11 October 2013
Response to Defra for Nick Hughes (reviewfoodintegrityassurance@defra.gsi.gov.uk)
Please find IFST response to the call for evidence questions below.
1. What measures need to be taken by the UK food industry and government to increase consumers trust in the integrity of the food supply systems?
Consumer trust will be enhanced by a robust outcome to the investigations of how the horsemeat scandal happened and appropriate penalties for identified wrongdoers. This should be supplemented by proactive ‘policing’ of food authenticity in the future. Food industry and government should campaign together to communicate clearly to the consumers the measures taken to ensure the safety and authenticity of food. Balanced food supply chain involves food consumer engagement and education of lengths the food industry takes to provide safe food and the challenges face by the food industry which doesn’t come without a cost.
2. The Terms of Reference for the Review require an approach that is proportionate to the risks involved to the consumer. What does this mean in practice?
In practice we believe this means taking account of risks with regard to fraud, consumer choice and safety. We support Commissioner Borg’s 5 point action plan. We also support the Commission’s stated position that where financial penalties are used in relation to intentional violations of food chain law, they are at a level which is sufficiently dissuasive and higher than the economic gain expected from the fraud. So too we support that it will also be expected that Member States include in their control plans and perform regularly mandatory unannounced official controls (including inspections and testing) directed at combating food fraud and the Commission wish to be able to impose (not just recommend) coordinated testing programmes in specific cases, in particular in case of fraud. The out-workings of the above plan will determine much of what will be put in place in the UK in the future and it is timely that Regulation 882/2004 on official controls is under review.
The approach also must deal with imports into the EC again using risk analysis to identify the countries and products most likely to be subject to fraud and substitution.
The food industry and government should work collaboratively using intelligent systems and data sharing to combat fraudulent practices allowing resources to focused and used more effectively.
3. How can government, food businesses and regulators better identify new and emerging forms of food fraud?
We suggest that proactive ‘policing’ of food authenticity in the future, identification of any product or group or products where significant money can be made by fraud and substitution. We also suggest global intelligence gathering and sharing on food fraud which allows better identification for new and emerging forms of food fraud. This should not be limited to high volume low cost meat or meat-like products, but also for example oils and high value spices to name few.
4. Food supply chains have variable economic factors impacting on price at every stage. Which factors in relation to risks of potential fraud are most influential and are there trends developing?
Scarcity, protein demand and cost, easy of manufacture/distribution and sale, cost benefit, provenance, easy of detection.
5. Do consumers fully understand the way industry describes the composition and quality of the products on sale?
We do not believe that consumers fully understand the way industry describes the composition and quality of the products on sale but that smarter labelling will help. If anything we need to make labels simpler, and easier to understand in the seconds or less that a consumer actually has to read them. Often the call is for more labelling, but actually labelling which consumer reads is needed – and this does not mean using logos instead of text as the logos are just as prolific.
There is a need for a consumer education related to the labelling and food choices. Challenge is to improve knowledge of a complex food system and motivate consumers to choose food which is proven to be produced minimising any possibilities for the negative interference to food safety and integrity.
6. Has the consumer developed unrealistic expectations of the food industry and if so, what role is there for the food industry and government in doing something about it?
In some senses consumers have developed unrealistic expectations of the food industry, for example there is little appreciation of the true economics of meat production and especially the cost of diversion or disposal of carcase parts not readily consumed in the UK. Government should campaign together with food industry and other professional bodies to make food supply chain more transparent and explain how safe food reaches our tables and the constraints the food industry has faced.
7. Do government decisions about regulation and inspection get the balance right between producer, processor, retailer and consumer when it comes to food? Do further measures need to be taken by the EU or by the UK government to increase consumer trust?
We support Commissioner Borg’s 5 point action plan (see above) but having said that we believe that rather than impose further measures government should ensure that there is sustainable pre-planned centrally coordinated and effective enforcement of the measures already available.
Also global intelligence gathering and sharing on food fraud which allows better identification for new and emerging forms of food fraud would increase consumer trust.
