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The value of the Food Hygiene Rating Scheme and potential changes to regulatory approach: Consumer research

Value of FHRS Consumer Research: Chapter 3 Perceptions on the proportionality and fairness of the current Food Hygiene Rating Scheme

This chapter outlines consumer views on the fairness and proportionality of the Food Hygiene Rating Scheme.

3.1 Assumptions around frequency of inspections

Participants generally expected that food businesses would be inspected at least annually, with many assuming that there would be visits every few months. They associated food businesses with a risk to consumers and to public health, and wanted reassurance that inspections were happening frequently enough to identify any issues.

“I have always thought it was every six months. I don’t know why.”
(Wales, Aware of FHRS)

“I would like to think a lot more often than 6 months to a year. Like maybe every 6 weeks.”
(Northern Ireland, Limited awareness of FHRS)

However, in groups with an awareness of the FHRS, participants across all three nations thought that inspections were likely to be less frequent. They suggested that visits happen around every two years and drew on examples of food businesses in their local area that had ratings going back at least two years to before the COVID-19 pandemic. They also discussed the limited availability of resources for more regular inspections.

“Every 2 years is reasonable enough. As I said, I don’t know how long. It could be 2 years or 4 years. I think 4 years is too long. 2 years is just fine. I don’t know.”
(England, Aware of FHRS)

3.2 Factors informing inspection frequency

Participants across nations and with varying levels of awareness of the FHRS generally held the view that the inspection frequency should be the same for all businesses because of the potential risks to consumers. They felt that every business selling food to the public should be treated the same, noting that this approach was simpler and clearer.

“I just think everybody has to be measured the same way as they’re making a level playing field regardless of what you’re selling.”
(Northern Ireland, Limited awareness of FHRS)

By contrast, some participants suggested there should be some variation in inspection frequency, and this view was again held across all three nations. While it was difficult for participants to comment in detail on how this should be determined, they suggested certain types of businesses which should be inspected more or less frequently. They based this broadly on two main criteria: firstly, the risks they associated with different types of food businesses, and secondly, how compliant the business had been previously. 

When considering inspection frequency, participants viewed preparing and serving fresh food as being riskier. This viewpoint also covered businesses who were selling certain kinds of fresh food considered higher risk, like meat and seafood. Participants who thought inspection frequency should vary, felt that more attention should be given to inspecting these businesses because of the perceived greater risks for consumers. 

“The risks of serving hot food are going to be higher than a pub selling bar snacks and pre-packaged foods. You think there would need to be more rigorous in relation to those establishments.”
(Northern Ireland, Limited awareness of FHRS)

“If you’re just selling cakes, then should you be inspected as much as someone selling seafood or someone preparing meals that could cause severe illness?”
(Wales, Aware of FHRS)

Similarly, some participants assumed that businesses where problems had been found previously, would be visited more often. They felt there should be a follow-up visit to check whether issues had been addressed. Taking compliance into account when deciding how often to inspect businesses was seen as a good approach in principle. Participants felt this helped ensure that businesses perceived as potentially presenting a higher risk to the public were more closely monitored.

“The ones that aren’t up to standard [should be inspected more]. If the score is high, I assume they don’t come as often.”
(England, Limited awareness of FHRS)

A few participants spontaneously raised the internal audit schemes they assumed large restaurant chains and retailers had in place to monitor food safety and hygiene. Views were mixed with some believing these might reduce the need for independent inspections, while others raised concerns about the potential risks of removing external assessments. This is discussed in more detail in Chapter 4.

3.3 Interacting with businesses awaiting inspection

Participants generally assumed that businesses that were awaiting inspection were new and had yet to receive a rating. A few participants thought this could include businesses who had a previous inspection and needed to be visited again to check compliance, but this was less common.

“Are they new businesses still waiting on that first inspection? Just because it’s a waiting inspection, it doesn’t mean it’s a bad thing. After that first one they will have a number.”
(England, Aware of FHRS)

There were different views about whether participants would buy food from a new business that had yet to be inspected and receive a rating. In some cases, participants felt these businesses were likely to be maintaining good standards because they would be expecting an inspection soon after they opened. They assumed there would be some checks before a business started trading or pointed to the fact that businesses would be breaking the law if they did not maintain appropriate food hygiene standards. 

