CIEH EHN December 2021

Senior Environmental Health Officer • Chichester District Council • Up to £36,922 P27

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THE MAGAZINE FOR CIEH MEMBERS

www.cieh.org Dec 2021–Jan 2022 Volume 36 Issue 10

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THE YEAR AHEAD Challenges and opportunities for environmental health in 2022

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020 7827 5815 membership@cieh.org

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Editor

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Sarah Kovandzich editor@cieh.org

Contributing editors

Steve Smethurst, Nicola Smith

Design

Matthew Ball

Chief Sub-editor Sian Campbell

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Andrew Littlefield

Client Engagement Director Anna Vassallo

Think Media Group 20 Mortimer Street London W1T 3JW Tel: 020 3771 7200

SHUTTERSTOCK. COVER ILLUSTRATION: KERRY HYNDMAN

EHN is printed on paper made from pulp sourced from sustainable materials. It is also mailed in a wrapper that is made from potato starch and is fully compostable. You can even use it in your kitchen caddy.

The views expressed in the magazine do not necessarily reflect those of CIEH. All information is correct at the time of going to press.

Articles published in the magazine may be reproduced only with the permission of CIEH and with acknowledgement to EHN. CIEH does not accept responsibility for the accuracy of statements made by contributors or advertisers. The contents of this magazine are the copyright of CIEH. Ideas and letters to the editor are welcome.

EMILY MILES AND OTHER EXPERTS

09

LOOK AHEAD TO 2022

POLLUTION AND ITS RISK TO THE HEART

05 UPDAT E

News Pesticides in food a threat to public health; ‘significant decline’ in food standards; coronavirus research network welcomed; climate change bills battle it out in Northern Ireland Assembly; data on the effects of pollution on the heart.

EVE RY I S SU E 32 TALES FROM THE FRONT LINE Lisa Ackerley on the role of environmental health in keeping COP26 in Glasgow clean and hygienic.

G O ON L I N E Find your next job at www.ehn-jobs.com, and see how to further your career at www.cieh.org

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FEATU R E S 11 THE YEAR AHEAD Professionals share their views on the challenges and opportunities of the next 12 months.

14 MEET VICE PRESIDENT CHRIS BRERETON The former chief EHO for Wales on making environmental health’s voice heard.

16 EXPLAINER Who is entitled to call themself an EHP?

1 9 L EGAL BR I E FI NG Opinion Case shows need for effective regulation.

Prosecutions Puppy dog tales and big chain action.

2 3 YOU R CAR E E R 8 takeaways from… CIEH’s Safe Food Conference.

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WELCOME

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As COP26 negotiated the details of the Glasgow Climate Pact (ukcop26.org), the ongoing risk of COVID-19 remained on the personal agendas of delegates

Out with the old, in with…?

EMEMBER HOW A

handful of years ago, everything was about ‘2020 vision’?

Organisations and teams of all shapes and sizes seemed unable to resist the pun offered by the new decade to present a glowing vision of a future that was going to be so much better than the past. Then 2020 happened, and 2021. If we’ve learned anything, it’s that not even hindsight is 20-20 and if we can’t even agree on a single version of the past, then what hope is there for rallying around a vision of the future?

My current association with the environmental health profession began in 2021, and even in that very short time, the political and regulatory landscape has shifted enormously through the COVID-19 pandemic, Brexit and the comprehensive spending review. Throw in COP26 and we’ve barely even mentioned the headlines

R

W HO’S I NS I DE

CHRIS BRERETON “It’s up to EHPs to take advantage of existing networks or create new ones to make their voices heard”

LISA ACKERLEY “Our role was to put hygiene protocols in place to help protect the 26,000 daily attendees against COVID-19”

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of the year, let alone the myriad personal achievements, sacrifices, innovations and heartbreaks experienced by those working across the profession.

As we turn towards 2022, one question I’m left with is what it means to shape the future when it’s clear that we’re nowhere near as in control of that future as we’d like to be. While for me the idea of the corporate vision statement is tired and obsolete, we can still take time to listen to diverse perspectives on the past, on what’s happening right now, and what might be around the corner. I hope you find your own moments of joy from the past and inspiration for the future in this edition of EHN.

PHIL JAMES CIEH Chief Executive Officer DEC 2021–JAN 2022 / ENVIRONMENTAL HEALTH NEWS 3

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NEWS YOU CAN USE DEC 2021–JAN 2022 Follow us on Twitter

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‘Cocktail effect’ of pesticides in food creates threat to public health Evidence grows that chemicals can combine to become more toxic

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the UK contains a dangerous “cocktail of pesticides”, according to research by Pesticide Action Network UK (PAN). The charity analysed government data on residue levels in food consumed in the UK from 2018 to 2020 and found traces of 122 pesticides in the 12 most polluted fruit and vegetable products.

Many of the pesticides found were groundwater contaminants, potentially affecting aquatic biodiversity and drinking water quality.

PAN said 61% are classified as highly hazardous pesticides, a term used by the UN to identify substances most harmful to the environment or human health.

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The list of pesticides also included 47 with links to cancer, and 15 “reproductive or developmental toxins” that can have adverse effects on sexual function and fertility.

PAN spokesman Nick Mole said: “While safety limits continue to be set for just one pesticide at a time, evidence is growing that chemicals can combine to be more toxic, a phenomenon known as the cocktail effect.”

A spokesperson for the Department for Environment, Food & Rural Affairs (Defra) said all food sold in the UK met strict rules on pesticide residue. Defra recently consulted on a national plan to minimise the impacts of pesticides and increase the uptake of safer alternatives.

DATA

2,460

samples of 33 different types of food were tested by the government for up to 371 pesticides in 2020. Every fruit and vegetable analysed contained more than one pesticide, including:

87% of the grape samples

86%

of the orange samples

81%

of the herbs and dried fruit samples 2019 2020

30% of fruit and vegetables contained more than one pesticide in 2020, compared with 48% in 2019

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Spraying crops with pesticides leaves traces of hazardous chemicals in our food, PAN UK research shows. Defra has consulted on plans for safer alternatives to pesticides.

READ THE FULL STORY ONLINE AT bit.ly/3DbCsP7 WWW.CIEH.ORG

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‘Significant decline’ in food hygiene standards increases inspection burden

The law makes it clear that food business operators are responsible for providing safe food

Lack of enforcement officers leads to lower FHRS ratings

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Archibald said: “FBOs are not taking responsibility for maintenance, hygiene or paperwork. It’s because an enforcement officer hasn’t been out to draw their attention to what needs to be done next.

