FHRS Case Study: Wales 1
This mini report presents findings from one of 8 local authority case studies
developed for the stage 2 process evaluation of the Food Hygiene Rating Scheme
(FHRS) and the Food Hygiene Information Scheme (FHIS). The report provides
evidence from discussions with a local authority food safety officer, food business
operators and consumers. The 8 case studies are aggregated within the main report
of process evaluation findings, which included additional data sources, and are
intended to provide snapshot illustrations of how the schemes were perceived and
experienced by individuals within a local context.
Summary
In this Welsh urban local authority, FHRS has been incorporated into the regular
inspection programme yet, after two years, not all businesses had been
assigned an FHRS rating due to limited staff resource. Though inspections have
not changed under FHRS, food safety officers were taking more time scoring
and discussing ratings. This was to ensure ratings were justified and to maintain
consistency in scoring; however, inconsistencies were noted between local
authorities. Extra administration and formal requests (re-inspections and
appeals) have added to workloads.
Overall, the local authority officer said that levels of broad compliance have
improved as ratings of ‘3’ and higher were observed to be increasing. Yet it was
noted there remains a hard core of food businesses where improvements
remain difficult. Language and cultural issues were thought to act as barriers to
change. Relationships with some poor performing food businesses have been
strained. Interviewed food businesses felt extra pressure under FHRS,
particularly in light of the fact that display of ratings would become a legal
requirement. The requirement to document food safety systems was considered
arduous for small business owners and the level of downgrading for incomplete
documentation of food safety systems was considered unfair.
Food business operators acknowledged that mandatory display of ratings would
draw customers’ attention to food hygiene and were anxious that low ratings
would deter new trade, although they relied heavily on regular customers.
In the focus groups, consumers were very positive about the FHRS but felt more
information about the scheme and wider publicity were needed, including
mandatory display of ratings on business premises. Food hygiene information
was considered more useful when people took time to review different eating
choices such as for a special occasion or when on holiday.
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The local authority context
The urban local authority is characterised with a population of over 300,000
according to the 2011 census. 16% of residents live in the most deprived areas of
Wales and the 9% unemployment rate is higher than the Welsh average. Health,
retail and education are the largest industries and the area is also popular with
tourists. At 14%, the ethnic minority community is three times the Welsh average.
The local authority had a food hygiene scheme in operation before FHRS was
launched in late 2010. According to December 2012 ratings data (supplied by the
FSA), one in four (24%) food businesses in the area had been given an FHRS rating
or 0, 1 or 2.
Research sample
One local authority food safety officer was interviewed by telephone which took place
in March 2013. The officer worked in a team of 15 inspectors which covered over
3000 food businesses within scope of the FHRS. For research with the other
stakeholder groups, the officer helped to identify a neighbourhood with a
concentration of poor performing food businesses.
A main inner-city road was selected for fieldwork with food businesses. The area
was comprised mostly of eating establishments serving ethnic cuisine. Businesses
were closely packed in mostly older (100-200+ years) buildings. At one end of the
road there were a number of empty shops. Very few FHRS stickers were visible at
street level and these showed only 4 or 5 ratings.
Fieldwork with food business took place over two weekdays in May 2013. Nine food
business operators took part in the interviews which took place on their premises
during business hours. The study aimed to collect the perspectives of mainly low
rated food businesses: six proprietors had been given an FHRS rating of less than
‘3’. The sample comprised mainly takeaways along with a pub, restaurant and a
retail shop. Seven were independently run businesses while the remaining two were
franchises.
Eight people took part in the focus group – 4 males and 4 females – which was
hosted in a local hotel conference room. The focus group was conducted on a
weekday evening in May 2013. Participants had been selected to ensure awareness
of the FHRS and interest in new eating experiences and/or concern for food hygiene.
In the screening exercise, 7 reported they had seen FHRS stickers displayed on food
premises, 2 had used the FSA ratings website and 3 said that FHRS ratings had
influenced their choice when eating out.
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Local authority viewpoint
The local authority food safety officer viewed the FHRS as a good thing for Wales
and said the scheme acts as a tool to motivate food businesses to improve
standards and to gauge progress. The respondent noted that levels of broad
compliance have improved in the local authority as ratings of ‘3’ and higher were
increasing.
