Food and drink has to be safe and legal. It’s the law. But, despite the best endeavours of reputable companies within the industry, there are examples of it not being either. And, in the worst incidents, people have been made very ill – and, tragically, sometimes died.
To put things in context, the UK food and drink supply chain is generally quite safe. Certainly, it has a much better food hygiene and safety record than many other countries around the globe. But things still go wrong, and that can be down to a variety of reasons.
Over the past few years, we have seen extreme examples of deliberate contamination of products, with incidents such as chilli powder being illegally adulterated with the dyes Sudan 1 and Para Red in 2005 to enhance the colour; the 2008 melamine in milk scandal in China; and the 2013 horsemeat adulteration scandal.
‘Horsegate’ attracted much adverse publicity but – perhaps more worryingly for the food and drink supply chain – it highlighted the fact that the industry’s traceability controls were not quite as good as many believed them to be.
While it was a serious wake-up call for the sector, it wasn’t the first case of food fraud based on the use of inauthentic ingredients and won’t be the last. But, next time, the food safety consequences could prove far more damaging in terms of human health.
We have also experienced other major, high-profile incidents, such as the bovine spongiform encephalopathy (BSE) or ‘mad cow’ disease crisis of 2000, which caused much damage to the UK’s livestock sector.
Then there was the Welsh E.coli O157 outbreak in 2005 caused by contaminated meat, which caused the tragic death of five-year-old Mason Jones and left more than 150 other people ill. The following year (2006) there was the equally high profile incident involving Cadbury chocolate contaminated with salmonella.
In between these incidents, there have also been numerous other alerts and product recalls, caused by everything from accidental chemical and foreign body contamination of food, to foodstuffs containing unlabelled allergens, and others involving high levels of dangerous bacteria and viruses.
What all these cases vividly illustrate, is that – to paraphrase the Scottish Bard Robert Burns – despite the best-laid plans of those with good intentions who seek to ensure food safety, things still go wrong. Sometimes, it is due to carelessness on the part of food business operators and regulators and, sometimes, it is due to deliberate fraud committed by those who care only about making an illegal profit and think nothing of those to whom they cause harm.
It means that food and drink manufacturers must remain continually vigilant to ensure their procedures – internal food safety and hygiene practices; supply chain traceability systems; and threat analysis critical control procedures – are up to scratch.
Huge challenges ahead (Back to top)
Against this backdrop, the food and drink supply chain is also faced with some huge challenges ahead. First there is Brexit, whose full implications on regulation, trade and staffing have yet to fully emerge, but which will inevitably impact on food safety.
Then there is the squeeze on resources – both human and financial – faced by those that regulate the industry, namely the Food Standards Agency (FSA) and local authority (LA) environmental health departments.
The FSA has already recognised that the system of checks and balances it uses is no longer fit for purpose and is planning to move to more risk-based approach to policing of the sector. It has plans to adopt a system of ‘earned recognition’ for the good guys, which will allow inspectors to focus greater attention on the likely transgressors. At least, that’s the theory.
To make matters worse – and despite the industry being reluctant to acknowledge the fact – increasing competition is putting pressure on some production departments to focus on output at the expense of food hygiene practices, which is leading to corners being dangerously cut.
This situation reinforces the importance of inculcating a culture of good hygiene practices in food factories to ensure that productivity and output targets never trump food hygiene.
The issues raised above were the subject of Food Manufacture Group’s 2017 one-day food safety conference titled: ‘Food Safety 2020: preparing your business for change’, which took place in Leamington Spa, Warwickshire on June 22.
The event was chaired by Professor Steven Walker, director general of Campden BRI and sponsored by: food safety management systems supplier Checkit; hygienic floor systems specialist Dycem; testing laboratory eurofins; X-ray equipment supplier Ishida; hygienic workwear and wet wipe manufacturer Pal International; and Westgate Factory Dividers, which makes industrial partitioning and factory dividers.
Setting the scene for the day was a presentation from Neil Griffiths, retail services director with SGS, on how Brexit is likely to impact food safety legislation and another by John Barnes, food safety consultant with Enmoore and formerly with the Food Standards Agency (FSA), who discussed plans by the FSA to adopt earned recognition as a more risk-based approach to regulation.
Exclusive survey (Back to top)
Then followed a presentation titled: ‘What food safety issues keep factory managers awake at night?’ given by Food Manufacture group editor Mike Stones, which was based on the results of an exclusive online food safety survey carried out on foodmanufacture.co.uk between March and June 2017.
Readers were asked what they considered to be the big food safety issues facing UK food and drink manufacturers as we head towards Brexit and as the FSA changes the way it polices the sector through its Regulating our Future programme.
The results, from the 571 respondents to survey, were surprising in several areas, but less so in others. It provided reassurance that food safety and hygiene remained top of mind for most people working in the sector.
