Incident Management Plan: communications and engagement

Communications

5.1 Communication during an incident is key, not just to the public but to other stakeholders too, whether they are industry, consumer groups, the media, local authorities (LAs), government ministers or other national or international agencies.

The Food Standards Agency (FSA) is committed to being as open as possible about what we do and why we are doing it.

The FSA will:

• give people and stakeholders suitable information where they need to act and to keep them informed
• be open about emerging incidents and what the FSA is doing to investigate them, even if we do not have the full details, including the source
• provide timely response as appropriate to media enquiries
• protect enforcement action or legal proceedings by not publishing information that may prejudice investigations, unless the need to protect consumers would require immediate release of information

Communications management

5.2 When a high-profile incident is particularly widespread or poses an immediate risk to people’s health, the FSA will issue communications, including news stories, sharing information on social media, and responding to requests for information from the media and the public. The FSA will act as the main source of information on food and feed related issues during incidents and will work collaboratively with others to cascade information to the public, industry, and businesses as well as Other Government Departments (OGDs), Non-Government Organisations (NGOs) and LAs. 

5.3 Where OGDs are leading the investigation, the FSA will work closely with them. The FSA applies the same approach to risk assessment and risk management across England, Wales and Northern Ireland, and will manage its communications in the same proportionate and considered manner. The FSA also works closely with Food Standards Scotland (FSS) to ensure that messages are consistent.

Communications approaches

5.4 In any high-profile incident that relates to food or feed, there are a number of groups who need to be kept informed. They include:

Consumers

5.5 When an incident is considered serious with an immediate risk to the public, the FSA will seek to rapidly reach people using a mix of channels, appropriate to the audience, to give context and further explanation of risks. 

5.6 The FSA will also consider whether to give the public information about an ongoing incident even if the cause is not known if it is appropriate to do so. An example of this might be an outbreak of foodborne illness spread over several weeks or months, where there is a spike in cases linked to a common strain of pathogen. Often, the actual source takes time to investigate and even establishing a link to food can be difficult to prove. 

5.7 The FSA will be open and factual in its communications about the potential risk, the products affected, and the advice given. The FSA will state what actions the food business operator (FBO) involved has taken or is taking (for example, to remove the product from sale) and give advice on what to do if they have the affected product or have already consumed it.

Industry and local authorities (LAs)

5.8 Many incidents will require close collaboration with industry and LAs on communications. We will work with FBOs on steps they are taking to highlight a recall through social media, displaying point of sale notices or other means.

5.9 On occasion, the FSA may still feel it necessary to publish a news story or undertake social media activity even when the relevant FBOs are taking all the appropriate action in withdrawing or recalling an affected product. 

5.10 The FSA will, where appropriate, show news stories to relevant FBOs and LAs in advance of publication to confirm factual accuracy. The FSA will be prepared to consider new information or additional comments, if they are relevant, but will retain full editorial control.

Media handling

5.11 The FSA spokesperson will be the person who will give the public the most confidence in the FSA’s response to the incident. This will be agreed by Strategic Incident Oversight Group (SIOG) based on advice from the FSA Communications team. Although each incident is different, the spokesperson is most likely to be either the Chief Executive or Strategic Incident Director (SID) if the request is about our response, and/or we have an ‘ask’ for the business or the public, and/or the CSA if the request is about the risk assessment or science. If it is about commenting to the public on the role of the FSA and its handling of the incident, this is more likely to be the FSA Chair.

FSA board and staff

5.12 We use our internal communications channels to ensure we keep FSA staff updated during non-routine incidents as agreed in the Incident Management Co-ordination Group (IMCG) / SIOG incident communications strategy.

5.13 The SID as SIOG chair will be responsible for providing updates and agreeing the frequency of updates between the FSA Board, the FSA Chair and SIOG. 

Ministerial Communications

5.14 The SID through the SIOG will lead on updates to Ministers working across the Devolved Administrations as appropriate. Frequency is determined by SIOG as part of the incident Daily Rhythm. Further information on FSA’s communications with Ministers is included in the FSA’s internal standard operating procedures (SOPs). 

FSA in support 

5.15 In multi-agency incidents or emergencies where the FSA is not the lead department, the agency adopts a supporting role. In such cases, the FSA will contribute risk assessments, scientific evidence and risk management advice through Strategic Coordination Groups (SCG) as per the emergency response framework set out in the Civil Contingencies Act 2004. 

5.16 When the FSA is in a multi-agency supporting role, the Amber Book principles as laid out in the FSA’s non-routine incident management plan will apply.

5.17 Where there are wider political and public policy considerations, Ministers may want to make final decisions on risk management although the FSA reserves the right to publish independent advice if deemed appropriate. 