8. What impact could fraud have on the safety of food consumed in the UK?
Fraud has the potential for huge impact on food safety. It places unknown risks into the supply chain e.g. unwitting consumption of allergens, microbiological problems, pesticide and veterinary residues, illegal additives, methanol, etc. Food fraud also poses real potential problems of the ‘unknown’ variety.
9. What implications do the recent changes to the public health responsibilities of English local authorities have for food inspection and enforcement regimes?
IFST is not commenting to this question.
10. What control systems do food businesses have in place for assuring themselves that the food they supply is of the nature and quality they expect? How have these systems been tightened since the horsemeat fraud was identified?
This should be assessed in the light of guidelines such as IFST GMP 6th Ed and the use of GFSI recognised schemes such as BRC6. There are currently, in development, a number of industry driven initiatives that will ensure control mechanisms are in place in relation to potential fraudulent activity however there should be a coordinating body to ensure the best possible result for initiatives to develop to a solid guidance which is distributed widely to the all relevant parties.
11. How can large corporations relying on complex supply chains improve both information and evidence as to the traceability of food?
Complex supply chains are here to stay and are not only limited to large food businesses but can also be seen in many other industries. Promises made to source items from the UK are helpful, but are only relevant obviously for things we can produce in the UK and there are still many items we have to source as imports. Unfortunately UK sourced does not mean a guarantee of authenticity – fraud can and does happen anywhere there is money to be made. We suggest that strict adherence to guidelines such as IFST GMP 6th Ed. and compliance to GFSI recognised schemes such as BRC6, where there are a number of requirements which place specific emphasis on best practice product procurement such as supplier approval and monitoring, product analytical programmes, specifications, traceability and complaint handling.
12. Should there be legislative requirements for tamper proof labelling, and/or to advise competent authorities of mislabelling if it is discovered in the supply chain?
Tamper proof labelling has no real bearing on food fraud as there are very good examples where the packaging itself may be counterfeit e.g. Alcoholic drinks. Tamper proof packaging does add a level of security in relation to deliberate malpractice or accidentally damage, but again the main function of tamper proof packaging is to highlight any malpractice within the food supply chain.
In relation to mislabelling the notification should be based on the principles supporting the EU General Food Law where the food business operator must inform the competent if there has been or suspects there has been unsafe product placed into the supply chain.
13. What additional information does the public need to be offered about food content and processing techniques? How can this information be conveyed in an easy to understand manner?
Challenge is to find an interesting way to educate food consumers and fill the large gap between what customers know about food production and what actually happens. As a consequence of industrialisation of society and the move away from a rural economy it is more difficult be connected with food and the origin and content of it. Food consumer is not likely to be interested of the food processing techniques however access to all the additional information should be available if easily if needed. Food labelling is one way of communication this and it has to be honest and transparent labelling argument however it has its limitations. However, the key word in the question is “offered”. So, this means available if wished for, so not on every label by default. There are many means nowadays for interested customers to find out more, from simply asking at the customer service desk, to following web links and Q-codes and no doubt more around the corner. In terms of being easy to understand, that is a matter for wordsmiths and such like to use their skills.
14. Whose responsibility is it to give the public assurances about the safety and quality of food?
Public assurances about the safety and quality of food is the responsibility of the food industry supported by sustainable and convincing regulation and enforcement of food law involving everyone from farmer to retailer/restaurant, government and professional bodies.
These assurances provided by either party should be open, trustworthy and comprehensive. When consumer trust is in question we have seen the media play a role in which tends to focus upon Government, which in most cases is not helpful. One should look at the lessons learned after the Sudan 1 incident in 2005 where the media challenged the Food Standards Agency rather than the food manufacturers and food retailers.
15. How should information about traceability be presented to the public? What level of public understanding is there about traceability and food adulteration?
Born, reared and slaughtered information seems to be well understood, but unfortunately are only relevant to meat. The issue on traceability goes beyond meat to all food and drink products and ingredients. Public would not necessarily understand or need to understand the detail behind traceability systems but should understand the principles that food should be controlled and identifiable within the food supply chain. For example if compound product consist a recipe meal with 20+ ingredients there is no purpose of presenting the traceability of the 20+ ingredients for the consumer. Such information does not prevent fraud. If someone earlier in the chain has substituted an ingredient then any subsequent labelling is irrelevant.