By contrast, other participants said they would not visit a new business that had yet to receive an inspection. They were concerned that their food safety and hygiene practices were unknown and had not been checked independently. These participants assumed this would happen quickly and felt it would be better to wait the short time for the inspection rather than taking the risk.

“I think that should be in place before you open, that should be a prerequisite. I would probably avoid it until the rating was there.”
(Wales, Limited awareness of FHRS)

3.4 Views on how scores are awarded

Participants did not have detailed spontaneous views about the specifics of how ratings are awarded in practice. They expected that food hygiene standards were assessed through regular physical inspections and considered this appropriate. They discussed inspectors using checklists or criteria to assess and score a business’s compliance. Drawing on their awareness of the scheme or their assumptions about how it operated, participants across groups mentioned a range of issues they thought would be covered. This included checking cleanliness, storage, handling, preparing food safely to avoid cross-contamination, and having appropriate systems and paperwork in place.

“I think it’s how the food is stored in the fridges, the freezers, as well as how it’s prepared in the kitchen. I know environmental health has to go in and check for rats or animals. You have to tick things off to see the fridges are clean. It’s a big checklist, I presume.”
(England, Aware of FHRS)

“Food preparation sites. Refrigeration of either cooked or uncooked products.”
(Northern Ireland, Aware of FHRS)

Even those who were relatively familiar with the scheme did not know enough to suggest specific changes or alternative approaches. As such, more detailed consumer views around how ratings should be awarded were covered in the second workshop, where participants were asked to discuss issues such as the use of remote assessments, using businesses’ own data for assessment, and independent third-party audits in the context of the wider regulatory approach to assessing food hygiene standards. Findings from these discussions are included in Chapter 4.

3.5 Should it be the same for all businesses?

Reflecting the expectations discussed in Chapter 2, participants had different views on whether all businesses within the scope of the FHRS should be assessed in the same way, or whether there should be differences. This was based on different ways of thinking about the FHRS.

Those who wanted a consistent approach started from a consumer safety perspective. Participants discussed that if a business is providing food to consumers, it should be assessed based on a uniform set of standards. They felt that the type of business or the different foods being sold did not matter and the scheme should treat all businesses the same, to ensure fairness and consistency. They linked this to having consistent ratings that applied across different types of business.

“I think regardless of where the business is, whether you’re self-employed working from home or a restaurant, there should be a consistent scheme so that every business gets rated in the same way.”
(England, Aware of FHRS)

By contrast, participants across all three nations and with varied levels of awareness of the FHRS considered the risks associated with different types of businesses, both in terms of the food they handled and prepared, and the people they provided food to. Some also considered how compliant businesses had been previously. For these participants, the priority was ensuring resources can be focused on businesses where the risk to consumers is highest. While they still felt consistency was important, they were more open to some differences in the way food hygiene standards are regulated across business types.

“[There should be more focus] on those with low scores or those at higher risk, like restaurants and takeaways, and producing food in care homes because those are vulnerable people. If something goes wrong, they’re at more risk, aren’t they?”
(England, Aware of FHRS)

3.6 Prompted views of the current FHRS

Following the spontaneous discussions about the FHRS, participants were given more details about the scheme overall. In general, the scheme was in line with their expectations, and reflected the importance of ensuring food hygiene standards are maintained and any problems identified and addressed.

Their key concerns about the FHRS and awarding ratings were around whether inspections happened frequently enough. Participants also felt a consistent approach should be taken and assumed this happened given that businesses are all awarded equivalent ratings. In some cases, participants were surprised that food quality was not included as part of the FHRS, given its importance to consumers. These participants had previously assumed this was considered. Other participants argued that it would not be possible to include quality because it cannot be assessed in the same consistent way as compliance with food hygiene standards can.

Participants’ other questions about the scheme focused on understanding the meaning of specific FHRS ratings and the implications of lower scores for businesses. They also expected more clarity on the different roles played by the FSA and LAs in running the scheme.