Regulatory Services Service plan 2023-25
Argyll and Bute Council · 21 June 2023
Back to Planning, Protective Services and Licensing Committee — 21 June 2023 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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Appendix 1 ARGYLL AND BUTE COUNCIL REGULATORY SERVICES SERVICE PLAN 2023-2025
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Background and Context Purpose, Timeframe and monitoring 1.1 The Councils Regulatory Services provides regulatory and advice functions within Argyll and Bute Council and delivers a range of statutory duties placed on the Council. This Operational Plan outlines the wide range of services provided within the Regulatory Services banner, our achievements, performance and priorities for the period 2023-25. The plan forms an important part of the Service’s processes to deliver national and local priorities and standards within available resources and working with our partners, stakeholders and customers. 1.2 The plan aligns with the Council’s vision of being ambitious, sustainable and connected, the Council’s Corporate Plan and the Communities and Place Directorate Service Plan. Structure and resources 2.1 Regulatory Services has an full-time establishment of 40.6 Full Time Equivalent (FTE) with a revenue budget of £1,803,198 .The service operates from four geographical areas although staff operate as a virtual team targeting resources to the public health and service priorities 2.2 The different component part of Regulatory Services are environmental health, animal health and welfare, licensing standards and short-term let licensing. Roles and responsibilities 3.1 Regulatory Services consists of the multifaceted areas of environmental health, animal health and welfare, licensing standards and short-term let licensing. These statutory services aim to protect public health and public safety and secure compliance with legislation and standards. Environmental Health is the branch of public health which deals with all aspects of the natural and built environment that may affect public health, together with animal welfare and licensing duties. The main functions include: Public Health Protection which includes Water supplies (private supplies and mains water issues e.g. lead), Nuisances, Smoking in Public Places, Port Health, Communicable disease investigation e.g. Food-borne / Waterborne disease, Covid 19, Legionnaires Disease; Food Safety/Control covering enforcement and advisory roles for food hygiene, food standards, labelling, export certification, and imported food checks; Health and Safety at work including enforcement role in Local Authority enforced premises, topic based projects, accident at work investigations, business advice and complaint investigations; Pollution Control which includes Noise Control and Local Air Quality management; Contaminated Land covering the regulatory role for contaminated land prevention through development control, advisory role to other council services on asset transfer and development; Private Water Supplies –the monitoring and improvement of private water supplies, together with providing improvement grants to improve the quality of drinking water; Private Landlord Registration – the registration of properties and landlords who provide accommodation to the private let sector;
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Environmental Health Licensing – the determination and enforcement of activities/businesses which fall within a statutory licensing regime. These include the licensing of caravan sites, venison dealers, animal boarding establishments, zoos, cinemas, riding establishments, dangerous wild animals, pet selling, operating certain animal welfare establishments (including rehoming centres and animal sanctuaries), engaging in other animal rehoming activities and dog, cat and rabbit breeding; and houses in multiple occupation; Animal Health & Welfare which the inspection of markets and farms from an animal health and welfare perspective, the investigation of animal disease including avian influenza , rabies, & Mouth disease, Anthrax, Avian Flu, Bluetongue and Imported Pets; and the enforcement of the Animal Health (Scotland() Act and associated legislation. of animal by-products. Licensing Standards role is to provide guidance, ensure compliance with the Licensing (Scotland) Act 2025 and offer mediation in licensing disputes. Short-term Let Licensing is a new statutory licensing regime which came into effect on the 1 October 2022 with the aim of licensing accommodation which is available for short-term let, principally for holiday purposes. Assisting with Civil contingencies and emergency planning, with specific responsibilities regarding recovery from incidents. 3.2 Much of the work is preventative and the team has an important role in ensuring a safe and healthy place in which to live, work and holiday. We aim to support local businesses by providing advice on appropriate regulations and ensuring any regulatory activity follows the five principles of better regulation: Proportionate, Consistent, Accountable, Transparent and Targeted. Our 4E’s enforcement policy, comprising of Engage, Educate, Encourage and Enforcement, was very effective in our response to the Covid pandemic. This secures compliance through a range of measures with formal enforcement used for issues where there is major non-compliance, lack of cooperation or where there are significant risks to public health or safety. Demands 4.1 Service workload can be categorised as proactive (programmable) work and reactive work (unplanned). Proactive work includes interventions and inspections of businesses for food safety, health and safety, environmental protection and licensing functions. Reactive work includes service requests from the public, businesses, responding to incidents or outbreaks, initiating formal enforcement action following planned interventions, new duties or demands from national regulators (Food Standards Scotland, Health and Safety Executive, Scottish Government etc) and consultations from other services (e.g. planning, civic government etc). 4.2 Managing the service resource is challenging as reactive workload is met by reallocating resources from planned activity. Professional Officers manage these conflicts on a daily basis, but the increase in reactive work allied with depleted resources due to recruitment difficulties and higher customer expectations, results in less time being allocated to planned activities. To combat this, a demand reduction exercise was undertaken in an attempt to find new ways of responding to reactive work and release more time to planned activities. Whilst helpful, insufficient time is allocated to planned activities.
