Food safety inspection is on the verge of a step change that may greatly reduce the responsibilities and autonomy of local authority environmental health services. Does it matter? Will Hatchett speaks up for the role of the professional judgement and integrity offered by EHOs and warns against dumbed-down, tick-box enforcement.

In 2017, I watched, over a couple of weeks, as the library of the Chartered Institute of Environmental Health was loaded into skips for off-site disposal. Decades of policy papers, technical reports and books on subjects ranging from identifying sea fish and exotic fruit and vegetables to drains, clean air and slum clearance were sent to landfill.

It was an economic measure – perhaps a short-sighted one – necessitated by huge financial losses and a radical downsizing. I had often used the library as editor of the CIEH’s news magazine. The move seemed symbolic of the reduced status of environmental health’s holistic, local authority-based heritage, stretching back to the Public Health Acts of 1848 and 1875. This professional erosion continues. According to a CIEH workforce survey in 2021, 56% of local authorities had environmental health vacancies unfilled for more than 6 months; 87% said agency staff were needed because they could not recruit permanent staff. A Local Government Association capacity survey in 2024 found that 51% of the workforce is over 50, while only 9% is under 30, creating a significant retirement ‘cliff edge’.

In the same year, the Food Standards Agency expressed concern that around 1 in 7food safety posts in England, Wales and Northern Ireland were vacant.

Response to skills shortages

One could conclude from this that local authority-based environmental health is dying – literally – as a branch of the public health workforce. The trend is not new. University environmental health degrees have been closing for years, while comparatively poor terms and conditions and limited post-Covid flexibility have made local government less attractive to graduates.

The decline of the EHO as the person who inspects the kitchen of your local restaurant may have been accelerated last year by two significant developments. In October 2025, responding to an escalating crisis in food safety inspection capacity, the FSA introduced a revised Food Law Code of Practice (CoP) and accompanying practice guidance. The CoP is the FSA’s legal blueprint for how local authorities regulate food businesses.

The revised CoP brought the business risk decision model (BRDM) into force in England, replacing the previous inspection regime with a more flexible, intelligence-led and risk-based approach to food hygiene controls. Moving away from a rigid 28-day inspection target, local authorities can now triage new food business registrations. This allows immediate inspections to focus on higher-risk establishments.

The new code formalises the use of remote official controls, such as desktop reviews and remote assessments, and allows trained officers with lower-level qualifications than previously required to undertake more regulatory work.

Currently, a fully qualified EHO typically has a Level 6 honours degree requiring 3 or more years of study and additional professional training. The CIEH has agreed, in principle, with the FSA on the development of a new Level 5 qualification for food law enforcement to broaden the regulatory workforce. It will be approximately equivalent to a foundation degree or higher national diploma, although the curriculum and assessment have yet to be finalised. Level 4-qualified food safety practitioners, who can be trained in a matter of weeks, are now able to undertake supporting regulatory activities, including the desktop assessment of newly registered food businesses.

Critics argue that the changes risk diluting professional expertise, while supporters say they are a pragmatic response to severe workforce shortages. Both the CIEH and the FSA support a ‘permit to trade’ for new food businesses and the mandatory display of Food Hygiene Rating Scheme scores for food businesses in England, as in the rest of the UK. These long-overdue measures would certainly help the FSA to fulfil its mission to “protect public health and maintain consumer confidence in the food system”.

Surprise announcement

In November 2025, in an unexpected move, the government invited the FSA, through the Budget, to develop “a consistent, national approach in England for the regulation of large food businesses”.

The idea did not emerge overnight. The FSA introduced Primary Authority partnerships in 2009, allowing large multi-site food businesses to work with a single local authority acting as their central regulatory contact. In 2023, it piloted National Level Regulation (NLR), under which major retailers would be regulated centrally through scrutiny of their systems and data. The largest retailers have already begun preparing for such a system, developing national digital dashboards capable of sharing refrigeration records, staff training and pest control data directly with the FSA.

To supporters, NLR is the logical next step in modern risk-based regulation. To many EHOs, it represents a profound constitutional shift: the weakening of politically accountable local authority enforcement, the further decline of the generalist EHO and an increased risk of regulatory capture. Unlike BRDM, however, NLR remains a proposal. It will require further design, consultation and primary legislation.

Many questions remain unanswered. We do not know how many businesses will qualify for NLR, how the scheme will be funded, or whether the FSA, rather than local authorities, will ultimately prosecute serious offences. Such powers would not be unprecedented – the Financial Conduct Authority and the Health and Safety Executive both combine regulatory and enforcement functions – but they would mark a significant departure from the current system.

New government – new priorities

Established in 2000 following the BSE crisis and the 1996 E. coli O157 outbreak in Lanarkshire, the FSA, now led by its sixth chief executive, Katie Pettifer, is a political creation. Its independence and transparency were originally badges of honour after the failure of MAFF’s in-house advice during the BSE crisis.

In 2010, perceived as too political and too large, it lost its responsibilities for nutrition policy to the DoH and food labelling to Defra. Following years of budget cuts that greatly reduced its staff count, the agency has increasingly become a technical and managerial organisation, rather than a public champion. Since Brexit and Covid, new priorities have emerged: maintaining food security and reducing regulatory burdens on businesses facing rising costs. These are now objectives of the Labour Government and are likely to outlast it.

The prospect of political continuity, together with last year’s Budget request to streamline regulation for large businesses, has led the FSA to combine the new CoP and BRDM with NLR under its all-embracing Future of Food Regulation Programme. In March, the programme was presented to the FSA Board as a ‘step change’ towards a flexible, risk-based and modern food regulatory system, recognising the “evolving food landscape and the persistent pressures on local authority delivery”. FSA Chair Susan Jebb endorsed the programme and instructed officials to proceed with detailed design.

In June, the FSA published a work plan integrating NLR with improved local regulation, stressing that local authorities must remain part of the solution. Mid-2027 is the deadline for post-Brexit dynamic alignment negotiations. The FSA must keep one eye on the EU if it is to fulfil its Budget brief while reducing unnecessary burdens on internationally trading food businesses.

Risks versus benefits

If fully implemented, these reforms will represent the biggest structural change in food regulation since the FSA was created. Many of the underlying ideas – including licensing, earned recognition and national regulation – have been discussed for years. An earlier modernisation programme, Regulating Our Future, launched in 2016, was derailed by Covid. But deepening austerity, workforce shortages and a new political climate have accelerated what might otherwise have been a gradual evolution into something closer to revolution.

The issues at stake are not professional self-interest or nostalgia but trust, integrity and accountability. Most professionals concede that incorporating advanced data collection and AI into official controls is welcome, but many argue that virtual assessments and documentary assurances cannot entirely replace an experienced professional visiting premises. The keenest eyes are often those of the generalist rather than the contractor working to a narrowly defined specification. Sceptics fear that environmental health in the public sector will remain seriously underfunded. They portray a future of dumbed-down, tick-box enforcement, increased outsourcing and reliance on third-party auditors.

The strength of environmental health has never simply been technical competence in food hygiene. Its distinctive contribution has been its breadth. An officer inspecting a restaurant may also understand housing, infectious disease, occupational health, air quality, noise, drainage and wider public health.

Expertise, independence and thoroughness have long characterised the environmental health profession. It is bound by a code of ethics, and its practitioners are motivated by more than commercial considerations. Whatever shape the future regulatory system takes, those qualities are surely worth preserving.

William Hatchett