1. Aims and Objectives
2. Background
3. Rother Structure
4. Food Hygiene in Rother District
5. Service Delivery
6. Resources
7. Quality Assessment
8. National Recognition
9. Conclusion
10. Contacts
11. Appendix 1

Aims and Objectives

This Food Service Plan is an expression of Rother District Council’s continuing commitment to Food Hygiene. The mission statement for this service is to

“Deliver an increasingly efficient and effective public health service which strives to promote and sustain a safe, prosperous community for businesses, residents and visitors.”

This plan has been prepared in accordance with paragraph 2.4 of the Food Law Code of Practice (2021).

1. The purpose of this plan is to set out how Rother DC will deliver Official Controls within its area.
2. This service plan notes paragraph 6 of The Regulators Code (published April 2014), which states that “Regulators should ensure their approach to their regulatory activities is transparent”.
3. The food hygiene service of Rother DC is informed by the principles of:
   • Proportionately (in applying the law)
   • Consistency (of approach)
   • Targeting (of enforcement action)
   • Transparency (about how we operate and what those regulated may expect)  
4. The food hygiene service supports the vision of Rother DC Corporate Plan (2020 – 2027) “to put residents at the heart of all we do” by delivering an effective public health service to promote and sustain a safe prosperous community for businesses and residents. Corporate Plan 2020-2027 – Rother District Council
5. Rother DC has adopted Equality Policies at Equalities at Rother District Council – Rother District Council. The Environmental Health Service conducts equality monitoring.
6. The Better Regulation Delivery Office placed food hygiene at Number 5 in their five priority regulatory outcomes for England (November 2011).

Background

Rother District Council – Profile

Population: 96,080 (ONS UK 2019)
Area: 511.8 Km²

Rother’s District is mainly a rural area with urban centres: Bexhill, Battle and Rye. As a District Council, Rother’s hygiene service is concerned only with food hygiene; the food standards and feeding stuffs function is delivered by East Sussex County Council (Trading Standards).

The District of Rother contains small pockets of rural, coastal and urban living. The food businesses within the District reflects this mix. The coastal areas have a significant holiday industry and seasonal influx of visitors affects Camber and Rye in particular. Battle is a year-round tourist destination.  Bexhill, the main urban development, has a significant care industry which is reflected in the high number of care homes. In rural areas there are food businesses associated with agricultural and fisheries sectors (dairies, cheese makers, export of fish and fish products).

Rother District Council Structure

Decision Making and Overview and Scrutiny Structure

Food Safety Team Structure

The food hygiene of Rother’s District is carried out by the members of the Food Safety team (FAST), as part of the shared environmental health service and interlinks with UKHSA (United Kingdom Health Security Agency – formerly Public Health England) neighbouring local authorities, Food Standards Agency and other agencies as shown below;

The function of the team, in addition to food hygiene, is to advise on health and safety at work including Covid 19, investigate notifiable infectious diseases, regulate skin piercing, licence holiday and residential caravan sites, licence kennels and catteries, provide pest and dog control service and risk assess private water supplies.

The team operates from Town Hall, Bexhill-on-Sea and Vicarage Lane, Hailsham from 8.30am – 5.00pm Monday to Thursday and 4:30pm Friday. The service operates an agile working system. Planned out-of-hour work is undertaken and emergency calls are received by a standby system currently operated by Cornwall Council on 01424 787868.

Any complaints can be submitted to Rother DC website at Environmental Health – Rother District Council; or reported by telephone 01424 787500

Rother DC adopted an Enforcement Policy for the shared Environmental Health service in October 2014, cabinet minute 14/31

The Environmental Health service standards and this service plan can be found on our Environmental Health Service Standards page

Food Hygiene in Rother District

The profile of food businesses in the Rother district on 5 April 2022:

Type of Business	Number
Caring Premises	122
Distributor	12
Hotel/Guest House	59
Importer	1
Manufacturer	36
Mobile	48
Producer	35
Pub/Club	117
Restaurant/Cafe	211
Caterer	125
Retailer	84
School/College	52
Small Retailer	82
Supermarket	13
Takeaway	45
Total	1042

Each year the numbers of food businesses varies – the total of 1042 is higher than previous years which have been around 990. This increase is the explosion of micro food businesses that occurred during the lockdown months.

The service does not inspect each food business annually, instead it inspects according to risk and performance to make sure that the highest risk and the lowest performers receive the most attention.

