Is food safety broken? If so, how do we fix it?

Food safety enforcement in England could be on the verge of its largest change since the nineteenth century. Some fear privatisation and ‘regulator capture’. Others argue that technology-driven innovation is long overdue. 

It’s been a newsy year for food safety. In January, the UK was unable to implement its promised frictionless, single trade window, featuring newly-designated border control posts and digital health certificates, in time for the return of controls on EU animal and plant imports. The result was long queues of lorries and chaos. It was more Dad’s Army than James Bond.

EHOs in Dover warned of illegal pork being smuggled into the UK in unprecedented quantities in white vans, prompting fears, in the Daily Mail, of an outbreak of African swine fever. In March, the Guardian reported that hospital admissions from salmonella, the most common form of food poisoning, were at all at time high. Some commentators attributed the surge to Brexit catastrophically reducing physical safety controls and the stripping of capacity from local government over the austerity period.

In October, stories in the catering trade press proclaimed ‘Move to self-regulate could reduce safety visits’, then ‘Scores on doors scandal to “torpedo” FSA plans for food safety shake-up’. An undercover BBC investigation had discovered hundreds of premises, including a branch of Sainsbury’s mis-declaring their food hygiene rating scores. Food is always political, and policy decisions are often hijacked by events.

It would be possible to conclude from this year’s headlines that the UK’s food safety system is ‘broken’. Public health commentator Sterling Crew doesn’t think that the system is broken. But he does believe that it needs some reforms, to bring it up to date.

Crew, a chartered fellow of the CIEH has a 40-year background in food regulation, manufacturing and retailing. Today, he observes, supermarkets account for 95% of grocery sales, in a sector that is dominated by ten giants. Yet, he notes, the model for food safety enforcement has changed little since the 1875 Public Health Act.

It was designed for an era in which environmental health officers trod local beats inspecting abattoirs, cowshed and pie shops. He says: “I was very happy when I became a local authority EHO, over 40 years ago. But I did not think that the methods of the job had really changed since Victorian times.”

Local versus national

The anomaly of locally-based enforcement system, set against increasingly national, and global, food supply and retailing chains has been clear for several decades and it is growing more acute as local authority budgets continue to shrink. In response, in 2009, the UK’s Food Standards Agency, which was set up by New Labour in 2000, established a voluntary system of ‘primary’ authorities. Under this system, national retailing chains could choose a single council to act as a lead and referral point for advice and enforcement. The scheme was expanded in 2017.

The legislation that created the FSA allowed it to become a national enforcement body, but its political masters have chosen, up to now, not to give it that remit. The agency has intimated, at times, that it would be appropriate for it to regulate big business, leaving local authorities to focus on the sole traders and SMEs that make up the majority of the UK’s 600,000 food businesses.

In 2015, the FSA set off down that road. Under a controversial plan called Regulating Our Future, the agency would hold a national database of risk-rated registered food businesses. For the first time, data from third party, private sector audits would be incorporated into the primary authority system. Later, the agency envisaged, large businesses would be charged for food safety inspection, shifting the cost from local government.

The plan met with widespread opposition from many traditionalist EHOs, who viewed it as a heresy – a ‘privatisation’ of food safety inspection and a threat to local accountability. It was delayed and ultimately prevented by the huge national disruption caused by Brexit – events hijacking policy again.

Not dead, but resting

Regulating our Future has not disappeared from the FSA’s thinking. It has just been resting. It re-emerged, in a slightly modified form, in 2021 as Achieving Business Compliance. Conceived as a blueprint for a future regulatory system, ABC includes ‘enhanced registration’ of food businesses, co-ordinated by the FSA, and national regulation of big businesses, incorporating third-party audit data.

The system has been trialled by the FSA with, Aldi Asda, Sainsbury’s, Tesco and Waitrose. According to the agency, the data available from supermarkets’ third-party audits offers greater insight into their adherence to food safety rules than the existing local authority regimes. But ABC is just as controversial with many EHOs, as its predecessors Regulating Our Future and the primary authority system and, for the same reasons – they fear loss of local control and accountability and the potential for ‘regulatory capture’.

Discussed by the FSA board in in September, the latest iteration of ABC is that the legal enforcement body for UK’s ten largest supermarkets chains would become their primary authority as soon as next year. In the second phase, secondary legislation and changes to the Food Law Code of Practice would extend the FSA’s powers across retail, manufacturing and food-to-go sectors – a significant ‘nationalisation’ of enforcement, removing the cost of a large proportion of the cost of food safety services from councils.

Such a dramatic re-configuring to of the enforcement architecture, breaking the Victorian template and reducing the role of councils, would have to be a decision made at government level, either late in this Parliament, or the next one.

Crew does not fear such a change, if it is intelligently applied. He says: “In my opinion, the UK benefits from one of the most well-regulated, safest and authentic food systems in the world. But, despite that, we still have challenges to address. There is a need for a strong and capable regulator particularly with a global supply chain.”

He notes that Edwin Chadwick, who was the prime mover of food safety and sanitary reform in the nineteenth century, did not foresee Deliveroo, ‘dark restaurants’, globe-spanning food multinationals and artificial intelligence. Data is ubiquitous in the twenty-first century, he reasons. Why not use it and share it better?

He says: “Environmental health practitioners both in LAs and the private sector are passionate about the values to protect public health. I have seen many public and private collaboration initiatives that have improved public health, and I hope to see many more.”

Dwindling resources

He adds: “I do have major concerns surrounding the dwindling resources within local authorities We have seen a dramatic drop in the employment of EHOs. With strains on resources, I believe the regulatory framework needs to act smarter and take advantage of some of the new innovation in the sector.

“One way to do this is to incorporate the findings of voluntary third-party audits into the assessment of inspections. We could also take advantage of using remote inspections and audits. We saw some of these new innovations adopted during the Covid19 pandemic.”

Crew is a fervent admirer of the local authority EHO. He has been one himself. He argues that such a nationalised approach could be accompanied by much-needed and long overdue local reforms – why shouldn’t passporting, or prior approval, be required for running a food business? The mandatory display of food hygiene rating scores in England, as in Wales and Northern Ireland, he adds, would massively enhance the effectiveness of the scheme.

Long-term he believes that the biggest threat to food safety is not regulatory architecture but in filling future job roles and the resilience of the food safety profession. He says: “I am convinced that the biggest challenge ahead of the food sector is in retaining and recruiting talent, especially in the technical arenas. I think there are great rewarding careers available as an environmental health practitioner. We should all do our upmost to encourage people to join us.”

Crime and policing – whoops, we lost society

Labour's desired return to ‘neighbourhood policing’ is problematic. The infrastructure and shared values that once held communities together has been lost. But at least we can start to trying to rebuild.

UK politics are cyclical. For example, traditionally, the Conservatives remove rent control and security of tenure, Labour brings them back. Shifts of government bring dramatic changes of emphasis on criminal justice, from ‘bang ’em up’ to ‘hug a hoodie’ and back again.

Keir Starmer’s government, under the banner ‘take back our streets’, has promised to return to neighbourhood policing, delivered by 13,000 new neighbourhood police and police community support officers.

The ambitous plan is that Young Futures programme hubs will be staffed by youth and mental health workers and careers advisers. In the frontline of tackling ASB, new Respect Orders (a clever name) look like a re-tread of ASBOs. They will address issues including street drinking, noise, off-road biking and fly-tipping. Breaching them will potentially lead to fines or imprisonment.

The plan is well-judged and timely. It sounds utopian, compared to what we've got now. The measures look familiar. Both the rhetoric and mechanics of the new government’s approach, combining preventive programmes with unabashed punishment, strongly recall those of New Labour.

Jim Nixon, RHE Global’s director of community safety, a well-known podcaster and influencer on anti-social behaviour, has seen many changes of government and dramatic shifts in emphasis over the years. He began his career as a policeman in the West Midlands in 1995, reaching the rank of sergeant.

