UK-WIDE FOOD HYGIENE RATINGS STEERING GROUP
Inter-sessional paper
February 2016
National consistency exercise – summary of findings
Issue
1.
This paper reports on the findings of the first national consistency exercise
organised and run by the Food Standards Agency (FSA) and on the actions being
taken following this.
Steering Group Action
2.
The Steering Group is asked to:

Note the results of the scoring and rating exercise;

Note the feedback on the issues that influenced the scoring/rating
decisions; and

Note the next steps being taken.
Background
3.
Consistent operation of the Food Hygiene Rating Scheme (FHRS) is critical to
ensuring that consumers can make meaningful comparisons of hygiene ratings for
establishments within and across different local authority areas, and to ensuring that
businesses are treated fairly and equitably. Ratings are calculated using the scores
assigned by food safety officers using the food hygiene intervention rating scheme
as set out at Chapter 5.6 of the Food Law Code of Practice. Consistency in applying
these scores is of key importance.
4.
The FSA has a role in monitoring consistency and the FHRS Brand Standard
highlights that this may include the development and organisation of national
consistency exercises. The first such exercise has recently been completed.
5.
The exercise is part of a wider programme of FSA work to monitor
consistency of application of the Brand Standard (and the statutory guidance in
Wales) and to identify areas of potential inconsistency for which additional FSA
support may be needed.
Exercise scenario
6.
Local authorities in England, Wales and Northern Ireland were asked to
assess an online scenario. The subject of the exercise was a restaurant and the
setting was a routine planned intervention. The online materials provided included
background on the business and the food business operator (FBO) and staff,
previous intervention history, a narrative for the current inspection with staff
interviews, and some short video clips.
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7.
The main challenge of the scenario was the
approach taken by the FBO to avoiding crosscontamination between raw and ready to eat food.
Control was through the use of large cutting boards
and a scrupulous cleaning regime.
8.
Local authority food safety teams were asked
to consider the scenario and to agree hygiene
intervention rating scores and the associated food
hygiene rating and to report these to us.
Subsequently, and to help us understand the results
and put them in context, local authorities were asked
for feedback on the arrangements and instructions
provided to them, the level of information provided in
the scenario materials and on the issues which most
influenced their scoring decisions.
Participation
9.
There was a very good response to the exercise. All 11 local authorities in
Northern Ireland, 21 out of 22 in Wales and 309 out of the 325 in England operating
FHRS - approximately 95% overall - participated.
Expected outcome
10.
The expected outcome of the scenario, in the form of the inspecting officer’s
report, is provided at Appendix A. In essence, the business was operating to a good
standard of compliance, with just a few minor contraventions. The expected food
hygiene rating was ‘5’ with underlying intervention scores of 5/0/5 for hygiene and
safety procedures, structure and confidence in management/control procedures
respectively.
Results
11.
The distribution of food hygiene ratings given as a whole and by country are
shown at Table 1. The most frequent result overall was in line with the expected
outcome with 181 (53.1%) local authorities giving the business a ‘5’ rating. As
expected for a desktop exercise, there was a broad variation in the scores/ratings
given. Figure 1 shows the frequency of intervention rating scheme scoring patterns
banded by food hygiene rating.
Table 1: Rating distribution by country
Ratings
5
No.
4
%
No.
3
%
2
1
0
No. % No. % No. % No. %
Total LA
responses
Total across
three countries
181 53.1 99 29.0 32 9.4 12 3.5 16 4.7
1
0.3
341
England
163 52.8 88 28.5 29 9.4 12 3.9 16 5.2
1
0.3
309
Wales
9
42.9 10 47.6
2
9.5
0
0
0
0
0
0
21
Northern Ireland
9
81.8
1
9.1
0
0
0
0
0
0
11
1
9.1
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Figure 1: Food Law Code of Practice intervention rating score pattern frequencies
Feedback
12.
There was a good response to this part of the exercise with 146 local
authorities providing feedback. These responses and liaison with local authorities
through the FHRS User Groups and Food Liaison Groups highlighted that local
authorities very much welcomed the exercise and its aims.
13.
Generally, the arrangements and instructions were found to be clear to follow,
and the scenario material was easy to access and use.
14.
A number of factors have been identified that led to different scores being
given and these fall into two broad areas: practical issues; and interpretation of
policy/guidance.
Practical issues
15.
The video clips were very short and limited in what could be seen and
additional information about the business was needed to simulate more closely what
an officer would see or be able to access at the time of inspection. The lack of
information led to some teams over-analysing matters and having access to a
completed aide memoire, officer notes and a scale plan of the premises may have
reduced the number of assumptions that were made and led to more consistent
assessments.
16.
Of greater significance was the inability of officers to ask the food business
operator or staff any follow up questions to probe further or clarify matters and this
led to an overly precautionary approach being taken.
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Interpretation of policy/guidance
17.
Three main issues have been identified as having most influence on the
decisions made by those that gave intervention rating scores higher than was
expected:
 Sous vide – Sous vide was mentioned in the previous inspection report but not in
the scenario materials which led to some teams speculating about whether or not
a suitable process was in place.
 Cleaning practices and layout – Although there was no evidence of
contamination (so not a contravention), some teams had concerns about the use
of reusable wiping cloths and other aspects of the cleaning regime.
 Avoidance of cross-contamination - The most common influencing factor was
reservations about the approach to avoiding cross-contamination between raw
and ready to eat food where some teams would have recommended designating
separate areas for handling and preparing RTE food on a permanent basis.
18.
It is recognised that inconsistency on some of these points may have been
