Incident Management Plan forNon-Routine Incidents

DOCUMENT CONTROLOwnership and maintenance of this Plan and internal supporting documentation is theresponsibility of the Resilience Team, part of the Incidents and Resilience Unit of the FoodStandards Agency. It will be reviewed on an annual basis.VersionVersion 6DateOctober 2017Reason for changeReview1

Table of ContentsChief Executive Foreword31Aims, Objectives & Scope of Plan42Definition of an Incident53Alerting, Activation, Escalation and Closure74Management of an Incident125FSA Major Incident – UK Government Response166Communication Strategy187Incident Review and Planning24Glossary25Annex A – List of Standard Operating Procedures and guides for theIncident Management PlanAnnex B – Central Government Emergency Levels compared with FSALevelsAnnex C – Which FSA Office Leads?27Annex D – The Six Strategic Questions30Annex E – Battle Rhythm31Annex F – UK Government Emergency Response32Annex G - FSA Communications Plan352829

Food Standards Agency - Incident Management PlanChief Executive ForewordThe main objective of the Food Standards Agency (FSA) in carrying out its functions is toprotect public health from risks which may arise in connection with the consumption of food,including risks caused by the way in which it is produced or supplied, and otherwise to protectthe wider interests of consumers in relation to food.Our five year Strategic Plan describes how we will work to achieve our goal of ‘food we cantrust’ and how we will continue to put consumers first in everything we do. Respondingeffectively to emergencies is critical to meeting these commitments, protecting consumers andbuilding consumer confidence in food.As the Chief Executive of the Food Standards Agency, I have ultimate responsibility forensuring that we respond effectively to all food and/or feed incidents.Investigating and managing incidents to ensure food and feed safety has been, and willcontinue to be, a crucial aspect of our work. The FSA has investigated over 22,000 food andfeed incidents since the year 2000, acting promptly to protect public health and consumerinterests. The majority of incidents are dealt with using routine incident managementprocedures, but when the nature and/or scale of an incident exceeds this scope, this plan willbe invoked.We continue to improve incident response arrangements through continuous testing,conducting lessons learnt exercises and reflection. In addition to our own internal exerciseprogramme the FSA routinely participates in cross-Government emergency exercises. Thisplan will continue to evolve as part of this learning process.We welcome feedback on the Plan as these will contribute to regular reviews, and ensure thisdocument continues to be fit for purpose. Should you wish to comment please email theResilience Team at [email protected] Feeney MBEChief ExecutiveFood Standards Agency3

Food Standards Agency - Incident Management Plan1. Aims, Objectives & Scope of PlanAimThis Incident Management Plan (IMP) outlines the FSA’s procedures for fulfilling itsresponsibilities in response to non-routine food or feed-related incidents (routine and nonroutine incidents are explained in section 2.1 Classification of Incidents). The FSA’s objective isto protect public health from risks which may arise in connection with the consumption of food(including risks caused by the way in which it is produced or supplied) and otherwise to protectthe interests of consumers in relation to food. The IMP defines the FSA’s response to anincident where the FSA takes responsibility, either by statutory requirement, in its role of LeadGovernment Department, following an actual or potential threat to the safety, quality or integrityof food and/or animal feed or as supporting Department.AIMTo set out the strategic and tactical arrangements for effective incident managementduring non-routine incidents affecting food and / or feed in order to protectconsumers.OBJECTIVESThe Plan provides a framework to meet the following objectives: Ensure robust command and control procedures are in place;Ensure effective mechanisms for escalation are in place;Ensure the ability to determine the key parties and resources required to developand implement an effective response; andEnsure effective communication across all parties.Scope of PlanThis plan provides a comprehensive framework which summarises key activities undertakenduring a response to a food and / or feed-related non-routine incident. The Plan establishescommon procedures to be followed by all FSA offices across England, Wales and NorthernIreland. Routine incidents are dealt with using a Routine Incident Management Plan (RIMP).The detailed processes which support this IMP are set out in a series of Standard OperatingProcedures and guidance (see Annex A).A Memorandum of Understanding with Food Standards Scotland (FSS) is in place to ensureliaison arrangements continue to deliver a coordinated incident handling response acrossScotland, England, Northern Ireland and Wales. The Food Standards Scotland IncidentManagement Plan defines how FSS led incidents are incident-management-plan).4

