Item 12 - Food Enforcement Service Plan 2024-2025
West Dunbartonshire Council · 6 November 2024
Back to Corporate Services Committee — 6 November 2024 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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WEST DUNBARTONSHIRE COUNCIL Report by the - Chief Officer of Regulatory and Regeneration Corporate Services Committee 6 Nov 2024 ____________________________________________________________________________ Subject: Food Enforcement Service Plan 2024/2025 1. Purpose 1.1 To seek Committee approval of the Food Enforcement Service Plan 2024/2025. (Appendix 1). 2. Recommendations 2.1 It is recommended that the committee approve the Food Enforcement Service Plan 2024/2025 3. Background 3.1 The Food Law Code of Practice requires that each Food Authority must complete an annual Food Enforcement Service Plan which details their food enforcement interventions programme for the coming year. Such a programme requires to be adequately resourced and the Food Enforcement Service Plan requires to be subject to approval at the appropriate governance level within each Local Authority. 3.2 Local Authority delivery of Food Law and Official Controls is an essential part of Scotland’s infrastructure for Public Health protection. The Food Law Code of Practice sets out how Food Standards Scotland and Local Authorities will work in partnership to discharge their statutory duties and help maintain consumer confidence in the regulation of the food supply chain in Scotland. 4. Main Issues 4.1 The Environmental Health Service’s Food Enforcement Service Plan 2024/25 describes how the food enforcement service is discharged and details the numbers, types and priority ratings of the Council’s food premises, the frequency of planned interventions, sampling programmes, reactive work, including responding to food complaints, food hazard warnings and investigation of infectious diseases. The plan contains information on proposals for the undertaking of the Environmental Health Service’s statutory duties in 2024/25 4.2 In common with a number of other professional groups in local government there are significant issues with the recruitment and training of Environmental Health Officers. This has led to a focus from Food Standards Scotland on the ability of Councils to carry out their obligations under the Code of Practice with some authorities which have significant staffing issues receiving red ratings in audits. This is not currently an issue in West Dunbartonshire, however the last Food Standards Scotland audit was carried out in 2018. 4.3 The Food Enforcement Service Plan helps protect public health in West Dunbartonshire. It is important that Council documents are as accessible as possible and the Council's Communication Effectively Guidance has been followed. ITEM 12
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5. People Implications 5.1 There are no personnel issues. 6. Financial Implications 6.1 There are no financial implications 7. Risk Analysis 7.1 Failure to approve the Food Enforcement Service Plan for 2024/25 would be deemed to be non-compliant with the Code of Practice requirements. 8. Equalities Impact 8.1 EIA 1067: The proposal has been equality impact assessed and should have positive impact in terms of protecting public health. 9. Conclusion 9.1 The Food Enforcement Service Plan 2024/25 requires to be approved to ensure compliance with the Food Law Code of Practice (Scotland) - 2019 Alan Douglas Chief Officer - Regulatory & Regeneration Date: ________________________________________________________________ Person to Contact: Eilidh Paton, Interim Service Co-ordinator Food Business Group, 16 Church Street, Dumbarton, G82 1QL, Telephone: 0141 951 7983, Email: eilidh.paton@west-dunbarton.gov.uk Appendices: Appendix 1- Food enforcement Service Plan 2024-2025 Appendix 2- Equality Impact Assessment Background Papers: Food Law Code of Practice (Scotland) - 2019 Wards Affected: All
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West Dunbartonshire Council Environmental Health Food Service Plan 2024 - 2025 C
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Contents Section 1 – Introduction Service Role 2 Service Aims & Objectives 3 Organisational Structure 4 Specialist Services 5 Food Standards Scotland (FSS) 5 Scope of the Food Service 5 Demands on the Food Service 6 Enforcement Policy 6 Section 2 – Service Provision Service Delivery 7 Review of 2023/24 Activities 7 Sampling Activities and Service Requests 8 Food Fraud 9 Communicable Disease Investigation 9 Eatsafe Scheme 9 Food Hygiene Information Scheme 10 Food Export Certification 10 Food Safety Promotion 10 Food Premises Inspections 10-11 Future Actions 2024-2025 12 Page 1
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Section 1 – Introduction Service Role The Environmental Health Service administers West Dunbartonshire’s Council’s statutory functions in respect of a wide range of Environmental Health and associated legislation. This includes Food Safety; Health and Safety at Work; Environmental Protection and Public Health. Additionally the Service delivers a range of non-statutory functions, including advice to local businesses, food hygiene training to other council services; public information and sampling and Pest Control Services. The service continues to provide a co-ordinated response working with other service teams such as licensing, fraud, trading standards and asset management. In planning the service delivery for 2024-2025, consideration has been made of both existing and new functions. A set of performance indicators has been developed to reflect the functions of the service. These will be reported via the Pentana system – the Council’s performance management system.