His days on the beat coincided with the implementation of New Labour’s far-reaching Crime and Disorder Act of 1998, which promised ‘joined up thinking‘ and brought the innovations of community safety partnerships and antisocial behaviour orders (ASBOs). Obliging councils and the police to work together, often for the first time, the act was designed to ‘tackle the causes of crime’, rather than to merely deal with the consequences.

Generous funding 

In that era, historically generous funding reached street level. Nixon recalls working in a team of eight police officers on a single beat in Sandwell, dealing with issues from graffiti to burglary and armed robbery, generally without cars. By the end of New Labour’s second term, the funding that had brought shiny regeneration schemes to blighted council estates and inner cities had run out. But some valuable legacies remained, at least as good practice – evidence-based policy making and partnership working.

The next policy milestone came just before Nixon left the police to bring his skills and knowledge to a large social landlord. Building on some elements of New Labour’s legacy and assumptions, the 2014 Crime and Policing Act amalgamated multiple ASB powers into six, including public space protection orders (PSPOs), enforced through fixed penalties.

Civil injunctions were attached to ASB enforcement, reducing its evidential burden and criminal behaviour orders (CBOs) were introduced, replacing ASBOs, which had been fixated upon by the popular media and trivialised, so that they were perceived as ‘badges of honour’ by offenders.

It’s common, in this area of policy, for governments to copy the good ideas of predecessors but to call them something else. The legislation that this Labour government has promised, will build on the Conservatives’ Criminal Justice Bill, introduced in 2023. It came with similar mood music – unsafe public spaces, needing to be ‘reclaimed’ by frightened communities.

Labour also inherits from the Conservatives elected police and crime commissioners (PCCs) which replaced police authorities in 2018. Most people would say that PCCs have failed to attract public support or interest. They have been largely invisible. Nor has the Independent Office for Police Conduct, set up in 2017 to improve public confidence in the police complaints system in England and Wales, demonstrated that it is genuinely autonomous and has teeth. 

Police at low ebb

Battered by cuts, and by allegations of excessive violence and racism, now provable by camera footage, and of ‘two-tier policing’ by recent short-lived but opportunistic home secretaries, the 43 largely autonomous police forces of England and Wales are currently functioning at an extremely low ebb.

Nixon admits: “Policing, from a reputational point of view, is the lowest I’ve ever known it.” In addition, he notes, our courts and prisons are overloaded, the probation service is “on its knees” and mental health services, for people of all ages, are stretched to breaking point. 

It’s not a great place to start from. Margaret Thatcher said “there's no such thing as society” – almost two decades of austerity-led Conservative government policies have helped to bring that about.

David Cameron's Coalition government in 2010 proposed the cozy oneness of the ‘big society’ – dog shows, the Women's Institute, jumble sales – to replace facilties and instiutions that were jeopardised or being shut down – libraries, youth services, community centres. Of course, it was nonsense. For those of us who are not rich, public serivices are the glue that unites us and makes life tolerable, or, in some cases, possible. Much of this infrastructure has simply been removed. What's left is creaking. In some cases, parks and museum are now run by volunteers – which is what Cameron's policy idea eerily forestalled.

Labour has mulitple problems that will take longer than five years to fix. The collapse of criminal justice is symptomatic of a far broader problem. Society has retreated in the face of a neo-liberal, low-tax assault whose objective were, ultimately, California-style private police forces and gated communites, with the poor camping on pavements,

Politician are viewed by the public as cynical, self-interested and greedy. The idea of ‘public service‘ is almost dead. We've lost the shared values that made possible policing by consent, the paradigm of the service inherited from Sir Robert Peel. We're at the bottom of a very deep hole. Multiple institutions need repairing and the largest – such as the House of Lords, the police, health and social care – defy repair becuase our sytems of governance themselves are broken. 

In the face of this unholy mess, it's a good job that some people remember the good old days before the expenses scandal of 2009, began to unravel UK politics, leading to a clown's parade of weird, no-hoper loosers leading or seeking to lead the Conservative party, since the collapse of the Cameron coaltion and the catastrophe of Brexit.

At a local level, some of the good ideas initiated during more progressive periods of policy, have surivived in a vestigial form in some places. For example, the partnership, multi-agency working that was introduced in public services in the late 1990s, is now accepted as the best way to get results, if not always observed. The problem is a lack of uniformity. There have no ‘big brains’ in charge of the major departments of state within the living memory of Gen Z. All they have seen is chaos. No wonder they have such low expectations.

In the case of the police, separate authorities largely ‘do their own thing’. The service is neither national or local and, tossed around as a political football, it has lost a sense of identity. Getting it back will require policy consistency and continuity and for politicians to move beyond gimmicks and slogans. It will take longer than the five years of a political cycle.

To get ‘neighbourhood policing’ right, Nixon says, we’ll need to genuinely listen to empower communities. It is a hard thing to do, he notes. Empowerment was the language of New Labour, but it wasn’t always the practice. The party adopted a top-down approach. It parachuted in well-paid consultants to interpret the wishes of the socially excluded or self-appointed ‘community leaders’. Some new infrastructure that was built was never used.

The government’s lavish final regeneration programme, housing market renewal pathfinders, delivered solutions that few people wanted across the north of England, including the demolition of popular housing. It ran out of steam and was abandoned. 

Tackling the causes

Nixon believes that the best strategy to reduce ASB, including noise, is to tackle its human, social and physical causes, rather than serving notices as a first resort. He says: “It’s important not to rush into enforcement. You’ve got to understand the problem first and the people you are dealing with to find the right solutions. You may need to have a professionals meeting and bring in other agencies to assess what is the best course of action.”

He adds: “In my view, short-term prison sentences don’t work. I would always look at other options to address what is causing the behaviour. Alternatives to prison are desperately needed. I’m a firm believer that people’s behaviour can change with the right approach.” 

Nixon welcomes the prospect of new legislation. He says: “We’re all waiting on the Criminal Justice Bill that will bring in a review of the tools and powers around antisocial behaviour, including Respect Orders. It’s imminent but, at the moment, everyone’s in the dark – we don’t know exactly what will be in it.”

At the same time, he argues that existing legal mechanisms to reduce pressure on courts and prisons are not being sufficiently used. He notes that positive requirements that can be included in injunctions and criminal behaviour orders (CBOs), for example to address drug or alcohol issues, are not being applied to their full effect. Community safety partnerships, a welcome innovation of 1998, have been patchily applied and there is no auditing of their effectiveness.

In addition, the victims of ASB, are being badly let down by statutory services, as argued by a recent report from Victims’ Commissioner, Baroness Newlove. Nixon says: “We’re now in the tenth year of the 2014 Crime and Policing Act which introduced the community trigger, now called the ASB case review, but a lot of victims of ASB who contact me say they have never heard of case reviews. In my view, there are far too few of them and there needs to be a standardised, uniform template for how they are conducted.”

Sniped at by right wing commentariat and the deluded far left of his party, Starmer is an adult in the room. Yes, he has needed to be as slippery as a dog toy to gain control of the levers of power – a new Harold Wilson. Health, the Home Office and the Treasury now have credible and intelligent people in charge and Angela Raynor gives Starmer the street cred that John Prescott provided to Tony Blair. There is less privilege and entitlement around the cabinet table that at any time in our history

The cabinet is far too big – it's dysfunctional. The Privy Council, the royal prerogative and bishops in the House of Lords are ludicrous survivals of Feudalism. England probably needs its own Parliament, in somewhee like Birmingham, as the post-Brexit union continues to diverge, But that's second term stuff. Maybe Starmer can at least start to fix the car of state. Broken, rusty and tucked away in some farmer's barn, this old classic is now only fit for the scrapyard.

On comic books and the end of history

 

Dumbed down TV, dumbed down politicians, dumbed down ‘debates’ which are little more than exchanges of insults and slogans. Ever felt like you are living in a comic?

We live in a world of instant communication – stuff that is happening in our postcode and two continents away clamours equally for our attention. Our constantly pinging smart phones are the neurons of a planetary brain. Sarah at number seven needs some compost. President Trump wants to shut down the US Department of Education.

