12. Annex 1 - Local action group and local action plan
12.1 Introduction
In Scotland, there are procedures in place to deal with high E. coli results from classified production areas. This involves introducing two levels of ‘alert states’, investigative and incident (see below for details). These ‘alert states’ facilitate a more risk-managed approach when high contamination results occur, which allows a more open and transparent system of enforcement. The two alert states also provide a rapid response facility when levels exceed pre-defined E. coli trigger levels.
12.2 Role of Local Action Groups (LAGs)
This system will operate by means of LAGs set up to deal with results out-with classification above pre-determined levels. The work will range from providing advice, to more extensive incident investigations. This may result in a temporary downgrade/closure of the affected production area, following the identification of a potential risk to public health. Each LAG is responsible for developing a Local Action Plan (LAP) and laying down investigation procedures.
The LAG will consist of Officers from the LA, local SEPA Officers and the harvester. FSS will provide the LA with results out-with classification, as is currently the case. Where necessary, the group will be involved in activities such as gathering data pertinent to local factors and/or conditions that may affect test results. The LA will hold the contact details for their LAG.
The LAG is intended to centralise communication and information sharing, while aiding in the investigation of unusual results. The exchange of information will be on an electronic basis, thus the impact on resource is expected to be minimal. The LAG encourages the sharing of expertise on specific local issues.
12.3 Establishing a Local Action Group (LAG)
All relevant LAs with classified shellfish areas are required to establish a LAG and LAP, as all will be subject to alert states if and/or when results for Class A, B or C production areas exceed levels specified above. The LAG will provide LAs with assistance in investigations of unusually high E. coli results under “Incident State”. The LAG should develop LAPs specific to local areas (with laboratory/FSS input), contributing data and local knowledge to ensure effective and timely information exchange. Electronic exchange of information is expected rather than formal meetings and is not expected to be resource intensive.
12.4 Classification
The LAG will not be able to overturn classification results or remove them from the classification data set. However, FSS will take note of any such recommendations that the LAG wishes to present. The decision on whether to act on this evidence- based recommendation will remain with FSS, with advice where necessary obtained from the laboratory and the UK NRL.
12.5 Results out with classification
The two ‘alert states’ of response for results out-with classification will be essential to ensure that the monitoring and reporting procedures are rapid. The criteria for action and implementation of the LAG and LAP are as follows:
- Incident State
- Investigative State.
12.6 Investigative State
This state will apply only to A and B production areas and is the first alert action level for results slightly out-with classification (but below the “Incident State” trigger levels).
Table 3. Investigative State Definitions
| Area Classification | Result Range | State activated |
|---|---|---|
| A | 231 – 700 E. coli /100g flesh | Investigative |
| B | 4601 – 9100 E. coli /100g flesh | Investigative |
The LA would initiate an investigation in consultation with the harvester, SEPA and FSS, if required. In instances where there is no apparent reason for the high result (e.g. heavy rainfall preceding the sample) some assistance from the LAG would be expected under the LAP in identifying a cause for the high level. The LA will need to decide what control measures are needed, but temporary closure/restrictions are not expected unless it is deemed otherwise. Further details on decisions following monitoring results can be found in the Food Law Code of Practice and Practice guidance sections relating to shellfish.
12.7 Incident State
This state will apply only to A and B production areas for results above the “investigative state” but below the “prohibited state” trigger level.
Table 4.
| Area Classification | Result Range | State activated |
|---|---|---|
| A | 701 E. coli /100g flesh and above | Incident State |
| A/B | 9101 E.coli/ 100g flesh and above | Incident State |
| A/B/C | 46000 E. coli / 100g flesh and above | Immediate TCN |
An “Incident State” is activated by the LA who notifies the relevant LAG. The LAG is required to implement the LAP to assist the authority in providing appropriate control measures. The LA should implement the necessary control measures. If the result is >46000 a TCN should be issued. If high results continue for 3 months or more, classification status is to be reconsidered by FSS.
12.8 Formulating a Local Action Plan (LAP)
In order to facilitate this process, it is recommended that the LAG set up and maintain a LAP. This should clarify the process of data collection and exchange, as well as identify what measures are to be put in place or removed when an “Incident State” occurs. The effectiveness of the LAP relies on it being tailored to specific local needs, to enhance existing measures of public health protection. Therefore, all members of the LAG should be involved in the development of the LAP and be aware of its function and scope within the two alert states as described in tables 2 and 3. LAPs should consider the appropriate action and investigations that may be required when E. coli results are out with classification and should take into account likely pollution scenarios in these circumstances. The swift implementation of the LAP is of prime importance and must contain contact details for the LAG members, FSS and other relevant personnel. All outputs from the investigation undertaken by the LAG upon implementation of the LAP should be provided to FSS.
12.9 In general terms the LAP should:
- Be sent to FSS for review and approval indicating the LA responsibilities as co-ordinator;
- Be ready for use prior to contamination events occurring. They should cover all E. coli RMPs over which the LA has responsibility;
- Detail methods and scope of communication;
- Allow for shared responsibilities with other Authorities while giving a clear indication of who takes the lead as the co-ordinator;
- Indicate who should receive information internally and externally;
- Clarify how and in what format this information will be fed back to FSS;
- Indicate criteria for lifting control measures, ending investigations and time scales for reporting of the outcome.
12.10 Checklist for the setting up LAGs and LAPs
- Contact SEPA representative to discuss preferences and identify other authorities;
- Contact harvesters to discuss preferences for being part of the group;
- Invite relevant bodies/associations with interests to be member of LAG e.g. SW representative;
- Formulate LAP based on template and recommendations in conjunction with members of the LAG;
- Notify and agree plans with FSS, who should be informed by the LAG at all relevant point.