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 contributes to the Rother DC objective of “Stronger Safer Communities” and “Sustainable Economic Prosperity” in the corporate plan for 2014-21; “a fairer society” and “development of Rother’s economy” in the draft corporate plan from 2020 to 2027.
  5. Rother DC has adopted an Equality Policy and 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).


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).

Ordnance Survey Map of Rother
Map of the Rother District reproduced by kind permission of Ordnance Survey

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

Rother District Council
Rother District Council
Licensing & General Purposes
Licensing & Gene…
Audit & Standard
Audit & Standard
Overview and Scrutiny Committee
Overview and Scr…
Chief Executive
Mr Malcolm Johnson
Chief Executive…
Service Manager of Environmental Health, Licensing and Community Safety

Mr Richard Parker-Harding
Service Manager of Environmental Health, Licensing and Commun…
Food and Safety Team (FAST) 
Community Protection Team
Licensing Team
Community Safety
Food and Safety Team (FAST)…
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Rother District Council Departmental Structure

The chart below shows the departmental structure as of Spring 2021.

The draft corporate plan from 2020 to 2027 will be supported by a new corporate management team structure, which will be in place January 2022.

The objectives of the new corporate plan will be firstly, shaping the district to deliver improvements in the environmental, economic and social situation that Rother residents, businesses and visitors enjoy. Secondly, enabling the Council to transform through an efficient and empowered workforce placing the “customer” at the centre of all we do.

Executive Directors
Executive Directors
Housing & Community
Housing & Community
Environmental Services, Licensing & community Safety
Environmental Servi…
Corporate Core
Corporate Core
Acquisitions, Transformation & Regeneration
Acquisitions, Trans…
Strategy and Planning
Strategy and Planni…
Financial Services

Revenues and Benefits

Infrastructure & Service Desk

Business Operations & Reprographics
Financial Services…

Building Maintenance

Neighbourhood Services & Contracts

Customer Services

Beach and Coast Management




Food and Safety

Pest Control

Community Safety

Private Sector Housing
Executive Support

Joint Waste

Emergency Planning

Internal Audit


Democratic Services






Executive Support…

Economic Development



Housing Development


Corporate Policy and Performance

Property Investment and Income Generation
Development Management

Planning & Environmental Enforcement

Planning Policy & Strategy
Development Managem…
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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 Public Health England, neighbouring local authorities, Food Standards Agency and other agencies as shown below;

Sussex Food Liaison Group
Sussex Food Liaiso…
Food Hygiene Service Rother District Council
Food Hygiene Servi…
Public Analyst Kent Scientific Services
Public Analyst Ken…
Public Health England Food Water & Env Lab
Public Health Engl…
PHE (HPU) Kent, Surrey and Sussex
PHE (HPU) Kent, Su…
CIEH Susses FOOD Study
Regulatory Delivery
Regulatory Delivery
Food Standards Agency
Food Standards Age…
Joint District Control of Infection Committee
Joint District Con…
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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 cosmetic 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 2021 is as follows

Type of BusinessNumber
Caring Premises125
Hotel/Guest House70
Small Retailer77

Each year the numbers of food businesses varies – the total of 1071 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. All ratings are available on the 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 Rating stickers showing all the scores from 0 (Urgent Improvement Necessary) to 5 (Very Good)

In April 2021 99 % of food businesses in Rother were broadly compliant with food law, a significant increase from 97.3 % in April 2020. 

RatingApril 2021April 2020
Broadly Compliant99%97.3%

The very high performance for 2021 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 453 food businesses were due for an intervention in 2020 – 21 plus 29 inspections which had not been done the previous year. Of the 453 due inspections 306 were done giving 68% completion of the programme. Further 8 of the 29 inspections carried forward from 2019/20 were not completed. These were the luncheon elderly clubs which temporarily ceased trading during the pandemic. There are two distinct reasons for this performance   – many food businesses had to close during 2020/1 and inspections could not be done – the officers of the Food and Safety Team were responsible for enforcing the Covid 19 restrictions in all types of businesses throughout 2020 and 2021.

There was a dramatic increase in the numbers of micro food businesses operating from domestic properties during the lockdown months. On 5th April there were seventy-one such micro businesses awaiting their first inspection. As these are generally low risk (cake makers, preserves and chutneys) their initial inspection must be fitted around high-risk work.

As planned in 2020 -21 an alternative enforcement strategy (AES) was adopted for 99 of the very low risk businesses. These businesses were contacted electronically and asked to complete an online survey about their hygiene arrangements. The majority gave satisfactory answers; 11 did not respond and required further follow up.

Food Hygiene Performance 2020-2021 - Inspections Done 57%, Not Done 27% and AES 16%

The priority for the Food and Safety team during 2020/1 was the advice and enforcement of the Coronavirus Closure Regulations 2020, and in the latter half of the year the new export certification system for exported food.

Service Delivery 2021-2022

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

For the year 2021 -22 the total number of food premises due for inspection is 446. These inspections are categorised as follows:

Category A1
Category B60
Category C110
Category D170
Category E105
Carried forward from 2020 -21147

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 on specifically on social media. A series of social media messages were made during 2020/1 asking for whistle blowers to come forward and this campaign resulted in several genuine reports of unregistered food businesses. This campaign will be repeated in 2021 – 22.  