Reality is too complicated – there are too many permutations for the human brain to compute. Is it really so surprising that we have adopted a simplistic Marvel comics view of the world, which does not allow for character for moral nuance. Like the world portrayed in those comics, politics are blue and red, black and white, more than they ever have been. It wasn’t supposed to be like this, was it?

Is it a coincidence that both Marvel and DC comics were born in the United States at the same time as the rise of European fascism? It was an era in which simple answers were being sought and visual symbols and colours loomed large. Now, in the era of the logotype and social media, the process is magnified. Politics are brands, visual and evanscent media have primacy over the written and the reflective. Even words are being generated by machines.

The digital revolution that has leapt into our pockets is ushering in the end of history. Now there is only now. American political commentator, Francis Fukuyama, argued that history ended in 1990 with the dissolution of the Soviet Union. He believed that this would usher in the “universalization of Western liberal democracy as the final form of human government”. He was trebly wrong – not only in when and how history would end, but in what would follow it. It's not looking like liberal democracy but fascism.

Victors write history

It is the victors who write history. Enabled by the internet, victors can simply declare themselves as such, either because they own a means of global communication, or they control it through the sheer reach and volume of the content which they and their followers generate.

Thus an almost successful insurrectionist becomes a president; a sexual predator declares himself to be a follower of Christ – an unrepentant one – and attracts even more followers. As far as we can tell, tousle-haired Russell Brand with his leather pants and his rococo vocabulary, admits to no sin. The priapic Jesus lookalike is merely the victim of a conspiracy, cooked up by the boring ‘legacy media’ to destroy the cult of Russell, just as it’s trying to close down anti-vaxxers and people who believe that the world began 6,000 years ago and that carbon dating is fake.

Hitler’s PR guy, Josef Goebbels, is whispering his poison into our ear buds, while Trump, following his blitzkrieg of the once sacred institutions of American democracy, bellows his me-centred discourse from a non-existent balcony mocked up for YouTube, with a dubbed on cheer track.

We all saw and heard what he did – he tried to rustle up missing votes from a state official who bravely stood his ground  – and he recorded himself doing it! What do you do with that and with the proud boy uprising? You can’t change them or argue that they didn’t matter (unless you are morally reprehensible or an idiot). To preserve your mental equilibrium, you pretend that they didn’t happen, or you normalise them, to blend in with a new reality. Or both.

You welcome the guy to the Whitehouse and he pretends to be nice, not a brutal street thug. A voice inside you says that, if you don’t do that, you risk being grabbed on the street one day and beaten with billy clubs.

Fukuyama is weeping

Fukuyama must be weeping. The 1930s are only an eye blink away. We had democracy for a few decades. Now we are back to the jack boot and superheroes and villiains in tights – the triumph of brutal ignorance. Trump is set to make America stupid, not great – a country built in his own image.

They say that crowds have wisdom. It’s sometimes true. We in are living in a geopolitical framework dominated by gangsters who have subverted democratic processes, or who operate outside them. Two of them need to be in office to avoid being locked up in prison.

One of them is an absurd looking orange-faced man with stretchy sports clothing struggling to contain his ample frame and a wife who looks as if she is made from plastic. This guy, see, he can video call the other leaders and they can sort out the world – carving it up between them, like gangsters in prohibition-era Chicago. In other words, in a world of bullies, we need the biggest bully.

The things is, in a Marvelised universe, this scenario has a logic and even a depressing appeal. Faced by Trump and an industrial assault on middle American opinion from Russian bot farms, the Democrats could not find an equally potent leader and a credible story to take on the Donald, the polyester horror.

Story is everything. A depressing conclusion would be that being nice, like Joe and Kamala, just doesn’t cut it these days. A less depressing one would be that an anti-Trump could have won the 2024 election, or could be found in time for the next one – a man or woman leading a US crusade for pluralism, tolerance and democracy – the founding values of the US – a titan at the negotiating table with a natural feel for the peasant brutality of Stalin’s successors, Vladimir Putin and Kim Jong Un.

In previous decades, before swamp politics became the norm, this person could have been a Republican. They would be at vanguard of a high tech, world-leading assault on global warming. They would be gracious and cultured, and they would know the right cutlery to use at Buckingham Palace and how to behave next to a gracious monarch. Surely Marvel could imagine something like that into being? We have to hope so.





 

Hooray for the ‘nanny state’

Despite a barrage of criticism from the right wing commentariat, the Government, wishes for us to smoke and drink less, to adopt better diets and to live in more secure, healthier homes. 

A jolly good thing too, says Will Hatchett! But is there enough public infrastructure left in the UK to help make a difference?

With optimism thin on the ground, it’s no wonder people are excited about Oasis reforming. Anyone who is now in their late 30s, or older, will remember the last time that an old, tired government in the UK was replaced overnight in a seismic demographic, cultural and political shift. 

Tony Blair’s smile when he arrived in Number 10 matched the bright colours and catchy, patriotic jingles of Britpop. For a while, he basked in the radiance of Cool Britannia. It was a great time to work in the environmental health discipline of local government, because the Blair government refreshed policy areas that had withered from neglect in the sterile, market-ruled politics of the previous two decades.

New Labour promised upstream, generously-funded health intervention. It appointed the UK’s first public health minister, Tessa Jowell. It created a Health Development Agency and a health-focused Food Standards Agency, and turned its sights on the deadly triad of smoking, poor diet and alcohol, in a programme of ‘lifestyle politics’.

Labour’s radical approach to health was vigorously opposed by right-wing commentators. Their views reflected those of a famous editorial in the Times, opposing the 1848 Public Health Act. It stated: ‘We prefer to take our chance with cholera than be bullied into health. There is nothing a man hates so much as being cleansed against his will, or having his floors swept, his walls whitewashed, his pet dung heaps cleared away, or his thatch forced to give way to slate, all at thecommand of a sort of sanitary bombaliff.’

These anti-health campaigners, often allies of the tobacco industry, adopted a term that had been used by Margaret Thatcher, to lampoon measures designed to level up the life chances of the least well off, i.e. the non-rich, ‘the nanny state’.

Well, the nanny state is back, or so The Daily Telegraph and Daily Mail would have us believe. It’s the latest example of the UK’s traditional oscillation, in government, between interventionism and libertarianism – Labour and Conservative. 

We are unhealthier 

The statistics on health have worsened since 1997, when New Labour took office. Life expectancy is no longer increasing; there is an epidemic of child and adult obesity linked to junk food consumption and lack of exercise. Housing in the UK kills old people in the winter because it’s too cold. A child in a housing association property in Rochdale died in 2020 because his house was infested with mould. 

The causes of these ‘crises’ are entitrely avoidable. As a society, we could eat better food, exercise more, smoke and drink less and ensure safer and more affordable housing – of course we could. These lifestyle changes would save money for the state on health interventions in our lives.

Keir Starmer, with his subsidised spectacles and Taylor Swift tickets, is no Tony Blair. The Oasis brothers won’t be dropping into Downing Street any time soon. But his government has re-occupied the interventionist territory of Tony Blair and Gordon Brown. On housing, Labour’s Renters’ Rights Bill promises to ban no-fault evictions and to improve private rented housing. Health-wise, tobacco is, again, public health enemy number one.

A proposal to outlaw smoking in pub gardens has the Mail and Telegraph boiling with indignation. And nanny has confiscated the keys to the tuckshop: a pre-watershed ban on TV advertising for junk food is proposed from next October, alongside banning the sale of high-caffeine energy drinks for under-16s. Disposable vapes are also in Labour’s sights. 

Anticipating a second term, more strategically, Labour has indicated that NHS reform should include structural change aligning more funding to upstream interventions designed to prevent people from becoming sick. 

Yes, we have been here before. Remember the Acheson report of 1998 on tackling the determinants of health? Sadly by its second term in 2001, New Labour had lost momentum on shifting the focus of health funding towards tackling the social and environmental determinants of ill-health. It reverted to what all governments do – pouring more money into the leaky bucket of the NHS while holes are banged in with six-inch nails.   

