The Caterer's latest roundtable event, sponsored by Diversey Care, gathered experts in food safety to debate the impact of the Food Hygiene Rating Scheme since its launch in 2010 and how it might be developed. Rosalind Mullen reports from M Victoria in London
Who took part
- John Barnes, strategic advisor, Shieldyourself (former head of local delivery at FSA)
- Paul Carrington, H&S manager, JD Wetherspoon
- Tracey Colbert, director of health & food safety, Casual Dining Group
- Julie Munn, head of safety, Boparan Restaurants
- Tim Robins, global account director, Johnson Diversey
- Darryl Thomson, head of safety, Mitchells & Butlers
How is the Food Hygiene Rating Scheme (FHRS) treated by operators in England, who are not obliged to display their 0-5 rating, unlike Wales and Northern Ireland?
Paul Carrington This is an easy question to answer. We display every five rating, so some 92% of our ratings are outside our pubs and on our website. Some 98% of JDW pubs are rated either 4 or 5, which I think is a comparable metric to those quoted by the other companies present.
Tracey Colbert We display our four and five-star ratings, which account for 96% of our restaurants. For the small number of others, we introduce measures designed to ensure the restaurant moves to where it needs to be immediately, and then communicate improvements to the EHO to encourage another visit and reappraisal.
What was intended when the FHRS was set up in 2010?
John Barnes The original idea was to make it voluntary for people to display their ratings. More than 90% of ratings are between 3 and 5 nationally, with about 6% between 0 and 2. Customers can get the information from an app and they can also make their own decision if or why a restaurant hasn't displayed their rating.
What is the effect in Wales where it is mandatory to display or face a fine?
JB In Wales, the ratings have improved at a significantly faster rate than in England. [Figures show that 94% of food businesses now have a rating of three or above, with 62.5% having the highest rating, five in 2013, this was 87% and 45% respectively]. The FSA does an annual survey to check display rates and works with local authorities to encourage businesses with good ratings to display them.
Some businesses still don't display, but if you don't, customers assume you are unhygienic so you might as well shut the door. Some fail to put poor ratings up, but they are being fined.
In the rest of the UK, there is a scheme where the FSA works with local authorities to encourage businesses to display ratings for customers. However, as it is not mandatory yet to display, it tends to be those businesses with 3-5s where improvements are seen through this measure. But this does not happen in Wales because they are required to display.
Darryl Thomson We adopted the 0-5 marking for internal measurement at M&B. In 2011, top ratings were at 66% and now they are at 96%. The scheme has had a dramatic impact at M&B. But it would need legislation to make it mandatory to display ratings.
Are consumers aware of what the Food Hygiene Rating Scheme is - and the significance of not displaying the rating?
DT You would have envisaged that customers would avoid a business where there was no display. But it hasn't got as much traction as you might have thought.
TC Consumers are aware that five is good. It helps that one-to-five rating systems are increasingly common - for instance in TripAdvisor and Amazon reviews - and that has played a part in driving awareness of the rating. And it definitely drives consumer confidence in the venue.
JB There is now a more than 70% recognition rate of FHRS stickers among consumers. Whether they use it is another matter, although FSA surveys show more than 40% said they did.
TC It is trending upwards. Organisers will check ratings for conferences and for big events.
JB Government bodies and organisations won't book low-rating companies.
PC Awareness is almost generational. The younger generation watch food inspector TV programmes and understand that the ratings are there.
Does the way in which you are inspected accurately reflect the state of the business? Should it be operated differently?
DT Many businesses haven't been inspected regularly. Only 40% of our businesses have been inspected in the past 18 months. If a business hasn't been inspected in the past three years it is not an effective consumer information scheme.
There is a three-month window for a revisit. It doesn't make sense to make consumers wait for a representative rating. A visit is just a snapshot, but it needs to be better than it is now. Consumers need to drive the scheme by not going to businesses with a low rating.
TC When the ratings were introduced, businesses were nervous, but we have made a big leap forward. What was put in place was good and now is the time to optimise on the scheme, to stop and reflect. I don't think we need big changes. We need tweaks to ensure its success and longevity.
What are the barriers to making the scheme more effective?
DT Today, the local authorities are only able to inspect 600 of our 1,800 businesses a year. They cannot support the scheme as it stands so something dramatic needs to happen. It will require the industry to arrange its own inspections.
We have 4,000 inspections of our businesses each year from our own third-party auditors. It's about how we can think laterally to use the resources that we have.
Inspections don't need to be done by a public body. Think of MOTs where you go to a garage and they assess your vehicle on behalf of the government. Think of it as a kitchen MOT - as long as you have clear standards.
JB The local authorities are doing a great job, but the extended time between inspections is a worry. It is bad enough if there is a food poisoning outbreak if you were inspected a week ago, but it would become a bigger problem if the premises haven't been inspected for three years. What trust could the public have?
So would you want to replace the system?
JB I am not talking replacement. I agree the system is difficult to sustain, but FHRS has a commercial value because the customer looks at it. The FSA is looking at third-party accreditation, but needs to ensure any changes do not lose consumer trust.
Then again, if the local authority only gets round for an inspection every two or three years because you are fully compliant, and you are good because you use third-party accreditation, should there not be a way to pass on this information, especially about any improvements made that way, to the local authority for recognition? Any FHRS rating could be uploaded online as being from a private accredited body and it would also give the local authority valuable information for its own inspection programmes.
