Food Standards Scotland
Incident Management Plan
for
Non-routine Incidents.
May 2015
v 1.0
DOCUMENT CONTROL
This Food Standards Scotland (FSS) Incident Management Plan, and its associated internally
held supporting documentation will be reviewed on an annual basis. This review will take place
following the Food Standards Agency Incident Management Plan annual review in order to
ensure the two documents remain compatible.
Version
Date of Issue
v 1.0
May 2015
For more information please contact:
Intelligence, Incidents and Delivery Assurance branch
Food Standards Scotland
Pilgrim House
Old Ford Road
Aberdeen
AB11 5RL
Tel:
01224 285100
Food Standards Scotland
Chief Executive Foreword
Food Standards Scotland (FSS) was established on 1 April 2015 and is the Scottish authority
responsible for ensuring food is safe to eat in Scotland.
As Chief Executive of Food Standards Scotland, it is my responsibility to ensure that FSS acts
in a timely manner during incidents which may have an impact on consumers. It is our role to
work closely with Local Authorities, Public Health professionals, Scottish Government, Industry,
Retailers and Trade Associations to quickly minimise the risk to consumers in the event of a
food incident.
However, the food supply chain is a global one and FSS works closely with colleagues in the
Food Standards Agency to manage incidents across the UK and in Europe. A Memorandum of
Understanding is in place between Food Standards Scotland and the Food Standards Agency
to ensure liaison arrangements continue to deliver a coordinated incident handling response.
Investigating and managing incidents to ensure that food safety is protected has been, and will
continue to be, a crucial aspect of all our work. This FSS Incident Management Plan for Nonroutine incidents has been developed in accordance with the principles of the FSA’s equivalent
Incident Management Plan and will be reviewed regularly to ensure the document continues to
be fit for purpose.
Geoff Ogle
Chief Executive
Food Standards Scotland
Table of Contents
Table of Contents
1
1
Aims, Objectives & Scope of Plan
2
2
Definition of an Incident
4
3
Management of an Incident
6
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
4
Incident Notification
Activation
Risk Assessment in response to an Incident
Escalation Decision Tree
Resilience in protracted incidents
Transition arrangements from an FSS to FSA incident
Communications Strategy
De-escalation and Closure
6
8
10
12
16
16
17
18
Formal Incident Review & Exercising
19
Annex A – Role, Responsibilities and Tasks
21
Annex B – OIDT Meeting Agenda & Membership
32
Annex C – SIT Meeting Agenda & Membership
34
Annex D – Management of UK-Wide Incidents by FSA flowchart
36
Annex E – Battle Rhythm
37
Annex F – Communications Plan
38
Annex G - Major Incidents- Preparing Scotland
40
Annex H – Glossary
43
Annex I – Food Standard Scotland’s Incident Handling Standard Operating Procedures
45
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1
Aims, Objectives & Scope of Plan
1.1
Aims
This Incident Management Plan (IMP) outlines Food Standards Scotland’s (FSS) plans
and procedures for fulfilling its responsibilities in response to non-routine food/feedrelated incidents that are led by Food Standards Scotland. Routine incidents are
handled using a Routine Incident Management plan.
The IMP will clearly define Food Standards Scotland’s response to an incident (where
the FSS takes the lead) following an actual or potential threat to the safety or integrity of
food and/or animal feed in Scotland.
This IMP is aligned with the FSA’s Incident Management Plan in place across England,
Wales and Northern Ireland and is compatible with the principles therein.
1.2
Objectives
FSS and the FSA undertake actions to ensure the greatest achievable protection to
consumers across the full geographical scope of any food or feed incident.
Hence, the objectives of this IMP are to outline FSS’s:

Lines of command, control and communication

Decision-making procedures

Clarify the lead organisation during food incidents affecting the UK

Collaboration with others
The Plan aims to address FSS’s response to a food/feed-related incident by explaining
how it will:

Ensure robust Incident Management procedures are in place

Ensure the ability to determine the key parties and resources required to
develop and implement an effective response

