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If I had to eat out anywhere in this country today, I would choose Great Yarmouth. Not because their food is more delicious than anywhere else in the country or their ingredients more delectable (although this may be true). No. It is because their food is likely to be safer than anywhere else in the country. After a decade of compliance-based best practice and benchmarking, Great Yarmouth Council has dared to do things differently. What they have done has attracted the attention of the Environmental Health industry and highlighted what good and supportive regulation looks like.
A compliance-based enforcement-oriented target-driven system
Kate Watts, Environmental Health Manager at Great Yarmouth [see video left ’The old system’] explains that the purpose of the Food Safety service is what is says on the tin, ‘going out and ensuring that businesses are producing safe food’. The food safety system used to be very compliance based. The Food Standards Agency Code of Practice dictated not only what should happen within a service, but exactly how it should happen. What this translated to on the ground at Great Yarmouth was Kate allocating a number of inspections to the team, which they would be expected to deliver. The form these inspections took is what Environmental Health Officer, Sarah Flatman calls ‘structural inspections’ looking at the ‘walls, floors and ceilings’. Afterwards, they would head back to the office to send letters to the businesses about what they scored and their need to comply. It was an enforcement-oriented environment.
Check reveals true performance every time
What Kate and her team found when they studied their system using the Vanguard Method was an eye-opener. They discovered that they had no overt purpose but a de-facto one that consisted of meeting the targets set for the numbers of inspections carried out. The computer system reinforced this relentless focus upon inspections, designed to log that businesses had been visited within the specified time. Everything visit generated a letter. At each stage there was an escalation that was focused upon enforcement and finally prosecution for the high-end risk businesses. Kate says that there was never any permission to try something different, or if a business needed more help be able to spend more time with them. Sarah says that she disliked the work and before they transformed their service as it felt like they spent their time ‘lecturing to businesses’. Often a business’s reaction to the Food Safety team was negative, and sometimes openly hostile.
A new purpose
The team has a clear definition of purpose: ‘to ensure that food is safe for public consumption’. It is a purpose that Kate says gives the team great flexibility in trying out new things. Talking to each individual business ‘with that purpose in the back of your mind’, helps officers to focus upon whatever is needed to help the business. If there were any problems in the old system, it would have generated a long letter, with a long list of problems that needed addressing. In the new system officers have a face-to-face conversation that helps the business prioritise what is important. It also helps the environmental health officers to prioritise what they need to do to help the business create safe food. Kate says that this is where the biggest difference is. Businesses now understand that officers will keep coming back if there are problems and they will help them to improve.
Helping people: a better method than beating people up
Sarah provides one case that highlights the differences in approach between the old and new system [watch video left 'how it is different']. During an inspection a business was identified as having dirty contact points (plugs, light switches, door handles etc), within the premises. Upon Sarah’s return, the contact points were still dirty. In the old system this would have been an enforcement letter. Instead, Sarah got her hands dirty demonstrating to the cleaning staff what to do. They also showed how dirty hands spread contamination around contact points. ‘Once they saw that, it was incredible when we went back to see the change’ say Sarah ‘it was sparkling’. They had seen and understood why it was important. The staff had ‘got it’. Helping people to understand why there is a problem, and helping them to solve the problems leads to sustainable solutions and safer food for the public. Sometimes when people understand the problem they often stop the high risk activity.
Helping business to become safe & stay safe
Not all of the businesses have been assessed in the new system [watch video left 'improvement in the new system']. This will take some time. A new method of measuring performance and safety was needed, requiring the collection of baseline data (an initial visit). The baseline allows the team after the second visit to understand how effective their different ways of helping a business are. If a business gets worse or doesn’t improve different things can be tried. It is a much more effective method than sending letters for non-compliance. Kate says that in the old system ‘high risk business always stayed high risk’ they were ‘always A’s’ and now more businesses are improving. This suggests that the new approach is achieving long-term sustainability and making eating out in Great Yarmouth a safer experience for the public.
An exciting new model of regulation
The Food Standards Agency was supportive of Great Yarmouth during experimentation and in their new way of working. It is refreshing to see a regulatory body nurturing innovation and experimentation and genuinely curious to see how things could be different. Can you imagine if HMRC took the same approach with businesses instead of a threatening compliance approach? Food for thought!
For more information contact:
Vanguard consultant responsible for pioneering the work at Great Yarmouth
or the Systems Thinking Review
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