EHJ February 2003, pages 42-45 As the Food Standards Agency campaigns to reduce the incidents of food poisoning by 2006, Nick Warburton looks at the different approaches to improving food safety

As Dr Robyn Fairman and Charlotte Yapp point out (EHJ January 2003, page 16), the debate over whether education or prosecution is the best approach to improving food standards in businesses remains hotly contested. The fact that food has become such a huge industry and standards vary considerably, even between businesses of equal resource and size, means that ensuring food safety is adhered to across the board remains a major challenge.

In recent years, the trend for people eating out has risen noticeably. Research carried out by the market analysts Datamonitor suggests that eating out is now "becoming a convenience", especially during the week.¹ The study builds on research by the Food and Drink Federation, which predicts that by 2025, 50 per cent of food consumption will take place out of the home.² Meanwhile, the Government's food watchdog, the Food Standards Agency (FSA), published the Microbiological Foodborne Disease Strategy in July 2001, which estimates that 88 per cent of general outbreaks of foodborne disease are associated with restaurants, hotels, pubs, bars, and caterers.

In February 2002, the FSA launched the first phase of a five-year strategy aimed at improving hygiene standards in catering businesses.³ Targeting the UK's 370,000 caterers, the long-term aim is to reduce the incidents of food poisoning by 20 per cent by 2006. One of the key features of the FSA's national campaign is the need to promote a culture of learning and training within the UK.

According to Jenny Morris, CIEH policy officer, training is key to food safety, providing a knowledge base to build on. Equally important however, is how appropriate that training is and how it is applied in businesses. There must be a motivation in businesses, she points out, to use that training in the workplace.

The CIEH (and other awarding bodies) has played a leading role in introducing food hygiene training qualifications and supporting courses, and has been working closely with the FSA to emphasise the importance of businesses using food hygiene trainers that are registered with recognised awarding bodies. Last year, the CIEH achieved formal accreditation of its vocational qualifications through the Qualifications Curriculum Authority (QCA). CIEH national training auditor, Kevin Wilkinson, believes that most good companies tend to go for a recognised awarding body as it provides the "rubber stamp" of approval.

Since the early 1990s, the trend in food legislation has increasingly been towards risk assessment. The Food Safety (General Food Hygiene) Regulations 1995 require hazard analysis and the appropriate food hygiene training for all food handlers. The FSA advocates the Hazard Analysis and Critical Control Point (Haccp) system of food safety management as the most effective way for food businesses to ensure consumer protection. It argues that the application of effective Haccp-based controls across the food chain is key to reducing foodborne disease and has been campaigning to increase the awareness and application of Haccp in UK food businesses.⁴

The FSA five-year strategy, which saw the second phase get under way at the end of last year, was influenced by the agency's survey of over 1,000 workers and managers in small independent catering businesses. The survey found that less than two thirds of the catering workers questioned had a certificate in basic food hygiene and only 3 per cent of catering managers interviewed said that retaining skilled, trained staff was important to their business.⁵

Dr Fairman and Ms Yapp argue that the emphasis towards a more self-regulatory system, which forces businesses to take responsibility for food safety, poses significant problems for small to medium sized businesses (SMEs). This has resulted in a lack of compliance in the past, as demonstrated by a FSA report on local authority food law enforcement activity, which showed that of the 235,969 restaurants and catering establishments inspected in 2000, 118,555 had broken food safety laws (EHJ, December 2001, page 366).

Euan MacAuslan, environmental heath training co-ordinator at the Royal Borough of Kensington and Chelsea goes further and says: "Enforcement officers and catering managers alike are continually confronted with food handlers who have gained nationally recognised food hygiene certificates, but do not put into practice what they have been taught." (EHJ, March 2002, page 80)

He has also identified significant problems in areas with increasing numbers of candidates whose first language is not English, and raised concerns that there was a national shortage of suitably qualified trainers to run courses in other languages apart from English.

Referring to research carried out by the Caterer and Hotelkeeper, Mr MacAuslan says that the UK's hospitality industry will need to fill an estimated 300,000 new jobs before 2009. One of the key requirements for this group will be food hygiene training. The likelihood is that most of these positions will be filled predominantly by food handlers who speak English as a second language, the greater percentage coming from Eastern Europe.

Training-related problems and its lack of application in the workplace are generally picked up when environmental health officers carry out inspections of food premises. As Ms Morris acknowledges, self-regulation in many of the larger businesses can often be higher than legal requirements, and that is why enforcement is primarily focused on SMEs, which generally have a higher level of risk. One of the key indicators of risk, says Ms Morris, is confidence in management.

While she argues that enforcement is driven by the likelihood of food businesses being caught out for failing to comply (whether deliberately or through ignorance), and the punishment applied, she adds that education is key. Enforcement, she argues, gives local authorities an opportunity to provide businesses with advice on good practice and highlight areas of improvement.

Another source of information (and training) for businesses is consultants. As a privately funded operation that has advised the top end of the food market for over 10 years, Food Alert takes a preventative and investigative approach to food safety.

