Three-Year Corporate Plan

1. Summary

1.1 This paper sets out the FSA’s corporate objectives for the next three years.  It describes how we will continue to deliver our strategy ‘Food you can trust’ published last year.

1.2 It also provides detail on the indicators we will use to measure progress toward delivering our strategy. 

1.3    The Board is asked to:

• Approve the three-year objectives contained in this paper
• Agree on the approach taken to indicators of the success of the strategy contained in this paper
• Agree for the executive to publish a more detailed plan updating and setting out how we will deliver each of these objectives over the next three years, to be published in due course.

2. Introduction

2.1 The FSA published our 2022-2027 strategy in March 2022.  Alongside this we indicated our intent to publish a three-year corporate plan and annual business plans.

2.2  The purpose of the three-year corporate plan is to set out how we will turn the ambitions of our strategy into concrete action.  It bridges the gap between the strategy and our more detailed annual business plans, which describe the activities that we will deliver each year.  The longer term view means that we are better able to plan work over the whole three years, including work that will take more than one year to deliver and where we will start work in later years as we create capacity following our prioritisation work in 2022/23. 

2.3  The three-year plan gives the organisation a clear sense of direction, while allowing us the flexibility to respond to new challenges as they emerge.   

3. Discussion

Our Approach

3.1    We have adopted the following principles in putting together our three-year corporate plan:

Flexibility: we continue to face uncertainty over the next three years, both economically and politically with a general election expected to take place no later than January 2025.  We have embedded flexibility in the plan, being explicit about what we absolutely must do, what we intend to do, and what we could do if resources allowed - adopting a Must, Should, Could framework.

Balance: our strategy will be delivered through a mixture of the core, day to day activities and change and reform.  We need to strike the right balance between these ensuring we deliver food you can trust now, and in the future.  Our plan recognises this by including sections on both core and change objectives.

Three-country working: Our plan covers our role across England, Wales and Northern Ireland, reflecting our ‘One FSA’ approach.  For all of the objectives discussed in our plan, we will ensure that specific circumstances of each country are considered, and that stakeholders from each country are informed and heard.  We also work collaboratively with Food Standards Scotland in line with our commitments to four-country working.  Further information on plans specific to the FSA in Wales are set out in our prioritised plan for Wales and reports from the Director of the FSA in Northern Ireland.  Further updates will be provided this year from both Wales and Northern Ireland reflecting the changing landscape and priorities.

3.2 Our strategy sets out five roles the FSA has in delivering food you can trust.  These are evidence generator; policy maker; regulator; watchdog and convenor; and collaborator.  These five roles form the framework of our three-year plan. 

3.3  This plan covers all three parts of our vision, food is safe; food is what it says it is; and food is healthier and more sustainable.  The majority of our work – particularly our work as an evidence generator, policy maker and regulator – is focused on our core role to ensure that food is safe and is what it says it is.  

3.4 Our ambition for work toward healthier and more sustainable food is substantively different.  This part of our vision will not be embedded across our organisation in the same way as our work around ‘food is safe and what it says it is’ and will remain more discretionary.  We have a small number of specific responsibilities on food that is healthier and more sustainable (for example, our nutrition policy remit in Northern Ireland) but most of our work will be in our role as an evidence generator, convenor and collaborator, and watchdog.  We will continue to look for opportunities to develop and share insights, and to work with other parts of government and the wider food system to achieve shared goals. 

Our objectives: evidence generator, policy maker and regulator

3.5  Our strategy sets out five roles the FSA has in delivering food you can trust.  These are evidence generator; policy maker; regulator; watchdog and convenor; and collaborator.  These five roles form the framework of our three-year plan.  The first three roles represent the more established part of our work, and our statutory responsibilities.  They are non-discretionary and will continue to be where we focus the majority of our resources. 

3.6  As an evidence generator, we ensure that our decisions, and those of others, are informed by the best evidence – so that people can have food they can trust.  We use our evidence to advise ministers on policy that sets rules relating to food and then enforce and assure these rules are being followed.  We deliver strong data, analysis, insight and research to support food safety and authenticity, and, where appropriate, to contribute to environmental and health outcomes around food.