“FBOs are also using the pandemic as a reason for a drop in standards as no one is checking up on them. It’s also partly financial as some have no money to buy chemicals or to make simple repairs.”

She also reported that many businesses have not updated training on any level, with some reopening without any pre-planning about cleaning.

Gillian Dicken, principal EHO at Monmouthshire County

Council, faces a similar situation.

She said: “In 2018/19, we carried out 503 full inspections of which 33 required follow-up visits. It was similar in 2019/20, when we had 559 with 37 follow-ups.

Now, my team are telling me that four out of five premises they’ve been to need follow-up enforcement visits. That’s a significant increase.”

CIEH director Kate Thompson said it’s too early to know whether these findings are

representative of the whole food sector or a consequence of new businesses (and those that are the subject of complaints) being targeted for inspection following a lull during the pandemic.

Michael Jackson, the Food Standards Agency’s head of regulatory compliance, said: “The law is clear that it is [FBOs’] responsibility to provide safe food and they should follow all the appropriate protocols and processes to operate.”

“Four out of five premises need follow-up enforcement visits.

That’s a significant increase” GILLIAN DICKEN, MONMOUTHSHIRE COUNCIL

COUNCIL GETS SECRETARY OF STATE GO-AHEAD FOR PROSECUTION Kwasi Kwarteng MP overturns primary authority’s refusal to allow council’s enforcement action against shop

ETARY BUSINESS SECR NG MP KWASI KWARTE

A borough in north-east London has secured an application from the secretary of state for Business, Energy and Industrial Strategy to pursue legal action against a London supermarket outlet after it failed to implement

established pest control policies and procedures locally.

In April 2020, a customer bought an Easter egg from the shop, and discovered mouse droppings and fur in the packaging. They reported the incident, and the local authority sent environmental health officers to inspect the premises.

Inspectors found an active mouse infestation and served a hygiene emergency prohibition notice. The judge at the

magistrates’ court signed a declaration that the health risk condition had been fulfilled.

The council notified the primary authority (PA) that it planned enforcement action but the PA refused, arguing that the business had taken all reasonable precautions.

The issue was escalated to Kwasi Kwarteng MP, who revoked the PA decision in September 2021, allowing enforcement action to proceed.

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business operators (FBOs) are neglecting hygiene, maintenance and training because enforcement officers are unable to make the necessary visits, with environmental health professionals continuing to report a significant reduction in food hygiene standards.

Carol Archibald, team leader for food, health and safety at Tendring Council in Essex, said many food businesses have “slid quickly into poor routines” that have resulted in an increase in food hygiene improvement notices being served, leading to lower Food Hygiene Rating Scheme (FHRS) ratings.

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Update

New network adopts WHO’s ‘One Health’ approach to coronavirus research £500,000 to be spent over four years preparing for future outbreaks IEH HAS

welcomed a new coronavirus research network.

Launched in September 2021, the UK International Coronavirus Network (UK-ICN) is designed to plug the gap in understanding of the transmission of coronaviruses from animals to humans.

It has been awarded £500,000 over four years to support the delivery of collaborative scientific research into this area.

The global network, funded by the Biotechnology and Biological Sciences Research Council (BBSRC) and the Department for Environment, Food & Rural Affairs (Defra), brings together researchers from animal- and humancoronavirus communities. The partnership is between the universities of Cambridge, Edinburgh and Liverpool, plus the Animal and Plant Health Agency, the Roslin Institute and the Pirbright Institute.

The past two decades have seen three coronaviruses (SARS, MERS, SARS-CoV-2) emerge from animal reservoirs. The UK-ICN will draw on a range of expertise from different sectors, such as public health, animal health and the environment, to further the understanding of seasonality, transmission, ecology and evolution.

The network will use the ‘One Health’ approach designed by the World Health Organization (WHO), bringing

DATA

VIRUS STILL A GLOBAL THREAT COVID-19 continues to spread around the world. There have been over 250 million confirmed cases and more than five million deaths.

The US, India and Brazil have had the highest number of confirmed cases, followed by the UK, Russia and Turkey. The 100 millionth case was recorded at the end of January 2021, approximately 12 months after the first case of the virus was officially diagnosed1.

together multiple sectors and involving researchers and partners in the fields of virology, pathogenesis, genotypic markers of phenotype, transmission and immunity.

Professor Melanie Welham, BBSRC executive chair, said:

“The UK-ICN will draw on a range of expertise from different sectors, such as public health and animal health” WWW.CIEH.ORG

257,469,528

SOURCES: 1) WWW.BBC.CO.UK/NEWS/WORLD-51235105; 2) COVID19.WHO.INT

C

SARS-CoV-2 is the third coronavirus to pass from animals to humans

confirmed cases of COVID-19 globally had been reported to WHO as of 23 November 2021

5,158,211

of these had resulted in deaths, reported to WHO

7,408,870,760 vaccine doses had been administered as of 22 November 20212

“The animal-human interface remains a key and understudied research gap in the current pandemic. Understanding interactions between animals, humans and the environment is critical in preventing future zoonotic outbreaks.”

Kate Thompson, CIEH director, said: “We welcome this initiative. The pandemic has illustrated the significant global impact that diseases originating in animals can have.

“Environmental Health Practitioners have worked tirelessly over the past 18 months to prevent community transmission of the virus.

“Adopting the ‘One Health’ approach, this work will help bridge the gap in understanding the transmission of coronaviruses from animals to humans and between animal species and help us prepare for future outbreaks of zoonotic diseases.”

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Two climate change bills go head-tohead in Northern Ireland Assembly

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A compromise is needed between the visions of NI’s Green Party and DAERA

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Ireland has two competing climate change bills currently proceeding through legislative stages, with heads in Northern Ireland thrashing out action on climate change despite no binding targets.

The first, a private member’s bill, introduced by NI Green Party leader Clare Bailey, is aiming for net zero by 2045 and

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completed the first stage in the Assembly in March.

The second bill completed its first stage in July, and was introduced by the Department of Agriculture, Environment and Rural Affairs (DAERA) and its minister Edwin Poots.

It calls for an 82% reduction in greenhouse gas emissions by 2050.

The private member’s bill has wide political support and backing, but Poots has argued that the emissions targets would cause “devastation” to Northern Ireland’s farming

community, and points that aiming for to the UK Climate net zero in a Change Committee climate change Clare Bailey, NI Green which has said it bill removed Party would be “morally the temptation leader wrong” to set for different unachievable targets industry sectors for Northern Ireland. to lobby Over the summer government for calls were made for a share of the evidence and views on the remaining emissions.