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.

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 2020 – 21 Rother DC investigated 44 requests for service regarding foodstuffs and food businesses.

New Businesses

One hundred and twenty-eight new food businesses opened in Rother in 2020 – 21.  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 our starting a food business page


Rother DC samples food to ensure it is clean and safe to eat.  In 2020/1 there were two distinct sampling campaigns – ready to eat salads and processed chicken products. The concern with ready to eat salads is that E. coli and other disease-causing bacteria can be present, mainly due to poor handling.

In 2020/1 there was a nationwide outbreak of Salmonella, which was linked to processed chicken products. A total of nineteen visits were made to select food samples in 2020-21. Salmonella contamination was found in half the chicken products sampled and these were subject to an FSA recall notice. The salads were generally satisfactory.

Samples labelled and ready to be packed into transport containers for Public Health England
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. In the Autumn of 2020 significant time was spent working with businesses to develop a new working method 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.  

During these preparations 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.

Fish being inspected
Pallets of fish to be loaded
Seal on the back of a lorry

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

To date each consignment dispatched has reached its final destination safely, but not without challenge. We believe our success is due to our attention to detail and our prompt action when requested by border control officials. 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 occasion further documents are required.

Before 1st January 2021 fish exported to France and Belgium was listed on a single document, as shown below. No inspection or certification was required; no customs clearance was required.

An example of a fish export document from before 1st January 2021

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

In January, Feb and March there were further requirements for Covid 19 tests for HGV drivers and permits to enter Kent.

Export Health Certificates laid out on a table
Examples of invoices

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.

Nortrade Foods Ltd cold store in Etchingham
Frozen calamari from California
Breaded Haddock Fillets opened for inspection
The box resealed with Rother DC official control tape and stamp
Pile of boxes

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 March 2021 twenty-five export health certificates were issued for 76,473 kg of fresh fish and 18,373 kg frozen fish.  In effect 94 tonnes of fish.

During this period, a small charge was made, from 1st April 2021 each certificate is charged at £100.

Notifiable Diseases

In 2020-21 Rother DC received 159 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 Diseases2020/12019/20
Covid 19    9   0
Salmonella  10 13
E. coli 0157  10   6
Shigella   0   4
Giardia   1   1
Cryptosporidium   1   1

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 2020 – 21.

Advice for Food Businesses

Rother District Council is committed to supporting all food businesses through provision of advice on our Safe Food and Healthy Workspaces page

All updates on the implications for food businesses and EU exit were made by Rother Council direct (electronically) through the gov.uk website to all registered food businesses.

Work for other bodies

Rother DC undertakes training in Environmental Health for universities. In 2019 – 20 this training was delivered online to students in Brighton University.


Area2021-22 Budget
TOTAL cost£124,677
Employee Costs£117,057
Supplies and Services£7,620
Staff2.5 FTE
Budget Area£Notes
Sampling Budget  9,948With PHE not ROTHER DC
Legal Action1,000,000For general Council disasters and emergencies – not specific to food hygiene functions
 9,420Specifically, for food hygiene matters

The number of full-time equivalent staff working on food hygiene, including supervision and management, for 2021 -22 is 2.5. All the authorised food officers are named below;

Environmental Health OfficerAdditional QualificationLevel of Authorisation InspectionLevel of Authorisation Enforcement
PAGE   DavidEHORB Registration Env Health Degree Chartered EHPC-EFull
HOYLAND RichardEnv Health Degree EHORB RegistrationA-EFull  
KANE UnaMSc Env Health Degree EHORB registration Lead Assessor Chartered EHPA-EFull
PAGE SarahEnv Health Degree EHORB Registration Chartered EHPA-EFull
WAKEFORD ClaireEnv Health Degree EHORB RegistrationA-EFull
POWELL JamieEnv Health Degree EHORB RegistrationA-EFull
WRIGHT PhilipEnv Health Degree EHORB RegistrationA-EFull

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

SurnameFirst NameJob Title
PARKER-HARDINGRichardHead of Environmental Health  
EDWARDSSimonSenior Environmental Health Officer  
RANDOLPHMarkSenior Environmental Health Officer
SMITHSueSenior Environmental Health Officer
MINNSGregorySenior Environmental Health Officer
BEAUMONTCathyDeputy 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 2020/1 team meetings were held online every week.

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 FAST 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 2020 – 21 the food and safety team participated in one consistency exercise; these are blind tests designed to ensure that individual officers are consistent with scoring. Rother DC is also represented on the CIEH Sussex Branch of the Food Study Group, and Public Health England 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 significant backlog of food inspections. The FSA have yet to advise on this matter, but it is Rother’s intention to complete as many as possible.  

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

A photo of the country side near Burwash
Beautiful Rother – Burwash

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


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: 7 July 2021

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

Dated: 7 July 2021


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


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 AssessmentNotes
HAZARD – Covid 19Although 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.
RISKSVery 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 but the precautions will make the visits significantly longer. Officers must assess Covid security measures within the business as well as food hygiene.  

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
  • 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 focussed 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

An external contractor has been engaged to complete the outstanding 147 food inspections from 2020/1.