The EU General Food Law is not helpful here either as this lays down the minimum legal requirements, which in virtually all cases the food industry exceeds e.g. the requirement for full internal traceability.
16. Where multiple ingredients are used in food processing to create a dish, should country of origin information be made available for them all? What do the public care most about?
Public cares about integrity of the food product most of all but country of origin information doesn’t contribute to the stopping fraud. Cost impacts to the food industry has to be also considered in the situations where an ingredient maybe sourced from a number of countries and in some cases blended from a number of sources. The food industry is looking for ingredients of specified quality and attribute but irrespective of source must be safe. A good example would be vegetable oil which may be sourced from a number of countries (due to factors such as cost, seasonality and availability) and in many cases blends are used.
There has to be another system in place to stop food fraud than making country of origin information available for all ingredients. Public cares about the food integrity and the forum to communicate product meeting the expectations has to easily accessible for example on the website of the product.
Public is likely to care most about high value / high cost ingredients and bulking agents such as water.
17. Should caterers/restaurants and those providing food ready to eat direct to the consumer be required to provide more information? For example, should an item such as ‘Fish and Chips’ on a menu always state which fish has been used?
This form of labelling should not be mandatory, again as this would add significant cost and possibly lack of flexibility of production for the reasons given above. In the majority of cases the caterer/restaurant will have direct knowledge of the product and source and this information should be available, if requested. There is also in place Trade Description as well as Food Labelling legislation to be considered here.
18. Are there shortcomings in the inspection and enforcement tools available to the FSA and local authorities?
We believe better coordination, publicly available information on outcomes, funding for targeted speculative sampling and analysis and agreed coordinated planning for the future of enforcement will assist.
19. Can substitution or adulteration ever be considered ‘harmless’?
Given the level of control required under current legislation these practices should be considered as being potentially harmful and by definition unsafe.
20. Is it appropriate to base inspection and enforcement action on perceptions of risk, or should a zero tolerance approach be taken to all food fraud?
A balanced view on this is required but as with ‘volume crime’ we believe DNA techniques can be used to address ‘volume food fraud’ so that a zero tolerance approach can be approximated.
21. Does current intelligence make best use of the evidence available, and take adequate account of risk factors such as commercial reputation and public confidence?
Food businesses are well aware of commercial reputation and public confidence, but in relation to the use of evidence and intelligence the systems currently under development will look at these factors and develop best industry practice on vulnerability.
22. Does the Five Point Plan proposed by Commissioner Borg contain the necessary levers to achieve effective change? What further actions might be needed?
Creative thinking on funding will be required to support Commissioner Borg’s plan.
23. Is there evidence that the machinery of Government changes in 2010 for England (which led to Defra taking over responsibility for authenticity and compositional policy) have made food supply networks more vulnerable to fraud?
The changes did not help, and whilst there was the potential for disruption, it appears that in spite of this officials worked well together after the machinery of government changes. It has to be said though that the interruption in continuity and the decline in food authenticity surveys may have played a part in the vulnerability to fraud.
24. Are there gaps in analytical approaches to support food testing, to verify authenticity and to enforce food law? Which areas in food authenticity should be prioritised for method development and validation to support testing?
For the meat industry, the detection of designated meat in mixtures with legitimate meat and quantitative DNA approaches to meat speciation are important as are the recently publicised methods for verifying country of origin. .From an overall food industry perspective, there must be continued investment in, and confidence in the competence of, the official control system.
Additionally vulnerability assessments must also the shared between industry and Governments to allow the prioritisation of the developments of analytical techniques to accurately verify food authenticity.
25. What are the cost burdens and financial benefits to food businesses of current approaches to assurance, information and regulation? What have been the financial and other impacts of recent food frauds?
IFST is not commenting to this.
26. What impact does increased sourcing of locally produced foods have on food authenticity and food prices? Is a shortening of supply chains likely to improve traceability?
