On food safety and the decline of the generalist EHO

Food safety inspection is on the verge of a step change that may greatly reduce the responsibilities and autonomy of local authority environmental health services. Will Hatchett speaks up for the role of the professional judgment and integrity offered by environmental health officers (EHOs) and warns against dumbed-down, tick-box enforcement.

In 2017, I watched, over a couple of weeks, as the library of the Chartered Institute of Environmental Health was loaded into skips for off-site disposal. Decades of policy papers, technical reports and books on subjects ranging from identifying sea fish and exotic fruit and vegetables to drains, clean air and slum clearance were sent to landfill.

It was an economy measure – perhaps a short-sighted one – necessitated by huge financial losses and a radical downsizing. I had often used the library as editor of the CIEH's news magazine. The move seemed symbolic of the reduced status of environmental health's holistic, local authority-based heritage, stretching back to the Public Health Acts of 1848 and 1875.

This professional erosion continues. According to a CIEH workforce survey in 2021, 56% of councils had environmental health vacancies unfilled for more than six months; 87% said agency staff were needed because they could not recruit permanent staff. A Local Government Association capacity survey in 2024 found that 51% of the workforce is over 50, while only 9% is under 30, creating a significant retirement 'cliff edge'.

In the same year, the Food Standards Agency expressed concern that around one in seven food safety posts in England, Wales and Northern Ireland were vacant.

Response to skills shortages

One could conclude from this that council-based environmental health is dying – literally – as a branch of the public health workforce. The trend is not new. University environmental health degrees have been closing for years, while comparatively poor terms and conditions and limited post-Covid flexibility have made local government less attractive to graduates.

The decline of the EHO as the person who inspects the kitchen of your local restaurant may have been accelerated last year by two significant developments. In October 2025, responding to an escalating crisis in food safety inspection capacity, the FSA introduced a revised Food Law Code of Practice (CoP) and accompanying practice guidance. The CoP is the FSA's legal blueprint for how local authorities regulate food businesses.

The revised CoP brought the Business Risk Decision Model (BRDM) into force in England, replacing the previous inspection regime with a more flexible, intelligence-led and risk-based approach to food hygiene controls. Moving away from a rigid 28-day inspection target, local authorities can now triage new food business registrations. This allows immediate inspections to focus on higher-risk establishments.

The new code formalises the use of remote official controls, such as desktop reviews and remote assessments, and allows trained officers with lower-level qualifications than previously required to undertake more regulatory work.
Currently, a fully qualified EHO typically has a Level 6 honours degree requiring three or more years of study and additional professional training. The CIEH has agreed, in principle, with the FSA on the development of a new Level 5 qualification for food law enforcement to broaden the regulatory workforce. It will be approximately equivalent to a Foundation Degree or Higher National Diploma, although the curriculum and assessment have yet to be finalised.

Level 4-qualified food safety practitioners, who can be trained in a matter of weeks, are now able to undertake supporting regulatory activities, including the desktop assessment of newly registered food businesses.

Critics argue that the changes risk diluting professional expertise, while supporters say they are a pragmatic response to severe workforce shortages. Both the CIEH and the FSA support a 'permit to trade' for new food businesses and the mandatory display of Food Hygiene Rating Scheme scores for food businesses in England, as in the rest of the UK. These long overdue measures would certainly help the FSA to fulfil its mission to “protect public health and maintain consumer confidence in the food system”.

Surprise announcement

In November 2025, in an unexpected move, the Government invited the FSA, through the Budget, to develop "a consistent, national approach in England for the regulation of large food businesses".

The idea did not emerge overnight. The FSA introduced Primary Authority partnerships in 2009, allowing large multi-site food businesses to work with a single local authority acting as their central regulatory contact. In 2023 it piloted National Level Regulation (NLR), under which major retailers would be regulated centrally through scrutiny of their systems and data.

The largest retailers have already begun preparing for such a system, developing national digital dashboards capable of sharing refrigeration records, staff training and pest control data directly with the FSA.

To supporters, NLR is the logical next step in modern, risk-based regulation. To many EHOs, it represents a profound constitutional shift: the weakening of politically accountable local authority enforcement, the further decline of the generalist EHO and an increased risk of regulatory capture. Unlike BRDM, however, NLR remains a proposal. It will require further design, consultation and primary legislation.

Many questions remain unanswered. We do not know how many businesses will qualify for NLR, how the scheme will be funded, or whether the FSA rather than councils will ultimately prosecute serious offences. Such powers would not be unprecedented – the Financial Conduct Authority and the Health and Safety Executive both combine regulatory and enforcement functions – but they would mark a significant departure from the current system.

New government – new priorities

Established in 2000 following the BSE crisis and the 1996 E. coli O157 outbreak in Lanarkshire, the FSA, now led by its sixth chief executive, Katie Pettifer, is a political creation. Its independence and transparency were originally badges of honour after the failure of MAFF's in-house advice during the BSE crisis.

