The Food Hygiene Rating Scheme – Is It Still Fit for Purpose?

BY Matthew Frankcom MCIEH, CEnvH Environmental and Public Health Consultant and RIAMS Specialist Reviewer

RHE Global

18 Jun 2024

Since the Food Hygiene Rating Scheme (FHRS) was introduced in November 2010,1 literally millions of inspections and ratings of UK food businesses have been completed by local authorities (LAs). Ratings range from 5 – ‘very good’ to 0 – ‘urgent improvement necessary’.

A search of the scheme database today will reveal ratings for some 539 thousand food businesses in England, Wales and Northern Ireland (NI), and a further 56 thousand in Scotland. The scheme aims to help consumers make more informed choices about where they purchase their food by providing clear information about hygiene standards. But have these aims been achieved? Consumers are faced with a vast array of information and advertising designed to influence their food purchasing. Food is becoming ever more expensive, so is cost now the overriding factor? And is the scheme information consistent across the UK, particularly in light of falling local authority budgets? We consider some of these challenges.

Qualitative research from the Food Standards Agency (FSA), published in March 2023,2 found that awareness of the FHRS varied substantially across participants. Those who knew more about it associated the scheme with their actions of checking food safety and hygiene ratings before deciding where to buy food. But other participants were less aware, tending not to use the ratings when making those choices. Further, whilst participants “considered FHRS rating stickers as a source of trustworthy, independent information about the food hygiene standards in a business”, other participants “often described the FHRS ratings as making little difference to their decisions about buying food from different kinds of businesses – including takeaways, supermarkets, cafes, and restaurants – even if they were familiar with the scheme”. However, other quantitative FSA research around the same time found that 86% of respondents in England, 92% in Wales and 91% in Northern Ireland had heard of the FHRS,3 with most saying they would eat at higher-rated rather than lower-rated premises. Whilst it does appear the scheme is punching through to those consumers responding, what of those who do not engage with surveys? Or those with limited means, opportunities or difficult circumstances? Individual choices are unequal and not always made on a level playing field. But to make thought-through choices, information and means are required. So do food businesses throughout the UK consistently display their ratings to help consumers make choices that are more considered?

In 2010/11, when the FHRS was launched, an average of 41% of food businesses across England, Northern Ireland and Wales displayed their rating.4 Display is now 91% in Wales and 87% in Northern Ireland – a massive success. But in England, the increase over 10 years has only been 26%, with just 67% displaying their rating.

Unlike in Wales and Northern Ireland, food businesses in England do not legally have to display their ratings. So English consumers are not being afforded the same opportunities to choose as those in Wales or Northern Ireland, where fixed penalty notice powers exist to require mandatory rating display. Another disparity is the lack of requirements for any online display of ratings in any UK country. Online shopping is huge, with 60% of consumers ordering their grocery shopping that way.5 And let’s consider menus: only in Wales is it a requirement for a food business to promote in publicity materials and menus where consumers can find out their food hygiene rating. And finally, food manufacturers are not covered by the FHRS, so arguable transparency for the public in hygiene standards operating at the places where their food is made is not provided.

Consistency and transparent governance are needed in the operation of any scheme to provide public and business trust and confidence. The Office for Product Safety and Standards (OPSS), for example, state they are ‘committed to delivering regulation in a manner that is risk-based, proportionate and consistent and we aim to be transparent and accountable about our regulatory approach and activities’.6 LAs implement the FHRS and go to great lengths to ensure rating consistency between officers and themselves. The most recent national consistency exercise coordinated by the FSA in 2023 showed good general ratings consistency between England, Wales and Northern Ireland.7

But, of course, sufficient resources must be available to LAs if they are to operate the FHRS effectively and consistently. Whilst in general good progress was made by LAs in meeting the FSA [Covid pandemic] Recovery Plan for food safety and standards inspections,8 the plan itself did not require inspection of lower-risk premises, so some may be overdue. Over time, low risk can, if left, easily change to present high or unknown risks to consumers. Further, the National Audit Office (for England) report ‘Ensuring Food Safety and Standards’ (2019) highlighted that ‘the level of funding LAs allocate to food controls has been declining for a number of years’.9 They state that ‘spending [in England] on food hygiene fell by an estimated 19% between 2012/13, and 2017/18 fell from £125 million to £101 million’. Similar financial pressures exist in Wales and Northern Ireland, as well as workforce pressures throughout the UK due to the lack of availability of qualified and competent officers authorised to undertake official food controls. The World Health Organisation’s universal truth of ‘no health without a workforce’10 certainly applies to food safety work and the continued effective operation of the FHRS.

A further factor to evaluate in the context of consistency is how LAs determine appeals against ratings. LAs determine appeals themselves in accordance with the FHRS Brand Standard.11 Whilst there are few appeals,12 with FSA and Welsh Senedd oversight not indicating any major issues with this,13 it could be believed by businesses that LAs are ‘marking their own homework’.

Finally, the FHRS does what it says on the tin – rating food hygiene – and does this very well. But food standards are equally important to consumers, with now 1 in 20 people in the UK having a confirmed food allergy.14 Such consumers require assurance that their allergy needs will be taken care of by food businesses. The FSA has recently been assessing a Food Allergy Safety Scheme (FASS) option but recommended this will not now be progressed.15 They propose instead to develop and implement a ‘series of linked projects focusing on education and guidance for food businesses.

It could be argued that mandating requirements for consistency and ensuring sufficient resources to implement them is a way to ensure compliance and provide consumer assurance. Not least, and particularly at this time, there are financial, political, social, operational and business challenges to overcome for the FHRS and any other assurance schemes. But it is very important these continue and develop to meet all consumers’ needs, to help ensure food is safe and is what it says it is,16 and that no-one is left behind.17

Footnotes

1. https://ratings.food.gov.uk/

2. https://www.food.gov.uk/research/value-of-fhrs-consumer-research-executive-summary

3. https://www.food.gov.uk/research/food-and-you-2-fhrs-wave-6-executive-summary

4. https://www.iffresearch.com/case-studies/fsa-food-hygiene-rating-scheme/

5. https://ecommerceage.co.uk/marketplaces/uk-online-grocery-report-2022-spryker-appinio/

6. https://www.gov.uk/government/publications/safety-and-standards-enforcement-enforcement-policy

7. https://smartercommunications.food.gov.uk/communications/shared-files/8277?token=rUdtr360pFt1boA5iKw3xxyk9iFODSSV

8. https://www.food.gov.uk/research/local-authority-recovery-plan-assurance-assessment-key-findings

9. https://www.nao.org.uk/wp-content/uploads/2019/06/Ensuring-food-safety-and-standards.pdf

10. https://www.who.int/publications/m/item/hrh_universal_truth

11. https://www.food.gov.uk/local-authorities/guidance-on-implementation-and-operation-of-the-food-hygiene-rating-scheme-the-brand-standard-and-statutory-guidance