DAERA bill, which closed at Net zero also offers clarity the end of September. One of and certainty, and would align the groups that responded was with the rest of the UK and the Climate Northern Ireland Ireland, although the CNI has (CNI) partnership, which urged also noted the potential £900m that NI “act now” and argued annual costs involved.

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ZERO Y DEBATES NET THE NI ASSEMBL 50 20 REDUCTION BY BY 2045 OR 82%

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AIR AND NOISE POLLUTION COMBINE TO INCREASE HEART FAILURE RISK IN WOMEN A long-term study of more than 22,000 Danish female nurses has found that prolonged exposure to air pollution and traffic pollution increases the risk of heart failure in women.

The study, published in the Journal

Call for action as Danish study reveals damaging impact when environmental factors interact WWW.CIEH.ORG

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of the American Heart Association in October 2021, showed that two common air pollutants, fine particulate matter and nitrogen dioxide, alongside traffic noise pollution, affected the heart’s ability to pump blood.

DATA THE ANALYSIS OF VARIOUS POLLUTANTS FOUND THERE WAS A

10%

increase in risk of heart failure for every 8.6µg/m3 rise in NO2 exposure over three years

12%

increase in risk of heart failure for every 9.3dB rise in road traffic noise exposure over three years

17%

increase in risk of heart failure for every 5.1µg/m3 rise in fine particulate matter exposure over three years

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THE YEAR AHEAD

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Professionals share their opinions on the challenges and opportunities for environmental health in 2022

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HE WORLD HAS

become more uncertain with the long-term social and economic consequences of the pandemic, the impacts of the UK’s EU exit and the emerging challenges of net zero,” says John Herriman, chief executive of the Chartered Trading Standards Institute – CIEH’s partner for its recent Year Ahead Conference.

“We know that regulatory services collectively rose to the challenges of COVID-19, where we demonstrated our adaptability. As we look to the future, in which we know there will be increasing consumer vulnerability, adaptability will be key.”

For Emily Miles, CEO of the Food Standards Agency (FSA), COVID-19 will continue to “cast a long shadow over all of our work”. She says: “Recovery from the pandemic will be a key priority, not least getting inspections and interventions of food businesses back on track.

“With the help of the FSA Local Authority Recovery Roadmap and the outstanding contribution of Environmental Health Practitioners (EHPs) we are getting there. A big

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thank you to all EHPs for your work in keeping us all safe over the last year.”

Highlighting other challenges, she says: “Labour shortages in hospitality, food processing, and in regulators, will continue for various reasons. I’m looking forward to the Commonwealth Games in Birmingham but I bet that will keep West Midlands EH professionals busy.

“The May elections in Northern Ireland remind us that Brexit issues are still alive and kicking. We’re expecting import controls to be introduced on

“As we look to the future, adaptability will be key” JOHN HERRIMAN

2022

some EU food imports in July, which could mean some re-engineering of supply chains. We’ll all need to respond to these changes and continue to keep the public safe.”

In housing, Alicia Kennedy, director of renter-led campaign Generation Rent, strikes an optimistic note. She says: “Right now, private renters can be evicted without reason under Section 21 and given just two months to pack up and move. Living in fear of an unfair eviction is why so many renters don’t complain when repairs need doing, undoubtedly part of the reason why 13% of privately rented homes in England are unsafe to live in. If the government sticks to its promises and brings forward the long-awaited Renters Reform Bill, these unfair evictions could end for good.

“Generation Rent will be working hard to make sure this legislation meets renters’ expectations. We have coordination across the housing sector through the Renters Reform Coalition, of which CIEH is a member.

The finish line is in sight.”

Ruth Ehrlich, policy manager at Shelter, leads on the charity’s work on private renting. She says: “Granting private renters genuine security will allow them to better

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enforce their rights but local authorities need the funding to help them do this.

“We need major investment in social housing to be a key part of the government’s Levelling Up agenda, so that people across the UK can access secure, good-quality and affordable homes.”

Matthew Copeland, head of policy and public affairs at National Energy Action (NEA), points to the dangers presented by hikes in energy prices: “The coming year represents a significant challenge for the poorest households living in the least energy-efficient homes. Many will see energy as increasingly unaffordable and begin to ration their usage. This means living in a cold, damp home, and increasing the likelihood of contracting, or exacerbating, ill health.”

There is hope, however, says Copeland: “The UK government has, for the first time in many years, committed long-term central funding to helping fuel-poor households improve their homes, with funding available for off-gas households up to 2025. They have also signalled that the transition to net zero must be ‘fair and affordable’. NEA will endeavour to ensure that the journey to decarbonisation is exactly that.”

AIR QUALITY

High on the agenda for Christopher Fry, chair of the Environmental Protection UK Board of Trustees, is air quality: “The Environment Bill will be one of the most important pieces of legislation but the Office of Environmental Protection needs to be truly independent of government to ensure compliance with standards. Air pollution is linked to climate change so both central and local government need to focus on tighter controls.

“I am most concerned about how urban air quality can be improved, especially particulates, to protect children

following the Ella Kissi-Debrah Inquest linking poor urban air quality with health impacts. Local authorities need to ensure adequate resources, with EHPs having time to take on the challenges. EHPs also have an important role in ensuring that new housing does not exacerbate poor urban air quality.

“I am optimistic that local authority EHPs, with planners, will rise to the challenge of ensuring that poor air pollution is tackled through a menu of options such as Clean Air Zones. While ground heat will have to be considered for new houses from 2025, I expect hydrogen to replace natural gas for the current 22 million homes with gas central heating. It could also be an alternative fuel for road vehicles along with pure electric and efficient hybrids.”

HEALTH AND SAFETY

For Colin Alborough, environmental health manager for Rushmoor Borough Council, the biggest challenge of 2022 in health and safety terms will be “making sure we keep the confidence, the competence and the commitment of our local authorities to resource the health and safety service”.

He adds: “We need to keep our health and safety regulatory role relevant to the working lives of our community and there’s a continuing need to link our H&S roles with good health outcomes in a more pressured, cost-sensitive environment.”

Eric Stuart, director of Gentian Events, highlights challenges facing event safety: “There are still significant shortages in the supply chain for events both physical and human. A great deal of asset such as barrier, trackway, lighting, power and fencing was sold off to ‘make ends meet’ and save storage space – it will take some time to recover.

“In addition, the UK security and stewarding industry has been decimated.

