Argyll and Bute Council as a “food authority”   
2.7.1 The Service has responsibility for 2500 FBOs excluding the businesses which
operate on a temporary or ad-hoc basis. The FBOs are divided into risk rated
categories according to the Food Law Rating Scheme (FLRS) as follows:   
Category Minimum Inspection
Frequencies
Number of
Establishments  
Group 01  Risk Band A Every 18 months 17  
Group 01  Risk Band B Every 12 months 65 (includes 57
Approved premises)  
Group 01  Risk Band C Every 6 months 1  
Group 1 unrated  17  
Group 02  Risk Band A Every 24 months 134  
Group 02  Risk Band B Every 18 months 406  
Group 02  Risk Band C Every 12 months 152  
Group 02  Risk Band D Every 3 months 14  
Group 02  Risk Band E Every 1 month 2  
Group 2 Unrated  276  
Group 03  Risk Band A Every 60 months 592  
Group 03  Risk Band B Every 36 months 574  
Group 03  Risk Band C Every 24 months 50  
Group 03  Risk Band D Every 3 months 1  
Group 03 Unrated   262   
2.7.2 The 55 approved establishments (smokeries, shellfish processers, harvesters and
cheesemakers etc.) amounts to the third highest number in Scotland. These FBOs
fall within the ambit of Official Control Verification (OCV) and accordingly require the
resources according to the OCV resource calculation. The 45 further manufacturers
are not subject to approval because they do not process products of animal origin or
they process composite products containing products of animal origin, including
sandwich manufacturers, ready meal manufacturers, non-dairy cheese
manufacturers, a significant distilling sector and a brewing sector. A significant
proportion of the Approved and manufacturing FBOs minimally process their
products and utilise specialist ‘Hurdle Technology’, which places specialist demands
upon the Service. Manufacturing establishments in general also embody increased
political risks for the Council and commercial risks and opportunities for the local
economy, in that they distribute high risk products throughout the UK and globally.   
2.7.3 The Service has participated in the national awards relating to the Food Hygiene
Information Scheme and the EatSafe Awards which are run by the Food Standards
Scotland. Both recognise good businesses in terms of food safety and provide
information to allow the consumer to make an informed choice. The Service will
continue to participate insofar as limited resources will allow. Argyll and Bute, have
issued 114 Eat Safe awards out of a total of 1176 in Scotland.   
3. SERVICE PLANNING PROCESS   
3.1 Service Plan   
The Food Control Law Enforcement Service Plan (i.e. this plan) is submitted to the
Planning, Protective Services and Licensing Committee for approval. The plan
proposes a level of service and scope of work in relation to resources available in the
context of the statutory obligations placed on the Council. This plan does not meet in
full the FLCOP but focuses on higher risk priorities

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3.1.1 Resources, Demands and Risks   
Fundamental to Service planning is establishing the relationship between resources,
demands and risks and producing a plan that achieves the most optimal
reconciliation of these factors. This plan acknowledges a significant resource deficit
and is underpinned by risk assessment to provide the most effective application of
resources.   
The OCV Resource calculation in combination with the SFELC Food Control
Calculation in 2022 identified that the service required 17.94 FTE Food dedicated
Officers to deal with the full suite of statutory duties including backlogs and after
these backlogs have been addressed requires 11.22 FTE Food Control dedicated
Officers. Regulatory Services currently employ approximately 4.6 FTE in the
Manufacturing Working Group and 7.35 FTE will be applied to food control overall
with the addition of this plan, although 0.7 FTE is presently vacant.  Accordingly,
there is a significant resource deficit even when the current structure is fully staffed. 
The Service requires 5 FTE to deliver manufacturing OCs by dedicated food officers
and is not able to provide this.  Note the figure of 5 excludes food standards because
currently there is no OCV basis for quantifying that demand.  Currently there are 8
vacancies within the existing structure, including 1.6 FTE long term ill-health
absence.   
Accordingly, the Service has and will continue to apply a risk and intelligence-based
approach focussing resources upon areas of highest risk, including high risk FBOs.
Priority will be given to OCV in manufacturing, supply to vulnerable groups
enforcement, investigations and responding to incidents.   
This approach to managing risk through the most effective targeting of available
resources is wholly appropriate in the circumstances, although there is a significant
risk that Food Standards Scotland are likely, through formal audit, to raise another
major non-conformance confirming that the Council does not have sufficient
resources to deliver the full range of statutory requirements of food control. This can
lead to a direction from the Minister that the Council acquires the requisite resources.   
An example of the significant resource issues within the Service occurred in the
recent past where 6 vacancies occurred, including 3 officers who were authorised to
specifically deal with the high risk approved sector. Whilst the Service responded to
this situation appropriately, operational activities took priority and there was little
capacity to undertake “management” related activities including review of policies,
and internal monitoring. This demonstrates the challenges facing the service. This is 
exacerbated by the national shortage of environmental health officers and food
safety officers and this matter is being discussed nationally and reflects the SAFER
approach being taken in Scotland     
3.2 Review   
This plan will operate over a 2-year period from 2023-2025 with an annual
management review and regular performance reporting to the appropriate
Committee.