Operations
Applying a gradual approach to rating food businesses under the FHRS, the food
safety team have carried out inspections according to the food business risk rating.
The respondent reported that all A-C category businesses had been rated (except
for new businesses).1 The food safety team have been unable to rate all food
businesses due to limited resources.
Changes attributed to the FHRS
Under FHRS, the team was applying the same inspection programme as they had
done previously. There had been no change to the length or inspection visits but
local authority officers were taking more care assigning ratings and more time
discussing scores with other team members. It was felt the FHRS requires more
paperwork to justify ratings. The team have administrative support to help with
printing stickers/certificates and uploading ratings to the website. Extra time to
discuss scores and administration of the scheme have added to team workloads.
The respondent mentioned that the E. coli cross-contamination guidance had also
added changes that required more care in scoring compliance with food hygiene law.
The local authority officer reported that the FHRS has changed relationships with
food businesses somewhat. The scheme can act as a motivator for proprietors by
providing a structure for improvements, but it could also be interpreted as giving the
local authority more control over proprietors. Sometimes food business operators
reacted negatively to low ratings. The respondent added that this reaction was being
exacerbated by negative media coverage and freedom of information requests to
uncover poor performing premises.
Rating consistency, training and guidance
Consistency was not an issue within the food safety team. They continued to
address this through multiple means: team meetings and one-to-ones between food
safety officers and managers; consistency training across Welsh local authorities;
and discussions at regional technical meetings.
1
The frequency of food hygiene interventions is determined by the assessed risk of food premises,
assigned as categories A through E, with A being the highest risk.
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The respondent reported that cross-Wales training has revealed inconsistencies
between local authorities and suggested that consistency training needs to be
ongoing to be effective and to ensure that scoring across local authorities is
comparable.
The Brand Standard was considered to be a useful source of guidance on scoring
consistency. However, it was felt that it needs to be updated in relation to the E. coli
cross-contamination guidance.
Safeguard measures
The local authority officer reported that formal requests from food businesses have
added to workloads, described as ‘a pressure point’. Since the start of the scheme,
the respondent estimated there have been about 150 rescores; there were five
appeals in 2012 and no complaints or rights to reply. These formal communications
tended to come from food businesses with ratings less than ‘3’. But it was noted that
some of these were initiated by institutions (e.g., nurseries) that were broadly
compliant (rated 3 or 4) and the respondent was concerned that these cases were
taking resource away from the lower performing premises.
The respondent also expressed concern that the volume of formal requests and
appeals will increase when it becomes mandatory for food businesses to display
ratings. This will require more staff resource which could be partly offset if fees for
re-inspections are invested in food safety team resources.
Views on food business engagement
The local authority officer had noticed improvements in food business awareness of
the FHRS and in attitudes about the importance of food hygiene. However, there is a
hard core of food businesses that will not change until they are forced to display their
ratings to the public. Difficulties were associated with food business operators from a
minority ethnic background where there are language and cultural issues with
understanding the concepts in the FHRS. These was also a high turnover of
ownership in deprived areas of the city. Together, this made it difficult for some poor
performing food businesses to improve.
Feedback from businesses (following food hygiene training) suggested that
proprietors wish to be informed of developments in food hygiene requirements
before inspections. To address this, the local authority had started advising new
businesses about documenting food hygiene systems prior to the first inspection.
With support from FSA funding, the food safety team had also been paying one-toone advisory visits to 0 and 1 rated businesses to help them improve their hygiene
standards.
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Display of ratings
The respondent observed that there was a reluctance among food businesses to
display FHRS ratings – with those rated 4 or 5 more likely to display in order to
promote their hygiene standards to customers. It was felt that officers have ‘no teeth’
when discussing display with poor performing food businesses. Therefore they ‘do
not go out of their way’ to encourage display with this group.
The local authority officer felt that mandatory display will help generate changes
needed among poor performing food businesses. However, it was anticipated this
requirement will entail more work for the team with more businesses exercising their
safeguard rights.
Scheme publicity
FSA campaigns in Wales have raised public awareness of food hygiene information
– there have been more freedom of information requests, contact from special
interest groups, and local media attention. Local authority publicity was concentrated
at launch of the scheme in late 2010 and early 2011.
