Incident Management Plan: Management of a non-routine incident, de-escalation and closure

3.1 Command and control set up for non-routine incident

Once an Incident has been escalated and/or declared as non-routine the following basic principles apply when setting up the command-and-control structure. These arrangements can be scaled up to manage large incidents that fall outside our remit but require both a tactical and strategic response. 

The FSA operates the same incident response structure, applying the procedures coherently, across England, Wales and Northern Ireland. The FSA incident response teams located in each FSA’s office lead the response to routine or serious incidents within their area depending on the geographical area affected. FSS, following their own procedures, lead on incidents within their country and work closely with the FSA. 

If an incident originates in Scotland or is initially led by FSS and escalates to a UK-wide incident, the FSS will continue to lead the incident, unless it is mutually agreed that it is more appropriate for the FSA to lead. This arrangement ensures the FSA/FSS maintains the capability and credibility to access local intelligence and liaise on cross-border issues. The Food Standards Scotland Incident Management Framework, defines how incidents contained within Scotland are managed. For UK-wide outbreaks Public Health England (PHE) takes the lead, working closely with health departments in other UK Nations. 

The roles and responsibilities for non-routine incidents sets out the various roles that may be required during a non-routine incident and sets out the purpose of each of those roles.

3.2 Incidents Team response

The Incident Team in England, Consumer Protection Teams in Wales and Northern Ireland provide the administrative and investigative lead for all food and/or feed-related incidents. 

The Head of Incidents / Incident Management/ Consumer Protection will usually act as the Incident Manager (depending on the nature of the incident) and ensures that the relevant Teams meet their responsibilities for incident handling throughout the duration of an incident. 

The Head of IRU (or equivalent position in Wales and Northern Ireland) will decide, based on the information available, whether an incident meets the criteria for escalation. The Incident Management Co-ordination Group (IMCG) will be convened during a non-routine incident in order to manage and co-ordinate the response at a tactical level.

3.3 Incident Manager

Depending on the nature of an incident, one of the following may be appointed as the Incident Manager: the Head of Incident and Resilience Unit (IRU), the Head of Incident Management in Wales, to the Head of Consumer Protection in Northern Ireland; the Head of Division or the head of a policy team with responsibility for the issue. The Incident Manager is accountable to their group director.

If links are made with an ongoing NFCU investigation, it may be that the lead for this investigation and the Incident Manager need to establish a close working relationship in terms of ensuring that the respective objectives of risk mitigation and effective investigative progression can both be met.  

The Incident Manager takes responsibility for the ICA and the risk management of the incident, making sure the FSA is effective in taking corrective action. The Incident Manager will need to be able to understand the technical issues and the nature of the risk management strategies needed.

The role of the Incident Manager is deliberately separate to that of the IMCG Chair, although the same person can carry out both roles depending on the scope and scale of an incident. The Incident Manager will work in synergy with the IMCG Chair.

3.4 Incident Response Meeting Secretariat 

For non-routine incidents, the Incident Response Meeting Secretariat will issue a calling notice for the IMCG meeting or a SIOG meeting. Representation from the FSA offices in Wales and Northern Ireland will be included. 

Meetings are virtual by default, and the standard calling notice includes details of conference call dial in procedures or video conference arrangements. The incident response meeting secretariat instructions contains more information on the Incident Secretariat.

3.5 Incident Management and Co-ordination Group (IMCG)

The IMCG manage and co-ordinate the response at a tactical level for non-routine incidents. For severe and major incidents, the IMCG will have a role in implementing the strategy directed by the Strategic Incident Oversight Group (SIOG). Membership of the IMCG will be decided depending on the classification level and location of the incident (for example, FSS will be invited if the UK-wide incident has an impact in Scotland). The higher the level of classification, the greater the expectation for more senior staff to attend. 

For serious incidents and above, the IMCG will consider the battle rhythm/ meeting frequency, make decisions on the setting up of the Briefing Cell and the Emergency Call Handling Centre (also known as the incidents hotline) as required and the set-up of any stakeholder liaison meetings. In addition, it will also consider creating operational leads, staff resourcing, financing; and setting taskforces to manage operational work streams.

Decisions and issues that require strategic input and direction will be escalated by the IMCG Chair to SIOG.  See point 3.8 below.

The IMCG may consider further escalation or notification to the Civil Contingencies Secretariat (CCS) and will discuss this with the SID as appropriate. The IMCG will be maintained for the duration of non-routine incidents.

The purpose, membership, and example agenda for the IMCG are set out in the Incident Management & Co-ordination Group Standard Operating Procedure.