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4. SERVICE REVIEW – Summarising the Pandemic Period and Project New Start   
4.1 Summary Food Service Plan Review   
The principal achievements through the Pandemic and the Restart of Food Control
have been: 
1. The redeployment of Officers to address the Public Health emergency of the
pandemic in accordance with Scottish Government priorities which led to the
cessation of many Food Control activities. 
2. The Service provided support to the food manufacturing sector and its
personnel by taking a proactive and innovative approach to COVID-19 control
in Food Manufacture which continued to operate during the pandemic and
potentially constituted a vector and threat to wider society. Extensive support
was provided to food businesses during the Covid restrictions to ensure that
could trade safely and to assess changes to food safety management
arrangements which were necessary to comply with restrictions (e.g.
takeaway shops, wet sales premises providing some catering etc.). The
Service worked with the University of Lincoln National Centre for Food
Manufacture and both developed guidance and presented an online seminar
to some 440 FBOs included all the Approved establishments and other major
manufactures located in Argyll. This was very well received. The Service
afterward continued to provide bespoke support within Argyll. 
3. The Service was very actively engaged in the EU Exit transition to new export
arrangements and systems. Leading up to the transition and afterwards the
Service provide intense support for exporting FBOs and has also undertaken
the following:- 
 Established an automated quarterly system for application and issuing
Export Attestations. 
 Issued all EHCs requested on time amounting to 587 in the financial
year 2022-2023 
 Authorised Officers have been supported to qualify on the
DEFRA/APHA register for signing EHC 
 Established systems for providing EHCS for exports to China 
4. All Authorised Officers have been qualified in Advanced HACCP in Food
Manufacturing and in ‘OCV-Lite ‘for Catering and retail. All authorised Officers
except two have been qualified in OCV.      
5. During an application of for Approval to manufacture Biltong the Service
confirmed that the biltong process was not validated which led to a great deal
of research and work in order to produce a process that led to greater than 5-
Log reduction in contaminating bacteria. This led to a Scotland wide review of
standards for Biltong. 
6. The Lead Officer led a SFELC Working Group with the purpose of producing
a system of quantifying the resources that a Service requires to provide all
the statutory requirements for Food Control. This was adopted nationally and
has been operationalised in EXCEL. This has clearly confirmed a significant
deficit of resources at the Service and Scotland-wide.

