Managing Food Incidents Incident Management in the Food Standards Agency Colin Houston Head of Incidents Unit - EMERGENZE IN SICUREZZA ALIMENTARE: ...

EMERGENZE IN SICUREZZA ALIMENTARE: PROCEDURE E GESTIONE
 FOOD SAFETY EMERGENCY: PROCEDURES AND MANAGEMENT
                Cremona, 6-8 Giugno 2011

       Managing Food Incidents
      Incident Management in the
        Food Standards Agency

             Colin Houston
          Head of Incidents Unit

Overview of Presentation
•   What is an incident?
•   Role of the Agency and the Incidents Unit
•   Types and frequency of incidents
•   How do we manage incidents?
•   How do we classify an incident?
•   What action do we take?
•   How do we learn from experience?

What is an incident?

“An incident is any event where, based on the
information available, there are concerns about actual or
suspected threats to the safety or quality of food that
could require intervention to protect consumers’
interests.”

Role of the Agency

• Agency is the Lead Government Department for
  widespread contamination of food
• Agency also has a key supporting role, providing
  food safety and standards advice in relation to a
  range of other incidents

Role of the Incidents Unit

• Role covers incident response, food fraud and emergency planning

Incidents Branch
• First contact point for incidents in England (24/7 response)
• Local variations in devolved countries
• ‘Lead’ administrative role during incidents
• Maintain an official audit trail, using a dedicated Incidents Database
• Contact local authorities
• Support to Operational and Strategic Incident Management Teams
• Arranges issue of food alerts and allergy alerts
• Alerts EC via Rapid Alert System for Food and Feed (RASFF)

Types of Incidents
(clockwise from top left – food borne illness, chemical fires, illegal colours, on-farm)

Frequency of Incidents in 2010
• In 2010 we investigated 1,505 incidents in the UK. Where
  needed, action was taken to ensure consumers were
  protected from eating unsafe food.
The major categories of incident in 2010 were:
• environmental contamination – 23%
• microbiological contamination – 18%
• natural chemical contamination (mycotoxins, algal toxins and
  others) – 15%
• on-farm incidents – 8%
• physical contamination – 8%

How do we manage incidents?
• We follow a set Protocol, which covers, inter alia:
- notification procedures;
- incident classification levels;
- roles and responsibilities;
- management structure during Low, Medium and High incidents
- Meetings with external stakeholders – Scoping Group and
  Stakeholder meetings
- out-of-hours procedures
- closure and review procedures
• Protocol is regularly reviewed and revised version published in May
• Rolling training programme for Agency staff on protocol and
  database (300+ staff trained)

How do we classify an incident?
• We classify all incidents using a combination
  of the severity of the incident and the
  complexity of the investigation. A number of
  parameters contribute to these high-level
  criteria. But the overall assessment or output
  is simply high, medium or low.

How do we classify an incident?
Severity                     Complexity
• Extent of health effects   • Numbers of reports
• Numbers and/or groups        received
  of consumers affected      • Numbers of
• Public health risk           products/locations
  assessment                 • Number of agencies
• Perceived risk by            involved
  consumers                  • Traceability
• Perceived risk by the
  media

How do we classify an incident?
• Each heading contains a range of scores and is
  weighted to produce a final score that equates to
  high, medium or low. The system enables rapid and
  consistent categorisation of incidents, once notified,
  and as they develop.
• This allows incidents to be effectively scoped,
  resourced and managed. The system is not designed
  as a risk assessment tool, but a means to aid us in
  planning and management decisions.

How do we classify an incident?
Low
• These are minor incidents, with localised effects and few, if any, food safety
    implications. Examples of such incidents include barn fires, vehicles in rivers, or
    minor oil spills.
 Medium
• These include incidents involving evidence of illness, impact on vulnerable groups
    (babies, pregnant women or the elderly) and breaches of statutory limits (for
    example, for mycotoxins). In some cases the public or the media are likely to
    express some concerns.
 High
• These are severe incidents with the potential to cause serious illness or deaths.
    They are complex, with a large number of products affected and a high level of
    resources required to manage. They are widespread and likely to generate a high
    level of concern among the public and the media.