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Service Aims & Objectives Within the Environmental Health Service the Food and Business Group delivers the statutory food safety functions on behalf of West Dunbartonshire Council The aim of West Dunbartonshire Council Food and Business Group is to strive through the application and maintenance of adequate human, technological and physical resources to ensure that food and drink intended for human consumption, which is produced, stored, distributed, handled, prepared, labelled, or consumed within the West Dunbartonshire area complies with the requirements of the Food Safety Act 1990, European Food Regulation and is safe for the consumer. This will be achieved through a combination of: • Risk based programmes of inspections covering all food business in the Council area; • Risk based food sampling programmes in line with the revised and consolidated Food Law Code of Practice 2019 and associated guidance; • Open and transparent engagement with local businesses to encourage, through education and advice, compliance with food safety legislation; • Investigation of food complaints and dealing with enquiries relating to food business operations; which are received by or referred to the Council Food and Business Group- • Management and processing of approvals, certificates, registrations and the professional assessment of compliance with standards in relation to food business operation; • Engagement and participation in projects, surveys and campaigns to improve food law delivery and raise awareness of food law and related matters and to highlight current issues of note to communities; • Continued development of service provision in line with Food Standards Scotland (FSS) Guidance [including the E. Coli O157 - Control of Cross-Contamination - Guidance for food business operators and enforcement authorities], The Regulatory Reform (Scotland) Act 2014, The Scottish Regulators Strategic Code of Practice, and the Food Law Code of Practice (Scotland) 2019 and associated guidance and participation in the workings of the Scottish Food Enforcement Liaison Committee and projects that evolve, risk management and consistency in food law delivery;. • Continued engagement with internal and external community and national partners to promote fairness, consistency, equality, health protection, improvement and best practice in food law service provision. Page 2
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Page 3 Organisational Structure Council Structure Eilidh Paton, Interim Food & Business Co-ordinator, retains responsibility for the Food and Business Group and is the Lead Officer under Regulation (EC)882/2004, the Food Law Code of Practice (Scotland) and the Framework Agreement on Official Feed and Food Controls for the delivery of the food service. The Principal Officer for Environmental Health has overall responsibility for the management of the Service and reports directly to the Planning, Building Standards & Environmental Health Manager. Food Law Service issues are reported to the Corporate Services Committee. Within the Food and Business Group, there are 5.60 full time equivalent (FTE) Environmental Health Officers, including the Service Co-ordinator, with 3.03 FTE attributed to food law work. The FTE figure was reduced in August 2023 due to maternity leave and there was a further temporary reduction in staffing levels in the last quarter of the 2023-2024 financial year. A study carried out in 2021 into resources identified a deficit of 2.39 FTE. Recruitment to fill these vacancies in 2022 was unsuccessful and these vacancies have since been deleted as part of the Council’s budget savings exercise in December 2022. The service structure incorporating the Food and Business Group is detailed in Annex 1. The Service structure is currently under review, with the removal of one Service Co- ordinator, therefore the team structures within the Environmental Health Service will require to be adjusted to manage this reduction.
