Environmental Health News - Back to Basics
2nd September 2011
Ever thought parts of your job are pointless? The fortnightly management reports with no apparent purpose, the logging of data that tells you nothing, a documentation system that anticipates prosecutions that you rarely, if ever, take?
Often, it is not in our power to question our role. But what if your local authority has the courage to throw away preconceived ideas and look afresh at its purpose and how it achieves it?
That is what the Great Yarmouth environmental health team has done and the outcome has caused quite a stir.
When Kate Watts, environmental health service manager at Great Yarmouth BC, first posted the outcome on the environmental health intranet EHCnet, she was swamped with 200 requests for more information. The new way of working has also impressed delegations from the CIEH, the Food Standards Agency (FSA) and the Local Better Regulation Office (LBRO), which see a potentially new approach to delivering food safety.
At the heart of the process is systems thinking, a theory designed to look at a process such as food safety as a whole, from an outside-in perspective, in this case from the perspective of local food businesses.
Ms Watts warns it is not a process for the faint-hearted; it revealed the team’s inefficiencies and forced her to face that what they did often obstructed their intended purpose. But Great Yarmouth’s EHOs now have improved relationships with food businesses, increased morale and a measurable increase in food hygiene standards and nuisance responses.
* * * * *
The impetus for change came from the top. A poor FSA audit in 2002 revealed a significant backlog of inspections that was only resolved in 2006 with consultant support. As soon as the team caught up, numbers once again started to slip. With only four staff inspecting 1,400 food businesses, they would always be playing catch-up.
Great Yarmouth’s chief executive approached Vanguard, a company offering systems thinking. ‘I was then sent on a three-day system thinking course and could see how it would help with our issues,’ explains Ms Watts.
‘Vanguard came to us on the understanding that they would make our service more capable within the resources we had. We did not go into this for cost savings but to be more capable.’
In March 2010, the consultant spent two weeks with environmental health managers helping them to look at their existing system, what it was trying to achieve and how. The consultant then left, providing support when needed.
The next task was to establish an overarching objective and see how it could be achieved. The final stage was an ongoing process of ensuring that what they did achieved the original objective. In the jargon, these phases are termed check, experiment (plan) and redesign (do). Once designed, the system is continuously evaluated and improved against its objective.
* * * * *
What looked simple on paper proved more challenging in reality. Just working out who the food team’s customers were took hours of intense debate.
Commercial team manager Harriet Sealey says: ‘We talked about members of the public being our customer, we talked about business, we talked about legislation being our customer or the FSA. We had a lot of difficult conversations and ultimately came up with the food businesses.’
Next, they needed to establish demand, or what food businesses wanted from them. After interviewing more than 40 food outlets of every type and size, the team was surprised to find that all wanted the same thing – regular contact with repeat visits after inspections and support before opening. All had the same aim – not to harm customers.
This matched the LBRO findings looking at the national picture. ‘What the Great Yarmouth team discovered mirrors almost exactly the national business messages that we are picking up about the value of the relationship, the need for information and that they want more risk based inspections,’ says LBRO director Rob Powell.
Ms Sealey was surprised by the uniform response: ‘From compliant to non-compliant businesses, they all said the same thing, they did not want to harm anyone and they actually wanted to see more of us. We were really surprised and came away buzzing.’
When the team looked at how their existing systems, designed to maximise inspection numbers for FSA targets, were meeting their customer’s needs they found it was letting down businesses at every stage.
There was no incentive to notice new traders, as they added to a stretched inspection list. Once noticed, they would be sent a form to register and a leaflet, then ignored. Repeat visits were also low on the team’s priority list. ‘They wanted to show us they had done the right thing as we said we were coming back to revisit. They wanted their gold star and when we didn’t bother turning up, you can imagine over two or three years what they felt about us as regulators,’ says Ms Watts.
The team also realised that time-constrained inspections focusing on legislation were failing to prioritise issues to ensure traders understood the greatest risks and how not to harm customers.
‘I remember this lady saying: “I have got my antibacterial hand spray, come and have a look”, and I was standing in a business that I knew was no good and thought: “Oh my God she thinks all she needed to do was get the spray when there were major issues going on”,’ says Ms Watts.
