The training of EHOs is threatened by falling student numbers and the whisper of more specialist requirements from Brussels. The future of the profession is not clear and the division between public and private sectors appears to be growing. Here Dr Fiona Bushell reveals her research into student EHOs, which highlights the enduring value of traditional generalist strengths and also some practical weaknesses of the newly qualified officer, while offering a way forward for the profession in an increasingly specialist field

For 20 years there have been differing opinions on the role of the EHO - whether it is to provide an objective, balanced and integrated overview of the environmental factors that can affect public health, to provide advice and enforce the law in specialist areas, or a combination of the two. The education and training programme has been endeavouring to produce a graduate who is a specialist in four main areas and has a holistic overview, within an undergraduate programme, and unsurprisingly has been criticised for failing. It is essential that all concerned know what they are trying to produce and are realistic about what they can achieve.

General findings
A cohort of over 300 students who qualified in 1995 from 12 colleges in England, Wales and Northern Ireland, offering courses accredited by the CIEH, were surveyed at the end of their practical training year and at the end of their academic course, to obtain their views and experiences.(1) A final questionnaire sought their views on factors that helped or hindered them during their first year after qualification. Satellite surveys were also undertaken of training officers' views on this group, while the food industry's view on any change of approach since the Food Safety (General Food Hygiene) Regulations 1995 was obtained using an update of a Lacots survey.(2)

Most of the students surveyed enjoyed their studies, with over a third giving a very positive response. Almost two-thirds were female, the majority were in their 20s on graduation, had good entrance qualifications and obtained good degrees. On graduation, most newly qualified officers and training officers/managers had confidence in the officers' knowledge and skills. The new officers were particularly confident about their communication skills, their ability to take appropriate action and advise and educate. The older the officer, the better equipped they felt to deal with people. The officers felt their best achievement since qualifying, was in getting premises improved and over 20 per cent were involved in special projects. Even though they had only been qualified for a year, some had already taken responsibility for demanding work.

There had been considerable opportunity for the new officers to extend their knowledge, with three-quarters going on technical courses since qualifying and a third on courses on formal procedures. The most difficult situations they had faced were mainly confrontational, followed by formal procedures, then technical difficulties. This highlights the fact that, although 42 per cent had no difficulty with confrontational situations, for some officers there is a need for more training. Only 20 per cent had been on a personal safety course and 12 per cent on communication skills training. With regard to technical difficulties, Lacots reported in 1993 that there appeared to be insufficient post-qualification training of a satisfactory standard for EHOs in local government, but their research in 1995/6 revealed a range of opportunities on food safety issues.(3)

HOLISTIC APPROACH
The majority of students had chosen environmental health because of interest in the subject, variety of the work, previous work experience and job prospects, rather than salary or the fact that it was a professional qualification, and not office based. If the course was to become more specialised, some of its attractions would therefore disappear. The majority of the students and training officers were against specialisation at undergraduate level. However funding is a problem for later specialisation as councils are having difficulty meeting inspection targets, so officers are unlikely to be released to undertake postgraduate courses, such as an MSc or research degree.(4)

The Environmental Health Commission's findings support the need for the EHO to be flexible and multidisciplinary.(5) Even the Audit Commission conceded in its 1991 report that the role of the EHO had expanded to encompass the interaction between each component of a common environment and, for example, food hygiene problems could not be considered in isolation.(6) Making sure all members of society have access to safe, wholesome and nutritionally balanced food involves wider issues of poverty, coronary heart disease, nutrition and sustainability and requires reintegration of public and environmental health. To develop the skills necessary for a holistic approach, education and training programmes must ensure the integration of subject areas, the fusion of theory and practice, and practical training which is structured, monitored and assessed. They must be geared to producing team players who collaborate, solve problems, communicate well and are able to continue learning.

