Incident Management Framework

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Incident Management FrameworkVersion 1.0August 2018

Incident Management FrameworkFood Standards ScotlandVersion ControlThe Enforcement Delivery branch in FSS is responsible for maintaining this IncidentManagement Framework which will be reviewed on an annual basis. Anyqueries/feedback relating to this document should be emailed to:enforcement@fss.scotVersionDateLast reviewcarried outNext reviewdueComments1.0August 2018N/AAugust 2019First VersionContact DetailsFood Standards Scotland (FSS)The FSS Incidents Team can be contacted during office hours as follows:Tel: 01224 288 379 / 01224 285 156 / 01224 288 358E-mail: incidents@fss.scot (GSI equivalent is fssincidents@scotland.gsi.gov.uk)FSS operates a 24-hour response to food/feed incidents and can be contacted bytelephone on Tel: 07881 516 867.The Communications team can be contacted out of hours on Tel: 07776 226 856.If liaison is required with the Food Standards Agency’s Incident Teams they can becontact as follows:FSA EnglandTel: 020 7276 8448E-mail: foodincidents@food.gov.ukOut-of-hours calls to the team should be made via the Defra Duty Room Tel: 0845051 8486. The Duty Room member of staff will immediately contact the FSA on-callmember of staff to alert them to the call).FSA Wales (Consumer Protection Team)Tel: 029 2067 8899 (out-of-hours Tel: 07789 926 573)E-mail: wales.foodincidents@food.gov.ukFSA Northern Ireland (Consumer Protection Team)Tel: 028 9041 7725E-mail: incidents.ni@food.gov.ukv1.02

Incident Management FrameworkFood Standards ScotlandForewordFood Standards Scotland (FSS) was established on 1 April 2015 and is the NationalFood Body in Scotland with responsibility for ensuring food is safe, is what it says itis, and that feed controls protect animal and human health.As Chief Executive of Food Standards Scotland, it is my responsibility to ensure thatFSS acts in a timely manner during incidents which may have an impact onconsumers. It is our role to work closely with Local Authorities, Public Healthprofessionals, Scottish Government, Industry, Retailers and Trade Associations toquickly 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 withcolleagues in the Food Standards Agency to manage incidents across the UK and inEurope. A Memorandum of Understanding is in place between Food StandardsScotland and the Food Standards Agency to ensure liaison arrangements continue todeliver a coordinated incident handling response.Investigating and managing incidents to ensure that consumers are protected hasbeen, and will continue to be, a crucial aspect of all our work. Protection of publichealth will always be our first priority and maintaining confidence in the food supplysystem comes next. We accept that meeting those objectives can cause tension withbusinesses involved in incidents. However, our approach is, and always will be,determined by levels of uncertainty: the more uncertainty there is, the moreprecautionary we are likely to be to achieve our objectives. However, businessesshould be assured that our response will also be proportionate and determined bythe evidence we have.This FSS Incident Management Framework has been developed in recognition of thesize and structure of our organisation, whilst continuing to be aligned to the principlesof the FSA’s equivalent Incident Management Plan and will be reviewed regularly toensure the document continues to be fit for purpose.Geoff OgleChief ExecutiveFood Standards Scotlandv1.03

Incident Management FrameworkFood Standards ScotlandTable of ContentsForeword. 3Abbreviations . 71. Introduction . 81.1 Purpose . 81.2 Scope of response. 91.3 Governance . 101.3.1 Accountability . 101.3.2 Ownership . 101.3.3 Responsibility . 101.3.4 Delivery . 101.4 Definitions . 111.5 Objectives . 111.6 Guiding principles . 122. Structure, roles and responsibilities . 142.1 Response structure . 142.2 Team descriptions . 142.3 Incident Assessment Team (IAT) . 152.3.1 Membership of the IAT . 152.4 Operational Incident Team (OIT) . 162.4.1 Membership of the OIT . 172.4.2 OIT Members Roles and Responsibilities . 182.5 Strategic Incident Team (SIT) . 202.5.1 Membership of the SIT . 212.5.2 SIT Members Roles and Responsibilities . 222.6 Support team roles . 242.7 Branch involvement . 253. Escalation and mobilisation . 273.1 Notification . 273.2 Incident classification . 273.3 Declaring an incident. 283.4 Escalation . 284. Risk Analysis . 304.1 Risk Analysis Process. 304.2 Scientific Risk Assessment . 30v1.04