Next came a forensic analysis of processes. Using two observers, every part of an average category C premises inspection was analysed from allocation to sign-off. The process revealed extraordinary waste. ‘We worked out when you looked at the whole process it took a day to do an average C inspection. When you talk about capability and staffing resources, it was crazy,’ says Ms Watts.
* * * * *
Staff morale was also examined. Team members were asked what they thought managers wanted from them. ‘The most common answer was numbers of inspections and statistics, nothing about food safety, it was just about numbers,’ says Ms Watts.
The team threw out target chasing and defined a new way of working. Their purpose became ‘ensuring that food for public consumption is safe’ and they designed a way to achieve this single objective.
‘We had guiding principles that we could only make decisions based on knowledge and data. We also challenged our thinking of doing what the FSA says when redesigning our new system,’ says Ms Watts.
The new way of working is creating interest among colleagues and regulators. Food safety assessments are now at the heart of the process. Letters were replaced by visit reports left after the assessment. Now they were not collating statistics, the team had time to be in food outlets.
Having analysed their inspection style, the team understood that when they told food producers to do things that made no sense to them, they lost respect. Just to tell them, ‘the legislation says so’, was inadequate.
‘This produced the biggest headache of the experimentation stage, which was where legislation was going to fit into the new system,’ says Ms Sealey. ‘So we started to think about the spirit of the legislation and why it was there in the first place. That’s when we had our breakthrough moment and looked at the legislation in a different way.’
The team decided to differentiate between safe and unsafe non-compliance. Ms Sealey says: ‘Whereas in our old system we saw a procedural problem and would tie it to a piece of legislation and tell them they can’t do it, we started to talk to them as professional people and make an assessment directly related to our purpose, “is that food business producing safe food?” ’
New assessment forms, verification checks and sampling tools were designed. ‘Selection of an assessment tool is now based on an individual business. It’s not tied up with the code of practice or risk rating. With any business we have no knowledge of, we would do a full assessment,’ says Ms Sealey.
Premises deemed unsafe to go into a ‘make-safe’ category are visited as many times as necessary, with tailored training and practical demonstrations offered until the problem is solved. ‘We are not restricted by time any more and so we are able to spend time with those business that need our help,’ says Ms Sealey.
During this make-safe phase, officers use the most appropriate tools to ensure sustainable changes are in place once they leave. The officer may choose to do cleaning and hand washing demonstrations or use food sampling to illustrate food safety. Ticking boxes is a thing of the past.
The number of business moving from unsafe to safe then became a measure of performance, along with businesses reducing their risk rating. On both measures, the team demonstrated the success of the new working. Category A risk premises moved into category C or better.
The food team soon started reaping benefits. Relationships with food producers improved while businesses that had a historically poor food safety record suddenly showed significant progress. No enforcement action has been taken under the new system as the businesses now understand risk and commit to improving.
* * * * *
The team then had to tell the FSA about the new system, which had involved deviating from the code of practice and not collecting all the data for the FSA’s local authority enforcement monitoring system (Laems). Ms Watts admits she was worried.
‘In the end, the FSA was fantastic and said that they would give us space to develop the system. With the Laems return, they just wanted to know what we could provide and what we could not,’ she says.
Once contacted John Barnes, the head of the FSA local authority audit and liaison group, visited Great Yarmouth. ‘We are keen to see how this systems approach evaluates. We were contacted by the authority early in their thinking because it raised issues in relation to national monitoring arrangements and enforcement approaches,’ says Mr Barnes.
‘I have met the Yarmouth team and the work is both innovative and well planned. The project should provide some very useful information for the FSA’s own culture research, as well as our wider activity to identify what intervention approaches work best in driving up compliance and protecting consumers.’
The LBRO’s Rob Powell applauds the way better outcomes have been achieved for businesses.
He says: ‘Crucially, it is the way they have worked positively with the FSA to deliver innovation within the context of the national regulatory system, showing that what some may see as barriers to innovation are not as inflexible as they might think.’
David Kidney, CIEH head of policy, sees the model as potentially pointing to a new approach following the FSA review of official controls. ‘This is fresh and forward-looking, given the complaint from the profession about the tyranny of inspection numbers and reports. What is lovely about it is that it puts right at the centre of the service the judgement of professionals like EHPs and I think it is the right way to go.’