A high percentage of the newly qualified officers were rated highly by the training officers in terms of team-working, and for their attitude to the public and business proprietors. Three-quarters were considered to have a good or excellent level of commitment to the profession, ability to build on previous knowledge and skills and maturity. Two-thirds were considered to have good or excellent levels of confidence, self-reliance and interpersonal skills.

Very few newly qualified EHOs will be fully competent professionals; a further period will be needed to consolidate knowledge and develop skills. Knowledge gained at college has a limited life, so it is essential that colleges develop the students' skills for problem-solving and research, and that officers continue to acquire knowledge and skills as part of Continuing Professional Development.

On reflection, one year after qualifying, 43 per cent of officers felt that their practical training had equipped them for the job, but only 21 per cent felt that their college training had done, and over a third felt they did not put into practice what they had learnt at college. They felt major areas of weakness were that the college course was not sufficiently practical/job specific, that it did not cover all aspects and more training was needed on enforcement procedures. Comments from training officers supported these views: 27 per cent said there should be more attention to basics such as communication skills, report and notice writing, and legislation. More students had difficulty with the production of well-structured, concise reports than other general skills. Students on the part-time course said that it had been more practical and easier to relate theory to the practice. Training officers commented that the levels of liaison and monitoring varied between colleges, although twice as many training officers said liaison was good or satisfactory as those who said there was little liaison.

Practical Training Programmes
Most training authorities of the students surveyed followed DoH codes of practice and Lacots' advice and took measures to reduce inconsistency such as cross-auditing.(7) Most also had comprehensive policies on food, enforcement, sampling and infectious disease, and a proactive approach. In order for the student to develop skills and competencies in line with good practice, where there are departmental policies to guide them, this is an advantage, although awareness does not always extend to familiarity and understanding. The majority of the students, for example, said they were aware their training department had policies on enforcement procedures and food sampling but they still identified enforcement procedures as a weaker area in their training and 16 per cent reported a poor understanding of microbiological surveillance. Students were more likely to have a thorough, planned and organised training programme in a metropolitan council and more likely to have a poorly planned programme or no programme at all, at a rural district council.

The training officers/line managers felt that 19 per cent of newly qualified officers had difficulty with working independently, deciding priorities and targets and following a course of action to completion and, correspondingly, 18 per cent of the students said they spent most of their training year watching officers or on administration. Working under supervision in training appears to suit more students in terms of equipping them for the job and has a similar effect on their ability to work independently as spending most of their time working independently, or progressing to independent work. However, 12 per cent of the training officers/line managers said the student was expected to work with little or no supervision.

lure of consultancy
The majority of the study group had been employed since graduation in local authorities, mostly with the council that trained them, in specialist roles. They relied mainly on colleagues for advice and information, so it is essential that these are up to date and using appropriate procedures. A third of the study group saw their long-term future in industry or consultancy, rather than in local government. Local government should be concerned that many of these enthusiastic, well-qualified students are not attracted to working there, though many will stay for two years to take their assessment of professional competence. Local government is a bureaucracy which demands and reinforces a particular model of professional knowledge and technical expertise. The factors that officers felt had the most negative effect on their ability to do the job were those associated with a bureaucracy, such as trivia, excessive paperwork, lack of resources, local politics and deregulation.

MAKING MISTAKES
Of 80 newly qualified officers who admitted making mistakes, most were due to lack of knowledge, not following procedures, paperwork and taking on too much. Being too trusting, promising too much, not collecting full information, giving wrong advice, being unprepared, not being firm enough, poor time management, taking the wrong action and not putting things in writing were all mentioned, without prompting, and are mistakes of inexperience.

Lacots 1993 survey suggested that in many cases, councils lacked any real system for monitoring the quality of inspections/investigations.(8) For the study group, almost a quarter of newly qualified officers said they did not have their work monitored. Of those that did, checking of letters was the common method. Failure to adequately monitor newly qualified officers could lead to inconsistency.

