Minutes of Performance Strategy Group meeting: 20 April 2005

David Statham (Chair), FSA
Nick Baker, North Norfolk District Council
Paul Berryman, Hampshire County Council
Peter Griggs, Chartered Institute of Environmental Health (CIEH)
Barny Heywood, Northern Ireland Food Safety Group
Andrew Jamieson, Royal Environmental Health Institute of Scotland (REHIS)
David Pickering, Trading Standards Institute (TSI)
Huw Williams, Food Safety Panel Wales
Julie Monk, FSA
Alison Gleadle, FSA
Geoff Deville, FSA
Jane Davies, FSA Wales
Michael Jackson, FSA Northern Ireland
Christina Walder, FSA
Sandie Yeats, FSA

Stewart Heggie, Angus Council
Jenny Morris, Chartered Institute of Environmental Health (CIEH)
Malcolm Mathias, East Riding of Yorkshire
Mark Du Val, LACORS
Vicki Gracie-Langrick, LACORS
Jim Thomson, FSA Scotland

1.1 The Chairman began by welcoming everyone to the meeting and took the opportunity to introduce Christina Walder from Enforcement Division - Audit Branch to the Group.

[Secretary's Note: LACORS submitted written comments on individual agenda items prior to the meeting and those comments form part of the discussion reported in this note.]

2.1 The Chairman asked the group if they had any comments on the note of the last meeting held on 11 January 2005. Three comments were received on agenda item 3 - proposal to simplify the reporting system of food safety/standards inspections. Jane Davies asked the Secretariat for feedback from the meeting held on 28 January 2005 between the Agency and software providers. The Secretariat reported that representatives from around one-dozen software companies attended the meeting and were supportive of the proposed measures. The Secretariat added that further meetings with the software suppliers would be held when the detail of the review becomes available. Huw Williams asked whether representatives from the software companies would received training on the new measures. The Secretariat reported that the Monitoring System Monitoring Group (MSUG) had recommended that these companies should be invited to attend the training sessions offered to local authority personnel. Paul Berryman sought clarification on how local authority achievement of food safety/standards inspections would be reported in the matrix. Secretariat explained that the wording on the matrix would focus on the positive outcome and report the percentage of inspections achieved. However, for calculation purposes local authorities would be asked to supply details of both achieved and missed inspections.

3.1 Geoff Deville introduced the circulated paper and explained to the Group that it was a discussion paper not a proposal. He then opened up the discussion and asked the Group to consider how the component parts of the matrix should be weighted/scored.

3.2 The Group noted the comment from LACORS that LACORS/LGA would be 'in principle' against introducing a further specific scoring system. Group Members discussed this issue and stated that they fully appreciated the concerns of LACORS/LGA. However, at the end of the discussion the Group concluded that a matrix should be introduced and weighted/scored. The Group then sought clarification on a proposal to use the Comprehensive Performance Assessment (CPA) overall rating system ('excellent', 'good', 'fair', 'weak' and 'poor') to score the matrix. It was noted by the Group that the CPA system does not operate in Wales, Scotland and N.Ireland and that all parts of the UK have, to some extent, differing performance measures which would need to be considered when developing the weighting/scoring system. The Secretariat explained that the use of the CPA overall assessment descriptors had been proposed because it would be familiar to many local authorities. The suggestion was that these descriptors could be used to provide the overall assessment rating, with each descriptor linked to a banded scoring range which would be developed by the Group. But it was not proposed to adapt the detailed and extensive questions of the full CPA, which required a two day audit to score. The Group was content with the explanation and agreed that in order to make comparisons the system should be consistent across the UK and be consistent with Agency policies. This would allow the reporting of UK wide data to the EU and the FSA Board.

3.3. The Group then considered the detailed requirements of the weighting/scoring for the matrix. The discussion covered five main themes:

• which enforcement activities should be the most heavily weighted;
• whether different weighting systems were required for first and second tier authorities;
• where to set the baselines to define the average ('fair') rating;
• the level of local authority achievement needed to secure the highest ('excellent') rating; and
• how to encourage authorities to strive to for 'excellence'.

3.4 The Group asked the Secretariat to amend the paper to incorporate additional suggestions from the Group. These included:

• focus on whether the local authority had and followed a structured management policy or procedure, rather than volume of work;
• for sampling, to focus on management procedures for unsatisfactory samples rather than the number;
• for training, to look at BV166;
• if award schemes are retained, to note the different approach in Wales;
• in scoring, to maintain the weighting of advisory and educational work, but to weight work with food businesses higher than work with schools;
• to consider reducing the weighting of food samples for local authorities responsible only for food hygiene.

• Action Point: PSG Secretariat to produce a second paper on weighting/scoring to take into account responses received to the consultation.

3.5 Barny Heywood outlined to the Group an alternative method for the collection and collation of the data for the outcome measures section of the matrix. The Group discussed the option of comparing average compliance scores across all inspectable premises, rather than just those inspected during the year, in risk rating bands A-C to establish an outcome measure of Environmental Health intervention. The Group asked that a copy of the proposal be sent to the Secretariat to allow the Agency to seek advice from their statisticians (to cover both all premises and those inspected during the year).

• Action Point: Barny Heywood to send the Secretariat details of proposals on outcome measures. [Secretary's note: received on 25 April 2005].