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Annex 1 Team Service Structure Plan Page 4 Chief Officer Regulatory & Regeneration Acting Principal Officer & Co-ordinator Food, Business, Pest Contro & Dog Control Co-ordinator Environmental & Community Health Protection Planning, Building Standards & Environmental Health Manager
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Specialist Services Glasgow Scientific Services (GSS) provides the analytical services and microbiological services for the food authority in addition to being the appointed Food Examiner for West Dunbartonshire. Glasgow Scientific Services is also designated Agricultural Analyst under the Agriculture Act 1970 for feed samples. Food Standards Scotland (FSS) Food Standards Scotland (FSS) incepted on 1st April 2015 and is a competent Food Authority established under the Food (Scotland) Act 2015. It provides advice, guidance and audit function to Local Authorities including this Council which is itself a competent Food Authority. From 1 April 2021, FSS became responsible for carrying out official controls (this includes sampling and inspections) and enforcement of feed law. The Feed (Transfer of Functions) (Miscellaneous Amendments) (Scotland) Regulations 2020 transferred competence for feed law functions from local authorities to FSS, and provides the power to delegate functions to a qualifying third party. The Council’s Trading Standards team are one of those included. Scope of the Food Service The Food and Business Group has, in addition to its non-food statutory regulatory responsibilities, responsibility for all areas of food safety and food standards regulation, referred to as ‘Food Law’. This includes food sampling and the investigation and management of communicable disease in liaison with NHS Greater Glasgow and Clyde public health partners. Food law Inspections of, and other interventions at, all food businesses are based on assessment of risk in compliance with The Council’s procedures and the Food Law Code of Practice 2015 issued under Section 40 of the Act. Guidance for food authorities and food business operators on controlling the risks of cross contamination from E. coli O157 continues to be significant feature of risk based inspections and other interventions. Cross contamination controls continue to be identified and shortfalls in compliance dealt with according to the risk identified. The full range of risk profile food businesses in West Dunbartonshire are currently subject to inspection according to their risk profile. For food businesses identified as requiring improvement, enforcement action related to risk will continue to be taken to protect the health and wellbeing of anyone (residents, visitors or others) in West Dunbartonshire who may be exposed to the unmanaged risk of cross contamination or other risks through consumption of food produced or sold in West Dunbartonshire. In addition to enforcement, advice to business forms an integral part of the Service strategy. A Civica APP Flare based software system is used to manage all aspects of regulatory services including the food inspection programme. Inspections, interventions, sampling, complaint or incident investigations etc., are undertaken by Environmental Health Officers. The Food and Business Group also enforce laws encompassing health and safety, smoking in public places and private water supplies for Food Businesses as well as the professional standards elements of licensing e.g. licensing standards, skin piercing and tattooists, pet shops, zoos, animal boarding, riding schools, cinemas, caravan sites, and venison dealers. Page 5
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Demands on the Food Service The Interventions Code came into force across Scotland on the 26 June 2019 and supersedes certain sections of the consolidated Food Law Code of Practice 2019. Compliance with the code was suspended on 23 March 2020 creating an ongoing backlog of interventions while resource was diverted to pandemic response. In 2021, in anticipation of a foreseeable end to pandemic response, a Food Law restart plan for Scotland was agreed. Local Authorities are to: 1. Transfer all businesses risk-rated under the previous rating system to the Food Law Rating Scheme; then. 2. Generate an Intervention Programme – placing all establishments at dates in the future – after the ‘restart’ date; then 3. Calculate the resources required to undertake all food law enforcement work; then 4. Produce a programme for delivery based on the above with all food businesses given a desk top rating under the new code and assigned an intervention date. The demands of the Food Law Rating Scheme under the code are greater than previous requirements, with greater frequency of intervention and scope covered in each intervention. This new scheme has changed the inspection profile of the businesses due to the different priorities built into the scheme, resulting in many businesses requiring inspection on a more frequent basis. Large or complex businesses are to be inspected more frequently due to their inherent risk. The introduction of concentrated interventions is effective at securing improvement in poorly performing businesses. This regime is very demanding on officer time. The option to extend the inspection frequency to two years for highly compliant businesses has changed, meaning a business will need to demonstrate over a period of three inspections that they have sustained a high level of compliance before they can be placed on this lower inspection frequency. This will take at least five years to fully take effect. All these factors contribute towards a heavier inspection program moving forward. This, along with addressing a backlog of interventions due to the pandemic, requires greater resource to meet the requirements of the code in the five year period following the restart date of October 2021. This was calculated as a deficit of 2.39 full time equivalents, based on the resource calculation carried out by all Scottish Local Authorities in 2021. A recruitment exercise in 2022 was unsuccessful and these posts have since been deleted as part of the Council’s budget process. Limited resources to undertake this work remains a significant challenge to the service. Enforcement Policy The Enforcement Policy outlines the Service’s advisory, consultative, and proportional approach towards enforcement decisions. Enforcement will be applied in a graduated, risk-based manner and resources shall be targeted at those businesses which pose the greatest risk to health. Page 6
