The UK Food Standards Agency (FSA) has recently published the results of its biannual public attitudes tracker. The results show that the top food safety concern for respondents is food hygiene when eating out. Perhaps more noteworthy though is the increased awareness of the Food Hygiene Rating Scheme (FHRS), often called “scores on the doors”. The survey was compiled by interviewing a representative sample of over 2,500 adults in the UK and reports that:
…more than a third (37%) of respondents in England, Wales and Northern Ireland reported being aware of the FHRS, compared to 21-34% between November 2011 and May 2013.
Greater public awareness will require those in the food service industry to pay considerably more attention to these “scores”: how they are generated and what they mean for their customer base.
The FHRS was launched in England, Wales and Northern Ireland in November 2010, although it has been operating in some parts of Scotland since 2006 (the Food Hygiene Information Scheme). The scheme is run by local authorities, which rate premises such as restaurants, takeaways, cafes, sandwich shops, pubs, hotels, food shops and schools/ hospitals following inspections. The rating is then published on the FSA’s website, with a search facility for the general public to check the scores.
In England and Northern Ireland, businesses are not currently required to display their rating on the premises, although many choose to do so if their rating is good. In Wales, however, businesses that get a new rating after 28 November 2013, must by law display a sticker showing their rating in a prominent place. With awareness of the scheme on the increase, getting a good rating is likely to be increasingly important to customer-facing businesses, even where the display of the sticker is not yet mandatory.
What Factors Will Affect Your Rating?
The FHRS works by giving marks for food hygiene and safety, structure and cleaning, and confidence in management and control procedures. The last category is based on the business having a food safety management system, for example, a written HACCP (Hazard Analysis and Critical Control Point system), or a written system developed in-house covering all aspects of the business including matters such as training, stock control and delivery checks.
Developing and recording robust written systems for food safety management and hygiene will therefore be an important factor in getting a good / improved rating under the scheme, as well as helping to ensure compliance with the Food Hygiene Regulations 2006 and Regulation 852/2004/EC, which require food business operators to comply with general hygiene requirements and put in place procedures to manage food safety within their establishment.
Can you Improve Your Rating?
Whilst the level of concern amongst the general public regarding food hygiene may well justify the continued use of ‘scores on the doors’, businesses have a legitimate concern that infrequent inspections might mean they are stuck with a poor rating long after they have made improvements. The frequency of inspections is in reality in the hands of the local authority, after all.
There is some comfort for businesses in that they can request a re-visit after they have made improvements recommended by the food safety officer. However, you are only entitled to one re-visit between the authority’s planned inspections of your premises and as such, it is important to address all of the recommendations first.
Nevertheless, the re-visit system is potentially of limited comfort: while the new scores will be published by the local authority following the re-visit, there may well be a delay of several weeks or even months and in the meantime the scores from the previous inspection will remain on the FSA website and potentially affect customer loyalty.
What if the Local Authority ‘Get it Wrong’?
Businesses can appeal a rating if they believe it is wrong or unfair; i.e., does not properly reflect the hygiene standards at the time of the inspection. The appeal must be made in writing within 14 days of the notification of the rating and the case will be reviewed by another officer, who may re-visit. In the interim period, the FSA website will show the rating as ‘awaiting publication’. The appeal process does not, however, apply where changes have been made since the inspection and therefore it will be of limited application.
Separately, businesses have a ‘right to reply’ to explain to customers actions taken since the inspection or unusual circumstances during the inspection. Your comments must be sent to the food safety officer that undertook the inspection on a standard form and your comments will be published online alongside your hygiene rating (although the local authority may edit your comments to remove offensive, defamatory, inaccurate or irrelevant remarks). Utilising the right to reply may help to manage customer reactions, but will not affect the rating itself.
Conclusions and Takeaways
The options to request a re-inspection, appeal a decision, or post comments under your ‘right to reply’ are undoubtedly tools for damage control in an electronic age where bad publicity travels faster than ever. It is likely that they will be used more and more frequently as customer awareness of the FHRS increases.
However, though useful, these tools certainly do not eliminate the risk to reputation altogether: in the event of a re-inspection, there will be a significant delay until scores are revised; the grounds for an appeal will only arise in limited circumstances; and the ‘right to reply’ means only that your comments will be posted alongside the rating, the rating itself will remain.
As such, the old adage that “prevention is better than cure” certainly remains the case: food business operators should make sure they understand the scoring system and requirements under food safety legislation to ensure that they get a good rating the “first time round” during planned inspections by understanding their obligations on hygiene, assessing the risks and implementing and documenting management systems to address those risks.