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4.3 Proactive work The team carry out proactive/programmable work under certain legislation. The work is risk based and intelligence driven. Often specific proactive work is carried out in Partnership with other agencies such as Police Scotland, Scottish Fire and Rescue Service, HSE, SEPA, and Home Office Immigration Enforcement. A summary of the some of the proactive demands is provided below. Food Safety Responsible as statutory Food Authority for approximately 2493 food businesses in Argyll and Bute which includes a very significant (3rd highest in Scotland) approved food businesses which manufacturing premises and exporters. There are insufficient resources to meet the Food Code of Practice and resources are allocated to the highest risk sector and on an intelligence, and incident focussed basis. Private Water Supplies In Argyll and Bute, there are 3,322 private water supplies serving a population of 28,034. There are currently 522 “Regulated” supplies (commercial or large private water supplies) that are registered and subject to mandatory risk assessment and monitoring and intervention by the Council, and a further 233 have bene identified. The regulated supplies and subject to a proactive monitoring program to ensure each supply is visited annually, or more frequently as required by statute, to monitoring drinking water quality against required standards. Where they fail, advice is issued to protect public health (e.g. boil water notices, alternative bottled water) and specific advice on improvements. New treatment can be supported through the Councils private water supply improvement grant which is delivered by the team. There are also 2800 domestic smaller private water supplies registered whereby our duty is to offer advice and assistance and discretionary powers in respect of sampling. These supplies serve an estimated population of 12,212. Health & Safety at Work Enforcement of health and safety at work legislation is divided between the Health and Safety Executive and local authorities. HSE is responsible for workplaces including factories, farms, building sites, schools, hospitals and offshore installations. The Council cover businesses including offices, shops, hotels, leisure premises, caterers, nurseries and clubs. In Argyll and Bute the Environmental Health team have responsibility for enforcement in over 3500 businesses. In line with national guidance proactive work is carried out based on the HSE identified priorities for targeted interventions. These are focussed on those sectors and activities with the most serious risks or where the risks are least well-controlled based on national statistics and local intelligence. Initiatives have looked at gas safety in commercial catering premises, swimming pools and spas, risk of infection at animal petting farms, and nail bars. Public Health The Joint Health Protection Plan 2023/25 outlines a range of national and local priorities designed to protect public health and the effective management and control of public health incidents or diseases. This work largely goes unnoticed, other than during a major outbreak
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or incident where the investigation and control of disease is paramount, and came to the forefront during the Covid pandemic. Day-to-day work is undertaken principally by Environmental Health in the Local Authorities and with colleagues in partner agencies including the Health Protection team in NHS Highland. The Plan seeks to ensure that the standards defined by statute, or expected by society are met, namely that food is safe to eat from commercial premises, that water is safe to drink, that air is safe to breathe, that workplaces and other facilities/attractions (e.g. leisure facilities etc.) are safe to use and that we have a good and healthy environment. Animal Health and Welfare Officers carry out proactive inspections of animal markets and other sales, and Assembly Centres to ensure compliance, in particular with biosecurity (vehicles, premises and people), livestock identification, welfare, transport, licensing and record keeping. Around 140 inspections are carried out per year. The team also investigate allegations of illegally imported pets from both the EU and third countries and respond to animal disease incidents, including avian influenza Local Air Quality Management Officers fulfil the Councils duties in terms of the requirements of Local Air Quality Management (LAQM) as set out in Part IV of the Environment Act 1995 and the relevant Policy and Technical Guidance documents. The LAQM process places an obligation on all local authorities to regularly review and assess air quality in their areas, and to determine whether or not the air quality objectives are likely to be achieved. An Annual Progress Report (APR) is prepared and submitted to Scottish Government. Local air quality in Argyll and Bute is good and there are no Local Air Quality Action Areas in place. 4.4 Reactive work 4.4.1 The team deal with significant number of incidents and major investigations in addition to the more routine service requests from the public and businesses. The numbers of requests have been generally increasing year on year, with an unusually high number of service requests in 21/22 being associated with Covid related workload. Customer expectations are increasing and there is also an increase in formal Stage and stage 2 corporate complaints Year 2020/21 2021/22 2022/23 Total requests 3195 3909 3110 The table below provides examples of the range of service requests received by the team in a year (based on 2022/23 data). Category count Category count Animal Health & Welfare 158 Noise complaint 220 Food related complaints and enquiries 311 Public Health complaints 340 Health and safety at Work enquiries/complaints 90 Ukraine Refugee enquiry/Property Check 55