Besides providing CIEH-accredited training courses, the company's preventative measures range from advising on kitchen layouts at the planning stage to inspecting busy restaurant kitchens on a regular basis to ensure standards are not falling. As part of this approach, Food Alert helps its clients to develop the risk assessment. "What we try to do, rather than say 'here's a manual and good luck to you," says Peter Christopher, Food Alert's managing director and a former EHO, "is go in with the client, help do the risk assessment and get the documentation done." The focus is on bringing the client up to the required standard and then, once that has been achieved, following a routine of maintenance. The frequency of maintenance, he says, depends on each individual client.

Mr Christopher adds that chefs are highly trained and regularly go through refresher courses to maintain standards and keep up-to-date with industry requirements. "As a company, right from 12 years ago, we said once a year we want to go back and do one hour's refresher with the food handlers."

While he argues that food standards have never been higher, he also recognises that the number of complaints has never been higher either (Financial Times, 29-30 June 2002). He puts this down to three factors, which are not directly related to restaurant standards. One is that the British public is more prepared now than ever to complain about a service. He also claims that there has been a rising trend for solicitors to act on a "no win-no fee" basis, which has resulted in an increasing number of legal cases being brought. Finally, he recognises that there is greater control and enforcement at a local level by EHOs, however over stretched they may be.

Ms Morris agrees that improvements have been made but says that this is not the case across all food sectors. Furthermore, while food enforcement is directed mainly at the lower end of the food market, she also argues that in some large businesses there is a potential conflict between cost and safety. "The aim of the business is to make a profit, so there has to be a degree of conflict."

In Food Alert's case, Mr Christopher believes that 90 to 95 per cent of the hygiene allegations his clients receive don't add up. "It's fair to say that a significant number of them are possibly people who have been disappointed by the dining experience or have spent more than they meant to." To support his argument, he claims that most complaints come in on a Monday morning and during December "when a lot more people eat out and invariably drink more than usual," so the pattern suggests that complaints could be a cover for absenteeism.

Investigating suspected food poisoning cases is fraught with difficulties, as David Lyons, group manager for public safety at Middlesborough Council underlines (EHJ, April 2002, page 112). Gathering and presenting evidence to secure a conviction under Section 8 of the Food Safety Act 1990 is difficult, he says, and the job is not made any easier by the rules and laws relating to criminal evidence. "Even investigations which, on the face of it, yield up fairly compelling evidence can unravel in all kinds of unforeseen ways because of evidential problems."

As a recent study by the Public Health Laboratory Service (PHLS),⁶ noted, in order for the FSA to monitor the progress made on reducing food poisoning and to set priorities for the development of control strategies, the agency "requires reliable measures of the burden (morbidity, health service usage, and mortality) of indigenous foodborne disease (IFD)."

The PHLS study provides the most accurate picture of the burden of foodborne disease by refining an approach developed in the US by the Centers for Disease Control and Prevention (CDC), which produced pathogen specific morbidity, hospital admission and mortality estimates for foodborne infections in the US. Building on this method, the PHLS, also accounted for imported infections and described recent trends in the burden of IFD in England and Wales.

Somewhat surprisingly, the study found a decline in IFD over a period when food poisoning notifications increased. Using supporting information from another study, the PHLS discovered that food poisoning notifications are closely bound to the laboratory reporting of salmonellas and campylobacters,⁷ which appears to be borne out by the examination of recent trends showing that increases and decreases in notifications are matched by the reporting of these pathogens.^8,9 The significance of the PHLS study is that the trends identified in IFD, take into account a much wider range of pathogens and more importantly measure the burden of infection due to each of these agents in a way that food poisoning notification data cannot.

Dr Sarah O'Brien, one of the report's authors, says that improving food safety requires a co-ordinated approach covering the entire food chain from farm to fork. While training, enforcement and investigations each have a crucial role to play, educating the general public is also important.

From his experience as a public sector EHO, and through his work at Food Alert, Mr Christopher agrees that more needs to be done in the home to raise awareness of food hygiene issues. While he sees television as one of the best mediums to get the message across - "it is entertainment but they could still put education in" - he recognises Food Alert's role in educating the marketplace, and consequently the home environment. "One question you can ask people on courses is how many people know the temperature of their fridge at home. That's probably the easiest thing you can do to prevent food poisoning at home," he says.

References

1. www.ananova.com/news/story/sm_737986.html?menu=news.surveys
2. www.fdf.org.uk/eating_out_trends/eating_out_market_over.html
3. Trainers' Exchange, summer 2002, volume 12, issue 2, p2.
4. www.foodstandards.gov.uk/foodindustry/
5. Trainers' Exchange, winter 2002, volume 12, issue 4, p1.
6. Adak, G K, Long S M, O'Brien, S J. "Trends in indigenous foodborne disease and deaths, England and Wales: 1992 to 2000". Gut 2002; 51: 832.841.
7. Atkinson, P, Maguire, H. "Is food poisoning a clinical or laboratory diagnosis? A survey of local authority practices in the south Thames region." Commun Dis Public Health 1998; 1: 161-4.
8. CDSC. 1999/2000. Review of Communicable Disease. London: PHLS, 2002: 86-87.
9. CDSC. "Trends in selected gastrointestinal infections - 2000. Commun Dis Rep CDR weekly (serial online) 2001 (cited 8 February 2001); 11 (6): enteric.