Food Standards Agency - Incident Management Plan2. Definition of an IncidentThe FSA defines an incident as:“any event where, based on the information available, there are concerns about actual orsuspected threats to the safety, quality or integrity of food and/or feed that could requireintervention to protect consumers’ interests”.2.1CLASSIFICATION OF INCIDENTSThe FSA is responsible for responding to all food and feed incidents and in the initial stages allincidents will be regarded as a potential risk to public health until there is evidence to thecontrary. An incident response will be activated for food chain integrity, food authenticity or foodfraud issues.The FSA assigns an ‘incident classification’ by recognising and understanding the potentialimpact of an incident and then considering how the incident should be managed in terms oflevels of resource and authority. This plan recognises four levels of incidents classification,Routine, Serious, Severe and Major based on the principle of escalation of management. Thehigher the level of magnitude of incident, the greater the involvement of senior FSA staff, andthe more tactical and strategic measures are brought to bear. This may be required even whenthe FSA is not the Lead Government Department (LGD).Classification DescriptionRoutine incidents which are dealt with at the operational level using everyday resources andprocedures. They make up the majority of incidents dealt with by the FSA. They may involveevidence of illness, impact on vulnerable groups and breaches of statutory limits. They alsoinclude incidents such as barn fires or oil spills that have an actual or potential impact onfood and feed. In some cases the public or media are likely to express some concern.Serious incidents are those which cannot be dealt with using everyday resources andprocedures and require decision making and resource allocation to be made at a higher leveland require the invocation of the incident Management & Co-ordination Group (IMCG) seesection 4.4.Severe incidents are those which require Strategic level input and support by the invocationof the Strategic Incident Oversight Group (SIOG) see section 4.6. Incidents of this typerequire significant cross-departmental collaboration and communications strategy and areoften longer in duration and have significant impact on resources.Major incidents are of such significance they require a Central Government coordinatedresponse. Depending on the nature of the incident the FSA may assume variousresponsibilities including acting as the Lead Government Department. An example would bea nationwide outbreak of a food-borne E. coli infection posing a high risk to public health.The E. coli outbreak in Germany in 2009 is an example of this. How FSA incidentclassification relates to the central Government emergency classification is shown in AnnexB. Other equivalent structures will apply in the Devolved Administrations (for further detailssee Annex F).5

Food Standards Agency - Incident Management Plan3. Alerting, Activation, Escalation andClosureThis section covers the alerting process for the FSA to respond to an incident and also theactivation and escalation process which ensures the incident is managed at the appropriatelevel of authority.3.1INITIAL ALERTINGInitial alerting may originate from many sources as shown in the diagram below. Incidents mayalso be notified via the EU Commission’s Rapid Alert System for Food and Feed (RASFF) orthe International Food Safety Authorities Network (INFOSAN).Local Authorities (LAs) have a responsibility under the Food Law Code of Practice (withseparate codes for England, Scotland, Wales and Northern Ireland) to inform the FSA / FSS ofnational or serious localised incidents.The FSA is also informed of incidents via other Government Departments and the emergencyservices if they consider an incident may potentially impact on food safety. Members of thepublic can report food safety concerns to the FSA helpline (020 7276 8829) or [email protected], food businesses and enforcement officers should report incidents direct to theIncidents teams across England, Wales and Northern Ireland and the equivalent reportingprocess for FSS. FSA Incidents teams in England, Wales, and Northern Ireland operate a 24/7response to food/feed and environmental contamination incidents and can be contacted bytelephone and e-mail. Information on incident reporting is available on the FSA website –‘report an incident’. FSS has its own reporting process in place as detailed within the FSSIncident Management Plan.6