4.1 Geoff Deville introduced the circulated paper and apologised that the Annex attached to the circulated paper was out of date. He reported that the independent Business Analyst (BA), who had been employed to establish the requirements of the new system, had been introduced to the MSUG. Over the next few weeks the BA would be talking in depth with MSUG members across the UK and would produce a 'Functions Requirement Report' which would identify the requirements for a new system and the ramifications and practicalities for local authorities and the Agency. The Group was asked to note that the BA would be reporting his findings to the MSUG when they meet next on 15 June 2005.

4.2 PSG Members were asked whether they had any comments/questions on the paper/work of the MSUG. The Group raised two issues for discussion.

4.3 First, the Group discussed a concern raised by the MSUG regarding the advisory and educational activities proposals. MSUG felt that these proposals needed to be more specific to reflect the extent and quality of such activities. The Group concluded that this could be addressed by recasting the relevant Yes/No matrix questions in order to place the emphasis on planned activities, rather than reactive ones. The issue of quality could be addressed by specifying the type of promotional work to be reported, for example, excluding the issuing of leaflets unless they formed part of a wider promotion activity, such as a workshop.

4.4 Second, the Group asked the Secretariat why the MSUG had suggested that only complaints which led to a visit to the premises in question should be reported. Several PSG Members commented that resolving a complaint by telephone could be equally as complex as a visit and in rural areas resolution by telephone, if appropriate, could be more cost effective and efficient than a visit. It was explained that the suggestion stemmed from concerns that there are inconsistencies in dealing with complaints. The Group agreed that clear guidance would be required in order to segregate service requests from complaints.

5.1 The Group discussed the three issues that were carried forward from the last PSG meeting.

5.2 On outcome measures used by other regulatory services the Group discussed whether looking again at this issue would take the debate any further. Earlier discussion suggested that there was not an 'off the peg' outcome performance indicator that could be adapted for food services. The Group concluded that the debate had moved on and agreed not to pursue this issue any further.

5.3 The second issue on the Comprehensive Performance Assessment (CPA) model and how it might be adapted for scoring the matrix was discussed and noted under Agenda item 3 - Development of a Scoring/Weighting System for the Draft Performance Matrix.

5.4 On the third issue of the relationship between peer review / audit and monitoring the Secretariat informed the Group that a paper on the findings of the Agency's focussed audit programme on Inter Authority Audit (IAA) would be discussed by the Enforcement Liaison Group (ELG) at its meeting on 26 May 2005. Group members were of the view that they should have regard to this work and pointers from other examples of IAA, such as that of the Health & Safety Executive where positive results have been reported. The Chairman informed Members that the Agency would want to work with local authorities on this issue and a meeting would be arranged with the Improvement and Development Agency for local government (I&DeA) in the near future. He confirmed that examples of different types of IAA would be considered before any decision was taken.

6.1 Christina Walder from Enforcement Division Audit Branch presented the report to the Group. She explained that the focussed audit programme had looked specifically at the arrangements local authorities have in place for collecting, validating and submitting monitoring data to the Agency on their food law enforcement activity. The purpose of the programme was to examine the reasons why many local authorities had provided inaccurate monitoring returns to the Agency and to help identify changes needed to the monitoring system. The programme covered 31 local authorities in the UK.

6.2 The Group commented that the audit programme was a very useful piece of work which highlighted the critical issues to be addressed in order to restore the confidence of the Agency's Board in the monitoring system.

6.3 The Group noted that some areas of good practice principally relating to database maintenance and data validation were identified during the focussed audits would soon be available on the Agency's website.

7.1 The Secretariat gave an up-date on the Official Feed and Food (OFFC) Regulation which will replace Council Directive 95/53/EC Official Food and Feed Control from 1 January 2006. It was explained that the specific data requirements of the new control had not yet been set, but the OFFC Regulation would however retain the provisions that obliges Member States to provide annual results of their inspection activities to the Commission. It is envisaged that a EU working group would be set up to consider this issue.

7.2 The Group discussed the recommendations of the final Hampton Report. It was noted that the Wine Standards Board, an organisation with around 12 personnel, would be amalgamated with the Agency. The Group were content that the current approach to enforcement followed the principles outlined in the Report.

7.3 The Secretariat provided the Group with an outline of the immediate next steps of the review of the monitoring system:

• Secretariat to produce a second paper on a scoring/weighting system for the draft performance matrix. Paper to reflect the ideas and comments from the Group.
• Secretariat to assess the responses to the first consultation exercise (closes on 27 May) and report back the results to the Group. Group to meet again late June/early July.
• A second consultation exercise to commence in June [Secretary's note: put back to July]. Results of the work of the independent Business Analyst to be included at this stage.
• Road shows for local authorities to discuss the review and provide the Agency with feedback to commence in May and end in June. First road show arranged for 12 May in Wales. Dates to be arranged for Scotland, N Ireland and England. Suggested venues for England: York and London, with additional meetings in Exeter, if necessary. PSG Members kindly offered to help present the road shows. The Chairman accepted this extremely helpful offer.

• Action Point: Secretariat to produce a second paper on a scoring/weighting system for the draft performance matrix.
• Action Point: Secretariat to notify Group of the results of the first consultation exercise.
• Action Point: Secretariat to liaise with members over dates for roadshows.

PSG Secretariat
Enforcement Division
April 2005