Wafer thin resources and the emergence of new business models are giving regulators plenty to ponder as they try to keep our food safe. Nick Hughes reports.
The system designed to keep the UK’s food safe is straining at the seams. The alarm was sounded last month by the Food Standards Agency (FSA) and Food Standards Scotland (FSS) who warned that the UK’s ability to carry out critical food safety and standards checks in food businesses is at risk of being undermined by a shortage of key workers like hygiene inspectors and vets.
Although the total number of reported food incidents across the UK decreased slightly in 2022 compared to 2021, and remained broadly consistent with long-term trends, years of cuts to local authority budgets and enforcement teams are heaping pressure on a system that is already having to evolve to keep pace with the changing way we buy and consume food.
The regulators, in their joint annual review, said that unless gaps were plugged in key occupations needed to keep food safe it would be more difficult to identify, monitor and respond to risks to food safety, leaving consumers and businesses vulnerable.
How worried should we be? And how are regulators responding to these ever-growing pressures?
Covid changes everything
The covid-19 pandemic changed the enforcement landscape by forcing many food inspections to take place remotely. It also spawned a host of new start-ups, many of which didn’t even consider themselves to be food business operators.
Although data is hard to come by, enforcement professionals agree there has been a significant rise in the number of people preparing food in their own domestic kitchens to sell direct to the public online through social media platforms and other direct networks. Many of these individuals have not registered as food businesses meaning the majority will be unknown to environmental health and trading standards teams.
Amid dwindling officer numbers, local authorities have struggled to keep pace with demand for checks. The FSA’s analysis of local authority staffing shows there are approximately 14% fewer food safety posts being funded across England, Wales and Northern Ireland compared to a decade ago – and even where these posts do exist, over 13% are vacant.
The number of UK food standards officers has fallen even further – by 45% compared to 10 years ago. Meanwhile the UK veterinary profession has experienced a 27% decline in people joining it between 2019 and 2022, creating significant challenges in securing the vets needed to verify that animal health and welfare standards are being met.
Hygiene holds up
The raw data on businesses adhering to food hygiene standards suggests most businesses continue to take their responsibilities seriously. Just over three-quarters (75.7%) of food businesses in England, Wales and Northern Ireland achieved a top rating of five for hygiene in 2022, while 2.9% of businesses achieved a rating of two or below meaning they require improvement, major improvement, or urgent improvement.
Yet although inspection frequencies for food hygiene have gradually returned to pre-covid levels, there were still approximately 39,000 businesses awaiting a rating as of April 2023 across England, Wales and Northern Ireland.
Risk-based approach
The mismatch between the supply of inspectors and demand for their services is in part why the FSA is overhauling the way it delivers food standards controls. Future food enforcement in England and Northern Ireland will help local authorities take a more risk-based and intelligence-driven approach to inspection, focusing their time and resources on food businesses that pose the greatest risk to consumers. In essence, non-compliant businesses will face more frequent physical checks than businesses that can demonstrate good levels of sustained compliance.
Since April, the FSA has been running a trial with five leading grocery retailers to see whether it is possible to make a business level, data-led assessment of their systems and processes, supplemented with some appropriate checks on the ground.
Speaking at the recent Chartered Institute of Environmental Health (CIEH) annual food safety conference, Katie Pettifer, FSA director of strategy and regulatory compliance, insisted the new regime did not amount to self-regulation. “Businesses are still being regulated,” she said. “We’re just trying [to determine] whether we can carry out checks in a different way by looking at different things.”
Digital growth
Alongside there being fewer boots on the ground, a change in the way food is sold outside of the home has made old models of regulation increasingly unfit for purpose. Traditional linear foodservice models whereby producers sell through wholesalers to pubs and restaurants are being displaced by digital ecosystems of foodservice providers – think Just Eat or the person selling home-produced food on Facebook.
This fragmented, dynamic landscape presents both challenges and opportunities for regulators like the FSA. The growth of food aggregators like Just Eat, Deliveroo and Uber Eats adds an extra link in often long, complex foodservice supply chains; but it also presents the opportunity to reach thousands of small businesses by engaging with three giant ones.
The FSA has been working with the market leading trio on the development of a voluntary food safety charter which includes good practice ground rules like only accepting registered businesses onto their platforms and requiring sellers to achieve minimum food hygiene rating scores. “These three platforms are used by tens of thousands of food businesses and millions of consumers so they have the potential to really drive good practice [….] through the rules that they set,” said Pettifer.
Food aggregators are relatively easy to work with, according to Pettifer, because they are focused solely on food. Regulating food sold via Facebook and other social media platforms is an altogether tougher nut to crack. To-date, the FSA has failed in its attempts to encourage Facebook to set specific rules for those people selling food via its platform. “We are a tiny, tiny fish in a much bigger pond of consumer protection issues,” admitted Pettifer, who went on to suggest that rather than the FSA engage with Facebook individually “we need to try and make common cause by joining up with other regulators in other sectors rather than just thinking about food”.
Kitchen nightmares
A new piece of research commissioned by the FSA lays bare some of the risks associated with people preparing food in their own homes. The Kitchen Life 2 project installed motion-sensitive cameras and fridge thermometers in 101 kitchens to explore approaches to food hygiene. Supplemented with interviews, the research found that almost half of the time, householders who took part only rinsed their hands with water and did not use soap when preparing meat, fish or poultry, thus exposing themselves to potential foodborne illness. The study also found that over half of households who installed a thermometer in their fridge had an average temperature higher than the recommended maximum of 5°C, risking the growth of harmful bacteria.
The use of so-called ‘dark kitchens’ – satellite sites without a customer-facing store front set up by established brands or online-only operators to meet demand for food deliveries – is another new(ish) route to market that has regulators scratching their heads for how best to respond.
Footprint has previously detailed the myriad ways in which rules could be ignored – either intentionally or unintentionally – in a dark kitchen environment, for instance over the provision of accurate allergen information to the end customer. Academics from Lancaster University and Teesside University told the CIEH conference how they are looking to gain funding for a research project looking at how local authorities can effectively monitor, evaluate, control and work with dark kitchens to support population health.
The research proposes to fill existing data gaps by asking whether current monitoring systems capture information around dark kitchens and the types of food they are providing, and to understand how dark kitchens might impact on diets and ultimately on health.
It’s further evidence that regulators, and those that influence the regulatory sphere, are acutely aware of the challenges facing food law enforcement. How to deal with those challenges in the face of dwindling resources is another question entirely.
