We Asked, You Said, We Did

We asked if a model transferring competency with an ability to delegate would achieve the expected benefits, of addressing identified weaknesses and establishing a sustainable process for future feed law delivery, outlined in the consultation document.

A model transferring competency with an ability to delegate would be beneficial.

Any future model would need to be adequately and sustainably resourced; support the maintenance of skills and knowledge of officers delivering official controls; provide consistency to the feed sector and maintain the benefits of local knowledge.

FSS continues to work with stakeholders through an Implementation Group and other mechanisms to develop the infrastructure to deliver the new model.

FSS asked respondents for their views on the newly developed guidance on Food Traceability, Withdrawals and Recalls within the UK Food Industry.

Respondents were broadly supportive of the guidance and supporting tools.  Comments received from respondents on the type of information that they wish to see included in the quick reference guide which would support the overarching guidance document.

Consultation responses were used to refine our final guidance document which was published on 12th March 2019.  Quick reference guide currently being produced taking into account the comments received as part of the consultation responses.

https://www.foodstandards.gov.scot/publications-and-research/publications/guidance-on-food-recalls

For views on the new legislation which will provide for centralised delivery of feed official controls 

Please see consultation responses

We considered all views and shall amend the legislation to allow full transfer of competence

Q5:

Please provide us with evidence to support your view on the amount of time required for familiarisation.

Q7:

Is our estimation of the familiarisation costs for enforcement authorities reasonable?

Q11:

Does the proposed SSI provide an effective means to enforce the requirements of novel food in future?

Response to Q5:

Disagree. It took 2.5 hours to scan roughly and absorb requirements.   

Response to Q7:

Underestimate. At least 2.5 hours to gain understanding.  No costs for the time of key staff when information is being disseminated to them.

Response to Q11:

Articles 4(1) and 4(2) should not be included in the list of offences. There is no requirement to notify Member State about intention to place food on the market, including novel food. Determination whether any ‘new’ food meets the novel food status prior of placing it on the market would be part of the FBO due diligence. The procedure for determination of novel food status and consultation process should be responsibility of the Central Food Authority (Food Standards Scotland or Food Standards Agency). Local authorities do not have capacity or expertise to determine whether the food falls within the novel food status.

Consultation comments and changes made to the Final Business Regulatory Impact Assessment

FSS feedback to R5:

Based on your feedback, our revised estimate is that the reading and understanding of the EU Regulation will take two and a half hours with a further two and a half hours for dissemination to key staff within each firm (a total of 5 hours).  This will be reflected in the Final Business Regulatory Impact Assessment.

FSS feedback to R7:

Based on your feedback, our revised estimate for the familiarisation costs have increased to two and a half hours for all 210 enforcement officers. This will be reflected in the Final Business Regulatory Impact Assessment.

FSS feedback to R11:

The Commission have consulted on an Implementing Regulation which clarifies the procedural steps to be followed in the consultation process to determine whether or not a food falls within the scope of Regulation (EU) 2015/2283.  The determination to verify whether the consultation request complies remains with the Member State.  Competent Authorities of the Member State shall be provided to the Commission by 01/03/18 and contact details will be published on the Commission’s website by 01/5/18. It is envisaged that the Competent Authority will be bodies such as Food Standards Scotland rather than local authorities. We note that Regulation (EU) 2015/2283 places a clear obligation on food business operators to determine the status of their product before being placed on the market and therefore an offence provision is necessary in the event of non-compliance with Articles 4(1) and 4(2).

Do you agree with the proposal to transpose Directive 2015/1787 removing the need for local authority check/audit monitoring for bottled spring and drinking water and what would the impacts be

Agreed with our proposal and assessment of the impact

Noted the responses

FSS asked respondents for their views on our draft regulatory strategy, and those areas of the food and feed regulatory system that may need to be changed in the future.

Respondents were broadly supportive of our proposed regulatory approach, and provided detailed views on areas of possible change highlighted in the consultation.

Consultation responses were used to refine our final regulatory strategy, which was considered and agreed by FSS at their open Board meeting on 17 May 2017, and are informing further policy development across the supporting regulatory strategy programme. 