Incident Management FrameworkFood Standards Scotland4.2.1 Pre-determined scientific risk assessments . 314.3 Risk Management . 324.3.1 Making the risk management decision during a Level 1 incident . 344.3.2 Making the risk management decision during a Level 2/3/4 incident. 364.4 Risk Communication . 375 Mode of operation . 385.1 Activating teams. 385.2 Facilities . 385.3 Setting ground rules . 385.5 Information management. 395.5.1 Information management cycle . 395.6 Battle rhythm . 395.7 Concept of operation . 405.8 Communication . 415.9 Ministerial Briefings . 415.10 Stakeholder management . 415.11 Clearance process . 415.12 Resource. 415.13 Lead Agency . 425.13.1 Scottish Government central response . 425.13.2 Cross border incidents . 435.13.3 Out of hours response . 435.13.4 Shift handover. 436. Stand down . 446.1 De-escalation . 446.2 Post Incident Reviews. 446.2.1 Hot Debrief . 446.3 Lessons learned. 457. Preparedness . 467.1 Training . 467.2 Exercising . 467.3 Review . 468. Tools and templates . 478.1 IAT Meeting Agenda . 478.2 OIT Meeting Agenda . 488.3 SIT Meeting Agenda . 49v1.05

Incident Management FrameworkFood Standards Scotland8.4 Information Board . 508.5 Objectives Board . 518.6 Decision Log . 528.7 Issues & Actions Log. 538.8 Situation Report . 548.9 Stakeholder Management Matrix . 558.10 Shift Handover Log . 56Annex A – Role Profiles . 57Annex B – Role of the Board . 62v1.06

Incident Management FrameworkFood Standards al and Plant Health AgencyBusiness As UsualFood Alert For ActionFood Business OperatorFreedom of InformationFood Protection Science and SurveillanceFood Standards AgencyFood Standards ScotlandHealth Protection ScotlandIncident Assessment TeamIncident Classification MatrixIncident Communications PlanIncident Management FrameworkIncident Management PlanIncident Management Team (external)Local Food AuthorityOther Government DepartmentOperational Incident TeamOut of HoursProduct Recall Information NoticeRapid Alert System for Food and FeedRoutine Incident Management PlanRisk Management Decision Making ModelScottish Environmental Protection AgencyScottish Food Crime and Incidents UnitScottish Government Legal DepartmentScottish Government Resilience RoomScottish Health Protection NetworkStrategic Incident TeamSituation ReportSenior Management TeamStandard Operating ProcedureScientific Risk AssessmentWider Risk Assessment7

Food Standards Scotland1. Introduction1.1 PurposeThis document outlines FSS’s principles, processes and structures to be establishedwhen leading in the management of a Level 2 or above food or feed incident. In theevent of a Level 1 incident, the routine incident management plan should beconsulted.Other documents and Standard Operating Procedures (SOP) and routine incidentmanagement processes exist which also contribute to incident management.Together, these will provide the structure and guidance for the organisation torespond effectively and appropriately to any incidents or issues that have thepotential to significantly impact public health, undermine confidence in the foodsupply system; impact adversely on FSS’s reputation or ability to operate.The components of FSS’s incident management documentation are as follows:-Incident Management Framework (IMF)The IMF defines FSS’s approach to incident and crisis management, thestructures and teams that are in place to manage an incident, and provides anoverview of how the Operational Incident Team (OIT) and Strategic IncidentTeam (SIT) will operate in different classifications of incident.-Incident Management PolicyThe Policy outlines FSS’s commitment and policy obligations regardingincident management, and is included in the IMF.-OIT Incident Management Plan (IMP)The OIT IMP contains practical guidance on how to activate and manage anoperational response in the event of a serious incident, or work alongside theSIT in the event of a severe incident/crisis situation. The IMP is to be used bythe OIT members, and has been designed in a simple and user-friendly way inorder to support them.-SIT Incident Management Plan (IMP)The SIT IMP contains practical guidance on how to activate and manage astrategic response in the event of a severe incident/crisis situation. The IMP isto be used by SIT members, and has been designed in a simple and userfriendly way in order to support them.-Incident Communications Plan (ICP)The ICP outlines FSS’s communications guiding principles and processesduring incident management. The ICP contains practical guidance, tools andtemplates around developing a communication strategy, drafting messaging,stakeholder engagement and handling media enquiries.-Routine Incident Management Plan (RIMP)The RIMP contains practical guidance on how to activate and manage anoperational response in the event of a Level 1 routine incident. This is handledby the incidents team, with support from the different branches as required.v1.08INTRODUCTIONIncident Management Framework

