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.


 

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 ‘regulatory 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.”

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/

The gentle art of faking

The six-day Glasgow meat trial of 1889 was a milestone in public health. It led to the enhanced inspection of abattoirs. But fraud, truth denial and producer prioritisation delayed the effective regulation of the meat and dairy industries for many decades. 

On the 9th of May 1889, Peter Fyfe, who had been appointed as Glasgow City Council’s chief sanitary inspector in 1885, saw something troubling in the city’s Moore Street slaughterhouse. Two carcasses showed red discolouration and contained nodules well known to indicate the presence of tuberculosis. He duly seized and condemned the carcasses from their sellers, Hugh Couper and Charles Moore, judging them unfit for human consumption.

This state of the meat that he had found was by no means unusual. The barely regulated abattoirs of Victorian Britain were disgusting by modern standards. Animals were packed into filthy, overcrowded pens and killed within sight of each other. There was no legal requirement for post or antemortem animal inspection. Diseased cuts and offal from emaciated, often decomposing carcasses were consumed by the poor, who relied on cheap meat for their meagre diets. Awareness of animal diseases and their zoonotic effects was limited. 

In addition, many scams were prevalent in the meat trade. Norwich sanitary inspector, Bernard Penny, wrote of butchers in The Sanitary Journal in March, 1910: “These gentlemen are past masters of the gentle art of faking and can dress a dead lamb or calf and clean up an old cow or a weedy steer in a marvellous manner. What with the inflation of veal and lamb (misdescription of cheaper meat) and stripping and cleaning of beasts, it often takes very careful inspection to detect anything wrong.”

Milk was also a nutritional staple of the poor, particularly for children and infants. But dairies and cowsheds were as unhygienic as abattoirs, so the purity of milk could not be relied upon, and it was often watered down. It was a serious public health issue. Infected milk was a primary cause of streptococcal infection, typhoid, scarlet fever and diphtheria, as well as tuberculosis.

Over the Victorian period, protective legislation, which was some of the first in the world, slowly caught up as urban populations swelled in size. UK statutes on food composition, powers to seize and condemn foodstuffs and laws to clean up cowsheds and dairy herds appeared from the middle of the century. They were enforced by medical officers of health and sanitary inspectors. However, in his bold enforcement action of 1889, Peter Fyfe, a prolific writer and lecturer, who devoted his life to improving housing, air quality and food safety in Glasgow, was going out on a limb, pushing the law to its limits.

The science of tuberculosis

It makes sense that if food stinks it will make you ill. But links between bacteria and disease were still being discovered. German pioneer microbiologist Robert Koch had identified the bacterium causing tuberculosis – a milestone of medical science – in 1882. It was known that both cows and cattle contracted TB. In humans, TB, which was untreatable, was ubiquitous in over-crowded slums. Called phthisis, then consumption, this scourge of the poor was dreaded under another name, ‘the white plague’. It is thought to have been responsible for a quarter of human deaths in the nineteenth century – but, in 1889, a link between bovine and human forms of the disease had yet to be conclusively established.

Fyfe and other sanitary inspectors were convinced that TB did transmit from the milk and meat of cattle, causing a massive toll of human illness and death. They were extremely concerned by the extent of TB in Britain’s beef and dairy herds – it was estimated that a fifth of cows were affected by the disease – but felt that their hands were tied behind their back. Legislation was patchy. The Public Health Act 1875 (1867 in Scotland) allowed unsound meat and animals to be seized, for the first time, by local authorities but the powers were sparingly applied.

Angered by an injustice, Fyfe, who was a chess player and dramatist, as well as a health campaigner, asked eloquently in The Sanitary Journal in 1910: “Who can calculate the mass of human suffering, the numberless army of pale-faced pilgrims in their weary march to the consumptive’s grave, whose painful progress from birth to death has been caused by a draught of disease bearing milk?”.

In practice, in rural areas, the meat trade was dealt with leniently by magistrates, who often had close connections to farmers, while urban authorities were hugely under-resourced and they had to tackle slum housing and poor air quality and seek to reduce the spread a host of communicable diseases, as well as cleaning up the food chain. In 1911, Manchester's sanitary department employed only 100 staff for a city of 1.5 million people. Rotting and pathogenic food was a major health menace. Sanitary inspectors annually seized and destroyed hundreds of tonnes of unfit mean, fish shellfish and fruit and vegetable.

Then as now, vested interest in the food chain were implacably opposed to reform. The farmers, abattoirs, wholesalers and butchers providing the nation’s meat did not want even emaciated and diseased carcasses to be removed from the food chain.