Post-Grenfell landscape 

The landscape has changed since New Labour. Since the crash of 2008, politics have been all about crisis and firefighting. The Food Standards Agency, set up in 2000, made a strong start on promoting healthy eating and reigning in ‘big food’. But it was soon tamed and ‘de-politicised’. Now it’s a managerialist body. The Conservatives removed the NHS’s public health function in the privatisation-friendly Health and Social Care Act of 2012 and failed to transfer budget savings to local government.

One of the casualties of the Covid pandemic was Public Health England, a flagbearer for ‘lifestyle politics’. Set up to replace it, the UK Health Security Agency has a microbiological focus, and the Office for Health Improvement and Disparities is an invisible body that gathers statistics. Civil servants prefer public health to be passive, not active.

However, the Grenfell Fire of 2017 was a wake-up call. It showed us that maniacal, ideologically driven deregulation kills people.

Housing is political. Food is political, Smoking, drinking and vaping are political. Environmental health practitioners (EHPs) who work for local government ensuring safe food and workplaces, clean air and healthy rented housing, are not political, nor should they be – they are public servants. But their skill-sets, for example, in coercing food businesses and pub owners into behaviour that is in the public interest and in reigning in bad landlords through a well-tested blend of education and coercion, have a century-long record of effectiveness.

In the 1990s and early 2000s, the historically well-resourced environmental health services of local councils became active in areas as diverse as tackling food deserts and improving sexual health. Two chief medical officers of the period – the senior health officials working in government – Sir Donald Acheson and Sir Keneth Calman, were the last CMOs to view local government professionals as part of the public health workforce. There's not much left now of the civil society that still existed when the Coalition took office in 2010.

It’s hard to remember now but, in the Britpop era, EHPs visited shopping centres and housing estates dressed as vegetables or pieces of fruit – or giant cigarettes. They were active champions of the smoke-free laws of 2007 and played a major role in their enforcement. 

The fact that EHPs, with their specific and well-honed skills in contact tracing for infectious illness, were initially ignored and sidelined during the Covid pandemic is a testament to our dysfunctional political system, the short memories of politicians and the unerring ability of the civil service to douse down innovation and revert to  bean counting. 

Other worlds are possible 

Dare I say this: the time has come for the UK to revisit the almost forgotten Black, Acheson and Marmot reports and to address the causes of ill health – poor national diet, insecure over-expensive housing and generally unhealthy lifestyles. EHPs can and should be part of changing this unhealthy status quo. They have been before, and although their teams have been reduced to skeleton status by cuts to frontline services, they could be again. The motto of the Chartered Institute of Environmental Health, Amicus Humani Generis, translates as ‘Friend of the Human Race’.  

The Punch and Judy politics of the political tribes, with their non-evidential basis and simplistic, headline-favouring slogans, are entertaining and make good copy. That’s one reason we still have them. But they are ineffectual. A downstream treatment-after-the-damage-is-done model dominates health and social care as it inevitably will under a political system that is based on five-year electoral cycles and ministerial musical chairs.

Such a system will always be defended by the well-paid flag-wavers of libertarianism and its corollaries, lower taxes and ‘small government’. How dare a ruling party think that it might be in office for more than five years – long enough to make a difference – and that things could be done differently! More nails! More buckets! 

In truth, the noisy, wannabe influencers of GB News and newspapers owned by billionaire offshore-based press barons, are largely talking to each other in print and online, while claiming that they are denied a voice by mere ‘experts’ and the ‘legacy media’. 

EHPs are, or should be, the primary health champions within local government. In many cases, directors of public health, at several tiers of seniority above them, are barely aware of their existence. I’m not calling for EHPs to become more involved in political debate – those in managerial roles, quite rightly, are not allowed to. I’d just like them to be given their rightful role in fixing broken Britain (and Northern Ireland). It can happen. As the situationists used to say, ‘other worlds are possible’.

 

Throwaway fire sticks – a disposable menace

 

The disposable vapes is the most environmentally damaging and dangerous consumer product ever sold. 

This is the contention of director of UK-based recycling NGO, Material Focus, Scott Butler.

He explains the reason: “Let’s take some of the most valuable materials on the planet that we really need for a greener future and put them in a cheap to buy addictive form of FastTech, sell them in their 100s of millions, market them as disposable and do next to nothing to meet our legal obligations to offer and finance the takeback and recycling of them.” 

‘FastTech’ refers to everyday small electrical items, including headphones, cables, decorative lights and single-use vapes. They are cheap and have a short lifespan, so that they are seen as ‘disposable’.

The last government proposed legislation to ban the sale of disposable vapes and even proposed a date, April 2025. Then the election came.

Labour has been reported as being in favour of this measure, following a long and growing list of countries, including France and Belgium, and its implementation date. It is supported by the British Medical Association, which argues that disposable vape are displayed and marketed in a way that is appealing to children and teenagers – undesirable because their health effects are not known.

A brief history of e-smoking

Take the evidence of your local corner shop – the places where people buy fags and booze, often at antisocial hours. This invaluable and necessary part of the UK retail fabric has changed, a lot, over the past decade. You probably haven’t noticed because the process has been incremental.

The booze shelves are still well stocked but on shelves that once dispensed cigarettes you’ll now see row upon row disposable vapes in attractive little boxes available, legally, to over-18s. Their liquids contain throat soothing vegetable glycerine and a plethora of flavours, including mint, bubble gum, mango, crème brûlée or even old-fashioned tobacco.  

E-cigarettes arrived in the UK from China in mid-2000s. The product arrived to fill a niche that was being created by tobacco control. The product took off rapidly as adult smoking rates declined – around a quarter of UK adults smoked then, today it’s 13%.

The percentage of a vapers, 11% of adults, will soon catch up with the declining smokers. According to pro-health charity ASH almost half of them also smoke and the same proportion have been vaping for more than three years.

Remember the early-2000s? Environmental health officers (EHOs) working for local authorities lobbied strongly for smoking control, against overwhelming opposition from the nicotine addicted and their powerful allies in big tobacco and retailing.

They were successful. Smoking was prohibited in virtually all enclosed workplaces and public places in 2007. The tobacco lobby had predicted mass civil disobedience. It didn’t happen. Most smokers, it transpired, wanted to quit. The ban was almost immediately accepted and normalised. EHOs rarely needed to enforce the rules. The restrictions, which had been portrayed as an outrageous infringement of civil liberties by the majority of newspapers, were self-enforcing.

E-cigarettes had a strong and totally valid argument on their side. They supplied a hit of nicotine without tar. Thus, they helped smokers to prolong their lives. On the one hand, their image was that of pharmaceutical products, like aspirins and corn plasters, on the other, they were rapidly adopted as accessories by hipsters. They had a DIY feel. It was an innocent and novel seeming fruit-flavoured rebellion, propelled on every high street by what would soon be called vape shops. 

The disposable fire stick

The vaping market has changed since then and so has its implications for the environment and health. The reason? Disposable vapes, containing lithium-ion batteries, have been widely available in the UK for the past four years. They have come to dominate the vaping market, in one of the fastest moving consumer and retail trends of recent years.

In nicotine terms, one disposable vape is equivalent to 20 cigarettes, at a quarter of the price.

Young people are not vaping to give up smoking, but instead of smoking, and, in some case, are becoming nicotine addicted and damaging their lungs. This also applies to adult vapers. Vaping, increasingly, is no longer a way of stopping smoking, but a thing in itself. Not all vape additives are innocuous and medical science has not yet established what long-term vaping does to our lungs, so, at best, it is a gamble with human health.

I do not think that vaping should banned per se, merely regulated through effectively enforced retail and environmental legislation, and taxation. I believe that vapes should still be available to adults who want to stop smoking, on prescription.

The retail sale of disposable vapes certainly should be prohibited. China, the world's largest e-cigarette manufacturer, has outlawed the selling of fruit-flavoured vapes to children.

Menace of thrown away vapes 

If the medical case that would discourage e-smoking is not yet fully proven, the environmental arguments for banning disposable vapes are overwhelming. According to research from Material Focus, in 2023, five million of them were being casually discarded each week in the UK a fourfold increase from the previous year. Thrown away vapes are a fire hazard, because of their batteries, and a shocking waste of resources.

