Key points
Like ‘quality’ in relation to certain foods, ‘traceability’ combines legal definitions with subjective interpretations that generally go well beyond these minimum requirements and differ from company to company.
The Food and Drink Federation’s (FDF’s) director of regulation, science and health Barbara Gallani explains: “The EU defines traceability as the ability to trace and follow food, feed and ingredients through all stages of production, processing and distribution. The requirement is for businesses to be at least able to identify the immediate supplier of the product in question and the immediate subsequent recipient.”
Beyond the legal minimum (Return to top)
Head of crisis management at Leatherhead Food Research Tony Hines emphasises measures that go beyond the minimum ‘one step forward and one step back’. “It is now commonplace to say: 'Understand your supplier’s supplier’,” he states.
What ‘understanding’ should entail, and how it should be implemented, is another matter.
That focus on how and where raw materials are sourced will always be reinforced whenever there is a crisis involving food contamination or adulteration. Because the horsemeat saga rumbled on for so long and took in so much of the retail supply chain, it has had a profound impact. Arguably, it was precisely because there was no safety issue per se that consumers were invited to focus on the long, convoluted and obscure nature of the food supply chain.
In July last year, after six months of the scandal, Mintel reported that fewer than half of British consumers trusted the industry to provide safe food. A further 37% were undecided. Only 36% of consumers polled felt that manufacturers were aware where their ingredients originated.
Mintel did not have more recent figures for comparison. But it is probably safe to assume that, even if this distrust has subsided to some extent, a wider credibility gap remains than before the fraud was first detected.
Industry changed forever (Return to top)
Hines says: “The industry changed forever on January 16 2013. It can never be the same. Now the vulnerability has been highlighted, fraud mitigation is now firmly on the agenda at the very highest level in every responsible business.”
But where is the overlap between ‘fraud mitigation’ and ‘traceability’ in its widest sense?
The FDF is eager to underscore the role of “fraudulent activities” in horsegate. Gallani argues: “The traceability systems were fit for purpose and allowed manufacturers, retailers and authorities across Europe to quickly identify and address issues, despite the complexity.”
Unfortunately, that is not the public perception. In the same Mintel research from mid-2013 only 42% of British consumers polled thought the industry could effectively react to food scares of this type. Just 23% believed the various elements in the supply chain worked effectively together.
Detecting several examples of criminal adulteration can imply the problem goes much further than current information suggests. Perceptions are arguably not the same when you track down an E-Coli outbreak, for instance.
As ever, industry is keen to ensure the regulatory burden doesn’t increase. At Campden BRI, head of agriculture Chris Knight echoes the view of many in the supply chain when he says: “I’m not sure there is a need for more rules. What we have needs to be effectively managed. The systems that are available cannot prevent fraud in themselves. However, diligent risk management and verifying the effectiveness of systems already in place are the key.”
That element of verification, or compliance testing, seems important to ensure systems conform to requirements.
“This may include audits, a physical test of the system to demonstrate efficacy and retrieval time, for example, product analysis where applicable, and a quantity or mass balance assessment to account for raw materials used, any waste or co-products produced, and finished product,” says Knight.
On the critical importance of audits and risk assessment, the British Retail Consortium (BRC) Global Standard has much to say. BRC technical director David Brackston says: “Among the key elements of the Standard are testing and acceptance procedures [for raw materials] and, based on this, risk assessment.”
Horizon scanning (Return to top)
As well as known risks, there is an increasing emphasis on horizon-scanning. “For instance, we’re using the outputs of audits, withdrawals and recalls,” says Brackston. “Let’s gather that information and share it anonymously to help drive the way we conduct future audits." Monitoring data on recalls from the Food and Drugs Administration, for instance, as well as other international agencies and certification bodies is already standard practice,” he adds.
“When it comes to communicating risks, there are pockets of work going on with different organisations, but it’s a question of pulling all that information together and making it more widely available,” he says. “There are different European government agencies looking at this whole question of improving the sourcing and sharing of information on risk.”
Knight at Campden agrees risk assessment and horizon scanning are now recognised as essential components in the identification of “emerging and potential threats”.
He explains: “A core process in the defence of food is a systematic evaluation of vulnerable elements in the supply chain, carried out by an experienced and trusted team. This has been called Threat Assessment Critical Control Point.”
The results of Freedom of Information requests from IT systems supplier Trace One, published last November, suggest that the culture of ‘communication’ and ‘sharing’ has some way to go. Local authorities appear to be selective about which product withdrawals they report to the Food Standards Agency (FSA). One Welsh authority removed unsafe product from shelves 63 times over two years, says Trace One, but not one of these cases was reported. Indeed, legally, the council was not obliged to report them.
The FSA said it only listed withdrawals on its ‘Food Alerts’ webpage where products were distributed nationally. It told the firm it did not keep an official list of local cases and responses.
So what about audits, as one of the ‘stress tests’ of robust traceability within the framework of voluntary standards? Do they have a role to play in averting future crises of this sort?
“There has been a move to unannounced audits,” says the BRC's Brackston. “They’re not necessarily going to prevent this sort of issue. But they may make it more difficult for people to cheat the system, and will hopefully help to drive a change in attitudes in some factories.”
But if Brackston is an advocate of the benefits of audits, he is equally clear on their limitations. “They were designed to look at food safety issues,” he points out “To undertake a fraud-type inspection would be very different. You’d be looking in a more forensic way at invoices and other paperwork. That's a sizeable challenge.”
Of course, BRC Standards has other tools with which to monitor what is happening in the supply chain. “Through our Directory, which now lists around 20,000 audited sites, we’re looking at providing far greater transparency through the whole supply chain,” says Brackston. “We’re exploring the possibility of linking the various sites and making visible the interrelationships between different suppliers and manufacturers.”
Information sharing (Return to top)
Nor is this trend unique to standards providers. At Trace One, senior vice president for northern Europe Nick Martin describes the role of its web portal aimed at own-label manufacturers: “We’re enabling information sharing at site level, about suppliers, at product level, regarding certification, on sustainability criteria, and so on.” He adds: “Typically, a lot of this has not been shared down the supply chain, and this has to change.”
It has systems running among retailers and manufacturers in North America and mainland Europe, and is talking to “one or two key retailers” to see how this might work in a UK context.
“A retailer can quickly identify a particular raw material and where it resides, in which food categories and in which of its stores,” Martin says. “In our view, if a manufacturer is willing to be 100% transparent, then the likelihood of fraud taking place is greatly reduced,” argues Martin.
The BRC’s Brackston says the limitations of quality-based audits in addressing fraud should not make supply chain partners complacent. “After all, horizon-scanning links into food safety and audits,” he says. “We do have to work harder. We can’t wash our hands completely of this.”
Hines at Leatherhead recommends thinking like a criminal: “How would they get around our testing protocols? What alternative would they use to substitute, bulk or dilute? Which market would offer the best fraudulent returns? ”
This may be a ‘fraud mitigation’ process, but it feeds directly back into the effectiveness of current and future traceability systems.