It is possible that increased local sourcing will increase prices/reduce availability of some items, thus making them perhaps candidates for fraud; the most likely would be claiming to be local when not. Shorter supply chains make traceability simpler, but do not guarantee that there will not be any fraud. A complex supply chain can and should still have effective traceability.
27. If additional testing of food products for authenticity is required across a wide range of commodities, can this be kept proportionate, relevant and timely?
Planned rotation of audit and testing through the known possibilities for food fraud following regular vulnerability assessments.
28. Additional testing for food authenticity across a wide range of commodities will have a significant cost. Who should be responsible for absorbing these costs?
All in the production chain, from farmers, producers, importers, retailers/restaurateurs, and customers.
Any testing carried out by Government should not be passed onto the food business operators.
29. Other than for allergens, how significant are the issues raised by trace contamination from carry-over from equipment previously used for other food types? What can be done to reduce the level of carry-over while ensuring that the response is proportionate? At what level of trace contamination is there a need to require separate production lines for different products?
The level of advantageous contamination in relation to GMO can be considered as a precedent. This is regarded as industrial best practice in the sectors affected by possible cross contamination of GMO.
We also suggest the outcomes of current research commissioned by Defra from LGC should be awaited
On the behalf of the institute of Food Science and Technology
Marjo Kiiveri
Technical and Registration Officer
11 October 2013
Review into the Integrity and Assurance of Food Supply Networks – Call for Evidence questions
Response to Defra for Nick Hughes (reviewfoodintegrityassurance@defra.gsi.gov.uk)
Please find IFST response to the call for evidence questions below.
1. What measures need to be taken by the UK food industry and government to increase consumers trust in the integrity of the food supply systems?
Consumer trust will be enhanced by a robust outcome to the investigations of how the horsemeat scandal happened and appropriate penalties for identified wrongdoers. This should be supplemented by proactive ‘policing’ of food authenticity in the future. Food industry and government should campaign together to communicate clearly to the consumers the measures taken to ensure the safety and authenticity of food. Balanced food supply chain involves food consumer engagement and education of lengths the food industry takes to provide safe food and the challenges face by the food industry which doesn’t come without a cost.
2. The Terms of Reference for the Review require an approach that is proportionate to the risks involved to the consumer. What does this mean in practice?
In practice we believe this means taking account of risks with regard to fraud, consumer choice and safety. We support Commissioner Borg’s 5 point action plan. We also support the Commission’s stated position that where financial penalties are used in relation to intentional violations of food chain law, they are at a level which is sufficiently dissuasive and higher than the economic gain expected from the fraud. So too we support that it will also be expected that Member States include in their control plans and perform regularly mandatory unannounced official controls (including inspections and testing) directed at combating food fraud and the Commission wish to be able to impose (not just recommend) coordinated testing programmes in specific cases, in particular in case of fraud. The out-workings of the above plan will determine much of what will be put in place in the UK in the future and it is timely that Regulation 882/2004 on official controls is under review.
The approach also must deal with imports into the EC again using risk analysis to identify the countries and products most likely to be subject to fraud and substitution.
The food industry and government should work collaboratively using intelligent systems and data sharing to combat fraudulent practices allowing resources to focused and used more effectively.
3. How can government, food businesses and regulators better identify new and emerging forms of food fraud?
We suggest that proactive ‘policing’ of food authenticity in the future, identification of any product or group or products where significant money can be made by fraud and substitution. We also suggest global intelligence gathering and sharing on food fraud which allows better identification for new and emerging forms of food fraud. This should not be limited to high volume low cost meat or meat-like products, but also for example oils and high value spices to name few.
4. Food supply chains have variable economic factors impacting on price at every stage. Which factors in relation to risks of potential fraud are most influential and are there trends developing?
Scarcity, protein demand and cost, easy of manufacture/distribution and sale, cost benefit, provenance, easy of detection.