In 2010, perceived as too political and too large, it lost its responsibilities for nutrition policy to the DoH and food labelling to Defra. Following years of budget cuts greatly reducing its staff count, the agency has increasingly become a technical and managerial organisation, rather than a public champion.

Since Brexit and Covid, new priorities have emerged: maintaining food security and reducing regulatory burdens on businesses facing rising costs. These are now objectives of the Labour Government and are likely to outlast it.

The prospect of political continuity, together with last year's Budget request to streamline regulation for large businesses, have led the FSA to combine the new CoP and BRDM with National Level Regulation under its all-embracing Future of Food Regulation Programme.

In March, the programme was presented to the FSA Board as a ‘step change’ towards a flexible, risk-based and modern food regulatory system, recognising the “evolving food landscape and the persistent pressures on local authority delivery”. FSA Chair, Susan Jebb, endorsed the programme and instructed officials to proceed with detailed design.

In June, the FSA published a workplan integrating National Level Regulation with improved local regulation, stressing that local authorities must remain part of the solution. Mid-2027 is the deadline for post-Brexit dynamic alignment negotiations. The FSA must keep one eye on the EU if it is to fulfil its Budget brief while reducing unnecessary burdens on internationally trading food businesses.

Risks versus benefits

If fully implemented, these reforms will represent the biggest structural change in food regulation since the Food Standards Agency was created. Many of the underlying ideas – including licensing, earned recognition and national regulation – have been discussed for years. An earlier modernisation programme, Regulating Our Future, launched in 2016, was derailed by Covid.

But deepening austerity, workforce shortages and a new political climate have accelerated what might otherwise have been gradual evolution into something closer to revolution.

The issues at stake are not professional self-interest or nostalgia but trust, integrity and accountability. Most professionals concede that incorporating advanced data collection and AI into official controls is welcome, but many argue that virtual assessments and documentary assurances cannot entirely replace an experienced professional visiting premises.

The keenest eyes are often those of the generalist rather than the contractor working to a narrowly defined specification. Sceptics fear that EH in the public sector will continue to be seriously underfunded. They portray a future of dumbed-down, tick-box enforcement, increased outsourcing and over-reliance on third-party auditors.

The strength of environmental health has never simply been technical competence in food hygiene. Its distinctive contribution has been its breadth. An officer inspecting a restaurant may also understand housing, infectious disease, occupational health, air quality, noise, drainage and wider public health.

Expertise, independence and thoroughness have long characterised the environmental health profession. It is bound by a code of ethics, and its practitioners are motivated by more than commercial considerations. Whatever shape the future regulatory system takes, those qualities are surely worth preserving.


 

Do you think that’s wise, Mr President?

The first presidents of environmental health’s professional body, all knighted, were an extraordinary group of people – nationally famous, single-minded and highly successful in their fields. One of them was ‘the last of the great Victorians’, another met Mark Twain.

 

No-one could accuse early presidents of the Sanitary Inspector’s Association, later the Chartered Institute of environmental health, of not being famous, or important. The first seven of them, forming an unbroken chain from 1883 to1938, were knights of the realm.

 

Reviled by some, admired by many, but never ignored, the first president, Sir Edwin Chadwick, (pictured) was one of the most celebrated public figures of the 19th century. In an age when cholera and other waterborne diseases were prevalent in towns and cities, Chadwick, a privately-tutored Manchester-born barrister and follower of the utilitarian philosopher, Jeremy Bentham, was obsessed about terrible state of London’s refuse collection and sewers.

 

His self-financed report on the sanitary condition of the labouring population of Great Britain was so forceful and persuasive that it led to a royal commission and, in turn, the Public Health Act of 1848, arguably the first piece of legislation of its kind, directing the full powers and insitutions of an industrialised state to making its citzenry healthier, in the world. Chadwick was instrumental in the setting up of the Metropolitan Commission of Sewers, which was to direct, only ten years later, the creation of London’s first extensive sewer network – a measure that saved hundreds of thousands of lives.

 

Chadwick was also a social reformer – but he deserves fewer plaudits in this area. He was an architect of the 1834 Poor Law, whose central idea was to make workhouse unpleasant and punitive institutions, to discourage poor people from entering them.  So – sewers great, workhouses terrible. One out of two is not bad.

 

Chadwick whose surprisingly small walking stick was formerly displayed in a glass case in the CIEH council chamber, was dogmatic, obsessive and dictatorial. “We prefer to take our chance with cholera than be bullied into health,” said a famous diatribe against his sanitary reforms in 1854, in the London Times.

 

By the time this Victorian grandee became the first CIEH president, in 1883, he was 82 years old. Even now, Chadwick clung to the long past its sell-by-date ‘miasma’ theory of disease (a belief, inherited from ancient Greece, that illness was caused by an invisible gas rising from rotting matter). He had been right about sewers, that poor sanitation made people ill, for the wrong reason.

 

He also believed that crime was caused by insanity and that a large proportion of orphaned children were the offspring of “hereditary vagrants, mendicants and delinquents”. But London’s improved sewers, it is estimated, had raised average life expectancy in the capital by 20 years, so let’s not judge him too harshly.

