Emily Miles addressed the 2021 Chartered Institute of Environmental Health's (CIEH) Year Ahead Conference which, in partnership with the Chartered Trading Standards Institute (CTSI), hosted key policy discussions, examining the challenges to the future of public health and the impact of the pandemic.
Transcript as follows:
Thank you so much for inviting me to speak to the CIEH again and take part in this discussion.
Before I set out some thoughts on our future plans, I wanted to say a big thank you to EHPs and TSOs for all of your efforts over the last year in managing the impact of the pandemic on the food system, under unprecedented levels of pressure.
I would also like to thank you for your work in supporting the FSA to implement ‘Natasha’s Law’, the new food allergen labelling rules which will boost protection for the two million people who live with food allergies in this country. You’ve done this in the public sector, and the private sector.
The work you do every day to protect the public is an invaluable service to our communities.
At the FSA, how we shape the future is a question we care about
The immediate future is dominated by recovery from COVID-19.
When I spoke to the CIEH in June, the FSA had just launched the Local Authority Recovery Plan. This was developed to guide local authorities to get back to business as usual following a year of managing COVID-19.
I can report that local authorities are starting to get back on track.
Back in March 2021, around half of local authority food teams' resources were being deployed on to other tasks. Now resources are being returned to food teams.
In October we found, for food hygiene teams, levels were back up to 81% in England, 64% in Wales, and 76% in Northern Ireland. For food standards teams, the figures were slightly higher for each country.
In June 2020, 461 establishments received their hygiene rating. In January 2021, the figure was 4010. By September 2021, they were back up to 14000 hygiene ratings awarded.
There is still a way to go. As of September, there were 63,000 businesses ‘awaiting inspection’. We know that nearly a third of these are ‘other catering premises’, including home-based caterers.
We have asked local authorities to prioritise premises that are more risky, so it is good to see that this advice appears to be being followed. For food standards work, early evaluation of our pilots is indicating that resources are being targeted more effectively at the highest risk businesses that the current model allows, which bodes well for the future.
Recovery is happening, but our impression is that it is hard work
We hear anecdotally from many councils that some restaurants and cafes’ standards have slipped over the pandemic, and they are having to do more work to support businesses to reach acceptable standards.
It was right that COVID-19 was the priority for local authorities. COVID-19 is a nasty, life-threatening disease, and so the measures taken to prevent its spread were essential to protect the public. But we can’t delay food inspections indefinitely.
The FSA’s own internal research has linked higher FHRS ratings to lower levels of microbes found in food businesses, ultimately lowering the risk to consumers of foodborne illness when eating food from higher rated premises.
So, every single action you take with a business, to improve their food hygiene practice, protects consumers. Many inspections and ratings have been delayed, and this makes the FSA feel uncomfortable on behalf of consumers.
Thank you for all you are doing to catch up and work with businesses to provide safe and authentic food to everyone.
You are doing this with a food industry and regulatory landscape that have changed over the last few years and will continue to do so.
More and more food is being sold online, technology and new digital platforms are changing the way we buy food, and micro-businesses can access large markets easily.
At the FSA, we work to understand the shifts in the food industry and what impact they could have on consumers, businesses and local authorities.
As with all changes, there are opportunities
For example, a shift in the way we consume protein could ensure that we use less carbon in food production; genomics could improve the traceability of food; while digital innovation along the entire food chain offers unprecedented new opportunities for consumer choice.
However, with these opportunities comes risk. Cell cultured meat is very energy intensive to produce and we do not know what the long-term health effects might be of consuming this type of heavily processed food.
Like raw drinking milk, or rare burgers, will some types of novel food need extra attention from food handlers to make sure it is safe? Or will we need to put additional information on labels to discourage vulnerable consumers from eating it?
All this needs to be worked out as these new foods are brought to market. The FSA stands ready to make these assessments for regulated products.
Taking another example. A greater choice of food online presents the risk of a lawless marketplace with platforms hosting dubious sellers refusing to take their responsibilities seriously.
It’s not always very easy for a local authority environmental health officer to get an audience with a global multinational social media company about a product or a seller that’s on their platform.
I think there are a number of implications for the FSA’s work over the next few years – and indeed implications for other regulators, local authorities, and EHPs to consider.
We must continue to put consumer interests at the heart of everything we do. We need to ensure that consumers are safe, that they understand what they are buying, and have access to food they can trust.
We need to make sure consumer interests and perspectives are taken into account
We need to adapt a regulatory system based on ‘bricks and mortar’ premises for a digital world. Data, networks, and sensors are fast becoming the tools which businesses use to maintain the integrity and resilience of their systems.
Regulators, EHPs, and TSOs need to engage with businesses as data generators, not just food producers. This is something our Achieving Business Compliance regulatory reform programme is already focussed on and where I want the FSA to play a bigger role.
Our regulated products authorisation service, which we took over from the EU, will also be essential. Regulated products require a premarket safety evaluation and approval by Ministers before they can be used in the UK market.
This service is there to protect the public, but it must also support the food industry innovations, like alternative proteins, that could help create a healthier more sustainable food system.
Risk analysis will require more than just a look at the hazards to human health. It will mean taking into account things like economic impact, behavioural science, environmental impact and consumer views.
We will need to encourage more research, expand our range of academic partners, and keep our eye on the horizon so we can identify and address the gaps in our knowledge.
For those of you engaged in regulatory compliance, new types of food, with new risk management expectations, requires new knowledge. This will require upskilling, guidance, and training. And new ways of selling food requires different interventions with those sellers.
The big challenges ahead for us as a society are the climate crisis
This could present an existential risk to us, and long-term health, especially obesity and the non-communicable diseases it causes. Food has a part to play in causing these problems, and therefore a real part to play in being a solution to these problems.
Government should be leveraging the regulatory relationships local authorities and the FSA have with food businesses to shape expectations of those in the food system.
I would like to see the forthcoming Defra white paper on food to be as bold as possible in considering the levers and mechanisms that could help bring about real change in the food system. For the consumers who want to choose to eat healthily and sustainably, it can feel like swimming upstream. Government needs to help make it easier to swim.
For the FSA, the future is about maintaining the standards which have protected consumers for decades, and having the agility to respond to a complex food system.
EHPs and local authorities will continue to play a vital role in the future. Our aim, as ever, is to meet these challenges together.