With Brexit and the ‘Great Repeal Bill’ – which is widely expected to adopt in one fell swoop the vast majority of EU legislation into UK law as we leave the union – in prospect, it is probably not surprising that most respondents (67.8%) did not expect the regulatory burden of food safety legislation on businesses to be reduced once the UK left the EU.
More interesting, perhaps, was that a greater number (74.2%) feared that exports to the EU would be damaged were the UK to take the opportunity to significantly change food safety legislation from that which applies in the EU.
Audit burden (Back to top)
It is a common complaint among food businesses that they are overburdened (62%) by third-party food hygiene audits from their retail customers and others. The competence of inspectors and auditors was also called into question by several respondents.
“I am being over-stretched, under-resourced, over-loaded with requests/audits, etc, to the point the core job is being diluted,” complained one compliance manager.
The technical director with an ambient food manufacturer commented: “Retail and BRC [British Retail Consortium] audits try to cover too much ground – the scope is too wide that they lose focus on genuine food safety risks. HACCP [hazard analysis critical control point] programmes are now taken for granted and are rarely challenged.”
But complaints about audits were not restricted to suppliers. The head of technical with a large wholesaler remarked: “BRC could do more to ensure a uniform approach to auditing and increase the trust that buying organisations have in it.
“Our experience is that certain auditing bodies give an ‘easier’ audit than others or do not cover some of the clauses as deeply as you would expect. There is still some way to go with BRC, although the standard itself has become more robust over the last few years.”
So, it might come as a surprise that most respondents (80.9%) want the new government to provide more financial support to the FSA and LA environmental health departments to ensure food is safe.
That is, until the answers to a question about the FSA’s plans to transfer more of the costs of its inspection regime onto food businesses themselves are analysed, which show a more mixed response.
A slight majority, 54% of the 555 who responded, believe food businesses should absorb more of the costs of ensuring food safety in the UK is properly regulated and policed, while 40.1% disagreed with this view.
The survey also identifies that companies are increasingly using social media (60%), such as Twitter and Facebook, as advance warning that they might have a food safety issue with food poisoning outbreaks, before formal announcements and investigations are made.
It is something the FSA and Public Health England are already using quite widely as part of their risk management strategies.
A large majority (74.8%) also believe advanced technologies, such as smart and active packaging; the Internet of Things and nanotechnology, should play a bigger role in reducing food safety incidents.
Given that the wider public is far more suspicious than those working in the industry about the use of science, such as irradiation of food and genetic modification, it would be interesting to compare these results with those from a survey carried out exclusively among consumers.
Microbiologists and other food safety experts working in the agri-food supply chain involved in horizon scanning are increasingly worried about the negative impacts of climate change in the form of new and emerging bacteria and viruses.
Meanwhile, others are also concerned about the overuse of antibiotics – both in humans and in the food chain – and resultant antimicrobial resistance (AMR) that is growing dangerously around the world. In fact, Food Manufacture’s food safety conference heard what the UK poultry sector was doing to reduce its use of antibiotics in flocks.
While our survey did not specifically ask about readers’ concerns about AMR, it did find that most respondents (62.2%) believe climate change poses a serious risk to global food safety as far as the spread of existing pathogens and the emergence of new ones is concerned.
However, most respondents (85.5% – see the chart above) would welcome a move to a more risk-based approach to the policing of food businesses in the UK.
Under this sort of regime, inspections would be targeted at businesses that pose a greater risk and take into account those with a good safety record. For example, third-party audits – such as the BRC’s Global Standard – might be used as a measure of a firm’s hygiene record.
Food safety compromised (Back to top)
Even more contentiously, the survey discovers that a small majority (54.4% – see the chart below) of the 555 respondents to the question agree that food safety is sometimes compromised to ensure production targets and schedules are met. Against this, 40% disagree.
These findings probably explain why food hygiene and safety culture is currently such a hot topic in the food and drink sector. At Food Manufacture’s food safety conference, Sterling Crew, head of technical at Kolak Snack Foods in London, spoke about ‘Creating a strong food safety culture in your workplace’.
Crew addressed the issue of pressure to meet tight production schedules, which leads some food factory workers – even though they know it is wrong – to cut corners and put food hygiene in jeopardy.
His presentation described how to inculcate a food safety culture, so that good food hygiene practices are second nature and embraced from the board to shopfloor.
In the second biggest positive response to any of the survey questions, 83.4% of respondents claim a culture of food safety and hygiene practices permeate their companies. However, some respondents are less happy that the world is quite as rosy as this figure suggests.
“Food safety always seems to be compromised against volume,” said a training manager at a poultry company. A technical manager at another poultry company expressed concern about the lack of “adequate training and comprehension of instructions for those non-English speakers”.
And an academic working with small food companies remarked that her biggest worry was “people getting so wrapped up in paperwork and processes that they forget about practical food safety controls on the shop floor”.
Meanwhile, the boss of a specialist food hygiene company expressed concern about food companies “chasing profit at the expense of food safety”.
