1 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
2 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?
3 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.
4 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
5 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)
6 Types of Incidents (clockwise from top left food borne illness, chemical fires, illegal colours, on-farm)
7 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%
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)
9 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.
10 How do we classify an incident? Severity Extent of health effects Numbers and/or groups of consumers affected Public health risk assessment Perceived risk by consumers Perceived risk by the media Complexity Numbers of reports received Numbers of products/locations Number of agencies involved Traceability
11 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.
12 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.
13 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.
14 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.
15 How do we manage incidents? I n c id e n t N o tific a tio n In c id e n ts B r a n c h In fo r m a tio n flo w O th e r D e p a r tm e n ts / A g e n c ie s In d u s tr y L o c a l A u th o ritie s P o lic y D iv is io n ( R is k A s s e s s m e n t) C o m m u n ic a tio n s L e g a l R is k M a n a g e m e n t O p tio n s S tr a te g y A c t io n W ith d r a w a l o r r e c a ll M o n ito rin g a n d s a m p lin g C o m m u n ic a tio n G u id a n c e o r a d v ic e R e s tric tio n s
16 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.
17 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.
18 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.
19 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.
20 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.
21 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.
22 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.
23 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
24 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.
25 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 to Legal Services (preferably in the 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..
26 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.
27 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.
28 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.
29 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.
30 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.
31 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.
32 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.
33 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
34 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
35 Thank you