This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan Consented version no. Primary Authority Inspection Plan Date, version no. [this should be used to track dates and document versions during development and submission. It will be changed by BRDO on consent] Developed by "[click & insert LA name]" in support of the partnership between "[click & insert business name]" & "[click & insert LA name]" This Inspection Plan relates to the following category of legislation: 1. "[click & insert category covered by the plan]" Note: The content of this Inspection Plan may contain Confidential and Commercially Sensitive information. Please seek the approval of the Primary Authority before sharing this inspection plan with other businesses. Contacts: Principal Contact at "[click & insert LA name]" is: Name: Address: Telephone No: Role: E Mail: Principal Contact at "[click & insert Business name]" is: Name: Address: Telephone No: Role: E Mail: This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 1 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan Consented version no. 1. SUMMARY OF INSPECTION PLAN REQUIREMENTS Reproduce, in brief, the key requirements included in Part A of the plan. These should make clear what local authority officers must do, and anything they must not do, in order to follow the plan. Anything else will be at the officers’ discretion. The key elements listed here must align with the content set out in the body of the plan. Explanations relating to the statutory basis of the scheme should not be included here. These are covered in the body of the plan. A reference to the need to provide feedback should be included, for example “Feedback is required on inspection activity undertaken, as specified in sections [specify relevant sections] of this plan. The feedback must be provided as soon as reasonably practicable after the inspection has been undertaken [include instructions on how the feedback is to be provided – this will typically be via the Primary Authority Register]. This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 2 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan Consented version no. CONTENTS 1. SUMMARY OF INSPECTION PLAN REQUIREMENTS ..............................................................................2 2. Overview ...............................................................................................................................................4 3. Scope .....................................................................................................................................................4 Part A: Inspection Plan Requirements ........................................................................................................5 4. National inspection strategy co-ordinated by the primary authority...................................................5 5. Inspection activities that are not to be undertaken locally ..................................................................6 6. Policies / procedures that are not to be checked locally ......................................................................6 7. Targeting of local inspection activity ....................................................................................................7 Part B: Information to support local authorities ........................................................................................7 8. Information to guide local inspection activity ......................................................................................7 9. Risk rating..............................................................................................................................................7 10. Obtaining information from "[click & insert business name]" .............................................................8 11. Communication .....................................................................................................................................8 12. Document Control.................................................................................................................................9 13. Inspection Plan Rationale – Summary of Evidence ............................................................................ 10 This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 3 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan 2. Consented version no. Overview Suggested content: Include a very brief overview of the business, detailing any points that will be of particular interest to local authorities, for example where there might be confusion about the premises operated by the business because it trades under a number of different names or because it franchises its operations. Where the primary authority wishes to provide more detailed background information about the business or about its general approach to compliance, this can be made available via the partnership’s page in the secure IT system, and referenced here. Where the primary authority wishes to provide further information about the business’ approach to compliance in specific areas, which is of relevance to the content of the inspection plan, this can also be made available via the partnership’s page, and referenced here. If it would be helpful for local authorities, include a brief explanation of the basis of the plan and an outline of its key objectives. The objectives should be specific to the plan. Refer to any national regulators that were consulted as part of the development of the plan. Many inspection plans will include both elements that impose requirements on local authorities and elements that are for information or are suggestions only – it is important that these are clearly distinguished. A general point to bear in mind is that the inspection plan should be as concise as possible, while still providing the essential information needed for it to achieve its objectives. For those sections under Parts A or B for which you have no requirements or suggestions to make, these sections should be deleted and the inspection plan contents list amended accordingly. Note that a sample inspection feedback form is made available by BRDO. Use of this form is optional and it can be modified to suit your particular inspection plan. 3. Scope 3.1 This inspection plan aims to deliver improved local regulation in the following category of regulation, which is covered by the partnership: "[click & insert the category covered by the plan]" 1 The geographical scope of the category covered by the plan should be set out in a footnote. For example, for the Food Safety and Hygiene category: “Applicable in England and Wales. Not 1 Insert details of the geographical scope of each category This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 4 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan Consented version no. applicable in Scotland or Northern Ireland”. Details of the geographical scope of each category can be found in the List of Primary Authority Categories. 