Incident Management Plan for Non-Routine Incidents
Incident Management Plan: Incident review and exercise planning
A review process takes place for those non-routine incidents where lessons have been identified.
6.1 Incident review
A review process, including RCA methodology, will take place for those non-routine incidents where lessons have been identified.
The FSA’s Emergency Preparedness Resilience & Response Board (EPRRB) has oversight responsibility for making sure the FSA identifies lessons from incident review and emergency exercises to ensure FSA capability in this respect is maintained.
It delegates functions relating to incident review planning to the Incident Review Sub-Group (IRSG). This is to ensure incident handling continually improves and to understand the root cause of incidents to help prevent future incidents of a similar nature. The FSA may undertake joint reviews with partner organisations.
Various mechanisms for review exist and a single review may include more than one of the mechanisms shown in the table below.
Table 4: Timescales for incident review type
| Review type | Timescale |
|---|---|
| Hot wash up or hot debrief | Within two weeks after the incident has been closed or period of duty if incident is protracted with responders (at each location). |
| Organisational debrief (cold debrief) | Within eight months post-incident |
| Multi-agency debrief (cold debrief) | Within four to six weeks post-incident |
| Third party post-incident report | For protracted or high impact incidents, the FSA may commission a third-party post-incident report. Timescales for these would need to be agreed and would be supported by terms of reference. Output will be in the form of a report with recommendations. |
The IRSG advises on case-by-case basis, on the method of review. In general, cold debrief workshops are mainly used for multi-agency incidents involving external stakeholders, and questionnaires are used for review of incidents managed internally.
Review reports are submitted to IRSG and may be submitted to the EPRRB.
6.2 Root Cause Analysis
Root Cause Analysis (RCA) allows food businesses to identify the initiating cause(s), which led to the food incident and, additionally, the stage at which intervention could reasonably be implemented to mitigate risk and prevent future recurrence. Thus, it provides a better understanding of when, why, and how food safety incidents occur in accordance with the Food Law Code of Practice (England) 5.2.5.
Alongside other bodies of work, the FSA encourages FBOs to conduct RCA after a food incident has occurred (especially when a recall of a product(s) was required) and share the learnings. This helps the FSA to identify emerging incident causal factors, best practice and working with industry/enforcement bodies to mitigate future incidents.
Where an element of food crime is involved, or suspected to be involved, in the RCA of a food incident, it will be necessary for evidence gathering opportunities to be considered before a food business is requested to perform such an analysis, if it is even appropriate in these circumstances for such an analysis to be requested. This evidence gathering could include the procurement of witness accounts or exhibits in a prompt and evidentially sound manner.
6.3 Exercise planning
The FSA builds and embeds lessons learned from exercising and drilling as well as from reviews of incidents to continuously improve organisational-wide incident resilience and capability.
The EPRRB oversees the FSA’s emergency exercise programme which includes a training and drilling programme. The programme includes participation in exercises led by OGDs.
The FSA exercise programme has two basic aims:
- to exercise the FSA IMP and associated SOPs to ensure its fitness for purpose
- to involve FSA staff in emergency exercises as part of maintaining a capable cadre of staff trained to take on incident and emergency response roles and maintain FSA competency in this area.
Post exercise reports are produced, and any actions added to the Central Actions Log (CAL) which is monitored by EPRRB.