Incident Management Plan: Definition of an incident

The FSA defines an incident as:

“any event where, based on the information available, there are concerns about actual or suspected threats to the safety, quality or integrity of food and/or feed that could require intervention to protect consumers’ interests. Quality should be considered to include food standards, authenticity and composition”.

The IMP sets out the strategic, tactical, and operational command and control structure and procedures for managing food and feed safety incidents, as well as other incidents, including those that fall outside of our remit but that require tactical and/or strategic measure such as a business continuity or pandemic and other events that impact on delivering of our business. 

The following section covers the alerting process for the FSA to respond to an incident, as well as the activation and escalation process which ensures the incident is managed at the appropriate level of authority.

2.1 Alerting of an incident 

Initial alerts may originate from many sources as described below. 

Internal: An incident may be notified by internal divisions, such as Field Operations or Receipt and Management Team (RAM). An incident may also be identified from intelligence received or generated by the National Food Crime Unit (NFCU). Relevant information which may indicate a food incident should be shared with the Incidents Team; this may be immediately after the receipt of information, or at a later point in the development of a strand of intelligence, for example, if a current safety concern relating to food on the market becomes apparent.

External: Industry and food business operators (FBOs) report incidents directly to the incidents teams across England, Wales and Northern Ireland via email or via the on-line reporting tool and use the equivalent reporting process for FSS. FSA incidents teams in England, Wales, and Northern Ireland operate a 24/7 response to food and/or feed-related and environmental contamination incidents. Members of the public can report food safety concerns to the FSA helpline (020 7276 8829) or via email helpline@food.gov.uk.

Information on incident reporting is available on the FSA’s website report an incident. FSS has its own reporting process in place as detailed within the Food Standards Scotland Incident Management Framework. 

Local Authorities (LAs): LAs have a responsibility under the Food Law Code of Practice (with separate codes for England, Scotland, Wales and Northern Ireland) to inform the FSA / FSS of national (non-localised) or serious localised incidents.

Other Government Departments (OGDs): Some incidents, such as serious outbreaks may also be notified by the public health authority’s in each nation. The FSA is also informed of incidents via OGDs and the emergency services if they consider an incident or cross cutting issues may potentially impact on food and/or feed safety.

International: International Food Safety Authorities Network (INFOSAN) or Import of Products, Animals, Food and Feed System (IPAFFS) are also important sources. Since the EU Transition on 1 January 2021, the UK is no longer an active member of the EU Commission Rapid Alert System for Food and Feed (RASFF) network. The UK now has third country access to RASFF and the FSA only receives food and feed safety related information where the UK is affected.

On receipt of an incident notification, classification of the incident is carried out by means of an Incident Classification Assessment (ICA), as set out in section 2.2. 

If during a routine incident it is considered that successful management requires levels of resources and authority beyond those available for normal incident handling, then a decision will be made on whether to escalate to non-routine incident classification levels.

2.2 Classification of incidents

The FSA is responsible for responding to all food and feed incidents that it is notified of, and in the initial stages all incidents will be regarded as a suspected risk to public or animal health until there is evidence to the contrary. 

An incident response may also be activated for food chain integrity, food authenticity, food crime issues, Business Continuity or as part of a co-ordinated response to a serious localised or non-localised (for example, national) outbreak. Such outbreak responses are led by the public health authority in each UK nation and those relating to animal health are led by the Animal Health and Plant Health Agency (APHA).

The FSA assigns an ‘incident classification’ by recognising and understanding the suspected impact of an incident and then considering how the incident should be managed in terms of levels of resource and authority. 

This plan recognises four levels of incident classification: routine, serious, severe and major, based on the principle of escalation of management. The higher the level of magnitude of an incident, the greater the involvement of senior FSA staff, and the more tactical and strategic measures are required. Non-routine incidents are routine incidents that have met the required criteria to be escalated to serious or severe. This may be required even when the FSA is not the Lead Government Department (LGD).

2.3 Classification description

Incidents dealt with by the FSA are routine and are managed at an operational level using  everyday resources and procedures.  They may involve evidence of illness, impact on vulnerable groups, breaches of statutory limits or non-compliance. They may also include barn fires or oil and chemical spills, which have an actual or potential impact on food and feed. In some cases, the public or media are likely to express some concern.  Non-routine incidents are classified as serious, severe or major.

Serious incidents are classified as those matters which cannot be dealt with using everyday resources and procedures. They require decision making and resource allocation to be made at a higher level and require the invocation of the Incident Management & Co-ordination Group (IMCG) read section 3.5.