Food Hygiene Intervention Ratings

The Food Standards Agency sets out a numerical scheme which local authorities must use at each food hygiene inspection and this is used to determine;

1. When the next intervention will be (date)
2. What the next intervention will be (inspection/partial inspection/alternative)
3. Food hygiene rating

This numerical assessment of the business is based on the hazards, risks and controls. These figures are entered into the database and the next inspection is planned. The same information is used to create the food hygiene rating to inform customers of the general standards within a food business.

A business that produces high risk food with good controls is seen once between twelve to eighteen months. This intervention frequency will increase to once in six to twelve months if the business serves a vulnerable group (elderly/infirm/young). Any business with poor controls will require the most attention as decided by the inspecting officer. All food hygiene inspections fall into one of these categories;

1. Category A and B (92+; 72+)
   These are the highest risk food businesses and must be subject to an inspection, partial inspection or audit at least every six months (A) and every 12 months with (B). It is Rother’s policy that these businesses are fully inspected.
2.  Category C (52-71)
   These medium risk businesses will receive an inspection, at eighteen months, if they are broadly compliant it will be a partial inspection; otherwise a full inspection will be made.
3. Category D (31+)
   Category D premises are subject to an intervention every 24 months. Where they are rated 30 or 40 for “type of food”, these businesses must be subject to inspection, partial inspection or audit. Where the premises are rated less than 30 for type of food etc. it can alternate between official controls. Rother District Council inspects all category D’s, partial inspections for those that are broadly compliant.
4. Category E (0-30)
   The FSA advice on these lowest risk food businesses is that they could have an intervention every 36 months. It is Rother DC policy that these lowest risk food businesses are subject to a physical inspection or an alternative enforcement questionnaire every 36 months. It is important to retain observation of these lowest risk businesses to prevent minor issues becoming major over a long intervention interval.

Food Hygiene Rating Scheme

The food hygiene rating scheme was adopted by Rother DC in April 2011 to provide information to consumers on the hygiene, structure and management of a food business. At the end of an inspection the business is rated with one of the window stickers below. In England it is not a legal requirement to display FHR stickers, although the FSA has expressed its support for this. Rother ratings are available at Food Gov.uk website

Business with a 3, 4 or 5 are deemed to be broadly compliant with food hygiene legislation and those with ratings of 0, 1 or 2 have failed.

Food Hygiene Ratings April 2022 RDC

Rating	April 2022	April 2021
0	0	2
1	2	2
2	1	2
3	44	63
4	119	149
5	762	712
Broadly Compliant	99%	99%

The very high performance for 2021/2 cannot be taken at face value. Food hygiene inspections were made during the lockdown months by appointment. This was to protect the health and safety of both officers and businesses.

Food Hygiene Interventions – Performance 2020-2021

A total of 442 food businesses were due for an intervention in 2021 – 22 plus 148 inspections which had not been done the previous year. Of the 442 due inspections 381 were done plus 116 (of the 148 inspections) carried forward from the previous year. The overall performance is 85%.
The target of 98% has been missed. There are distinct reasons for this performance – many food businesses had to close for significant periods during 2021/2 and food hygiene inspections could not be done. Some businesses operated sporadically, and others decided to ceased trading. Physically gaining access to many businesses was difficult and time consuming.

The Covid pandemic had the unprecedented effect of causing a record number of businesses to cease trading (94) and simultaneously for new businesses to open (75). This turmoil is not reflected in the figures. Significant time was spent in 2021-2 in chasing businesses to establish whether they were trading. Large numbers of businesses applied to be registered and many were difficult to access for inspections. Of those that applied, seventy-five new food businesses are now in operation.

The priority for the Food and Safety team during 2021/2 was the inspection of food businesses to ensure standards were maintained and to support those businesses that export food into Europe by issuing export health certificates.

Service Delivery 2021-2022

Rother DC is committed to providing a full food hygiene service as follows;

For the year 2021 -23 the total number of food premises due for inspection is 410. These inspections are categorised as follows:

Category	Number
Category A	1
Category B	72
Category C	89
Category D	153
Category E	95
TOTAL	410
Carried forward from 2020 -21	61

The food hygiene interventions are conducted to ensure the food business meets the requirements of food hygiene law. It is Rother DC’s policy that these planned inspections are given priority and that 98% of this planned programme will be completed.

Our Approach

It is ROTHER DC policy to make food hygiene inspections without appointment. The Environmental Health Officer will identify themselves to the food business owner (or person in charge) before starting the inspection. The intervention will be conducted in accordance with the Food Law Code 2021 in particular:

• The hazards and risks will be assessed
• The controls will be verified
• The businesses validation will be examined
• The findings will be discussed
• A report of visit form will be left
• A follow up letter may be issued

The Environmental Health Officers of Rother DC will also deal with licensing and health and safety issues during a food inspection.

