This year, Food Manufacture’s Food Safety Briefing looked at the current risks and threats facing the industry and the ones we should be mindful of in the future.
Sponsored by Unibloc Hygienic Technologies, Klüber Lubrication, QAD Redzone and Tracegains, we were joined by four experts who shared their insights. The panel included:
- Selvarani Elahi, UK deputy government chemist and executive director of the Food Authenticity Network
- Callum Whyborne, lead application engineer for Unibloc Hygienic Technologies
- Terry McGrath, chief scientific officer for Bia Analytical
- Alison Johnson, managing director of Food Forensics
- Sterling Crew, chair of the IFST, chair of Food Authenticity Network, and member of the Board of Trustees at The Chartered Institute of Environmental Health
In this article, we are joined once again by Johnson (AJ), McGrath (TM), Elahi (SE), Sterling (SC) and Whyborne (CW) to field the questions we didn’t have a chance to respond to in the live Q&A. Meanwhile, you can still watch the Food Safety Briefing 2024 for free, on-demand here.
Q: Are issues with additives in food contact packaging emerging? Where do we think its heading?
AJ: The increased focus on using recycled material increases the risks of additives no longer being used recycling into current packaging – such as BPA. There are also concerns that legislation such as the EU’s new rules to reduce, reuse and recycle packaging could lead to new packaging being ‘recycled’ to fulfil objectives. The requirements to reduce packaging are diametrically opposed, in some instances, to the requirements to continue to extend shelf life.
We do need to develop more surveillance testing to keep a check on packaging, testing tends to happen at the start of a contract – it should be considered a risk on a batch-by-batch basis.
You specifically asked about additives. I assume therefore you are enquiring about substances intentionally added to plastics to achieve a physical or chemical effect during processing of the plastic or in the final material or article. This may include PFAS or the use of nanosilicas among other items. There are certainly areas that should be considered when approving new packaging materials, particularly recycled materials – migration studies should be undertaken to fully understand the potential risks mindful of the sources of the materials and therefore potential contaminants to consider.
SE: Yes, in relation to the circular economy. In my presentation, I mentioned the migration of non-intentionally added substances from plastic packaging:
- Volatile and semi-volatile organic substances, including surfactants, antioxidants, and odours from decayed food. PBDEs and benzotriazole UV stabilizers
- Organophosphate esters
- Ethanol and ethylene glycol; and flavourings such as anethole and limonene
- PAHs, PBDEs, and PCBs.
This FAO report gives further information: Food safety in a circular economy.
Q: What are the latest technologies and methods that companies can implement to combat food fraud effectively?
SE: The FAN is an open access website that contains invaluable and free curated information that smaller businesses can use. It is free to sign up and as a member you will receive a monthly summary of activity that serves as a great horizon scanning tool. In addition, FAN contributed to the FDF’s 2024 Food Authenticity: Five steps to help protect your business from food fraud.
AJ: Firstly, use insight and intelligence and combine this with historical testing results. Use the data to drive dynamic, actionable insights. Once you understand the risk it is straightforward to determine the most appropriate testing.
There are lots of available methods, all have strengths and weaknesses. Ensuing a range of methods makes your testing unpredictable which adds an additional (and free!) deterrent into the mix.
As an example – for herbs and spices you could alternate between FT-IR which can detect spent material, dilution with other materials etc.; Next Generation Sequencing – which has a much lower detection level but only detects adulteration with other DNA-containing material pesticide residues – information on where it was grown and are the actives detected (hopefully below the MRLs) consistent with spray plans etc.; or with organic production – pesticide residues check for non-permitted treatments, isotope testing detects whether synthetic fertilisers have been used.
These are examples, there are origin, variety, compositional, contaminants tests which also help signpost for authenticity. Be unpredictable.
Q: Are there any allergen risks we should be aware of with the move to eating insects.
SC: Insects are extremely rich in protein. It is likely they will be used more widely in our diet. The protein Tropomyosin which is a major allergen found in crustaceans (such as prawns crabs and lobsters) is also present in insects. So will have the same effect on those who suffer from this particular food hypersensitivity.
People who suffer from a reaction to this allergen are aware that it is present as it is clearly labelled by law on UK packaging as one of the 14 listed allergens.
We need to make sure that the presence of insects and the associated risk are clearly labelled, so consumers can make an informed choice.
Q. How can smaller businesses manage the world of food fraud – when teams are more stretched, knowledge perhaps not as deep, and costs tighter?
AJ: Use tools such as risk newsletters to identify risks and focus on what is important within your business. Reach out to businesses that specialise in this area – we can usually offer business-appropriate guidance and solutions. The important take away is to do something. We would also recommend linking in with FiiN for information sharing.
Q: What about bigger manufacturers – how can they enhance their risk assessment processes?
AJ: We see some really good risk assessments and horizon scanning in larger organisations, but often the link to make the insights actionable is missing.
Risk assessments may still be considered an annual event – unfortunate risk is not. Larger businesses collect lots of information – test results, price increase requests, shortages, quality issues, supply business restructures etc – all of these provide valuable insight.
