FHRS Case Study: Wales 2 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 At the time of research, this rural Welsh local authority had been operating the FHRS for approximately two years. The scheme had been incorporated into the regular inspection programme but workloads have increased due to extra administration, extra time for inspections and greater care scoring and discussing ratings within the team. It was felt there were inconsistencies across local authorities in scoring FHRS ratings. Food business use of the safeguard measures was also adding strain to staff resource. The local authority food safety officer reported positive changes in FHRS ratings (at all levels) and improvements across all types of food establishments since the start of the scheme. However, it was felt there were some problem food businesses that did not take the FHRS ratings seriously. Food business operators who took part in the research were generally supportive of the scheme. Those with low ratings were mainly frustrated about being downgraded for incomplete documentation of food safety systems. It was felt that more needed to be done to help customers understand what the different ratings mean, given that display of ratings was going to be compulsory. This was borne out of the concern that a low rating does not equate to unsafe kitchen practices. Consumers were very positive about receiving food hygiene information in a uniform format. Food hygiene was not considered to be a key factor when making decisions about eating outside the home, but a lack of cleanliness (through visual cues) would deter people. In terms of FHRS ratings, people said they would apply the ratings more flexibly when considering a regular eating place but would expect higher standards of hygiene when paying more for a meal or when choosing between unfamiliar eating establishments. 1 The local authority context The local authority in a rural location is characterised by a higher standard of living relative to other areas in Wales – with lower rates of unemployment and deprivation – and a homogenous white ethnic population. The main industries are agriculture and tourism. The local authority did not have a local food hygiene scheme in place before the FHRS was launched in spring 2011. According to December 2012 ratings data, 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 in March 2013. The officer worked in a team of 12 inspectors who covered over 1500 food businesses within scope of the FHRS. The officer also supplied information about the area chosen for research with the other stakeholder groups. A small town was selected for fieldwork with food businesses and consumers. Commerce was located primarily on three main roads in the town centre and consisted of a mix of retail, service and food premises. There were no empty shops. Only FHRS stickers with 4 or 5 ratings were visible from outside of premises. Fieldwork with food business took place over two weekdays in June 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: four proprietors had been given an FHRS rating of less than ‘3’ while a further three had received a ‘3’. The sample comprised a range of business types: hotel restaurant, café, grocery shop, pub, butcher, bed & breakfast. All were independently run businesses. Seven people took part in the focus group – 4 females and 3 males – which was hosted in a local hotel conference room. The focus group was conducted on a weekday evening in June 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, all reported they had seen FHRS stickers displayed on food premises but only one participant had previously used the ratings website. Local authority viewpoint The local authority officer said the FHRS was working ‘fine’ and reported improvements in food hygiene standards across a wide spectrum of food businesses. There had been positive changes in FHRS ratings (at all levels). There was no perceived pattern in terms of types of food businesses with lower ratings, i.e., takeaways can range from 0 to 5. However, the respondent added that FHRS ratings 2 were expected to go down due to the stringency of the E. coli cross-contamination guidance. Operations The local authority used a gradual approach to roll out. They prioritised high risk businesses and, at the time of interview, had completed physical inspections for all businesses in risk categories A through D.1 An alternative enforcement procedure (food safety newsletter) had been applied to those with an E risk rating. Changes attributed to the FHRS The respondent felt the scheme had increased the team’s workload. Inspections tended to take longer and were more detailed with officers taking them ‘to the letter’ to fit the Brand Standard and to ensure they have adequate evidence to justify ratings. There was also a higher volume of paperwork. The local authority officer noted that more time was devoted to explaining scores to poor performing food businesses. Some proprietors were more appreciative of these discussions than others. This reflected in relationships. For example, the respondent explained that some businesses were very surprised to get a poor rating and would complain, ‘You've been coming here for years and we didn't realise this is what you thought about our business’. On the other hand, other poor performing businesses were positive about the scheme and acted on the advice. Rating consistency, training and guidance The food safety team had worked hard to establish and maintain consistency in FHRS ratings. The respondent was confident that officers were reliably scoring the criteria, ‘I’m quite happy that the officers in the team are consistent … Where the scoring is tricky for want of a better word, or you think that the conditions that you’ve found kind of fall in between two scores, there’s a lot of discussion in the office about scoring premises and making sure that it’s accurate.’ FSA training, team discussions, inspection scenarios and exercises have been used to achieve this. Internal team work with practice scenarios (using the trickier food businesses) were viewed to be the most effective. However, the respondent noted there were still differences between local authorities regarding the volume of low rated premises and felt this reflected the different scoring approaches. It was felt that more consistency training/exercises were needed including shadowing officers in different local authorities. 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. 3 The local authority had not produced any separate FHRS materials for the team. They refer to the Brand Standard which was considered adequate. Safeguard measures The team have had experience of all safeguard measures, with the exception of formal complaints. Requests for re-inspection were the most frequent and these tended to come from food businesses with a rating of ‘3’ or lower.2 The safeguard measures were straining team resources yet it was also noted that efforts were paying off as ratings were increasing. During an inspection visit, it was reported that officers provide food business operators with a leaflet on the scheme and their rights to safeguard measures. Officers do not inform the proprietor about the rating they will be given until after the scores have been processed at the office. However, for those food businesses that will be given a low rating, officers would pre-warn them so that ‘people are less shocked when they get the letter in the post’. It was felt this helped to reduce the rate of appeals. The respondent felt that the FSA should reconsider plans to post inspection reports on the internet because there was concern that this would increase food business formal requests and consequently, officer workloads. Views on food business engagement The local authority officer observed that food business operators were becoming increasingly aware of the importance of food hygiene standards. Some realise they can use the FHRS rating to their advantage in promoting their business. Within the local authority there were some problem food businesses that did not take the hygiene ratings seriously and the officer felt that the scheme was helping to expose those that ‘aren’t pulling their weight as much’. The local authority has used FSA funding to address food safety management systems (Article 5 compliance) among food businesses with a 0 or 1 rating. These businesses received the Safer Food Better Business pack and were invited to attend a seminar facilitated by a food safety consultant. The respondent did not comment on how effective these sessions have been. Display of ratings It was felt that food businesses with a ‘4’ or ‘5’ rating were more amenable to displaying a sticker or certificate. For these businesses, the FHRS was a positive way to communicate good hygiene standards to customers. It was also viewed as adding a competitive edge to businesses as those that did not display their rating 2 The respondent said he has personally dealt with about 10 requests for re-inspection and approximately 5 appeals each year since the start of FHRS. He could not speculate on these quantities for other members of the team. 4 were increasingly viewed with suspicion by other food businesses and by the public. For this reason it was considered simpler to encourage the higher rated businesses to display their ratings. The local authority officers generally promoted display among the 0-2 rated businesses with the warning that they would be required to display their rating in the near future. The respondent was adamant that mandatory display would help drive up food hygiene standards by forcing 0-2 rated businesses to take the FHRS more seriously. However, the knock on effect will be an increased workload for the food safety team as it was expected that mandatory display would lead to more use of the safeguard measures among food business. Scheme publicity Most promotional activities took place during the launch of the scheme. Since then food businesses have received a letter informing them about the legal requirement to display FHRS ratings from November 2013. The scheme has also been mentioned in the local authority newsletter and the county newspaper. The respondent could not recall details and could not comment on the effectiveness of these communications. Food businesses The FHRS was generally well received by food business operators who considered that a system was needed to ensure that businesses are following proper hygiene controls. For example, proprietors mentioned that the scheme keeps businesses 'on the ball' and the incremental ratings provide a structure for businesses to strive toward. An owner of a fish ‘n chip takeaway (rated 3) questioned the relevance of the FHRS for a small town. It was felt that the scheme may be needed in cities and big towns where there are more people from outside the area. But small towns rely on regular customers who come back for the good quality food (and do not base food purchase decisions on food hygiene information). Views on ratings received Food businesses with 4 and 5 ratings were generally satisfied with their achievements, while those with lower ratings were not happy with the outcome. These respondents were generally frustrated with the requirements for documenting food safety systems (making the FHRS ‘paperwork driven’). For example, one B&B owner (rated 1) relayed his disappointment, ‘The rating was solely based on the fact that we hadn’t completed the paperwork … it had nothing to do with the cleanliness, the storage, or anything else which obviously is disappointing.’ 