Food Standards Agency - Incident Management Plan3.2 ACTIVATION AND INCIDENT ESCALATIONOn receipt of an incident notification, classification of the incident is carried out by means of anIncident Classification Assessment (see Section 3.3 Risk Assessment in Response to anIncident).If during the course of a routine incident it is considered that successful management requireslevels of resources and authority beyond those available for normal incident handling, then adecision will be made whether to escalate to non-routine incident classification levels, (as setout under Section 4 Management of an Incident). The table below shows responsibilities forincident lead, the decision to escalate and the lines of accountability, for the incidentclassification levels. The strategic direction, tactical and operational management during thecourse of an incident is subject to continuous review and adjustment.Who is Incident lead?Routine- Incident Manager- Heads of Incidents inEngland, Northern Ireland &Wales- Equivalents in FSSWho decides escalationand classification?Routine to SeriousEngland & National impactincidentAccountability- Head Incidents and ResilienceUnit– FSA Chief Operating OfficerDevolved Authorities- Heads of Consumer ProtectionSerious- The Incident Managementand Co-ordination Group(IMCG)- Chair of the IMCG- Appointed Incident ManagerSevereStrategic Lead- Strategic Incident Oversightgroup (SIOG)- 1Strategic Incident Director(SID).RoutineEngland & National impactincidentDevolved Authorities- FSA NI and FSA WalesDirectorsSerious to SevereAs for Serious Incident Lead:SeriousEngland & National impactincident- IMCG- Chair of the IMCG- Appointed Incident Manager– FSA Chief Operating OfficerSevere to Major(decision to notify the CivilContingencies Secretariat)SevereDevolved Authorities- FSA NI and FSA WalesDirectors- FSA Chief Executive Officer- SID- SIOG- SIDTactical Leads- IMCG- Chair of the IMCG- Appointed Incident ManagerMajorFSA response is the sameas for Severe1Major- FSA Chief Executive- Westminster Governmentand Devolved GovernmentMinistersThis can be a Devolved Director.7

Food Standards Agency - Incident Management PlanRapid Escalation: In the case of an obvious severe incident the escalation steps may be takenrapidly. The Head of Incidents and Resilience Unit will immediately notify the Chief OperatingOfficer, the Chief Executive and the Devolved Administration Directors. It is still important inthese instances to make sure the correct incident set up process is carried out.Major Incidents: Escalation to a Major incident will occur if the severity of the incident is suchthat it may threaten serious damage to human welfare or serious damage to the environment.In such cases it may be classed as an ‘Emergency’ in the terms of the Civil Contingencies Act(2004). Those with FSA strategic oversight responsibility will communicate with Cabinet Officeand Civil Contingencies Secretariat who then decide whether a central co-ordinatedGovernment response is required and COBR is activated.Figure showing the escalation decision process8

Food Standards Agency - Incident Management Plan3.3 RISK ASSESSMENT IN RESPONSE TO AN INCIDENTThe purpose of assessing the risk associated with an incident is to determine the potentialscale, scope, nature and impact of the incident. There are two components of riskassessment: The Incident Classification Assessment which prioritises and classifies anincident and a Scientific Assessment which determines food safety risks and informs theIncident Classification Assessment. The assessment is co-ordinated by the FSA’s IncidentsTeam with input from relevant policy teams.Incidents Classification Assessment (ICA)The Incident Classification Assessment (ICA) is a decision making process that ensures allthe factors relevant to determining the nature of an incident are considered. It is auditableand allows strategic and tactical decisions to be recorded in a structured way. It is not ascientific methodology for assessing and quantifying risk.Guidance on the assessment process is provided in the Escalation Standard OperatingProcedure. The assessment may require input from scientific and policy experts bothinternal and external (internal FSA policy teams and external Other GovernmentDepartments).The initial assessment will be largely down to professional judgment of Incidents Team staff,with oversight from the Incident Manager. The ICA will be updated as further evidence andinformation becomes available. For all incidents (routine and non-routine) the IncidentManager oversees the ICA to help assess the impact and scale of the incident.The assessment includes indicators of health effects food integrity risk numbers of products ordistribution consumers affected concern levels media perceived risk tracking and withdrawalof product known incident type political engagementScientific Risk AssessmentA scientific risk assessment will be undertaken in order to determine risks associated with anincident and informs the ICA. This is commissioned by the Incidents Team and is carried outby the science and policy experts from within the FSA and Other Government Departmentssuch as Department of Health or Public Health England (and their equivalent in NorthernIreland, Scotland and Wales) as required. The scientific risk assessment encompasses thefollowing principles: Hazard IdentificationHazard CharacterisationExposure assessmentRisk characterisation.9