Food businesses
Overall views
The FHRS was received with a mix of views from food business operators. From a
positive perspective, the scheme was seen as a measure to keep businesses ‘on
their toes’ as the extra work was for the benefit of public safety. On the other hand,
business operators felt the requirements of the scheme (particularly the
documentation of food safety systems) were difficult for small business owners.
There was also the view that the FHRS was not being implemented properly as
those with poor standards of hygiene were able to ‘hide from the public’ because
they were not displaying their rating.
Views on ratings received
In the sample, food business operators with a ‘4’ or ‘5’ rating were generally pleased
and felt the outcome reflected their hard work. Those with a rating of less than ‘4’
were unhappy with the outcome, mainly because they expected a higher rating or
because they felt the rating was unjustified. Several businesses had been marked
down due to poor documentation of food safety systems. For example, the owner of
a Turkish restaurant and takeaway (rated 3) said he was told everything was fine
except his ‘paperwork’. It was unclear to him why the local authority removed 2
points for this. He was proud of his business and did not feel a ‘3’ was good enough
to display. Yet he worked 12 hour days with little help and could not do the level of
record keeping required. All respondents with a rating less than ‘5’ indicated they
wanted to improve further.
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Barriers to changes
Issues that made it difficult for proprietors to introduce requested changes included:
time constraints on small business owners; planning permission and landlord
restrictions.
There was also evidence that operators did not fully understand the changes
required or what could be done to improve their hygiene rating, particularly among
those whose first language was not English.
Safeguard measures
Respondents in the sample were aware of their safeguard rights. Three were waiting
for a requested re-inspection and one was planning to apply closer to November
2013 when it would be mandatory to display ratings. An owner of a grocery shop and
butchery (with a 3 rating) felt that six months was too long to wait for a re-inspection.
A pub manager that had been uprated from a 2 to a 5 rating after re-inspection was
pleased with the process. Requested structural changes had been completed by the
owner of the pub franchise.
Display of ratings/results
Only those businesses with a 4 or 5 rating were displaying their rating. These
businesses were proud of the outcome and felt that the rating was a way of letting
their customers know that they treat food safety seriously. Those not displaying did
not wish to publicise their rating because it was ‘not good enough’ – this sentiment
was also felt by businesses with a ‘3’ rating. Other reasons for not displaying were
that the proprietor had misplaced the sticker/certificate and the concern that a low
rating would have a negative impact on business.
Food business operators had received a letter from the local authority informing
them that display of FHRS ratings would be a legal requirement in November 2013
and they generally supported the measure. It was felt that mandatory display was
needed to fully implement the scheme. An owner of a pizza franchise (who was
displaying a 5 rating) reasoned that not until display is mandatory and people know
more about the FHRS will ratings make a difference to businesses.
Those with lower ratings who weren’t displaying were anxious to achieve a higher
rating before November. There was concern that the local authority would not have
the resources to re-inspect businesses before this deadline so proprietors would be
forced to display a rating that did not reflect the changes made. In addition, the
owner of an Indian restaurant (who was displaying a 5 rating) was concerned that if
other Indian restaurants display 1 or 2 ratings British people will come to distrust all
Indian restaurants and consequently his business will suffer.
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Awareness of other food business ratings
Proprietors were mainly aware of local business ratings from the stickers on display.
Two respondents (both with 5 ratings) had researched ratings of area businesses on
the FSA website because they wanted to know more about their competition. One
noted that they would feel humiliated if their rating was more than a point lower than
a competitor.
Views on FHRS impact
Respondents generally did not feel the public were engaged with the FHRS because
the value of good quality food outweighed food hygiene ratings. But it was
acknowledged that mandatory display of ratings would draw attention to food
hygiene.
Concerns and suggestions for improvements
There was a common view that the local businesses were not being adequately
supported by the local authority. All but one respondent in the sample were from an
ethnic minority background. Business owners felt they were being ‘targeted’ and their
livelihood was under threat. It was suggested that they should be consulted and
better informed by the local authority prior to introducing new food safety
requirements.
There was also a view that the FHRS was not being applied consistently across
countries. For example, a manager of a pub franchise was aware of procedures in
another franchise located in England and felt that the ratings given were not
comparable.