“The May elections in Northern Ireland remind us that Brexit issues are still alive and kicking” EMILY MILES We believe we have lost around 4 in 10.

My concern is that the shortages will lead to a serious safety issue when there is a really busy weekend as events get back to full speed and demand outstrips availability. I wonder how close we have come and it has not been shared.

“Health and safety professionals, especially those within local authorities and Safety Advisory Groups, need to watch carefully as plans develop – help and support those trying to do the right thing but watch out for the shysters and cowboys who have inevitably appeared and continue to take risks with public safety by cutting budgets. Safety isn’t

“The new funding won’t be enough to cover forecast demand pressures by the end of the three-year SR period”

“Air pollution is linked to climate change so both central and local government need to focus on tighter controls.“

“Watch out for the cowboys who take risks with public safety. Safety isn’t glamorous, but it does stop people dying.”

“The coming year [will be] a significant challenge for the poorest households living in the least energy-efficient homes.”

“If the government sticks to its promises and brings forward the long-awaited Renters Reform Bill, these unfair evictions could end.”

ELLIE GREENWOOD

CHRISTOPHER FRY

ERIC STUART

MATTHEW COPELAND

ALICIA KENNEDY

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BUDGET PRESSURES

Local authority budgets were top concern for Ellie Greenwood, senior adviser at the Local Government Association: “Spending Review 2021 was better than expected for councils but it won’t end the pressures and there was no additional funding for public health or environmental health services.

The new funding alongside maximum council tax income won’t be enough to cover forecast demand pressures by the end of the three-year SR period so environmental health will continue juggling a wide range of demands with too few staff due to budget pressures.”

She remains optimistic about the “expertise, dedication and commitment” of current staff, though. “I’d like to acknowledge the enormity of the role EHOs and colleagues have played throughout COVID-19, and to welcome the recognition this has received. We are trying hard to translate that into measurable improvements in resourcing.”

Chris Brereton, CIEH vice president and former chief EHO, Welsh Government, also has concerns: “In the next 12 months I hope to see a transition from response to recovery and environmental health getting back to the day job, but there will be a lot of catching up to do by officers who are already exhausted.”

The profile of EHPs is high on his 2022 list: “An opportunity will be squandered if we fail to build on the profile environmental health has hard earned during the pandemic. The service that emerges post pandemic should look and feel different to the one that preceded it.

“There will be a brief period when the enhanced links with national government and devolved administrations might allow for a fresh look at the professional identity and value given to EHOs. “I’m optimistic local government and CIEH will use this unique opportunity to work together to seek legislative recognition for the profession.”

The profile of EH is also key for Dr Lisa Ackerley, director of medical and scientific engagement, hygiene, at Reckitt: “We have to make sure people know why we’re so valuable to the country. We need to push to ensure that we’re back in control of the investigation of infectious diseases on the ground and people understand our value.”

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glamorous and doesn’t sell tickets, but it does stop people dying.”

UPCOMING REGULATORY CHANGES

In 2021, senior representatives from central and local government worked together through the CrossGovernment Regulatory Task and Finish Group to provide a joined-up approach to addressing regulatory issues. One of the challenges identified by the group was the difficulty for local authorities in planning ahead.

A resulting outcome was that the government has committed to circulating details of planned changes to regulatory activity and new regulations to help local authorities plan ahead. In July 2021, the

government circulated a ‘Forward look’ calender of upcoming change expected to affect LA regulatory services. The most recent ‘Forward look’ covers up to the end of the first quarter of 2022 – see below (with the lead government department indicated in italics).

The FSA also published its LA Recovery Plan, providing a framework and expectations for food control activities up to June 2023, setting out their expectations around priorities.

Visit www.food.gov.uk/sites/default/ files/media/document/fsa-21-05-02local-authority-recovery.pdf

‘FORWAR D LO OK’ : PL AN N E D C HANG E S I N 2 0 2 2 JANUARY 2022 l Port Health Authority (PHA)/LA at authorised Border Control Posts (BCPs) implement full documentary checks on High Risk Food Not of Animal Origin (HRFNAO), and implement physical checks on Products of Animal Origin certain ABP, germinal products and HRFNAO. l Checks of high priority plants and plant products will move from places of destination to designated BCPs.

l Introduction of pre-notification requirements and documentary checks, including phytosanitary certificates, for low risk plants and plant products.

(Lead department: Defra – bio security checks / FSA – imported food safety)

number of days on which temporary events may be held at such premises from 21 to 26.

(Lead dept: Home Office)

JANUARY 2022 l Increase in the allowance of temporary event notices (TENs) that a licensed premises can give from 15 to 20 and the maximum

MARCH 2022 l PHA/LA at authorised BCPs will introduce live animal checks and checks on low risk plants and plant products (Lead dept: Defra/FSA)

Q1 2022 l Compulsory cat microchipping (Lead dept: Defra)

In 2022 there will be more checks at UK ports

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MAKING OURSELVES HEARD

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In the latest of our series of interviews with CIEH vice presidents, Chris Brereton explains his determination to be a proactive voice for environmental health

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N DECEMBER 2019,

Chris Brereton was awarded the OBE for services to environmental and public health – it marked his retirement from the post of chief environmental health officer (EHO), Welsh Government.

However, his retirement was short-lived as he returned to help in the response to the first wave of COVID-19. Any plans to put his feet up following this were ended when he was persuaded by CIEH president Julie Barratt to put his experience and contacts to good use as a vice president.

“I worked with Julie in the 1980s at Basildon Council in Essex,” says Chris, “and more recently when she was director of CIEH in Wales. I knew there was little point arguing with her.”

Chris brings his experience of a devolved administration to the role of CIEH vice president: “We have worked hard in Wales to ensure Environmental Health Practitioners (EHPs) are a respected and authoritative part of the public health system. They are listened to at a government level when it comes to developing public health policy, legislation and delivery to protect our communities.

“I want that to continue and grow.

To do so will require adequate local authority funding for environmental health, new training opportunities, clearer career paths,

CA R E E R H IG H L IG H TS Chris’s career began in England, qualifying as an EHO in London and gaining further qualifications in pollution control, health and safety and business management (MBA).

He moved to Wales in 1982 to join Cardiff Council as an EHO before going on to strategic management posts at director level. Prior

to joining the Welsh Government in 2006, he was responsible for delivering all the functions of environmental health and public protection. He has more than 40 years’ professional experience, 30 of which have been at a strategic level.

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enhanced professional development, recognition and long-term workforce plans to ensure we have the right people to do the job.”