5. Do consumers fully understand the way industry describes the composition and quality of the products on sale?
We do not believe that consumers fully understand the way industry describes the composition and quality of the products on sale but that smarter labelling will help. If anything we need to make labels simpler, and easier to understand in the seconds or less that a consumer actually has to read them. Often the call is for more labelling, but actually labelling which consumer reads is needed – and this does not mean using logos instead of text as the logos are just as prolific.
There is a need for a consumer education related to the labelling and food choices. Challenge is to improve knowledge of a complex food system and motivate consumers to choose food which is proven to be produced minimising any possibilities for the negative interference to food safety and integrity.
6. Has the consumer developed unrealistic expectations of the food industry and if so, what role is there for the food industry and government in doing something about it?
In some senses consumers have developed unrealistic expectations of the food industry, for example there is little appreciation of the true economics of meat production and especially the cost of diversion or disposal of carcase parts not readily consumed in the UK. Government should campaign together with food industry and other professional bodies to make food supply chain more transparent and explain how safe food reaches our tables and the constraints the food industry has faced.
7. Do government decisions about regulation and inspection get the balance right between producer, processor, retailer and consumer when it comes to food? Do further measures need to be taken by the EU or by the UK government to increase consumer trust?
We support Commissioner Borg’s 5 point action plan (see above) but having said that we believe that rather than impose further measures government should ensure that there is sustainable pre-planned centrally coordinated and effective enforcement of the measures already available.
Also global intelligence gathering and sharing on food fraud which allows better identification for new and emerging forms of food fraud would increase consumer trust.
8. What impact could fraud have on the safety of food consumed in the UK?
Fraud has the potential for huge impact on food safety. It places unknown risks into the supply chain e.g. unwitting consumption of allergens, microbiological problems, pesticide and veterinary residues, illegal additives, methanol, etc. Food fraud also poses real potential problems of the ‘unknown’ variety.
9. What implications do the recent changes to the public health responsibilities of English local authorities have for food inspection and enforcement regimes?
IFST is not commenting to this question.
10. What control systems do food businesses have in place for assuring themselves that the food they supply is of the nature and quality they expect? How have these systems been tightened since the horsemeat fraud was identified?
This should be assessed in the light of guidelines such as IFST GMP 6th Ed and the use of GFSI recognised schemes such as BRC6. There are currently, in development, a number of industry driven initiatives that will ensure control mechanisms are in place in relation to potential fraudulent activity however there should be a coordinating body to ensure the best possible result for initiatives to develop to a solid guidance which is distributed widely to the all relevant parties.
11. How can large corporations relying on complex supply chains improve both information and evidence as to the traceability of food?
Complex supply chains are here to stay and are not only limited to large food businesses but can also be seen in many other industries. Promises made to source items from the UK are helpful, but are only relevant obviously for things we can produce in the UK and there are still many items we have to source as imports. Unfortunately UK sourced does not mean a guarantee of authenticity – fraud can and does happen anywhere there is money to be made. We suggest that strict adherence to guidelines such as IFST GMP 6th Ed. and compliance to GFSI recognised schemes such as BRC6, where there are a number of requirements which place specific emphasis on best practice product procurement such as supplier approval and monitoring, product analytical programmes, specifications, traceability and complaint handling.
12. Should there be legislative requirements for tamper proof labelling, and/or to advise competent authorities of mislabelling if it is discovered in the supply chain?
Tamper proof labelling has no real bearing on food fraud as there are very good examples where the packaging itself may be counterfeit e.g. Alcoholic drinks. Tamper proof packaging does add a level of security in relation to deliberate malpractice or accidentally damage, but again the main function of tamper proof packaging is to highlight any malpractice within the food supply chain.
In relation to mislabelling the notification should be based on the principles supporting the EU General Food Law where the food business operator must inform the competent if there has been or suspects there has been unsafe product placed into the supply chain.
13. What additional information does the public need to be offered about food content and processing techniques? How can this information be conveyed in an easy to understand manner?