By the beginning of the twentieth century, other countries, notably the USA, had successfully cleaned up their cattle and dairy herds. But the UK lagged behind. Farmers vigorously objected to a system requiring them to certify their animals as healthy and opposed pasteurisation – a life-saving measure which was well understood by the beginning of the century. To support this stance, they denied that infected milk or animal products caused tuberculosis and other illnesses in humans – lobbying issues that contributed, in 1908, to the formation of the National Farmers' Union.  

Need for vigilance

Because the economic stakes were so high, Fyfe’s seizure of two grossly diseased carcasses in Glasgow led to an important test case The butchers involved – Couper and Moore, contested his action. This triggered a six-day trial, heard in May and June 1899, in which both sides called numerous witnesses. 

The trial was extensively reported, well beyond the medical and trade press. The defence maintained that, as only parts of the carcasses were diseased, they should not have been seized. The prosecution argued, citing studies that were still not universally accepted, that science had shown that the presence of the tubercular bacillus in part of an animal would render the whole dangerous.

The case went well for Fyfe – the judge found in Glasgow’s favour. Following this verdict, councils with meat inspectors, including Liverpool, Belfast, Leeds and Newcastle now began to seize whole carcasses with localised signs of disease – a measure that must have saved many lives. 

Eliminating diseased carcasses at the end of food chain was effective in cleaning up herds. It also circumvented the many tricks of the trade of the meat trade to pass off sub-standard products as safe to eat. Outraged butchers lobbied their MPs and the Board of Agriculture, complaining that they would be driven out of business.

Delighted by the verdict, The Lancet wrote that the sale of tuberculous meat is now “illegal …. even where disease is limited in distribution and the carcass otherwise apparently sound”. The Meat Trades Journal pronounced the judgment to be “momentous”. However, these conclusions proved to be premature. Battles between town and country, regulated and regulator were to continue, and the science of tuberculosis was not settled.

At the instigation of the Local Government Board, a Royal Commission on tuberculosis in animals was commissioned in 1896 It called for meat inspectors to be trained and qualified in animal pathology, but fudged the contamination issue. A second Royal Commission was set up in 1901. Its work dragged on for a decade, further delaying clarity.

The Public Health (Meat) Regulations, which set standards for slaughterhouse inspection and consolidated local authority powers, did not come into force until 1924. As we have seen in another blog (The battle for safe milk) regulation of the dairy industry was also delayed for many decades. Many private bills requiring the certification of dairy herds, some introduced by the London County Council, were successfully blocked by land owning and farming interests.

Edith Summerskill’s Milk (Special Designations) Act systematically tackling sick herds and ushering in widespread pasteurisation, was not passed until 1949 – one of the most costly to life and egregious delays in UK public health history. Pasteurisation did not become compulsory in Scotland until 1983 and in England, Wales and Norther Ireland two years later.

The Glasgow meat case is interesting because it illustrates themes that always apply to regulation. Science evolves and is subject to interpretation and regulators and the regulated often have incompatible agendas. The worst hygiene horrors of the Victorian era may have passed into history, but new and novel threats will aways emerge and fraud will never disappear. 

Fyfe was feted in his city and was to become a fellow of the Royal Society of Edinburgh. His successfully pursued case has much to teach us about the need for vigilance in public health and for precautionary, impartial science-based practice, based on the best available understanding. These principles are too often forgotten, ignored or compromised by politicians.

Will Hatchett has been a journalist since 1986 He was editor of Environmental Health News from 1998 until 2018. The views expressed here are purely his own.

On food safety and amnesia

 

The UK is in desperate need of an independent, non-ministerial department responsible for food and health, which champions and protects the public. Political memories are short. We have forgotten that we used to have one. It was called the Food Standards Agency.

News that hospital admissions related to food-linked illnesses in England are rising steeply have led a well-respected expert, Tim Lang, food policy professor at City University, to say that the public is now ‘playing Russian roulette with food’.

The Guardian revealed this month that hospitals recorded three admissions for every 100,000 people for salmonella last year, an all-time high. Admissions caused by campylobacter, the most common cause of food poisoning, and E. coli, which can be the most deadly, are also on an upward trend.

The UK Health Security Agency may attribute this to advancements in molecular diagnostics, but Lang, and other commentators, point to other probable factors. They include Brexit, which has drastically reduced inspection of high-risk imported foods, the stripping of capacity from local government and the move to self-regulation for businesses, both in food safety and port health controls.

Lang told RHE Global: “Food safety is taking a low priority. It has fallen off the government’s agenda. History shows us that it takes something to go wrong for this policy area to lead to a public health response.”

