The inclusion in paragraph 13(e) of the Bill as introduced of the duty of the FSA to; “promote the scheme to food business establishments and consumers in Wales” is to be welcomed[15]. However, FSB Wales believes there is scope in the Bill to strengthen the duties of the FSA beyond simply promoting the scheme to actively highlighting good practice to businesses in order to better enable them to achieve satisfactory ratings.

Finally, as mentioned above, it is crucial that businesses are aware of the changes that the Bill proposes. FSB Wales calls on the Welsh Government to provide guidance to small businesses affected by this scheme in a timely manner. The overall objective of the scheme should be to ensure that good practice in food hygiene is rewarded. Therefore, guidance from the Welsh Government should encourage small businesses to achieve the best possible rating.

FSB Wales believes that the Food Hygiene Rating (Wales) Bill as introduced requires greater regulatory impact assessment to ascertain the likely implications for small businesses of the inclusion of business to business trade within the remit of Bill. The inclusion of business to business trade constitutes a divergence in direction from the Welsh Government’s original stated aims around the introduction of a Food Hygiene Rating (Wales) Bill that would move the voluntary scheme to a mandatory basis.

FSB Wales welcomes adaptations around the right of reply, right of appeal and re-ratings procedures but believes further examination of their costs to small businesses and the timescales involved is needed.

Finally, FSB Wales would like to see the Welsh Government produce strong guidance in advance of the legislation coming into force to ensure that small businesses are aware and able to achieve the highest rating possible. The Food Standards Agency has a significant role to play in creating adequate guidance and fixed penalty notice receipts should help finance this.

FSB Wales hopes you find these comments of interest and looks forward to discussing them further with the committee.

The FSB is non-profit making and non-party political. The Federation of Small Businesses is the UK's largest campaigning pressure group promoting and protecting the interests of the self-employed and owners of small firms. Formed in 1974, it now has 200,000 members across 33 regions and 194 branches.

Our lobbying arm - led by the Westminster Press and Parliamentary office - applies pressure on MPs, Government and Whitehall and puts the FSB viewpoint over to the media. The FSB also has Press and Parliamentary Offices in Glasgow, Cardiff and Belfast to lobby the devolved assemblies. Development Managers work alongside members in our regions to further FSB influence at a regional level.

In addition, Member Services is committed to delivering a wide range of high quality, good value business services to members of the FSB. These services will be subject to continuing review and will represent a positive enhancement to the benefit of membership of the Leading Business Organisation in the UK.

A community that recognises, values and adequately rewards the endeavours of those who are self employed and small business owners within the UK

The Federation of Small Businesses is the trading name of the National Federation of Self Employed and Small Businesses Limited. Our registered office is Sir Frank Whittle Way, Blackpool Business Park, Blackpool, Lancashire, FY4 2FE. Our company number is 1263540 and our Data Protection Act registration number is Z7356876. We are a non-profit making organisation and we have registered with the Information Commissioner on a voluntary basis.

We have two associated companies, FSB (Member Services) Limited (company number 02875304 and Data Protection Act registration number Z7356601) and NFSE Sales Limited (company number 01222258 and Data Protection Act registration number Z7315310).

[1] Welsh Government. 2012. Draft Regulatory Impact Assessment: Food Hygiene Rating (Wales) Bill [Online]. Available at: http://wales.gov.uk/docs/phhs/consultation/111214impacten.pdf (accessed 28th June 2012).

[2] Members’ Research Service. 2012. Bill Summary: Food Hygiene Rating (Wales) Bill [Online]. Available at: http://www.assemblywales.org/bus-home/research/bus-assembly-research-publications/research-constitution/12-029.pdf?langoption=3&ttl=Food%20Hygiene%20Rating%20%28Wales%29%20Bill%20-%20Bill%20Summary%20paper (accessed 28^th June 2012).

[3] FSA. 2011. The Display of Food Hygiene Rating Wales [Online]. Available at: http://www.foodbase.org.uk//admintools/reportdocuments/732-1-1244_FHRS_Report-13_December_2011_-_FINAL.pdf (accessed 28th June 2012).

[4] Members’ Research Service. 2012. Bill Summary: Food Hygiene Rating (Wales) Bill [Online]. Available at: http://www.assemblywales.org/bus-home/research/bus-assembly-research-publications/researchconstitution/12-029.pdf?langoption=3&ttl=Food%20Hygiene%20Rating%20%28Wales%29%20Bill%20-%20Bill%20Summary%20paper (accessed 28^th June 2012).

[5] Welsh Government. 2012. Food Hygiene Rating (Wales) Bill: Explanatory Memorandum [Online]. Available at: http://www.assemblywales.org/bus-home/bus-business-fourth-assembly-laid-docs/pri-ld8916-em-e.pdf?langoption=3&ttl=PRI-LD8916-EM%20-%20Food%20Hygiene%20Rating%20%28Wales%29%20Bill%20-%20Explanatory%20Memorandum (accessed 28^th June 2012).

[6] Record of Proceedings 29 May 2012. Introduction of the Food Hygiene Rating (Wales) Bill [Online]. Available at: http://www.assemblywales.org/bus-home/bus-chamber-fourth-assembly-rop.htm?act=dis&id=234781&ds=5%2F2012#dat4 (accessed 29^th June 2012).

[7] FSB Wales. 2012. Food Hygiene Rating (Wales) Bill: written submission to the Welsh Government [Online]. Available at: http://www.fsb.org.uk/policy/rpu/wales/assets/policy%20documents/food%20hygiene%20rating%20(wales)%20bill%20%20-%207th%20march%202012.pdf (accessed 26^th June 2012)

[8] Food Hygiene Rating (Wales) Bill. As introduced. (2011-12) [Online]. Available at: http://www.assemblywales.org/bus-home/bus-business-fourth-assembly-laid-docs/pri-ld8916-e.pdf?langoption=3&ttl=PRI-LD8916%20-%20Food%20Hygiene%20Rating%20%28Wales%29%20Bill (accessed 26^th June 2012)

[9] Draft Food Hygiene Rating (Wales) Bill. (2011-12). [Online]. Available at: http://wales.gov.uk/docs/phhs/consultation/111214billen.pdf (accessed 26th June 2012)

[10] Food Hygiene Rating (Wales) Bill. As introduced. (2011-12) [Online]. Available at: http://www.assemblywales.org/bus-home/bus-business-fourth-assembly-laid-docs/pri-ld8916-e.pdf?langoption=3&ttl=PRI-LD8916%20-%20Food%20Hygiene%20Rating%20%28Wales%29%20Bill (accessed 26^th June 2012)

[11] ibid

[12] ibid

[13] ibid

[14] ibid

[15] ibid