Poorest Performers

In Rother DC food businesses scoring 0-2 will receive more attention and support to continue to raise standards. This means that inspectors will make compliance checks (revisit) within three months of the initial inspection. If significant improvements have not been made Inspectors will take enforcement action.

Those businesses which show little or no improvement may be advised to contact a training contractor for tailored coaching, which they will have to pay for.

Seasonal Businesses

There are many seasonal food businesses within the Rother district who trade only between June and September or early December. These businesses are inspected according to the Food Standards Agency food hygiene intervention scheme (as 4.2 above). However, those categorised as C are scheduled for an intervention at 18 months which may fall within their closed period. In these cases, it is policy to bring these inspections forward, so they are inspected when they are trading.

Unrated Businesses

Unrated businesses will be subject to an inspection in accordance with Food Law Code. Surveillance is conducted for food business previously unknown to the authority specifically on social media. A series of social media messages were made during 2021/2 asking for whistle blowers to come forward and this campaign resulted in several genuine reports of unregistered food businesses. 

Revisits

Revisits are made to any businesses where significant statutory requirements were found on the programmed inspection. Food Law Code specifies where 15 or higher is awarded for hygiene/structure or 20 for confidence in management, a revisit will be made.

Revisits are always made after the expiry of statutory notices and to any businesses rated 0-2 FHRS. Revisits may also be made at the discretion of the EHO.

Food businesses with a 3 or 4 who wish to improve their score may apply for a revisit without charge after a three-month period or with charge once the work has been completed.

Food Hygiene Rating Scheme – Information for Food Businesses – Rother District Council

Service Requests

Complaints about foodstuffs, food businesses or handlers can be made directly to Rother DC by emailing foodhs@rother.gov.uk or by telephone to 01424 787550.

We do not accept anonymous complaints, full contact details will be asked for, which will be kept confidential. The team will observe the shared service complaint investigation policy, give a first response to a service request within 5 days and complete the investigation within 90 days. In 2021 – 22 Rother DC investigated 32 requests for service regarding foodstuffs and food businesses.

New Businesses

Seventy-five new food businesses opened in Rother in 2021 – 22. Each of these businesses was given advice and guidance on both food hygiene and safety matters.

Every new food business is obliged to register with their local authority and this form is available on the Rother DC website along with full advice on starting up a new food business.

Starting a food business page

Sampling

Rother DC samples food to ensure it is clean and safe to eat. Food samples are taken and sent to UKHSA in Porton Down for examination.

In 2021-22 there was a study involving scratchings (pork, chicken or duck). There had been a nationwide outbreak of Salmonella, which was linked to a factory in the North West of England. A variety of scratchings were purchased in the Rother area from a range of outlets – these were submitted to UKHSA at Porton Down for examination. None were found to contain Salmonella.

Food samples labelled and ready to be packed into transport containers for Public Health England.

Primary Authority

Primary Authority allows businesses to be involved in their own regulation. It enables them to form a statutory partnership with one local authority which then provides robust and reliable advice for other local regulators to consider when carrying out inspections or addressing non-compliance. Rother DC does not act as a primary authority for any food business. Rother DC complies with the primary authority principle by checking the appropriate website before conducting food hygiene inspections and noting any assured advice or inspection plans.

Import/Export of Food

Since 1st January 2021 certification of food before export into Europe is required. This means that every consignment of food must be inspected and certified by an Environmental Health Officer before export. This is a distinct issue for those businesses exporting fish from Rye to Europe. Significant time was spent working with businesses to develop working methods to allow inspection and certification at the right time before transport. Environmental Health Officers had refresher training on fish identification and assessment of fitness for consumption.

It became clear that many fishermen would not be able to access the new export system. Chapmans of Rye and the Environmental Health Service of Rother and Wealden worked together to establish an export hub which serves the fishing communities of Sussex, Kent and Essex.

Fish from Sussex, Kent and Essex is collected by road, transferred to Rye where it is inspected and dispatched. One export health certificate is issued. This allows for rapid transit at the border control post and minimises the cost to all involved. One local authority, Rother District Council, provides the EHC.

Photographs show – inspection of fish by EHO; prepared pallets of fish ready to be loaded; seal on vehicle ready to go.

Delays are caused by border control post checks. Consignments are inspected and questions raised, which must be answered satisfactorily before the consignment will be released. On three occasions consignments have been refused entry into Europe, against which there is no appeal mechanism.