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7. Restarted our food control arrangements focusing on the approved FBOs
sector and FBOs where intelligence suggested they had deteriorated to
Category B (former Annex 5) or worse during the pandemic. These FBOs
were inspected, and the appropriate interventions were taken.  The service
continued to respond to suspected or confirmed cases of food-borne disease,
complaints relating to food businesses and to the formal food alerts issued by
Food Standards Scotland.      
8. The Service achieved statutory compliance and protected food safety in
accordance with our enforcement policy which seeks to work with business to
secure compliance , and to initiate formal action where there are imminent
risks to food safety ,major or repeated non-compliance or non- cooperation.     
4.2 There has also been unplanned or reactive work which we have had to respond to,
and in some cases, this redeploys resources from our planned activities. These tend
to be high priority as they may relate to national alerts; the need for formal
enforcement action and are necessary to protect food safety and public health. An
example of this work is a national trade withdrawal of fish pate and responding to two
Food Alerts for Action involving non-compliant kebab meat.   
4.3 The Service was unable to deliver in full the food control restart due to resourcing
pressures created by 6 FTE vacancies across the environmental health team. As a
result, a range of actions were taken to manage resources across the whole of the
environmental health service which included a demand reduction exercise for all
environmental health service requests. This was aimed at redirecting resources to
higher risk activities. In respect of food control, the decision was taken to initially
focus on the high risk approved and food manufacturing sector, new business, and a
contractor was employed to carry out general FBO OCs to targeted food businesses.
These challenges continue.    
5. SERVICE PRIORITIES AND WORKPLAN 2023-2025   
5.1 The overarching Regulatory Services Service plan 2023-25 stated the food control
priorities as 
- To secure Committee approval for our Food Control Law Enforcement
Workplan for 2023-2025 (this plan) and implement measures to deliver it. 
- Continue to work with Food Standards Scotland on the review of the
approach to Food Control following the pandemic.  The Service is also
engaged in an emergent national Scottish SAFER project to redesign the
approach to Food Control applying limited resources to maximum effect and
in the longer term to provide assurance in public health protection, with
sufficient and sustainable resources to deliver the required work. 
- Review demand from export food business for export health certification and
attestations to identify resourcing requirements and the financial implications
from new business trading models which are focussing on commercial hubs
established post EU Exit.   
5.2 This service plan details the planned activities and priorities for 2023-2025. These
acknowledge the Services resource deficit, the advent of OCV and FLRS and
anticipate the FSS’s forthcoming SAFER programme. Key themes are Risk Focus,
planned proactive work, the use of intelligence OCV, FLRS and innovation intended
to optimise the effectiveness of Food Control, using scientific methods techniques
and modern technology. These are elaborated below:

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5.2.1 Inspection Programme   
- Recognising the Service’s resource deficit, the key Public Health and
consumer protection priorities of the manufacturing sector and its supply
chains, together with the political, economic/trade, export, reputational and
employment risks of this sector and also informed by and anticipating the
FSS SAFER programme, the inspection programme shall be operated
according to a framework which segments FBOs into three risk categories
i.e., low risk, medium risk and high risk. Within this framework Food Control
will be provided according to different approaches. References is made to
Figure one below. 
Figure One: - Categorisation of the Food Sector and its Food Businesses Operators according to Risk and
Intelligence 
FBOs will be placed into three risk categories and provided with OCs as follows:- 
 High Risk:  A planned and scheduled programme consisting of OCV
inspection cycles shall be applied to these FBOs. The performance target is
that all FBOs will be verified according to OCV with a minimum scope of
verification of all Critical Control Points and Operational Prerequisite
Programmes (OPPs) and a minimum time application of 80% of the resource
calculation according to the SFELC Guidance on OCV within each Inspection
cycle to be scheduled over one fiscal year. The Lead Officer will provide
professional, enforcement and technical support. 
 Medium Risk: -Intelligence – led interventions shall be performed reactively
which may, depending on the outcome, result in the transfer the FBO into the
High-Risk category. The intervention, which shall be an OCV inspection, will

