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(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

(2)

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

(6)

Types of Incidents

(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%

(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

(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

(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 i d e n t I n c i d e n t s B r a n c h C o m m u n i c a t i o n s P o l i c y D i v i s i o n ( R i s k A s s e s s m e n t ) L o c a l A u th o r i t i e s I n d u s t r y O t h e r D e p a r t m e n t s / A g e n c i e s L e g a l R i s k M a n a g e m e n t O p t i o n s S t r a t e g y A c t i o n N o t i fi c a t i o n I n f o r m a t i o n f l o w W i t h d r a w a l o r r e c a l l G u i d a n c e o r a d v i c e C o m m u n i c a t i o n R e s t r i c t i o n s M o n i t o r i n g a n d s a m p l i n g I n c i d e n t I n c i d e n t s B r a n c h C o m m u n i c a t i o n s P o l i c y D i v i s i o n ( R i s k A s s e s s m e n t ) L o c a l A u th o r i t i e s I n d u s t r y O t h e r D e p a r t m e n t s / A g e n c i e s L e g a l R i s k M a n a g e m e n t O p t i o n s S t r a t e g y A c t i o n N o t i fi c a t i o n I n f o r m a t i o n f l o w I n c i d e n t I n c i d e n t I n c i d e n t s B r a n c h C o m m u n i c a t i o n s P o l i c y D i v i s i o n ( R i s k A s s e s s m e n t ) L o c a l A u th o r i t i e s I n d u s t r y O t h e r D e p a r t m e n t s / A g e n c i e s L e g a l R i s k M a n a g e m e n t O p t i o n s R i s k M a n a g e m e n t O p t i o n s S t r a t e g y A c t i o n A c t i o n N o t i fi c a t i o n I n f o r m a t i o n f l o w W i t h d r a w a l o r r e c a l l G u i d a n c e o r a d v i c e C o m m u n i c a t i o n R e s t r i c t i o n s M o n i t o r i n g a n d s a m p l i n g W i t h d r a w a l o r r e c a l l G u i d a n c e o r a d v i c e C o m m u n i c a t i o n R e s t r i c t i o n s M o n i t o r i n g a n d s a m p l i n g
(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

(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 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

(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

(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

(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

(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

(35)

References

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