Food Standards Agency - Incident Management Plan3.4 CRITERIA FOR ESCALATIONKey to successful incident response is making sure the incident is managed at the appropriatelevel. The decision to escalate can seldom be made in empirical terms and judgement andexperience will always be brought to bear on the process. Ultimately, it is for those managingthe incident to make relevant decisions.Escalation through the incident response levels is driven by the nature, scale, scope andimpact of incidents coupled with the expectations of the FSA to respond. Further information oncriteria used to assist the decision on escalation can be found in the Escalation StandardOperating Procedure. Escalation to non-routine should be considered even when the FSA isnot the LGD as a strategic /tactical response may still be required (with Strategic IncidentOversight Group (SIOG) alerted).The table below provides an illustration of how scale of impact affects the scale of FSAresponse. The table offers indicative examples to demonstrate how influences apply.MATRIX SHOWING HOW FSA INCIDENT CLASSIFICATION MAY BE APPLIED nMediaShort lived localIncreasingProlonged, Nationalinterest requiringRegional interestinterest requiringbrief statementrequiring cointense mediaordinated briefings monitoring andand statementsfrequent briefings andstatementsPublicHealthVery localised,isolated cases ofshort term minorillnessWidespread casesof illness, somerequiring shortterm hospitalisationUK wide serious andprolonged illness,isolated deathsIndustryproductOnly 1 small batchaffected from asingle sourcerequiring simpleremedial actionSeveral batchesaffected and/orfrom severalsources requiringshort term closureof plant(s)Numerous batchesaffected industry widerequiring several plantclosures for detailedinvestigationEXAMPLES OFMajorSustainednational lstatementsWidespreadnational and/orinternationaldeathsWidespreadnational tmarkets10

Food Standards Agency - Incident Management PlanConsumerConcernShort term, localconsumer concernrequiring routineinvestigation and abrief statement ofreassuranceHeightenedregional loss ofconfidence in oneor some aspects ofthe food chainrequiring specificinternalinvestigationsSignificant Nationalloss of confidence inaspects of theintegrity of the foodsupply chain in the UKrequiring co-ordinateddefensive briefingsand statementsand/or Agency wideinvestigationWidespreadloss of public /industry /internationalconfidence inthe integrity ofthe food supplychain in the UK11

Food Standards Agency - Incident Management Plan3.5 DE-ESCALATION AND CLOSUREAs the incident draws towards resolution, it may be appropriate to de-escalate to a lower levelor to return completely to routine business. The decision to de-escalate will be taken by theIncident Manager and the Chair of the IMCG. If a decision is made that a FSA response is nolonger appropriate, then a process will be initiated to close the incident. All response levelchanges will be communicated formally to those involved in the response, internally andexternally. Options to be considered during incident closure should include handing over toFSA teams that can carry out surveillance or monitor corrective measures.Any decision to de-escalate or close an incident may need to take into account any specificrequirements for recovery and the IMCG should consider the necessary strategy, resourcesand authority for successful recovery. Incidents where recovery is a consideration areradiological incidents and other environmental contamination affecting food. Recovery for majorincidents should follow the procedures set out in the Central Government Concept ofOperations (CONOPs) using command and control arrangements in place for a major incident.Once closed, all non-routine incidents are subject to incident review – See Section 7 IncidentReview and Planning.12