Since 2023, says the charity, vape producers and retailers have not increased their compliance with environmental regulations. Sales of disposable single-use vapes are now at least 360 million per year in the UK and growing.

For all the disposable single-use vapes sold in the UK this would be equivalent to providing the lithium in the batteries for over 6,700 electric vehicles in the UK.  Over 90% of vape producers and 90% retailers, says the charity, are not fulfilling their statutory obligations to provide and pay for recycling for vapes – there are supposed to be takeback bins in the shops where they are sold. Have you ever seen one?

Vape drop off points, it says, were available in 33% of 57 specialist vape retailers survey. However, high street brands and convenience stores provided very little or zero recycling drop-off points. It warns that, without immediate action on retailer takeback and recycling at least a quarter of a billion single-use vapes will be thrown away between now and the possible imposition of a ban next year.

Anticipating the ban, manufacturers have adapted vape design, offering products with a USB slot for battery re-charging. Elfbar and Lost Mary, sister brands responsible for than half of the UK’s disposable vape sales, have launched reusable versions. 

Tough battle ahead

Even if a ban on selling disposable vapes is implemented in the UK, in the face of familiar claims in the newspapers that fervently apposed indoor smoking restrictions, invoking the weird spectre of a ‘nanny state’, it won’t offer a magic solution to the environmental problem. Butler says: “There might be a slight change, because, in theory, there will be fewer waste batteries, but there will still be issues with littering for the pod element of the devices. 

He adds: “The devices will still be sold for a little as £5. This will give the message, reinforced now locked-in consumer behaviour that they are a cheap, throwaway item.” 

An Elfbar spokesperson said: “We refute any suggestion that we are trying to circumvent proposed restrictions. We have worked with producer compliance schemes to ensure the costs of recycling vapes are met, and this is evolving due to the new waste electrical equipment directive requirements, which we support.”

EHOs played an essential role in making the case for and bringing about historic UK-wide tobacco legislation in 2007 and making it work. It was milestone in UK public health legislation, akin to the Clean Air Act of 1956. Vaping should not be prohibited across the board. but I think that we need to put the brakes on. The forces and interest groups in its favour are powerful and have deep pockets. It will be a tough battle.

Festival food safety

Food safety expert Dr Lisa Ackerley shared some thoughts with Will Hatchett on the factors that increase the risk of food poisoning outbreaks at outdoor events and how organisers and regulators can minimise them.

If one had to design an environment likely to cause a food poisoning outbreak, a badly organised outdoor music food festival, lacking adequate food hygiene controls, would tick many boxes. 

This summer’s Download Festival, which brought 75,000 rock and metal fans to Donnington Park in Leicestershire in June, appears to have been a well-run event. Organisers Live Nation pre-vetted food sellers and required safety inspections before and throughout the festival. EHOs from North West Leicestershire District Council (NWLDC) carried out onsite safety checks, with revisits to ensure compliance. Two food vendors were closed by the organisers over the weekend. Despite these measures, a food poisoning outbreak struck the festival.

Vomiting and severe stomach cramps were reported. Performer Sean Smith of Raiders was hospitalised and received intravenous fluids. A spokesperson for NWLDC said that there had been four calls from festival attendees and that six people became unwell at the weekend. However, online, there are claims that up to 500 people were affected.

Theories have circulated on social media but, so far, the cause of the outbreak has not been identified. Paul Sanders, head of community services at NWLDC, said: “We are aware of reports of people feeling unwell and will continue to investigate. However, we have not received any confirmed cases of food poisoning linked to the festival to date.”

Multiple variables

Given the multiple variables involved in 75,000 people setting up a town under canvas in a field and buying food from 140 vendors, it’s possible that the cause won’t be found – it wasn’t for the food poisoning outbreak at the Reading Festival in 2022. Food poisoning in the UK is hugely under-reported. For every case of intestinal infectious disease officially notified, it’s estimated that there are 147 cases in the community.

Independent Chartered Environmental Health Practitioner Dr Lisa Ackerley notes: “One thing we need to consider is that symptoms of food poisoning don’t necessarily mean it was contaminated food that was the problem. Festivals can be mud baths in fields previously used for livestock, with poor sanitation facilities helping infections such as norovirus to run rife.”

Ackerley has worked for local authorities, central government and the private sector. She has appeared as an on-screen expert in TV series including the BBC’s Watchdog, Rogue Restaurants, The Secret Tourist and Holiday Hit Squad. She knows about festival food safety, both from the point of view of an enforcement officer and a consultant.

Vendors can cut corners

She observes, from firsthand experience, that vendors are pushing out food at great pressure, serving long queues. That can lead to corners being cut, which can manifest in cross-contamination and undercooked food being served. The guests are having a great time and they are hungry. Their guard is down. They may not be as aware of an undercooked burger or raw chicken as much as they would be in another setting.

In addition: “We’ve got a load of people in very close proximity, often using very insanitary toilets, often with little hand-washing going on and restricted access to showers, soap and water. Potentially, it’s a perfect storm.”

UK weather is not optimum – hot sun beating down on the metal vans where food is prepared, displayed and served, and the tents in which it’s eaten, with wind blowing dust around, rain turning fields into quagmires of potentially contaminated mud. We’ve all seen films of smiling hippies sliding through the mud at Woodstock and Glastonbury. This year’s Download, marked by fierce thunderstorms, was re-christened Downpour.

Two potential festival risks, Ackerley notes, are contracting E. coli from the ground and norovirus from people. But campylobacter, salmonella, cryptosporidiosis and giardia are also pathogens that must occupy the attention of organisers and enforcers – each with an optimum route of transmission and its own stratagem for surviving in water, food and the environment and passing illness from person to person.

The good news is pathogens, vectors and risks are well known, all of the normal food safety and environmental health laws apply, and there are paramedics on site. Risks to the public can be significantly reduced.

Pointers for festival safety

1. What was the land used for before the festival? Has livestock been on the land within the last year? The science is not settled, but one study found that E. coli O157 bacteria can survive on grass pasture for at least five months.nt

2. Norovirus, whose symptoms include projectile vomiting, is easily spread when people are in close proximity. Good hand-washing facilities with water and soap are vital. Hand basins and toilets need to be regularly and thoroughly cleaned. Hand gels may not be effective against norovirus.

Ideally, pre-festival instructions would tell people with symptoms of diarrhoea or sickness not to attend, or what to do if they are ill.

3. Water supplies must be potable. How is water collected? Is the transmission of water into containers clean and hygienic? If the site has a private supply, have risk assessment and sampling recently been carried out? Could rain cause contamination?

4. Food safety checks should be carried out before and during the event. What are the vendors like when they have a long queue and are under pressure? Are they cooking to temperature? Site organisers are able to go beyond the law and require vendors to have potable water, wash basins, disinfectants and thermometers before being allowed on site.

5. All legal allergy requirements apply. Vendors must be able to provide information about the 14 allergens.

Nationwide Caterers Association (NCASS)
Mobile catering and food safety at festivals:
 

https://www.ncass.org.uk/news/mobile-catering-and-food-safety-at-festivals/

Pick-up truck populism

The Prime Video series, Clarkson’s Farm, has made Diddly Squat farm in Oxfordshire world famous. It’s a great show, which sheds welcome light on land-use, farming and food policy in the tradition of William Cobbett. 

But Jeremy Clarkson's visceral hatred of local authorities as they regulate planning and food safety is dangerous version of personal freedom.

Jeremy Clarkson makes excellent TV programmes. The former Top Gear presenter has a rare ability to reach through the screen and grab his viewers' attention. 

His latest Prime Video show, Clarkson’s Farm, which has just finished its third series, has brought the attention of very large audience – up to five million people a week – to a topic normally destined for 5.45 in the morning on Radio 4, or the cocoa-assisted Sunday evening rural idyll slot on BBC 1. It’s also big in China. The Clarkson brand travels.