Evidence generator core objective: Ensure that our decisions, and those of others (consumers, businesses and policy makers) are informed by evidence.

Evidence generator change objective: Build evidence so we can anticipate opportunities and risks across the UK food system (for example, food itself, food industry behaviours, food regulatory system and consumers, standard of food imports vs domestic production).

3.7 As a policy maker we ensure that the body of guidance, rules and regulations that exist – nationally, internationally and at a devolved level – deliver food you can trust.

Policy maker core objective: Make robust recommendations and support decision makers to take informed decisions on rules relating to food and feed, based on evidence and independent assessment.

Policy maker change objective: Improve and reform the Regulated Products Service to create a proportionate, effective and future-focused approach to regulation that protects consumers and reduces barriers to innovation. 

3.8 As a regulator we – either directly or through partners like local authorities – make sure that food businesses are compliant with the rules and support them to follow best practice, so that consumers have food you can trust.

Regulator core objective: Deliver our regulatory responsibilities to ensure food and feed businesses comply with the rules so that food is safe and what it says it is.

Regulator change objective: Reform the food safety regulatory framework to deliver more proportionate and risk-based assurance, now and in the future.

Our objectives: Watchdog, Convenor and Collaborator

3.9 The fourth and fifth roles in our strategy represented areas where we wanted to grow our role and do more.

3.10  We want to identify how we can best deliver these roles over the coming three years.  This would include work in support of achieving all three elements of our vision, food is safe, food is what is says it is and food is healthier and more sustainable. 

3.11 In our watchdog role, we can look across the food system and monitor developments or progress toward actions that support public health, or the other interests of consumers in relation to food.  We will use our independence, our voice and our evidence to inform and persuade others in line with our principle to be the trusted voice on food standards, protecting consumer interests.

Watchdog objective: Speak out publicly about areas of consumer interest to support food standards in the UK.

3.12  The FSA is just one of the actors in the food system.  To deliver food you can trust, we will need to work with other parts of government, including the UK Government, Welsh Government and Northern Ireland Executive, Food Standards Scotland and local authorities, our delivery partners, industry and consumer associations.

3.13  We will collaborate with partners across all of our work – but we will also look to go further by proactively convening others in the food system to explore new approaches, ideas and challenges, working together to ensure food you can trust.

Convenor and collaborator objective: Work in partnerships across the food system to address issues in the food system affecting consumers and businesses.

Our objectives: Enabler

The roles described in our strategy focus on our outward facing work to ensure food you can trust.  However, this could not happen without significant contributions by enabling functions that allow our organisation to operate.

3.15  Therefore, this three-year plan has an additional section reflecting the objectives and goals we need to deliver in this space. 

3.16  This includes delivering supporting functions such as finance, human resources and culture, commercial and technology.  It also covers specialist skills in communications, legal, project and programme management and strategy, which are required for our organisation to run effectively.

3.17 Our enabling work ensures that all of the other parts of the organisation are equipped to deliver food you can trust.

Enabler objective: Provide the people, resources and processes needed to deliver the FSA’s corporate objectives and priorities.

3.18 A breakdown of all activities is included as Annex 1.

Indicators of Progress

3.19  When discussing our strategy with the Board in March 2022, we committed to providing an update on how we would measure progress.  We propose including a set of indicators in our three-year plan which will help us to evaluate the progress of our strategy, in line with the guiding principle from our strategy: we are open and transparent.

3.20 These indicators will deliberately be focused on outcomes in the food system, rather than outputs from the FSA.  We think this is important, since ultimately all of our work is aimed at delivering such outcomes.  But the food system is complex, and it will not always be possible to draw a direct causal link between our actions and outcomes in the system.  We intend the indicators to be a bellwether rather than a set of KPIs for the FSA.  We will make this very clear in our plan.

3.21 We will give the Board an annual update on these indicators, which can support a discussion about our progress in delivering the FSA’s mission (food you can trust) and vision (food is safe, food is what it says it is, food is healthier and more sustainable), and where we need to focus our efforts in the coming year.  Meanwhile, we envisage that the Business Committee would continue to scrutinise the FSA’s own performance against our statutory duties and consider whether we are delivering the commitments made in our plans.  