INFLUENCING POLICY

Chris is also a member of the Welsh Food Advisory Committee (WFAC). “My first job was as an EHO in the food team,” he says.

“My career took me into other areas, but my passion for food safety was rekindled when I attended the public inquiry into the 2005 food poisoning outbreak of E.coli 0157 on behalf of Chris at the sealing the Welsh Government.” ceremony in Cardiff, Wales had just when the Public suffered its largest Health (Wales) Bill outbreak of E.coli, became an Act of the Assembly with 157 cases. More than 30 people were hospitalised and a five-year-old child had died.

“Listening to the evidence and assisting in the implementation of the Pennington Report recommendations had a WWW.CIEH.ORG

interview: VP Chris Brereton, 1 OUTBREAKS AND INFLUENCE The E.coli 0157 outbreak of 2005 had a powerful effect on Chris Brereton, reinforcing his belief in the importance of food safety

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Below: The Senedd building, home of the Welsh Parliament

lasting effect on me,” says Chris. “It brought home to me the vital role that EHOs can play in preventing outbreaks of this kind.”

The WFAC advises the Food Standards Agency (FSA) about food policy relating to Wales: “It’s a powerful committee as the FSA is required to take the advice of WFAC into account when carrying out its functions or advising ministers. For me, it’s about environmental health having a voice and a seat at the table.

“I’m reminded of the old adage,” he says, “‘If you are not at the table then you’re probably on the menu’. If EHPs want to influence policy, they need to be present when it’s being debated and made. Ideally, you should aim to get in early and be listened to well before opinions harden.

Influencing policy is not a passive process, you need to be proactive.

“At Welsh Government level, politicians are incredibly busy. Realistically, you need to target other opinion formers. Within the civil service, this means policy team leaders, deputy directors and directors.

Within government it includes special advisers and researchers.

“It takes time to respond to consultation requests and prepare evidence to give at WWW.CIEH.ORG

“If EHPs want to influence policy, they need to be present when it’s being debated and made” scrutiny committees and speak to the media but that’s the price of having a voice and influencing policy. It’s up to EHPs to take advantage of existing networks or create new ones to make their voices heard.”

A SEAT AT THE TABLE

In terms of the challenges facing the profession, Chris acknowledges that resources have been stretched: “The demands on the public sector EH service won’t go away,” he says. “CIEH has been working hard on the resources side by looking at how we attract people to the profession, their capability, qualifications and mentoring in order to sustain and grow the environmental health workforce.

“We need to do more on the demand side by taking a closer look at the cumulative effect of new burdens on services. This goes back to having a seat at the table. By doing so you can not only look at the content of new regulations but also how they will best be enforced and sustainably funded.”

Chris, who describes himself as ‘trustworthy, approachable and persevering’ says: “I’m not sure I’m obstinate but I am determined. I like to get things done and I don’t give up easily.”

He sees these attributes as extremely relevant to his role as a CIEH vice president: “We have a voice and we need to use it to make ourselves heard,” he says.

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A QUESTION OF ENTITLEMENT

Who is entitled to call themself an Environmental Health Practitioner (EHP)? Here, the leadership team clarify the issue that has vexed the profession for years ART PRODUCTION CLIENT

EHRB LIMITATIONS

In the past individuals could describe themselves as EHPs once they were admitted to the EHRB register, but a previous review acknowledged that the EHRB register was not without its flaws.

Admission to the register was for life, was not tied to any evidence of continuing professional development or professional conduct and did not reflect in any way on the practitioners or their career stage.

The discontinuance of EHRB gave us an opportunity to undertake a root and branch review of what was required for a forward-looking profession and to design a registration pathway that is fit for purpose now and for the future. Such was the importance attached to the project that the Board of Trustees instructed the chief executive that it was to be given the highest level of priority and was to be 16 ENVIRONMENTAL HEALTH NEWS / DEC 2021–JAN 2022

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delivered before the end of 2021.

WHAT IS AN EHP?

The most important question for the review team was to define an ‘EHP’ and who can call themselves one. Advice received was that while CIEH did not own the title we could, by putting in place a registration scheme, determine and control who could be called a Registered EHP, and include within that recognition of their career progression, competence and professionalism. The team were also keen to ensure that the credentials of anyone calling themselves a Registered EHP could be checked in real time to ensure credibility and transparency.

It is important to say that the new Pathway to Registration (see above right) was not created by CIEH in a vacuum. At every stage of its evolution the working group charged with designing it consulted with members, public, private and third sector employers, academics and other stakeholder bodies to ensure that the evolving registration process was fit for purpose, tweaking and amending it in response to the comments received.

“Registration is a claim of up-to-date competency and a reassurance that practice is within a Code of Conduct”

EASY ACCESS Anyone can search the CIEH register for an EHP’s professional credentials

BADGE OF COMPETENCY

The design of the Pathway to Registration and the digital credentials that accompany it has been an enormous project and has required considerable resources. So what have they delivered and what will they deliver for members, employers and the public in the future?

The primary benefit for members is that admission to the appropriate register and the ability to display the associated digital credentials demonstrates that they have proved to the CIEH – their professional body – that they are competent to practise.

The register also shows their ongoing competency, through continuing professional development (CPD) records, and that they are maintaining high standards of professionalism. The fact that members who fail to complete the necessary CPD obligation or who act in an unprofessional manner can be removed from the register enhances the credibility of those practitioners whose names appear on it and underpins the credibility and rigour of the scheme as a register of professionals.

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T THE START OF 2021,

the new leadership team at CIEH identified the issue of who is entitled to call themselves an EHP as one of our biggest challenges. When Phil James took over as chief executive, Terenja Humphries as chair of the Board and Julie Barratt as president, the CIEH Board asked the team to make progress for the future, rather than rake over the coals of the past.

The touchstone for the CIEH is its charter, which identifies its role as being to promote for the public benefit the theory and science of environmental health in all its aspects and to disseminate knowledge about environmental health. Such a broad and far-reaching objective means that membership of the CIEH can be a broad church, but it is conspicuously silent on the definition of an EHP.

A FACE THAT FITS Appearing on the CIEH register is proof of your competence as an Environmental Health Practitioner

EHP Explainer, 1

?

T H E PAT H WAY PRO C E S S In September the Pathway to Registration scheme went live: l The pathway starts with completion of a CIEH accredited degree, at bachelor’s or master’s level, and is accessible through traditional or apprenticeship routes. l Graduates must then satisfactorily complete an Environmental Health Portfolio and a professional interview. l They can then be admitted to the register as Registered Environmental Health Practitioners (EHPs). l Together with Chartered Practitioners, their names, credentials and claims to their professional titles can be checked publicly by a search of the registers on the CIEH website. l There are also registers for Registered Food Safety Practitioners and for those people still registered with EHRB, all operating and searchable in the same way.

