Scottish Food Enforcement Liaison Committee 3 June 2016

Chairman Billy Hamilton from City of Glasgow Council welcomed 19 members.

The major item of the day was the Verfification of FSMS (Food Safety Management System) and Principles for Official Controls in approved/manufacturing sector; examining the method and technique of approvals. The challenge initially was to improve controls in approved establishments. This came against a background of threat of Food Standards Scotland (FSS) taking away that process from local authorities. An extensive review had examined methodology of inspections. A more educated scientific approach to inspections – as recommended by Fatal Accident Inquiry Sherriff Graham Cox is required. Considered that an inspection was about protecting the public not necessarily compliance. Eliminating all hazards was the most important thing by asking the question are they reduced?

Scope:-
Approved establishments and manufacturing establishments covered by both FSS and LA.
Not restricted to food hygiene – incorporates aspects of food standards and food related crime.

Purpose:-
To provide guidance to inspecting officers on the verification of FSMS.
A systematic approach.
Ensure a consistently high standard of verification.
Robust system which will stand up to audit.
Not a 'how to' guide.

Will require more resources, more time and not necessarily unannounced visits because of the need to speak with technical management. A Resource calculation tool would be available for EHOs.

Need to look deeply into the food management systems of FBOs. Hunting for all the controls. Need to look at HACCP, TACCP and VACCP with a proactive approach. The inspector needs to match the FBOs FSMS, FBO FSMS in reality and official control FSMS independent assessment. This requires the inspector needs to do a risk assessment of their own as they inspect.

The process would include evidential triangulation. Corroboration is sought through observation, interviews and inspection of records.

The structure of inspection includes preparation, document review, opening meeting, reality check.

Reality check examines if the process is as recorded. Includes a traceability page. Ultimately the desire is to raise the bar.

A further presentation by Andrew Morrison looked at Approved Establishments National Protocol.

He felt that the guidance should have more weight than just guidance. Currently two reference points for approvals, one used by Local Authorities and one by FSS.

Competency of inspectorate was review and identified that they required trained to Advanced HACCP including training in relation to the assessment of HACCP systems in the approved sector with product specific knowledge.

The need for approval of butchers cutting for their own use may come under more rigid compliance and need more approvals. Change of FBO ownership would require to be notified within one calendar week or approval would be lost.

There will be an eight week consultation starting w/c 20th June 2016. SAMW and Poultry Industry representatives need to be made aware of this.

Impact will concern Local Authorities in relation to time requirement. Consistency of inspection will continue to be a concern to all parties. FSS charges for Official Controls delivery and some sectors of industry subsidise competitors currently. Going forward charges will be more directly charged.

Comment: concentrate too much on the process and miss the dangers. (This certainly is the FBOs current view).

Next SFELC meeting in October will focus on resourcing and so will enable industry to question the ability to inspect weekend markets.

Food Standards Scotland update
FSS have now purchased MenuCalc licence from FSA NI. Currently only useful for allergen identification and calories computation for menu items. Extremely user friendly. Late summer launch.
Nutritional information for December
FSS will have a summer campaign on theme of cooking barbecue foods.
Review of FHIS (Food Hygiene Information Scheme) will be undertaken to see if consumer behaviour is affected and to review if it has increased compliance.

In Scotland a National Food Crime Advisory group has being formed with Derek Oliver (Lead EHO East Lothian) as chair.

Next meeting: Friday 7th October in Aberdeen