Food Standards ScotlandIt should be noted that separate arrangements1 are in place for the multi-agencyinvestigation and control of public health incidents in Scotland, which includesoutbreaks of foodborne illness. In such cases, FSS is a member of the multi-agencyIncident Management Team (IMT) established to investigate the outbreak. As shownbelow in figure 1, FSS’s Incident Management Framework, Policy and Planscomplement other industry specific plans and guidance.Figure 1: FSS incident management documentation & supporting documentation1.2 Scope of responseFood/Feed incidents have the potential to impact on any individual nation within theUK or any combination of two or more. A Memorandum of Understanding is in placewith the Food Standards Agency (FSA) to ensure liaison arrangements deliver acoordinated incident response across the UK. For the purposes of FSS or FSA-ledIncident Management, only two jurisdictions are defined: FSS – ScotlandFSA – England, Wales and Northern IrelandThe scope of an individual incident will be considered as FSA, FSS or UK-wide.Where the scope of an incident does not extend beyond either England, Wales orNorthern Ireland, the incident will be managed by FSA, and information about suchincidents shared with FSS. Where the scope of the incident does not extend beyondScotland, the incident will be managed by FSS, and information about such incidentsshared with FSA.If an incident originates in Scotland or is initially led by FSS, and escalates to a UKwide incident, FSS will continue to lead the incident by mutual agreement, unless it isagreed that it is more appropriate for FSA to lead. The FSA‘s Incident Managementplan defines how incidents led by FSA will be managed. px?id incidentsv1.09INTRODUCTIONIncident Management Framework

Food Standards Scotland1.3 Governance1.3.1 AccountabilityUltimate accountability for incident management at FSS sits with the Chief ExecutiveOfficer. All Branch Heads have a responsibility to ensure the Incident ManagementFramework and Incident Management Plans are followed and adhered to.The FSS Board is responsible for the strategic direction of the organisation and forsupporting the Senior Management Team (SMT) in its leadership function. Anoverview of the role of the board in incident management can be found in Annex B.1.3.2 OwnershipChanges and updates to the IMF/IMP will be conducted by the Food EmergencyPlanning Manager, who is also responsible for coordinating a regular training andexercising programme. Any changes to the IMF must be approved by the SMT.1.3.3 ResponsibilityLocal Food Authority (LFA) Environmental Health Professionals have responsibilityfor enforcing legal food safety and standards requirements and verifying compliancewith the appropriate regulations in the majority of food businesses across Scotland.Trading Standards officers in Scotland have responsibility for enforcing feed safetyrequirements. Food establishments which require additional veterinary supervision(i.e. abattoirs, cutting plants, and game handling establishments) are approved andsubject to enforcement by FSS. The Food Safety Act 1990 and Regulation (EC)178/2002 provide the framework of food law applicable in Scotland commonly usedby LFA Environmental Health Professionals and FSS.1.3.4 DeliveryFSS has issued a Code of Practice 3 on behalf of Scottish Ministers which providesdirections and clear guidance to LFAs on the execution and enforcement of FoodLaw, including the investigation of incidents and outbreaks of food borne illness. Anequivalent Feed law Code of Practice also exists. FSS has also produced a guide toScottish Food and Feed Law4 which details all of the current food and feed lawapplicable in Scotland. This includes references to overarching EU Food Hygienelegislation and supporting guidance that is relevant to the investigation andenforcement action that is relevant to food incidents.Food Business Operators (FBOs) are required to inform the LFA (or FSS in the caseof an FSS enforced establishment) immediately when they have reason to believethat food which it has imported, produced, processed, manufactured or distributeddoes not comply with food safety requirements, and/or when it may be injurious tohuman health. Competent authorities should also be notified in the event of a breachof food information law and there are similar requirements in the legislation Food Law Code of Practice Scotland CTIONIncident Management Framework

Incident Management FrameworkFood Standards ScotlandIncident: any event where, based on the information available, there are concernsabout actual or suspected threats to the safety, quality or integrity of food/feed orfraud that could require intervention to protect consumers’ interests.FSS’s existing definitionCrisis: An abnormal and unstable food/feed or fraud situation that adverselythreatens public safety or threatens FSS’s strategic objectives, reputation orviability.BS11200 definition adapted for FSS.1.5 ObjectivesThe overarching objective guiding FSS’s incident management response is theprotection of public health with respect to food and feed intended to be placed on themarket.The objectives of Incident Management at FSS are to: 5Successfully identify and manage food or feed incidentsProvide informative advice to consumers during a food or feed incidentAct as the coordinating body during food or feed INTRODUCTIONapply to feed. This can be done by completing the incident report form found on theFSS website 5.1.4 DefinitionsThe following definitions are used by FSS:

Incident Management FrameworkFood Standards ScotlandPeoplePutting consumers firstPublic health and consumer protection in relation to food safety, standards &authenticity will be at the forefront of every response. All decisions willrevolve around their safety, and response teams will remain empatheticthroughout the incident and commit to providing the necessary welfare tothose affected.PreparednessPlans and proceduresFSS shall have effective plans and procedures in place to guide them in theevent of food/feed incidents affecting Scotland, or reputational incidentsaffecting the organisation. These plans shall be reviewed on a regular basisto ensure they remain fit for purpose.Professionally trained and competent staffFor all those who may be involved in managing an incident, FSS will ensurethat staff are sufficiently trained and competent to undertake the role theyhave been given. Appropriate training will take place on a regular basis.Precautionary principleAt FSS, the precautionary principle should guide all elements of incidentmanagement, including the decision to activate the incident response teams.Levels of precaution will be determined by the degree of uncertainty but beproportionate. It is better to over-react, then stand-down resources as moreinformation becomes available, rather than delay mobilisation and thetactical/strategic response.ResponseTransparencyAs far as it is possible, without releasing confidential information, FSS’sincident management response will be driven by transparency and opennessto ensure effective and proactive communication flows with all stakeholdersare in place.Speed of responseAll aspects of the incident response (i.e. decision-making, communicationand information flow) should be conducted in a timely manner. Our decisionsand actions should support compliant businesses and be effective at dealingwith non-compliant ones. Incident response teams may be required to makedifficult decisions, often on the basis of partial or incomplete information.While a speedy response is vital, it is crucial that decision-making isevidence-based, transparent and recorded.v1.012INTRODUCTION1.6 Guiding principlesThe overarching purpose of incident management at FSS is public health andconsumer protection. To ensure FSS responds in line with the objectives outlined inSection 1.5, the following principles will guide all incident management responseactivities and is applicable to each and every level of the response.

Incident Management FrameworkFood Standards ScotlandIn line with FSS’s Regulatory Strategy 6, FSS will ensure all legal obligationsare considered and there is consistent and proportionate application of thelaw when making risk management decisions.ReputationConsidering our stakeholdersAt FSS, stakeholders should be factored into the strategic decision-makingprocess required to manage an incident at all times. Consideration must alsobe given to how these decisions will impact stakeholders critical to FSS’ssuccess (including, although not limited to, the general public, employees,Scottish Government, HPS, LFAs, media etc.).Proactive communicationWhere possible, FSS will take a proactive approach to incident management,ensuring that the organisation is seen by key stakeholders as theauthoritative source of information in relation to the oads/Food Standards Scotland Regulatory Strategy.pdfv1.013INTRODUCTIONRegulation and policy

Food Standards Scotland2. Structure, roles and responsibilitiesFSS deals with many food incidents every year as outlined in the Annual Report ofIncidents 7. FSS operates a two tier incident management structure, as shown inFigure 2 below. In many cases, the Incidents Team will respond to incidents usingtheir Level 1 routine procedures. However, if a more coordinated operationalresponse is required, an OIT may be invoked. In the event strategic direction isrequired to coordinate and manage the situation, a SIT may be formed. The FoodIncidents section of the Food Law Code of Practice 8 outlines the roles of LFAs duringincident management.2.1 Response structureFigure 2: Incident Management structureIATIAT: The role of the IAT is to consider the potential implications of a situation,including threat to public safety, FSS’s operations and reputation. The IATthen agrees on the classification of the incident if required, and follows theprocesses in place to activate the OIT as needed.OIT2.2 Team descriptionsOIT: The role of the OIT in the initial stage of the incident will be to supportand manage the operational and tactical response to the incident, includingincident management, information gathering, tactical planning, internal andexternal communications, and stakeholder andards.gov.scot/downloads/Food Law Code of Practice Scotland .pdfv1.014STRUCTURE & ROLESIncident Management Framework

Food Standards ScotlandSITSIT: The SIT primarily consists of Senior Management Team (SMT) membersand, where necessary, representatives from central and local Governmentgroups and strategic industry stakeholders. The SIT provides high-levelstrategic leadership and direction to the OIT, evaluating future risks andensuring appropriate actions are taken.The SIT supports the OIT in managing its response including strategiccommunications, reputation management, senior stakeholder engagement,keeping Ministers informed, preparing for any legal implications, leading therecovery, and horizon scanning to identify any upcoming or potential risks.The SIT is also responsible for liaising with and briefing the FSS Board onincidents.2.3 Incident Assessment Team (IAT)The IAT may be activated in the event where it is unclear what level the incident isand when further information, discussion and clarif

The IMF defines FSS's approach to incident and crisis management, the structures and teams that are in place to manage an incident, and provides an overview of how the Operational Incident Team (OIT) and Strategic Incident Team (SIT) will operate in different classifications of incident. -

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