The final regulatory strategy has now been published on the FSS website and can be found here. http://www.foodstandards.gov.scot/business-and-industry/safety-and-regulation/regulation-legislation/fss-regulatory-strategy

We asked for your comments and views on the 1st Food Standards Scotland Science, Evidence and Information Strategy.

R1: I believe that the SEI strategy is appropriate and well thought-out. Only one information I would like to see (emphasised) would have been "how" some of the outcomes and priorities would be reaches. In particular, how the relationship/collaboration with other (governmental) institutions and independent responsibilities could help achieve these objectives and outcomes would be helpful to mention. (University of Stirling)

R2: The strategy as proposed appears to be complete and appropriate for the role of the agency. The values are sensible, but as has occurred recently with the E. coli-cheese outbreak, are obviously not a given, e.g. ‘Authority’ relating to Trust. This implies that complying with the values is not an end-point, rather an ongoing attainment. The outcomes are entirely appropriate. A minor comment for ‘Working with others’ (pg 5), point 6 ‘build and maintain strategic partnerships & networks’. I would have thought that linking with other food agencies across Europe/elsewhere is critical to ensure a wide enough outlook, rather than ‘where possible’? The approach to Risk Management appears to be entirely appropriate and sensible. (James Hutton)

R3: Overall it is a good document, although I do wonder whether the average person in Scotland will understand or appreciate much of the content. If the document is for the average person its too long and needs an executive summary written in lay terms Page 1, the Act defines the objectives. these are understandable (drink might be included along with food?), and the FSS strategic outcomes are appropriate. I would like to read a bit more on the outcomes, for example when you say FSS is a trusted organization you are for example implying "obtaining and providing the correct information in a clear and timely manner so that no member of the public etc can question you as being biased or non-transparent? page 2. I have difficulty with SDSD. While good dietary recommendations and the basis for these are appropriate I do not believe that it is a government to formulate a plan to rebalance anyone's diet. It smacks of interference. If someone wants to consume a deep fried mars bar everyday for lunch, that's there business not governments. So you need to be very careful what you imply here I do not see any external expert committees being formed to provide consensus input. Is it only the people at FSS who will make decisions? if so who are they, and what are their credentials. There is no indication of consumer involvement in the decision making processes The prioritizing science, evidence & information is ok: # 5 is perhaps the most critical and requires constant review Enhancing communication: a critical component. personally I find such social media as twitter of limited value. This tends to be knee jerk responses. FSS would be better to consider the use for example of youtube video's. In the USA this is the most informative and efficient technology that can be viewed on smartphones. Building strategic partnerships.. good idea, who is going to do it. from personal experience it is difficult to obtain let alone continue. It requires constant interactions. Not a job for the timid. Governance page 7. Table excellent if you have a science background. Might be too detailed for the general public, and will they care to read the detail. The first column is written somewhat in lay terms. page 8/9 again v. good and clear if you are a scientist, not so much for the lay person the figure on page 9. again v. good if you are a scientist. (USDA).

R4: Thank you for providing the opportunity to comment on the Food Standards Scotland Science, Evidence and Information Strategy.

The strategy is welcome and sets out how FSS intends to use science, evidence and information (SEI) to deliver its strategic objectives and demonstrates a commitment to ensure that SEI underpins all of the work of the organisation. In particular, it is noted that FSS intends to ‘....work with others to increase value ... and deliver ambitious objectives and cross-cutting impact through strategic partnerships’ - an approach that we fully support. However, although the document identifies NHS Health Scotland as a key partner, it does not mention partnerships with other NHS bodies such as Health Protection Scotland, NHS board departments of public health, and NHS laboratories which we would consider as key to the successful delivery of this strategy. Similarly, partnerships with the Scottish Health Protection Network and local Integration Joint Boards will also be important.

R5:      The new science, evidence and information strategy demonstrates the prominence of science, evidence and evaluation within Food Standards Scotland.

•           NHS Health Scotland welcomes the continuation and further development of joint working with Food Standards Scotland to support the dissemination and use of science, evidence and information.

•           The strategy could be enhanced by the addition of an explicit reference to qualitative evidence.

NHS Health Scotland welcomes Food Standards Scotland’s new science, evidence and information strategy.  The new strategy clearly demonstrates the prominence of science, evidence and evaluation within Food Standards Scotland both to internal staff and external stakeholders. 