After 1st January 2021, the paperwork required to export is; Export Health Certificates for each consignment, see photo on left; invoice, see photo on right, catch certificates, packing list and customs declaration.

Several other businesses asked for support with the new export certification process, and many found that they were unable to continue with their current operating model of grouping together foods as ordered. This system known as “groupage” had developed with the single market, as foods moved freely around Europe. Foods must now be packed into food groups, e.g. fish only, meat and meat products only etc. This is to allow for export certification for each food type.

Nortrade Foods Ltd, based in Etchingham exports frozen fish and fish products to the Rep of Ireland. As with the fresh fish, each consignment must be inspected and certified before loading. The fish products (fish cakes, fish pies etc) are manufactured and packed with batch codes which must be checked by officers before the certificate can be granted.

From September 2021 we could not offer certification to Nortrade Foods Ltd as a rule change required triangular certification, for which we are not authorised.

Photographs show – Nortrade Foods Ltd cold store Etchingham, frozen calamari from California, breaded haddock fillets both opened for inspection. The box resealed with Rother DC official control tape and stamp and replaced into the pallet load.

Between 1st January and 31st December 2021 one hundred and thirty-four export health certificates were issued for 501 tonnes of fresh fish and 55 tonnes of frozen fish and 7328.5 kg of live scallops. Each certificate is charged at £100.

Notifiable Diseases

In 2021 – 22 Rother DC received 180 notifications of infectious diseases from Public Health England. From January 2021 we began investigating cases of Covid 19 that test and trace could not contact. These notifications must be followed up promptly to prevent further spread of the disease. For Covid 19 Environmental Health Officers attend the home address, for food poisoning officers contact cases within 24 hours by phone and less urgent cases contacted by post, in accordance with PHE guidelines.

Reportable Diseases	2021/22	2020/21
Campylobacter	106	128
Covid 19	44	9
Salmonella	12	10
E. coli 0157	11	10
Shigella	4	0
Giardia	3	1
Cryptosporidium	0	1
Total	180	159

Food Alerts

Food hazard warnings are responded to in accordance with the Food Law Code 2021 and with written procedure. There were no food alerts for Rother District Council action in 2021 – 22.

Advice for Food Businesses

Rother District Council is committed to supporting all food businesses through provision of advice on the Rother District Council’s website at Safe Food and Healthy Workspaces page

Work for other bodies

Rother DC undertakes training in Environmental Health. In 2021 – 22 this training was delivered online over three days to the new port health officers at Ashford Borough Council. The new Port Health officers also undertook shadow visits with members of Rother’s food and safety team. Shadow visits are essential to qualify as food safety practitioners and Rother Dc was paid for this work.

Resources

Area	2021-22 Budget
TOTAL cost	£124,677
Employee Costs	£117,057
Supplies and Services	£7,620
Staff	2.5 FTE

Budget Area	£	Notes
Sampling Budget	9,948	With UKHSA not ROTHER DC
Legal Action	1,000,000	For general Council disasters and emergencies – not specific to food hygiene functions
	9,420	Specifically, for food hygiene matters

The number of full-time equivalent staff working on food hygiene, including supervision and management, for 2022 -23 is 2.5. All the authorised food officers are named below;

Environmental Health Officer	Additional Qualification	Level of Authorisation Inspection	Level of Authorisation Enforcement
EDWARDS Simon	Env Health Degree EHORB Registration	A-E	Full
HOYLAND Richard	Env Health Degree EHORB Registration	A-E	Full
KANE Una	MSc Env Health Degree EHORB registration Lead Assessor Chartered EHP	A-E	Full
OGINNI Oladayo	MSc EHORB Registered	A-E	Full
KAMUNDA Maybee	Env Health Degree EHORB Registration	A-E	Full
POWELL Jamie	Env Health Degree EHORB Registration	A-E	Full
WRIGHT Philip	Env Health Degree EHORB Registration	A-E	Full

Other Officers, within the Environmental Health Department (but not within the Food and Safety team), who are authorised are as follows:

Surname	First Name	Job Title
PARKER-HARDING	Richard	Head of Environmental Health
RANDOLPH	Mark	Senior Environmental Health Officer
SMITH	Sue	Senior Environmental Health Officer
BEAUMONT	Cathy	Deputy head of Environmental Health

The Council employs two Pest Control officers who assist officers in inspecting premises for pest activity and acts as expert witnesses in prosecutions.