Ensure effective communication across all parties

Ensure effective mechanisms for escalation are in place.
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1.3
Scope of Plan
Incidents have the potential to impact on any individual nation within the UK or any
combination of two or more. For the purposes of this protocol only two jurisdictions are
defined:
FSA FSS -
England, Wales and Northern Ireland
Scotland
The scope of an individual incident will be classified as FSA, FSS or UK-wide.
Where the scope of an incident does not extend beyond either England, Wales or
Northern Ireland, the incident will be managed by FSA, and information about such
incidents shared with FSS.
Where the scope of the incident does not extend beyond Scotland, the incident will be
managed by FSS, and information about such incidents shared with FSA.
When an incident escalates from a FSA or FSS incident to a UK-wide incident, FSA will
manage the incident, although in some cases, it may be managed by FSS by mutual
agreement. For example, if an incident originates in Scotland or is initially dealt with by
FSS, it may be more efficient for FSS to continue to manage the incident in accordance
with the FSA Incident Management Plan.
This FSS Incident Management plan defines how incidents contained within Scotland
and led by Food Standards Scotland will be managed.
The FSA‘s Incident Management plan defines how FSA & UK-wide incidents led by the
Food Standards Agency will be managed.1
1
http://www.food.gov.uk/business-industry/food-incidents
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2
Definition of an Incident
For the purposes of this protocol an incident is defined as “any event where, based on the information available, there are concerns about actual
or suspected threats to the safety or integrity of food and/or feed that could require
intervention to protect consumers’ interests”.
Classification of Incidents
Assigning ‘classification labels’ to types of incident can be over prescriptive and
misleading. It is more important to recognise and understand the impacts and potential
impacts of the incident such that it is managed at the most appropriate level of
competence and authority. Rather than defining classifications of incidents, this plan
recognises 4 levels at which incidents are managed and is based on the principal of
escalating the management of the incident to those who are best able to manage the
response.
Routine incidents are those which are dealt with at the Operational level using
everyday resources and procedures. Such incidents include the majority of incidents
FSS deals with and will not require the invocation of the procedures contained within
this plan. They may involve evidence of illness, impact on vulnerable groups and
breaches of statutory limits. In some cases the public or media are likely to express
some concern. They also include incidents such as barn fires or oil spills that have an
actual or potential impact on food/and or feed.
Serious incidents are those which cannot be dealt with using everyday resources and
procedures and require decision making and resource allocation to be made at the
Tactical Level by the invocation of the Senior Incident Team. These incidents may be
localised but potentially serious, for example, large-scale contamination of food
production at a single facility which has a potential or actual public health impact.
Severe incidents are those which require Strategic level direction and support by the
invocation of the Senior Incident Team. Incidents of this type require significant crossdepartmental collaboration and communications strategy and are likely to be longer in
duration and have significant impact on resources. The horsemeat contamination
incident in 2013 would be an example of this type of incident.
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Major incidents are of such severe significance that they require a centralised
Government response, likely to require co-ordination through SGoRR and COBR
mechanisms, as appropriate. It should be noted that in the event that COBR is
established, then FSA will liaise with COBR on a UK basis.
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3
Management of an Incident
Where the scope of the incident does not extend beyond Scotland, the incident will be
managed by FSS, and information about such incidents shared with FSA.
Where the scope of an incident does not extend beyond England, Wales and/or
Northern Ireland, the incident will be managed by FSA, and information about such
incidents shared with FSS.
When an incident escalates from a FSA or FSS incident to a UK-wide incident, FSA will
manage the incident in accordance with the FSA IMP, although in some cases, it may
be managed by FSS by mutual agreement.
The flowchart in Fig 1 outlines the Food Standards Scotland Incident management
process for a non-routine Incident. The management of FSA and UK-wide incident by
FSA can be found in Annex D.
3.1
Incident Notification
FSS could be notified of an incident from its colleagues in the FSA or from a wide
range of sources including Local Authorities, Emergency services, Government
Departments and Agencies, industry bodies, individual companies, international bodies,
the media and the public.
Local Authorities (LAs) have a responsibility under Codes of Practice2 to inform Food
Standards Scotland of national or serious localised incidents.
The FSA is the national contact point for the European Commission’s Rapid Alert
System for Food and Feed (RASFF – see below) responsible for the managing of the
system in the UK. FSA would receive notification of European food/feed incidents with
the potential to affect the UK. This system is also used to inform Member States, the
European Commission and originating third countries of serious incidents or outbreaks
caused by a food/feed whose distribution is beyond the UK’s national borders.
The FSA is also the national contact point for INFOSAN (International Food Safety
Authorities Network) for communication between national food safety authorities
regarding urgent events.
Appropriate liaison arrangements are in place between FSS & FSA to share and issue
RASFF & Infosan alerts.
2
http://www.foodstandards.gov.scot/food-safety-standards/regulation-and-enforcement-food-laws-scotland/foodand-feed-law. The same is true for Local Authorities in England, Wales and Northern Ireland.
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Members of the public can report incidents directly to the FSS Incidents Team on
01224 285138/ 01224 285196 or via email ([email protected]).
Businesses and Local Authorities are asked to complete the Incident Report form found
on our website at http://www.foodstandards.gov.scot/food-safety-standards/foodincidents
The FSS Incidents Team operates a 24-hour response to food/feed incidents and can
be contacted by telephone on Tel: 07881516867
Contact details for FSA Incidents Teams across the UK are:
Scotland
Tel: 01224 285138 / 01224 285196 (24 Hour telephone: 07881 1516867)
E-mail: [email protected]
(GSI equivalent is [email protected])
England
Tel: 020 7276 8448 (out-of-hours calls to the team should be made via the Defra Duty
Room: 0845 051 8486. The Duty Room member of staff will immediately contact the
FSA on-call member of staff to alert them to the call.)
E-mail: [email protected]
Wales
Tel: 029 2067 8961 (out-of-hours telephone: 07789926573)
E-mail: [email protected]
Northern Ireland
Tel: 028 9041 7700
E-mail: [email protected]
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3.2
Activation
Once notification of an incident has been received, classification of the incident is
carried out by means of a risk assessment. The risk assessment takes into account
factors determining the scale, scope, nature and impact of the incident and also
includes a scientific assessment to determine the level of response required. This is
co-ordinated by the FSS Incident team in liaison with relevant policy and science teams
in FSS and FSA, as appropriate. Scientific risk assessments may be completed by
FSA on behalf of FSS, if necessary
The FSA will lead on risk assessment within its remit, and in areas of agreed FSA
expertise, where there is a foreseeable impact beyond Scotland. In doing this, FSA will
consult FSS with regards to any issues, evidence or analysis specific to Scotland, with
the aim of ensuring that assessments properly reflect the situation in Scotland, as far
as the evidence allows. On request by FSS, the FSA will provide input into risk
assessments being developed by FSS.
FSS will be responsible for any risk assessments within its remit that apply exclusively
in Scotland.
After these assessments, the Operational Incident Manager may consider that the
incident is business as usual and it will be managed by the Operational Incident
Delivery Team (OIDT), chaired by the Operational Incident Manager (OIM).
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3.3
Risk Assessment in response to an Incident
The purpose of assessing the risk associated with an incident is to determine the
potential scale and impact of the incident. This allows FSS to classify the incident in
terms of the level of response required by FSS and partner organisations. There are
two components of risk assessment:


Strategic Risk Assessment
Scientific Risk Assessment
Strategic Risk Assessment:
For all incidents (routine and non-routine) the Operational Incident Manager oversees a
strategic risk assessment to help assess the scale, scope, nature and impact of the
incident.
Carrying out a Strategic Assessment ensures that the all factors relevant to determining
the nature of an incident are considered. It also allows the justification for making
strategic and tactical decisions to be recorded in a structured way. It is not a scientific
methodology for assessing and quantifying risk.
The assessment looks at factors that will help determine the potential risks involved in
incident. These include indicators of risk to public health and consumer protection,
numbers of products affected, numbers of consumers potentially affected, consumer
perception, media interest, impact on business, complexity of the issue, numbers of
agencies involved and the potential impact on industry.
Guidance on the risk assessment process, including details of the Incident
Classification Matrix, is provided in the Risk Assessment Standard Operating
Procedure (held internally).
This initial assessment will be largely down to professional judgment of operational staff
carrying out the task, with oversight from the Operational Incident Manager. The
strategic risk assessment will be a living document, and updated as evidence and
information become available. It will reviewed by the TIMT and the SIMT as a standing
agenda item
Scientific Risk Assessment
To inform the Strategic Risk Assessment, a Scientific Risk assessment may also be
carried out to establish the risk associated with a particular type of incident i.e.
Microbiological, Chemical, Radiological etc. This is commissioned by the Operational
Incident manager (OIM) and involves input from scientific and policy experts from within
FSS and FSA, as required.
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For certain types of incidents, other partner organisations such as Health Protection
Scotland, Public Health England (radiological incidents), may be asked to provide
scientific risk assessments. The scientific risk assessment will consider the following:




Hazard Identification
Hazard Characterisation
Exposure assessment
Risk characterisation
In the event of a radiological emergency in the UK (including those in or affecting
Scotland), the food safety incident response will be led by the FSA unless it is mutually
agreed that FSS will take over the lead. FSS will provide the on-site response in
Scotland. Radiological Risk Assessments & Modelling are provided to FSS by the
Radiological & Novel Food Policy team in FSA.
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3.4
3
Escalation Decision Tree3
De-Escalation of an incident can be found in Section 3.8
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If after the relevant risk assessments, the Operational Incident Manager (OIM)
considers that the incident is not business as usual, he will inform the Head of
Intelligence, Incidents and Delivery Assurance branch (IIDA). They will review the
situation and consider whether the risk, complexity or scale of the incident requires
strategic direction by senior management. This review takes place using a defined
PESTLE Analysis method to aid decision making.
If Strategic direction is not required, and the incident is still affecting Scotland only, the
incident will continue to be managed by the OIM with regular updates being provided to
the Head of IIDA branch.
For FSS Major Incidents coordinated at central Government level – see Section 4.
OPERATIONAL INCIDENT DELIVERY TEAM (OIDT)
When the Operational Incident Manager (OIM) believes that escalation is required it
may be appropriate to form an Operational Incident Delivery Team (OIDT) in order to
deliver an FSS response at Operational level.
The OIDT team will:
 Handle the operational tasks associated with Incident management i.e. establish,
products effected, distribution lists, liaise with Food Business Operators, Local
Authorities, Retailers as appropriate.
 Take forward actions at the operational level as directed by the Senior Incident
Team (SIT), if established.
 Consist of representatives from the Incidents team, Communications team and
relevant Policy and Science teams.
 Review whether the incident remains a Scottish only incident.
 Use the Agenda for OIDT meetings set out in Annex B.
 Decide when to de-escalate /close an incident if a SIT was not called.
It is the secretariat’s responsibility to issue invitations to the members of all OIDT
meetings, giving details of meeting time, location and teleconference dial in details &
record accurate notes and actions from each OIDT meeting.
The OIM may decide to convene a meeting of the Operational Incident Delivery Team
meetings for routine incidents where a co-ordinated response is needed at the
operational level.
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OPERATIONAL INCIDENT MANAGER (OIM)
For each incident an OIM will be identified. This would normally be a senior official in
the IIDA branch or their appointed deputy.
The OIM is responsible for:
 Identifying incidents with the potential to escalate to a higher level of the incident
management process.
 Convening & chairing the OIDT and identifying the OIDT membership &
secretariat support at the outset.
 The operational management of the incident, implementation of decisions taken
by the SIT and is accountable to the Strategic Manager (SM).
 Ensuring the pace of operational response meets the timings of the ‘battle rhythm’
(See Annex E for a definition).
 Ensuring FSA and relevant interested parties such as Ministers, Health Protection
Scotland, etc. receive timely briefings on the progress of incident investigations.
 Notifying FSA when a decision is made to invoke the Senior Incident Team &
where appropriate, invite a FSA representative to attend.
 Identifying a deputy, with authority and responsibility, to take decisions in their
absence.
SENIOR INCIDENT TEAM (SIT)
If Strategic & Tactical direction is required by the OIM and Head of IIDA branch, this will
be provided by the SIT.
The SIT will:
 Set the overall Incident Management strategy for incidents classified as Serious
and above.
 Ensure that the strategy is effectively implemented by directing and supporting the
Operational Incident Delivery Team (OIDT), who will regularly report back on
progress.
 Consider and set the appropriate Communications Strategy
 Use the Agenda for SIT meetings set out in Annex C
The SIT will consider the following tactical & strategic aspects to an incident:
 The scope and severity of the event
 Whether an action plan is needed setting out FSA strategy
 Setting the level of engagement with stakeholders
 Availability of resources
 The timescale for resolution.
 Any legal considerations
 Review whether the incident remains a Scottish only incident.
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



Establish whether a recovery processes is required
Establish a review process
Any international or EU consequences
Decide when to de-escalate /close the incident they are leading
It is the secretariat’s responsibility to issue invitations to the members of all SIT
meetings, giving details of meeting time, location and teleconference dial in details &
record accurate notes and actions from each SIT meeting.
STRATEGIC MANAGER (SM)
The Strategic Manager (SM) is responsible for:




Evaluating the current situation and the OIM’s request for a SIT meeting. He
may decide that the incident should continue to be managed at the Operational
level or call a Senior Incident Team (SIT).
Convening & chairing the SIT and identifying the SIT membership & secretariat
support at the outset.
The tactical and strategic management of the incident and has oversight of the
response to the incident
Setting meeting timings to fit with the established ‘battle rhythm’ (battle rhythm is
defined in Annex E)
The essence of successful incident management is making sure the incident is
managed at the appropriate level by a team that has the necessary resources,
capabilities, authorities and competences to carry out the task. A decision as to
whether to escalate can seldom be made in empirical terms and judgement and
experience will always be brought to bear on the process. Ultimately it is for the
incident manager at whatever level to make a decision with the help of the
Management team.
Escalation through the incident response levels may be driven by the nature, scale and
complexity of incidents coupled with the expectations of FSS’s response.
PUBLIC SECTOR INCIDENT PROTOCOL
In the event that an incident affects the public sector in Scotland, a public sector
incident protocol, which has been tested and due to be finalised shortly, would be used
to inform all the relevant stakeholders and Scottish Government.
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3.5
Resilience in protracted incidents
During an incident with a prolonged response phase, it is the responsibility of the
Strategic Manager to establish robust resourcing arrangements at an early opportunity.
For anticipated prolonged responses all staff will be rotated to ensure sufficient rest
periods. This will be co-ordinated on a rolling basis, with strong handover procedures in
place, to ensure continuity of response.
3.6
Transition arrangements from an FSS to FSA incident
In the event that an FSS-led incident, in accordance with the Memorandum of
Understanding4 in place between FSS and FSA, evolves and is required to be led by
FSA, FSS will work with FSA to ensure the transition is as seamless as possible. FSS
and FSA use a shared incident database to aid this transition.
4
http://www.foodstandards.gov.scot/corporate-governance
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3.7
Communications Strategy
Communication during an incident is key, not just to the public but to other stakeholders
too, whether they are industry, consumer groups, the media, local authorities or other
national or international agencies. Food Standards Scotland (FSS) is committed to
being as open as possible about what we do and why we are doing it. FSS will, as a
principle:

Give consumers helpful information when they need to act

Protect enforcement action or legal proceedings by not publishing information that
may prejudice investigations, unless the need to protect consumers would require
immediate release of information.
Further information on the FSS Communications Plan can be found in Annex F.
Responsibility for communications
When a food or feed incident is particularly widespread and/or poses an immediate risk
to people’s health, FSS will co-ordinate communications within Scotland. This will
involve being the focal point for advice in Scotland to the public, industry, NonGovernment Organisations (NGOs) and local authorities, and also keeping the public
informed via the web, press releases, social media and FSS spokespeople. FSS’s role
would not extend to compiling or assembling lists of affected products, but FSS would
consider publishing any lists provided on its website.
FSS applies the same approach to risk assessment and risk management as FSA and
will manage its communication in the same proportionate and considered manner. In
the event of a UK-wide incident FSS will work in partnership with the FSA and the
relevant UK-wide organisations. FSS will lead the communications to the Scottish
media with messages and handling being agreed in advance with FSA in London.
Communication options
There are two tools which may be used to co-ordinate communications from FSS: the
Briefing Cell and Birdtable Meetings. The SIT will decide whether either or both will be
set up.
Briefing Cell
Depending on the scale of the incident, it may be appropriate to set up a dedicated
briefing cell at the Tactical Level. This is to ensure that the information management
function is fully resourced, allowing resource to be freed up for the management of the
operation. It is expected that the Head of Private Office (or appointed deputy) would
take on the role of leading the briefing cell. The Strategic Manager will ensure that the
briefing cell is adequately resourced.
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Birdtable Meetings
The purpose of the Birdtable meeting is to facilitate the effective management of the
incident by ensuring communication between all major stakeholders and partners. The
lead for communications will be involved in all briefings at an early stage to consider at
what stages key internal and external stakeholders are notified. Communications leads
in relevant stakeholder and partners organisations should be identified and shared in
advance.
Internally held Standard operating procedures detail how these meetings are arranged.
3.8
De-escalation and Closure
As the incident draws towards resolution, it may be appropriate to de-escalate its
management to a lower level or to return completely to routine business. The decision
to de-escalate will be taken by the most senior team that was set up to lead the
response i.e. If a SIT was established, then the SIT will decide whether it is appropriate
to de-escalate.
The chair of the most senior team leading the response will review any outstanding
actions to ensure it is appropriate to de-escalate and/or close the incident.
If a decision is made that a FSS response is no longer appropriate, the stand down
process will be initiated. Any decision to de-escalate or close an incident may need to
take into account any specific requirements for Recovery, as opposed to Response.
All response level changes will be communicated formally both internally and externally
to those involved in the response.
Most food incidents with the exception of radiological incidents do not a require
recovery phase unless they are linked to environmental contamination. Recovery for
major incidents will follow the procedures set out in the Scottish Government Preparing
Scotland Recovering from Emergencies Guidance5.
All serious, severe and major incidents will be subject to a full review process as
outlined in Section 4.
5
http://www.gov.scot/Resource/Doc/333504/0108885.pdf
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4
Formal Incident Review & Exercising
All serious, severe and major incidents will be subject to a full review process, including
root cause analysis methodology, including debriefing and report. A science section will
be included in all incident review reports and will cover good practice, lessons learnt
and any improvements; expertise gap analysis; speed of response and communication
of the science.
Debriefs will be carried out internally in FSS following the response to any incident or
exercise.
The sequence of debriefs is as follows6:
[1] Hot wash up or Hot debrief: Immediately after the incident or period of duty if
incident is protracted with responders
[2] Organisational debrief: within two weeks post incident
[3] Multi-agency debrief: within one month of incident where there has been multiagency involvement
[4] Post incident reports: within six weeks of incident. These will be supported by
action plans and recommendations in order to update any relevant plans and outline
any training and further exercising required.
The SIT responsible for the incident will ensure that these debriefs take place and are
adequately resourced.
Debrief reports will be submitted to the Emergency Preparedness Response and
Resilience Board (EPRRB), attended by both FSA and FSS, to identify where
improvement is needed across resilience arrangements and make sure action is taken
to address any shortcomings.
4.1
Exercising
This Incident Management Plan (IMP) will be reviewed at least annually and tested
during FSS’s Exercise Programme.
FSS will consider participation in an appropriate number of Emergency Exercises
planned by other Emergency responders as part of FSS’s exercise programme.
6
Subject to the requirement to retain confidentiality on matters that may be subject to criminal proceedings
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Participating in exercises is part of training for staff that has a role in incident response,
ensuring ongoing FSS competency in this area. The FSS training and exercise
programme ensures a sufficient number of core staff is familiar with expected roles and
procedures. Training requirements will be identified by responsible FSS managers as
part of their staff development plans within the Performance Review cycle.
This plan will also be reviewed following any changes to the relevant legislation.
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Annex A – Role, Responsibilities and Tasks
1 - Strategic Manager (SM)
Person specification
 Food Standards Scotland Chief Executive or nominated deputy
Role
 To be responsible for the strategic & tactical management of the response & the
decisions taken by the Senior Incident Team (SIT)
The SM will lead the SIT to:
 determine the scope, severity & possible timescale to resolution of the incident
 identify those responsible for delivering work-streams
 identify those responsible for initiating and maintaining contact with stakeholders
 allocate the necessary resources
 agree briefings/press statements as required.
Immediate Tasks