5 Proprietors were also concerned about the potential interpretation of ratings, pointing out that the same rating could mean weaknesses in different areas of noncompliance, i.e., poor documentation in one business while the other could have cleaning issues. There was also concern that customers might equate a high rating with good quality food. Barriers to changes Building regulations, landlord restrictions and limited resources (time, finances) were the main barriers to changes noted in the sample. In addition, proprietors had to delay making some repairs until low season. There was also the view that the FHRS was putting extra pressure on small businesses. For example, the owner of an independent pub (with a 2 rating) said he and his wife worked 12 hour days and were struggling to maintain all the requirements under the FHRS, particularly the requirement to document food safety systems. Safeguard measures In the sample, all but one of the respondents with a rating of less than ‘4’ planned to or had already made a formal request for a re-inspection. Proprietors were motivated to improve their ratings before display becomes mandatory. One respondent, the owner of a south Asian grocery shop, was not aware of the safeguard measures and said he did not wish to ‘disturb’ the council staff. Display of ratings/results Food business operators were displaying their 4 and 5 ratings out of pride and as a way to communicate their good hygiene standards to customers. Various reasons were provided by those who were not displaying: concern that displaying a low rating would negatively affect business, dissatisfaction with the rating, and a misplaced sticker/certificate. All but one of the respondents was aware that display would become mandatory in November 2013. The new requirement was broadly supported but food business operators were concerned about the infrequency of inspections as recent changes would not be reflected in ratings, a concern for those who believed customers would start to pay attention to ratings. An alternative view was that display of low ratings would not affect regular trade but it might deter new customers. There was also the view that, alongside mandatory display, consumers need to be better informed to use the FHRS, as relayed by a restaurant manager (rated 4), ‘I think they just need to educate people … it’s all very well saying, “put signs in the doors and it’s compulsory to put them up on the doors” but ... it needs to be a bit more clear … to Joe public if they see it’s a nought or a one on the door, and explaining that it’s below par, you’re instantly going to think it’s got a 6 dirty kitchen. It might have a dirty kitchen, I don’t know, but there are probably other reasons behind it.’ Awareness of other food business ratings Two of the respondents had researched the FHRS ratings of other local businesses and felt that the ratings were increasingly becoming grounds for competition. For example, a restaurant manager described how a rival supplier pointed out that his current supplier had a lower rating. In this case the rival business used the FHRS as a ‘tool’ to attract trade. The remaining respondents were not aware of other ratings or were only aware of those on display in local businesses. Views on FHRS impact No one in the sample felt that the changes made to improve their hygiene standards had made an impact on their trade. There were cases where it was felt that kitchen staff had become more aware of the requirement to document food safety systems. Those that were displaying their 4/5 ratings said that no customers had commented on them to date. Concerns and suggestions for improvements Perceived inconsistencies with the FHRS were a concern. Food business operators had noted ratings could differ from one inspection to another due to different food safety officers (who focused on different areas when requesting changes) or if inspections took place at different times of the year (low and high season). They also felt that assessing different types of food businesses under the one rating system was unfair and did not recognise that obtaining a 5 rating was easier for certain businesses than others. It was felt that the local authority should communicate changes in food safety guidance to 'the coal face' well ahead of inspections so food business operators have a chance to make changes and avoid downgrading. It was also unclear to food businesses on what criteria the frequency of inspections was based. Every two years was considered too long a gap to provide an accurate representation of current hygiene standards. Consumers Role of food hygiene when eating out People in the focus group said that they take hygiene into consideration when purchasing food and eating outside the home. As one female pointed out, 'when somebody is touching your food, they need to be of a higher standard' because it is 7 out of your control. With the knowledge that food hygiene is regulated in public eating places, people said they expect kitchens to be clean, especially franchises – which follow uniform procedures. Still participants said they wanted to judge the cleanliness of the premises themselves, relying on mainly visual cues to see 'with your eyes the presentation, how fresh the food is and how clean the establishment is.' Internet and other media reviews were consulted but it was pointed