DT We don't want a less robust system, so we need to find a way of using third-party assessment to maintain trust and rigour.
JB Nobody wants self-regulation. Even if third parties were involved it would need some kind of verification by the local authority.
How might first-party or third-party inspections be used?
DT Some companies use first-party inspections, but that is a harder sell to the public. Yet they can be robust.
TC You need a third-party inspection before you can go to first party because of the trust issue. It would be a huge leap to go to first party.
PC We previously had third-party auditors, but there was not enough teeth to the system. However, third-party inspections can give you good feedback. The EHO report doesn't give you anything to work with to improve the business. Some EHO reports do not provide enough detail for actions to be taken to drive the business forward.
JB I agree. But the EHO are there primarily to regulate, not to act as an estate management tool.
A lot of contractors are working for local authorities. We need one consumer-facing body. Ratings provided through an accredited contractor would have to go through the local authority first. It already happens. For instance, the local authority looks at a lift report; they don't inspect the lift themselves.
The system is good but it is not sustainable. I think we need to have a combination of private and local authority inspections with effective governance. The big problem at the moment is the length of time between inspections.
What are your views about the Food Hygiene Information Scheme (FHIS) in Scotland, whereby it is a pass or improvement required rather than 0-5?
DT We have done surveys that show the public in Scotland don't like their scheme, so we live in hope of ultimately having one UK scheme.
JB With the FHRS system of 0-5 you get room for improvement - it has had significant improvement in the number of fives in England and particularly in Wales. But in Scotland growth is low because there is no room for incremental improvement under the FHIS.
DT Five is not the gold standard; it is the legal requirement.
PC So is there not an argument for a higher award?
JB Local authorities could bring in awards to show consumers that you have held a 'five' for a few visits.
TC We have introduced an internal audit -including in Scotland - that tends to be harder than the EHO and uses a six-star programme. It is a great drive of standards and internal competition, and when a manager gets a six they are rightly celebrated. We are now building a brand around six-star ratings and the culture around it. It forms part of the manager's bonus and has precedence over other KPIs. It has teeth. It is a driver for the business.
Should businesses also have to show their ratings on their websites?
DT In Wales, the ratings have to be shown on the door and on leaflets [and takeaways have to show them on websites]. In Northern Ireland, it also has to be shown on the website. Long-term, ratings will have to go on websites because people book via the internet, order food and so on, so it makes sense that it should be shown there.
JB The data is already available online [the FSA website].
A Diversey study shows that 30% of people will leave a restaurant that they find dirty. Some 23% will order but leave during a meal. Do people make a decision before they arrive?
JB There is a view that consumers need to be able to access information in a timely way - for example, to see if the restaurant is unsafe or even about to be closed. It needs to be simpler to see.
Tim Robins But if the audit was done three years ago and you have looked on the website it would be wrong. Is that a risk to the system?
JB To sustain the system, you ideally need an annual check. Possibly a combination of a check every 18 months to three years by the local authority with verifiable audits in between.
What are the typical reasons for a low score?
TC That one visit in a two-to-three year audit cycle is just a snapshot. There could be isolated issues or a systematic error, or a it could be a mistake on a particular day, which then has an impact on the scoring. The more the inspector understands the specific business, the more likely it is to receive a fair and true score.
JB The inspector looks at the system of food safety management. If they don't see a track record of controls and systems they mark low. So, businesses need to keep a record of what they are doing. It is not good enough to be just clean. You need to check for food fraud, chemical contamination and so on.
TC Some [employees] don't do well in exam-type conditions. We train our staff by show and tell. If you said: "show me how you operate that sanitiser" they could do it. But they couldn't tell you how they do it.
How do you respond to a low score?
TC It is taken incredibly seriously, and we drive full accountability. It's a key measure and a bad score is a genuine risk in terms of ability to trade and threat to reputation. In isolated circumstances, we look at disciplinary measures. We are a big company and have stringent and clear procedures, and problems arise if these have not been followed. Occasionally, if we get a rating we don't agree with we may appeal.
JB It is all about having an accurate rating for consumers, so there needs to be a quick, efficient appeal system and re-rating where needed.
Julie Munn It is about consistency. With a third-party assessment there is some inconsistency, but the approach is level. From an operator's point of view, knowing what would happen when the EHO comes in would help.
TC If there is a discrepancy it can be hard to get the officer on the phone to get a better understanding, but that helps.
So you are not calling for self-regulation; you would prefer independent accredited agencies to assess you?
PC No, I disagree with self-regulation when it comes to food hygiene inspections. They should remain independent and with local authorities.
JB Any system needs to ensure there is no conflict of interest. You would need to use them to augment the local authority. The FSA is no doubt looking at the role of third-party data to see if there is some way the information can target the inspection process. If you get a two, three or four rating, you may be stuck with it for 18 months or longer.
TC We think it needs looking at. It might work if a third party goes in and makes suggestions for a better chance of getting a four or five. That would have real traction.
JB The idea of a pre-visit could help businesses - particularly new businesses - by giving advice.
Should it be compulsory to display hygiene ratings?
JB It is about getting data. Data is the new natural resource, but we are not using it as much as we ought. Local authorities could look at third-party data and agree with it or not rather than wait for their next inspection date to come round. The FHRS is too important to lose. It gives a common currency around hygiene standards. I would be surprised if it is not mandated in England. Your profits are probably measured in consumer confidence. More information gives more confidence.
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