Decide or review the appropriate level and scale of the response
Agree the resources required to effectively respond to the incident
Convene the SIT and appoint other senior roles.
Establish and maintain regular liaison with FSS board & FSA senior management
regarding the progress of the incident.
 Provide sign off of key documents including briefing, submissions(or delegate this to a
Deputy as appropriate
Actions once response established
 To set and maintain the ‘pace’ of the incident investigation, including advising on the
Battle Rhythm and frequency and timing of SIT meetings.
 Chair regular SIT meetings
 To ensure that they have a suitable deputy to carry out this role in their absence
 Identify & establish contact with appropriate stakeholders that need to be engaged with
in the response & instruct OIDT to set up Birdtable and/or Stakeholder meetings
 Establish and maintain the Battle Rhythm
 Identify initial objectives for the Operational Delivery Team.
 Continue to assess the incident to consider if de-escalation/closure is required.
 Instigate process to identify any lessons learnt via incident review, hot wash-ups etc.
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2 – Operational Incident Manager (OIM)
Person specification
 Role would normally be carried out by a senior official in the IIDA branch (or nominated
deputy).
Role
 To effectively manage food/feed incidents to ensure that food safety is protected.
 During a significant incident, the post holder will be accountable to the Strategic
Manager for the operational management of the incident & for the implementation of
decisions taken by the Senior Incident Team (SIT) and for the delivery of the incident
investigation.
Tasks
An Operational Incident Manager’s tasks will include:
 Setting and maintaining the pace of incident investigation.
 Convene and leading Operational Incident Delivery Team meetings and attending other
incident related meetings, as appropriate
 Commenting on and officially signing off food alerts, allergy alerts, recall and withdrawal
information notices
 Identifying incidents with the potential to become more serious and for escalating these
via the Head of IIDA to the Strategic Manager to activate the Incident Management Plan
for non-routine incidents
 Ensuring the provision of timely briefings on the progress of incident investigations to the
SM and SIT
 Notifying FSA when a decision is made to invoke the Senior Incident Team and where
appropriate, invite a FSA representative to attend
 Where appropriate, identify any issues which require action by SIT
 Overseeing, where necessary, preparation of distribution flow chart, mapping out the
distribution of the potentially affected product(s)
 Identify a deputy7, with the authority and responsibility, to take decisions in their
absence.
 Allocate roles to individuals, as appropriate.
 Identify resource to ensure the Incidents Database is updated as appropriate.
 Contribute to incident reviews, hot wash-ups and debriefs.
7
In cases where the Operational Incident Manager changes during the investigation, it is vital that there is a seamless
handover.
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3 - Investigating Officer
Person specification
 Normally this role would be carried out by a member of FSS’s Intelligence, Incidents and
Delivery Assurance branch.
 The role holder must have been trained beforehand in the FSS’s incident response
procedures, which would normally be provided by the IIDA branch. Only individuals
trained in the use of the Incidents database would be allocated the role of database
management.
Role
 To investigate the incident, acting as the main contact point within the Incidents team.
During a ‘non-routine’ incident, a number of investigating officers may be assigned to an
incident, depending on the level of resource required. The Operational Incident Manager
will determine who takes on this role, taking into account officials’ workloads at the time.
 The Investigating Officer will ensure that the incident is dealt with in a timely manner, key
stakeholders (internal and external) are updated on developments and that all staff
dealing with the incident follow the Incident Management Plan.
Tasks
An Investigating Officer’s tasks will include:
 Information gathering (liaising with a range of external stakeholders including food
business operators, local authorities and other Government departments);
 Seeking rapid risk assessments to inform risk management options
 Seeking legal advice, where the legal position is unclear;
 Arranging and attending Operational Incident Delivery Team (OIDT) meetings, as
required
 Ensuring notes of meetings are recorded;
 Co-ordinating briefing (in liaison with the Briefing Cell if convened);
 Drafting food alerts, allergy alerts and product withdrawal/recall information notices;
 Preparing RASFF /FAFA/WIN/RIN notifications;
 Logging data on the Incidents Database, as appropriate
 Liaising with Local Authorities, Food Business Operators and public analysts regarding
the incident.
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4 - Incident Support Officer
Person specification
This role will be carried out by an IIDA team member of staff.
Role
 To act as a single point of contact between FSS and other Operational Partners and
Stakeholders during a significant incident, in order to clarify communication channels
and co-ordinate activities between all involved in the response.
Tasks
An Incident Liaison Officer’s tasks may include:
 Maintain a list of assisting and cooperating Government Departments, agencies and
other stakeholders and Agency Representatives;
 Assist in establishing and coordinating interagency contacts;
 Keep agencies supporting the incident aware of incident status;
 Monitor incident operations to identify current or potential cross-responder problems;
 Participate in planning meetings, providing current resource status, including limitations
and capability of assisting agency resources;
 Maintain the Incident Log.
 Ensure that they have a suitable deputy to carry out the role in their absence.
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5 - Briefing Cell Manager
Person specification
 Role would normally be carried out by Head of Private office (or nominated deputy)
Role
 To lead the Briefing Cell, overseeing the work of its members to ensure effective
information management during an incident8.
Tasks
The Briefing Cell Manager’s tasks will include:
 Chairing regular briefing cell meetings and attending other incident related meetings
(including review meetings), as required
 Overseeing co-ordination of briefing and/or submissions (e.g. to FSS board & Senior
Management Team, Ministers, etc.)
 Overseeing activation and maintenance of incident hotline
 Overseeing arrangements to ensure that Ministers across the UK are being briefed
simultaneously
 Overseeing preparation and maintenance of Incident Situation Report (ISR) and incident
timeline
 Overseeing the production and maintenance of a Q&A brief
 Overseeing co-ordination of responses to Ministers,
 Overseeing the co-ordination of responses to Freedom of Information (FOI) requests;
 Ensuring that FSA staff across the UK are briefed and ensure early and regular
stakeholder contact.
8
The activation of the briefing cell will ensure that the information management function is fully. resourced, allowing resource to be freed up for
the management of the operation.
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6 - Briefing Cell Member
Person specification
 Staff from the Incidents, Communications and Private Office teams would normally be
members of the briefing cell.
Role
To work as part of the briefing cell, set up during significant incidents to ensure effective
information management during an incident9.
Tasks
The Briefing Cell Member’s tasks will include:
 co-ordination and, where appropriate, drafting of briefing and/or submissions (e.g. to FSS
Board & Senior Management Team, Ministers, Parliamentary select committees and their
equivalents)
 activation and maintenance of incident hotline
 preparation and maintenance of Incident Situation Report (ISR) and incident timeline
(Member of Incidents team)
 where necessary, preparation of distribution flow chart, mapping out the distribution of the
potentially affected product(s)
 the production and maintenance of a Q&A brief
 co-ordination and, where appropriate, drafting of responses to Ministers Correspondence
Cases, Parliamentary and Assembly Questions and Treat Official letters
 co-ordinating and, where appropriate, collating information and drafting responses to
Freedom of Information (FOI) requests
 Attend incident review meetings.
9
The activation of the briefing cell will ensure that the information management function is fully resourced, allowing resource to be freed up for
the management of the operation.
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7 – Secretariat Support Staff
Person specification
 Role would normally be carried out by a member of the Administration pool.
Role
 To support the OIDT & SIT in ensuring that all information regarding the incident is
managed and recorded effectively to enable timely decision making and maintaining a
comprehensive audit trail.
Immediate Task
 Establish email distribution lists for the OIDT and SIT meetings, based on membership
established by the SM and OIM and update as the incident develops.
The tasks of the support staff are to:
 Issue invites to OIDT & SIT meetings as instructed by OIM and/or SM.
 Ensuring that a suitable official is available to deputise for them in their absence.
 Attending internal and/or external incident related meetings and acting as official note
taker
 Ensure that, once cleared by the Chair, a note of the actions from OIDT/SIT meetings &
other Birdtable/Stakeholder meetings, as required, is circulated to attendees and other
key staff dealing with the incident within 1 hour of the meeting
 To draft a detailed, accurate draft minutes of the meeting to be circulated to attendees
within 24 hours of the meeting.
 To ensure that a cleared final note of the meeting is circulated to key officials in a timely
manner.
 Contribute to incident reviews, formal review meetings, debriefs, hot wash-ups etc.
 Booking incident meeting rooms
 Sending out invites to incident meetings (using established distribution lists which be
maintained by the jobholder)
 Arranging tele/video - conferencing arrangements and communicating the number to
attendees
 Arranging refreshments, where needed
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8 - Legal Advisor
Person specification
 Role will be carried out by a representative from Scottish Government Legal Department
(SGLD).
Role
 To provide legal advice, as necessary, during an incident.
Tasks
The Legal Advisor’s will include:






Providing advice (orally and/or in writing) on any legal aspects of the incident, for
example where clarification is required over which legislation is most applicable in this
instance;
Attend OIDT and SIT and/or external incident related meetings, as required.
Comment on incident related documents (draft food alerts, allergy alerts,
recall/withdrawal information notices, draft notes of meetings, Q&As etc), as required.
‘Lead’ on the production of Order under the Food and Environmental Protection Act
(FEPA), emergency declarations or other legislation required to be introduced as part
of the incident response.
Contribute to incident reviews, attending formal review meetings, debriefs, hot washups etc.
Ensuring that a suitable official is available to deputise for them in their absence.
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9 - Media Spokesperson
Person specification
 Role normally carried out by a senior FSS official (e.g. Chief Executive or nominated
deputy), who has been media trained.
 Consideration should also be given to utilising one of the various chairs of the expert
scientific committees10 who advise FSS & the FSA during incidents or one of the
Government’s Chief Medical Officers. These scientific experts would provide an
‘independent’, trusted voice.
Role
 To provide media statements and interviews during incidents, in accordance with the
Communications strategy.
Tasks
The Media spokesperson main tasks are to:
 Providing media statements and interviews during the course of an incident
 Ensure they have a suitable deputy who can carry out this role in their absence
10
For example, the Chair of the Advisory Committee Novel Foods & Processes during a ‘non-routine’ novel food
incident http://acnfp.food.gov.uk/
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10 - Chief Scientific Advisor (CSA)
Person specification
 This role will be carried out by the FSS’s Chief Scientific Advisor (or nominated deputy).
Role
 To provide independent assurance and where necessary challenge FSS’s use of
science, evidence and analysis to inform its incident response.
Tasks
The Chief Scientific Advisor’s tasks may include:






Attending internal and/or external incident related meetings (e.g. Senior Incident
Team meeting, as appropriate.
Comment on key incident related documents (including internal risk assessment,
during significant incidents.
Communicates with the Government’s Chief Scientific Advisor during the incident, as
appropriate.
Ensure there is a suitable deputy to carry out this role during their absence.
Participate in emergency exercises, as appropriate.
Contribute to incident reviews, attending formal review meetings, debriefs, hot washups etc.
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11 – Head of Food Protection, Science and Surveillance
Person specification
 Role will be carried out by the FSS staff member who holds the above post.
Role
 To ensure that relevant science, evidence and analysis is identified, delivered and
properly reflected in the incident response.
Tasks
The role holder’s tasks will include:





Attending internal and/or external incident related meetings (e.g. Senior Incident
Team (SIT), as appropriate
Comment on key incident related documents (internal risk assessment (during
significant incidents), draft food alerts, allergy alerts, recall/withdrawal information
notices, draft notes of meetings, Q&As etc.)
Participate in emergency exercises, as appropriate
Contribute to incident reviews, attending formal review meetings, debriefs, hot washups etc.
Ensuring that a suitable official is available to deputise for them in their absence
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Annex B – OIDT Meeting Agenda & Membership
1.
Confirm OIDT Membership & agree nominated secretariat & distribution list
2.
Allocate Operational roles and responsibilities (kept under review)
3.
Incident status report – update from the Operational Incident Manager

Actions from SIT, as appropriate.

What do we know?

What do we need to know?
4.
Any items for immediate action (including general risk assessment)
5.
Role of FSS in the incident
6.
Strategic & Tactical aims

What they are

Review of progress towards delivering aims
7.
Science Risk Assessment (current status, uncertainties)
8.
Strategic Risk Assessment (updates, as appropriate)
9.
Review of Operational Risk
10. Legal issues

Legal basis for action - at initial meeting (kept under review)
11. Risk management actions
Distribution/traceability details, if appropriate - what do we know/need to know
12. Review of communications strategy

Delivery of timeline, ISR, Q&A, distribution maps, briefs, submissions, as required.
13. If appropriate, Stakeholder meeting arrangements
14. Resource Requirements (HR and finance)
15. AOB
16. Allocation of actions, referrals to SIT & time-scales
17. Date and time of next meeting
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OPERATIONAL INCIDENT DELIVERY TEAM (OIDT) MEMBERSHIP
Incident Ref & Brief description
Meeting Date /Time
Role
Individual
Attended

Operational Incident Manager (CHAIR)
Deputy Operation Incident Manager
Investigating Officer
Incident Support Officer
Briefing Cell Member
Communications Team rep.
Legal Advisor
Media Spokesperson
Food Safety, Science & Surveillance Team rep.
Secretariat Support Staff
In addition to roles above, identify people to be added to the Email Distribution list by
Secretariat Support staff here:
[email protected]
[email protected]
[email protected]
[email protected]
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Annex C – SIT Meeting Agenda & Membership
1.
Confirm SIT Membership, agree nominated secretariat & distribution list
2.
What are the facts and impacts of the incident?
3.
4.