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Health and safety reported accidents, injuries and disease 36 Approval/Licence/Authorisations application 7 Drinking water related enquiries/complaints, requests for assistance 290 Food safety Alert/FSS reports 54 Export Health Certificates 587 Pests 70 EH licensing enquiries and complaints 64 FOI requests 123 Licensing Standards - consultations 860 Consultations- planning, civil government/liquor licencing 956 NEW (not included in total service requests) Short-term let enquiries 743 Short-term let applications 334 4.4.2 Significant incidents can take considerable time to investigate and conclude as often complex issues involved. For example, a prosecution can take the equivalent of 4-6 weeks of one officer’s time to investigate including interviewing witnesses and then to prepare a detailed case for the Procurator Fiscal. In the last year, number of cases were reported to the Procurator Fiscal for offences under animal health, and health & safety legislation. The health & safety cases have followed investigations of fatalities or serious accidents. Of highlight are: Successful prosecution relating to an investigation into a fatality at Loch Awe involving a boat hire company and offences under the Health and Safety etc Act 1974. The company pled guilty and fined a total of £10,000. A fiscal warning was issued relating to a case within a food business where an employee received severe burns whilst working with equipment. Case submitted relating to offences under the Animal Health and Welfare (Scotland) Act 2006 for keeping animals in a way likely to cause unnecessary suffering and causing unnecessary suffering. Accused pled guilty. 5 Risk Management 5.1 The team manages significant risks in relation to the consequences of serious communicable, foodborne or waterborne disease outbreak. This is identified in the Service Risk Register. 6 Reporting and performance 6.1 Regulatory Services require to provide a range of statutory performance reports to arrange of statutory regulators detailing the work undertaken in the previous year. These include the Health and Safety Executive, Drinking Water Quality Regulator, Food Standards Scotland and Scottish Government. In addition there are two key performance measures which are reported corporately. Performance for 2022/23 compared to previous years is as follows:
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Measure Targe t (%) 202 0/21 202 1/22 202 2/23 Comments Percentage of service requests resolved within 20 working days. 80% 87 % 80 % 76 % Performance affected by vacancies in team Percentage of high risk inspections/interventions completed 95% N/A N/A 85 % Performance affected by vacancies in team 7 Achievements in 2022/23 7.1 It’s been a challenging year in 2022/23 restarting services post Covid, dealing with recruitment difficulties where at one point, the team were without 6FTE posts, and with new duties. Key achievements to highlight are: Restarted our official food control program post Covid. This involved risk rating all 2493 food businesses against a new national risk rating system developing and implementing a formal interventions program. This has been successful although adjustments were made to focus on the high risk manufacturing sector, as a result of 2 FTE Environmental Health Officer vacancies Reinstated all services post Covid Completed a demand reduction exercise to evaluate alternative ways of responding to an increasing number of service requests and to release resource to focus on planned and other activities The UK outbreak of avian influenza in 2022/23 resulted in large number of outbreaks across the UK and measures to control the spread of diseases from wild birds to commercial/domestic poultry, and in the event of outbreaks, to other premises keeping poultry. Whilst there were no confirmed outbreak in Argyll and Bute, a significant amount of work was undertaken to support and inform poultry keepers, enforce the national restrictions and minimise the risks from a significant amount of wild bird carcases which were being washed onto the shorelines of Argyll, and Bute. Supported a wide range of safe and successful events which were organised post pandemic, including the Tiree Music Festival , to ensure that they were managed safely Successful prosecution relating to an investigation into a fatality at Loch Awe involving a boat hire company and offences under the Health and Safety etc Act 1974. The company pled guilty and fined a total of £10,000. Introduced support to users of private water supplies experiencing water scarcity, as required by Scottish Government Councils had a statutory duty to introduce a new short term let licensing regime by the 1 October 2022. This was very challenging and required the development of a scheme, public consultation, and formal approval within a 5 month period. This was achieved and on the 29 September 2022, Argyll and Bute Council formally approved its short term let licensing regime and policy. This work also included the development of an in-house information management system which was able to receive on-line applications from hosts