A food hygiene specialist speaking at a previous Food Manufacturing food safety conference had raised the problem of maintenance staff disregarding basic hygiene rules when carrying out their work.
It was an issue raised by one health and safety consultant responding to the survey, who lamented the “lack of understanding from the engineering team during plant maintenance”.
An operations director in dairy processing remarked: “Downward pressure on prices from the supermarkets is causing manufacturers to bypass critical procedures to reduce costs and increase shelf-life.”
Meanwhile, another project manager said problems were being caused by a “lack of understanding and training for people and the drive to cost reduce, which resulted in more ‘tick box’ ways of working”.
While that might be attributable to unpremeditated – albeit unacceptable – risk taking on the behalf of some companies and their staff, even more worryingly, fears of “malicious tampering” are mentioned by a number of respondents.
One boss of a food transport company also raised the little-mentioned risk of contamination of food during transport between factories, supermarket regional distribution centres and supermarkets.
He attributed the problem to contaminated food conveyance equipment, such as pallets, trays, roll cages, as well as vehicles themselves. “Contamination by pathogens is rife – yet not a single article ever appears in any publication, seminar or conference, etc,” he complained. “This is not being honest about consumer risk. Out of sight out of mind?”
Food fraud (Back to top)
Following the huge press and TV coverage given to ‘horsegate’ and the subsequent inquiry and recommendations made by Professor Chris Elliott, chair of food safety and microbiology at Queen’s University Belfast, it is perhaps not surprising that 62.7% of respondents felt fraud was a growing problem in the UK food and drink supply chain.
Despite saying that organised food and drink fraud wasn’t currently a big issue in the UK, Andy Morling, head of the FSA’s Food Crime Unit (FCU), warned delegates to last year’s Food Manufacture food safety conference to remain vigilant against opportunistic food fraud and called on those in the sector to share intelligence in confidence with his unit.
Although Morling lamented the food sector’s reluctance to share more information with the FCU – possibly through fear that it might come back to bite those blowing the whistle – he should take heart from the survey’s findings, which showed that 61.8% of respondents trusted the FCU to preserve their anonymity and guarantee protection against being personally targeted were they to share information about illegal practices in the food supply chain.
With opportunity, low risk and financial returns now recognised as being major drivers of food fraud – and with inflation returning to the sector as ingredients costs rise – Morling’s warnings about the potential risks of rising food fraud could prove even more prescient.
Allergen management (Back to top)
One of the biggest causes of food and drink product recalls each year is due to the presence of undeclared allergens.
It comes from one of two sources: cross contamination during manufacture and from incorrectly labelled packs – a frequently encountered problem leading to many recalls. The latter can occur when products are reformulated but the packaging used for them doesn’t reflect this.
While the issue of incorrectly labelled packs containing allergens should be addressed by implementing systems and controls to ensure it doesn’t happen, the problem of accidental, ‘adventitious’ contamination is coming under increasing scrutiny, with health experts and others seeking to find some acceptable level of allergen presence – so-called ‘action’ or ‘threshold’ levels – below which the majority of the population will not suffer an allergic reaction.
Food Manufacture’s food safety conference heard from Dr Rachel Ward, an expert allergy management consultant, who spoke about ‘Reducing allergen recalls’. She offered delegates advice on how to avoid falling foul of costly allergen recalls.
Allergy management was also one of the most frequent concerns raised by respondents to our survey. Complaints ranged from the lack of consistent standards used by different players within the sector to the absence of threshold levels, despite a wealth of clinical studies and other work in this area.
“Retailers’ conflicting approach to allergen management in factory environments is causing much confusion,” claimed the technical director of a snacks supplier, who added: “A unified standard needs to be agreed by all and suitably enforced.”
Another allergen expert with a large multinational also lamented the “inconsistency” in standards, while a logistics specialist pointed to the incorrect labelling of allergens in the supply chain compromising traceability.
A quality expert with a large meat processor pointed to “a lack of clear direction from the regulators on allergens, allergen cross-contamination and threshold levels”. Meanwhile, a technical director in the spices and bakery sector remarked: “Allergens are taking up too much technical time without sufficient back-up for what is a significant risk.”
The future (Back to top)
The future, from a food safety perspective, looks worryingly uncertain – as does the economic future – given the huge changes facing the nation as we leave the EU.
In recognition of the new world order we are entering, the FSA is not only carrying out a major review of how it operates, it is also – together with Food Standards Scotland (FSS) – undertaking a project to understand more about food recall arrangements within the food retail sector.
The system for withdrawals and recalls has never been reviewed before, and the FSA and FSS believe the time is right to take a look at how things are working to make sure they have the most effective system in place for everyone consumers, food business operators and regulators alike.
The project aims to identify what currently works well and where improvements could be made to better protect and inform consumers. The project involves an external stakeholder reference group made up of bodies representing industry, consumers and regulators to help it interpret research findings and identify recommendations to improve the current product recall system.
Expect changes and improvements identified to start being introduced this summer.