Risk Assessment
• We have a wide range of scientific and policy experts at our
  disposal during incidents. These experts provide advice on
  risks to human health, risk to the food chain and applicable
  legislation during incidents. This advice is used to formulate
  risk management options and determine a risk management
  strategy during each incident.
• We also have access to various independent scientific
  committees that comprise individuals with recognised
  expertise within their field. These committees provide
  independent, expert advice to the Agency on research and
  policy when requested.

Risk Management
• Risk assessment is used to inform the risk management options during
   each incident. The Agency will liaise with the relevant local authorities,
   industry, other government departments and agencies in order to arrive
   at an appropriate risk management strategy.
 The strategy will take into account:-
• risk assessment
• risk communication
• proportionality
• legislation
• the precautionary approach
• Once a strategy is decided upon by ourselves in consultation with key
   external stakeholders, it will be disseminated to teams within the Agency,
   local authorities, industry and others as appropriate.

How do we manage incidents?
                                                                             I n c id e n t

                                                                                           N o t i fi c a t i o n

                                                                        In c id e n ts B r a n c h
                                                                                                                                                     I n f o r m a t i o n f lo w

O th e r                     In d u s tr y      L o c a l A u th o r i t i e s           P o lic y D iv is io n                    C o m m u n ic a tio n s             Legal
D e p a r tm e n ts /                                                                    (R is k A s s e s s m e n t)
A g e n c ie s

                                                                               R is k
                                                                          M anagement
                                                                             O p t io n s

                                                                                 S tr a te g y

                                                                                 A c t io n

    W it h d r a w a l o r              M o n ito rin g a n d             C o m m u n i c a t io n                  G u id a n c e o r a d v ic e      R e s tric tio n s
    r e c a ll                          s a m p lin g

ROLES & RESPONSIBILITIES
• Where a member of staff has been assigned a specific role
  (Incident Manager, Investigating Officer, Official Note Taker
  etc) that individual must ensure at the outset that they have
  identified a suitable deputy, who can effectively carry out that
  function in their absence, and updated the Incident Manager
  accordingly.
• The Incidents Branch act as the first point of contact with
  external stakeholders for incidents and maintain the official
  audit trail for the investigation by co-ordinating the logging,
  collation and distribution of information required during the
  investigation.

ROLES & RESPONSIBILITIES
• Where there has been known distribution of potentially contaminated
  products, the Branch will contact the relevant local authorities (LAs) to
  trace this material and report back its findings to the Operational Incident
  Management Team.
• The Branch shall also arrange Operational Incident Management Team
  meetings, draft notes of meetings, co-ordinate the production of briefing
  for Directors, Ministers and provide any other administrative support to
  the Operational Incident Management Team deemed necessary.
• The Incidents Branch arrange the issue of food alerts and product
  recall/withdrawal information notices to LAs, other Government
  departments, trade organisations etc. Incidents Branch acts as UK contact
  point for the Rapid Alert System for Food and Feed (RASFF) and is
  responsible for issuing RASFF notifications to the Commission.

ROLES & RESPONSIBILITIES
• For high level incidents, the Incidents Branch has
  suitable business continuity plans in place to ensure
  that it can continue to operate effectively in the
  event of an IT failure or similar serious business
  disruption.
• During ‘High’ level incidents, it is often appropriate
  to set up a dedicated briefing cell to carry out the
  information management and/or briefing function.

Incident Manager
• For each incident an Incident Manager is identified. This
  would normally be the Head of the Incidents Unit or their
  appointed deputy.
• To cope with the intense demands of the role, for ‘high’ level
  incidents at least two Incident Managers will be required.
  Where two (or more) incident managers will be undertaking
  this role, a meeting between them will be required at the
  outset to agree on the allocation of tasks.
• The Incident Manager is accountable to Directors and the
  Chief Executive for the strategic management of the incident,
  for decisions taken by the operational incident management
  team and for the outcome of the incident investigation.