The show isn’t about food safety – obviously – but food is at its very centre – where and how it is made and the societal, legal and cultural structures that determine the nature of farming. However, Clarkson’s Farm isn’t a branch of public service broadcasting, or the lush backdrop to a former Blue Peter presenter put out to pasture. 

Populated by well-defined and likeable characters, it’s down and dirty visceral TV – up at four o’clock in the morning to milk the cows, down in the straw with a heavily pregnant, Oxford Sandy and Black sow, heaving bags of decomposing mushroom compost onto a trailer, scything through stinging nettles.

Topic and format work perfectly. It’s a reality we (urban dwellers) don’t normally see, mediated by Clarkson’s everyman persona, nurtured for years on Top Gear – bumbling, amateurish, somewhat work averse, loving gadgets and dangerously immune to instruction manuals. This is in a real world that matters. We all go to the countryside, or live in it, we all eat. 

Jeopardy and resolution

In reality, Clarkson has the financial means to do whatever he wants. He purchased 1,000 acres of prime Cotswolds land, in an Area of Outstanding Natural Beauty in 2008 and began farming it, full-time, in 2020, alongside a lucrative reality TV deal.

Surprise, surprise, here’s the spin. Clarkson – middle England’s Mr Petrol Head – is now ‘into’ the environment. Over three series, he re-wilds a large portion of the farm with wildflower meadows and native woodland, dams a stream to create a trout pond, tries regenerative farming – a two-crop system of beans and cereal – and makes forays into jam, nettle soup and mushroom production, in nearly always doomed attempts to sure up Didley Squat Farm’s meagre income.

Series three of Clarkson’s Farm was filmed in 2022, so this is serious stuff. War racked up the prices of fertiliser and diesel and the weather was a peculiar and, for farming, catastrophic, mixture of torrential rain and extreme heat and dryness. 

TV shows love jeopardy and resolution. We, the audience, want Clarkson, his partner Lisa, his go-to Chipping Norton rustics, Kaleb (yes, that’s his real name) and Gerald Cooper (who speaks in an incomprehensible Oxfordshire dialect), and his dry and shrewd agronomic adviser, Charlie Ireland, to succeed against the odds. How could we not want to? 

This man calls milk ‘cow juice’ and mushrooms ‘space penises’. We see him fail to harvest blackberries with a Henry vacuum cleaner, spend money on a bramble clearing gadget that does not work (he decides to use goats instead), fail as a wasabi farmer and get stung, literally, trying to turn a profit from selling nettle soup in his shop. When Clarkson says, ‘I’ve had an idea’, you know that it’s going to go wrong. One of his ideas works – very well. It’s a in-piggery crash barrier, designed to stop sows from rolling on and crushing their baby pigs. It’s called ‘Clarkson’s ring’.

Rural Rides re-visited

The show is a re-tread of the utopian and nostalgic idea, promoted in William Cobbett’s 1830 book, Rural Rides, of the self-sufficient ‘yeoman farmer’. That book looked to the past, before the enclosures of common land, as a golden age. Clarkson’s farm looks forward to a re-wilded, regenerative, carbon negative golden age. 

We know that Clarkson loves his over-powered Lamborghini tractor a bit too much. We know that his Barber jacketed neighbours mine bitcoin for a living in the city, and that the wealthy Cotswolds have, for the most part, become a rustic theme park – a Marie Antoinette-style fantasy of rural life. We also know that subsidy driven, over-intensive arable farming has degraded English soil and led to biodiversity collapse, while making fortunes for the wheat barons of the arable heartlands – or it did.

Didley Squat’s timely and topical experiment in green farming – ‘farming the unfarmed’, as Clarkson calls it, is a reiteration of Cobbett’s Cottage Economy (1821). The book, still in print, is both a pollical tract and a practical manual. It contains Information ‘Relative to the Brewing of Beer, Making of Bread, Keeping of Cows, Pigs, Bees, Ewes, Goats, Poultry and ... of the Affairs of a Labourer's Family’.

Cottage Economy comes wrapped in a flag of freedom – what if I could live self-sufficiently, as a ‘yeoman’, free from the tyranny of alienating employment, aristocrats and pollical and economic control? This ‘what if’ is embedded in the collective psyche of the over-industrialised English, with their historically dreadful food and penchant for bottled condiments to make it edible.  

Three-mile tailback

It’s in all of us who are not aristocrats – even in wealthy Jeremy Clarkson. His Didley Squat Farm – with its three-mile tailbacks of visiting car-encased Top Gear fans, newly enthusiastic about eco farming, is emblematic of an England that we would like to live in – one with flowers and bees (Clarkson sub-lets to a Ukrainian bee keeper in one of his few successful ventures), beer (he has a sideline in Hawkstone Premium Lager), home-made jam and a pig being nicely fattened up for Christmas, with household scraps.

It's the freedom part of the dream that is problematic. For all his radical credentials, William Cobbett, like Clarkson, was deeply socially Conservative. A US version of Clarkson might be a redneck in pick-up truck, denying the legitimacy of federal government to raise taxes and to prevent massacres with assault rifles.

Listen, England is a small country and we need to be nice to each other, right? The Didley Squat brand, sadly, has traces of toxicity. Let’s unpack freedom from planning laws. The farm’s local authority, West Oxfordshire Council is portrayed, throughout each series, as a monstrous Kafkaesque bureaucracy, solely devoted to crushing personal initiative and all pleasure – the enemy.

You see, the council dared to object to Clarkson converting his lambing barn into a highly successful restaurant, without planning permission. That’s when the traffic started backing up to the local village, Chadlington, because of Top Gear tourism, much to local people’s annoyance. Planning may be boring and, yes, bureaucratic but it is still run by democratically elected local government. We need planning, so that homeless people are not forced to live in tiny units in poorly converted office blocks, under ‘permitted development’, exempt from public scrutiny and controls. 

Truly painful

Freedom from food safety and trading standards laws? Er no, don’t think so, Jeremy. It must be truly painful for an EHO to watch Clarkson’s Farm, especially the kind who believes in coaxing the wilfully ignorant into compliance, rather than serving notices. OK, it’s a bit of an act – Clarkson stumbling over the clumsy, non-phonetic acronym Haccp (thanks NASA), or thinking that CCP stands the Chinese Communist Party, rather than critical control point. But isn’t that a bit worrying for a food business operator? Clostridium botulinum is a thing, Jeremy. It kills people. 

It’s a good job that his proposed mushroom-based product line, powdered lion’s main, was subject to a bacterial and water activity test, in an ACAS-accredited lab. The sample was contaminated, and it failed. Actually, Clarkson had been sceptical from the beginning, viewing the product as a new age fad for the over-leisured Chipping Nortonites.

To be fair, Didley Squat’s emporium, now the most famous farm shop in the UK, if not the world, is fully Haccp-complaint (live with it, Clarkson) and it suffers the tyranny of a level five food hygiene rating score. Clarkson’s colleague in the show, his adviser, Charlie, is a shrewd and intelligent man, moderating Clarkson’s bluffness and impatience and providing a welcome balance.

He knows what a Haccp is and that you have to have one. He speaks the language of council planers and knows how to navigate sensibly their rules and conditions, without dumping manure on the town hall steps, or using a verbal blunderbuss. ‘Cheerful Charlie’ provides the show with much-needed balance.

Jeremy Clarkson is a powerful and influential man. That gives him responsibilities. A new law was introduced as a direct result of the show – ‘Clarkson’s clause’. It extends farmers’ permitted development rights, outside Area of Outstanding Natural Beauty, to convert farm building to other uses, such as homes and shops – probably a quite sensible idea, but we’ll see. 

Few challenges 

To millions of people, Clarkson, rightly or wrongly, is a folk hero, akin to a rich Robin Hood – an everyman (not an everywoman). Here, the distorting, amplifying and dumbing down effect of social media comes into effect. Look at any thread beneath a review or story about the show – typical comment “you are helping everyone, fighting the government and getting raked over the coals for it. The UK’s Trump”.  