3.6 Incident Management Co-ordination Group Chair (IMCG)

The default chair for IMCG will be the Head of IRU. However, depending on the nature of the incident or emergency response  one of the following - the Head of Incidents, the Head of Incident Management in Wales or Head of Consumer Protection in Northern Ireland, may assume this role. The chair of IMCG will be  appointed by the Director of Operations.  

For serious incidents where there is no Strategic Incident Oversight Group (SIOG) established and therefore no Strategic Incident Director (SID), the IMCG chair will be appointed by and accountable to the Director of Operations. When there is no SIOG, the Director of Operations is responsible for updating the Executive Management Team and the CEO, and as required the FSA Board on the incident.

In severe and major incidents where SIOG is established with a SID, the IMCG chair will be accountable to the SID. The IMCG chair will work with the appointed Incident Manager to agree the key determinants of the incident management process.

The IMCG chair shall also ensure that plans for communications with external stakeholders, for example, OGDs, LAs, Primary Authorities (PAs) - where appropriate, industry and consumer groups, are in place so that they are engaged, as and where appropriate. For more information on FSA Communications and Engagement see Section 5.

3.7 Briefing Cell

The purpose of the Briefing Cell (BC) is to provide a dedicated resource to support senior managers in responding to the incident. The BC will collate all the relevant information for the incident, develop the situation report (SitRep), as well as standard lines to take for responding to other government departments, wider stakeholders and industry. In addition, the BC will draft briefing documents, prepare ministerial submissions and respond to Parliamentary questions as required.

3.8 Strategic Incident Oversight Group (SIOG)

The objective of the group is to set strategy and have oversight of incidents classified as severe and above. The group’s deliberations are around six key and predefined strategic questions. The SIOG strategy will be passed to the IMCG for implementation and any requirements for update reports will be set.

SIOG will also be responsible for providing strategic input and direction on any decisions or issues that have been escalated by the IMCG Chair. 

SIOG are responsible for making strategic decisions based on the risk management advice to enable IMCG to deliver the response. In exceptional circumstances where decisions or issues cannot be made by SIOG, as they require higher level decision making by the FSA Board, these will be escalated by the SIOG Chair for the attention and decision of the FSA Chair.  The FSA Chair will judge if they have the delegated Board authority to make any decision required or if an extraordinary Board meeting needs to be called.  
 
SIOG will be involved in decisions such as interaction with Cabinet Office Briefing Room (COBR) (or its devolved equivalent) attendance and will establish strategic level cross-government lines of communication.

The purpose, membership, example agenda and template meeting note for the group are set out in the Strategic Incident Oversight Group Standard Operating Procedure. Senior members of FSS will be invited to attend where appropriate.

3.9 Strategic Incident Director (SID)

The SID is responsible for the strategic oversight of the incident. The SID is appointed by the Chief Executive Officer and will usually be the director most relevant to the incident. Depending on the nature of the incident, the Chief Executive Officer may decide to assume the role of SID themselves. The SID is responsible for activating the strategic management structure, including convening the SIOG that they will then chair, setting the battle rhythm for the response, providing updates to the FSA Chair and Board and escalating any decisions for higher level decision making to the FSA Chair where appropriate.

The SID is also responsible for convening any briefing or stock-take meetings with their counterparts in OGDs, co-ordinating these with the incident battle rhythm as required. 

3.10 Operational cascade briefings 

Any operational leads will be confirmed by the IMCG. They are responsible for specific areas of the FSA’s emergency response and will be expected to attend IMCG meetings and other related meetings. Operational leads are responsible for sharing the outcomes of these briefings with their colleagues.

As part of the battle rhythm, it is important for operational leads to hold cascade briefings on a regular basis with their team members (this may be on a daily or more frequent basis). The briefings will cover relevant outputs from the IMCG, SIOG or bird table meetings. Tasks for the team will be assigned, timescales agreed, quality standards set and clearance routes for work sign off will be established.

Further information on Cascade Briefings is contained in the Operational cascade briefing standard operating procedure.

3.11 Battle rhythm 

The battle rhythm is the daily routine of events (briefings, teleconferences, meetings etc.) at set times that are designed to flow from one to another, providing a sense of continuity and familiarity to the handling of an incident. The battle rhythm sets out the sequence of events preceding meetings and the processes that follow meetings at the tactical and strategic levels. Although the battle rhythm is usually set early in an incident, it can change as the incident develops and should consider meetings held by FSS as part of their control and command structure. 

