FSA 3-year Corporate Plan: Appendix 1 our activities

This will include provision of risk assessment, research and evidence to priorities described elsewhere in this plan, such as the Retained EU Law Review, Border Target Operating Model and our regulated products service. 

This work will carry on each year, in line with evidence needs.

Public analyst official laboratories conduct chemical and compositional analyses on food and feed samples, sent by local authorities or port health authorities for enforcement and surveillance purposes. Direct intervention is needed to ensure the UK retains and builds the testing capacity and capability required to undertake routine testing, support incidents and enable research-related analysis.

We have set out a 3-phase approach to addressing this. We will deliver phase 2 in 2023/24 and 2024/25, and then move to phase 3 in 2025/26.

This includes novel laboratory testing methods to enhance our surveillance capabilities such as genome sequencing and wastewater testing. This will be delivered through the cross-government Pathogen Surveillance in Agriculture, Food and the Environment (PATH-SAFE) programme. In 2023/24 we will continue developing the programme, ready for pilots of new approaches in 2024/25 and 2025/26.

It also includes new analytical methods and approaches to help us better use data such as data trusts, which we will explore in 2024/25.

This includes people’s values, attitudes and behaviours. We will keep publishing research on our website and use it to inform all our work. This also provides information to support our annual Food Standards Report, discussed below as part of our watchdog role.

In 2023/24, we will focus on the impact of household food insecurity, then in 2024/25 and 2025/26, we may be able to begin expanding the scope of our evidence into healthier and more sustainable diets, in line with the FSA strategy. We intend to work with others to deliver this, including our involvement in the SALIENT Food Trials, to design and evaluate a series of trials across the food sector to encourage healthy and sustainable diets.

Risk analysis is the process of assessing, managing and communicating food and animal feed safety risks, making robust and independent recommendations about food safety and standards to decision makers. Risk analysis uses science and evidence to provide advice to government, business and consumers on food safety risks and what to do about them. It’s how we ensure high standards of food and feed safety and protect consumers.

This is an ongoing activity, we’ll continue delivering a quality service each year.

We will continue to support government's work on trade opportunities for the UK, providing risk assessments of countries that want to start importing to the UK and demonstrating our own food safety arrangements to countries we export to. We provide advice to ministers on whether Free Trade Agreements maintain statutory protections for human health to support reports produced for the UK Parliament under Section 42 of the Agriculture Act 2020, and separately on requests to access our markets for specific commodities. 

This is an ongoing activity. Our advice on Free Trade Agreements will continue to be developed on request once new deals are agreed. In 2023/24 we anticipate agreeing a service level agreement for imports market access with Defra, in which case we would deliver in line with that. 

This activity also links to our watchdog role below, providing assurance to parliament and the public on trade agreements.

Activities such as inspections, audits and surveillance, sampling in food businesses are known as official controls. We will ensure clear timely policy advice and recommendations to support the official controls process that makes the best use of available evidence, with early engagement across all UK countries to minimise divergence where appropriate.

This is an ongoing activity, although we will set out particular policy goals in our annual plans in light of issues occurring at the time.

The devolved nature of food policy decisions means that, now Great Britain is outside the EU’s harmonised system, divergence has already started to occur between the regulatory systems of different UK nations. We are committed to working with other parts of government to seek consensus in the advice we provide to ministers in each country. This includes participating in Common Frameworks – cross-government processes that ensure a common approach is taken in devolved policy areas.

This is something we will continue to do on an ongoing basis, ensuring due consideration of divergence issues in all policy development. 

On 27 February 2023, UK Government announced it had reached a new international agreement with the EU on changes to practical arrangements for the Northern Ireland Protocol. 

The FSA must implement aspects of the new agreement, beginning in late 2023/24 and through to 2025. 

The Retained EU Law (Reform and Revocation) Act contains a list of Retained EU Law (REUL) that will be revoked directly at the end of 2023 via a revocation schedule. All other REU will be automatically transferred into domestic, UK legislation at the same date. We will review all pieces of REUL in our remit in England, Wales and Northern Ireland and advise ministers on each of them. We will need to make sure the body of law continues to work effectively as a whole and delivers obligations derived from international agreements. We will do this whilst developing a reform programme to maximise the FSA's ability to make change.

Initial work to review REUL will take place in the first year of this plan, with longer term reforms delivered in 2024/25 and 2025/26.

Precision breeding describes a range of genetic techniques that can alter the DNA of plants and animals in a in a quicker and more precise way but resulting in outcomes that could have been achieved using conventional methods. 