There are few, if any, challenges to his council-hating orthodoxy. This gives Clarkson a fast track to politicians, like Rishi Sunak and Michael Gove, who wish to demonstrate their deep understanding of what the man on the Chipping Norton omnibus is thinking (whoops, there isn’t one – privatisation). 

Now look at this comment on Clarkson’s Farm, from a very reasonable, and nice, West Oxfordshire District councillor, Dean Temple, who, following series three, felt obliged to resign. He said: "I was sitting there watching it as a fan, laughing away, thinking, ‘This is brilliant, this is fantastic, this is... ah, sugar'. All of a sudden I was getting calls, death threats from all over the world because, apparently, I’m a nasty individual." 

You have created something culturally important, Clarkson, like Orwell did, with Animal Farm, an allegory for the state. You understand global warming and you are advocating farming and landscape policies, including diversification, with which most reasonable people agree. Your lager is probably quite good (I’ve never tried it), unlike your cider (which has a tendency to explode, because it’s still fermenting). Personally, I would steer clear of your powdered lion’s mane until it’s proved to be safe – not that you are selling it. 

Your council is trying to be nice to you. Its online statement says: “As a planning authority, we have a responsibility to make sure that national and local planning laws and policies are followed correctly by everyone. We have worked with the owners and planning agents of Diddly Squat Farm for many years, offering to help the business with planning applications and supporting them to diversify and make changes on the site. 

“The work [the farm] is doing to highlight the wider challenges faced by farmers is commendable. We will continue to treat Diddly Squat Farm fairly and we will be happy to work [with it] on any future plans. Our door has always been open and will remain open should they choose to work with us.” 

Underneath the statement are two hundred and ninety-five negative comments, with not a single dissenting voice: “As a Council you are a great example of what's wrong with this country...” “It is clear that you DO NOT help local farmers.” West Oxfordshire District Council, killing the countryside one farm at a time.” 

That says a lot about councils’ failure to get messages across about positive service delivery. One of problems of environment health is that, if it’s done well, it’s invisible. All the more reason to point out its successes. 

Will Hatchett has been a journalist since 1986 He was editor of Environmental Health News from 1998 until 2018 and his written for many publications including The Guardian and The Observer. The views expressed here are purely his own.




 

Hidden perils of private water supplies

A change of guidance on the regulations means that the number of private water supplies requiring risk assessment and sampling by local authorities has significantly increased, at a time when resources are thinly stretched.

Private water supplies come off and on the radar of regulatory attention. Ensuring their safety is one of those public health duties that can either be very important or not important at all, depending on location.

Doing the work well requires detailed legislative and practical knowledge of a niche but highly important area. Enforcement is assisted by persistent and tactful people skills. These also, sadly, are becoming less common than they were, with fewer environmental health staff treading familiar beats and engaging in face-to-face contact.

There’s another issue. Private water legislation assumes that if there is a problem, a notice must and will be served – no ifs. These days, most council enforcement policies favour advisory escalation, with notices served only as a last resort. It can be hard to reconcile these apparently conflicting enforcement cultures – ‘old school’ versus ‘softly softy’. But are they actually conflicting? Discuss. Surely, smart enforcement can combine both?

David Clapham is a UK environmental health officer and an expert in this area, who has written a standard reference work on the topic. He has specialised in private water supplies for 30 years, 13 of them as a consultant. Some users, he explains, are large – a stately home, a hospital, a factory, a theme park. Some are odd, like a Napoleonic era fort in the Solent, or a vinegar manufacturer in the west midlands. Most are small – down to a single dwelling.

Clapham has tramped down countless muddy lanes to inspect challengingly remote supplies. Very common is the farmer or cottage owner who insists: “My family has been drinking this water for generations and no-one has ever been ill.” How do you deal with that? It’s the private water supply version of the frustrating ‘hygiene hypothesis’ that every EHO occasionally comes up against: “Bugs are good for you”.

First comes a deep sigh, then a series of appropriately articulated microbiological, chemical, practical and historical arguments. For example, you might point out that in Walkerton, in Canada, in 2000, 2,000 people became ill and seven died, including a two-year-old child, when a communal supply became contaminated with E. coli 0157, from manure on farmland. “Yes,” comes the reply, “but my grandmother drank this water all her life …”

Uneven distribution

In terms of the totality of supplies, off-grid water is uncommon and unevenly distrusted, mainly in rural areas. It serves one percent of the English population, about twice that in Scotland. The most common supplies are boreholes, followed by springs. For springs, biological contamination from pastureland run-off poses the greatest risk, for boreholes it’s chemicals from the rocks that surface water has percolated through – fortunately often a long way.

For small users, in most cases, treatment involving filtration to precipitate minerals, oxygenation and disinfection using UV lamps, costing a few hundred pounds, can make water safe. Reverse osmosis filters, now affordable for small applications with particularly difficult problems, are also available. But, stresses Clapham, who trains EHOs in this area, source, pathway and receptor can work in myriad combinations – no two supplies are exactly the same.

Private water supplies, previously lightly regulated, first came onto the antennae of EHOs with regulations attached to Water industy Act 1991. The new duties ignited a career-long passion for Clapham and were the subject of his MSc research dissertation at Leeds University.

In 2009, new private water regulations augmented sampling with risk assessment. But sampling, he explains, which is cheaper than risk assessment, only goes so far as a public health tool, because, for springs, the level of contamination detected tends to correlate directly to rainfall. A supply can be unsafe one day and safe a few days later.

Legally, all private water supplies must be risk assessed every five years. Sampling is additionally required on a one to five-year cycle, depending on whether the water is used by the public or to produce food, the size of supply and its consequent health implications. In some cases, this area of EHOs work is not being done. Drinking Water Inspectorate (DWI) returns show that, in 2022, in England, only about 25% of smaller domestic private supplies had an in-date risk assessment. For large, commercial users it was 47%. In total, 13,000 supplies required a risk assessment. 

Changes to Regulation 8

Regulation 8 of the new rules applied in 2009 added a new category – distributed supplies. This means that water that comes from a mains water supply is piped, normally without storage or treatment, to end users, for example on a caravan park or an industrial estate, who pay an intermediary other than a water company.
Environmental health services argued, justifiably, that the health risks in this scenario, are extremely low. As reflected by DWI statistics, they did not devote thousands of EHO hours to pursuing what they viewed as a theoretical low risk. In recognition, in April 2013, the guidance was significantly modified. One caravan park from now on would count as a single premises and thus not a Reg 8 supply at all. This significantly cut EHOs’ workloads and allowed them to concentrate on other work.

Here’s the significant news. Following legal advice received by civil servants at the DWI, from January, the 2013 Regulation 8 guidance has been removed and the situation now seems to be the same as it was in 2009. In some cases, this will be significant for already hard-pressed environmental health services. The re-interpretation has added a new dimension to an escalating problem and to a growing list of things that need to be done by fewer people. Meanwhile, because money is tight, training budgets have often been cut.

Clapham says: “If you think of seaside authorities, for example, they may have hundreds of campsites and permanent and semi-permanent caravan sites. All of a sudden, they have a great deal of work, when there isn’t a huge risk because, in most cases, it’s just re-distributed mains water, which is not exposed to contaminants, going down proper pipes, with no tanks and no extra treatment. But you can never be completely sure.”

Can you afford to take that risk? Clearly not. Clapham observes: “I say to colleagues, ‘if you’ve gone along and you’ve risk assessed or sampled a supply and it is contaminated with faecal material and you haven’t served a notice, and a child contracts E. coli and dies, you’ll need to yourself, do you bear some responsibility’?”

There’s more bad news. The guidance suggests that enforcing this area also requires knowledge of the similarly complex Water Fittings Regulations.

Don’t worry. You’ve got this

But don’t worry, whether you are a service manager or practitioner. There are at least four reasons why this situation is not as worrying as it may, at first sight, appear.

One – notices served regarding private water supplies that have been appealed against have always been upheld.
Two, risk assessment and sampling are chargeable and designed to be self-financing. There is no maximum charge in England. Typically, a risk assessment would cost in the region of £360.