UK history bears this out. In 1984, the deaths of 19 elderly people in the Stanley Royd Hospital in West Yorkshire from salmonella led to tighter legal controls. In 1996, an outbreak of E. coli 0158 in Lanarkshire that claimed 21 lives caused a similar public outcry and calls for legislative action. The BSE epidemic of the 1980s and ’90s was partly attributed to unhygienic abattoirs. Their inspection was transferred from local authorities to a new body, the Meat Hygiene Service, in 1995.

Creation of new agency

The fallout from Lanarkshire and BSE led to another important change. In 2000, a revolutionary new body, the Food Standards Agency was set up. It was given a distinctive green logo and guaranteed political independence. It held its meetings in public, which was unheard of for what was, effectively, a branch of the civil service. Its live-streamed meetings were well attended and reported in the national press. Reporting to the Department of Health, the FSA was tasked with two main purposes – to advise ministers and to protect the public “from risks arising from food”.

It became the lead body for UK food safety systems which are enforced by local government officers called EHOs – a system that began with Victorian public health legislation. The agency began strongly, it dealt successfully with emerging food safety threats, introduced a food hygiene rating system against strong opposition, ‘scores on the doors’, and significantly reduced campylobacter from infected poultry, with a targeted campaign.

In retrospect, amnesia began the day after it set up shop. As memories of Stanley Royd, BSE and Lanarkshire faded, the FSA was downgraded and stripped of powers. In 2010, perceived as ‘too political’ by a new government, particularly in its advocacy of traffic light labelling, it lost its responsibility for nutrition policy, including labelling, to the Department of Health. Whitehall culture, which is resistant to openness, was reasserting itself. The ten-year old agency narrowly avoided complete abolition by health secretary Andrew Lansley in 2010, when the political urge to deregulate was at its height.

The FSA survived by the skin of its teeth, but the shift of governments over the past 14 years away from positive health interventions, massive de-investment in local government and the UK’s detachment from Europe, with its well-developed scientific and food alert services and controls, have left us with a publicly run food safety service which is a shadow of what it was.

New threats emerge

The world is more complicated than when the FSA began. Allergies and intolerances, acrylamide, dioxins and new foodborne viruses have entered the vocabulary of food safety. The subject is highly political, as it always has been. Impartial advice to government risks being polluted by producer interests. Demarcation lines are important – are obesogenic environments and ultra-processed foods legitimate areas for regulation?

Consumers are taking about food and health more than ever but policy making has gone back into the shadows. We are in desperate need of an independent, non-ministerial executive department which wrests policy making from civil service invisibility and the interests of food manufacturers and champions the public – something like the original Food Standard Agency. And funding for frontline food safety services needs to be restored.

The implications of not having such an agency, and of decades of under-resourcing, are beginning to show, with a reported increase in the main forms of infectious intestinal disease contracted from food. History risks repeating itself. The consequences could become even more serious.

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.

Battle for safe milk

Buying milk used to be a life-or-death gamble, especially for the poor. But laws ensuring public safety were resisted for more than a century. In an age of novel pathogens and growing scientific obscurantism, it’s a warning.

How safe is the milk you buy from local shop? We’re talking about cow’s milk here – not the kind made from oats, peas or soy beans. Pretty safe, right? If you aren’t allergic to it, you can be almost 100% certain that legally-compliant milk consumed before its expiration date isn’t going to make you ill.

Having said that, recent exchanges between environmental health professionals on RHE's 'Communities' platform indicate that milk being sold via vending machines, now popping-up in a myriad of locations across the UK, may present significant risks to the health of the public, unless careful and diligent management is exercised by those owning and operating them.

The sale of unpasteurized or ‘raw’ cows’ milk is prohibited in England except from farm premises, where microbial controls can be more confidently guaranteed, thanks to visits from EHOs. Legislation and effective food safety enforcement normally protect us.

But that wasn't always the case. Bovine TB was identified as health risk to humans who drank milk from infected animals in the 1890s. Yet milk pasteurisation did not become compulsory in England, Wales and Northern Ireland until 1985. It is estimated is that a million deaths were caused in Great Britain by bovine TB contracted from infected milk from 1850 to 1950.

As we saw with BSE and, more recently, Covid-19, new zoonotic pathogens can emerge at any time. Political delay while science is uncertain is understandable – even advisable. But, in the case of milk, proven aetiologies between animal and human disease went unheeded by policy makers for a century. It’s a shocking example from history and a warning – especially as the links between science and policy are now loosening, in era when social media channels amplify ignorance.

The first laws allowing EHOs to crack down on filthy dairies and cowsheds, that were known incubators for animal and human disease were passed in 1879. Buying milk was a life-or-death gamble, especially for the poor, who needed it most for its fat, carbohydrates, vitamins and minerals.