Food Standards Agency - Incident Management Plan4. Management of an Incident4.1 COMMAND AND CONTROL SET UP FOR NON-ROUTINE INCIDENTSOnce a non-routine Incident has been declared the following basic principles apply whensetting up command and control structure:Which Country takes the lead? The FSA operates a uniform incident response structure,applying these procedures coherently across England, Wales and Northern Ireland. The FSAincident response teams located in each FSA office, lead the response to routine incidentswithin their area. Food Standards Scotland (FSS), following their own procedures, lead onincidents within their country and work closely with the FSA and may handover the incident tothe FSA where issues have a UK wide impact. This arrangement ensures the FSA maintainsthe capability and credibility to access local intelligence and liaise on cross-border issues.Annex C shows which FSA office leads for different scales of incident.Incident Meeting Secretariat: For non-routine incidents, the Incident Secretariat will issue acalling notice for the Incident Management and Co-ordination Group meeting or a StrategicIncident Oversight Group meeting. Representation from the Devolved Administrations (andField Operations), will be included in these meetings. The default physical meeting location isthe FSA London office. However, most meetings are now virtual and the standard calling noticeincludes details of conference call dial in procedures or VC arrangements. For furtherinformation see the Non-routine Incident Secretariat Standard Operating Procedure.Role descriptions during a non-routine Incident are set in the Roles and ResponsibilitiesSOP, they include:Strategic IncidentDirectorIncident ManagerField OperationsManagerIncident OfficerChief OperatingChief ScientificOfficerAdvisorBriefing Cell Manager CommunicationsDirectorLegal AdvisorHead of Science andEvidenceMedia Spokesperson IMCG ChairNote TakerPolicy ExpertPress OfficerOperational Leads4.2 INCIDENT TEAM RESPONSEThe detailed characteristics of the Incident Team response are set out in the FSA RoutineIncident Management Plan. The Head of Incidents, based on information available, will decidewhether an incident is put forward for escalation. They will act as Incident Manager until anincident has been escalated. The Head of Incidents will ensure the Incident Team meet theirresponsibilities for incident handling. The Incident Manager may decide to convene a meetingof the Incident Management and Co-ordination Group (IMCG) for routine incidents where a coordinated response is needed.13

Food Standards Agency - Incident Management Plan4.3 INCIDENT MANAGERThe Incident Manager for Serious and above incidents is appointed by the IMCG and isaccountable to their Group Director. The Incident Manager may be the Head of Incidents, theHead of the Incidents and Resilience Unit, the Head of Consumer Protection in the DevolvedAdministrations; the Head of Division or Head / Head of Team with policy responsibility for theissue.The purpose of the Incident Manager is to take responsibility for the incident classification andthe risk management of the incident, making sure the FSA is effective in taking correctiveaction. The Incident Manager will need to be able to understand the technical issues and thenature of the risk management strategies needed.The role of the Incident Manager is deliberately separate to that of the Incident ManagementCo-ordination Group Chair, although the same person can carry out both roles. The IncidentManager will work in synergy with the Incident Management Co-ordination Group Chair.4.4 INCIDENT MANAGEMENT & CO-ORDINATION GROUP (IMCG)The purpose of the IMCG is to manage and co-ordinate the response at a tactical level for nonroutine incidents.For Severe and Major incidents the IMCG will have a role in implementing the strategy directedby the Strategic Incident Oversight Group (SIOG).Membership of the IMCG will be decided depending on the classification level of the incident.The higher level the classification the greater the expectation for more senior staff to attend.The IMCG will appoint an Incident Manager and will confirm any Operational Leads.For Serious and above incidents the IMCG will make decisions on Battle Rhythm (for definitionand examples of Battle Rhythm see Annex E), setting up of the Briefing Cell and theEmergency Call Handling Centre (as required), set up of any stakeholder liaison meetings,establishment of operational leads, staff resourcing and financing; setting taskforces to manageoperational work streams.The IMCG may consider further escalation or notification to the Civil Contingencies Secretariat.The IMCG will be maintained for the duration of non-routine incidents.The purpose, membership, and example agenda for the IMCG are set out in the IncidentManagement Co-ordination & Group Standard Operating Procedure.4.5 INCIDENT MANAGEMENT AND CO-ORDINATION GROUP CHAIRThe IMCG Chair will be the Head of Incidents and Resilience Unit, or the Head ofConsumer Protection in the Devolved Administrations.For serious incidents where there is no SIOG established and therefore no SID, the IMCG chairwill be appointed by the Chief Operating Officer the chair who will be accountable to the ChiefOperating Officer for serious incidents. In severe and major incidents where SIOG isestablished with a SID the IMCG chair will be accountable to the SID.14