3.22 We propose three groups of indicators which align with the FSA mission and vision set out in the strategy.  Each group title also sets out our ambition for the group:

• Maintaining food you can trust: our ambition is that trust and confidence in the food system, and in the FSA remain at their current, high levels, despite pressures emerging in the coming three years.  This would include indicators such as consumers’ confidence in the food system and FSA itself measured via surveys.
• Maintaining food that is safe and is what it says it is: our ambition is that current high levels of safety and authenticity standards are maintained.  This would include measures such as rates of foodborne pathogens, compliance rates for food businesses and statistics on the number of incidents.
• Contributing to food that is healthier and more sustainable: our ambition is to grow our contribution to food that is healthier and more sustainable, building on the work we have started since we published our strategy.  This is the most complex area in which to set indicators because our contribution is limited.  Therefore, this would include measures of outcomes for our work in Northern Ireland on nutritional standards and dietary health, alongside case studies of our specific contribution to projects.  We will refine our approach indicators for this part of our vision through the external engagement on our three-year plan described below.
• Each group will comprise around three to four indicators.  We are refining an appropriate list of indicators with the Executive and colleagues in the FSA’s Science, Evidence and Research Directorate.  These will complement and draw from existing performance assurance and reporting, and publications such as the Annual Report on Food Standards.

Engaging Externally on our plans

3.23  We will engage externally following the publication of our three-year plan on specific parts of the plan.  This will take the form of targeted events and feedback, rather than a formal public consultation. 

3.24  Our roles as evidence generator, policy maker or regulator are well established, and in many cases set out in legislation.  As such, the focus for our engagement will be input from stakeholders on our watchdog and convenor and collaborator roles.  This engagement will provide an opportunity to identify opportunities for collaboration.  We do not expect to engage externally on the “enabler” part of our plan, which is internal.

4. Conclusions

4.1 The contents of this paper set out the executive’s view of what we will deliver in the coming three years to achieve our strategy.

4.2 The Board is asked to:

• Approve the three-year objectives contained in this paper.
• Agree on the approach taken to indicators of progress of the strategy contained in this paper.
• Agree for the executive to publish a more detailed plan updating and setting out how we will deliver each of these objectives over the next three years (to be published later in March).

Annex 1: Detailed Activities within each objective

We have broken down each objective into a set of more detailed and specific activities.  Given our context, we need to remain flexible in terms of what we commit to for the next three years.

To reflect this, we have further divided our activities into:

• must: things we absolutely need to deliver.  These might be statutory responsibilities we need to maintain or changes we need to deliver in order to ensure the regulatory system continues to protect consumers.
• should: things we will aim to deliver but may need to reassess if circumstances change.
• could: things we will deliver only if resources and circumstances allow.

Objective: Evidence Generator core: Ensure that our decisions, and those of others (consumers, businesses and policy makers) are informed by evidence.

Must: Ensure risk analysis decisions and priority ‘core and change’ work are informed by timely and robust evidence.  

Objective: Evidence Generator change: Build evidence so we can anticipate opportunities and risks across the UK food system

Must: Develop a labs and sampling regime that is fit for purpose and resilient to the future to assure food safety and authenticity.  

Should: Identify and test technical and scientific innovations to enhance the FSA’s capabilities.

Should: Maintain and where necessary build our evidence base on the public interest in food to better inform all our decisions.

Should: Improve information to consumers, regulators, businesses and other stakeholders on the standards of UK food.  

Could: Start to build more evidence on the externalised costs of UK food to the environment and people’s health, to demonstrate the importance of the standard of food.

Could: Develop and publish best practice guidance for the food industry and product level data standards.  

Objective: Policy maker core: Make robust recommendations and support decision makers to take informed decisions on rules relating to food, based on evidence and independent assessment.

Must: Maintain an effective and efficient risk analysis process supporting decision making across all UK countries.

Must: Make recommendations to Ministers about which food and feed products should be authorised for sale on the market in Great Britain.  

Must: Assess and make recommendations on market access requests and provide technical input to other government departments on “Sanitary and Phytosanitary” and “Technical Barriers to Trade” issues in trade agreements

Must: Provide policy advice to support delivery of effective and risk-based official controls.