PUBLIC PROOF

While digital credentials are a modern, digital-age feature, the principle of registration will be familiar from other professions and household schemes such as the Gas Safe Register.

The public nature of the registers means they can be checked in real time by any potential employers, clients or members of the public who wish to satisfy themselves that the EHP is a qualified, competent and professional individual. Employers can specifically ask in job advertisements for Registered EHPs, relying on the fact that registration is a claim of up-to-date competency refreshed through CPD and a reassurance that practice is within the parameters of a Code of Conduct.

Registered EHPs will be able to use their status to sell themselves at job interviews, when engaging with clients or when tendering for projects. They can also use their professional title to establish their credibility in court when acting as a lay or expert witness. This credibility is further enhanced as the practitioner moves up the Registration Pathway from Registered Practitioner to Chartered Practitioner as their career develops.

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The Pathway to Registration project, the public registers and the digital credentials that support them mean that CIEH is now in a position to control who can call themselves a Registered EHP, a Chartered EHP or a Registered Food Safety Practitioner, and to determine what is meant by those titles. Clearly, we hope that EHPs will understand and appreciate the value of being admitted to the register and will actively use the digital credentials to demonstrate their professional status and title.

We recognise that not all of those who call themselves EHPs may wish to engage with the registration process and may wish to simply continue to practise outside it.

That is, of course, a matter of personal choice. However, as the scheme becomes more widely used, recognised and valued, we anticipate that there will be a wide expectation that being admitted to and remaining on a CIEH register will be the accepted default position for environmental health professionals.

It will be for an EHP whose name does not appear on a register to provide a cogent explanation for that omission, particularly where, as in a court of law,

their competence and experience are subjected to rigorous scrutiny.

MORE THAN A TITLE

Being a professional and being recognised as one requires more than a mere title.

It requires accredited knowledge, professional competence and professional behaviour and attitude. The CIEH professional registers are a searchable, live record of Registered EHPs, independently accredited by their professional body. The digital credentials that registered practitioners are entitled to use prove – irrespective of their job title – that they are registered practitioners and can be relied on to act in a competent and professional manner.

We firmly believe that the profession and the professionals within it will be supported and strengthened by the registration scheme and the use of the digital credentials that attach to it, and we commend it to members.

For more information on registration, visit www.cieh.org/professionaldevelopment/professional-registration/ pathways-to-registration DEC 2021–JAN 2022/ ENVIRONMENTAL HEALTH NEWS 17

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Why failing to regulate emissions can be a breach of a child’s human rights

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Written by TIM EVERETT

HE RICHARDS*

case has significant implications for regulators when dealing with polluting activities that could reduce the life expectancy of third parties.

Regulators have a duty to carry out the necessary investigation and enquiries, and to seek expert advice where required. They then have a duty to take the appropriate action to achieve the necessary reduction within a reasonable timetable.

The case also provides a useful summary of relevant European Court of Human Rights decisions in respect of environmental pollution.

It is directly relevant to the Environmental Permitting functions of local authorities, but it may have much wider implications.

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At the heart of this case were the health impacts on a child with existing poor health, so that the legal tests were subjective – that is based on the effect on the individual claimant. Other key powers, such as the statutory nuisance procedure, have an objective test – the effect on an ordinary person. However, the leading cases on this took place before the Human Rights Act 1998 (HRA) became operative. Section 3 of that Act requires all legislation whenever passed to now be applied in a way compatible with these rights. This suggests that the courts may adopt a different approach in future when applying health criteria in a regulatory context.

The background to the case was a Staffordshire waste disposal site

that had been operating under an Environment Agency (EA) permit since 2005. The permit had been transferred to the current owners in 2016. In late 2020 the EA had agreed a variation which increased the waste throughput by 60%.

Following this there was a significant rise in complaints associated with odour from hydrogen sulphide (H2S) emissions. These emissions had particular effects on a child with bronchopulmonary dysplasia.

The EA served an enforcement notice in March, and the Council served an abatement notice for the smell nuisance in August.

Judicial review proceedings were brought against the EA by the child’s mother for a breach of Section 6 of the HRA in

* R (ON THE APPLICATION OF RICHARDS) V ENVIRONMENT AGENCY [2021] EWHC 2501 (ADMIN)

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Case highlights need to take effective action

PA IMAGES / ALAMY STOCK PHOTO, LISA MALTBY

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COURT WIN Rebecca Currie and her son, Mathew Richards, after winning a High Court case against the Environment Agency

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Protesters at the Subletting tenants landfill site have rights under the Protection from Eviction Act 1977

PRO S ECUT IONS This month’s selection of interesting cases and the lessons learned

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l Tim Everett, former

president of CIEH, is a doctoral researcher and trainer in environmental health law

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Mr Kiley planned to sell these blue French bulldog puppies for £2,800 each

Puppy seller’s unlicensed activity ends in prosecution and separation from pet AUTHORITY: Royal Borough of Greenwich DEFENDANT: Tristan Kiley OUTCOME: Community order (8pm to 6am 12-week curfew), disqualification order for five years (under Section 34 of the Animal Welfare Act 2006), £95 victim surcharge, £350 towards council legal costs OFFENCES UNDER: The Animal Welfare Act 2006 and the Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations 2018

THE STORY The home of Tristan Kiley of Plumstead was visited following a complaint about puppies being sold unlicensed. A litter of five blue French bulldog puppies were found in an enclosure in a damp and poorly ventilated laundry room that smelled of excrement. The puppies were being advertised for sale on various websites for £2,800 each. It transpired that Kiley had been selling dogs as pets without a licence since 2018.

HOW IT PLAYED OUT Due to welfare concerns, an improvement notice was served under Section 10 of the Animal Welfare Act 2006. To ensure that the notice had been complied with within 24 hours, a warrant of entry was obtained, and the property was subsequently visited by a multi-agency team led by the Senior Environmental Health Practitioner at the Royal Borough

of Greenwich. Despite repeated attempts to secure compliance, Kiley did not apply for the appropriate licence and prosecution followed.

Following two adjournments, at Bexley Magistrates’ Court on 7 July 2021, Kiley pleaded guilty to a charge of advertising dogs for sale and selling them as pets without a licence. He received a community order and a disqualification order for five years. This prohibits him from owning or transporting animals, including his family dog, which he had to rehome. He was also ordered to pay a victim surcharge and contribute towards the council’s legal costs.