Incident Manager
•   The Incident Manager will be responsible for setting and maintaining the ‘pace’ of
    the incident (including the frequency and timing of Operational Incident
    Management Team meetings) and for ensuring that the Strategic Director,
    Strategic Incident Management Team and other interested parties (e.g. Ministers)
    receive timely briefing on the progress of incident investigations.
•    The Incident Manager will agree at the outset, following consultation with other
    Operational Incident Management Team group members, the key determinants of
    the incident management process. These include:
•    the scope and severity of the event
•   the time-scale for resolution
•    the availability of resources
•    identifying those responsible for delivering work-streams
•   identifying those responsible for initiating and maintaining contact with
    stakeholders.

Incident Manager
•   The Incident Manager shall ensure that the standard agenda is followed as a
    minimum during Operational Incident Management Team meetings.
•   Incident Managers are also responsible for clearing final notes of Operational
    Incident Management Team meetings and ensuring that the content reflects the
    conclusions of the meeting.
•   The level of direct involvement of the Incident Manager in the operational
    management process will vary depending on the nature and severity of the
    incident.
•    Each Incident Manager must identify a deputy with the authority and
    responsibility to take decisions in their absence. In cases where the Incident
    Manager changes during the investigation, it is vital that there is a seamless
    handover.
•   Consequently, the new Incident Manager must be fully briefed by his/her
    predecessor. Where appropriate, the Incident Manager shall decide whether any
    further accommodation or resource issues need to be addressed, for example,
    when planning for activity out of normal office hours.

INVESTIGATING OFFICER
• The Investigating Officer is the main contact within
  the Incidents Branch ‘leading’ the incident. The Head
  of Incidents Unit or deputy will determine who takes
  on this role, taking into account officials’ workloads
  at the time.
• The Investigating Officer will ensure that the incident
  is dealt with in a timely manner, key stakeholders
  (internal and external) are updated on developments
  and that all staff dealing with the incident follow the
  protocol.

INVESTIGATING OFFICER
•   An Investigating Officer’s tasks will include:
•   information gathering (liaising with a range of external stakeholders including
    FBOs, LAs and OGDs)
•   seeking legal advice, where the legal position is unclear
•   arranging and attending Operational Incident Management Team meetings
•   taking notes of meetings
•   co-ordinating briefing
•   drafting food alerts, allergy alerts and product withdrawal/recall information
    notices
•   preparing RASFF notifications
•   logging data on the Incidents Database
•   answering calls and correspondence regarding the incident. Including Ministers’
    Correspondence cases, Freedom of Information requests and Parliamentary
    Questions

PRESS OFFICER
•   The Press Officer’s role will be to deal with any queries from the media regarding
    the incident.
•   All calls from journalists must be forwarded to the Communications Division press
    officer for his/her attention. The Agency’s press officer will also attend
    Operational Incident Management Team meetings and draft news stories as
    appropriate.
•    The Press Officer will aim, wherever possible, to issue web stories or press
    releases regarding incidents at set times during the day.
•   However, in many incidents this may prove to be difficult given the pressures,
    often from the media to distribute information as quickly as possible. Where this is
    the case the press office will aim to ensure that the release of information is as
    close to one of the set times as possible. The press office is also mindful of
    deadlines, particularly for printed media, and will aim to have information in the
    public domain before the end of the day.

LEGAL ADVISER
• The Agency’s Legal Adviser advise on any legal aspects of the incident (e.g.
  where clarification is required re: legal basis for our actions) and, where
  necessary, attend operational incident management team meetings.
• Where legal advice is being sought, the Incidents Branch must ensure that
  this is made explicitly clear in the e-mail to Legal Services (preferably in
  the e-mail title).
• The Legal Adviser will also lead on the production of Orders under the
  Food and Environmental Protection Act (FEPA) or other legislation
  required to be introduced as part of the incident response. .

OFFICIAL NOTE TAKER
•   Every incident involving an Operational Incident Management Team will have an
    official note taker assigned to it, taken from within the Incidents Branch.
•    The note taker will attend all Operational Incident Management Team meetings
    and, where appropriate, Strategic Incident Management Team meetings relating
    to that incident.
•   The note taker will produce a summary of the meeting, which will be circulated to
    all attendees and, where appropriate, Directors within one hour of the meeting.
    The summary shall in each case identify roles and responsibilities (e.g. Incident
    Manager), the legal basis, risk assessment and action points agreed, the
    individuals tasked with carrying them out and the time-scales for action. The
    Incident Manager will clear this summary note and, where there are significant
    legal issues, the note will also be cleared by the Legal Adviser.
•   The note taker will also prepare a formal note of the meeting, which will be
    commented on by attendees and cleared by the Chair.