The Genetic Technology (Precision Breeding) Act regulates precision bred plants and animals used in England. To support this and protect consumers, we will continue to develop a new evidence-based pre-marketing authorisation process, enforcement process, and public register for food and feed products developed using these technologies. We will also continue to advise ministers in Wales and Northern Ireland on the implications of the act in those nations.

In 2023/24, we will design each element, consulting on our proposals. We expect to make the necessary regulations in 2024 (this is dependent on parliamentary timetables). Once the new regime has become law, we will be ready to receive applications under the new regulations.

We will continue to proactively explore opportunities for regulatory reform to make the regulated products service more efficient and effective and remove barriers to innovation.

We will take the opportunity of work on Retained EU Law to remove some of the inefficiencies inherited in the body of law derived from the EU, and to streamline the authorisation process making it more efficient to administer, reducing unnecessary delay and improving outcomes for consumers and for industry. This includes the regime for authorisation of novel foods (foods which have not been widely consumed by people in the UK or European Union before May 1997). Novel foods need to be authorised before they can be placed on the market in Great Britain and the FSA advises ministers on authorisation decisions

In 2023/24, we will receive the findings of an independent review of novel foods regulatory approaches, and will evaluate these to consider which would be most fruitful to explore further. Where possible, we will take forward priority changes as part of the second stage of the work on Retained EU Law (by 2026). More ambitious reforms will be subject to the availability of resources to plan and implement change.

In addition to our core work on reducing harm to people with food hypersensitivity (such as responding to allergen incidents and providing advice and guidance to industry and enforcement officers), we have set out a programme of work which aims to improve the quality of life for people with Food Hypersensitivity.

In 2023/24, we will continue to gather evidence, consolidate what we have so far and develop options for next steps on provision of information in the non-prepacked food sector. We will also publish updated guidance to industry on ‘may contain’ statements. In 2024/25 we aim to consult on a workable system for precautionary allergen labelling and test policy options in light of our earlier evidence gathering.

The FSA acts as a ‘Central Competent Authority’ – part of a 3-tier structure to oversee and verify compliance with food law. Food Business Operators are responsible for complying with the rules. Competent Authorities verify and enforce FBO compliance, and Central Competent Authorities audit and assure the work of Competent Authorities.

This activity reflects our role as Central Competent Authority, we will continue to assure that those acting as competent authorities are effectively delivering their responsibilities and to provide support, predominantly but not exclusively to LAs, to deliver food and feed law official controls.

This is an ongoing role which will continue throughout the 3 years of this plan. We will report each quarter on the progress of competent authorities in delivery of their responsibilities to the FSA Business Committee and the findings from our audit programme to the FSA Audit and Risk Assurance Committee.

In addition to our role as a Central Competent Authority, the FSA has direct (Competent Authority) responsibility for inspecting, auditing and assuring businesses in England and Wales producing meat, wine and dairy. The FSA and local authorities together deliver shellfish controls.

This is an ongoing activity, we will continue to ensure appropriate assurance is delivered across all relevant activities, improving standards and assuring compliance. We will ensure that meat, dairy and wine official controls are effectively delivered to time, cost and quality in England and Wales with the correct capacity and capability. We will continue to update the Manual for Official Controls document, which sets out the tasks, responsibilities and duties FSA staff and veterinary contractors undertake in approved meat establishments. In 2024/25 will also publish a version of the Manual for Official Controls that meets accessibility requirements.

A food incident occurs when concerns around the safety or quality of food and or feed may require action to protect consumers. We will continue to use surveillance methods to identify risks to consumers and spot potential food safety incidents and respond to these when they happen. This also draws upon responsive policy input into incidents, and well supported policy advice to support action.

We will continue ensuring the FSA has the capacity and capability to effectively detect, respond and prevent food and feed safety incidents. 

Our National Food Crime Unit (NFCU) works to tackle serious fraud and related criminality in food supply chains. 

We will keep delivering an efficient and effective response to food crime each year. We will also continuously improve the way we do this. In 2023/24 and 2024/25, we will continue to deliver our action plan to implement the findings of reviews of the NFCU completed in 2020 and 2022. By 2025/26 we will benchmark our work against the ‘best in class’ in UK Law Enforcement and other specialist food crime investigative structures in other countries. This improvement is closely linked to securing investigative powers, described below in the change section.