reduced significantly by placing more emphasis on the instruction provided that,
where no information on a matter was given, officers should assume that were no
adverse food hygiene issues at the time of the inspection.
19.
That said, the inconsistencies observed point to some local authorities, in this
online scenario situation at least, not having due regard to the FSA’s E Coli control
of cross contamination guidance that allow a business to demonstrate that it can
achieve the objectives of the hygiene regulations in other ways. It also pointed to the
need for further clarification on applying the Code of Practice intervention-rating
scheme in respect of confidence in management. The benefit of covering these
issues in future FSA organised and funded consistency courses is recognised.
Conclusions
20.
The level of participation and the positive feedback received through the
FHRS User Groups and Food Liaison Groups highlights that our local authority
partners in the FHRS are committed to ensuring consistency between officers and
between local authorities. They are acutely aware of the need to operate the
scheme fairly and equitably to ensure its credibility is not compromised.
21.
Scenario-based exercises of this type cannot replicate a ‘real time’ inspection
and the limitations must be recognised. The exercise was, in effect, about matching
the appropriate scores to the description of compliance that was provided. Routine
inspection skills to probe and challenge rather than take matters at face value are
not readily transferable to exercises but are more likely to generate speculation in
team discussions where clarification cannot be provided by the food business.
22.
The results must be considered within that context. They do, nonetheless,
indicate areas where more attention needs to be given through FSA training
provision and to clarifying understanding and interpretation of guidance to further
improve consistency in delivery of the scheme.
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Next steps
23.
This exercise is part of a wider programme of work on monitoring and
improving consistency in application of the FHRS Brand Standard. The other
elements are a programme of FSA funded Inter- Authority Audits and a series of
FSA audits focussed on FHRS. These are due to be completed by the end of
March. Following that we will consider the results of all three exercises and identify
issues where further support, guidance and training is needed.
Steering Group Secretariat
February 2016
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Appendix A – Food hygiene report
Name of the food business
operator/food business proprietor
Serge Truscott
Business name
CARIB BAYOU
Business address
23 High Street
Fulchester
Date of inspection
01.10.2015
FOOD SAFETY AND HYGIENE (ENGLAND) REGULATIONS 2013
EC REGULATION 852/2004
HACCP – Food Safety Management
1. You are currently using the “Safer Food, Better Business” pack as your documented food
safety management system. All of the safe methods were completed in the pack and there
was good evidence that you were actually following these safe methods except in relation to
the matters referred to in paragraphs 3 and 5 below. A number of staff were interviewed and
showed good awareness of the safe methods and food hygiene in general. It was noted,
however, that a number of diary sheets were not signed off in your folder.
2. Temperature Control: Satisfactory at the time of the inspection. Whilst it was noted that
the alarm on the main kitchen fridge was set at 12ºC, there was no evidence to suggest that
food was stored at inappropriate temperatures.
3. Contamination Prevention Whilst it would be best practice to use separate work
surfaces for the handling of raw and ready to eat foods it is accepted that to do so in your
kitchen may lead to operational difficulties. It was noted that you have chosen to use colour
coded chopping boards for the preparation of these foods and that you disinfect the common
work surfaces in between uses. This method is deemed to be satisfactory.
However, during the inspection a knife previously used for the cutting of raw meat was seen
to be in direct contact with the work surface. It is accepted that the worksurface was
subsequently disinfected prior to the preparation of ready to eat food and that separate
dedicated chopping boards were in use. As such there was no breach of law on this
occasion. However, you are urged to take more care in future to ensure that adequate
measures are in place to prevent the cross contamination of ready to eat food.
In addition, one of the staff was seen to wipe a work surface down using a chef’s cloth rather
than a paper towel. There was no evidence that this was a direct source of contamination
but it is a bad practice and inconsistent with the safe method set out in your SFBB pack.
Recommendation: Remind all food handlers of the need to ensure that adequate
procedures are maintained to prevent the contamination of ready to eat foods.
4. Cleaning/Cleanliness Satisfactory.
5. Personal Hygiene One member of staff was observed wearing a bracelet whilst
preparing food. This is not a breach of law but is not consistent with the safe method set out
in your SFBB pack.
Recommendation: Remind all food handlers of the importance of the SFBB safe methods.
6. Food Hygiene Training: Satisfactory at the time of the inspection. It is recommended
that the matters referred to in paragraphs 3 and 5 above are brought to the attention of staff
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during one of your regular SFBB review meetings and that this is recorded in your SFBB
pack.
7. Stock Control/Food Protection: Satisfactory at the time of the inspection.
8. Pest Control: Satisfactory at the time of the inspection.
9. Structure/Maintenance/Waste Control. Satisfactory at the time of the inspection.
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Food premises risk rating sheet
Name of the food business
operator
Serge Truscott
Business name
CARIB BAYOU
Business address
23 High Street
Fulchester
Date of inspection
01.10.2015
Score
Comments
(Please circle)
Potential Hazard
Level of
Compliance
Type of food method
of handling
40 30 10 5
Method of
Processing
20
Consumers at Risk
15 10 5 0
Additional score
22
Hygiene
25 20 15 10
Structure
25 20 15 10 5 0
0
0
Confidence in
Management/control
procedures
30 20 10 5 0
Significant risk
20 0
Total Score
FHRS
5 0
Minor lapse in cross
contamination procedure,
food handler wearing
jewellery and use of cloth
rather than paper towel to
wipe work surface.
Not all diary sheets had
been completed and
evidence of minor
deviations from safe
methods.
45
Total score
10
Worst score
5
Rating
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