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Section 2 – Service Provision Service Delivery Review of 2023/24 Activities The Food and Business Groups food enforcement activities are summarised as follows: The food enforcement policy was reviewed to ensure it accords with the Food Law Code of Practice. It is incorporated into the aforementioned Enforcement Policy. For the year 2023/24 754 visits covering sampling, programmed inspections, complaint investigations, licensing inspections and advice were undertaken. The food related visits are detailed below. Food Visits Undertaken during 2023/2024 Type Count Food Law Intervention 348 Food Sampling visit 17 Food Complaint visit 92 Food advice visit 10 Food re-visits 139 Not trading at time of visit 143 Licensing (including Street Trader licensing visits) 5 An inspection rate for the highest risk food premises (every 1 to 6 months) of 96% was achieved, missing 100% target. For medium risk food premises (every 12 months) a rate of 79% was achieved, which narrowly missed the target of 80%. The Food and Business Group have operated with a reduced number of staff over the 2023/2024 period due to maternity leave and long term sickness. This reduction in staff numbers is in addition to the deficit of 2.39 identified in the 2021 resource calculator, which have since been taken as a Council saving. The FTE calculations do not include time spent on training, responses to major food incidents, food export certification activities, management time or staff meetings etc. The Food & Business Group are also responsible for a range of other activities including but not limited to licensing activities, health and safety interventions and food hygiene training. An enhanced protocol for the approval of manufacturers of products of animal origin based on the principles of Official Control Verification began in April 2023. This has placed a greater demand on the resources of West Dubartonshire’s Environmental Health service due to the increased time spent on document reviews and inspection times based on the time resource calculation required per premises. Page 7
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Sampling Activities and Service Requests There were 17 sampling visits carried out during the 2023/24 period. Food sampling visits in the 2023/24 period incorporate the work the service does in cooperation with FSS, its Local Authority partners in the West of Scotland Food Liaison Group and the associated sampling strategy and surveys which emanate from them including national Food Fraud initiatives and themes from Scottish Food Enforcement Liaison Committee and arising out of the work of the Scottish Food Crime Advisory Group and the Scottish Food Crime and Incidents Unit. There has been a reduction in this service in the last quarter due to inadequate staffing levels. The service actively engages on suspected food fraud and carries out food surveillance to ensure the protection of health and wellbeing for residents and visitors to the West Dunbartonshire area. The 2024/2025 sampling plan will be finalised when the FSS Local Authority Food Sampling programme is confirmed. For the year 2023/2024, the Food and Business Group received and dealt with a total of 588 food service requests. All service requests were actioned within the target time set in our internal monitoring system. These service requests are detailed as follows: Food Service Requests 2023/2024: Service Request Number Extraneous matter 0 Unfit 9 Condition/taint 4 Mouldy 7 Foreign bodies 10 Out of date 15 Food Business Registration 92 Labelling 1 Wrongly described 3 Contamination risk 29 Food alerts 5 Food allergy alerts 43 Export certificate requests 142 Advice 67 Approval of premises 3 Microbiological 3 Product Recall Information Notice 51 Hygiene of premises 52 Street Traders 5 Late Hours Catering 7 Public Entertainment Licences 27 Market Operators Licence 12 Venison Dealers 0 Occasional Licences 1 Page 8
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Food Fraud The Food and Business Group will continue its work on food crime in conjunction with its partners across Scotland. Scottish Food Crime Advisory Group The Scottish Food Crime Advisory Group was established in 2016 under the umbrella of the Scottish Food Enforcement Liaison Committee. The Scottish Food Crime Advisory Group provides for the required interface and joint working arrangements, whilst facilitating delivery of significant outcomes with partner agencies and working in very close partnership with the Scottish Food Crime and Investigations Unit of FSS. Communicable Disease Investigation There were 15 cases of notifiable communicable disease investigated by Environmental Health during the 2023/24 period. A protocol for reporting information and the passing of case information has been established with NHSGGC Public Health colleagues. Food and Business Group Training Delivery The Food and Business Group offers food related development and training to colleagues across the council and externally to citizens who can benefit from food safety training and qualification. The Food and Business Group