Staff Development

Annual appraisals are conducted to identify each team members training needs and these collected needs form a training programme. All attend external seminar meetings and training courses. During 2021 – 22 team meetings were held both online and in person, dependant on the Covid 19 rates at the time.

Those officers outside Food and Safety Team were invited to some online meetings to learn about new working procedures, specifically on export health certificates. Officers from outside the team do not conduct food hygiene inspections alone unless they have completed the required training and are up to date with food and safety procedures and policies.

Sussex Food Liaison Group Meetings

Rother DC is represented on the Sussex Food Liaison Group by the Team Manager. This liaison work ensures that our enforcement activities are consistent with those of our neighbours.

In 2021 – 22 the food and safety team participated in one consistency exercise; these are blind tests designed to ensure that individual officers are consistent with scoring which leads to award of food hygiene rating. Rother DC is also represented on the CIEH Sussex Branch of the Food Study Group, and UKHSA meetings on infection control.

Quality Assessment

Each year Rother DC’s performance against this plan is measured, using all the specified targets, standards and any targeted outcomes within this plan. The review will specify where there has been variance from the plan and the reason for that variance.

Any areas in need of improvement will be specified and an action plan put in place to implement their improvement. There is a backlog of 61 food inspections carried over from 2021 – 21. We are confident these inspections can be completed in this financial year.

The service subscribes to RIAMS, an on-line service, providing links to national advice and guidance for Environmental Health practitioners.

National Recognition

The establishment of an export hub for fish in Rye has attracted a lot of interest from central government departments and other local authorities. The success of the export hub is noted in the EFRA Report into Seafood and Meat Exports to the EU, published April 2021 at Seafood and Meat Exports to the EU – Committees – UK Parliament

Conclusion

This Service Plan has been authorised by the Head of Service, following consultation with the Cabinet Portfolio Holder.

It is published on the Rother website and in the Member’s Bulletin.

Signed: R. Parker-Harding
Mr R Parker-Harding BSc (Hons) MSc DMS CIEnv AMIOA
Chartered Environmental Health Practitioner
Head of Service, Environmental Services, Licensing and Community Safety

Dated: 22 August 2022

Signed: K Field
Councillor K Field
Cabinet Portfolio holder Environmental Health

Dated: 22 August 2022

Contacts

Website: www.rother.gov.uk
Address: Town Hall, Bexhill-on-Sea
Telephone: 01424-787000
E-mail: foodhs@rother.gov.uk

Appendix 1 – Impact of Covid 19 – Risk Assessment of Impacts

Recovery

The Food Standards Agency has asked each local authority to make a risk assessment of their resources to determine ability to complete to recover the planned programme of work. The issue here is the unknown demands that could be placed on the service in the coming year. The Director of Public Health (ESCC) has advised that he may need the assistance of qualified Environmental Health Officers from Rother to assist in any local outbreak, in accordance with the Covid 19 local outbreak plan.

The Food Standards Agency recovery plan advises local authorities to resume physical food hygiene inspections it has yet to advise on the backlog.

Risk Assessment	Notes
HAZARD – Covid 19	Although the vaccine programme is well underway there are growing numbers of cases locally among younger people. Outbreaks are occurring in schools and colleges. It is not possible to predict the number of local outbreaks the DPH will ask for assistance.
HAZARD – Non completion of food hygiene inspections	Food hygiene standards fall creating another public health risk.
THOSE AFFECTED	All in Rother
RISKS	Very high to public health from both Covid 19 and non-completion of food hygiene inspections.
CONTROLS – physical food hygiene inspections	Risk assessments have been prepared and sufficient PPE has been obtained. Precautions to be adjusted according to current rates of infection and this may make the visits longer. Officers are required to assess Covid security measures for their own safety before proceeding with an inspection.

Local Outbreak Control-impact on food programme

The Director of Public Health has said that he may require qualified EHOs to assist with local outbreaks of Covid 19 associated with health or care setting, schools, children with special needs, prisons or secure establishments.

As this will be a priority the food intervention programme could be varied according to circumstances.

Should the resource demand be low (less than 0.5 fte) it should be possible to complete;

• A and B rated food businesses as physical inspections
• C rated food businesses as focused physical inspections
• D and E rated food businesses as virtual inspections or alternative enforcement strategies.

Should the resource demand be medium (less than 1.0 fte) it should be possible to complete;

• A and B rated food businesses as physical inspections
• C rated food businesses as focused physical inspections

Should the resource demand be high (less than 2.0 fte) the minimum achievable would be;

• A and B rated food businesses as physical inspections