Evaluation of Food Standards pilot: Summary of Findings

This report presents the findings from the evaluation of the pilot programme that the Food Standards Agency (FSA) has completed to test a proposed Food Standards Delivery Model (FSDM) as part of the Achieving Business Compliance (ABC) programme. The proposed model aims to support local authorities (LAs) in England, Northern Ireland, and Wales in targeting resources more effectively, and provide better assurance and more flexibility to LAs. The pilot programme was carried out with seven LAs in England and Northern Ireland ^{(footnote 1)}. The pilot started in January 2021 and finished in March 2022.  

LAs in Wales were unable to pilot the proposed model at the same time, as the Food Law Code of Practice (Wales) (the Code) does not contain the same provision to allow LAs to deviate from the Code for pathfinders and pilots. There were also concerns about the proposal on how very low risk businesses would be regulated. These concerns have been addressed as part of the post-pilot model review and a pilot of the model is expected to be carried out in Wales in 2023, subject to Ministerial agreement. 

The evaluation methodology focused on capturing LAs’ experiences working to the new model through the entire pilot programme, to adequately capture nuances in its use and factors impacting its performance. It comprised of a scoping phase; data collection, including three rounds of interviews with LAs, interviews with FSA staff, quantitative data collected by FSA’s analytical unit; and an analysis and triangulation phase, integrating the qualitative and quantitative findings. 

The findings show that the three components introduced by the proposed FSDM (a risk scheme, a decision matrix and the use of intelligence) worked well. The new risk scheme was seen as more effective in identifying food businesses that present the greatest risk. Key benefits included greater flexibility in the model, the ability to re-score premises and the ability to use intelligence to select the most appropriate intervention. LAs highlighted the new risk scheme was straightforward to use and, by the end of the pilot, they had already embedded the new way of working into their work practices. 

The process of implementing the pilot was successful overall, with LAs identifying the support received from FSA as a key enabling factor. The support received helped LAs to change working practices to facilitate the proposed model and to strengthen communication channels, which promoted greater intelligence sharing. 

LAs identified challenges with the model. Some of these were resolved within the pilot, while others will require further work between both LAs and FSA. One challenge which was mitigated during the pilot centred on ensuring consistency of officer interpretation. For example, it was identified that ‘single local supplier’ was interpreted differently by LA officers. During the pilot, FSA and LAs collaborated to identify terms which were being interpreted inconsistently and provide clear definitions. The second challenge was related to the perceived effectiveness of Targeted Remote Interventions (TRIs), as some LAs perceived TRIs as being only useful for specific types of business. This led to LAs using TRIs in the context/s they deemed most appropriate and choosing to do a physical inspection in others. 

One outstanding challenge LAs identified during the pilot process relates to data inconsistencies about the registered Food Business Operators (FBOs) in the LAs’ respective Management Information Systems (MIS). The LAs were not always able to integrate the proposed model into their MIS software for the purposes of the pilot. While LAs were aware of this in relation to the pilot, it still led to some initial difficulties, such as duplicating the recording of work for some officers. Looking forward, FSA will recommend that LAs databases are up to date before starting to work with the proposed model. The use of intelligence (gathering and sharing it) was also identified as a challenge for some LAs, and this is an area which FSA and LAs continue to work on. 

Overall, the communication and ongoing support between FSA and LAs has been a success of the programme. The pilot model has been shown to work well and deliver the intended short-term outcomes. Most of the initial challenges identified which were not related to the practicalities of the pilot were addressed and the pilot has been a vital stage for FSA to inform the launch of the proposed model at a national scale.