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A Short-term let licensing team was established within Regulatory Services to deliver the licensing regime. The team was not fully recruited until March 2023 and in the interim, work was carried out by the existing environmental health team, focusing on provision of advice for all and processing of new host applications Working with Housing Services, responded to the challenges of the Ukrainian Resettlement program and undertook the inspection of properties which were intending to host Ukrainians to ensure that the accommodation was safe with adequate facilities. 8 Priorities and Objectives 23/25 8.1 The period of this plan, 2023-25, will be particularly difficult with increasing and new demands, allied with the financial challenges facing local authorities and the national recruitment issues affecting environmental health and other local government professions. Notwithstanding this, service priorities have been identified for 2023-25 (see Appendix 1) to be delivered, subject to available resource. Progress will be reviewed and reported on. Regulatory Services and Building Standards Manager 12 June 2023 APPENDIX 1: REGULATORY SERVICES PRIORITIES 2023-25 Argyll and Bute Council Regulatory Services Plan 2023-24/25 1. General management 1.1 Continue general review of approach to work to improve effectiveness and efficiency (redesign). Including: a. Service Management: To recruit an Environmental Health Manager (West) and build a new management team. b. Workforce planning: Continued focus on workforce planning and how to recruit, retain and develop our own workforce to combat the national shortage of environmental health and other regulatory professional staff c. Service redesign. Complete the redesign of regulatory services to provide a service reflecting available resources, support succession planning, workforce development; demand management, and appropriate to meet future challenges d. Performance: Review and develop improved methods of monitoring performance across all areas of work as part of the development of the performance framework, linked to resources; e. Supporting Procedures: Clear & consistent work procedures to improve efficiency and avoid duplication of effort; f. ICT & Business Support: Continual improvement in use of digital technology to reduce administrative burdens and free up officer resources (e.g. MS365; remote inspections will reduce travelling etc) through better use of digital technology. Specific projects include the migration of electronic document management system, better use of MS365, continued transfer from paper-based or site-specific files to electronic documents;
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g. Officer Development: build capacity by improving learning and development process for officers; and the successful training of graduate environmental health officers and authorised food safety officers h. Outcomes: Continue to demonstrate benefits and improve profile of work undertaken with greater use of opportunities of case management system reporting. i. Savings & Income: Increase income & identify further commercial opportunities and savings as part of Councils financial strategy j. Where resource permits, work with other Council teams and external housing organisations/partners (e.g. Under One Roof, Shelter, Building Standards, Housing etc) to provide opportunities to engage with homeowners and landlords on housing standards and signpost to available support 2. Health & Safety at work 2.1 To develop and deliver our Health and Safety Law Enforcement Workplan 2023-25. 2.2 To devise and deliver a programme of health and safety interventions based upon Local Authority Circular (LAC67/2) (rev12), and the list of national priorities published by the HSE. The programme shall consist of work to deliver those national priorities set by HSE, work to deliver local priorities and an inspection programme that meets the requirements of the National Local Authority Enforcement Code. All pro-active health and safety work is targeted in accordance with the HSE priorities or where local intelligence identifies any health and safety related issue. 2.3 To resource and provide an effective response to serious work-related incidents, including, where necessary, preparing and submitting reports to the Crown Office Procurator Fiscal Service. 2.4 To provide appropriate advice and information to employers and other duty-holders on securing the health, safety and welfare at work of their employees and the health and safety of other persons affected by the conduct of their undertakings. 2.5 To maintain the competence of the appointed health and safety inspectors to identify and intervene on matters of evident concern when undertaking other regulatory visits to premises. 