will continue to work with internal colleagues to ensure high standards are maintained across facilities and accurate high quality information is provided to all service users about the food they consume. The provision of training services offered includes a range of educational packs for training provision in the REHIS Food and Health course and Elementary Food Hygiene Course for continued delivery in the 2023/24 period. We will continue to support Council services and businesses in 2024 where possible. Eatsafe Scheme The Food and Business Group operates the Eatsafe Scheme. The Eatsafe Award extended to Scotland and is administered by the West Dunbartonshire Food and Business Group in conjunction with FSS. The main aim of the scheme is to provide an incentive to food businesses to strive for food hygiene and food safety management standards beyond those required by law. It also helps consumers make informed choices about where to eat out by providing a recognisable 'sign' of excellence in standards of food hygiene. Eligible establishments are assessed for the award as part of scheduled food hygiene inspections, carried out by the Food and Business Group, who also issue and control the issuing of Eatsafe Award certificates. The Eatsafe Award scheme continues to be promoted during all programmed food safety inspections throughout the year and there are 55 current award holders listed on http:// www.eatsafe.gov.uk for the West Dunbartonshire area. Page 9
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Food Hygiene Information Scheme The Council participates in the Food Hygiene Information Scheme in conjunction with FSS. Residents and visitors to West Dunbartonshire can now see Food Hygiene Information Scheme Pass Certificates issued by The Food and Business Group displayed by a number of restaurants and other food premises around the area. PASS ratings for food businesses can be found online at http://ratings.food.gov.uk/ The Food Hygiene Information Scheme is due for review due to the introduction of the Food Law Rating Scheme in a revised Food Law Code of Practice Scotland. The Food Law Rating Scheme covers not only food hygiene matters but food standards matters such as allergen information and other information for consumers. The review of the Food Hygiene Information Scheme is planned by FSS as part of its regulatory strategy. A system which reflects outcomes of Food Law inspections will be delivered following consultation with Food Authorities in Scotland. Food Export Certification The Council’s Environmental Health Service,acting as a Food Authority, produces Food Hygiene Export Certificates for food businesses exporting food to countries outside of the EU. The value of food exported under certification is estimated to be several millions of pounds. This service supports the export industry and contributes to economic development. Exports are predominantly from the local distillers although other products such as coffee and food contact materials have been exported. Food is certificated to nations in Africa, Asia, and South America as well as nations close to the EU 28 . The certificates issued within the 2023/2024 period are detailed in table: Health Certifica tes Product Registrations GMO Conformity Cerificates 259 56 4 The Service will continue to support businesses exporting food and drink in 2024/2025. Food Safety Promotion Food safety information including promotional messaging, food alerts and product recall information continues to be promoted through social media outlets and directly with businesses where such engagement and intervention is in the interest of public health. Food Premises Inspections Businesses are assigned a business group according to the compliance ladder approach set out in the revised Code of Practice. Group 1 - The highest risk activities, manufacturing, distributing and exporting. Group 2 - Other manufacturers and retailers handling open high risk foods. Group 3 - Retail activities, child minders and pubs not serving food. Different risk ratings are assigned to each group and provision is given for intensive intervention where there is sustained non-compliance, issues of public health significance or fraudulent activity. The rating system is a compliance matrix based on compliance level. Page 10
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This allows us to target resource at areas of highest risk. For the risk ratings and inspection frequencies, see Appendix A. Appendix A- FLRS - The Performance Ladder and Compliance Matrix The Compliance Matrix Aide-Mémoire Table There are currently 806 registered food premises in West Dunbartonshire. All food premises are inspected and risk rated in accordance with the Food Law Code of Practice (Scotland). In accordance with the Food Law Rating Scheme which was introduced on 1 July 2019, the following premises are registered. They sit within the categories detailed below. Group A B C D E Unrated 1 4 11 1 0 0 4 2 14 284 159 10 0 24 3 16 184 54 0 1 35 The food premises profile for West Dunbartonshire can be broken down (at 1 April 2024) into the following categories as follows. Premises Type No Primary Producer 7 Small Retailer 165 Restaurant/Café/Canteen 151 Takeaway 113 Caring Premises 78 Pub/Club 55 School/College 38 Hotel/Guest House 24 Mobile Food Unit 18 Manufacturer/Packer 41 Supermarket/Hypermarket 22 Restaurants and caterers – other 52 Distributer/Transporter 9 Retailer/Other 33 There are currently two approved premises (food businesses subject to approval under product specific legislation in the West Dunbartonshire area in terms of Regulation EC 853/2004(5. The Approved Establishments Scottish National Protocol has been produced for Scotland and places greater emphasis on risk in the food manufacturing / approved sector and delivery requires enhanced resource allocation for delivery.