LESSONS LEARNED This was the first case of this kind that the Royal Borough of Greenwich Licensing Team had investigated and successfully prosecuted. The fact that puppies lived in less than desirable conditions was taken seriously by the court and the disqualification order was granted.

During investigations it is important to ensure the continuity of evidence and adherence to the legislative time limits.

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failing to protect his rights under Article 2 (the right to life) and Article 8 (the right to personal and family life).

Expert evidence was heard, and the evidence of Public Health England for the EA carried particular weight.

The High Court judge granted the right to bring judicial review proceedings.

He then held that the EA had failed to meet their positive operational duties. While the EA had performed some of the relevant steps to comply with the duty under Section 6, they had failed to adopt a plan which would meet the relevant standards within a defined and acceptable timetable. This resulted in a breach of both Article 2 and Article 8 rights. A declaratory judgement was issued which dealt with these defects.

Because the claim was not successful on all counts, only partial costs were awarded.

The EA was refused permission to appeal.

The court focused on the actions taken by the EA to control the problem rather than its earlier decision to allow significantly increased tipping to take place from 2020. It was clear that the complaints increased after that, so the Agency was perhaps fortunate not to have had the decision to vary the permit challenged.

Legal briefing and prosecutions, 2 The McDonald’s restaurant in Leytonstone had to be closed temporarily because of rodent infestation

Environmental health team not afraid to take on multinational McDonald’s AUTHORITY: Waltham Forest Council DEFENDANT: McDonald’s OUTCOME: £1,821 costs OFFENCES UNDER: Food Safety and Hygiene (England) Regulations 2013

HAD A SUCCESSFUL PROSECUTION? Please tell us about it: email editor@cieh.org

WWW.CIEH.ORG

THE STORY In mid-October this year, Waltham Forest Council received a complaint from a customer of McDonald’s in Leytonstone which indicated that there was rodent activity at the restaurant.

The council’s food safety officers inspected the business and quickly established the presence of mice, including mouse droppings in the kitchen and a dead mouse in a storage cupboard. The restaurant was closed on the grounds that there was an immediate risk to public health.

Councillor Clyde Loakes, deputy leader of Waltham Forest Council who oversees food hygiene in the borough, said: “We know McDonald’s restaurants generally have a good record for cleanliness and I understand this is the first time council officers have closed one of its branches in more than two decades.”

Caroline Drewery, environmental health team leader at Waltham

Forest Council, said: “There was clear evidence of mice infestation and our officers didn’t hesitate to shut the restaurant using a formal hygiene emergency prohibition notice because of the immediate risk to health. An application for a hygiene emergency prohibition order (HEPO) was subsequently heard in court.”

HOW IT PLAYED OUT On 21 October, Thames Magistrates’ Court granted the HEPO, meaning the restaurant could not reopen until necessary improvements had been made and the risk to public health removed.

“McDonald’s did not attend the hearing as they agreed with the action the council were taking,” said Drewery.

McDonald’s did not contest

the action and agreed to pay the council’s full costs associated with the formal closure.

LESSONS LEARNED Drewery said: “All businesses must be treated equally, whether that is an independent local or a multinational like McDonald’s.

“Since the day of the closure, McDonald’s have worked alongside the council to rectify the situation and after 10 days they were reopened as the risk to health had been removed.”

By publishing details of the incident on its website, Waltham Forest was able to use the opportunity to remind diners to check the food hygiene ratings of restaurants using the Food Standard Agency’s online toolkit at ratings.food.gov.uk.

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TALK IT OVER The two-day meeting looked at all aspects of food safety, from allergens to AI

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8 L EA R N I NGS FROM…

CIEH’s Safe Food Conference

Sterling Crew, chair of CIEH’s November meeting, shares his highlights from the event

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T’S BEEN A CHALLENGING

year for the food sector, which has had to cope with the pandemic and Brexit. The focus of the Safe Food Conference was on how we can get back on track, working together to elevate food safety standards and build food safety management systems based on science and risk. Here are some of the learning points.

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1. WE NEED TO FUTURE-PROOF FOOD CONTROLS Michael Jackson, head of regulatory compliance at the Food Standards Agency (FSA), spoke about its work on a new approach to the delivery of food standards controls, the FSA’s review of the delivery model for food hygiene, and the development of new arrangements for

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reporting and monitoring local authority (LA) performance. He highlighted how LAs will be shifting their focus back to food hygiene and the food standards system. The Food Hygiene Rating Scheme will continue to play a major role.

Jackson’s clear message was that a sustainable and effective regulatory approach is not about pushing the existing system harder – it is about future-proofing controls and change, using the opportunities presented by innovation and new technologies.

2. HOSPITALITY AND LAs SHOULD CONTINUE TO COLLABORATE Kate Nicholls, CEO of UKHospitality, told delegates how the public health measures put in place to control the pandemic left the sector with high levels of debt and

staffing challenges, with many businesses closing down or exploring new ways of trading. But the sector is also optimistic and looking forward to playing its part in the nation’s recovery. She emphasised the importance of ongoing collaboration between hospitality and LAs.

3. FOOD SAFETY IN HOSPITALITY CAN BE IMPROVED John Barnes of Shield Safety looked at over-stretched LA resources and the current backlog of food safety inspections.

He emphasised the importance of well-supported LAs to regulate businesses, protect communities and maintain confidence in the food supply chain.

He said regulators should also give more recognition to industry assurance schemes such as the Safe to Trade DEC 2021–JAN 2022 / ENVIRONMENTAL HEALTH NEWS 23

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Scheme and their compliance data, as they not only provide support, advice and reassurance to businesses, but they can give regulators much richer and real time information on risks.

talked about how she is working with businesses to improve food safety performance, focusing on an organisation’s people and culture to drive positive change.

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8. HARNESS TECHNOLOGY TO DEVELOP SAFER FOOD

4. FOOD WASTE MUST BE ADDRESSED

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Eleanor Morris, special advisor for hospitality and food service at WRAP, described food waste as a catastrophe for the environment, pointing out how it takes a land mass larger than China to grow food each year that is never eaten.

When food waste goes to landfill, it creates methane, which is 23 times more deadly as a climate change gas than carbon dioxide.

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5. ALLERGENS CONTINUE TO PRESENT CHALLENGES

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Food safety allergen specialist Dr Belinda Stuart-Moonlight told delegates that allergens remain a problem for the food industry, despite increased awareness, laws and controls. She reviewed some of the legacies of allergen incidents including Natasha’s Law and the current call for Owen’s Law. She highlighted the practical difficulties and unexpected consequences of businesses trying to implement the new ‘prepacked for direct sale’ rules.