TECHNICAL SUPPORT OFFICER
• Every incident will have a technical support
  officer assigned to it, taken from within the
  Incidents Branch.
• This official will be responsible for all
  video/tele-conferencing arrangements
  relating to Operational, Strategic, Scoping
  Group and Stakeholder meetings held during
  that particular incident.

OPERATIONAL INCIDENT MANAGEMENT TEAM

• The Incidents Manager will ensure that the Incidents Branch
  identifies the members of an Operational Incident Management
  Team (OIMT) to progress the incident investigation.
• The Group will consist of representatives from the Incidents
  Branch, all of the relevant Policy Divisions, Communications
  Division, Legal Services, representatives for devolved
  administrations and any other relevant Agency officials, as
  appropriate.
• For incidents with a European dimension, EU and International
  Strategy team representatives need to be involved at an early stage
  and be included within the Operational Incident Management
  Team.

OPERATIONAL INCIDENT MANAGEMENT TEAM
• The OIMT will take tactical level decisions, discharge actions needed to
  collect information and formulate proposals for risk management options
  or strategic decisions for the Incident Manager to endorse.
• The OIMT should critically review precedents for action or inaction to
  establish whether they continue to be appropriate.
• It should also consider the consequences of action or inaction and these
  deliberations must be recorded as part of the official record. This should
  be an ongoing part of the incident investigation.
• The Group will, at the outset, document the legal basis for action or
  inaction, the factors relied on and the weight given to each factor.
• It will also clarify the role of enforcement authorities, recognising the
  authorities’ other statutory responsibilities and the need to prioritise
  resources.

STRATEGIC INCIDENT MANAGEMENT TEAM

• The purpose of the Strategic Incident Management Team is to
  set the overall strategy for responding to a ‘high’ level
  incident. As part of this function, the team should consider
  and agree an appropriate communications strategy. The
  overall strategy will then be passed to the Operational
  Incident Management Team for implementation, who will
  regularly report back on progress.
• Once the strategy is set, the Strategic Incident Management
  Team will ensure that the strategy is effectively implemented
  by directing and supporting the Operational Incident
  Management Team.

STRATEGIC INCIDENT MANAGEMENT TEAM

• SIMT meetings can also be used as a clearing house where key documents
  need to be cleared urgently (e.g. news story or Ministerial submission).
• These meetings will normally be chaired by the Strategic Director. Other
  potential members include the Chief Executive, Chief Scientist, Incident
  Manager, Director of Communications, Director of Legal Services, Head of
  EU and International Strategy, Strategic Adviser, Directors in devolved
  offices and senior representatives from relevant policy divisions.
• The Incidents Branch will always seek to ensure that Agency officials with
  suitable expertise are available, as required, for SIMT meetings.
• The Strategic Director will ultimately determine who attends each
  meeting.
• The frequency and number of these strategic meetings will depend largely
  on the scale of the incident and the degree of Agency involvement.

What will we do with the information
              once received?
• We will use the information received to inform our risk
  assessment, which, in turn will be taken into account when
  considering our risk management and risk communication
  options. Dialogue between industry, us and local authorities
  is encouraged at all stages to ensure our risk management
  advice is proportionate and practical.
• We may, in the light of the information received, issue a food
  alert to local authorities, who enforce food law. These alerts
  are used during incidents where, for example, the distribution
  of a product is wide and will potentially involve many local
  authorities.

Food Alerts
•   Two types of Food Alert
•   Drafted carefully to avoid mistakes and ambiguity
•   3 drafts of each Food Alert
•   Circulated for comment to LA / Company
•   Cleared by Senior Management
•   Press release / news story on web
•   Procedures for 'Product Withdrawal Information
    Notice' or a 'Product Recall Information Notice'
    began 2 June 2010

How do we learn from
experience?

• All incidents dealt with by the Incidents
  Branch are reviewed
• Ad-hoc incident review meetings
• Quarterly Review Meetings
• Findings from ad-hoc review meetings to
  Incident Review Group
• Protocol updated, where necessary

Thank you