FSA Board Meeting - December 2022: Questions to the Board

Question 1: Ginevra Pedrotti – Canon (UK) Ltd.  

I would like to make a request for the following information relating to the authority's current Multi-Functional Devices and printing/scanning services contract(s). 

Will FSA organise a pre engagement exercise to check what is available in the market as your current MFD contract is due to expire on June 2023? How will you engage with the relevant external providers? 

Our response: 

We are reviewing the current MFD offering and realigning the business need against user requirements alongside our Estates and Ways of Working strategies.  Based on the output of this exercise we will hold a supplier engagement session and the tender will be released to the market via Bravo and Contract Finder. 

Question 2: Jack Quick – UK Hospitality 

Good afternoon, 

Ahead of the FSA board meeting on 7 December, UKHospitality would like to submit the below question. 

UKHospitality respectfully ask the Board to ensure that as many adverse consequences as possible are considered when building the evidence base for future reform for provision of allergen information, in particular to the provision of written information on menus.   

• in many businesses, allergen information printed on menus is less reliable than verbal information as it is not easily updated and cannot quickly respond to supply chain volatility, which has been increasing.  
• across the sector, (or example, restaurants, pubs, cafes etc) the verbal conversation triggers additional controls in the kitchen which ensure safety. Written information may discourage this vital part of an allergen safety management system. 

Please ensure that the hypersensitivity team continue to consider the wide range of operating models that exist in the hospitality sector when reviewing written allergen information. UKHospitality would welcome any discussions to build on the ongoing work, and we remain committed to working closely with the FSA across the hypersensitivity agenda. 

(UKHospitality represents 740 companies operating around 100,000 venues across the UK). Please do get in touch if you have any questions. 

Our response: 

The FSA’s mission remains to ensure food you can trust, and we will continue to deliver our core functions which help to ensure that food is safe and is what it says it is. As part of this, a priority is to ensure people with food hypersensitivities are able to make safe, informed decisions when purchasing food.  

As you may note from the Board discussion this month, the FSA has had to make some difficult decisions and identify some work in our plans which can be reduced, paused or stopped. For example, to ensure the review of Retained EU Law retains the right protections for people with a food hypersensitivity, other planned reform work in this area will now need to be delivered over a longer timeframe or paused temporarily, including the provision of allergen information.  

Whilst the pace may have slowed, we are continuing to gather our evidence base and we note the points you make about considering adverse consequences.  In 2021/22 we commissioned research on the ‘Provision of Allergen Information in the Out of Home Sector’ and as part of our food hypersensitivity (FHS) programme of work, we are carrying out further research in this area.  

There are a wide range of different models of service in the out of home sector and the research currently underway will help us better understand how allergen information is provided to consumers across these models. It will also enable us to consider the challenges and opportunities any potential alternative models may present to businesses, particularly small and medium enterprises (SMEs).  

In addition, we are carrying out consumer research to better understand the type and frequency of food allergic reactions (and near-misses) and have commissioned a review of international models of the provision of allergen information and management for non-prepacked food.  

We appreciate the support offered by UKHospitality and will continue to engage with them through their representation on our FHS expert panel. 

Question 3: Paul Crowe, Technical Manager – Baird Foods Services 

Good morning, 

Please may we submit the following question to the board. 

Following the recent letter on the DEFINITION OF MSM 14th Nov 2022 , it informs Food Business Operators that the FSA “will now work to draft new guidance which will support FBO’s to achieve compliance  line with regulatory requirements”. 

Could the Board please give some time frame to when the Draft Guidance will be made public for discussion. 

Our response: 

Thank you for your query. We are unable to confirm the publication date for the guidance at this time. However, work is progressing and once published, Food Business Operators should consider the impact (if any) to their business processes and make any necessary changes.  As mentioned, the 12-week public consultation will be published next year, which will provide interested parties with the opportunity to alert us to any impact (or issues) regarding production. 

Please note that we will notify industry of further developments regarding guidance and the public consultation as soon as possible. 

Question 4: Simon Dawson, Policy Advisor – AIMS 

FSA Prioritization and Insourcing 

1. When the FSA announces the extension of the single service provider contract beyond March 2023, how will they ensure that they secure optimal value for money for the taxpayer and the meat industry? 

Our response:

A variation to the existing contract beyond March 2023 has been assessed as the most financially viable and operationally secure service delivery option within the FSA’s operating budget so as not to result in unreasonable increases to industry costs. To ensure optimal value for money throughout the remaining duration of the contracts, they will continue to be effectively managed in line with Government best practice Contract Management guidance. 

2. As the primary purpose of this proposed insourcing was to provide a benchmarking comparison with the single service provider how does the FSA plan to benchmark the performance and value for money of the service going forward? 

Our response:

Although it would have provided some benchmark of service standards, this was not a primary reason for the pilot of insourced OV resources. The FSA will continue to use existing performance management frameworks and financial monitoring to ensure value for money of all contracted services.  

3. What performance measures will the FSA introduce to address the repeated service delivery failures of the single service provider, which have previously been recognized by the FSA Board and the Business Committee? 

Our response:

There have not been any service delivery failures to FBOs under the existing contract. Throughout and since the Covid 19 pandemic, service delivery has been maintained, every day and in every premises. 

The FSA has a robust performance management framework in place that tracks any service failures or areas of non-compliance against several key performance indicators. Technical non-compliances have been more frequent in recent times, mainly due to lower levels of OV experience since EU Exit and the Covid 19 pandemic, and they are subject to both local and national action plans for resolution or rectification.  

The FSA is working with the supplier to improve the quality of the service and has agreed an action plan which focuses on communications, management, quality assurance and support for both OVs and Technical Managers.  

4. In taking any decision on continuing with the current delivery model what risk assessment has been carried out in relation to any future challenge to the validity of the model by current or potential export markets? 

Our response:

We understand this question to relate to FSA’s Official Veterinarian service delivery model. Any concerns by trading partners are addressed with them and resolved as part of the export negotiation process. There are currently no outstanding issues with our delivery model that have been raised by trading partners. This includes the USA, who at the latest audit in June 2022 were satisfied with our processes and raised no observations or non-compliances on this aspect of our official controls. 

 Our overall delivery model of official controls continues to ensure high standards of food safety and consumer protection currently in place in the UK’s meat, dairy and wine sectors. The UK’s current access to trade partners’ markets is a recognition of the ability of the UK’s Sanitary and Phytosanitary (SPS) control system to set and uphold our high standards of food safety and our ability to comply with their import requirements, as well as our adherence to World Trade Organisation (WTO) rules, including transparency obligations. The current delivery model of official controls is an instrumental part of the UK’s SPS system and is widely accepted and recognised by our trade partners, and it has been crucial to support export-led growth in relevant sectors.