Memorandum by Wiltshire Food Liaison Group
We should like to put forward our observations
for your Committees' perusal.
We start with our submission to the Getting
Ahead of the Curve document and go on to a brief outline of
areas which concern us and which we believe have implications
for the future of infection control and public health. We provide
more questions than answers and generally feel that infection
control and public health are becoming fragmented and need a strong
guiding hand to pull together all the areas of work.
SUBMISSION TO THE "GETTING AHEAD OF
THE CURVE DOCUMENT".
I write on behalf of the Wiltshire Food Liaison
group to express our deep concerns with regard to the ideas set
out in the Getting Ahead of the Curve Document. Although
we are past the date when consultations were to end we hope our
views can still be considered as the documents took some time
to reach the correct interested parties.
Our concerns can be summarised as:
1. The lack of information and thought given
to the services we use for food, water and environmental samples.
We feel this is a major omission from the report and is not joined
up government in reflecting the Food Standards Agency's concerns,
demands and aims.
2. If the Labs pass to local NHS Trusts
will the work we do be given the service level we currently receive
from the PHLS or will it be secondary to the clinical needs? Public
health must be given due priority and we have no confidence that
the "National Illness Service" will give the level of
3. Will the NHS Trusts be prepared to carry
out work from other areas? There is no PHLS Laboratory in Wiltshire
and we are dependent on Bristol and Southampton, both of which
have no allegiance to our populations. We have a courier service
provided in many cases to carry samples to the Labs.
4. The various accreditations and staff
training required to be regarded as a "Food Lab" are
expensive and time consuming. Will an NHS Trust be willing to
continue to offer this support if it is not a statutory function?
5. The breaking up of the PHLS seems madness
following over 50 years of proving how essential a dedicated public
health laboratory service is. The expertise in food, environmental
and water work must be maintained. What will happen to the various
specialist services? One which springs immediately to mind is
the service run from Exeter PHLS on the mouth flora of animals
6. At present we are not charged for the
services we receive. If the changes proposed come into force in
April 2003 how will the work be funded?
If we are to be required to pay for the work
from our budgets we will need at least a full financial year to
make a bid in our service planning process.
7. The option of having labs jointly managed
by the NHS Trust and the new Health Protection Agency is likely
to result in a bureaucratic muddle and serve nobody well.
We would urge that the matters raised in this
report be revisited and the needs of public health and services
provided to local authorities to be properly addressed.
We do not feel that our concerns have been addressed
in the final plans and fear for the future of Public Health disease
control and food examination.
The following points, not in order of importance,
may be of interest:
1. We regret loss of the PHLS and what will
happen with no real acknowledgement of food/water work. We are
concerned that the rapport and liaison, which we have developed
with the Lab personnel, will be lost.
2. GPs are poor at reporting food poisoning
and taking stool specimens.
2.1 A number of our group have experience
of patients being ill for some time or dealt with in an A&E
Department without a specimen being taken.
2.2 We are concerned that PCT budgets might
restrict the number of specimens to be submitted or where they
are sent. When fund-holding GPs came in we did have difficulties
with practices using private labs and therefore reporting fell
out of the usual loop.
3. The FSA are basing the target for the
reduction of food poisoning figures on GP reports of where a person
got intestinal illness. Unfortunately, many GPs ideas/knowledge
on incubation periods and causes of food poisoning are rather
different from ours.
3.1 We have had a number of instances where
the misinformation of the GP has complicated our investigations.
The patient generally trusts the GP and has some difficulty in
reconciling the GP information with our differing views. For example,
where a GP told a patient that the Campylobacter infection
they were suffering from had come from the scrambled eggs they
had had for breakfast the previous day. This is incorrect as far
as incubation period is concerned and the vehicle of infection.
4. There is no feedback system on infection
investigations. We find out where food poisoning has been contracted,
ie abroad or possibly from a particular food, and yet no one collates
the information when it could be significant.
5. We feel there is a lack of direction
at present with regard to the future of the CCDC and how the new
HPA will interface with LAs. At present all our authorisations
are wrong as they state that the CCDC is the proper officer for
the authority and works for the Health Authority, which of course
no longer exists.
6. We are unsure what power the HPA will
have to insist that EHOs work to a common standard. At present
we all receive different infection notifications and deal with
them in different ways. How will the HPA ensure that EHOs are
in post and authorised to work with the HPA?
6.1 We would be most concerned if we were
to lose an identifiable CCDC (consultant in communicable disease
control) for our specific area (county). We work very closely
with the CCDC, attend liaison meetings and frequently work with
him on specific cases or incidences.
7. Is there a future for the investigation
of infectious disease? Will the LA become more involved in diet
education or will that fall to the directors of public health
at the PCTs? It could be argued that we serve the public good
better carrying out health and safety inspections, which in mortality
and morbidity terms are more important than routine food poisoning.
8. From recent experience we believe that
TB will be of increasing significance yet the LA role is unclear
apart from obtaining court orders to detain open cases that are
not being treated. The lack of a clear medical public health practitioner
or CCDC for each district could lead to a more difficult or complex
9. It is unclear what role the Director
of Public Health for the PCT will play in infection control in
the community. One such director of a PCT in this area has already
requested that she be notified of all incidences of infectious
disease occurring in her area. This is obviously not possible.
9.1 Not all PCTs are conterminous with local
authorities. This could lead to duplication of communication systems
where the LA may have to contact different Directors of Public
Health in a number of different PCTs within their area of jurisdiction.
10. Our other major concern is that the
HPA seems to assume that there will be an EHO in some position
in the hierarchy where they have the power to act or influence
policy. Wiltshire is soon to be reduced to one Chief Environmental
Health Officer. The remaining environmental health managers reside
at 3rd or 4th tier, often with no overall officer in charge professionally
as a lead officer for all the functions. They tend to be called
team leaders or group leaders. They have no voice at a strategic
level. An example of how this works against us is in making ourselves
known to PCTs and in trying to promote student/trainee posts.
11. If LAs have to fund microbiological
examination of food this could have a major effect on the number
of samples taken. At present we are all having to make savings
on our budgets and cannot see any increase being allowed. We feel
that the micro-sampling of food is a useful and effective tool
in pinpointing poor or dangerous practices.
12. The shortage of trained officers to
carry out food inspections and investigate infectious disease
could adversely affect any national or local strategies planned
by the HPA. The prescriptive standards and entry requirements
for the required EHORB qualification exclude many potentially
excellent food officers from working.
13. All agencies need to work together for
mutual aims, ie FSA, HPA, local PCT and local authority.