We want to better support local authorities so that they can focus their time and expertise where it adds the most value and best protects consumers. This includes modernising the way local authorities regulate food hygiene and food standards in food businesses. This will help address shortcomings with the current models. 

For the food standards model, revised Food Law Codes of Practice will be introduced in England and Northern Ireland early in 2023/24, and local authorities will commence transition to implement the new model. We will also agree initial key performance indicators and a way to collect data. Our ambition is for all local authorities to implement the new code in 2024/25, and then we would conduct a post implementation review in 2025/26. In Wales, we will pilot the new model in 2023/24, and we anticipate a revised Food Law Code of Practice will be proposed in 2024/25.

Government has set out a UK Border Strategy, which includes a long-term Target Operating Model (TOM) for the border. This includes introduction of Sanitary and Phytosanitary import controls on EU goods and reform of the controls on non-EU goods. The FSA has worked with other government departments on the development of the Border TOM. Our priority is to ensure levels of food and feed safety are maintained or improved when the new Border TOM is introduced.

We anticipate publication of the proposed Border TOM in 2023, with implementation of the model beginning by the end of 2023 and through 2024 and continuous improvement in 2025/26.

The food landscape has changed dramatically in the 3 decades since the current regulatory system was introduced. Although regulation has continued to evolve, it has not kept pace with the significant changes in the food industry. For some parts of the food sector, there may be more effective ways to make sure businesses comply with the rules than our current regulatory model, which is based heavily on in person and regular inspection of food business premises by local authorities. 

In 2023/24, we will trial a new form of enterprise-level regulation with some of the major retailers in England. This could be implemented later in the 3-year period depending on the outcome of the trial.

During 2023/24, we will also begin policy work on the longer-term options available for a future regulatory model, and we expect to continue that work in subsequent years. 

The National Food Crime Unit (NFCU) does not currently have the full range of powers needed to gather the evidence necessary to secure prosecutions in complex and challenging cases of food crime. Although it has access to some powers and investigatory tools, it remains reliant on external partners, primarily the police, or potentially local authorities to carry out certain basic investigatory functions. In line with the recommendations of reviews of the NFCU (see the Kenworthy Review, NAO) we are in the process of securing these powers. In April 2022 Parliament passed the Police, Crime, Sentencing and Courts Act. It provides a power for the Secretary of State to confer relevant powers to officers of the NFCU in England and Wales.

In 2023/24, we will pursue opportunities for a suitable bill to enable the remaining gap in primary legislation (surrounding oversight by His Majesty's Inspectorate of Constabulary and Fire & Rescue Services) and lay out a clear timetable. We anticipate a statutory instrument being made in 2024/25, and the Unit will adopt the powers, with operational use of them continuing into 2025/26.

Food hygiene ratings reflect the standards of food hygiene found at the time of the inspection by the local authority at individual food businesses. Businesses are issued with a sticker showing their rating that can be displayed at their premises. Display of rating stickers at premises is mandatory in Wales and Northern Ireland, but voluntary in England. The FSA is committed to pressing the case for mandatory display at premises and online in England.

The timing of work to deliver this commitment will depend on identifying a suitable route to make primary legislation and a suitable fit with government priorities, and depends on the support of the Department for Health and Social Care. 

In addition to the reforms described above to deliver a sustainable and legally compliant model for official controls, we will continuously improve our own direct delivery of official controls in the meat, wine and dairy sectors within the current regulatory framework. 

In 2023/24, we will become a more effective operational delivery function, through technology and process improvements. These improvements will include, for example, how we collect and communicate inspection results, how we equip our auditors to collect and store information, and how we use data to better target our resources and interventions. We will also produce and deliver against a new, optimised operational performance framework. We will continue identifying new improvements into 2024/25 and 2025/26.

We always look to improve our approach to managing incidents, including rapid policy development. We also want to make greater use of emerging technology and insights, therefore developing our understanding of links between incidents to support prevention.

In 2023/24, we will implement recommendations of a strategic review conducted in light of lessons learnt from the incident arising from the war in Ukraine, and we expect to embed new structures and implement changes to the Incident Management Plan. We will also establish capabilities to provide better insight and analysis of incidents, for example, using root cause analysis surveillance and sampling. We will continue implementing the outcomes of the strategic review in 2024/25 and make further improvements into 2025/26.