CREDIBILITY IN A SPECIALIST FIELD
Qualifications, training and experience of enforcement officers have an important influence on whether duties are undertaken consistently.(9) Generalist training has been criticised for providing insufficient specialist expertise in food.(10) The knowledge required for professional competence is increasing and the majority of students felt a postgraduate course was desirable but not essential, three-quarters being confident about their knowledge on graduation.

To secure credibility in food control, officers must be able to apply the theory, and the education and training must provide the depth of knowledge and skills necessary to carry out risk assessments, audit food manufacturers and investigate food poisoning outbreaks. Again, it is essential that good practice is reinforced by local authorities as the main employers and inconsistency minimised.

Colleges concentrated on Haccp, legislation, food processing and preservation and more students were confident about their knowledge of these areas than others. Students from eight colleges and training officers/managers rated European directives as their weakest area of knowledge. Students from five colleges rated additives and labelling as among their weakest areas, even though the food standards role of EHOs is increasing, with the decline in food adulteration being replaced by more use of additives, concerns over labelling and food composition.

The strengths and weaknesses of the students' understanding of the subject areas may well reflect the particular experience, qualifications and interests of the food control tutor. College documents indicate the difference in emphasis and time spent on the different aspects of food, in particular, not all colleges covered food-related topics at Level 3. This level requires a deeper understanding and depth of analysis of the policy and practice, which is essential for students who carry out food control duties.

The lack of depth is highlighted by the fact that Richard Sprenger's Hygiene for Management was the most remembered text. This book is a general text for the CIEH Advanced Food Hygiene course and not one that should be heavily relied on at degree level. More academically demanding, specialised texts on food technology, food microbiology, quality assurance and Haccp, plus journals, should be regularly consulted. Final year projects increase the depth of knowledge in certain subject areas but only 17 per cent of final year projects were on food-related subjects (mainly food microbiology and Haccp); the majority were on pollution or health and safety. Although interest was given as the main reason for the choice, 28 per cent said their choice was influenced by their local authority.

One year after graduation, over half of the officers were not confident about the Systematic Assessment of the Food Environment and, a minority were not confident about prosecution procedures, food technology, sampling procedures, food preservation, supplier quality assurance and the Catering Industry Guide.(11,12) The figures show a slight increase from the self-assessments at the end of their training, indicating a lack of reinforcement within employment. The Catering Industry Guide and SAFE were published after the students qualified, (in 1996), are fundamental to the application of the legislation and Haccp, and should have been continually referred to by their department colleagues.

Practical Application
The importance of practical training was highlighted by the fact that only half of the respondents said they went on food-related site visits while at college and the majority found them valuable. Site visits enable students to apply the theory and assist their learning by experience. Three-quarters of the respondents had specialist speakers on food topics during their course and found them valuable. Practitioners can offer a valuable insight into real world problems to assist students' learning.

The more thorough the coverage of food matters during their placement, the more competent students felt about investigating food poisoning outbreaks and the inspection of food premises using risk assessment. However, 9.5 per cent of the students at the end of their placement felt they would have difficulty inspecting a range of premises using assessment of risk and monitoring of controls as a basis, whereas the training officers felt 18 per cent had difficulty on qualifying.

A fifth of the students at the end of their practical training said they would have difficulty following formal procedures and only half of them had been to a food premises prosecution. Lack of enforcement experience could be lessened by seeing the progress of a prosecution and a transfer to another authority where a prosecution is being taken should be considered.

The survey suggests there is a need for more attention to hazard warnings and emerging pathogens. When asked whether their departments had implemented procedures following hazard warnings on E. coli O157, over half did not know. Officers and students need to read DoH hazard warnings and communicable disease reports and keep up to date.

Both groups agreed that more students/newly qualified officers had difficulty with investigations of an outbreak of food poisoning than other areas of food control practice. However the training officers/line managers felt that all officers had an adequate knowledge of the range of micro-organisms which cause foodborne disease; their symptoms, incubation and prevention. This area was rated by the training officers/line managers as the strongest, but for 27 per cent was not translated into practice.