It should be noted that when COBR or its equivalents in Wales and Northern Ireland are convened, the battle rhythm should take account of the requirement to submit information for the Common Recognised Information Picture (CRIP), two hours before COBR or its equivalent meet. The procedures to be followed when COBR or its equivalents are invoked are contained in the Central Government Concept of Operations (CONOPs). 

3.12 Resilience during protracted incidents 

During an incident with a prolonged response phase, it is the responsibility of the IMCG, the Incident Manager, and when necessary, the SID to establish robust resourcing arrangements such that staff can be rotated, and rest periods provided for key staff. Rotation of staff should be co-ordinated, with handover procedures put in place.

A flexible approach will be employed between FSA Incidents Teams in the three countries (and in liaison with the FSS) to address resource shortfalls. Further to this, the FSA will muster suitable resource from across its structure to support and undertake specific roles and functions as the response dictates. Where necessary a decision may be taken to secure additional external resource from outside the FSA.

3.13 De-escalation and closure 

As the incident draws towards resolution, it may be appropriate to de-escalate to a lower Level, to return completely to routine business or close the incident. De-escalation will be based upon agreed criteria and the agreed criteria being met to inform the decision to de-escalate. The decision will be taken by SIOG and IMCG collectively.   The flowchart (Figure 2) below displays the incident de-escalation process from non-routine to routine or closure an includes:

• consider whether the incident has met the criteria for de-escalation from non-routine 
• the de-escalation criteria has not been met the incident continues as non-routine and follows the usual process
• where the de-escalation criteria has been met and agreed by SIOG and IMCG, the incidents classification status will return to routine or, if appropriate, closed. 

All response level changes will be communicated formally to those involved in the response, internally and externally. Options to be considered during incident closure should include handing over to FSA teams that can carry out surveillance or monitor corrective measures.

Any decision to de-escalate or close an incident may need to consider any specific requirements for recovery. The IMCG should consider the necessary strategy, resources and authority for successful recovery. The examples of incidents, where recovery is a consideration, are radiological incidents and other environmental contamination affecting food. Recovery for major incidents should follow the procedures set out in the CONOPs using command and control arrangements in place for a major incident.

Once closed, all non-routine incidents are subject to incident review – see Section 6 incident review and planning. 

If an incident is closed (owing to the mitigation of any risk to the public from unsafe food being on the market), it is possible that an investigation by NFCU may continue to explore any potential criminal offences associated with the subject of the incident. This should not require the continuation of IMCG or incident management processes, but the potential requirement to procure and exhibit material held by FSA staff and others, which could be relevant to the ongoing investigation, should be held in mind. A form of regular ongoing co-ordination or briefing between incidents team and NFCU may be appropriate.

Figure 2: Incident de-escalation process

Information Management

All information relating to an incident is accurately documented and captured on the FSA records management system to ensure that decisions can be justified, and activities can be evidenced. 

All key business information/official record sets are information assets and must be listed on the information asset register. 

Table 3: Command and control arrangements for FSA incident response at all levels

Incident classification	Command and control arrangements
Central Government Emergency Response (major) (red)	Co-ordinates the central government response. CRIP Cabinet Office convene COBR and invite FSA. FSA attendance decided by SIOG.  DHSC Minister leads. FSA officials brief ministers and attend officials meeting.
Strategic Incident Oversight Group (severe) (amber)	Chaired by Strategic Incident Director – appointed by CEO. Sets FSA strategy (severe and major) and has a stocktake role. Answers the six strategic questions to establish FSA’s strategic response. Meets according to battle rhythm  Liaises with OGDs equivalents as required.
Incident Management and Co-ordination Group (serious) (yellow)	Chair agreed by CEO. Sets incident’s battle rhythm. Tactical application of SIOG’s strategy (when severe or major incident) Reviews risk assessment and risk management advice Decides risk management strategies Agrees the need for a Briefing Cell Establishes the need for stakeholder and OGDs meetings Receives SitRep. Decides a communications strategy Confirms operational leads Confirms financial resources – rotation and deployment Review’s media lines and clears media strategies for tactical level incidents.
Routine incidents and operational management (green)	The Incidents team: issues INFOSAN; issues notices (Food Alerts for Action [FAFAs], recalls and allergy alerts); logs incidents; and provides IMCG administrative support. Operating the Briefing Cell (SitRep owner, Q&A, briefing). Developing Comms strategy and reactive and proactive lines.   Conduct sampling/surveillance including surveys and monitoring. Involvement of Field Operations as required. Involvement of NFCU where there is organised crime or food fraud concerns or where online investigations may be required.