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inform enforcement activity sufficient to restore food safety, consumer
protection and legal compliance 
 Low Risk: Interventions will be carried out, where appropriate, reactively
according to intelligence provided by sources (e.g. police, public, FSS) 
 Statistical sample: - A statistically representative sample of high and
medium risk catering and retailing FBOs will be selected for an OCV
inspection. The results will inform the Service about the state of compliance
of all FBOs within predetermined levels of confidence. This will be reviewed
on an annual basis, and the inspection programme adjusted accordingly      
The High-Risk FBOs will be verified by the Manufacturing OCs Working Group with
a target of 4.6 FTE resources to be allocated to this priority area, according to the
OCV resource calculation.  The Working Group is chaired and led by the Lead
Officer who shall also support the work of the group with responsibility for delivering
the program 
 Status - the second Inspection Cycle began on the 1 April 2023.
 Status – the food intervention plan is ongoing and resources will be
allocated to deliver the revised program 
5.2.2. Listeria Programme   
The service is cognizant of the changes in the FSS and FSA risks assessment of
Listeria monocytogenes in cold smoked fish and fish products, together with Health
Protection Scotland’s position that the current outbreak of Listeria monocytogenes is
due to the vector of imported fish.   
Accordingly, the Service will review the OCV inspection cycles to ensure that Control
Measures for Listeria are effective and the verification of them is also effective.   
 Status - Underway.  Verification of fish suppliers is scheduled by 30
September 2023. The verification of the remaining Control
Measures will be completed by the end of the Inspection cycle i.e.
31 March 2024 
5.2.3 Validation of Unpasteurised Cheese Programme. 
The service is cognizant of the potential for the unpasteurised cheese process to be
invalidated at the Isle of Cheese Company, albeit the FBO and the Specialist
Cheese Makers Association are adamant that it is validated. As part of the
inspection cycle the Service will verify the position on Validation.   
 Status - Inspection cycle began on the 1 September 2023. 
5.2.4  Review of Authorisation 
The Service will review the Authorisations of all Authorised Officers according to
retained (EC) and (EU) Food Law.   
 Status - Target 30 December 2023. 
5.2.5  Schools and Hospitals Food Supply

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In addition to the Inspection Programme outlined above, the Service will provide a
further programme of Official Controls consisting of two elements (i) A programme of
scheduled inspections (‘OCV-Lite’) aimed at Argyll’s schools and hospitals and (ii)
The Lead Officer assessing the Councils Commercial Services Food Safety
Management System and providing support to the schools, the hospitals and for the
Inspecting Officers. 
 Status - Inspection beginning 15 January 2024. 
5.2.6  Scheme of Charging for Non-Compliance 
The Service will consider the ability to develop a scheme of charging for non-
compliance based upon retained EU Food Law in order that compliance is
incentivised and to introduce a fee for enforcement   
 Status – Target 30 June 2024. 
5.2.7  CPD/Training 
The Service will support officers achieving a minimum of 10 hours of CPD in Food
Control to all Authorised Officers. 
Further specific CPD will be provide as follows: - 
REHIS/SEAFISH joint award in the Verification of Bivalve Processing
establishments.       
 Status – Target 1 March 2024 
5.2.8  Support for the Higher Certificate in Food Standards Inspections 
Pursuing FLRS the Service will support two Officers who are actively pursuing the
REHIS Higher Certificate in Food Standards premises Inspection       
 Status - Underway. Target 30 April 2024. 
5.2.9 Sampling Plan 
The Service has developed a sampling plan focussing upon supporting OCV for
verification of FCMSs in high-risk manufacturing FBOs which is cognisant of the
FSS/FSA risk assessment of Listeria monocytogenes. 
 Status – Started - to be completed by 31 March 2024. 
5.2.10 Exports and Attestations 
The Service will continue to issue all export health certificates and attestations
based upon verified legal compliance of FBOs where the requests have been made
with a minimum of 48 hours of working day notice. This is subject to the exigencies
of service.       
 Status – Underway and ongoing 
5.2.11  Innovation – Scientific Methods and Techniques

