Incident Management Plan: annex A – routine (operational) incident management

Routine incident response 

The Incident Team (England) and Consumer Protection Teams (Wales, Northern Ireland) lead the administrative and investigative response to all food/feed incidents.

The Head of Incidents / Consumer Protection usually acts as Incident Manager and ensures all teams meet their incident handling responsibilities.

The Head of Incidents and Resilience Unit (IRU) (or equivalent position in Wales and Northern Ireland), and the Head of Resilience and Prevention (or an equivalent) who can advise on incident protocols and offer an independent opinion, will decide, based on the written problem statement, whether an incident meets the criteria for escalation. The Incident Management Co-ordination Group (IMCG) will be convened during a non-routine incident to manage and co-ordinate the response at a tactical level.

The Food Standards Agency (FSA) response varies with incident scale. Routine responses may include:

• issuing Food Alerts For Actions, Product Recall Notices, Allergy Alerts, INFOSAN notices; incident logging; and IMCG administrative support
• developing communications strategies and question and answer materials
• conducting sampling, surveillance and monitoring
• involving Field Operations and, when relevant, National Food Crime Unit (NFCU) for food crime or online investigative needs

Incident classification assessment (ICA)

The incident classification assessment (ICA) is an auditable decision-making tool used to classify incidents and record strategic and tactical considerations. It does not quantify scientific risk.

Initial assessment is led by England’s Incident Team or devolved Consumer Protection Teams, overseen by the Incident Manager. Key ICA criteria include:

• ability to apply interventions to reduce concern
• concern levels and affected consumer groups
• efficacy of product identification and withdrawal or recall of product
• food integrity
• health impacts
• health security risks
• international engagement
• known incident hazard type
• media perception risk
• number of products or scale of distribution
• political concern

ICA updates may require input from internal policy teams, risk assessors, analysts, Other Government Departments (OGDs) and stakeholders. The Incident Manager oversees the ICA for all incidents.

Food crime may not increase food safety severity but increases investigative complexity. NFCU engagement should occur early to support evidence capture and operational coordination.

Incident classification 

An Incident response can be activated for food chain integrity, authenticity, food crime, business continuity, or health security risks related to food or feed, including local or national outbreaks. Outbreaks are managed by the public health authority in each UK nation, while animal health issues are handled by the Animal Health and Plant Health Agency (APHA).

Incident classification reflects the suspected impact and required levels of resource and authority.

Three non routine classifications are recognised: Serious, Severe, and Major, each with increasing magnitude and senior oversight and strategic involvement. Escalation may occur even if the FSA is not the Lead Government Department.

Classification descriptions 

Routine incidents are the most common and are managed with standard processes. They may involve outbreaks of illness, statutory breaches, contamination, animal disease implications, or pollution, and may generate public or media concern.

Serious incidents exceed routine capacity and require short term, tactical decision making for the resolution of the incident and resource allocation to be made by the Incident Management Coordination Group (IMCG). These tend to be the majority of our non-routine incidents and are usually quite complex.

Severe incidents require strategic leadership and decision making and to set the longer term, strategic direction of an incident for the IMCG. Escalation to this level leads to the invocation of the Strategic Incident Oversight Group (SIOG). Incidents of this type usually require significant cross-departmental communications strategy and collaboration. These usually have a significant impact on resources which may require reprioritisation of priorities

Major incidents are those which require a central government led co-ordinated response. The FSA may take on various roles, including acting as the Lead Government Department.

FSA classifications align with central government emergency classifications and responsibilities. The strategic direction and tactical management during an incident is subject to continuous review and adjustment

Responsibilities, accountability and command & control arrangements in England, Wales and Northern Ireland

Routine

• lead: Incident Manager; Heads of Incidents/Consumer Protection Division in England, Wales and Northern Ireland
• escalation: Head of IRU / devolved equivalents and other internal parties
• accountability: Director of Operations (England and national impact incidents) / Northern Ireland & Wales Directors
• operational tasks: Issue notices (Food Alert for Action [FAFA], recalls and allergy alerts), INFOSAN, SitReps, developing comms lines, Q&A, IMCG support

Serious

• lead: IMCG and Incident Manager
• escalation: Strategic Incident Director (SID) / IMCG Chair / IMCG
• accountability: Strategic Incident Director (SID), Director of Operations (England and national impact incidents) / Northern Ireland & Wales Directors
• tasks: Tactical response, daily rhythm, risk assessment and risk management, stakeholder coordination, SitRep co-ordination, Communications and media strategy approval

Severe

• lead: SIOG (strategic), IMCG (tactical)
• escalation: Strategic Incident Director (SID) / IMCG.  IMCG Chair provides a 1-page briefing note that sets out the facts, impacts and next steps to inform SIOG’s discussion
• accountability: SID and / or CEO
• tasks: Answers the strategic questions to establish FSA’s strategy response, liaise with (and includes) OGD equivalents as required

Major

• lead: SIOG (Strategic) / SID (CEO may act as SID), IMCG (Tactical), IMCG Chair
• escalation: COBR Unit
• accountability: FSA CEO and Ministers
• tasks: central government coordinated response, COBR participation, CRIP, ministerial briefings. In the event of a COBR(O) or COBR(M), the most relevant party with expertise to the situation would attend

How scale of impact drives escalation

Media

• serious: increasing regional interest requiring co-ordinated briefings, statements, media monitoring and engagement with OGDs
• severe: continuous national interest necessitating comprehensive media monitoring, regular briefings and statements, as well as coordinated engagement with other government departments
• major: sustained national and/or international interest requiring government level statements

Public health

• serious: widespread (UK) or multi-country cases of serious or prolonged illness, some requiring short-term hospitalisation, or isolated deaths in vulnerable groups
• severe: UK wide or multi-country serious and prolonged illness, high number of deaths or isolated deaths in vulnerable groups
• major: widespread national / international deaths

Industry impact

• serious: number of batches affected, widespread complex food supply chain involving numerous manufacturers, issues with compliance from several sources requiring closure of plant(s)
• severe: numerous to widespread batches affected, requiring several plant closures for detailed investigation or multi country impact, food supply chain issues
• major: widespread national / international closures threatening import / export markets and loss of confidence in the integrity of food supply chain in the UK

Consumer concern

• serious: heightened loss of consumer confidence one or some aspects of the food chain requiring specific internal investigations
• severe: significant national loss of confidence in aspects of the integrity of the food supply chain in the UK requiring co-ordinated cross government briefings/ statements and/or FSA wide investigation / reputational risk to role of FSA as a regulator  
• major: widespread loss of public / industry / international confidence in the integrity of the food supply chain in the UK