Ever thought parts of your job are pointless? The fortnightly management reports with no apparent purpose, the logging of data that tells you nothing, a documentation system that anticipates prosecutions that you rarely, if ever, take?
Often, it is not in our power to question our role. But what if your local authority has the courage to throw away preconceived ideas and look afresh at its purpose and how it achieves it?
That is what the Great Yarmouth environmental health team has done and the outcome has caused quite a stir.
When Kate Watts, environmental health service manager at Great Yarmouth BC, first posted the outcome on the environmental health intranet EHCnet, she was swamped with 200 requests for more information. The new way of working has also impressed delegations from the CIEH, the Food Standards Agency (FSA) and the Local Better Regulation Office (LBRO), which see a potentially new approach to delivering food safety.
At the heart of the process is systems thinking, a theory designed to look at a process such as food safety as a whole, from an outside-in perspective, in this case from the perspective of local food businesses.
Ms Watts warns it is not a process for the faint-hearted; it revealed the team’s inefficiencies and forced her to face that what they did often obstructed their intended purpose. But Great Yarmouth’s EHOs now have improved relationships with food businesses, increased morale and a measurable increase in food hygiene standards and nuisance responses.
* * * * *
The impetus for change came from the top. A poor FSA audit in 2002 revealed a significant backlog of inspections that was only resolved in 2006 with consultant support. As soon as the team caught up, numbers once again started to slip. With only four staff inspecting 1,400 food businesses, they would always be playing catch-up.
Great Yarmouth’s chief executive approached Vanguard, a company offering systems thinking. ‘I was then sent on a three-day system thinking course and could see how it would help with our issues,’ explains Ms Watts.
‘Vanguard came to us on the understanding that they would make our service more capable within the resources we had. We did not go into this for cost savings but to be more capable.’
In March 2010, the consultant spent two weeks with environmental health managers helping them to look at their existing system, what it was trying to achieve and how. The consultant then left, providing support when needed.
The next task was to establish an overarching objective and see how it could be achieved. The final stage was an ongoing process of ensuring that what they did achieved the original objective. In the jargon, these phases are termed check, experiment (plan) and redesign (do). Once designed, the system is continuously evaluated and improved against its objective.
* * * * *
What looked simple on paper proved more challenging in reality. Just working out who the food team’s customers were took hours of intense debate.
Commercial team manager Harriet Sealey says: ‘We talked about members of the public being our customer, we talked about business, we talked about legislation being our customer or the FSA. We had a lot of difficult conversations and ultimately came up with the food businesses.’
Next, they needed to establish demand, or what food businesses wanted from them. After interviewing more than 40 food outlets of every type and size, the team was surprised to find that all wanted the same thing – regular contact with repeat visits after inspections and support before opening. All had the same aim – not to harm customers.
This matched the LBRO findings looking at the national picture. ‘What the Great Yarmouth team discovered mirrors almost exactly the national business messages that we are picking up about the value of the relationship, the need for information and that they want more risk based inspections,’ says LBRO director Rob Powell.
Ms Sealey was surprised by the uniform response: ‘From compliant to non-compliant businesses, they all said the same thing, they did not want to harm anyone and they actually wanted to see more of us. We were really surprised and came away buzzing.’
When the team looked at how their existing systems, designed to maximise inspection numbers for FSA targets, were meeting their customer’s needs they found it was letting down businesses at every stage.
There was no incentive to notice new traders, as they added to a stretched inspection list. Once noticed, they would be sent a form to register and a leaflet, then ignored. Repeat visits were also low on the team’s priority list. ‘They wanted to show us they had done the right thing as we said we were coming back to revisit. They wanted their gold star and when we didn’t bother turning up, you can imagine over two or three years what they felt about us as regulators,’ says Ms Watts.
The team also realised that time-constrained inspections focusing on legislation were failing to prioritise issues to ensure traders understood the greatest risks and how not to harm customers.
‘I remember this lady saying: “I have got my antibacterial hand spray, come and have a look”, and I was standing in a business that I knew was no good and thought: “Oh my God she thinks all she needed to do was get the spray when there were major issues going on”,’ says Ms Watts.