FSA and Food Standards Scotland provide assurance under section 42(4) of the Agriculture Act 2020, on whether, or to what extent, the measures in trade deals between the UK and other countries maintain levels of statutory protection for human health for the areas within our statutory remit.
This is an ongoing activity, which we will perform for each year of this plan. Exact timelines and requirements are dependent on the speed and pace of government ambition to negotiate and agree trade deals with priority countries. Deadlines on section 42 are driven by the Department for Business and Trade.

This activity is closely linked to the advice we provide on trade deals described above as part of our policy maker role.

In 2022, FSA and Food Standards Scotland published our first annual review of food standards across the UK. In this report we asked whether our food standards have been maintained over the reporting year with a view to protecting consumers’ interests. 

In 2023/24, we will publish the ‘year 2’ food standards report and develop a 5-year programme of work for the following years. We will publish further reports in 2024/25 and 2025/26.

We work closely with other departments in UK Government, the Welsh Government and the Northern Ireland Executive to deliver shared priorities and ensure consumer interests in food are represented. Several of these priorities are discussed above, including our work on the Border Target Operating Model and Windsor Framework. 

However, there are further cross-government priorities we will make significant contributions to. 
These include some legal obligations and formal policy responsibility, including:

In Northern Ireland, the FSA will support the development and delivery of policy and research to achieve a healthier food environment within the outcomes in the new Department of Health led NI obesity strategy, supporting the NI consumer to access a healthier diet, for example, reformulation, nutritional labelling, restricting promotions and nutritional standards.

We will continue to deliver our comprehensive Welsh language provision in line with our statutory Welsh Language Scheme, under the Welsh Language Act 1993 to ensure an active language choice for our consumers in Wales, so that everybody who receives a service from the FSA, or who communicates with us, can do so in the language of their choice, and will be of the same quality and as accessible as English services 

We will support Welsh Ministers in undertaking their planned review of the FSA in Wales, which will consider current structures, governance and stakeholder engagement to ensure that any findings and recommendations will strengthen our ability to provide the people, resources and processes needed to deliver the FSA’s corporate objectives and priorities 

It also includes priorities we support due to our expertise and capabilities. The list of priorities we are involved with will evolve over time.

This includes FSA and the Department for Education launching a School Food Standards Compliance pilot across 18 participating local authorities in England. This is a joint initiative, supported by the Office for Health Improvement and Disparities, and aims to design and test a new approach in supporting schools to comply with the existing School Food Standards. The standards ensure that schools provide children with healthy food and drink options, and that children get the energy and nutrition they need across the school day. We will complete and evaluate the results of the pilot in 2023/24 and then consider next steps.

The FSA has also been working closely with Defra, Department for Health and Social Care and representatives from across the food supply chain to develop the Food Data Transparency Partnership (FDTP) to improve food system data and information. This will include developing consistent and defined metrics to measure the environmental sustainability impacts on food. We will develop government guidance on a standardised approach to the measurement and communication of scope 3 greenhouse gas emissions for the food and drink sector. We will also consider metrics that incentivise and more effectively measure progress towards improving the healthiness of food, and will enable and encourage food companies to demonstrate progress on the healthiness of their sales. The FSA (with industry) is responsible for the data workstream, which cuts across the entirety of FDTP.   

The Codex Alimentarius develops global food standards, guidelines and codes of practice for food safety and quality and was established nearly 60 years ago by the Food and Agriculture Organization of the United Nations and the World Health Organization to protect consumer health and promote fair practices in food trade. The Department of Environment, Food and Rural Affairs is the lead UK Government Department for Codex. The FSA takes the lead in many of the vertical committees dealing with food hygiene, food additives, methods analysis and sampling, food contaminants, and import and export certification systems. 

We will continue to lead on 5 Codex Committees, which will continue to meet routinely over the next 3 years to develop international standards.

This includes industry, academia, consumer representatives and our suppliers. Through these relationships we can identify opportunities to share information, disseminate guidance and better understand how we could work together in the consumer interest.

This is an ongoing activity we will continue each year. However, in 2023/24 we will also pilot a new ‘FSA Relationship Managers’ approach during our test of new approaches to regulating large retailers, acting as a first point of contact and coordination for their businesses (see regulator above). We will then assess the effectiveness and impact of this approach and consider if it is something that could add value for the FSA as part of our future approach as a regulator.