Severe incidents are classified as those which require strategic level input and support by the invocation of the Strategic Incident Oversight Group (SIOG) see section 3.8. Incidents of this type requires significant cross-departmental collaboration and a communications strategy and are often longer in duration and have significant impact on resources.

Major incidents are classified as those of such significance they require a central government co-ordinated response. Depending on the nature of the incident the FSA may assume various responsibilities including acting as the LGD.

FSA incident classification relates to the central government emergency classification. Table 1, below, shows responsibilities for leading incidents, escalation decisions and lines of accountability for incident classification levels. The strategic direction, tactical and operational management during an incident is subject to continuous review and adjustment.

Table 1: Lines of accountability for incident classification level

Classification	Who is the Incident Lead?	Who decides escalation and classification?	Accountabiity
Routine (Green)	Incident Manager, Heads of Incidents/Consumer Protection Division (CPD) England and Northern Ireland and Wales and Equivalents in FSS.	Head of IRU (England and national impact incident), Head of Incidents/Incident Management or CPD (Wales or Northern Ireland)	FS Director of Operations (England and national impact incident), FSANI and FSAW directors (Northern Ireland and Wales)
Serious (Yellow)	IMCG, Chair of the IMCG, Incident Manager	IMCG, Chair of IMCG, Incident Manager	FSA Director of Operations (England and national impact incident), FSANI and FSAW Directors (Northern Ireland and Wales), FSS CEO
Severe (Amber)	SIOG (strategic), Strategic Incident Director (SID) (this can be a Devolved Director), IMCG (tactical), Chair of IMCG, Incident Manager	Civil Contingencies Secretariat (CCS) to be notified, SIOG, SID	FSA Director of Operations, SID
Major (Red)	SOIG (strategic), Strategic Incident Director (SID), IMCG (tactical), Chair of IMCG, Incident Manager	Not applicable	FSA Chief Executive Officer, Westminster government ministers and devolved government ministers

2.4 Incident assessment

The purpose of assessing the risk associated with an incident is to determine the potential scale, scope, nature and impact of the incident. There are several components of incident assessment, the main part is the Incident Classification Assessment (ICA).

Risk management advice and food or feed safety risk assessment can contribute to the classification of an incident; they are, however, rarely conducted for the purposes of incident classification, and would more likely be performed during the incident response.

Incident Classification Assessment (ICA)

The ICA prioritises and classifies an incident. It is a decision-making process that ensures all the factors relevant to determining the nature of an incident are considered. It is auditable and allows strategic and tactical decisions to be recorded in a structured way. It is not a scientific methodology for assessing and quantifying risk.

The initial assessment will be largely down to the Incident Team in England and consumer protection teams in Wales and Northern Ireland, with oversight from the Incident Manager. They make decisions by applying a process of set criteria indicators and using their professional judgement. The ICA criteria indicators are: 

• food integrity risk
• media perceived risk
• political engagement
• concern levels
• number of product or distribution
• tracking and withdrawal of product
• consumers affected
• known incident type
• health effects

The assessment may require input from policy experts, risk assessment and analytical experts both internal and external (internal FSA policy teams and Other Government Departments (OGDs). The ICA will be updated as further evidence and information becomes available. For all incidents (routine and non-routine) the Incident Manager oversees the ICA to help assess the impact and scale of the incident.

The presence, or suspected presence, of food crime issues might not impact on the seriousness of an incident from a food safety perspective. However, it may present heightened complexities from a point of view of evidence capturing or operational co-ordination, both internally and externally. In such circumstances, NFCU would get involved at an early juncture to allow for a joined-up approach and appropriate consideration of evidence capture and other aspects of the investigative approach to be carried out in an appropriate way.

Risk Management

The process, distinct from risk assessment, is the weighing of policy alternatives to accept, minimize or reduce assessed risks and to select and implement appropriate options.  Done in consultation with all interested parties, considering risk assessment and other factors relevant for the health protection of consumers and for the promotion of fair-trade practices, and, if needed, selecting appropriate prevention and control options.

Scientific, risk assessment

A scientific risk assessment will be undertaken in order to determine human and/or animal health risks associated with an incident and informs the ICA. The risk assessment is co-ordinated by the FSA’s Incidents Team in England and consumer protection teams in Wales and Northern Ireland and in liaison with FSS Scientific Risk Assessment Team where appropriate. They liaise with the relevant policy teams, who will commission a risk assessment from the Risk Assessment Unit (RAU), if required. The involvement of ODGs such as Department of Health and Social Care (DHSC) or Department of Environment and Rural Affairs (DEFRA) may be required. Risk assessment involves the following steps:

Hazard identification: involves identifying biological, chemical, radiological, physical agent(s) and/or allergens capable of causing adverse health effects. In toxicology, hazard identification involves identifying the type and nature of adverse effects that an agent has an inherent capacity to cause in an organism, system or (sub)-population.