2.6 Key projects include: Building safety hazards arising from fragile roofs and unsafe shop signs; Infection hazards from animal contact in the commercial leisure sector; Safety of inflatable amusement devices; Gas safety in catering premises; Carbon monoxide from solid fuel catering appliances; and Legionella control in spa pools in commercial use. 3. Licensing enforcement and administration 3.1 To deliver the licensing scheme for short term let accommodation. 3.2 To review the arrangements for maintain a public register for all licences administered by Regulatory Services and develop a new suite of on-line public registers for all such licences 3.3 To complete the review of all Council licensing functions with the aim of improving their effectiveness and identify any efficiencies. 4. Private Water Supplies 4.1 Review the charging fees for private water supply related work. 4.2 Continue to use a risk-based system approach to the prioritising of the PWS monitoring and refocusing our risk assessment programme on regulated/commercial supplies
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4.3 Deliver the PWS Improvement Action plan which was developed to address the outcomes of the DWQR Supervisory visit in 2022 4.4 The impact of legislative changes in 2017 and statutory obligations on the Council to monitor and regulate private water supplies is its area has placed additional workload and resource requirements on the team. A review of workload and resources to be completed in 2023 to identify the resources needed to meet our obligations and provide a sustainable workforce going forward. 4.5 Continue to work in partnership with NHS Highlands concerning reports of illness with links to PWS. 4.6 Advise, educate and promote the private water supply grant funding scheme so that supplies are improved to provider safer drinking water. 4.7 Review the Council’s PWS Grant Policy to look at the eligibility criteria for hardship and consider enhanced funding for supplies that experience prolonged water scarcity and/or lead contamination 4.8 4.9 Complete digitisation of all PWS paper files onto the environmental health electronic document management system. Review the existing PWS registers to enable production of a single Register, and update PWS layers on GIS to reflect properties served and NGR types. Review and refresh understanding of lead in PWS failure protocol 5. Food Control 5.1 To secure Committee approval for our Food Law Enforcement Workplan for 2023-2025 and implement measures to deliver it. 5.2 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 Authorities Food Enforcement Rebuild (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. The review may include a new approach to publication of inspection information. 5.3 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. 5.4 Food Control – Inspection Priorities It must be noted that investigations, or enforcement action, significant to public health will take priority over the targets specified below. Priority 1: High Risk Food Program To undertake Official Control Verification completing verification of all *Critical Control Points, *Operational Prerequisite Programmes, *Traceability, *Authenticity and *Integrity arrangements within all Approved and other High-Risk Food Business Operators. (Target 95%) Priority 2: Mid-range Risk Food Program (Intelligence Informed) To establish on the basis of intelligence an inspection programme applied to medium risk Food Business operators which may require a formal intervention and integrate them into an inspection program to be carried out by authorised officers of the Council or appointed contractor. Priority 3 Mid-Range Food Programme (Assurance Informed) To establish based on representative and randomised sampling an inspection programme applied to medium risk Food Business Operators which may require a formal intervention and to integrate them into an inspection program to be carried out by authorised officers of the Council or appointed contractors and which will provide on the
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basis of a sample of FBOs an indication of the state of compliance of all FBOs under the Council’s jurisdiction. Priority 4: Low Risk & Unrated Food Business Operators (Intelligence Driven) Ensure that all low risk and unrated or new food hygiene premises are allocated with an appropriate risk and intervention. 5.5 Continue to engage with partners in Scottish Government and Industry to ensure EH Service is structured and financed to best facilitate the needs of the export market and appropriate arrangements are in place for imported food.. 5.6 Deliver a Food Sampling plan focussed upon the Official verification of High Risk FBOs. 6. General Public Health Protection 6.1 Implement and deliver the priorities defined in the Joint Health Protection Plan 23/25, working in conjunction with other partners and through our statutory work. 6.2 Assess the adequacy of public health controls at airports and ports across Argyll and Bute 6.3 Review the Councils temporary mortuary arrangements in Tiree to identify whether there is a continued need to provide this facility 6.4 Review and update of all risk assessments in regard of Blue Green Algae (BGA) affected water bodies and update as appropriate. Review of effectiveness of the 2022 project that used semi-permanent signage as a route to inform the public more widely of issues relating to BGA 7. Environmental Protection 7.1 Local Air Quality Management: Continue to monitor and review nitrogen dioxide levels at locations where members of the public might be regularly exposed and where there is the potential for poor air quality as a result of traffic emissions a. Prepare and submit the Annual Progress Report to the Scottish Government b. Establish a strategic approach to LAQM c. Respond to concerns and enquiries regarding local air quality impacts d. Continue to highlight potential air quality impact within Planning and Development control e. Review Air Quality impact reports submitted to support planning applications f. Participate in National initiatives to improve air quality 7.2 Land Contamination a. Continue to liaise within Development Management to ensure land contamination issues are appropriately considered b. Review weekly planning lists for developments with potential land contamination issues c. Review land contamination investigation and assessment reports submitted to support redevelopment d. Update and improve information on historic land use; creation of a potentially contaminated land database (GIS layer) e. Liaise with developers or their agents regarding potential land contamination as early in the development process as possible f. Continue to liaise with SEPA regarding water environment impact and assessment g. Respond to concerns and enquiries regarding land contamination h. Consider potential land contamination concerns in terms of formal Part IIA investigation i. Review the Council’s Contaminated Land Strategy
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j. Maintain the Council’s Contaminated Land Register k. Participate in National initiatives to address historic land contamination 7.3 General Environmental Protection a. Liaise with and support environmental health on issues such as burning, environmental noise, vibration, dust, vapours b. Support Service Management Team on National environmental issues such as relevant National consultations and preparation of briefing notes on National initiatives (e.g. Deposit return scheme) c. Support Service Management Team on local environmental issues such as Health Protection, Energy and Renewables, Pollution incidents d. Liaise with GSS and SEPA on the investigation and monitoring of pollution incidents and complaints (e.g. vapour, fumes and fuel leaks) 8. Short-term let licencing a. Deliver and promote the short-term let licensing scheme across Argyll and Bute Council and determine all applications for licence b. Review and develop procedures and systems relating to the licensing scheme c. Effective engagement with hosts, consultee, stakeholders and other agencies (e.g. Association of Scottish Self Caterers, Wild Argyll etc.) d. Support the work of the Council and Loch Lomond and the Trossachs National Park to consider the need for Short Term Let Planning Control Areas. 9. Private landlord registration a. To determine applications for renewal or new private landlord registration applications b. To provide advice and assistance to landlords seeking to register, and tenants raising concerns, in respect of the operation of the scheme and signpost to additional assistance as appropriate. c. Develop a procedure for ensuring complaints regarding private lets are investigated and actioned appropriately including the ability to make reports to the first-tier tribunal and design of a tenant's information pack/leaflet for circumstances where our direct intervention isn’t appropriate d. Investigate unregistered landlords and those with incomplete registrations in order to ensure compliance. Take enforcement action as appropriate against those who are noncompliant, including refusal of registration application referrals to Housing and Property Chamber. 10. Licensing Standards (Liquor) a. To deliver the Argyll and Bute Councils Licensing Standards Workplan for 23-25 b. Take appropriate action(s) in response of service requests and applications for new licences, renewals and for occasion and extended hours. c. Support the work of Safety Advisory Groups to secure safe and successful events. 11. Animal Health and Welfare a. The proportionate and effectiveness enforcement of animal health and welfare across Argyll and Bute to secure compliance. b. Working with stakeholders, deliver the Councils Animal Health and Welfare Framework Service Plan for 23-25 c. Continue to maintain an overview of the potential impact of the proposed new Scottish Veterinary Service on animal health and welfare services within local
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authorities. d. Provide support, through advice and enforcement, to agricultural industry and wider communities on animal disease issues, including avian influenza e. Review the Councils animal health disease outbreak plans and arrangements to improve our level of preparedness. Performance targets Performance measure Target 2023/24 Measure 1 Percentage of service requests resolved within 20 working days. 75% Measure 2 Percentage of high risk inspections/interventions completed 90%