3.2 The plan applies to "[click & outline scope in terms of premises etc]" 3.3 This plan applies to all inspection activity undertaken with respect to "[click & insert business name]" . ‘Inspection activity’ in this context is defined widely in the Primary Authority Statutory Guidance, and, for the purposes of this plan it covers proactive, planned or programmed regulatory interventions including : [inspections; test purchases; sampling visits; other checks on compliance, including those undertaken as an alternative to a premises visits; and advisory visits. Delete as appropriate] 3.4 Reactive interventions undertaken in relation to matters of specific concern about "[click & insert business name]" are outside the scope of this plan. This would include matters of specific concern that arise during a proactive intervention, i.e. while on site officers can legitimately take an alternative approach to that set out in the plan if problems are identified that need to be investigated. Where they have the opportunity, local authorities may find it useful to contact "[click & insert LA name]" in the first instance to obtain any background information that may be relevant to the particular issue of concern, and to avoid potential duplication of effort. Part A: Inspection Plan Requirements Local authorities must follow the requirements contained within Part A of the Plan. Should any local authority, having considered this plan, wish to follow an alternative approach to that set out in Part A, they must first make a request to "[click & insert LA name]" via the Primary Authority Register, setting out their proposed approach and their reasons for it. The alternative approach may be followed where agreement is given by the primary authority, or where no response is received within 5 working days. "[click & insert LA name]" would welcome contact from local authorities which may be considering following an alternative approach to this plan, where a discussion may be of assistance. 4. National inspection strategy co-ordinated by the primary authority Suggested content: Outline any national inspection strategy which the primary authority has undertaken to co-ordinate. It is expected that any national inspection strategy will include a requirement for participating enforcing authorities to provide specified feedback that will be relevant and useful. This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 5 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan Consented version no. Suggested text: Inspection activity undertaken at premises operated by "[click & insert business name]" must only be undertaken by those local authorities participating in the national inspection strategy co-ordinated by "[click & insert LA name]" . Local authorities wishing to participate should contact "[click & insert LA contact name]" at "[click & insert LA name]" . 5. Inspection activities that are not to be undertaken locally Suggested content: The systems that a business has implemented for securing compliance may operate in whole or in part at the head office level rather than locally, and in these respects the primary authority may have agreed to take responsibility for checking that the system is being implemented effectively. In these circumstances the primary authority may stipulate that the same checks must not be undertaken locally. Suggested text: Local authorities must not undertake compliance checks in relation to the matters listed below. The compliance performance of "[click & insert business name]" in these areas has been assessed and is being monitored by "[click & insert LA name]" at a national / regional [delete as appropriate] level: [list and describe the relevant areas of the business’ operations] 6. Policies / procedures that are not to be checked locally Suggested content: Where a primary authority has issued Primary Authority Advice to a business in relation to specified policies or procedures, indicating it is satisfied that these are capable of delivering compliance in a particular area if properly implemented, then it may specify here that those policies or procedures must not be reviewed at a local level to assess their adequacy or suitability (though it may be appropriate for local authorities to assess their implementation – see under 7 below). Suggested text: Local authorities must not review the following policies / procedures for the purposes of assessing their suitability or adequacy. These policies / procedures are centrally controlled by "[click & insert Business name]" and are checked at a national level by "[click & insert LA name]" . Instead, inspection activity should focus on their local implementation, as set out in section 9 below. In doing so, if a potential problem with the policy or procedure at a national level is identified, this should be fed back to "[click & insert LA name]" . This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 6 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan 7. Consented version no. Targeting of local inspection activity Suggested content: Detail those areas where local inspection activity must be focussed. For example, where the primary authority has analysed business compliance data, complaints referred by local authorities, and / or feedback from local authority inspection activity, it will be in a position to identify the areas of the business where the risks of non-compliance are most significant. It should be made clear whether inspection activity undertaken in such areas is ‘in addition to’ or ‘in place of’ the areas that a local authority officer would typically cover during an inspection, and a basic explanation of the reasons for focussing activity on these specified areas should be provided if this would not be evident. It is expected that any instructions relating to the targeting of inspection activity will include a requirement for enforcing authorities to provide specified feedback that will be relevant and useful. Suggested text: Local authorities must target their inspection activity on local compliance in the areas detailed below, and provide feedback to "[click & insert LA name]" on their findings. Other areas must not be included within the inspection / can be included within the inspection in accordance with normal procedures [delete as appropriate]. Part B: Information to support local authorities Part B of this plan does not impose requirements on local authorities. It contains suggestions or content that is for information only. 8. Information to guide local inspection activity Suggested content: Provide any general information that could assist local authority officers when undertaking local inspection activity. For example, this could relate to certain documents that should be kept on site and where on site they should be located; which tier of local management can be expected to assist on particular issues; key contacts on site; etc. 9. Risk rating Suggested content: Detail any recommendations made by the primary authority in respect of risk rating the premises or activities of the business. This section may also be used to outline the primary authority’s expectation of the risk scores that it would usually be appropriate to award in respect of specified elements of national risk rating schemes (note that with regard to ratings of confidence in management or similar, it should be made clear that the primary authority’s expectation of the risk score would need to be balanced with the officer’s local assessment, in determining the appropriate score). This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 7 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan Consented version no. 10. Obtaining information from "[click & insert Business name]" Suggested content: Include here any references to information contained in your partnership page on the Primary Authority Register (or elsewhere - include links where applicable) that it would be useful for local authorities undertaking inspection activities to be aware of. It will be particularly useful to highlight information that local authorities might otherwise seek to obtain directly from the business, including via self-inspection questionnaires. 