Internal control at tobacco sales outlets
Section 15 of the Tobacco Sales Regulations including explanations of internal controls
The internal control must be adapted to the size, nature, activities and risks of the sales outlet and be of the scope necessary to meet the requirements of the Norwegian Act relating to the Prevention of the Harmful Effects of Tobacco and related provisions. The internal control must be documented in writing and be of the required scope based on the size, nature, activities and risks of the sales outlet. Documentation must be up to date and available to the supervisory authorities at all times.
The internal control should ensure that the responsible parties at each sales outlet:
1. Understand the requirements of the Norwegian Act relating to the Prevention of the Harmful Effects of Tobacco and related provisions that apply to the sales outlet.
Explanation: An internal control must refer to the applicable legal framework, or excerpt/published version of the Norwegian Act relating to the Prevention of the Harmful Effects of Tobacco and the Tobacco Sales Regulations. You can find these on lovdata.no. You can also refer to information on tobacco sales on the Norwegian Directorate of Health’s website.
2. Ensure that all employees at the sales outlet have sufficient knowledge and competence to meet the sales outlet’s requirements, including the requirements for internal control.
Explanation: Employee training must be documented, and show, for example, courses passed or training forms signed by the employees. The employees must be familiar with the sales outlet’s internal control system. It must always be possible to demonstrate the internal control system during an inspection.
3. Understand how the sales outlet is organised and how tasks and responsibilities are distributed.
Explanation: The sales outlet must have an overview of who is responsible for purchasing, training, correcting any non-conformances, and other areas of responsibility. The list must indicate the contact person at the sales outlet in the Tobacco Sales Register and who is responsible for communicating with the supervisory authority in the manager’s absence. It is a good idea to attach a list of employees and an organisation chart.
4. Have procedures for ensuring compliance with the requirements of the Norwegian Act relating to the Prevention of the Harmful Effects of Tobacco and related provisions that apply to the sales outlet
Explanation: Describe what the sales outlet does to comply with the legal framework and to ensure that employees are familiar with the internal procedures. You should have internal procedures to prevent the following:
- Tobacco advertising
- The visible display of tobacco products
- Self-service of tobacco products
- Free distribution of tobacco products
- Sales at a discount
- The sale of packs of less than 20 cigarettes (It is not permitted to sell individual cigarettes)
- The sale of new nicotine and tobacco products
- Sales to minors
5. Have procedures for preventing, detecting and rectifying non-conformances
Explanation: If a non-conformance occurs, it must be possible to document this in order to prevent it from happening again. Non-conformances are documented using a non-conformance form or other suitable documentation. Describe what happened, how you reacted to the situation and how you can prevent the situation happening again.
6. Carry out a systematic and regular review of the internal control
Explanation: The sales outlet must be able to document that the internal control system has been reviewed with the employees. An internal control system that is not used will not contribute to the day-to-day operations. Consider discussing internal controls at staff meetings: Do employees complete a course once a year? When was the last non-conformance? Have any new procedures or laws been introduced that you need to comply with? Remember to document each time the internal control is applied or reviewed.