Engagement

Linking to Other Government Departments (OGDs) and Agencies

5.18 To ensure clear understanding of roles and responsibilities across UK government, the FSA has close working relationships with all the relevant government departments and agencies.

5.19 In the event of a non-routine incident, we will work with OGDs or agencies, as appropriate. The nature and scale of the incident will determine which organisations need to be involved and in what capacity. 

5.20 Often, OGDs will lead on specific incidents, for example Department for Health and Social Care (DHSC) and the relevant public health authority will lead on the public health impacts of foodborne illness outbreaks. In these instances, the FSA command and control structure may be set up to inform the OGD’s response and to cover the FSA’s areas of responsibility. The FSA escalation process should reflect its lead government responsibilities or supporting role, when dealing with food contamination during a foodborne outbreak.

5.21 The IMCG, in liaison with the Incident Manager, will consider options for communication including hosting meetings with relevant government officials across the UK, setting up ‘bird table’ meetings, inviting representatives from OGDs to be a member of IMCG or arranging exchange of information through sharing of incident Sit-Reps. The FSA’s Stakeholder Management Plan contains further details.

Linking to Local Authorities (LA)

5.22 Consideration of enforcement action required will be carried out as part of the FSA command and control processes. 
 
5.23 The FSA works with LAs as set out in The Food and Feed Law Codes of Practice and practice guidance. The expectations for action taken by LAs are communicated by various mechanisms. Plans for broad enforcement controls, such as sampling plans and advice to FBOs, may be decided at FSA strategic or tactical levels and funding considered. IMCG will engage with those LAs on decisions made during a serious incident.

5.24 The decision on taking legal action against an FBO will need to be made in accordance with relevant legal requirements, the LA’s own enforcement policy and the Food and Feed Law Codes of Practice, at LA level and in close liaison with the FSA. During an FSA major incident, the LAs may enact their local emergency procedures (via their own Local Resilience Forums) setting up their own strategic co-ordination mechanisms, which the FSA may be invited to attend.

5.25 The FSA is responsible for actions taken by dairy hygiene inspectors, wine inspectors and meat hygiene teams. 

5.26 Enforcement action may take place through activity linked to a food crime investigation by the National Food Crime Unit (NFCU), whether undertaken with partners or unilaterally.

5.27 There are instances where enforcement activities may be required in liaison with other government partners, such as Defra's agencies or DAERA. In these cases, the FSA will work closely with partners through the mechanisms outlined above.

5.28 Figure 4 displays the FSA’s response at a tactical and operational levels and the tools it uses to communicate and share information with internal and external enforcement partners. 

Figure 4: FSA enforcement partners

Flow diagram showing the Food Standards Agency (FSA) incident enforcement process. At the top, a box labeled “FSA tactical response” explains that enforcement requirements are set, including who should act, the legal basis, and resources needed. An arrow leads to “FSA operational response,” where the FSA liaises with enforcement partners to deliver the incident response. This flows to “Enforcement communication/sharing,” listing emails, phone calls, protocols, a knowledge hub, and enforcement letters. From this stage, two arrows branch to parallel boxes: “Operational enforcement – internal,” naming Dairy Hygiene Inspectors, FSA Field Operations, and the NFCU; and “Operational enforcement – external,” listing local authorities and other government departments such as APHA, CEFAS, DAERA, and DEFRA.

International links

5.29 Although the UK has left the EU, the FSA continues to liaise with the EU Commission on Crisis management as a matter of best practice and following the UK’s international obligations.

5.30 The FSA’s Incidents Team in England is the national contact point in the International Food Safety Authorities Network (INFOSAN) – run by World Health Organisation (WHO) and the Food and Agriculture Organisation of the United Nations (FAO) for communication between national food safety authorities regarding urgent events. FSA Northern Ireland continues to use RASFF and TRACES for international incidents.

5.31 INFOSAN, is used to exchange information on serious risks to public health in relation to food and feed which might impact on other countries, this function is based on International Health Regulations 2005. 

5.32 The UK shares a land border with the Republic of Ireland (RoI), and the FSA and the Food Safety Authority of Ireland (FSAI) work closely together to ensure the effective management of food incidents occurring in either or both jurisdictions. This arrangement is formalised by a Memorandum of Understanding between the two organisations. The FSA also works with the Department of Agriculture, Food, and the Marine (DAFM) in the RoI, via the established links with FSAI. A multi-agency approach is taken involving the relevant UK and RoI authorities to address non-routine incidents affecting either or both jurisdictions.

5.33 Where appropriate (for example where deception or fraud in another country is suspected as being a contributing factor to the root cause of an incident), the NFCU currently has the capability to share requests for assistance with EU member state food fraud contact points, via a protected section of the AAC IT platform while available or via established bilateral country contacts.