Milk could be watered down and adulterated with chalk, flour or arrowroot. It could also be contaminated with bacteria causing typhoid, enteritis, diphtheria, scarlet fever and TB. In 1907, a Royal Commission stated definitively, following a debate that had raged since the 1880s, that bovine TB could transfer, in a lethal form, to humans.

Despite this significant announcement, legislation protecting the public was successfully resisted by vested interests for decades. In rural districts, adoptive laws imposing hygienic standards on dairy farmers were rarely and unevenly enforced. 

Milk was poisoning the poor

That was less the case in large cities. But their medical officers of health knew that, each day, trainloads of TB-infected milk were arriving from the countryside to serve fast-growing populations. It was an issue of grave concern – a public health scandal – especially for infants who relied on milk, ‘nature’s perfect food’, to avoid rickets and malnutrition.

From the 1890s, the Liverpool and Manchester Corporations and the London Council used private acts of Parliament to assume powers allowing them to prevent the sale of milk from tubercular cows. Uniform national legislation was urgently needed to tackle what was now a well-known and preventable threat to public health, but the implementation of Herbert Samuel's 1914 Milk and Dairies Bill of 1914, designed for that purpose, was postponed by the onset of the First World War and it took many more years for uniform protection of the public from infected milk to be assured.

Clean milk’s most persuasive champion of the new century appears in The Sanitary Journal in February 1916, in which a talk he gave to EHOs is recorded. Wilfred Buckley was born in Birmingham in 1873 and amassed a fortune from his family's exporting business. Returning from the US in 1906, he purchased a 1,000-acre estate in Moundsmere, Hampshire, and set himself up as a sheep, poultry and dairy farmer.

Buckley had a personal interest in hygienic dairy farming. His daughter contracted bovine TB in 1902. With a fellow dairy farmer, the wealthy newspaper proprietor, Waldorf Astor MP, owner of the Cliveden Estate and vice president of the Pure Food and Health Society of Great Britain, he had set up the National Clean Milk Society (NCMS) in 1915.

The society advocated the mandatory refrigerated transportation of 'certified' milk of guaranteed cleanliness and hygiene score cards for dairy farmers. These had been successfully adopted in the US but not in Britain, whose farming practices remained firmly rooted in the nineteenth century. 

Buckley was a persuasive campaigner. He used multimedia techniques – pamphlets, posters, articles, films and lectures illustrated with magic lantern slides – to put across his shocking and compelling message – an average sample of milk contained the same number of bacteria per cubic centimetre as a municipal sewage farm.

As a result, he was gaining powerful allies, including the king's surgeon, Sir Frederick Treves. A 'milk drought' was also impelling government intervention in the milk supply, as had taken place in munitions and housing. In October 1916, milk reached the shocking price of 6d a quart in some London districts, resulting in a demonstration by mothers and infants in Hyde Park.

Wars tighten standards

In December 1916, a Ministry of Food Control was created. Its second minister, Lord Rhondda, adopted unprecedented national powers. In October, Buckley was appointed director of milk supplies, a position in which he was able to exert considerable influence on Lord Astor's official inquiry into milk production.

Milk prices were now fixed and the Local Government Board was given powers to regulate distribution and sale, including reduced prices for mothers and children. Most significantly, from Buckley's point of view, milk grading was initiated, on a small scale.

From September 1918, dairies with high hygiene scores could be licensed to produce grade A milk, which was awarded a 3d a pint premium. Grade B milk was slightly less clean, but still of a high standard. The scheme was inherited from the Local Government Board in 1919 by the new Ministry of Health but, to the frustration of the UK's first health minister, Liberal MP, Christopher Addison, it was not mandatory and was patchily adopted.

After the war, Buckley continued to give lectures for the NCMS and helped to set up the National Milk Publicity Council. He died aged 60, in 1933, un-knighted despite his years of valiant campaigning.

Through the 1920s and 1930s, the opposition of the farming lobby to dairy reform prevailed. It would take another war and further technological developments for effective mandatory national standards to be introduced. The Milk (Special Designations) Bill of l949 ushered in certified TB-free herds and the widespread use of pasteurisation, the efficacy of which had been known in the nineteenth century. One of the strongest advocates of the bill had been the Labour MP, Edith Summerskill, who was Parliamentary secretary to the food ministry and a campaigner for women's rights. As a doctor she had seen, seen first-hand, the effects of poor nutrition on mothers and young children in the 1930s.

Will Hatchett has been a journalist since 1986 He was editor of Environmental Health News from 1998 until 2018. The views expressed here are purely his own.