Must: Manage divergence, meet our common framework obligations and ensure consistency for consumers and businesses across the UK.

Must: Ensure food standards and public health are maintained, under the arrangements of the Windsor Framework for trade between Great Britain and Northern Ireland.  

Must: Deliver a series of Statutory Instruments needed to preserve Retained EU Law within our remit, whilst developing a reform programme to maximise the FSA’s ability to make change through the Retained EU Law Bill.

Objective: Policy maker change: Create a proportionate, effective, efficient and future focused approach to regulation through the risk analysis process and regulated produce service, that protects consumers and removes barriers to innovation

Must: Develop a new regulatory regime for precision bred food and feed.

Should: Explore targeted reforms to the regulated products regime through powers to be created under the Retained EU Law Bill.

Should: Explore options to improve the provision of allergen information for people with a food hypersensitivity.

Could: Review and strengthen FSA capability to take into account environmental and health benefits and risks when considering other legitimate factors as part of risk analysis.

Could: Influence thinking inside and outside government about ‘eco-labelling’ to ensure consumer interests are protected.

Objective: Regulator core: Deliver our regulatory responsibilities to ensure food and feed businesses comply with the rules so that food is safe and what it says it is. 

Must: Deliver our regulatory responsibilities as the national regulator to assure that feed, food and importing businesses are compliant with the rules.

Must: Directly deliver official controls in meat, dairy and wine businesses (including exporters).

Must: Deliver an efficient & effective response to Food and Feed Incidents.

Must: Deliver an efficient & effective response to food crime. 

Objective: Regulator change: Reform the food safety regulatory framework to deliver more proportionate and risk-based assurance, now and in the future. 

Must: Ensure the new food standards and revised hygiene delivery models for Local Authorities are in place and working well.

Must: Work effectively with governments in each country to agree and deliver the Border Target Operating Model for import controls.

Must: Develop a sustainable and legally compliant model for official controls.

Should: Secure access to appropriate additional investigatory powers for the National Food Crime Unit

Should: Work toward primary legislation making display of Food Hygiene Rating Scheme scores mandatory in England.

Should: Improve effectiveness and efficiency of FSA’s direct delivery of official controls.

Should: Improve our approach to preventing and managing incidents.

Could: Implement alternative approaches to obtaining assurance from multi-site businesses at enterprise level.  

Objective: Watchdog: Speak out publicly about areas of consumer interest to support food standards in the UK. 

Must: Produce advice on human health statutory protections in trade deals on request by DIT for section 42 reports, and otherwise comment publicly on the impact of a trade deal where appropriate to protect consumer interests in relation to food.

Should: Monitor the standard of UK food and produce regular national assessments of the state of the national food standard (concerning safety and authenticity), including both domestic and imported food as well as the state of the food regulatory system.

Could: Expand our monitoring of the standard of food to include health, sustainability, welfare and social impact, and in relation to consumer behaviour.  This could then be incorporated into an expanded annual food standards report.

Objective: Convenor and Collaborator: Work in partnerships across the food system to address issues in the food system affecting consumers and businesses

Must: Work with wider governments in the UK, Wales and Northern Ireland, and with Food Standards Scotland to ensure FSA contributes to the delivery of key cross government priorities on market access (imports and exports).

Must: Work with government in each country to contribute to cross government priorities in relation to food.

Should: Build strong working relationships with industry and food system stakeholders to work with and through others.

Could: Build our international reputation and influence as a leader in food safety and regulation to strengthen protection of consumers in the UK.  

Could: Convene food system stakeholders to solve key issues facing consumers.  

Objective: Enabler: Provide the people, resources and processes needed to delivery the FSA's corporate objectives and priorities

Must: Attract, retain, and support our people, identifying current skills and needs and delivering and implementing the people plan.

Must: Refresh our systems to provide robust and efficient technology support including a new finance, payroll and HR system implementation.

Must: Deliver and embed a new performance assurance framework.

Must: Support the FSA’s operating model by providing the right estate for our future needs.

Must: Develop evidence and the strategic approach to support the next Spending Review and other Government commissions.