6. REGULATORS MUST BE CLEAR ON CALORIE LABELLING There was an engaging panel discussion on the implications of the calorie labelling regulations that will come into force in April 2022.

Hannah Burton, associate solicitor, Pinsent Masons, addressed some of the legal ambiguity. Eric Robinson, Department of Psychological Sciences, University of Liverpool, went through the nutritional science behind the regulations and the analysis involved. Jim Cathcart, policy director at UKHospitality, commented on the impact on hospitality, emphasising the benefits of examining the business process rather than sampling and analysis.

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7. WE CAN DEVELOP A CULTURE OF FOOD SAFETY Carol Wallace, professor of food safety management systems at University of Central Lancashire,

The conference concluded with a presentation from Frank Yiannas, deputy commissioner for food policy and response at the US Food and Drink Administration.

He said new approaches to food safety can bend the curve of foodborne disease and reduce the number of illnesses.

He gave a global perspective on improvements in supply chain innovation and food traceability, including an insight into the benefits of technologies like blockchain, giving greater visibility and immutable assurance. He explained how Artificial Intelligence can convert data into usable intelligence, and how the Internet of Things would enable regulators, industry and consumers to make informed choices and create a more secure global food supply network.

To sign up for future CIEH conferences and events visit www.cieh.org/events

ABOUT THE WRITER Sterling Crew is a Chartered Fellow Environmental Health Practitioner, chair of the Food Authenticity Network, and an independent scientific advisor and public health commentator.

Sterling was elected a trustee of CIEH in 2021.

CI EH EVEN TS Here’s a taste of events CIEH is running in the new year. For a full list, visit www.cieh.org/ events WORKSHOPS l HHSRS: damp,

mould and excess cold 10 & 11 January (half days) l Fire risk assessment and awareness 18-21 January (four half days) l HHSRS enforcement 20-21 January (half days) CONFERENCES l CIEH 14th Housing

and Health Conference 24 May WEBINARS l CIEH-

conversations: the leadership team 16 February

SHARE YOUR STORY

MEMBER FORUM

Environmental health consultant Stephen Battersby is series editor of Routledge Focus on Environmental Health. He is inviting proposals to complement existing titles in the series outledge Focus on Environmental Health is a series of shortform publications in which Environmental Health Practitioners (EHPs) write about their work and other relevant topics. The series complements Clay’s Handbook of Environmental Health, last published in 2016 and due to be updated next year.

The Routledge series is supported by CIEH and provides a unique chance for EHPs to help others learn from their experiences

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and knowledge and also contribute to professional development.

The first of the eight titles, Pioneers in Public Health: Lessons from History, is a multi-author book comprising chapters that were originally part of a special edition of the now-defunct Journal of Environmental Health Research.

The publications are used by CIEH and others to demonstrate the range and importance of environmental health work.

Copies of COVID-19: The Global Environmental Health Experience

are being sent to chairs of the House of Commons Committees that produced the recent joint report on COVID-19.

We have a very flexible approach to titles and hope EHPs will give serious thought to writing about their work. l For more information contact sabattersby@blueyonder.co.uk l To see all existing titles in the series and for guidance on submitting a proposal visit www.routledge.com/ Routledge-Focus-on-EnvironmentalHealth/book-series/CONENHE

l HoadingUK coffee

and catch-up 1 February l New to the profession coffee and catch-up 15 February BITESIZE TRAINING l Dampness in

domestic dwellings 12 January l Timber frame and non-traditional construction housing 13 January l Control of listeria in food processing 20 January l To book visit www. cieh.org/events

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Your career

Front line: Lisa Ackerley, 1

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Dr Ackerley helped ensure a climate of cleanliness at COP26

L EAR N I NG POI N T S ANTICIPATE ISSUES We made sure we had documentation to hand in case anyone asked: “What’s your justification for why we should disinfect X and at this frequency?”

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‘We applied a risk assessment to every item in every location’ Environmental health played a key role in ensuring COP26 was hygienic, says Reckitt’s Lisa Ackerley

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HAD BEEN AN

environmental health consultant with Reckitt since the 1990s and took up a full-time position in June 2021. My job is to engage globally on hygiene across the brands, and to assist technically on projects. For COP26, the UN climate change conference, Reckitt was the official ‘Hygiene Partner’ and I was their environmental health expert.

Early on, I visited Glasgow to review the site, and to meet the Reckitt team, the Cabinet Office and facilities management.

The cleaning company was yet to be appointed. Our role was to put hygiene protocols in place to help protect the 26,000 daily attendees against COVID-19 and other infectious diseases.

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I feel strongly about targeted hygiene.

So, rather than advocating the more theatrical ‘deep cleaning’ on a daily basis, we understood the importance of disinfecting the high touch points at a frequency demanded by use and risk to break the chain of infection.

Because the area of COP26 was so large, we had to divide it into 12 types of location. For meeting rooms, we made suggestions about the areas that needed to be disinfected between meetings – the arms of the chairs, desks and the clicker on the remote control.

Effectively we applied a risk assessment to the locations, in relation to delegates’ journey through the site, and use of the

HAVE EHOs ON THE GROUND With EHOs’ knowledge, experience and flexible ‘can do’ practical approach, we achieved so much. They were able to coach and encourage where necessary.

2

COMMUNICATE QUICKLY We used WhatsApp groups to message each other – we found it was much more efficient than email.

3

areas. We applied that to every item in every location to gain a low-, medium- or high-risk rating and made it numerical.

It was all backed up by science; a lot of work took place behind the scenes and we assessed more than 80 research papers.

The team was made up of virologists, microbiologists, behavioural scientists and chemists, with me as a public health/ environmental health scientist. We also asked the London School of Hygiene & Tropical Medicine to review our proposals.

The final result was distilled into protocols for each location to be used with carefully chosen products to meet efficacy and sustainability requirements.

The Royal Environmental Health Institute of Scotland helped me find three EHOs to take adenosine triphosphate measurements of cleaned surfaces so we could check the cleaning was being done effectively and provide coaching and feedback as needed.

During the event we collated data for feedback to our EHOs and the cleaning teams which was also shared with the enforcement officers from Glasgow City Council and the government.

Dr Lisa Ackerley is director of medical and scientific engagement, hygiene, at Reckitt and a trustee of the International Scientific Forum on Home Hygiene

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