The FSA has always played an important role internationally through a number of international fora. This includes our involvement in multilateral groups such as the World Organisation for Animal Health (WOAH), the Standards and Trade Development Facility, and our collaborative work with other government departments at the World Trade Organisation. We value our membership of global technical and scientific groups, as well as reactive groups on crisis management and food fraud. We will continue to promote the use of modern digital and data approaches with our international partners. The integrated global structure of the food system requires strong and cooperative international engagement and partnership to maintain the safety of food on our market and otherwise protect consumer interests in relation to food. In order to make best use of limited FSA resources our activities will need to clearly support the priorities set out in the rest of this plan.

In 2023/24 we will develop an internal workplan to set clear priorities for FSA activities and introduce changes to internal processes to better coordinate engagement. We will also continue to organise senior engagements in support of corporate plan objectives, which in 23/24 will include the International Heads of Food Agencies in Dublin and the Global Food Safety Initiative, and planned visits to the US, Canada, France, Israel and India. 

Throughout the period, the FSA will also continue to engage internationally and across Whitehall in support of targeted regulatory modernisation, which improves international food control systems and better protects consumers in the UK. In line with our strategy, we should also look to identify opportunities to build our presence in relevant international fora. Domestic initiatives which we are participating in, such as the School Food Standards (see above for details) has attracted attention from the United Nations World Food Programme and once the results of the pilot are published there will be potential opportunities to share good practice.

The FSA is working with other government departments, including Foreign, Commonwealth and Development Office and The Department of Environment, Food and Rural Affairs’ newly established agriculture attaché network to identify suitable opportunities for engagement and influence. We will continue engagement to assist our learning and thinking relating to innovative methods for production of sustainable food products, including alternative proteins and cell-based meat which exploring various aspects to understand the processes but also the potential regulatory requirements which would need to be considered. 

This includes all of our business as usual activities to recruit people in a fair, innovative and effective approach, performance and talent management, and learning.

Key activities included in our people plan include undertaking a review of our reward package of pay and benefits in 2023/24 and continuing to build on our committed and supportive organisational culture so that our people feel welcome during their time with us and want to come back to the FSA. We will also introduce a new management and leadership development framework that reflect our priorities and values. The people plan sets out activities for 2024/25 and 2025/26, our plan to ensure we have the right mix of skills in our organisation (for example, vets or scientists), pay arrangements, and plans for inclusion and diversity in our organisation.

Everyone in the UK is a potential user of FSA digital and data services. Consumers need food safety and hygiene information, businesses need information to run a food business safely and FSA staff members need services to work efficiently.

We will continue to develop a range of digital and data services in line with our service standard and the Gov.uk service standard where applicable. This includes understanding users’ needs and problems, choosing the right tools and working in an agile way to deliver them. Examples of the services we provide include applying for regulated products authorisation, or our risk likelihood dashboard, which monitors the likelihood of risky food and feed commodities imported into the UK for local authorities.

We will continue to develop a portfolio of digital and data services each year, several specific digital services are discussed below as part of other activities, such as the refresh of several major systems.

Our work to provide fast, modern, reliable digital, data and technology services includes refreshing some of our major systems.

One of the major systems being replaced is our finance, payroll and HR system (work to procure and implement this is known internally as the Connect Programme). In 2023/24, we will exit from our current suppliers and move data into the new system. In 2024/25, we will explore expanding the functionality of the system beyond the minimum viable product of finance, payroll and HR.

In 2023/24, we will also begin the process of reviewing our Smarter Comms system (for communication with local authorities) and looking for a replacement for our Local Authority Enforcement Monitoring System (which captures data from local authorities on delivery of official controls), which are coming to the end of their life.

The FSA maintains several offices across the UK, including Clive House (our London office) and offices in Cardiff and Belfast.

In 2023/24, we will finalise our new Estates Strategy, setting out the FSA vision of our future estates and a plan to transition to it. In 2025/26, we anticipate exiting from our current Clive House London headquarters and moving to a new London office in outer London.

We will implement new performance measures to give strategic oversight of our progress in delivering our objectives. The framework will help identify cross-cutting risks, support prioritisation decisions and provide an overarching view on whether we are on track to deliver or if not, discuss what actions we can collectively take to remedy.

We will roll out our performance assurance framework in 2023/24, and then continue delivering and continuously improving it in 2024/25 and 2025/26. 

The FSA’s budget is set by HM Treasury as part of regular spending reviews, by the Welsh Government in Wales and by the Northern Ireland Executive in Northern Ireland. Our current financial settlement runs until the end of financial year 2024/25. 

In 2023/24, we will prepare evidence for our next spending review submission. We anticipate a request from the HM Treasury to develop a new bid for future years in 2024/25.