Auditing
One year after qualifying, fewer officers were confident about their ability to assess businesses' control of risks than they were about identifying hazards and risks themselves. Students from three colleges rated quality assurance as among their weakest areas, at a time of self-regulation and the need for enforcement agencies to be skilled auditors. In all, 19 per cent of the students at the end of their college course felt their understanding of quality assurance techniques and the methodology of an audit was poor or non-existent, whereas the training officers/line managers rated the understanding of 4 per cent as poor.
Students need to see the application of theory, to develop their skills in identifying hazards and monitoring controls, particularly in potentially high risk processes. Generally it was thought by respondents to the food industry questionnaire that practical training was inadequate and more visits to food companies should be incorporated.

HACCP
The 1993 Lacots survey showed that trade had real concerns about the consistency of enforcement and the fact that inspections and action were not related to risk.(13) North, Taylor and Rudder have also commented on the lack of an understanding and application of risk assessment.(9 14,15) The 1986 core curriculum did not explicitly include risk assessment and some councils have not comprehensively adopted risk assessment in inspection and enforcement.(17) EHOs must use the risk assessment approach or lose their credibility and be subject to increasing criticism. Successful training in Haccp requires experience in the practical application of Haccp.

Communication skills are important too. An explanation of the hazard analysis requirement of the legislation must be given in practical, simple terms, as many premises will not have a formal system in place. As Lacots Guidance suggests, an officer must be sure when he/she leaves the premises, that adequate controls are in place or if not, he/she has taken appropriate action.(17) A sound understanding of risk is needed to determine appropriate action.

Difficulties with the hazard analysis requirement of the Food Safety (General Food Hygiene) Regulations 1995 are continuing to hamper effectiveness as shown in the officers' approach to an inspection of a high risk premises where no hazard analysis had been undertaken by the proprietor. Council procedures should have ensured that newly qualified officers were following Lacots' advice, but, as a quarter did not have their work monitored, the council would not know if they were carrying out a risk assessment and monitoring letters could not identify this.

Sixty per cent of officers used standard paragraphs for Regulation 4 (3) and for the majority, that meant repeating the legal requirement and enclosing a leaflet. Only a third gave an explanation of the requirement. If this is the policy of the local authority, officers would not be able to deviate from it, even though their training had encouraged them to be more effective in seeking compliance. Those working for councils that ensured risk assessment was carried out and an explanation of Regulation 4 (3) given, would be working more effectively, and would have their training and education reinforced.

View from industry
A survey of industry views, a year after the 1995 Regulations were introduced, showed a change of approach was not universal. The criticisms were that there was little or no assessment of risk, there was too much emphasis on structure and cleanliness, EHOs did not have an adequate understanding of the operation of a corporate organisation, there was still widespread inconsistency and advice given on hazard analysis was poor. Legal requirements were generally, but not always, differentiated from recommendations, but some councils used a room-by-room approach and mixed them using an asterisk system to denote recommendations. The time spent appeared to be increasing but was not used to discuss hazard analysis or practices and there was more emphasis on documentation. Copies of correspondence indicated there was no hazard analysis approach to some inspections and no mention of it. The room-by-room approach goes against the process flow approach recommended in Code of Practice 9 and Lacots guidance, and it is hard to distinguish between legal requirements and recommendations.(18,19)

It is essential that the quality of inspections is monitored by managers to ensure a risk assessment approach is used. There were some positive comments however, such as: in -depth reviews of site-specific risk assessments are now taking place; consistency has improved; there is a more sensitive overall approach to the requirements of business and a flexibility and willingness to negotiate. One company EHO commented that the practical and generalist approach of EHOs makes them valuable in industry once they have developed commercial realism.

If newly qualified officers are to be effective in food control, it is essential their training is reinforced by practices and procedures outlined above. There is evidence of good practice, but still too many examples of a lack of change in approach - newly qualified officers finding themselves in councils in the latter category, will either adopt those poor practices or become disillusioned and leave.

