We had a short virtual meeting with the new chair of the Food Standards Agency (FSA) Professor Susan Jebb and some of their senior civil servants last Monday 27th September to discuss our concerns over the Agency’s Future Delivery Model etc. which is part of the FSA’s Operational Transformation Programme.
Whilst the Agency claimed that the changes they were proposing were to supplement the existing inspection regime with more technological data, they could give no assurances that there would not be less physical or hands on inspections.
Along with third party assurance rather than truly independent inspections without fear or favour the Agency’s written proposals also indicate that they are considering remote audits.
The Agency tried these remote audits and commissioned a report by ICF Consulting Services Ltd “Evaluating the use of remote assessments by local authorities for regulating food businesses” that was published in March 2021.
This small study, I believe, indicated some serious flaws in remote assessment and such approaches such as stated on page numbered 21 in the attached link below.
“RAs ((Remote Audit’s) providing an opportunity for FBOs (Food Business Operator’s) to falsify/conceal issues in preparation for site visits by FBOs being pre-warned (raised by 11 LAs, 5 of whom felt FHRS (Food Hygiene Rating Scheme) scores awarded in pre-arranged visits had been inflated artificially)”.
“likelihood of not identifying all the problems with FBOs (Food Business Operator’s) during a RA (Remote Audit) identified by 8 LAs, (Local Authorities) 3 of whom had observed inconsistency during later site visits with evidence FBOs gave remotely”.
“Most officers (Environmental Health Officers or Practioners EHO’S or EHP’S) also expressed that the overall time spent doing inspection work had increased since they started using RAs in conjunction with onsite inspections (raised by 11 LAs, and implied by the remaining 7), as they now had to:
do additional administrative work (e.g. gathering and locating up-to-date FBO contact details), chase FBOs who did not respond to outreach (e.g. who deliberately ignored calls or emails, or who said they were too busy – one officer said, ‘a lot of our businesses will put the phone down if they know who you are’), wait for FBOs to provide the correct documents, have ‘long-winded back and forth email explanations’ with FBOs and other LA staff who struggle with technology, about what is required and how to send it, tease out information from FBOs who do not offer it willingly during a RA, through direction and conversation (one officer explained that ‘the FBO tells you what they think you want to hear – they won’t say that it’s filthy under the cooker, so getting to the truth could be a slow process’), and five LAs expressed that not being able to rate or re-rate businesses based on remote work alone was perceived by some officers on their teams as a limitation of using RAs. Inability to use RAs on their own to clear rating backlogs and to fulfil re-rating requests had made some officers reluctant to devote their time to it, as they would still be required to go onsite to complete work, taking longer overall than if they had just visited businesses”.
https://www.food.gov.uk/sites/default/files/media/document/remote-assessments-report.pdf
We pointed out at this meeting that in relation to their current audits of meat plants that in the FSA’s Performance & Resources Report in period Q1 2021/2022 it showed that 60.02% were good and 37.73% were generally satisfactory, with 1.9% requiring improvement necessary and 0.34% requiring urgent improvement.
In relation to the 37.73% that were generally satisfactory, the majority of these had ONE major non-compliance at the initial time of the audit. This means that at the start of the audit those with a major non-compliance were in breach of hygiene legislation. This bears out what the Bureau of Investigative Journalism discovered in their reports in 2017 and 2018.
It is therefore important to keep bacterium out of the food chain as far as is possible, because if you suffer from Haemolytic Uraemic Syndrome (HUS) caused by bacterium such as E.coli O157 there is no specific treatment or cure to prevent long term kidney problems, brain damage etc. or even death.
We also pointed out that In March 2020 the FSA published “The Burden of Foodborne disease in the UK 2018”.
This report states on page numbered xi.
“Microbiological foodborne disease (FBD) places both a public health and financial burden on society. In 2018 there were estimated to be 2.4 million FBD-related cases in the UK”.
It goes on to say on the same page: “Based on 2018 case estimates, FBD costs society approximately £9.1bn a year”.
When we asked at this meeting about the FSA’s proposal in relation to legislative change they said they intended to introduce primary legislation.
This may mean they intend to lower food safety standards, but we will have to wait and see in the early part of the new year (Possibly March) what their proposals are in relation to any changes from the current legislation.
Given the Northern Ireland protocol and the EU, the FSA officials will have to be careful particularly in relation to food exports to the EU, as the EU have already stated they will not accept a lowering of our standards in relation to what they import from GB.
For the domestic market including imports consumers have already shown in previous research and reports they do not want a lowering of their food safety standards. At this virtual meeting we provided evidence of this including reports commissioned by the FSA.
Recently the Government published what they called an independent National Food Strategy, chaired by Henry Dimbleby a British businessman and cookery writer who is a co-founder of Leon Restaurants and the Sustainable Restaurant Association.
This is a very good report but unfortunately it hardly mentions foodborne illness. We can only presume that the author(s) forgot to seek the views of those who have had experience of this, as this should be included in any National food strategy.
In relation to this we will shortly be writing to the officials of the Department of the Environment Food and Rural Affairs (DEFRA) who are drafting advice to ministers and writing a white paper, to ask them to include this issue.
Many thanks to Paul Bell of Unison the National Officer for Meat Hygiene Inspectors who attended this virtual meeting to warn the FSA of the problems that could occur in relation to consumer safety and Sean Humber (of Leigh Day & Co) our pro bono lawyer who has helped over the last 25 years to help prevent foodborne illness by engaging with Government to prevent such.
