Verner Wheelock Associates Limited
Verner Wheelock, J
The objective of this study was to carry out an evaluation of the impact of the Butchers’ Shop Licensing Regulations in Scotland, which required butchers selling both raw and cooked meat to obtain a licence from their relevant Local Authority (LA) to grant approval to trade. The aim was to learn lessons relating to the practical application of Hazard Analysis and Critical Control Point (HACCP) Principles in small food businesses. The programme consisted of:
- A detailed investigation, by questionnaire, telephone interview and personal interview, in which the relevant officials in all 32 LAs in Scotland were visited to find out views on the licensing of butchers and the way in which it was implemented.
- Visits to 198 butchers’ shops in all LA areas of Scotland to obtain the views of the butchers and to assess their food safety management systems.
- A consumer confidence study in which a sample of 1,893 meat consumers in Scotland participated.
Local Authority Study
The main findings were that Food Enforcement Officers (FEOs) felt that:
- Food safety standards had improved in butchers’ shops since the E. Coli O157 outbreak in central Scotland.
- These food safety improvements may not be attributed solely to licensing, as LAs in Scotland had taken action to improve food safety standards in the immediate aftermath of the E.coli O157 outbreak and before the Butchers’ shop Licensing Regulations were introduced in Scotland in October 2000. These improvements were made possible by the provision of additional government funds to Scottish LAs specifically directed to support the Pennington Expert Group recommendations, with improved hygiene for high risk premises the main focus.
- LAs in Scotland felt that they faced a considerable challenge in introducing the Butchers’ shop Licensing Legislation because the timescale for implementation of the legislation was tight. Furthermore, the initial guidance from FSA Scotland was not issued until May 2000 with the date for implementation of the Butchers’ shop Licensing Regulations across Scotland on 2 October 2000.
- The survey of LAs identified a lack of consistency between the implementation of the licensing legislation across Scotland.
Survey of butchers and assessment of management systems
In this part of the study 150 independent butchers and 48 supermarkets were visited. The main findings were that:
- The standards of food safety were rated as excellent, fully acceptable or acceptable in 98% of supermarkets and 86% of independents.
- 49% of the supermarkets and 76% of the independents believe that food safety within shops has improved as a result of the licensing initiative. The remainder considered that they already had very high food safety standards as steps had been taken to improve food safety within their premises immediately after the E.coli O157 outbreak.
- The training requirement specified in the legislation did not provide all the information needed to prepare for licensing.
- FSA Scotland sent butchers the guidance document on the Butchers’ Shop Licensing Legislation in May 2000. However, this guidance document did not give guidance for butchers that explained what the requirements were and how they were to be implemented as the guidance stated that “individual businesses must decide in consultation with their LAs, the most appropriate way forward for them.”
- Therefore, the independents had to rely on the FEOs for advice on what would berequired under the licensing legislation to be awarded a licence.
- From the butchers’ perspective there was a lack of consistency between the LAs in the requirements expected in order to be granted a licence.
- 47% of the independents encountered difficulties in preparing for licensing, but only 16% of the supermarkets did.
- The support provided by the FEOs to butchers was rated as highly satisfactory or satisfactory by 92% of the respondents.
- In 75% of the independent butchers’ premises, the HACCP/Separation systems were rated excellent (14%), fully acceptable (37%) or acceptable (24%) by the assessors used in this study.
- In 78% of the independent butchers’ premises, the documentation and implementation were rated as excellent (17%), fully acceptable (35%) or acceptable (26%) by the assessors used in this study.
- Many of the food safety systems were rated simple but effective, while others were rated as cumbersome and the documentation excessive by the assessors used in this study.
- There were major differences between the independent butcher’s premises and the multiples (supermarkets). Multiples operate across the country, have considerable technical resources available and devise company-wide systems and procedures, which are applied to all stores. These differences between multiples and independent butchers’ premises may need to be taken into consideration when formulating future legislation.
Consumer confidence study
The objectives of this part of the study were to:
- Establish the level of consumer awareness of the licence scheme for butchers’ shops.
- Explore consumer attitudes to the licence scheme.
- Explore consumer understanding and attitudes to food safety in butchery outlets.
- Establish levels of consumer confidence and satisfaction in food safety in butchers’ shops.
A stratified sampling plan based on behavioural and demographic criteria was used for the consumer survey. A total of 1,893 meat purchasers in Scotland participated in the survey. The results are shown in the Summary Table of Consumer Responses in Chapter 4.
It was found that 58-82% of consumers, depending on the age group surveyed, were aware of the main food safety precautions which should be taken when handling and cooking raw meat. However, the results showed that their behaviour did not always match the awareness (42-72% depending on the age group surveyed). Clearly, there is still a need to continue consumer education, especially for those aged under 30. For example, although 84% of respondents strongly agreed that it is important for butchers to wash their hands between serving raw meat and ready to eat foods, only 42% of respondents strongly agreed that they watched to ensure this was done. This suggests a possible strategy for improving and maintaining food safety standards in retail outlets is to encourage customers to take a more critical interest in procedures adopted by staff serving them.
- Butchers’ licensing in Scotland was characterised by a failure to determine in advance what precisely butchers were required to do in order to be granted a licence. There was a lack of detail provided by the guidance with respect to premises and procedures. Consequently there was widespread confusion because of the lack of agreement on how to meet the licensing requirements. There were inconsistencies between LAs on what was necessary to be awarded a licence which resulted in a loss of confidence in the authorities.
- As there was no base-line study to establish the level of food safety standards before the E.coli O157 outbreak, it has not been possible to determine the extent of any improvement due to initiatives taken immediately after the outbreak or specifically due to the impact of Butchers’ Shop Licensing Regulations.
- This study does not provide any convincing evidence that it would be beneficial to extend licensing to other sectors of food retailing.
- In any future initiative, it is essential to provide clear, definitive information on what is expected and how it is to be accomplished. This may be achieved using the approach developed by the British Retail Consortium to devise its Technical Standard for food manufacturers.
- There are fundamental differences between the independent butchers’ premises and the retail multiples, which should be taken into consideration in formulating future legislation. For example a number of weaknesses in the Home Authority Principle were identified during the study.
- The fact that, in some instances, FEOs were responsible for providing advice and making recommendations on the award of a license may have produced a conflict of interest.
- When tackling other food sectors, there is a need to conduct background research as a first step to determine:
- The current level of food safety procedures and any particular risks.
- The current procedures in place and their effectiveness in achieving acceptable standards of food safety.
- Type of management and staff.
- Management commitment to food safety.
- Availability of suitable training
- Issues which need to be addressed in a national strategy to improve food safety.
The results of the research may provide a sound basis for the development of a Technical Standard, the relevant guidance for the traders as well as the appropriate training and the protocols for inspection.
Project Code: S01011