FHRS ‘Brand Standard’ (Revision 3) – ensuring a consistent approach Food Team briefing
Jan 23, 2016
FHRS ‘Brand Standard’ (Revision 3) – ensuring a consistent approach
Food Team briefing
• Which businesses should be rated?
• How does the scoring & mapping work?
• When and what needs to be notified to food businesses?
• What goes on the website?
• How does the appeal process work?
• What does ‘right to reply’ involve?
• How does the requested re-visits safeguard work?
• How can we ensure consistency?
• Any questions or comments?
What does the briefing cover?
Which businesses should be rated?
Key questionIs the establishment subject to registration requirements or is it an approved establishment with a retail element?
Key questionIs the establishment subject to registration requirements or is it an approved establishment with a retail element?
Excluded from scope - no food hygiene rating
Excluded from scope - no food hygiene rating
No
Yes
Next key questionNext key question
Follow the decision tree and answer the key questions
Key questionDoes the establishment supply food directly to consumers for consumption on or off the premises?
Key questionDoes the establishment supply food directly to consumers for consumption on or off the premises?
Excluded from scope – no food hygiene rating
Excluded from scope – no food hygiene rating
No
Yes
Next key questionNext key question
Examples Primary producers, manufacturers, packers, importers and exporters, distributors (including wholesalers), transporters, and other inter-business suppliers.
Examples Primary producers, manufacturers, packers, importers and exporters, distributors (including wholesalers), transporters, and other inter-business suppliers.
Examples Restaurants, pubs, cafes, takeaways, sandwich shops, B&Bs, guest houses, hotels, mobile traders, market stalls and occasional markets, supermarkets, fruit & vegetable shops, off-licences, schools, nurseries and residential care homes, armed forces, police and Crown establishments, wholesalers or cash & carries selling food direct to consumers, other places that people eat food prepared outside of the home.
Examples Restaurants, pubs, cafes, takeaways, sandwich shops, B&Bs, guest houses, hotels, mobile traders, market stalls and occasional markets, supermarkets, fruit & vegetable shops, off-licences, schools, nurseries and residential care homes, armed forces, police and Crown establishments, wholesalers or cash & carries selling food direct to consumers, other places that people eat food prepared outside of the home.
Follow the decision tree and answer the key questions
Which businesses should be rated? Which businesses should be rated?
Key questionIs the establishment 'low-risk' and not generally recognised by consumers as being a food businesses?
Key questionIs the establishment 'low-risk' and not generally recognised by consumers as being a food businesses?
No food hygiene rating
No food hygiene rating
Examples Visitor centres & similar establishments selling tins of biscuits or other wrapped goods amongst a range of goods, leisure centres with only food vending machines (with only drinks or low-risk foods), newsagents selling only pre-packed confectionery, chemist shops, off licences selling only drinks and wrapped goods..
Examples Visitor centres & similar establishments selling tins of biscuits or other wrapped goods amongst a range of goods, leisure centres with only food vending machines (with only drinks or low-risk foods), newsagents selling only pre-packed confectionery, chemist shops, off licences selling only drinks and wrapped goods..
No
Next key questionNext key question
Yes
Follow the decision tree and answer the key questions
Important change to Revision 3Businesses in this category can no longer ‘opt in’ to the FHRS.
Important change to Revision 3Businesses in this category can no longer ‘opt in’ to the FHRS.
Which businesses should be rated?
Key questionIs the establishment operating from a private address?
Key questionIs the establishment operating from a private address?
Key questionIs the establishment a childminder or are other caring services being provided in the home environment as part of a family unit ?
Key questionIs the establishment a childminder or are other caring services being provided in the home environment as part of a family unit ?
No food hygiene rating
No food hygiene rating
Yes Yes
Give food hygiene rating
Give food hygiene rating
No
No
Follow the decision tree and answer the key questions
Important change to Revision 3Businesses in this category can no longer ‘opt in’ to the FHRS.
Important change to Revision 3Businesses in this category can no longer ‘opt in’ to the FHRS.
Which businesses should be rated?
• Basis – Annex 5 of Code of Practice
− level of (current) compliance with food hygiene and safety procedures
− level of (current) compliance with structural requirements
− confidence in management/control procedures
• Brand Standard has descriptions of standards that might be expected for each Annex 5 score - Section 3: Scoring
• Rating at inspection, partial inspection or audit (only exception is requested re-visits)
• Ratings cannot be given on the basis of self-assessment questionnaires
How does the scoring & mapping work?
• In assessing ‘confidence in management’ at multi-site business outlets, both company-wide management systems and procedures and the implementation locally form part of any assessment.
• Where there is a Primary Authority Agreement, enforcing authorities should have regard to any Primary Authority Inspection Plan so that HACCP-based procedures are not subject to unnecessary further assessment.
• Local implementation of the HACCP-based procedures should be considered in the same way as for independent ‘single outlet’ businesses.