 

Humans versus robots

 

Some people fear that AI will put food safety professionals out of a job. Are these fears justified? What will a future of machine learning based algorithms mean for public protection services? 

AI seems tailor made for food safety. Both the food supply chain and the catering sector generate copious amounts of data that is dense with meaning. But interpreting it needs a lot of leg work.

Now we have a technology that can both capture that data and glean intelligence from it, effortlessly – like a seasoned EHO casting their eyes around a storeroom. So, is AI a fantastic opportunity for public protection? Or is it a threat? Is it going to put a lot of EHOs and food technicians out of businesss?

One would imagine that an AFSO (automated food safety operative), could carry out an inspection in nanoseconds. It wouldn’t need to set foot on the premises. In fact, there wouldn’t be an inspection.

Smart fridges, ovens, extractors and chillers, connected by the internet of things, multiple sensors and object recognition-enabled cameras able to detect grease, bacteria, insects and rodent movements and droppings, would provide a stream of real-time data back to HQ.

A little red light would blink and a text would go to the service head at the slightest sign of an issue. A well-designed algorithm would predict a problem brewing before it happened. And it would factor in customer ratings, complaints and social media posts.

We’re probably closer than we might think to the AFSO, says Helen Statham, head of health, food and fire safety at SSP Group, especially in food manufacturing.

Statham was formerly risk and compliance lead for a high street fast-food brand and served as director of food safety and trading standards for a London borough. She says, comparing the robot and the human: “In my opinion, there’s space for both. But EHOs do need to think about their role differently and envisage a future in which AI is involved.” 

Importance of behaviour

Intelligence, she notes is not necessarily ‘intelligence’. Compliance is important, but the largest determinant of food safety is behavioural – that’s why one shift in a fast-food outlet can be exemplary and the next chaotic. CCTV is already widely used by food business, for security purposes and to generate evidence to defend legal claims.

It’s not much of a jump from there to using it for food safety – how often do staff wash their hands? Are they putting their blue gloves on? How often are tables cleaned? What do they do at the end of a shift?

Here, we get into a potentially tricky area of compromising staff privacy. But Statham says: “The intention shouldn’t be to tell them off and it’s not an alternative to an audit or an EHO visit. Too often, as EHOs, we’re telling people where things go wrong, but we’re not understanding why it went wrong – the behaviour that led to it. That’s where technology comes in – as a tool for improvement.”

For large brands, she notes, the risk of reputational damage is a powerful motivator for compliance. For small businesses it often isn’t. For them, Statham argues, there is little evidence that enforcement and routine inspection work – fines for food safety offences are so small that they are regarded as an occupational hazard.

Food safety training is not mandatory for those setting up a business and they know that they won’t be inspected before they open. These issues need to addressed, regardless of technology.

In Statham’s ideal scenario, tech-enabled enforcement could free up time for highly-skilled EHOs to train the ignorant and pursue the ill-intentioned – the ‘bad actors’. There will always be enough work of this nature to keep them busy. 

Data into action

Food safety expert, Sterling Crew, president of the Institute of Food Science and Technology, agrees. In his view, AI won’t supplant human food safety professionals, but enhance what they do. He says: “What AI does is to translate data into information, provide analysis and guide corrective action. it’s a great tool for EHOs to use, but it’s not a replacement. The need for human intervention won’t go away. But that invention will be smarter.”

Crew is excited rather than challenged by the future. We are still only scratching the surface, he says, of what is possible. Emerging technologies and sophisticated affordable equipment, such as hand-held mass spectrometers, once only available in professional labs, are revolutionising food safety, in the catering and manufacturing sectors. They are also great for eliminating fraud from supply chains and for reducing waste. Science fiction is becoming science fact.

He says: “I have been in the food sector for more than 40 years, starting my working life as a regulator. I expect to see more changes driven by AI in the next decade than at any time in my life.” He concedes that professional bodies, technologists and scientists are often viewing AI with concern, fearing for their jobs. But, with resources in food safety enforcement so tightly stretched, he argues that they have more to gain than to lose.

Technology evolves, humans adapt. Could it be that the main problem with the AI revolution is that it’s happening so quickly? This article was written by a human, by the way. Or was it? Crew says: “We are at the beginning of an AI revolution in food safety. It has the potential to have the same impact as the industrial revolution, when blue-collar workers’ lives changed forever. AI will have a similar impact on white-collar workers. Including regulators and food technologists.” 

This Blog was written for RHE Global

Will Hatchett has been a journalist since 1986 He was editor of Environmental Health News from 1998 until 2018. The views expressed here are purely his own