Three. Private water suppliers could be sent a Section 85 Notice, under the Water Industry Act, requiring them to send information. It’s an old wrinkle. There is no appeal. If it’s ignored it’s an offence. This approach can often reveal who is legally responsible for the supply.

Four. It’s not rocket science. Training for those new to this area of work or for those who are already doing it but who need a refresher, is available. A few hours in the classroom or on-line and a few field visits is enough, in nearly all cases, to equip staff with the skills that they require to confidently risk assess supplies. To help equip EH services, RHE Global is running some training courses.


 

End time news

Tastes in fire and brimstone have changed little since the medieval era. With the countries of the Bible lands threatening to destroy each other, religious zealots are anxious to see divine signs in secular events – the ‘end time’ of their convoluted theologies.
 

Many are keen to identify, in these troubled times, signs of divine intervention. These doom merchants are tearing out handfuls of red meat from the Bible and flinging it around.

It’s an unedifying spectacle – a bunch of people scrambling to save their own asses, while they denounce other churches and denominations, whose members, they confidently predict, are on the road to Hell. 

They mainly draw their vocabulary – the Fiery Lake, the Lamb of God, the Wrath, the Antichrist, the Mark of the Beast, the Book of Life, and so on – from some endlessy chewed over Biblical passages. They particularly partial to the Olivet Discourse of Matthew 24-25, Revelation 4-22, Thessalonians 4 and parts of Jeremiah, Ezekiel and Daniel.

Christianity, Judaism and Islam all visualise versions of the of the end of the world, to maintain patriarchy and keep their adherents in line. Over the centuries, their intra-religious bickering has killed and maimed millions – not least in the Bible Lands.

The lesson of Lot 

Why can’t Jews and Christians follow the lesson of Lot, who is shown unfavourably in the Book of Genesis 13:11 selfishly grabbing the lush, fertile lands of the Jordon Valley from under Abraham’s nose. Why not drop vindictive dogma based on subjective textual interpretation and share life’s blessings? Be nice guys.

The Book of Revelation, which closes of the New Testament in a blood curdling finale, is a happy hunting ground for these Armageddon pedlars, who can identify a false prophet at the drop of the hat.

The imagery of Revelation, is suffused through western culture. We know the catch phrases. Most people don’t know the chronology, even if they have been to Sunday School, which focuses on tame and uncontroversial parables. Why would they?
The chronology goes as follows. After a low-key start, Revelation gets lively in chapter four, with opening of the seven seals (a seal is a scroll). This signals the beginning of the Tribulation. 

The seven seals 

The opening of the first seal (6:1) give us the four horsemen of the apocalypse – white, red, black and pale – the rider of the white one is sometimes identified as the Antichrist. That would be Pope Vincent, or Bill Gates. The sun turns black, the moon turns red, stars fall to earth (6:12). But this just an hors d’oeuvre.

When the seventh seal is opened, seven angels appear, and they blow on seven trumpets. See a pattern here? The first blast causes a hail made of fire and blood to burn up a third of the trees on the planet (8:17), the second turns a third of the sea into blood killing, everything that lives there and a third of all sailors – a bit arbitrary.=

When the fifth trumpet blows (9:1) Satan is given the key to the bottomless pit – a tactical manoeuvre on god’s part. The sky darkens and smoke and locusts issue from this fiery hole. Looking like armoured horses, with human faces and the sting of scorpions, the locusts torture the unrighteous for five months. Does God have anger issues? 

Armageddon outta here

With the sixth trumpet (9:13), God unleashes four wrathful angels who slaughter a third of the human race. He hasn’t finished yet. As a final gesture, he tips out seven bowls of wrath, which bring about seven plagues – festering sores, rivers and seas turned do blood, a blazing sun that shrivels flesh – more torture, on an industrial scale.

It’s the main event – Armageddon – rounded off by the biggest earthquake ever seen that reduces a city to ruins – it could be Jerusalem, Rome, or Babylon depending on your preference. As parting short, God rains down forty kilogram hailstones.

A new player appears and ends the Tribulation – a rider on a white horse, leading the armies of heaven (19: 11-16). ‘He treads the wine press of the fury of God’. He is the King of Kings. It’s the Second Coming! The tide is turning. Satan is ‘bound’ bringing about a thousand years of peace and righteousness begin (20:2). Righteous people who have died are resurrected.

 After a thousand years are up. Satan is released from Hell (20:7). He summons a force as numberless as the sand on the seashore. There is another one-sided bust-up. Satan is thrown into a lake of burning sulphur, where he will burn forever (20:10). Next, God, on his white throne, opens up the Book of Judgement on the living and the dead (20:11). A second resurrection occurs. Even those in Hell are given a chance (13). The Holy City, a New Jerusalem appears (21:1) in which the righteous will dwell forever. It’s the end of the end days. 

The crux of the matter

So, here’s the crucial point, theologically, for end of the world watchers. Have these events – the Tribulation, the seals, trumpets and bowls, Armageddon, the Second Coming, the Day of Judgement happened, are happening now or they yet to happen? Oceans of ink have been expended on these issues – a dismal swamp of exegesis. Over many centuries, proponents of theological turf wars have developed their own shorthand.

For ‘full preterists’ the events recounted in Revelation occurred in the past, including the Final Judgement. Far more common, for Protestant churches, is ‘partial preterism’. This is the vanilla option. Under this scenario, the nasty stuff has already happened – the violent retribution of Revelation from 4 to 19. It corresponds to the destruction of the Second Temple of Jerusalem in AD70 – thus, it was all the Jews’ fault. The nice stuff – the Second Coming and the Day of Judgement – haven’t happed yet. It’s just a matter of saying one’s prayers and waiting. Who knows for how long.

Then we have the full-colour futurists. Their creed is modern. It originated in the nineteenth century, took off like wildfire with the radio preaching of the 1920 and came to dominate US Protestantism in the 1970s, with the rise of Baptist and Presbyterian Churches, whose slick Bible thumping preachers dispensed old-fashioned fire and brimstone on TV. Their lapel-grabbing, no holds barred style travelled back across the pond to the UK, to the horror of the sherry sipping clerisy.

Futurists maintain that we are still awaiting the Tribulation or that we are in it – citing modern diseases and nuclear weapons as God’s signs. It’s the Apocalyptic, socially conservative religion of the red Republican states. Many adherents are ‘dispensationalist’. That is, they believe in the literal truth of the Bible.

Aerial event

They like the idea of rapture (Thessalonians 4) in which the resurrected and living faithful will mingle in the clouds in an ‘aerial event’. Their hell is not metaphorical but real and it is eternal. Key to their ‘dispensational premillennialism’ is a ‘pre-Tribulation rapture’.

That’s important to them. The rapture, deemed to be vulgar by Catholics and other Protestants, can happen at any time. Being pre-Tribulation means that those who have accepted Jesus into their lives – the bar for entry into their church is low – will be spared the plagues of boils, scorpion stings and angelic slaughter that will engulf the rest of us.

The Jews may not enjoy this free pass. But ultimately, they believe, the good ones, unlike Moslems and members of doctrinally unsound Protestant churches, will earn a place in heaven, after a bit of chastening punishment from the man upstairs.

Contradictory positions

Never accuse the Catholics of shying away from simultaneously holding two contradictory positions. The Church of Rome has promoted both preterist and futurist theology in its history. It was a defence mechanism. For centuries, Protestants said the Pope was the Antichrist (Revelation 13:7). It this part of the Bible happened before the Catholic church began, or would happen in the future, the Pope couldn’t be the bad guy, could he? It’s a great example of creative ambiguity.

Is any of this stuff true? Of course not. It’s nonsense, dating from the time of a geocentric view of the universe and the burning of witches. The Jehovah’s Witness confidently predicted the return of Christ to earth in 1914. Some of them believe that Satan and his demons were cast down to earth in that year and that he rules the current world order.

 Everyone should just grow up. The preachers should get proper jobs. Those proclaiming Biblical evidence of Armageddon are stirring up hatred and helping to bring it about through their very actions – a self-fulfilling prophecy. Maybe that is their intention.