Multi-site businesses
How does the scoring & mapping work?
Mapping of numerical scores from the intervention-rating scheme at Annex 5 of the Food Law Code of Practice to the six FHRS food hygiene ratings
Total Annex 5 scores
0 - 15 20 25 - 30 35 - 40 45 - 50 > 50
Additional scoring factor
No individual score greater
than 5
No individual score greater
than 10
No individual score greater
than 10
No individual score greater
than 15
No individual score greater
than 20-
Food hygiene rating
Descriptor Very good GoodGenerally
satisfactoryImprovement
necessary
Major improvement
necessary
Urgent improvement
necessary
How does the scoring & mapping work?
Individual Annex 5 scores
Total Annex 5 scoreHighest score –
additional scoring factorFood hygiene rating
5, 5, 5 15 5
0, 5, 10 15 10
5, 5, 20 30 20
Examples
How does the scoring & mapping work?
• At the time of the intervention OR after but without undue delay and within 14 days of the intervention
• Our policy is to [include policy]
When and what needs to be notified to food businesses?
When?
What information?
• Food hygiene rating
• Details of why it was rated as it was
• If less than a 5, the actions needed to achieve compliance for each of the three Annex 5 elements
• Indication of when the rating will be published
• Information on the safeguards including a weblink to food.gov.uk/ratings
• Contact details
When and what needs to be notified to food businesses?
What display material?
Important change to Revision 3Certificates are no longer part of the FHRS and should not be provided to businesses
Important change to Revision 3Certificates are no longer part of the FHRS and should not be provided to businesses
• A sticker should be provided at the time of intervention or with the notification of the rating
• Certificates should no longer be issued.
• Unless the ‘new’ rating is a 5, ‘old’ stickers should not be removed as the ’old’ rating remains valid until the end of the appeal period
Excluded Excluded
Included and private
Included and private
What goes on the website?
Operation Status tag
Does not supply direct to consumersDoes not supply direct to consumers
Manufacturers, packers, exportersManufacturers, packers, exporters
Home caterers and mobile tradersHome caterers and mobile traders
Included Included
Supplies consumers direct, is rated, but sensitivities about publishing full address
Supplies consumers direct, is rated, but sensitivities about publishing full address
Supermarkets, restaurants, cafes, pubs, hospitals, schoolsSupermarkets, restaurants, cafes, pubs, hospitals, schools
Supplies consumers direct, is rated, and can publish full addressSupplies consumers direct, is rated, and can publish full address
ExemptExempt
Visitor centres selling biscuits, newsagents selling only pre-packed confectionary
Visitor centres selling biscuits, newsagents selling only pre-packed confectionary
Supplies consumers direct but not rated as ‘low risk’ and not recognised as a food business, and can publish full address
Supplies consumers direct but not rated as ‘low risk’ and not recognised as a food business, and can publish full address
Examples
Operation Status tagExamples
Awaiting inspection Awaiting
inspection Businesses that have yet to receive an inspection and to be given a ratingBusinesses that have yet to receive an inspection and to be given a rating
SensitiveSensitive
Military establishments, child-minders and other caring services provided in home environments
Military establishments, child-minders and other caring services provided in home environments
Supplies consumers direct, is rated but sensitivities about publishing any address
Supplies consumers direct, is rated but sensitivities about publishing any address
Exempt and private
Exempt and private
Supplies consumers direct but not rated as ‘low risk’ and not recognised as a food business, but sensitivities about publishing full address
Supplies consumers direct but not rated as ‘low risk’ and not recognised as a food business, but sensitivities about publishing full address
Businesses that have yet to receive an inspection and to be given a rating and where there are sensitivities in about publishing full address information
Businesses that have yet to receive an inspection and to be given a rating and where there are sensitivities in about publishing full address information
Awaiting inspection
and private
Awaiting inspection
and private
What goes on the website?
ExcludedExcluded Nothing Nothing
IncludedIncluded
Business name and full addressLAEMS business categoryDate of inspection OR date of revised food hygiene rating Food hygiene rating OR revised food hygiene rating OR ‘awaiting inspection’ OR ‘awaiting publication’
Business name and full addressLAEMS business categoryDate of inspection OR date of revised food hygiene rating Food hygiene rating OR revised food hygiene rating OR ‘awaiting inspection’ OR ‘awaiting publication’
Included and private
Included and private
Business name and partial addressLAEMS business categoryDate of inspection OR date of revised food hygiene rating Food hygiene rating OR revised food hygiene rating OR ‘awaiting inspection’ OR ‘awaiting publication’
Business name and partial addressLAEMS business categoryDate of inspection OR date of revised food hygiene rating Food hygiene rating OR revised food hygiene rating OR ‘awaiting inspection’ OR ‘awaiting publication’
Status tags
What goes on the website?
