The Food Standards Agency’s Food Hygiene Rating Scheme could fall into disrepute unless more is done to increase the frequency of re-inspections, according to research carried out by David Edwards.
The UK’s Food Hygiene Rating Scheme (FHRS) is a flagship programme for the Food Standards Agency (FSA) and rightly so. Research described by its chief scientific advisor Professor Guy Poppy underscores why the FHRS is popular with local authority (LA) inspectors, giving them an important and proven tool to drive up standards. Put simply, it works.
First, the source of a rating has to be accurate and honest. We know that consumer-led ratings sites, such as TripAdvisor, while useful are vulnerable to fake ratings. Fortunately, the FHRS is essentially immune to this risk. The FSA has not only wrapped around its scheme a comprehensive set of brand standards and scoring guidelines, the LA inspectors undertaking the ratings are in the main highly professional, expert, and independent. However, they may just be tempted into ‘ratings creep’ if they too find themselves in the spotlight and at the bottom of league tables for performance. Putting that to one side, though, so far so good.
Consumers are also increasingly turning to the ratings for the assurance that they and their families can eat safely. Research has shown that you are twice as likely to experience a food poisoning incident in premises that are not broadly compliant with the FHRS. Experience in Northern Ireland and Wales, where the display of ratings is compulsory, has shown standards rising faster than in England where the display of ratings is currently voluntary.
FHRS ratings are also closely followed by journalists and pressure groups that increasingly benchmark high street brands using FHRS data. As one leading industry commentator has put it: “Consumers are the new regulators.”
Technology-based provider Just Eat has also recognised that it’s impossible for the company to take direct control of standards of businesses on its platform. But, after some hefty media criticism, it has taken the first step by insisting on a minimum rating of 3 and offering up £1m to help its business partners improve. The FHRS is here to stay and it is important.
So, why did I suggest in a recent blog that an intriguingly anonymous new website had the potential to undermine the FSA’s flagship FHRS programme and its essential information service?
Before I explain further, we need to look at two key components to any ratings service.
FHRS inspections must be frequent
Secondly, to be truly effective ratings must be timely. What is the value of an inspection so old as to be almost meaningless in practical terms? Commercial businesses using private inspections to maintain standards re-inspect at least bi-annually in order assure the highest standards. They know up-to-date information on performance is key.
It is therefore vital for FHRS credibility that ratings are not just accurate but contemporary and, I am sorry to report, they are not – at least not in far too many cases. I had an inkling of this issue developing back in April 2017 when my own Freedom of Information (FoI) request about the age of ratings revealed the results shown in the accompany Table.
Table: FHRS ratings in England, Wales and Northern Ireland that are more than two years old
| FHRS rating | Number of establishments where the ratings are more than two years old |
| 5 | 76,378 |
| 4 | 21,531 |
| 3 | 7,030 |
| 2 | 949 |
| 1 | 646 |
| 0 | 15 |
| Total | 107,049 |
Frankly, it’s not as bad as I suspected given how severely LA resources have been hit over recent years. But it still means that there are more than 1,600 premises rated as less than broadly compliant (ie with ratings below 3) that have not been re-inspected for over two years – and, remember, you are twice as likely to get sick in these. Tell me a consumer who would be happy with that?
And, who is to say the total of 104,939 businesses with ratings (3-5) more than two years old remain broadly compliant?
Here is another worry: re-rating by self assessment. Anecdotal evidence suggests many LAs are re-rating, or should I say ‘re-dating’ ratings based on self assessment. Really? Is that credible? A quick check in my own county illustrates the risk to the FHRS brand standard.
I know of a sad pub. It’s dreadful: smelly, dark, dirty, to the point where only a hard core drink bottled beer there almost as a social service. Yet it has a very current FHRS rating of 4! How on earth did that happen? I checked and the explanation was self assessment. No one in their right mind would give the place a rating above 1, whatever it sells. I am not saying there is a risk to public health here but for sure there is a risk to the credibility of the FHRS brand and that matters if the FSA is to retain public trust.
Website rates business and LAs
Back in 2017 I began to have concerns. But I have recently become aware of a new consumer service and website OmgOmg.co.uk that has thrown an even more uncomfortable spotlight on the issue in a way that really underscores just how important the need is to act before the FHRS loses the confidence of the very people it is designed to protect.
So, what
has the website OmgOmg.co.uk done? OmgOmg.co.uk has started to assess the
performance of not just the businesses but the LAs inspecting them. Naming and
shaming can work both ways. Most LAs do a great job in difficult circumstance,
but a number do not. At least that’s what the analysis from OmgOmg.co.uk suggests.
Currently, I have no way of validating the accuracy of the website because it provides no contact information whatsoever. And you might disagree with how LAs are rated. But here are a couple of snippets that caught my eye.
For no particular reason other than it used to be my county town, let’s take Northampton. The OmgOmg.co.uk website tells us a pretty shocking 10% of ratings are older than five years, and the oldest rating is 13.3 years – against a national average oldest rating of 8.1 years, which is hardly impressive in itself. Going a little further north, Corby comes in with 19% of ratings older than five years. And, as for Scotland, well that nation’s results would be laughable if it wasn’t such a serious issue.
Ways to build consumer trust
So what’s to be done? Here are five suggestions
- Update all ratings of high-risk premises to under two years – preferably annually. The FSA has £14m to spend on issues related to Brexit. How better than to give consumers real – rather than fake – informed choice by funding those updates. At commercial rates, £14m would fund at least 100,000 visits.
- The FSA needs to engage with LAs at the bottom end of the OmgOmg.co.uk league tables and find out what’s going on – or, rather, what’s not going on. Why are they so laggardly and why are ratings posted sometimes months after visits?
- Self assessment is ridiculous for something so important. Where it is identified, it should be stopped. That said, quick and efficient re-assessment has a role to play, particularly if provided by professional third parties. There is also software out there, such as Report Drop, that allows businesses to share evidence on performance and compliance, avoiding wasted visits and building confidence.
- Here is a radical idea: could the Chartered Institute of Environmental Health (CIEH) get together with LAs and offer training for a citizens’ army of food safety coaches and advisors? We are perfectly happy for organisations like St John Ambulance to provide skilled emergency medical services at local events. Why not food safety inspections? Maybe an on-demand service as self-funded community support.
- Get more efficient so more inspections can be done. The private sector uses all sorts of highly efficient inspection software and motivational tools to maximise productivity and reduce downtime. They’re out there for goodness sake, use them – and help LAs know about them. Identify best operational practice, which is something for professional bodies like the CIEH and Chartered Trading Standards Institute (CTSI) to work on.
In conclusion, I gave serious thought as to whether to publish this blog because it highlights problems that could undermine the FHRS. But that’s my point: we need the FHRS to maintain and build on the trust it already has and, unless robust action is taken by the FSA and LAs, all that is at risk.
So, my plea to the FSA is: don’t circle the wagons – act now!
Biography
David Edwards MCIEH was co-founder in 1985 of the food safety consultancy CMi plc, one of the leading businesses of its kind, which was sold in 2007 to NSF International. As well as building a business that employed over 200 full-time food safety and technical experts, Edwards has provided advice at board and strategic level to many leading companies over a career lasting 40 years. He has been a director of the Chartered Institute of Environmental Health (CIEH) commercial board, is a member of the government’s Better Regulation panel, and is currently a non-executive director of several companies operating in the field of food technology and software. He is a director Bayesian Ltd, Tascomi Ltd and ReportDrop Ltd. Edwards was awarded the CIEH lifetime achievement award in 2017. In his spare time, he works pro bono for charitable organisations and is an active supporter of Shelter and the Samaritans.