Food Sampling Policy
In accordance with the Scottish Borders Council Food Safety Policy, the aim of the food sampling policy is to ensure that food and drink, intended for sale for human consumption and produced, stored, distributed, handled or consumed in the Scottish Borders, is hygienic and complies with the appropriate food standard and labelling regulations.
The Risk Assessment or Hazard Analysis Critical Control Points (HACCP), approach to food safety, is a quality assurance based approach, aimed at producing food correctly, everytime. Sampling is useful for verification of HACCP systems, a vital investigative tool and a necessary part of the Local Authority’s food safety enforcement role.
Food sampling is used for raw materials of food as well as final product, just as the consumer would eat it, or at intermediate stages during investigation of final stage failures. Most initial samples will be of the final product. Food samples are taken to check for food hygiene or food standards including labelling. For food standards testing, samples are examined, tested or analysed to assess their compliance with food standards including absence of contaminants. The standards used are statutory (i.e. meat content), presumptive (i.e. fat in mince), or investigative (i.e. comparison of fish contents).
Food hygiene samples are predominantly examined microbiologically, for the presence of pathogens, indicator organisms or for total bacterial counts. Some food hygiene samples are subjected to testing for enzymes i.e. phosphatase in milk. The results are assessed against statutory standards (i.e. dairy products) or presumptive standards produced by trade and enforcement bodies (i.e. sandwiches).
Authorised Officers of the Local Authority are permitted under the Food Safety Act to take samples from food businesses and food premises, in some circumstances. Samples are taken in accordance with Code of Practice No.7. Where the food is on final sale, the samples may be purchased with or without informing the vendor.
Samples taken can be submitted to the Council’s Public Analyst for his microbiological examination or analysis. The Council is presently contracted to send approximately three hundred and fifty samples to the City of Edinburgh Council Public Analyst and Scientific Advisor. This number includes samples sent from complaints about food.
The Scottish Borders Council fully endorses the Local Authority Co-ordinating Body on Food and Trading Standards (LACOTS) "home authority" principle. This makes it primarily the responsibility of the Local Authority where food is manufactured, to enforce food standards, food hygiene and food labelling legislation. This principle does not exclude enforcement action by authorities wherever food is stored. In accordance with the "home authority" principle, the Scottish Borders Council food sampling programme is predominately composed of samples from premises for which the authority is the home authority. Food manufacturers include catering outlets.
The Food Team Leader, in consultation with the Food Team and the Public Analyst prepares the sampling programme by March each year. It will take into account the number, type, size and risk ratings, both for hygiene and standards, of the food businesses in the area, and the Council's "home authority" responsibility.
A number of on site tests have been developed and are available to the Food Team. Where these are used, the result is normally instant and will be relayed to the proprietor of the food business immediately. These tests are only considered to be indicator tests and will normally be followed up by official samples submitted to the Public Analyst.
Each year a number of nationally and regionally co-ordinated sampling programmes are carried out. The Scottish Borders Food Team participates in these as far as possible, predominantly sampling from manufacturers. In order to maximise the information gained from sampling, the sampling programme will incorporate a number of locally co-ordinated programmes each year i.e. the meat content of sausages throughout the Borders. Local pilot surveys are also used to explore potential problem areas.
The majority of samples will be taken informally, (although often samples for microbiological testing are considered formal as the vendor is informed the sample will be submitted for examination.) Where an informal sample or microbiological sample is considered to be less than satisfactory, the vendor will be informed usually directly, by the officer dealing with the premises, who will discuss the result, try to determine causes and suggest remedies to ensure future samples will be entirely satisfactory. Every informal sample reported result that is unsatisfactory will be followed up in 5 working days. The officer will confirm his findings by letter. Where previous unsatisfactory samples have occurred, a further sample will normally be taken formally, to confirm that defects have been remedied. All unsatisfactory formal samples are discussed with the Food Team Leader, prior to reporting to the Procurator Fiscal.
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