Food Hygiene Information Scheme (FHIS) Steering Group

Douglas Scott attended this meeting chaired by Moyra Burns of SFAC and there were representatives from the British Hospitality Association, Scottish Consumers Council and Food Standards Agency (Scotland).

This meeting acknowledged the debate at the March FSA Board Meeting where there was strong support from consumers, industry and local authority stakeholders for a national scheme in order to avoid continued proliferation of different arrangements in different areas and to ensure consistency for businesses and clarity for consumers, and concluded that a UK wide scheme would be desirable.

Following a wide ranging discussion, the Board recommended that the Agency should consult on two options for the UK wide scheme: a three star, plus fail (four tier) scheme and a pass/improvement required two tier scheme based on that which is currently being piloted by local authorities in Renfrewshire, Perth and Kinross, City of Aberdeen, City of Edinburgh and Fife.

The evaluation also indicated that mechanisms for businesses to request re-inspections or re-visits for the purposes of re-scoring, and to appeal against scores given are key to an effective SOTD scheme.

The Edinburgh meeting considered the reasons for continuing to support the two tier scheme, the flaws in the four tier scheme and possible ways of mobilising the silent majority to counter the lobbying and extreme views emanating from south of the border that are aimed at ensuring the continued financial success of a company called Transparency Data Ltd.

This company operates 169 of the 196 SOTD schemes currently operating in Britain and Northern Ireland. They charge the local authorities £3000 per year, so they have quite a vested interest in getting their five star scheme accepted. The consultation however is only about three stars and Pass/ Improvement Required schemes.

The number of tiers in any scheme has implications for fairness. As the number increases, so too does the potential for inaccuracy and inconsistency in scoring as it is more difficult to distinguish between the narrow scoring categories. This in turn would create more requests for re-scoring and appeals as food businesses disagreed with their categorisation.

What will be important when the FSA consultation is opened, is to encourage respondents and get a strong Scottish response to counter the emotional attachment that English local authorities will have to a stars scheme.

One of the major flaws in the star schemes scoring is that it bases its outcome on an element defined as “the likelihood of the level of compliance observed being maintained in the future. This is based on the local authority officer's confidence in the management of the business and the control procedures in place, and will be influenced by the track record of the business, attitude of the management, the technical knowledge available within the business, and satisfactory food safety management systems being in place. In contrast the Pass/Improvement Required scheme is designed to assess compliance at the time of inspection. Obviously views on the future are subjective, make it extremely difficult for new businesses to score highly and create fertile grounds for time consuming appeals.

Given that the FSA want to have a UK-wide SOTD scheme, when their consultation is issued, SFMTA will contact its trade association colleagues to point out the benefits of a Pass/ Improvement Required Scheme and ask for them to respond to the consultation.