 

Hygeia: a city of health

 

As president, he was a tough act to follow. Step up to the plate, Sir Benjamin Ward Richardson. A fellow of the Royal College of Physicians Richardson was a pioneer of forensic medicine and anaesthesia. He brough into use no fewer than fourteen anaesthetics. A strict abstainer from alcohol and campaigner for healthier food, he had had multiple public heath interests. As CIEH president, he led many deputations to the Local Government Board to argue for security of tenure for sanitary inspectors.

 

Richardson was a prolific writer of papers, biographies, plays, poems and songs. His Hygeia, the pamphlet of a talk that he delivered in 1875, is a fascinating piece of science fiction. It describes a purpose-built ‘city of health’. A population of around 100,000 would live on approximately 4,000 acres of land, with houses restricted to four storeys, in wide streets. The houses would be made from coloured glazed bricks, to facilitate cleaning, and have no cellars or basements – basement  dwellings and workshops were the bane of the nineteenth century sanitary inspector.

 

Hygeia would be served by underground trains and furnished with swimming pools, Turkish baths, playgrounds, gymnasia, libraries, lecture halls, municipal slaughterhouses and water and gas supplies. Factories would be separated from residents. Ozone would be passed through drinking water and diffused through the houses to disinfect them. Richardson was not a miasmist, he believed in the new germ theory – bacteria were known about but not yet viruses.

 

He predicted that, in his healthy city, dysentery, typhus, typhoid and cholera would be almost unknown, scarlet fever, whooping cough and tuberculosis reduced and smallpox ‘kept under control’. There are parallels for Hygeia in industrial villages, like Bournville and Port Sunlight, and Letchworth Garden City but it preceded all of them. The idea is still ahead of its time.

 

Written long before town planning had been thought of, it is a remarkable feat of imagination. In the days before the nano specialisms of today, scientists could be polymaths. They could present their latest idea as a dream,  a play or a classical allegory. It’s also significant that a famous scientist and physician of Ward’s stature would assume an honorary position of a body devoted to sanitary science – medicine (treating people after they are sick rather than preventing sickness) had not assumed the virtual monopoly of health that it has today.

 

Publishers as presidents

 

For the third name on the honours board of ex officio appointments that once hung in the hallowed CIEH council chamber, let us move to Sir John Hutton. Hutton was a publisher of newspapers and journals, including Sporting Life and the ABC Railway Guide. A London county councillor, serving for the Progressive party, and a campaigner for parks, known for dedicating Hackney Marshes as an open space, when he was chairman of the London County Council, a position that he held from 1892 to 1895.

 

Interestingly, the fourth CIEH president also came from the publishing world and was even wealthier. Sir Hugh Gilzean Reid was descended from a long line of Highland crofters. Self-educated, he studied to become a non-Conformist minister but transferred his primary interest from religion to business, through journalism.

 

Gilzean Reid, the first president of the Institute of Journalists, became editor of the Edinburgh Weekly News, and in the early 1860s, founded the Middlesbrough Daily Gazette, a highly successful halfpenny evening newspaper. This made him his fortune. In 1885, he was elected as MP for the Aston Manor constituency in Birmingham, as a Liberal.

 

Gilzean Reid was the local MP for HH Spears, who was then, aged 19, working his way up the environmental health career ladder. It seems highly probable that Spears suggested Gilzean Read as a likely president of the association, following Sir John Hutton, in 1899.

 

Enter Mark Twain

 

Life has some strange twists and turns. From 1897, Gilzean Reid, took up residence in the splendid Dollis Hill House in Willesden, north London. Standing in extensive grounds this villa, now demolished, had asociations with Liberal prime minister, William Gladstone, as well as Joseph Chamberlain and Lord Randolph Churchill.

 

In the summer of 1900, the celebrated American author Samuel Langhorne Clemens, aka Mark Twain, was Gilzean Read’s house guest. Twain wrote that he had "never seen any place that was so satisfactorily situated, with its noble trees and stretch of country, and everything that went to make life delightful, and all within a biscuit's throw of the metropolis of the world”.

 

HH Spears,  editor of The Sanitary Journal visited him there too. There is a reference to their meeting in the publication. Did they reminisce about the old days, in Aston – a place of densely packed slums and smoke-belching chimneys, where the sun rarely penetrated. Gilzean Reid was in his pomp, a British version of William Randolph Hearst. The celebrated publisher only served as CIEH president until 1901. He died in 1911, aged 75, following a motoring accident from which, Spears tells us, he never fully recovered.

 

First woman on the board - hurrah! But is it too late?

 

He was succeeded as president by Sir James Crichton-Browne, who served from 1902 to 1921. Known as ‘‘The Last of the Great Victorians’, Crichton-Browne, who had walrus-like whiskers and was a world authority on lunacy, deserves a blog to himself, as does the first female president, the remarkable Janet Russell. She was elected in 2012, 129 years after Chadwick. The CIEH has now had three female presidents, bringing a century of male domination, at least in that role, thankfully to a close.