11. Communication Suggested content: Detail any guidance on the most effective means of communicating with the business and/ or the primary authority. This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 8 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan Consented version no. 12. Document Control Amendments to this document will be made in consultation with "[click & insert business name]" , where appropriate. Amended versions of the plan will be published via the Primary Authority Register following consent from the Secretary of State. [use this section to detail the most recent amendments to the plan. This will help enforcing authorities to identify where a plan has been amended in a minor way, e.g. by updating contact details, and where there have been more significant change, e.g. the addition of a category of regulation]. Date Nature of amendments Made by Version No. This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 9 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan Consented version no. 13. Inspection Plan Rationale – Summary of Evidence [NOTE: Data provided in this section will be shared only with relevant national regulators and policy departments. This section is used by the Secretary of State to inform the decision on consent and will be removed from the Inspection Plan prior to publication] Primary authority Contact at primary authority Regulated person(s) Categories covered by inspection plan Please identify whether protective marking should be applied to the published plan (e.g. Confidential / Commercially Sensitive) Please indicate the proposed duration of the plan, from the date of the Secretary of State’s consent The maximum duration set out in the Primary Authority Statutory Guidance is 18 months 1. Primary aims of inspection plan Include here brief details of the aims of the plan 2. National regulators’ inputs Please confirm that details of the proposed plan have been sent to all relevant national regulators during its development, and summarise any issues raised and the outcome. Also include brief details of any input to the development of the plan by any other bodies, e.g. any other primary authorities with which the business has a partnership. 3. Business’s current experience of local regulation a. Include here an outline of the business’ current experience of local inspection activity e.g. programmed inspections / test purchases / sampling. b. Where the inspection plan seeks to address issues the business currently has with local inspection activity, include here an outline of what those issues are, e.g. need for improved feedback, better consistency, etc. This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 10 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan 4. Primary authority inputs Consented version no. a. Include here details of any relevant compliance monitoring undertaken by the primary authority e.g. where an audit has been undertaken of compliance with a particular company procedure, and / or of compliance with legal requirements. b. Where a plan includes requirements against reviewing specified policies or procedures of the business to determine their suitability or adequacy, the primary authority should confirm that it has reviewed the relevant policies / procedures, and that Primary Authority Advice has been given to the business on these matters. c. Where consideration of particular policies or procedures has been critical to the primary authority’s development of the plan, these should be listed (with dates / version numbers). d. Where a plan excludes certain areas of the business’ activity from local inspection, the primary authority should set out how it will ensure that the business’ compliance in these areas is monitored. e. Where a plan includes requirements in respect of the focus of local inspection activity, the primary authority must provide an explanation for the activity that is specified as being necessary, unless this is included in the plan. f. Where a plan includes requirements for specified inspection feedback, the primary authority must provide an explanation as to why the feedback is relevant and how it will be of use. g. Where a plan includes suggestions in respect of risk rating the business’ premises or activities, the primary authority should explain the basis on which it has made a suggestion that a particular risk score or risk rating applies. 5. Proposal to review and evaluate the success of the plan a. Include details of how and when the primary authority proposes to review the impact of the inspection plan, and its success in delivering the primary aims identified. BRDO will expect to see the results of this review when a new or revised inspection plan is submitted for consent e.g. on expiry of the current inspection plan. The following section should be completed where the plan sets out a national inspection strategy. This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 11 of 12 This header will be completed by BRDO with the business and local authority details, and a version number for the consented plan. Please note in the Rationale at section 13 whether this plan includes content that is Confidential or Commercially Sensitive. Primary Authority Inspection Plan 6. Management of national inspection strategy Consented version no. Outline any area where the primary authority is proposing to co-ordinate a national inspection strategy, including details of: whether the strategy seeks to control the level of local inspection activity and, if so, explain the proposed controls; how the strategy will be managed, including how the primary authority will ensure that it is responsive to changing circumstances; the method that will be used for securing specified activity by particular local authorities (where the strategy is reliant on this activity taking place); the feedback that will be required from participating enforcing authorities; how the effectiveness of the strategy will be evaluated; and the primary authority’s evaluation of the effectiveness of any national inspection strategy included in a previous plan to which the Secretary of State has consented. This footer will be completed by BRDO with an Issue Date and Expiry Date. Please include details in the Rationale at section 13 of the primary authority’s proposed duration for the Inspection Plan Inspection Plan Template, effective 1.10.13 Page 12 of 12