Food Standards Agency - Incident Management PlanThe IMCG chair will work with the appointed Incident Manager to agree the key determinants ofthe incident management process.The IMCG Chair shall also ensure that plans for communications with external stakeholders(e.g. other Government Departments, Local Authorities, industry and consumer groups) are inplace so that they are engaged, as and where appropriate. For more information on FSACommunications Planning see Annex G.4.6 STRATEGIC INCIDENT OVERSIGHT GROUP (SIOG)The objective of the Group is to set strategy and have oversight of incidents classified asSevere and above. The Group’s deliberations will be around six key and predefined strategicquestions (see Annex D). The SIOG strategy will be passed to the IMCG for implementationand any requirements for update reports will be set.SIOG will be involved in decisions such as interaction with COBR (or its devolved equivalent)attendance and will establish strategic level cross-Government lines of communication.The purpose, membership, example agenda and template meeting note for the group are setout in the Strategic Incident Oversight Group Standard Operating Procedure.4.7 STRATEGIC INCIDENT DIRECTORThe Strategic Incident Director (SID), appointed by the Chief Executive, is responsible for thestrategic oversight of the incident. The SID will activate the strategic management structure,including convening the SIOG which they will then chair.The SID will convene briefing or stock-take meetings with their counterparts in otherGovernment Departments (OGDs) as necessary and in co-ordination with SIOG meetingtimings and the incident response battle rhythm.4.8 OPERATIONAL CASCADE BRIEFINGSAny Operational leads will be confirmed by the IMCG. They are responsible for specific areasof the FSA’s emergency response and will be expected to attend IMCG meetings and otherrelated meetings.As part of the battle rhythm it is important for operational leads to hold Cascade Briefings on aregular basis with their team members (this may be on a daily or more frequent basis). Thebriefings will cover relevant outputs from the IMCG, SIOG or bird table meetings. Tasks for theteam will be assigned, timescales agreed, quality standards set and clearance routes for worksign off will be established.For further information see the Operational Cascade Briefing Standard OperatingProcedure.4.9 RESILIENCE IN PROTRACTED INCIDENTSDuring an incident with a prolonged response phase, it is the responsibility of the IMCG, theIncident Manager, and when necessary, the Strategic Incident Director to establish robustresourcing arrangements such that staff can be rotated and rest periods provided for key staff.Rotation of staff would be co-ordinated, with handover procedures put in place.15

Food Standards Agency - Incident Management PlanA flexible approach will be employed between FSA Incident teams in the three countries (and inliaison with the FSS) to address resource shortfalls. Further to this the FSA will muster suitableresource from across its structure to support and undertake specific roles and functions as theresponse dictates. Where necessary a decision may be taken to secure additional externalresource from outside the FSA.Command and control arrangements for FSA incident response at all levels are show inthe table below:Central Government Emergency Response (Major) Co-ordinates the Central GovernmentresponseCommon Recognised InformationPicture (CRIP) Cabinet Office convene COBR and inviteFSA – FSA attendance decided by SIOGDH Public Health Minister leads – FSAofficials brief Ministers and attend OfficialsmeetingStrategic Incident Oversight Group (Severe) Chaired by Strategic Incident Director– appointed by CEOSets FSA strategy (severe and major)and has a stocktake role Answers the six strategic questions toestablish FSA response strategy (seeAnnex D)Meets according to battle rhythm (seeAnnex E)Liaises with OGD equivalents as requiredIncident Management and Co-ordination Group (Serious) Chair agreed by Chief OperatingOfficerAppoints an Incident ManagerSets incident battle rhythmTactical application of SIOG’sstrategy (when Severe or Majorincident)Reviews risk assessmentDecides risk management strategies Sets up Briefing CellEstablishes the need for Stakeholder &OGD MeetingsReceives Sit-RepsDecides a communications strategyConfirms operational leadsConfirms financial resources requiredConsiders staff resources – rotation anddeploymentManagement of Incidents (Routine) & Operational ManagementIncident Response Team: issues RASFFs issues Notices – withdrawal, recall and allergy incident loggingOther operational aspects of FSA emergency response could include for example:Briefing Cellsit-rep owner; Q & A;briefingSampling /SurveillanceSurveys/monitoringField OperationsRapid ResponseTeam (FORRT)meat concerns orlocal monitoringNational Food CrimeUnit (NFCU)organised crime /food fraud / onlineinvestigations16

Food Standards Agency - Incident Management Plan5. Major Incidents - UK GovernmentResponseIf an incident falls into the central Government emergency classification then a centralGovernment response will be initi

common procedures to be followed by all FSA offices across England, Wales and Northern Ireland. Routine incidents are dealt with using a Routine Incident Management Plan (RIMP). The detailed processes which support this IMP are set out in a series of