Research into the use and perceptions of guidance on food safety and standards

This chapter draws together a range of suggestions from food businesses and food law professionals about how FSS’ guidance could be more effective. This includes identifying any gaps in existing guidance, highlighting improvements to content, accessibility and format of tools and guidance, and considering how communication between FSS, food law professionals and food businesses could be more effective.

In general, both food businesses and food law professionals felt that FSS’ guidance met most food businesses’ requirements. Food law professionals also noted that FSS may not produce guidance on a specific issue if it is addressed in FSA guidance. This typically met their needs and was not seen as problematic. 

However, a few respondents did identify some gaps where additional guidance could be beneficial. Both groups highlighted a rise in new and innovative food technologies or newly developed cooking methods for which there was limited guidance. For example, a few mentioned sous vide, which requires a vacuum sealer to cook food. One business mentioned working with food law professionals to develop guidance around slow cooking meat, welcoming their openness to help. A few food businesses also suggested providing more guidance for businesses that take part in higher-risk activities, such as homemade jarred sauces, jams, chutneys, and food made through complex processes such as pickling, curing, drying, ceviche, sashimi, and fermenting food. 

However, food law professionals had mixed views on creating guidance for such processes. While they felt new guidance could be helpful, they also acknowledged that it would be challenging and not necessarily the best use of FSS time and resources to provide guidance on niche or rare processes that could be rarely used. It was suggested that FSS remain aware of new processes and provide guidance where it is most needed or if new approaches become more commonly used.

A few food law professionals each requested more guidance that they felt could help them in their own role. These included, for example, more detailed shelf life guidance to enable food law professionals to write enforcement notices and guidance to cover a range of selling methods, for example, food being sold on online sites where food law professionals do not have oversight. 

Across the research, food businesses provided a range of examples of where they have experienced challenges in understanding or applying what they can perceive as general guidance to the practicalities of their business. Some examples of these challenges are outlined below.

Businesses that sold prepackaged food found that labelling guidance could be inconsistent or confusing. They often deferred to their food law professional to help them interpret the guidance. Specific challenges included issues with labelling products to sell at markets, labelling of compound ingredients, and labels becoming too long to fit on the packaging of small products. These businesses reflected that some of the standards can be challenging for small businesses to implement. 

Frustration was expressed by some food businesses with what they perceived as a blanket approach by enforcement bodies, where rules were applied uniformly without consideration for professional expertise or the practical realities of individual businesses. 

Some food businesses highlighted how attempts to seek clarification from official sources often resulted in vague or conflicting advice, adding to the time burden and uncertainty. A small number of businesses expressed reluctance to seek clarification from local authorities around hard-to-understand guidance due to fear that inquiries might trigger enforcement scrutiny. 

CookSafe was felt by some to contain a lot of information, which a small number described as daunting or overwhelming. Others commented that, despite its size, the guidance is not always tailored to specific businesses or their risk level. Food businesses also described adapting and customising it for their business, for example, combining multiple checklists into one daily sheet, creating their own procedures based on templates, and adjusting the requirements based on what they felt was needed for their specific operation.

This frustration that guidance can feel “one size fits all” led some businesses to call for more tailored advice for their specific business type, size, or risk profile. 

Suggestions for how this aspect could be improved included clearer signposting of what is essential for different operations and the ability to customise templates.  

One suggestion made by a few businesses was checklists of “quick start” guides for new businesses, tailored to different business types and sizes. A few suggested that guidance could be improved by including more case studies or practical examples.

A small number of food businesses and food law professionals considered how the FSS website could be used to provide more tailored information. For example, having a short questionnaire to assess the size and nature of a business that would then signpost to the most appropriate guidance or, potentially, provide personalised guidance, checklists or templates. One stakeholder suggested Artificial Intelligence (AI) could provide a legislative overview of all the factors a business might need to consider, including food safety, health and safety, etc, depending on their business.

A few food businesses commented on the need for guidance to reflect the realities of running a food business, including the pressures of time, staffing, and customer expectations. They called for guidance that not only helps ensure they are compliant but is also practical and efficient for them to use and implement. For instance, ways to improve the content of CookSafe included:

• Having a greater focus on house rules, as food law professionals felt these can be challenging for food businesses to develop.
• Including allergen information and corrective actions across the document.
• Having a more comprehensive section on high-risk foods, such as raw meat and fish, sous vide, and vacuum packing.

Others noted that guidance should be realistic about what can be achieved in different types of businesses and should not impose unnecessary burdens.

Comments on the need to seek clarification and reassurance also point to the potential need for both guidance which outlines how regulations and processes should be implemented in practice, and support for food businesses in interpreting that guidance.