Update on Incident status from the Operational Incidents Manager

Strategic Risk Assessment (current status, uncertainties)

Science Risk Assessment (current status, uncertainties)

Review of Operational Risk & Risk management decisions
What’s our Strategic intent?

Role of FSS in the incident

Strategic & Tactical aims for incident

What tasks need to be completed to achieve the intent?
What’s our main effort right now?

5.
6.
Any items for immediate action (including general risk assessment)
What resources and coordination are needed?

Resources

Consider and confirm if Incident lead should remain with FSS
Who needs to know what and when?

Review of communications strategy

Instruct OIDT/Briefing cell to arrange Stakeholder meetings, as appropriate
7.
Legal issues
8.
AOB
9.
Date and time of next meeting
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SENIOR INCIDENT TEAM (SIT) MEMBERSHIP
Incident Ref & Brief description
Meeting Date /Time
Role
Individual
Attended

FSS Chief Executive (Or nominated deputy)
(CHAIR)
Deputy Chief Executive
Director of Food Policy, Science and Evidence
Director of Operations
Operational Incident Manager
Head of Communications and Marketing
Legal Advisor
Chief Scientific Advisor
FSA representative, as required
Secretariat Support Staff
In addition to roles above, identify people to be added to the Email distribution list by
Secretariat Support staff here:
[email protected]
[email protected]
[email protected]
[email protected]
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Annex D – Management of UK-Wide Incidents by FSA flowchart
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Annex E – Battle Rhythm
This is the daily schedule of events (briefings, teleconferences, meetings etc.) that are set in
the early stages of an incident to provide structure to the incident management process.
The battle rhythm is not set in stone and intended to be flexible since the requirements for
meetings etc. may change as the incident evolves.
The Battle Rhythm should allow sufficient time between meetings for actions to be taken and
also consider any specific requirements/deadlines by which information is required i.e.
Ministerial or press briefings.
An example of Battle Rhythm is given below.
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Annex F – Communications Plan
In any food incident there are various communications areas that need to be addressed.
Communications include: internal FSS, Scottish Government, FSA and communications
across the Devolved Administrations. Other communications strategies are required to
consumers, industry, stakeholders and enforcement partners. This Annex sets out how FSS
should develop its communications approach with the various stakeholders. A
Communications Standard Operating Procedure provides two checklists for
communications: 1) an action checklist and 2) a checklist of stakeholders to communicate
with
Consumers
When an incident is considered serious and the risk posed immediate, the FSS will publish a
news story in the first instance, co-ordinating with stakeholders and partners as appropriate,
and proactively engage the public through the media, including social media. The intention
would be to reach a large number of consumers rapidly and to give context and further
explanation of the risk.
FSS will also consider informing the public about an ongoing incident the cause of which is at
the time unknown but which FSS, sometimes in conjunction with other bodies, is
investigating. A good example of this might be an outbreak of food poisoning spread over
several weeks or months where there is a spike in cases linked to a common strain of
pathogen. Often, the actual source takes time to investigate and even establishing a link to
food can be difficult to prove. However, information should be given to the public about the
outbreak and what government agencies are doing to discover the cause.
Although FSS remains of the view that it is preferable to give consumers specific information
that they can act on, it may not be possible to give specific information, especially during an
ongoing outbreak, and it is clearly unhelpful to give information which later turns out to be
wrong.
FSS aims to tell consumers the facts about an ongoing incident, even if sometimes it is not
able to identify specific products or recommend specific actions.
The FSS will state, where appropriate, what actions the Food Business Operator involved
have taken/are taking (e.g. to remove the product from sale) and advice if they have the
affected product or have already consumed it.
Alongside our traditional media routes such as news stories, our website and social media
channels will also be a primary means of communication. We will post regular updates in the
tone appropriate for each channel and respond to questions as quickly and accurately as the
nature, scale and stage of the incident allows.
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Although probably not possible in the first hours of an incident, we will consider proactive
social media outreach from senior voices during ongoing incidents, such as tweet chats or
longer blog posts which could offer background and reassurance to consumers.
Industry – businesses/trade bodies
Many incidents will require close collaboration with the industry on communications. We will
work with companies on steps they are taking to highlight a recall, such as placing
advertisements in local news or displaying point of sale notices.
On occasion FSS may still feel it necessary to publish a news story when the relevant
companies are taking all the appropriate action in withdrawing or recalling an affected
product. This may be the case if, for instance, public interest is high.
FSS will share news stories with relevant organisations, when possible, in advance of
publication. All information sent to companies before going into the public domain is supplied
to confirm factual accuracy. The FSS will be prepared to consider new information or
additional comments if they are relevant, but will retain full editorial control.
FSS will consider sharing its internal Q&As on request with companies, local authorities and
other relevant bodies involved in an incident. It will, however, not disclose information which
could prejudice current or future investigations or if the information is under embargo.
FSS staff and FSS Board
We will use our internal communications channels (e.g. Saltire) to ensure we proactively
keep staff informed of developments in major incidents. This can be supplemented in special
circumstances by email cascades to operational field staff and, in exceptional circumstances,
text messages to mobile phones. We will provide updates to the Board as and when
required.
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Annex G - Major Incidents- Preparing Scotland11
If the severity or potential severity of the incident is such that it may threaten serious damage to
human welfare or serious damage to the environment it may be classed as an ‘Emergency’ in
the terms of the Civil Contingencies Act (2004).
In Scotland, the Civil Contingencies Act 2004 (Contingency Planning) (Scotland) Regulations
2005 set out further detail on the application of the Act in Scotland, with particular regard to the
duties and roles of responders. Resilience structures in Scotland are based around 3 Regional
Resilience Partnerships (RRP) in the East, West and North of Scotland, supported by Local
Resilience Partnerships (LRP). Food Standards Scotland is not a Category 1 or 2 responder,
as defined in the act, but is part of any multi-agency response which may have an impact on
food.
In the event of an Emergency, FSS would engage with the relevant stakeholders as part of a
Scottish Multi-Agency response.
When the scale of complexity of an emergency is such that some degree of central government
co-ordination or support becomes necessary, Scottish Government will activate its emergency
response arrangements through the SG Resilience Room (SGoRR). Ministers would expect
senior FSS representation at this meeting with the relevant authority & accountability to make
decisions. The FSS representative will be expected to provide detailed information about the
ongoing incident and are encouraged to invite an additional colleague who will have a full
understanding of the tactical &operational issues, if required. It is likely that FSS’s Chief
Executive (or appointed deputy) would attend SGoRR meetings.
The precise role of SgoRR will vary depending on the nature of the emergency, but in broad
terms SGoRR will:
 Provide strategic national direction for Scotland
 Co-ordinate and support the activity of SG Directorates
 Collate and maintain a strategic picture of the emergency response with a particular focus
on response and recovery issues
 Brief Ministers
 Ensure effective communication between local, Scottish and UK levels, including the coordination of reports on the response and recovery effort.
 Support response and recovery efforts as appropriate, including allocation of national
resources
 Determine the SG’s public communication strategy and co-ordinate national public
messages.
 Disseminate national advice and information for the public, through the media
 If appropriate, liaise and work in partnership with the UK Government and the Cabinet
Office Briefing Room (COBR)
11
http://www.readyscotland.org/ready-government/preparing-scotland/
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When SGoRR is activated two groups will often meet:


SGoRR(O) which brings together the relevant senior staff from Scottish
Government, Multi-agency responders and stakeholders in preparation for the
SGoRR (Ministers) which is the Ministerial meeting to co-ordinate the incident response
and can be chaired by the First Minister or the Minister with the relevant portfolio.
CSC-SGoR which meets on an annual basis to keep under review Scottish Government’s
policies for managing the consequences of emergencies in Scotland. This sub-committee is
often chaired by the First Minister.
Cabinet Office Arrangements during a Co-ordinated UK Government Led
Emergency Response
In the event of a serious or catastrophic emergency at a UK level, the response is managed in
accordance with the Cabinet Office ‘Concept of Operations’12, which sets out arrangements
for responding to and recovering from emergencies requiring co-ordinated UK government
action. Where the Cabinet Office Briefing Room has been activated and there are food safety
issues, the Secretary of State for Health or Parliamentary Under-Secretary of State for Health
will normally represent the FSA at COBR meetings and the FSA Chief Executive or designated
deputy will brief the Minister in advance of that meeting. The National Security Council (NSC),
chaired by the Prime Minister of the UK, co-ordinates the efforts of governments departments
and agencies to safeguard UK security
Liaison between COBR and Scotland
The Cabinet Office Concept of Operations document describes in detail the mechanism of
COBR interaction with Devolved Administrations. The level of engagement depends on the
nature of the incident and where the incident occurs. There is scope for Devolved Ministers to
attend COBR in person where the incident affects their territories, with officials from the
Devolved Administrations invited to attend preparatory meetings.
In general for non-terrorist emergencies the Devolved Administrations have lead responsibility
for managing the consequences of a non-terrorist emergency as far as it affects their territory
using their own corporate response arrangements.
Fig 3 depicts liaison between Scottish and UK structures:
12
https://www.gov.uk/government/publications/the-central-government-s-concept-of-operations
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Annex H – Glossary
COBR: Cabinet Office Briefing Room.
Exposure Assessment: The qualitative and/or quantitative evaluation of the likely intake of
biological, chemical, and physical agents via food as well as exposures from other sources if
relevant.
FSA: Food Standards Agency with a remit in England, Wales and Northern Ireland.
FSS: Food Standards Scotland.
Hazard: A biological, chemical or physical agent in, or condition of, food with the potential to
cause an adverse health effect.
Hazard Characterization: The qualitative and/or quantitative evaluation of the nature of the
adverse health effects associated with biological, chemical and physical agents which may be
present in food.
Hazard Identification: The identification of biological, chemical, and physical agents capable of
causing adverse health effects and which may be present in a particular food or group of foods.
Hot Wash-up: A debrief providing an opportunity to gather lessons learned held immediately
after an incident or period of duty in the case of a protracted incident.
IIDA: The Intelligence, Incidents and Delivery Assurance branch in Food Standards Scotland.
IMP: Incident Management Plan.
INFOSAN: International Food Safety Authorities Network.
LRP: Local Resilience Partnership.
PSIP: Public Sector Incident Protocol.
RASFF: European Union’s Rapid Alert System for Food & Feed incidents.
Risk: A function of the probability of an adverse health effect and the severity of that effect,
consequential to a hazard(s) in food.
Risk Analysis: A process consisting of three components: risk assessment, risk management
and risk communication.
Risk Assessment: A scientifically based process consisting of the following steps: (i) hazard
identification, (ii) hazard characterization, (iii) exposure assessment, and (iv) risk
characterization.
Risk Characterization: The qualitative and/or quantitative estimation, including attendant
uncertainties, of the probability of occurrence and severity of known or potential adverse health
effects in a given population based on hazard identification, hazard characterization and
exposure assessment.
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Risk Communication: The interactive exchange of information and opinions throughout the
risk analysis process concerning hazards and risks, risk-related factors and risk perceptions,
among risk assessors, risk managers, consumers, industry, the academic community and other
interested parties, including the explanation of risk assessment findings and the basis of risk
Risk Management: The process, distinct from risk assessment, of weighing policy alternatives,
in consultation with all interested parties, considering risk assessment and other factors relevant
for the health protection of consumers and for the promotion of fair trade practices, and, if
needed, selecting appropriate prevention and control options.
RRP: Regional Resilience Partnership
SGLD: Scottish Government Legal Department
SGoRR: Scottish Government Resilience Room.
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Annex I – Food Standard Scotland’s Incident
Handling Standard Operating Procedures
The following Standard Operating Procedures are in place for Internal Use only
FOR INTERNAL USE ONLY
1.
Incident Notification
2.
Incident Risk Assessment
a.
Chemical
b. Radiological
c.
Microbiological
d. Incident Risk Matrix
e.
Local Authority database contact details/Public Analysts/Health boards/
3.
Communications Operating Procedure
a.
Briefing Cell
b. Birdtable meeting
c.
Stakeholder Management + contact details
d. Incidents Hotline
e.
Press Media Handling
4.
Incident Review
a.
EPRRB
b. Exercising programme
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