Feed Manual of Official Controls

Every quarter, a review of the Agent’s performance against the DSLA shall take place. 

FSS will carry out ongoing monitoring by analysis of the data held within FMIS.  Data utilised for monitoring purposes will be identified to the Agent and made available on a dashboard within FMIS.

Agents are required to carry out structured, proportionate and routine qualitative internal monitoring to ensure that interventions and other feed law activities, carried out under the terms of the DSLA, are done so appropriately. Outputs from the internal monitoring process shall be used to verify compliance with terms of the Feed Delivery DSLA. 

The Agent should use internal monitoring to ensure effectiveness of delivery methods, identify good practices, areas for improvement and satisfactorily address areas for improvement, as appropriate. 

The purpose of monitoring is for the Agent to be satisfied that:

• the Agent follows the Feed Service Delivery DSLA, FSS guidance and other relevant guidance
• the planned programme of interventions is being maintained and are being carried out competently and consistently
• the feed law risk rating scoring system, is applied in an appropriate and consistent manner including where changes are made to an establishments risk rating score
• appropriate use is made of inspection templates
• any action taken by officers during and following an official control is appropriate and consistent with FSS guidance, the Feed Delivery Enforcement Policy and other relevant guidance and
• officers have access and due regard to UK or Industry Guides to Good Practice, relevant to the businesses within their area. 

Agents should aim to carry out a monitoring exercise to establish compliance against the DSLA every quarter. A template for the recording of monitoring is provided in Annex 9.1. The following list provides examples of areas that may be monitored to verify that the service is delivering in accordance with the DSLA. Priority should be given to areas that are known to cause concern. 

• Adequate arrangements for delivery using sufficient, competent, qualified staff with suitable workload planning:
  • officers are familiar with the legislation they enforce and the relevant guidance
  • officers are competent and appropriately authorised for the businesses they inspect and the legislation they enforce
  • officers authorised to undertake feed hygiene and safety controls of feed business establishments have detailed, relevant and up to date knowledge of the nature and types of businesses in their area and the technology utilised by the businesses.
• Ensure each officer has an appropriate programme of training based on the principles of continuing professional development.

An Internal Monitoring Record (Annex 8.1) should be used for recording internal monitoring of an officer’s work. In addition, an officer may carry out a self-audit or if there is more than one officer engaged in feed work, a peer review (in both cases, using the checklist in Annex 8.2). 

Although not routine activities for Agents, where FSS has agreed that formal enforcement notices, approval and incident investigation shall take place in exceptional circumstances, these records and notices shall also be subject to monitoring.

Agents should aim to carry out a monitoring exercise for each officer (or self-audit/peer review) once per month. 

Tools used for monitoring include:

• accompanied inspections
• consistency exercises, e.g. a range of business scenarios to enable a comparison of officer assessments. These might include:
  • Risk scores
  • Enforcement decisions
  • FeBO intervention reports
• Checking of records e.g. official control reports, letters, sample failure investigations, and where appropriate, formal enforcement notices, approval and incident investigation:
• demonstrate that an assessment has been carried out
  • demonstrate the level of feed businesses compliance with the appropriate legislation
  • ensure subsequent official controls are informed by the individual business compliance history
  • inform each step of a graduated enforcement approach
  • FeBO’s receive timely notification of intervention findings and know what actions need to be taken with legal requirements distinguished clearly from recommendations
  • record actions relating to revisits
  • identify and document that instances of non-compliance are followed through, and all instances of significant non-compliance addressed which require notification to FSS are done so in a timely and effective manner, taking account of the FSS Feed Enforcement Policy.