CONCLUSIONS
The research showed weaknesses in the education and training affecting a minority of EHOs. In terms of the holistic approach, there needs to be: more integration of subject areas; more integration of theory and practice; structured practical training that is approved, monitored and assessed; more emphasis on research and skills for continued learning and problem solving; more group work across professional boundaries and reinforcement of good practice, once employed. The new core curriculum and logbook have gone some way to address these issues.

In terms of securing credibility in food control, there needs to be: more practical experience in auditing food manufacturers; more experience of enforcement procedures; more experience of investigative procedures, particularly with regard to food poisoning; more practical experience of Haccp procedures; continued reference to academically demanding, specialist texts and journals, to develop a depth of knowledge ,and reinforcement of risk assessment procedures by councils, once employed.

It is essential that there is adequate monitoring of new officers. Failure to follow procedures was a common mistake. Newly qualified officers rely mainly on colleagues for advice and information, so the knowledge and skills of these are important factors in developing competence in new officers. Local authorities' risk assessment policies and procedures must be kept up to date to incorporate hazard warnings, emerging pathogens and procedures used by the industry, such as SAFE.

The role of local government is crucial to the adequacy of the education and training of EHOs, as it is the main provider of practical training and employment on graduation. The core curriculum cannot cover every aspect of environmental health practice and there are good arguments for retaining the holistic base of the profession. Therefore, as with other professions, graduates will need to continue to develop their specialist knowledge and skills throughout their careers. EHOs cannot expect to be fully competent in all areas on the day they graduate. Local authorities must reinforce and support the education and training programme and provide opportunities for further development within CPD.

References
1. Bushell, F. 'The Adequacy of the Education and Training of Environmental Health Officers with specific reference to Food Control' PhD Thesis. Bradford University 1998.
2. Lacots Food Safety Enforcement and Prosecution Policies. June 1993.
3. Lacots Training Opportunities for Food Hygiene Enforcement Officers on Food Issues. Circular. February 1996.
4. EHN 12(9) 7 March 1997:3.
5. Environmental Health Commission. Agendas for Change. Chadwick House Group Ltd. 1997.
6. Audit Commission. Towards a Healthier Environment: Managing Environmental Health Services. London. HMSO.1991.
7. Bushell, F 'Practical Training for Environmental Health Students: Call for Consistency' EHJ 104(2) 1996: 49-52.
8. Lacots Food Safety Enforcement and Prosecution Policies. June 1993.
9. Lacots Food Safety Panel. Report of the Training of Food Control Officers Working Group. September 1993.
10. Audit Commission. Safer Food: Local Authorities and the Food Safety Act 1990. London. HMSO.1990.
11. British Hospitality Association. 'Systematic Assessment of the Food Environment: A Practical Guide to Hazard Analysis for Restaurateurs and Caterers.' British Hospitality Association.
12. Department of Health. A Catering Industry Guide. HMSO.1996.
13. Lacots Food Safety Enforcement and Prosecution Policies. June 1993.
14. North, R., Duguid, J., Sheard, M. 'The Quality of Public Sector Food-Poisoning Surveillance in England and Wales, with specific reference to Salmonella Food Poisoning.' British Food Journal. 98(2/3) 1996: 4-109.
15. Taylor, E A. Food Safety and The Catering Industry. PhD Thesis. 1994
16. Rudder, A. An Evaluation of LA Food Safety Units To Ascertain Whether A Standard Service is Offered. M. Phil. Thesis. University of Salford. 1996.
17. Lacots Guidance on Food Safety Enforcement Policies. 1994.
18. Department of Health. Food Safety Act 1990 Code of Practice No 9 Food Hygiene Inspections (Revised). HMSO.1995.
19. Lacots. Guidance on Food Hygiene Risk Assessment. 1995.