A few food law professionals also called for more technical, detailed guidance to meet their needs, and to enable them to be clear about what needs to be enforced and how to do that consistently. There was a view that FSS used to produce more technical guidance, but the current guidance now focuses primarily on guidance to meet the needs of food businesses. One food law professional suggested having a separate website section for food law professionals, noting that the current website setup is better suited to food businesses.

One stakeholder called for FSS to produce guidance which covers the whole of a product supply chain. They felt that while tailored guidance might exist for different parts of a chain – e.g. a producer, processor, transport, or supplier – any missing link in that chain could create a risk for the other businesses in the chain. They also felt it was important that each business understand the importance of their part of the chain and how their work interacts with and could impact other businesses.

A recurring theme among food businesses was the need for guidance, in particular CookSafe, to be as simple, accessible and user-friendly as possible. Avoiding long passages of dense text in guidance and condensing materials was recommended, such as using bullet points and providing clear checklists for daily, weekly, and monthly tasks. Additional templates in CookSafe would be welcomed, such as on product recall and traceability, packaging, supplier approval, and document control. 

In interviews, food law professionals were clear that existing FSS guidance is generally clear and easy to understand, and that the plain language helps them support food businesses more effectively. Food law professionals acknowledged efforts by FSS to use clear examples, with one commenting that the examples provided in the labelling for prepacked for direct sale guidance were particularly useful and encouraged the continued use of this approach. A few food law professionals noted that question-and-answer sections on guidance can be helpful for food businesses.

Both food businesses and food law professionals highlighted a need to consider the accessibility of guidance in terms of the language being used and how easy it is to read and understand. Food law professionals felt that a key barrier to the use of FSS guidance was that many food business employees do not speak, or have limited proficiency in, the English language. While it was noted that some FSS guidance, such as CookSafe, is provided in different languages, it was suggested that translations should also be provided in Polish, Turkish, Greek, Iranian, Cantonese, Mandarin, Kurdish, Arabic and other Eastern European languages. Prioritising translating the most widely used guidance, namely CookSafe, was recommended. One suggested that training be provided in other languages or with subtitles in more languages. 

More broadly, a few food law professionals and a few food businesses highlighted wider literacy challenges. They expressed the view that some of those entering hospitality or retail may lack basic literacy skills or are just more visual learners. It was felt that paper copies of guidance can support those with limited digital literacy and provide a practical format for easy reference within a kitchen or on a production line. As a result, it was also felt that such audiences would also value greater use of visuals, pictures and diagrams in guidance, rather than just text.

It was also felt that visual elements could better support those for whom English is not their first language and could assist food law professionals in communicating more effectively with food businesses employing these staff.

In line with the online survey results, when food businesses were asked about their preferences for the format of guidance, a range of formats are currently used, with no consensus about which is preferred and no evident pattern in preference by type of business.

A few food businesses highlighted the value of being able to print off specific resources, such as posters or checklists, directly from the FSS website. While food law professionals noted that paper versions of some guidance can be purchased from FSS, they emphasised that many people working in food businesses still prefer paper versions of guidance and called for FSS to do more to make paper versions of guidance available. It was felt that paper copies of guidance can support those with limited digital literacy and provide a practical format for easy reference within a kitchen or on a production line, for example. Food businesses also welcomed local authorities providing them with printed copies, to save them the cost and time of printing guidance documents. 

While several food businesses suggested digital guidance could be helpful, and there is at least some support for using digital tools to save time and space, there was little consensus and no strong appetite for any one approach. Businesses suggested a range of options, such as Apps and online portals, that could be used to complete and store records electronically, receive alerts, and access up-to-date guidance. 

The functionality of the FSS website was also highlighted by food law professionals as a barrier to food businesses accessing guidance online. Among this group, 43% disagreed that ‘it is easy for food businesses to find guidance on the FSS website'.

During interviews, a few businesses and a few food law professionals suggested that FSS could offer more accessible online training modules and promote these more widely. Other suggestions by food businesses included multimedia resources, such as videos or podcasts, to support learning and engagement and present examples of best practice. Suggestions included training on how to draw up a safety management system, what hazards are, what food businesses need to do, and explaining the process, for example, food-related chronic illnesses, and not just allergens. 

Suggested improvements to the allergen training were given, mostly by food law professionals, for instance making it more practical, using more visual and interactive elements and updating content relating to very low gluten food or gluten-free food.

In interviews, several food law professionals and one stakeholder highlighted the importance of keeping existing guidance up-to-date and aligned with current legislation. In the online survey, 96% of food law professionals felt it was important that guidance is regularly updated. They highlighted some existing FSS documents that are currently out of date, such as the imported food guidance, which contains old references to border control. One food law professional commented in the survey on the need for updated dairy industry guidance, but did not elaborate. One food law professional expressed the view that FSS can be slow to publicise food alerts requiring action, such as product recalls, and felt that FSA was faster.