out that these appraisals could be out of date so personal observations were still important. Some people mentioned they used Facebook and TripAdvisor and noted that bad reviews 'spread like wild fire' so you can avoid a place where someone has had a bad experience (with cleanliness or otherwise). Experience of FHRS All participants were aware of the FHRS, albeit to varying degrees. All became aware through stickers on display in various types of establishments (grocery, restaurant, pub, hotel, cafe, takeaways). Additionally, one female had seen a television programme that discussed the scheme. People were aware of a certain pub chain that had received a 5 rating across the franchise. One person searched the FSA ratings website when considering a restaurant to take his mother to, ‘I’ve looked on the sites. My mother lives in [town] and it was one of the worst for zero ratings ... I was very careful when I took her out.’ (male, age 50-64) Applying FHRS ratings Hypothetically, if ratings were displayed more widely, people said they would be useful for comparing food businesses. As one person stated, 'I think if you're going on a day out, somewhere that you don't know, there are three shops in a row and one has got a 5 and the other has a 3, you're going to go to the 5.' (female, age 50-64) There was also a general consensus that people would be sceptical if a food business was not displaying a rating when others were. It would be assumed that this business had a low rating. People were generally not willing to approach a business about its FHRS rating, mainly because they were not confident about their knowledge of the scheme or they questioned how willing the proprietor would be to divulge the information. The FSA ratings website was mentioned as an alternative source for this information. Minimum standards On the whole, all participants, except one, were happy to designate ‘3’ as the minimum acceptable FHRS rating for a food business. These people were deterred by ‘improvement necessary’ in the descriptions of the lower ratings. No one would 8 consider a zero rated business under any circumstances and it was felt these premises should be shut down until changes were made. Additionally, a male participant was aware of a friend who had food poisoning so would not consider any business rated below 2. One female said she would not want to go lower than a ‘4’ rating. She explained this was based on television programmes that show what can happen in a restaurant kitchen. For this reason she felt safer with a ‘4’ rating. Ratings in different circumstances When discussing different eating situations, it was evident that the focus group participants varied their food purchasing criteria under different circumstances. Price, food quality, convenience and reputation were important alongside food hygiene. Generally people wanted a higher FHRS rated establishment for a special occasion or expensive restaurant and they were willing to relax their standards for a place they knew well and liked. However, the one female participant stood her ground and would not accept a rating lower than ‘4’ under any of the alternative scenarios. Regular eating places and certain ‘unhealthy’ establishments seemed to be given the benefit of the doubt in terms of food hygiene. Two males said they were willing to purchase food from a place rated ‘1’ or ‘2’ if it sold ‘cheap’ food or if ‘it was a clean looking burger van’. Others said they would want to know why a familiar eating place was given a ‘2’ rating, for example, especially if the reason may have more to do with decorating than about food preparation. With this extra knowledge they would decide whether or not to continue to purchase food there. High end establishments and unfamiliar places would be scrutinised more closely before making a decision. People mentioned they sought more information on these occasions, either by recommendation or through searching reviews. Those who would accept a ‘2’ rating for a familiar place which they liked said they would stick to their minimum rating of ‘3’ when considering unfamiliar establishments. The composition of the eating party did not seem to make a difference to people’s views on the level of FHRS rating that would apply to different eating situations. Feedback and suggestions for improvements Focus group participants supported the scheme and considered it to be a good idea. A high rating provided assurance that the food business is a safe place to eat, 'there's no way of telling what the kitchen is like, so that rating is important'. To help increase public use of the FHRS, it was felt that the scheme needed to be publicised more widely (radio and television) and that display of ratings should be compulsory. It was reasoned that mandatory display would force the low rated businesses to improve their hygiene standards because higher ratings will attract patrons. 9 There was concern about the frequency of inspections and it was assumed that these were undertaken at least annually to ensure an up-to-date reflection of practices. People also wanted to know how soon after the requested changes were made that the food business is re-inspected (to reflect these improvements). It was generally felt that two year old inspections were not sufficient to maintain public confidence in the system. It was felt that more information about the composition of individual food business ratings should be available on both the internet and through a free help-line (for noninternet users). People also wanted a means for consumers to feed back on the scheme and to inform the FSA/council about a bad food hygiene experience. 10