The definitions of science, evidence and information appear to focus on quantitative data.  We feel this could be enhanced by the addition of an explicit reference to qualitative evidence.  This would contribute to our understanding of why things work as they do, for example, in exploring areas such as dietary culture, as well as supporting our understanding of the quantitative data.

NHS Health Scotland agrees that linking the new science, evidence and information strategy with Food Standards Scotland values will be a particularly effective way of embedding the strategy into the structures and processes of the organisation. The evidence suggests this is likely to have the effect of normalising the use of evidence throughout the organisation as part of everyday work.  In addition, we would welcome the continuation and further development of joint working with partners to support the dissemination and use of science, evidence and information.

The three science, evidence and information themes and the actions identified capture the core mechanisms to support the effective use of evidence identified by the Alliance for Useful Information’s 2016 evidence review .  We therefore believe the strategy is strong with potential to make significant contributions to the use of evidence. (NHS health Scotland).

R6: IFST would have liked to make a formal response to this consultation but the time frame was too tight. Discussing it with our Scientific Committee members we

would just like to make the following points.

- We think this is an important document for FSS, but could be tightened up in places, with more detail

- It is positive that you have built in an evaluation plan at the outset

- It is positive that you are explicit about maintaining cross-UK collaboration, particularly in light of Brexit

- It is positive that you formally deal with public concern-assessment as part of your risk assessment approach

I hope we can continue to support FSS in the evolution of its strategies, but would appreciate a bit more lead time if possible.

R7:

The request to respond to your consultation was passed to the SDsPH for comment. HPS sent us their response and I would like to inform you that the SDsPH group chaired by Andrew Fraser would like to endorse their response.

Consultation comments and changes made to the SEI Strategy

1. General comments: Seven of the consultation responses thought that the SEI strategy overall was good, complete, appropriate and that the principles and themes were sensible for the role of FSS. One response thought that the strategy could be tightened in places with a bit more detail.  One response indicated that the strategy is strong with potential to make significant contributions to the use of evidence and that the three science, evidence and information themes and the actions identified capture the core mechanisms to support the effective use of evidence identified by the Alliance for Useful Information’s 2016 evidence review[1] . 

2. Under the SEI theme on Working with others some additional suggestions were made by respondents for inclusion including European food agencies, Health Protection Scotland, NHS health boards, Departments of public health and NHS laboratories. It was suggested that the wording of linking with other food agencies where possible should be revised to omit that wording.

One comment was positive that  the strategy is explicit about maintaining cross-UK collaboration, particularly in light of Brexit.

These suggestions have been added to our science, evidence and information landscape under key partners in Scotland on page 9 of the strategy and the where possible wording on page 8 has been omitted.   

3. Two comments were made on how FSS would measure the impact of SEI collaboration and how some of the outcomes and priorities identified in the themes would be measured.

One comment was positive that the strategy had built in an evaluation plan at the outset as part of our science governance statement summarised on page 10.

A proposed approach to measure the impact of the SEI outcomes and priorities has been provided in para 4.1-4.2 of the Board paper which the FSS Board to considered and agreed at their meeting on the 8 March 2017.

4. A comment was made about simplifying or providing a summary of the SEI strategy for consumers to make it more accessible.

One comment was positive that the strategy formally deals with public concern-assessment as part of your risk assessment approach.

FSS will provide a short paragraph on our website to indicate that the SEI strategy is a working document for FSS staff e.g. Food Standards Scotland (FSS) has produced our first Science, Evidence and Information (SEI) strategy. The working strategy helps  how FSS operates to  support our vision and priorities. The strategy will link, our organisation, our staff and our three SEI themes with actions.

5. A comment was made about methods of enhancing communication and that FSS could use you-tube videos may be a method to do this.

Under our people and skills on pages 8 and 9 of the strategy the need for FSS staff to ensure that they include a communication plan at the onset of any project where SEI are gathered or used is specifically identified. You-tube and other social media can be part of that plan.

6. A comment was made about the definitions of science, evidence and information focusing on quantitative data and that this could be enhanced by the addition of an explicit reference to qualitative evidence. 

This was originally in the strategy but has now been made explicit on Page 5.