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The Service is committed to the review of current Methods and Techniques and
further innovation with the purpose of optimising the effectiveness of Food Control,
recognising that a resource deficit demands existing resources are used to
maximum effect. The Service will work within the SFELC/SOCEHS ‘Methods and
Techniques’ Working Group and within the FSS’s SAFER programme.       
 Status –Ongoing and to be completed 30 June 2024. 
5.2.12 Innovation – Remote Delivery Food Control 
The Service will work with the Council’s IT department to operationalise the
appropriate parts of OCV for remote delivery with the intention of reducing the 20%
of FTE that currently has to be devoted to travelling. This time will be recycled back
into Food Control.       
 Status – Target 31 March 2024. 
5.2.13 Innovation – Digital Processing of Documents 
The Service aims to migrate from paper to electronic case records for the receipt
and management of documentation required for Food Control.       
 Status – Target 31 March 2024. 
5.2.14 Innovation – Application of OCV to Catering and Retail FBOs and Improved
Quality Control over the use of Contactors 
The Service will develop an OCV approach suitable for catering and retailing FBOs
and to support the effectiveness and the consistency of the inspection programme
and to enhance the monitoring and the quality control over the use of external
contractors.       
 Status – Target 31 March 2024. 
5.2.15 Innovation – The Use of OCV for Food Authenticity and Integrity/ 
Food Fraud/ Crime 
Pursuing OCV and FLRS the Service will consider contracting with SEAFISH to
provide the REHIS/SEAFISH joint award in the Verification of Food Authenticity and
Integrity and operationalise the appropriate Methods and Techniques.       
 Status – Underway.  Target 31 March 2024. 
5.2.16  Internal Monitoring 
A phased return to internal monitoring consistent with operational demands and
available resources.       
 Target Formal Notices – 15 November 2023
 Verification of one inspection per Officer 31 March 2024.
 Extend internal monitoring and develop 24/25 plan 31 March 2025 


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5.2.17 Service redesign and review food safety delivery arrangements 
A service redesign will review the food control delivery arrangements and lead
officer arrangements 
 Status – 31 March 2024 
5.3 Reactive work arising from a range of sources and may include communicable
disease and food related illness, significant enforcement activity; national and local;
food withdrawals and emerging issues. These reactive demands, along with
planned and proactive work, will be risk assessed. Resources will be allocated in
accordance with the risk assessment outcomes. 
5.4 The longer-term horizon remains currently unclear, pending a number of significant
developments, including the resource deficit within a picture of a severe national
resource deficit, the advent of SAFER, the expansion of OCV, the implementation
of a further revision of the Food Law Code of Practice, and the developing food
crime agenda.   
5.5 Other Service Issues   
The Service will continue to:   
1. Work in partnership with NHS Highland in the investigation of reports of food
communicable disease, and more specifically food-borne illness.      
2. Focus our sampling activity on high-risk locally produced goods.      
3. Work with partners including other local authorities, the business sector and
Food Standards Scotland.      
4. Provide for an effective and appropriate response to Food Alerts and Food
incidents as required and issued by Food Standards Scotland where all
alerts are considered immediately, and appropriate action is taken.    
6. RESOURCES   
6.1 There is no separate food control budget and costs are included within the wider
environmental health budget. Estimated costs for food control are detailed below for
2023/24.   
FOOD
Employee costs £405,000
Training & Resource Materials 2000
Transport & Carriage Costs Included in laboratory costs
IT & communications 1,000
Laboratory costs 15000
Total £423,000

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P a g e | 15  FOOD SERVICE PLAN 2023-25 FINAL 091023 
6.2  Staffing Allocation   
All Enforcement Officers hold the qualifications described in the Food Safety Codes
of Practice for Food Safety and Food Standards under the Council’s Scheme of
Delegation. The Service has an established procedure for the Authorisation of
Enforcement Officers and Appendix II details the specific authorisations for Officers. 
These fall to be reviewed on a regular basis and may change in the course of the
period of the Service Plan.   
Approved Regulatory Services & Building Standards Manager 
Endorsed by Council PPSL Committee 
Regulatory Services & Building Standards Manager, October 2023