ExemptExemptBusiness name and full addressLAEMS business category‘Exempt’ in place of a food hygiene rating
Business name and full addressLAEMS business category‘Exempt’ in place of a food hygiene rating
SensitiveSensitive NothingNothing
Exempt and private
Exempt and private
Business name and partial addressLAEMS business category‘Exempt’ in place of a food hygiene rating
Business name and partial addressLAEMS business category‘Exempt’ in place of a food hygiene rating
Awaiting inspectionAwaiting
inspection
Awaiting inspection and
private
Awaiting inspection and
private
Business name and full address LAEMS business category‘Awaiting inspection’ in place of a food hygiene rating
Business name and full address LAEMS business category‘Awaiting inspection’ in place of a food hygiene rating
Business name and partial address – local authority name and first part of postcode onlyLAEMS business category‘Awaiting inspection’ in place of a food hygiene rating
Business name and partial address – local authority name and first part of postcode onlyLAEMS business category‘Awaiting inspection’ in place of a food hygiene rating
What goes on the website?
• FBO can appeal if s/he considers rating is unjust
• Try to resolve informally first
• Appeals must be lodged within 14 days of date of notification of rating
• Appeals should be determined by Lead Officer for Food or deputy, or an officer from another authority
• Applies to ratings at planned interventions and ratings given at requested re-visits/re-inspections
• Template forms available
• If FBO remains dissatisfied s/he can challenge by judicial review
How does the appeals process work?
FBO notified of rating at time of intervention or within 14 daysFBO notified of rating at time of intervention or within 14 days
Inspection, partial inspection, or audit or requested re-inspection/re-visit
Inspection, partial inspection, or audit or requested re-inspection/re-visit
No ‘appeal’ lodged within 14 days of notification
No ‘appeal’ lodged within 14 days of notification
‘food hygiene rating’ published
‘food hygiene rating’ published
FBO disputes rating and raises matter with ‘inspecting’ officerFBO disputes rating and raises matter with ‘inspecting’ officer
FBO still disputes rating and appeals within 14 days of date of notification
FBO still disputes rating and appeals within 14 days of date of notification
Appeal determined and decision communicated to FBO within 7 days
Appeal determined and decision communicated to FBO within 7 days
Dispute resolvedDispute resolved
Shown as ‘awaiting publication’
Shown as ‘awaiting publication’
How does the appeals process work?
• Provides FBO with an opportunity:− explain unusual circumstances at time
of inspection− highlight actions taken since
inspection to improve standards
• May submit electronically or in writing – template forms available
• LA reviews text and edits to remove offensive, defamatory or clearly inaccurate or irrelevant remarks
• LA should process and publish as soon as possible and without undue delay
• Comments published at food.gov.uk/ratings
What does ‘right to reply’ involve?
• FBOs can request a revisit when improvements identified at inspection have been made
• Revisits between three and six months after inspection and generally unannounced
• Only one revisit between planned interventions
• If inspection/partial inspection/audit, the risk rating also changed
• Ratings may go up, down or remain the same
• Template form available
How does the requested revisits safeguard work?
How can we ensure consistency?
• Operate our FHRS consistency framework
• Apply the FHRS ‘Brand Standard’
• Implement FSA ‘Top tips’
• Monitoring and auditing
• Training requirements and participation in consistency exercises
• Officer competency
• Food business database management
• Carrying out inspections and other interventions
• Interpretation of Annex 5
• Maintenance of intervention records and correspondence
• Service monitoring and related record keeping
• Operation of FHRS safeguards
How can we ensure consistency?
• Increasing FHRS visibility
• Ensuring a fair and consistent approach
• Improving data accuracy
• Business growth
• Multi-site outlets and primary authorities
Top tips
• Take account of the basic principles for applying Annex 5 of the Food Law Code of Practice
• Regularly review and discuss cases within the Food Team meetings
• Participate in FSA Annex 5 consistency training and other relevant training and cascade the learning
• If there is a Primary Authority agreement, make sure any Primary Authority inspection plan is followed
Consistent scoring
How can we ensure consistency?
Consistent and accurate data
• Check records on the database each time a new rating is given to ensure the LAEMS category is correct (see examples/definitions in the guidance at http://www.food.gov.uk/enforcement/monitoring/laems/generalinfo/)
• Check status tags are correct (child-minders should always have a ‘sensitive’ status)
• Check that the business name is still correct and that the address details are up to date and the full postcode is included
• Upload data to FSA system as regularly as possible but at least every 27 days
• If notified of possible errors on business details by Transparency Data (Scores on the Doors), only make appropriate amendments to your own database system
How can we ensure consistency?
Consistent messages for businesses
• Explain the improvements needed under the three Annex 5 headings
• Use the FSA template letters for notifying ratings and template letters and forms for dealing with safeguards.
• Use FSA leaflets
How can we ensure consistency?
Any questions or comments?
• Any questions?
• Any comments on the Brand Standard to feed back to the Food Hygiene Ratings Team at the FSA?