Hazard characterisation: involves evaluating the nature of the adverse health effects associated with the hazards. In toxicology, hazard characterisation involves describing the inherent properties of an agent or situation having the potential to cause adverse effects. 

Exposure assessment: characterises the amount of a hazard that may be consumed by members of the exposed population(s). It evaluates the likely intake of hazards via food as well as exposures from other sources if relevant. 

Risk characterisation: this step draws together the information from the stages of hazard identification, hazard characterisation and exposure assessment to give an overall assessment of the nature of the hazard and the extent to which people are likely to be exposed. It estimates the probability and severity of known or potential adverse health effects in a given population to produce an overall risk estimate. The overall uncertainty associated with the risk estimate is described during this stage.

2.5 Criteria for escalation

Making sure the incident is managed at the appropriate level is key to a successful incident response. 

Escalation of incident response levels is driven by the nature, scale, scope and impact of incidents coupled with the expectations of the FSA to respond. Escalation to non-routine should be considered even when the FSA is not the LGD as a strategic /tactical response may still be required (with SIOG alerted). An example of this may be an animal health related incident (for example, infectious and/or notifiable disease).  The flowchart (Figure 1) below displays the incident escalation process from routine to non-routine and includes:

• incident notification (including the facts and potential impacts)
• risk assessment and Risk management advice (as required)
• consideration whether  based on the evidence presented, the incident can be dealt with using everyday resources and procedures
• where escalation is not required, the incident continues as routine and follows the usual process
• where in incident cannot be resolved using everyday resources, procedures; requires decision making or strategic direction then escalation to non-routine incident is agreed and its classification status (Severe or Major) is decided.

Figure 1: Incident escalation process

Rapid escalation: In the case of an obvious severe incident the escalation steps may be taken rapidly. The Head of Incidents and Resilience Unit (IRU) will notify the Director of Operations, the Chief Executive Officer and the directors for Wales and Northern Ireland. It is still important in these instances to make sure the correct incident set up process is carried out.

Major incidents: Escalation to a Major incident will occur if the severity of the incident is such that it may threaten serious damage to human welfare or serious damage to the environment. In such cases it may be classed as an ‘Emergency’ in the terms of the Civil Contingencies Act (2004). Those with FSA strategic oversight responsibility will communicate with Cabinet Office and the Civil Contingencies Secretariat (CCS) who then decide whether a central co-ordinated government response is required, and Cabinet Office Briefing Room (COBR) should be activated or devolved equivalents.

Escalation to International stakeholders: In the event of a major food- or feed- related incident, occurring at international level, the Incident teams are responsible for the coordination of communication at an EU and international level.  

Table 2, on the next page provides an illustration of how scale of impact affects the scale of the FSA’s response. The table offers indicative examples to demonstrate how influences apply.

Table 2: Matrix showing how FSA incident classification may be applied with examples of impacts.

Issue/classification	Routine (green)	Serious (yellow)	Severe (amber)	Major (red)
Media	Short lived local interest requiring brief statement	Increasing regional interest requiring co-ordinated briefings and statements	Prolonged, national interest requiring intense media monitoring and frequent briefings and statements	Sustained national and/or international interest requiring government level statements
Public health	Localised or serious or widespread cases of illness, some requiring short term and/or low numbers of hospitalisation	UK widespread or multi-country cases of serious or prolonged illness, some requiring short term hospitalisation	UK wide or multi-country serious and prolonged illness, high number of deaths or isolated deaths in vulnerable groups	Widespread national and/or international deaths
Industry product	Can be 1 small batch affected from a single source requiring simple remedial action or several batches affected from several sources requiring remedial action to remove from food chain	Several batches affected and/or more widespread issues with compliance from several sources requiring closure of plant(s)	Numerous to widespread batches affected, requiring several plant closures for detailed investigation or multi-country impact	Widespread national and/or international closures threatening import/export markets and loss of confidence in integrity of food supply chain in the UK
Consumer concern	Short term, local consumer concern requiring routine investigation and a brief statement of reassurance	Heightened regional loss of confidence in one or some aspects of the food chain requiring specific internal investigations	Significant national loss of confidence in aspects of the integrity of the food supply chain in the UK requiring co-ordinated defensive briefings and statements and/or FSA wide investigation	Widespread loss of public / industry / international confidence in the integrity of the food supply chain in the UK.