Food sampling forms an integral part of local authority food law enforcement and it can provide useful information to help effective enforcement of food law and contribute to improved food safety and standards.
However, the FSA’s evidence requirement stated a ’perceived downturn in the number of routine surveillance samples that are taken at UK points of entry and inland. This investigation set out to see what risks might emerge from this perceived downturn in sampling.
Approach to the work:
This work evaluated whether there is an increased possibility for incidents and emerging risks to go undetected at UK borders due to a decline in surveillance sampling, by investigating the following four research questions:
1) What are the trends in food sampling?
This involved interviews with stakeholders about trends, asking LAs and PHAs to report trends, and analysis of Local Authority Enforcement Monitoring System (LAEMS) and UK Food Surveillance system (UKFSS) data held by the FSA on the number of sample analyses per year..
2) What are the reasons for these trends?
This entailed exploratory interviews with LAs, PHAs and stakeholder representatives, and a survey of LAs and PHAs about the cause of trends and local sampling policy. The analysis of LAEMS data on food samples also revealed differences in sampling practices between types of LAs and countries that indicated some additional factors.
3) What is the probability of detecting unsatisfactory results?
UKFSS data for 2012 was assessed to determine the statistical probability of detecting unsatisfactory results per category of products and type of analyses.
4) What potential improvements could be made?
Suggestions for potential improvements were drawn from stakeholder feedback, research findings and consideration of parallel FSA studies into risk-based sampling.
Port Health Authorities (PHAs)
- PHAs are completing more samples of FNOAO due to the additional EC regulated official sampling requirements in 2010. As the expenses for the statutory sampling are cost recoverable from the importer, there are no funding issues. The total number of FNOAO samples rose by 104% between 2009/10 and 2011/12; and
- The funds available from local budgets are insignificant and do not impact greatly on the overall number of samples. Most PHA sampling is either to fulfil EC requirements or in line with FSA grants.
Inland food sampling
- The reduction in budgets and staff has undoubtedly prompted more risk-based and intelligence-led food sampling
- The volume of food samples analyses by inland LAs in the UK has fallen by about 33% since 2008/09 due to reductions in budgets and staffing levels, whilst also having to sustain the prescribed rates of premises inspections
- The decline in sampling by inland LAs is greater for food standards, a 53% fall once FSA grant funded sampling is excluded, due to food standards staffing declining more than food hygiene staffing, the relatively higher cost of food standards tests, the relatively lower level of national co-ordination and the lack of ring fenced funding for food standards sampling
- There is very little testing by inland LAs of imported food unless problems are identified through intelligence or the FSA funds specific initiatives. Only one third of surveyed LAs say they test imported foods; and
- The level of testing of imported food by inland LAs has remained at a low level.
- There are various options for improvement. The themes for these options are noted below, with those that the FSA could lead on noted as such:
- The FSA could provide advice on how to make better use of current food sampling resources through:
- Better co-ordination between national, regional and local bodies. The FSA may need to help further develop national co-ordination arrangements and advice on regional co-ordination arrangements
- More risk-based and intelligence-led sampling by the FSA and LAs
- Better sharing of results/data, including amendments to UKFSS by the FSA
- More efficient working practices by LAs
- Changing funding arrangements, with a range of options for increased funding, while ‘ring fencing’ food sampling funds, and defining expected levels of sampling to be conducted by LAs. The FSA could lead on this option.
- Increasing level and scope of national sampling programmes directed or conducted by national agencies (FSA and Public Health England (PHE)), with less onus placed on LAs to plan or conduct food sampling. The FSA would need to lead on this option, in collaboration with PHE.
- To increase the extent/use of food sampling, following official sampling methods, undertaken by businesses through, for example, third party certification schemes, with requirements for sharing all results with LAs, FSA and PHE. The FSA would need to lead on the development of this option and advising LAs on its implementation.
The suggestions do need to be considered as a whole, as increasing the scope of national sampling programmes, for example, would reduce the onus placed on LA funding. Similarly, if third party certification schemes conducted independent food sampling activity, this might reduce the onus on LAs. Also, consideration could be given by the FSA to the statistical element of planning food sampling, the purpose of food sampling and whether results are assessed at a LA, regional or national level. This leads to a further theme of potential improvement concerning the statistical element of planning food surveillance sampling.