Finding a way to link these into the risk assessments and use this to inform risk mitigations will hugely enhance the risk assessment processes. We would also recommend linking in with FiiN for information sharing.
Q: You mentioned data sharing as a valuable tool for food fraud – but could this be used against producers given the rise of cyberattacks?
TM: An anonymised way of sharing data is needed. this has worked within FIIN. in theory there is always a risk if the right company is targeted (the one who anonymises the data) but extra precautions can be put in place to ringfence certain parts of their data.
AJ: I agree this needs to be used cautiously and cyber security of all data-sharing platforms (be it laboratory results in portals through to FiiN and other similar platforms) must be considered.
Ask how data is handled, stored and transmitted. Is it stored in an encrypted format? What security is in place for the site? Is two-factor authentication used? Does the provide hold any security accreditations (such as cyber essentials etc).
SE: Cyberattacks are usually related to IT security and not due to data sharing. Authenticity databases are particularly important for verification of the authenticity of unknown samples. These can be very expensive to set-up and curate, and so they are usually protected by IP, which does not encourage sharing of the information. However, there is very little visibility of what authenticity databases exist and who owns them. This is why FAN set-up the Authenticity Database search tool; we currently signpost to 216 authenticity databases.
Q: How concerned should we be about the level of antibiotic resistant bacterial contamination in food? (Given increasing intensification of some sectors of the meat industry - pigs and poultry.)
AJ: There has been some really encouraging work to reduce the use of antibiotics in livestock production, RUMA (responsible use of medicines in agriculture) has done a great job of capturing data, goal setting and monitoring targets for reduction. These have been supported by farm assurance schemes.
Of greater concern is the use of antibiotics outside the EU where regulation may be less rigorous, and use of banned drugs is more likely.
It is also worth bearing in mind that there is a trade-off between treating livestock with the associated risks (such as AMR) and not treating – zoonosis. The industry has moved forward in this area over the last 20 years and continues to, but increasing use of vaccines, breeding for higher natural resistance combined with better husbandry and management will all play a part in this area.
SE: Antimicrobial resistance (AMR) surveillance is crucial for understanding the development and spread of AMR across animals, humans, food and the environment. The Pathogen Surveillance in Agriculture, Food and Environment (PATH-SAFE) programme uses the latest DNA-sequencing technology and environmental sampling to improve the detection and tracking of foodborne disease and AMR.
Q: Are there any new key controls that companies should be looking to implement over the next 3 years?
AJ: Making intelligence and insight dynamic and applying mitigations to manage risk (mitigation may be greater supplier scrutiny, targeted audits, testing, changing supplier or reformulating to eliminate the risk).
SE: The current climate of geopolitical instability looks likely to continue into the foreseeable future impacting global food supply chains, so it is important that FBOs remain vigilant. It is critical to know your supplier base and identify risks that are relevant to your business/supply chain so that you can put in place specific prevention plans. FAN publishes an annual report on the top ten foods with the most global official food fraud reports.
Also, the importance of company culture in achieving food safety excellence is being increasingly accepted, so ensuring all employees share the company’s vision is important.
TM: Stay vigilant and push your risk assessments/due diligence checks as priority so that they are fresh and not years-old thoughts.
Q: Is the portable device planned to receive certification? Many retailers outline accreditation requirements used for the method of testing
TM: The portable test is a screening tool. It is designed to allow you to put through lots of samples so that you only need to send suspicious samples to the lab for accredited testing.
UK Government and EU have implemented this approach for many years in their surveillance testing for drug residues and pesticides.
Q: Labs have always said to me manufacturers need to know what they want to solve and why – but when you’re a new company that can be difficult. What kinds of testing do producers need to be asking for when it comes to food fraud?
TM: The important thing is to understand your supply chain - every little detail. This will then inform you of your exposure to risks as new issues emerge.
The issue is not really about what kinds of tests you should use but more about how someone can create a fraud opportunity for a particular commodity/ingredient.
Testing is not always the first option. Good monitoring can help by showing that you have your supply chain at the forefront of your thinking thus reducing the opportunity.
Q: You spoke about sensors within your presentation and of course predictive maintenance – do you believe this is where the sector is heading and how far until we get there?
CW: Current market research suggests yes, we will eventually get to a point where we are relying on advance system-based techniques as opposed to traditionally collected data. The timeframe is really an unknown, as with anything, it all depends on the product and process development over time.
Q: How are you ensuring your equipment is designed with the future in mind?
CW: By ensuring that we comply with all current, and upcoming regulations within the sectors which we operate. Each and every design we patent considers the legislative demands our products must conform to.
Q: Are there any other technical advantages to the Flotronic One Nut AODD?
CW: Yes, there are many more which are better suited/catered to specific application requirements. Please reach out to m directly to discuss.
Q: Recalls are often allergen-related, why do you believe this is still such a prevalent issue and what can we do to ensure these consumers are protected?
AJ: Manufacturing has moved to a just-in-time process to maximise shelf-life. This makes it almost impossible to undertake positive release raw material intake testing. As a result, there is a reliance on COAs and risk assessments.