Challenge is to find an interesting way to educate food consumers and fill the large gap between what customers know about food production and what actually happens. As a consequence of industrialisation of society and the move away from a rural economy it is more difficult be connected with food and the origin and content of it. Food consumer is not likely to be interested of the food processing techniques however access to all the additional information should be available if easily if needed. Food labelling is one way of communication this and it has to be honest and transparent labelling argument however it has its limitations. However, the key word in the question is “offered”. So, this means available if wished for, so not on every label by default. There are many means nowadays for interested customers to find out more, from simply asking at the customer service desk, to following web links and Q-codes and no doubt more around the corner. In terms of being easy to understand, that is a matter for wordsmiths and such like to use their skills.
14. Whose responsibility is it to give the public assurances about the safety and quality of food?
Public assurances about the safety and quality of food is the responsibility of the food industry supported by sustainable and convincing regulation and enforcement of food law involving everyone from farmer to retailer/restaurant, government and professional bodies.
These assurances provided by either party should be open, trustworthy and comprehensive. When consumer trust is in question we have seen the media play a role in which tends to focus upon Government, which in most cases is not helpful. One should look at the lessons learned after the Sudan 1 incident in 2005 where the media challenged the Food Standards Agency rather than the food manufacturers and food retailers.
15. How should information about traceability be presented to the public? What level of public understanding is there about traceability and food adulteration?
Born, reared and slaughtered information seems to be well understood, but unfortunately are only relevant to meat. The issue on traceability goes beyond meat to all food and drink products and ingredients. Public would not necessarily understand or need to understand the detail behind traceability systems but should understand the principles that food should be controlled and identifiable within the food supply chain. For example if compound product consist a recipe meal with 20+ ingredients there is no purpose of presenting the traceability of the 20+ ingredients for the consumer. Such information does not prevent fraud. If someone earlier in the chain has substituted an ingredient then any subsequent labelling is irrelevant.
The EU General Food Law is not helpful here either as this lays down the minimum legal requirements, which in virtually all cases the food industry exceeds e.g. the requirement for full internal traceability.
16. Where multiple ingredients are used in food processing to create a dish, should country of origin information be made available for them all? What do the public care most about?
Public cares about integrity of the food product most of all but country of origin information doesn’t contribute to the stopping fraud. Cost impacts to the food industry has to be also considered in the situations where an ingredient maybe sourced from a number of countries and in some cases blended from a number of sources. The food industry is looking for ingredients of specified quality and attribute but irrespective of source must be safe. A good example would be vegetable oil which may be sourced from a number of countries (due to factors such as cost, seasonality and availability) and in many cases blends are used.
There has to be another system in place to stop food fraud than making country of origin information available for all ingredients. Public cares about the food integrity and the forum to communicate product meeting the expectations has to easily accessible for example on the website of the product.
Public is likely to care most about high value / high cost ingredients and bulking agents such as water.
17. Should caterers/restaurants and those providing food ready to eat direct to the consumer be required to provide more information? For example, should an item such as ‘Fish and Chips’ on a menu always state which fish has been used?
This form of labelling should not be mandatory, again as this would add significant cost and possibly lack of flexibility of production for the reasons given above. In the majority of cases the caterer/restaurant will have direct knowledge of the product and source and this information should be available, if requested. There is also in place Trade Description as well as Food Labelling legislation to be considered here.
18. Are there shortcomings in the inspection and enforcement tools available to the FSA and local authorities?
We believe better coordination, publicly available information on outcomes, funding for targeted speculative sampling and analysis and agreed coordinated planning for the future of enforcement will assist.
19. Can substitution or adulteration ever be considered ‘harmless’?
Given the level of control required under current legislation these practices should be considered as being potentially harmful and by definition unsafe.
20. Is it appropriate to base inspection and enforcement action on perceptions of risk, or should a zero tolerance approach be taken to all food fraud?
A balanced view on this is required but as with ‘volume crime’ we believe DNA techniques can be used to address ‘volume food fraud’ so that a zero tolerance approach can be approximated.
21. Does current intelligence make best use of the evidence available, and take adequate account of risk factors such as commercial reputation and public confidence?
Food businesses are well aware of commercial reputation and public confidence, but in relation to the use of evidence and intelligence the systems currently under development will look at these factors and develop best industry practice on vulnerability.