Consumers
Role of food hygiene when eating out
Focus group participants agreed that people tend to take hygiene for granted when
eating out – cleanliness was less noticeable than uncleanliness. As one person
described it, ‘I eat with my eyes'.
People liked to see the food being prepared and relied mainly on visual cues for
signs of uncleanliness (e.g., ‘If it’s not clean on the front, it’s not going to be clean on
the inside.’). The group agreed that certain places have higher hygiene standards
(food chains) than others (ethnic food eateries).
Therefore, food hygiene was a consideration when a lack of hygiene was evident but
other criteria were also important when eating outside the home, such as value for
money, food quality, and convenience of location.
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Experience of FHRS
All focus group participants were aware of the scheme and commented that
stickers/certificates are increasingly visible in food establishments (e.g., local shops,
chain takeaways, sandwich shops, cafes and restaurants). Only the higher ratings (4
and 5) had been noticed. One female participant said her boyfriend uses the FSA
mobile app when deciding where they will eat out. One male had seen the FHRS
mentioned in a television programme and others had seen negative media attention
about businesses that have been forced to shut down due to poor hygiene. No one
was aware of any FSA or council promotion of the FHRS.
Applying FHRS ratings
If food hygiene information was more readily available focus group participants said
they would start to compare ratings across similar businesses when deciding where
to eat. People reported they would avoid those businesses rated 2 or lower and said
that businesses that do not display ratings when most others do would be treated
with suspicion.
To focus group participants, a zero rating meant ‘no hygiene’ and it seemed counter
intuitive that a zero FHRS rating meant the food business was still operating within
acceptable standards.
Minimum standards
There was general consensus that a ‘3’ rating was the minimum acceptable
standard. A rating of 2 or below was associated with a higher risk of becoming ill.
Ratings in different circumstances
People in the focus group identified different eating circumstances in which hygiene
standards may vary along with other priorities like convenience, familiarity, food
quality and price. As a general rule, people expected a higher level of hygiene (at
least a 4 rating) when they were paying more for a meal such as for a special
occasion or at an expensive restaurant, for example, ‘that should be your right
because you are paying for that right’. The composition of the eating party did not
seem to alter expectations for the minimum standard of hygiene. Parents with
younger children indicated that speed of service and price were important
considerations.
Food hygiene information was considered more useful when choosing a new place
to eat or in unfamiliar territory, like on holiday. These were also instances when
people relied on ‘word of mouth’ or online reviews. Generally, more information was
useful when people take time to decide on where to eat, for example,
‘I’d be willing to find out more if I was going to an eating-in place rather than a
takeaway. A takeaway, I haven't got time for all this.’ (female, age 35-49)
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Extra information was considered less useful for regular eating places when the
reliability of food quality and convenience were prioritised, as one person
commented,
‘If it’s somewhere you go all the time, you become a bit blasé about it and I’ve
been fine every time I’ve been there. So you just go there without thinking. If
it’s somewhere new you might look into it more.’ (male, age 35-49)
However, when faced with the proposition that a regular eatery had a low (0-2)
rating, people said they would either stop going or would think twice before going
and perhaps get more information on why the rating was low. In contrast, people
were less forgiving about an unfamiliar place that had a low rating. Everyone said
they would not even consider it.
Eating out to satisfy a yen for ‘greasy’ foods and ethnic cuisine was another occasion
when food hygiene standards were relaxed. This type of eating tended to be
connected with familiar territory and alcohol consumption, as one person explained,
‘You tend to stick with places that you know and you trust. I’d be very wary
really of going to a completely new kebab place or somewhere like that, even
when I was drunk.’ (male, age 25-34)
Feedback and suggestions for improvements
All participants viewed the FHRS as a good idea and became more engaged with
the scheme as they learned more about it. It was unanimously decided that the
scheme would be more effective if all food businesses displayed their rating and if
there was more done to promote the use of the scheme. People questioned how
mandatory display would be enforced.
Participants wanted further information on the interpretation of ratings and what
exactly the weaknesses of individual businesses were. It was felt that this extra
information could be provided on the FSA/council website.
They also questioned how frequently food businesses were inspected as this was
important for the accuracy of the ratings and how much trust they could put in to the
scheme.
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