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P a g e | 16  FOOD SERVICE PLAN 2023-25 FINAL 091023 
APPENDIX I 
REGULATORY SERVICES
SERVICE CONTACT ARRANGEMENTS 
Contact Arrangements and Details 
Regulatory Services operate the Councils hybrid working model with staff working at home, in the
office, remotely and on site depending on roles and responsibilities. Accordingly, the service cannot
ensure that officers will be available at Council offices unless specific appointments are made in
advance. Service requests and other access to the Service can be initiated by telephone, e-mail or
in person via Customer Service Centres. 
Regulatory Services can be contacted by telephone on 01546 605519 
by email. envhealth@argyll-bute.gov.uk 
Advice and information is available through the Council website www.argyll-bute.gov.uk 
Where a face to face meeting is required , this will be arranged on site, at the following Council
Offices or other suitable locations 
Offices where staff are based: 
EAST Argyll House, Alexandra Parade, Dunoon PA23 8AJ  
Civic Centre, 38 East Clyde Street, Helensburgh G84 7PG   
WEST Municipal Buildings, Albany Street, Oban PA34 4AW  
Kilmory, Lochgilphead PA31 8RT 
Regulatory Services management can be contacted at Kilmory, Lochgilphead, PA31 8RT,
telephone 01546 605519 
Advice and information on Regulatory Services is published on the Council’s website www.argyll-
bute.gov.uk.

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P a g e | 17  FOOD SERVICE PLAN 2023-25 FINAL 091023
APPENDIX II 
FORMAL AUTHORISATIONS AND APPOINTMENTS 
PUBLIC ANALYST, FOOD EXAMINERS, AGRICULTURAL ANALYSTS 
Public Analysts 
In terms of the Food Safety (Sampling and Qualifications) (Scotland) Regulations 2013, the following staff
members hold the Mastership in Chemical Analysis qualifications awarded by the Royal Society of Chemistry
and are eligible for appointment as Public Analysts: 
Gary Walker  Divisional Manager, Head of Community Safety and Regulatory Services
Jane White  Group Manager, Scientific Services 
Food Examiners 
In terms of the Food Safety (Sampling and Qualifications) (Scotland) Regulations 2013, the following staff
members hold academic qualifications listed in Part 1 of Schedule 2 and have attained the minimum three
year experience requirement in the laboratory listed in Part II of the Schedule: 
Gary Walker  Divisional Manager, Head of Community Safety and Regulatory Services
Jane White  Group Manager, Scientific Services
Dawn Neeson  Microbiologist
Alison Aitken  Microbiologist 
Agricultural Analyst 
Under the terms of the Fertilisers (Sampling and Analysis) Regulations 1996, the following staff members,
holding the Mastership in Chemical Analysis awarded by the Royal Society of Chemistry and whose practical
experience as Agricultural Analyst, have been attested, are eligible for appointment as Agricultural Analyst
and Deputy Agricultural Analyst. 
Gary Walker  (Agricultural Analyst) Scientific Services Manager
Jane White  (Deputy Agricultural Analyst) Public Analyst 
Under the terms of the Feed (Sampling and Analysis and Specified Undesirable Substances) (Scotland)
Regulations 2010, the following staff members, holding the Mastership in Chemical Analysis awarded by the
Royal Society of Chemistry and whose practical experience as Agricultural Analyst, has been attested, are
eligible for appointment as Agricultural Analyst or Deputy Agricultural Analyst. 
Gary Walker  (Deputy Agricultural Analyst) Scientific Services Manager
Jane White  (Deputy Agricultural Analyst) Public Analyst 
Food Standards Scotland are now the competent authority for feed and as such have appointed the above
individuals as Deputy Agricultural Analysts for Feed.  Duncan Campbell from Aberdeen Scientific Services is
the Agricultural Analyst for feed. 
Approved Signatories 
Under the laboratory UKAS quality system the following staff members through qualification and experience
are documented authorised signatories for specific sample types: 
Gary Walker  Divisional Manager, Head of Community Safety and Regulatory Services
Jane White  Group Manager, Scientific Services 
Jack Stoddart  Depute Group Manager, Scientific Services
Barbara Kraszewski Chemist
David Arthur  Team Leader
Richard Aitken  Team Leader
Karen Macvicar Chemist

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P a g e | 18  FOOD SERVICE PLAN 2023-25 FINAL 091023 
In terms of the Food Safety (Sampling and Qualifications) (Scotland) Regulations 2013, the following staff
members hold the Mastership in Chemical Analysis qualification awarded by the Royal Society of Chemistry
and are eligible for appointment as Public Analysts: 
Gary Walker  Divisional Manager, Head of Community Safety and Regulatory Services
Jane White  Group Manager, Scientific Services 
Official Control Laboratory Recognition 
The laboratory has been appointed as an official food control laboratory in the UK for both chemical analysis
and microbiological examination.  This can be confirmed by visiting the web site:
https://www.foodstandards.gov.scot/business-and-industry/local-authorities-gateway/official-feed-and-food-
laboratories