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Future Actions 2024-2025 o The Food and Business Group will continue with the food recovery programme. There are currently 806 registered food premises in West Dunbartonshire. These premises will be inspected over the 2024/2025 programme based on the risk ratings they have been assigned. o In 2024/2025 the Service will participate in the FSS funded sampling programme where specific products are sampled based on the priorities set by the FSS. We will also develop a sampling programme within West Dunbartonshire. o In order to ensure consistency in the application of food law, Scottish Local Authorities developed an enhanced system for official food control interventions based on the principles of Official Control Verification. This applies to specific food manufacturing premises of which there are two within West Dunbartonshire. The Official Control Verification guidance provides a framework to ensure a methodical and consistent approach that meets the legislative requirements and secures a high level of public health protection and protects the reputation of food businesses.
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CONTACT DETAILS Environmental Health, Council Offices, 16 Church Street, Dumbarton, G82 1QL Telephone: 0141 951 7957 Email: Environmental.Health@west-dunbarton.gov.uk OTHER FORMATS This document can be made available on request in alternative formats such as large print, Braille, audio tape or computer disc as well as in five community languages. This document is also available in other languages, large print and audio format on request. Arabic British Sign Language users can contact us via contactSCOTLAND-BSL, the on-line British Sign Language interpreting service on 01389 738282 Chinese (Cantonese) Gaelic Tha an sgrìobhainn seo cuideachd ri fhaighinn ann an cànanan eile, ann an clò mòr, agus ann an cruth claisneachd ma thèid iarraidh Hindi Polish Punjabi Ukrainian Цей документ також доступний іншими мовами, великим шрифтом та в аудіоформаті за запитом. Urdu West Dunbartonshire Council, 16 Church Street, Dumbarton, G82 1QL environmental.health@west-dunbarton.gov.uk 01389 738282 Page 11
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Assessment No 1067 Owner eilidh.paton Resource Regeneration, Environment and Growth Service Environment and Neighbourhood FirstName Surname Job Title Head Officer Eilidh Paton Service Co-ordinator Members Eilidh Paton (Please note: the word 'policy' is used as shorthand for strategy policy function or financial decision) Policy Title Food Enforcement Service Plan 2024-2025 The aim, objective, purpose and intended out come of policy The Statutory Food Law Code of Practice requires that each Food Authority must complete an annual Service Plan which details their food enforcement interventions programme for the coming year. Such a programme requires to be adequately resourced and the Service Plan requires to be subject to approval at the appropriate governance level within each Local Authority. The Environmental Health Sections Food Enforcement Service Plan 2024/25 describes how the food enforcement service is discharged and details the numbers, types and priority ratings of the authority’s food premises, the frequency of planned interventions, sampling programmes, reactive work, including responding to food complaints, food hazard warnings and investigation of infectious diseases. The plan contains information on proposals for the undertaking of the Environmental Health Sections statutory duties in 2024/25 Service/Partners/Stakeholders/service users involved in the development and/or implementation of policy. Environmental Health Food & Business Group Does the proposals involve the procurement of any goods or services? No If yes please confirm that you have contacted our procurement services to discuss your requirements. No SCREENING You must indicate if there is any relevance to the four areas Duty to eliminate discrimination (E), advance equal opportunities (A) or foster good relations (F) No Relevance to Human Rights (HR) No Relevance to Health Impacts (H) No Relevance to Social Economic Impacts (SE) No
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Who will be affected by this policy? Who will be/has been involved in the consultation process? Please outline any particular need/barriers which equality groups may have in relation to this policy list evidence you are using to support this and whether there is any negative impact on particular groups. Specific group to consider Needs Evidence Impact Age Disability Gender Reassign Marriage & Civil Partnership Pregnancy & Maternity Race Religion and Belief Sex Sexual Orientation Human Rights Health The Council is committed to the supporting and improving the Health and well being of local people The plan outlines how in this context we will work to support this The plan helps protect public health Social & Economic Impact Cross Cutting It is important that Council documents are accessible. The Council's Communication Effectively Guidance has been followed. Positive
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Actions Policy has a negative impact on an equality group,but is still to be implemented, please provide justification for this. Will the impact of the policy be monitored and reported on an ongoing bases? Q7 What is you recommendation for this policy? Please provide a meaningful summary of how you have reached the recommendation EIA 1067: The plan helps protect public health in West Dunbartonshire. It is important that Council documents are as accessible as possible and the Council's Communication Effectively Guidance has been followed.