Next came a forensic analysis of processes. Using two observers, every part of an average category C premises inspection was analysed from allocation to sign-off. The process revealed extraordinary waste. ‘We worked out when you looked at the whole process it took a day to do an average C inspection. When you talk about capability and staffing resources, it was crazy,’ says Ms Watts.
* * * * *
Staff morale was also examined. Team members were asked what they thought managers wanted from them. ‘The most common answer was numbers of inspections and statistics, nothing about food safety, it was just about numbers,’ says Ms Watts.
The team threw out target chasing and defined a new way of working. Their purpose became ‘ensuring that food for public consumption is safe’ and they designed a way to achieve this single objective.
‘We had guiding principles that we could only make decisions based on knowledge and data. We also challenged our thinking of doing what the FSA says when redesigning our new system,’ says Ms Watts.
The new way of working is creating interest among colleagues and regulators. Food safety assessments are now at the heart of the process. Letters were replaced by visit reports left after the assessment. Now they were not collating statistics, the team had time to be in food outlets.
Having analysed their inspection style, the team understood that when they told food producers to do things that made no sense to them, they lost respect. Just to tell them, ‘the legislation says so’, was inadequate.
‘This produced the biggest headache of the experimentation stage, which was where legislation was going to fit into the new system,’ says Ms Sealey. ‘So we started to think about the spirit of the legislation and why it was there in the first place. That’s when we had our breakthrough moment and looked at the legislation in a different way.’
The team decided to differentiate between safe and unsafe non-compliance. Ms Sealey says: ‘Whereas in our old system we saw a procedural problem and would tie it to a piece of legislation and tell them they can’t do it, we started to talk to them as professional people and make an assessment directly related to our purpose, “is that food business producing safe food?” ’
New assessment forms, verification checks and sampling tools were designed. ‘Selection of an assessment tool is now based on an individual business. It’s not tied up with the code of practice or risk rating. With any business we have no knowledge of, we would do a full assessment,’ says Ms Sealey.
Premises deemed unsafe to go into a ‘make-safe’ category are visited as many times as necessary, with tailored training and practical demonstrations offered until the problem is solved. ‘We are not restricted by time any more and so we are able to spend time with those business that need our help,’ says Ms Sealey.
During this make-safe phase, officers use the most appropriate tools to ensure sustainable changes are in place once they leave. The officer may choose to do cleaning and hand washing demonstrations or use food sampling to illustrate food safety. Ticking boxes is a thing of the past.
The number of business moving from unsafe to safe then became a measure of performance, along with businesses reducing their risk rating. On both measures, the team demonstrated the success of the new working. Category A risk premises moved into category C or better.
The food team soon started reaping benefits. Relationships with food producers improved while businesses that had a historically poor food safety record suddenly showed significant progress. No enforcement action has been taken under the new system as the businesses now understand risk and commit to improving.
* * * * *
The team then had to tell the FSA about the new system, which had involved deviating from the code of practice and not collecting all the data for the FSA’s local authority enforcement monitoring system (Laems). Ms Watts admits she was worried.
‘In the end, the FSA was fantastic and said that they would give us space to develop the system. With the Laems return, they just wanted to know what we could provide and what we could not,’ she says.
Once contacted John Barnes, the head of the FSA local authority audit and liaison group, visited Great Yarmouth. ‘We are keen to see how this systems approach evaluates. We were contacted by the authority early in their thinking because it raised issues in relation to national monitoring arrangements and enforcement approaches,’ says Mr Barnes.
‘I have met the Yarmouth team and the work is both innovative and well planned. The project should provide some very useful information for the FSA’s own culture research, as well as our wider activity to identify what intervention approaches work best in driving up compliance and protecting consumers.’
The LBRO’s Rob Powell applauds the way better outcomes have been achieved for businesses.
He says: ‘Crucially, it is the way they have worked positively with the FSA to deliver innovation within the context of the national regulatory system, showing that what some may see as barriers to innovation are not as inflexible as they might think.’
David Kidney, CIEH head of policy, sees the model as potentially pointing to a new approach following the FSA review of official controls. ‘This is fresh and forward-looking, given the complaint from the profession about the tyranny of inspection numbers and reports. What is lovely about it is that it puts right at the centre of the service the judgement of professionals like EHPs and I think it is the right way to go.’