Select Committee on Science and Technology Written Evidence

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.


  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 support required.

  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 who bite.

  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 communication system.

  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.

October 2002

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