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P a g e | 19  FOOD SERVICE PLAN 2023-25 FINAL 091023
APPENDIX III 
ARGYLL AND BUTE COUNCILS AUTHORISED OFFICERS UNDER FOOD SAFETY ACT 1990 
The following Officers are appointed under the Food Hygiene (Scotland) Regulations 2006 in accordance with Regulation (EU) 2017/625 of the
European Parliament and of the Council for the purposes of Community Legislation and retained EC and EU Food Regulations, are
appointed under the Food Safety Act 1990 as “authorised food officer”. Their powers of authorisation vary depending upon qualifications,
experience, post and competency. The undernoted details the specific authorisation levels for Authorised Officers. 
Food Hygiene and Food Standards 
Powers  
Visit, 
access and
inspection   Sampling Seizure and
detention
Service of
Improvement
Notice 
Service of
Temporary
Closure Notice
Service of
Remedial
Action Notice
Approval of
Businesses
Regulation
(EC) 853/2004    
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Alan Morrison
Regulatory
Services and
Building
Standards 
Manager √ √ √ √       N/A  
Andy MacLeod
Lead Officer
Food Control √ √ √ √ √ √ √  √ √ √ √  √ √
Jo Rains
Environmental
Health Officer √ √ √ √ √ √ √
√
√ √ √   
Andy
McClements
Environmental
Health Officer  √ √ √ √ √ √ √
√
√ √ √  √ 
Richard Gorman
Environmental
Health Officer √ √ √ √ √ √ √  √ √ √   
Jacqui Middleton
Environmental
Health
Manager
(West) √ √ √ √

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P a g e | 20  FOOD SERVICE PLAN 2023-25 FINAL 091023 
Powers  
Visit, 
access and
inspection   Sampling Seizure and
detention
Service of
Hygiene/
Improvement/
Food
Standards
Notices
Service of
Temporary
Closure Notice
Service of
Remedial
Action Notice
Service of
Emergency
Prohibition
Notice    
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Adrian Rowe
Regulatory
Services
Officer √ √ √ √ √ √ √  √ √ √ √ √  N/A
Marcillena
MacCuish
Regulatory
Services
Officer √ √ √   √ √ √   √       
Mary Watt
Environmental
Health
Manager
(East)  √ √ √ √ √ √ √ √ √  √   
Patrick Mackie
Environmental
Health Officer √ √ √ √          
Nicole Hamilton
Environmental
Health Officer √ √ √ √ √ √ √ √ √ √ √   
Cameron
McAuley
Environmental
Health Officer √ √ √ √ √ √ √ √ √ √ √   
Sue Stefek
Environmental
Health Officer  √  √  √  √  √  √  √  √  √   √     
Pauline Varley
Environmental
Health Officer √ √ √ √ √ √ √  √  √  √ 
Mark Parry
Environmental
Health Officer  √  √  √  √  √  √  √  √

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P a g e | 21  FOOD SERVICE PLAN 2023-25 FINAL 091023
Powers  
Visit, 
access and
inspection   Sampling Seizure and
detention
Service of
Hygiene/
Improvement/
Food
Standards
Notices
Service of
Temporary
Closure Notice
Service of
Remedial
Action Notice
Service of
Emergency
Prohibition
Notice    
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Hygiene
Standards
Ian Campbell
Regulatory
Services
Officer √ √ √ √          
Katie McNair
Technical
Officer  √ √ √ √          
Gemma Rae
Technical
Officer √ √ √ √          
Karen Goodchild
Technical
Officer √ √ √ √          
David Kerr
Senior Animal
Health and
Welfare Officer √ √ √ √          
Graeme Pirie
Animal Health
and Welfare
Officer √ √ √ √          
Jacklyn Sinclair
EH
Enforcement
Officer √ √ √ √