While these are reasonably effective at-risk-management of known issues they offer little protection for the unexpected. For example, raw material adulteration or unexpected contamination through the system from a new or missed risk area.
Testing at the finished product level is too late, focus on mitigation must happen higher up the supply chain.
Where finished product testing is helpful is for detecting manufacturing errors, such as mispacking as well as labelling errors. These should be adequately managed by good manufacturing practice.
There is no easy answer for this situation. With such complex supply chains and the trading of blended materials there will continue to be increasing risks in this area. Businesses must decide how they can best manage these risks. It may be from a consumer perspective the use of unpopular precautionary allergen labelling combined with focus on ‘free from’ claimed ranges may be the most pragmatic approach. Businesses are implementing (in the main) best practices within the constraints of commercial operations, but these will never protect from the unexpected.
SE: The primary reason for food allergen recalls is the omission of priority allergens from the list of ingredients. Other reasons for recalls include cross-contamination, mislabelling, products in the wrong packaging, and Items found to contain allergens they were declared free from.
A cross-government Knowledge Transfer (KT) programme has produced two eSeminars, which give guidance on precautionary allergen labelling:
- E-Seminar: Introduction to food allergen risk assessment - GOV.UK
- Food Allergens Risk Assessment Part 2 - GOV.UK
Q: Any insights re: cocoa & supply vs. demand issues? I don't think this is getting enough ‘recognition’ at present.
AJ: There is lots of information, intelligence and insight on this issue within the Food Forensics Knowledge Base (as there is also on coffee beans). Limited supply, high prices and strong demand present a perfect storm.
Fraud is highly likely in these supply chains – adulteration with cocoa husks, carob flour, chicory as well as peanut shells and other materials. This may introduce unexpected allergens into chocolate. Keeping tight control over supply chains and authenticity surveillance are critical at present.
Q: Can you expand on the risks associated with skills what kind of threats could this create and how can we resolve this issue?
SE: Appropriately qualified and trained people are vital for the future of the food and drink industry. Technical managers often deal with safety, authenticity, quality, legality, nutrition, sustainability, social compliance, staff management, organisational culture, analytical test results and cost. In the UK today, around 40 universities offer food science and technology degrees that are geared to developing the skills required compared to a handful 20 years ago.
However, skills shortages have been identified in the UK (in the 2022 and 2023 FSA & FSS ‘Our Food’ reports; noting long-term decline in funding for local authorities and allocation of resource away from food safety and food standards duties over the last decade, leading to a 45.1% drop in the number of food standards officer allocated posts from 2011/12 to 2021/22 in England, Wales and Northern Ireland.
There is also an inadequate supply and availability of official veterinarians to uphold food safety, animal health and welfare standards in abattoirs. With the Royal College of Veterinary Surgeons reporting a 27.4% fall in the number of people joining the veterinary profession between 2019 and 2022 and the reluctance among UK qualified vets to take on public health roles. Meaning that 99% of the official veterinaries (OVs) working in abattoirs come from overseas.
Staff shortages will continue until a long-term cross-government solution is found to create a robust and sustainable system. In the interim, FSA has been supporting public analysts through capability building grants.
Q: Can you give examples on food terrorism?
SE: UK food legislation is not intended to cover food terrorism, whereas the US Food Safety Modernization Act does; attacks intended to cause wide scale public health harm to humans including acts of terrorism focused on the food supply. I do not know of examples myself but found this WHO report: Microsoft Word - FInal_En_Terrorism and food.doc, which cites some examples.
AJ: There is a really nice paper on this. Extracts from that paper -
In 2003, the US Food and Drug Administration (FDA) declassified a document in which it stated that a large number of people would be harmed by an act of ‘food terrorism’.
Between 1950 and 2008, CENS identified 365 incidents that could be verified as food defence incidences. Only four incidents could be attributed to a terrorist group; the last confirmed incident was a failed attempt in 1992 by a cell of the Kurdistan Workers’ Party (PKK) to poison the water tank at an airbase in Turkey.
The most widely known case is that of the Rajneeshee cult, in which 751 people were reportedly injured when the cult deliberately contaminated a number of salad bars in a small town in Oregon, USA with a variant of salmonella.
Risks of hepatitis, anthrax, botulism etc., would all cause significant issues if introduced maliciously into the food supply chain.
Q: Alison mentioned threat of dioxins and micro plastics in flood water, dioxins are presence primarily in fat - therefore is micro fat dispersion in water. Would mineral oils – e.g. MOSH and MOAH – be a threat?
AJ: Quite possibly. Where we see flooding there is often oil visible on the water – as a result MOSH and MOAH would be risks.
Q: In terms of the risks you mentioned related to meal kits – do you believe that stricter regulations or new technologies will come in to help ensure safer food delivery?
SE: Yes, I think technology already exists in terms of smart packaging/temperature sensors that could be placed on/in meal kit boxes to show temperature and time. However, there must be the will to do this by all parties concerned whilst maintaining competitive price points.
You can read our summary of the session here, which flags 7 major food safety threats to watch out for.