22. Does the Five Point Plan proposed by Commissioner Borg contain the necessary levers to achieve effective change? What further actions might be needed?
Creative thinking on funding will be required to support Commissioner Borg’s plan.
23. Is there evidence that the machinery of Government changes in 2010 for England (which led to Defra taking over responsibility for authenticity and compositional policy) have made food supply networks more vulnerable to fraud?
The changes did not help, and whilst there was the potential for disruption, it appears that in spite of this officials worked well together after the machinery of government changes. It has to be said though that the interruption in continuity and the decline in food authenticity surveys may have played a part in the vulnerability to fraud.
24. Are there gaps in analytical approaches to support food testing, to verify authenticity and to enforce food law? Which areas in food authenticity should be prioritised for method development and validation to support testing?
For the meat industry, the detection of designated meat in mixtures with legitimate meat and quantitative DNA approaches to meat speciation are important as are the recently publicised methods for verifying country of origin. .From an overall food industry perspective, there must be continued investment in, and confidence in the competence of, the official control system.
Additionally vulnerability assessments must also the shared between industry and Governments to allow the prioritisation of the developments of analytical techniques to accurately verify food authenticity.
25. What are the cost burdens and financial benefits to food businesses of current approaches to assurance, information and regulation? What have been the financial and other impacts of recent food frauds?
IFST is not commenting to this.
26. What impact does increased sourcing of locally produced foods have on food authenticity and food prices? Is a shortening of supply chains likely to improve traceability?
It is possible that increased local sourcing will increase prices/reduce availability of some items, thus making them perhaps candidates for fraud; the most likely would be claiming to be local when not. Shorter supply chains make traceability simpler, but do not guarantee that there will not be any fraud. A complex supply chain can and should still have effective traceability.
27. If additional testing of food products for authenticity is required across a wide range of commodities, can this be kept proportionate, relevant and timely?
Planned rotation of audit and testing through the known possibilities for food fraud following regular vulnerability assessments.
28. Additional testing for food authenticity across a wide range of commodities will have a significant cost. Who should be responsible for absorbing these costs?
All in the production chain, from farmers, producers, importers, retailers/restaurateurs, and customers.
Any testing carried out by Government should not be passed onto the food business operators.
29. Other than for allergens, how significant are the issues raised by trace contamination from carry-over from equipment previously used for other food types? What can be done to reduce the level of carry-over while ensuring that the response is proportionate? At what level of trace contamination is there a need to require separate production lines for different products?
The level of advantageous contamination in relation to GMO can be considered as a precedent. This is regarded as industrial best practice in the sectors affected by possible cross contamination of GMO.
We also suggest the outcomes of current research commissioned by Defra from LGC should be awaited
On the behalf of the institute of Food Science and Technology
Marjo Kiiveri
Technical and Registration Officer
11 October 2013
Review into the Integrity and Assurance of Food Supply Networks – Call for Evidence questions
Response to Defra for Nick Hughes (reviewfoodintegrityassurance@defra.gsi.gov.uk)
Please find IFST response to the call for evidence questions below.
1. What measures need to be taken by the UK food industry and government to increase consumers trust in the integrity of the food supply systems?
Consumer trust will be enhanced by a robust outcome to the investigations of how the horsemeat scandal happened and appropriate penalties for identified wrongdoers. This should be supplemented by proactive ‘policing’ of food authenticity in the future. Food industry and government should campaign together to communicate clearly to the consumers the measures taken to ensure the safety and authenticity of food. Balanced food supply chain involves food consumer engagement and education of lengths the food industry takes to provide safe food and the challenges face by the food industry which doesn’t come without a cost.
2. The Terms of Reference for the Review require an approach that is proportionate to the risks involved to the consumer. What does this mean in practice?
In practice we believe this means taking account of risks with regard to fraud, consumer choice and safety. We support Commissioner Borg’s 5 point action plan. We also support the Commission’s stated position that where financial penalties are used in relation to intentional violations of food chain law, they are at a level which is sufficiently dissuasive and higher than the economic gain expected from the fraud. So too we support that it will also be expected that Member States include in their control plans and perform regularly mandatory unannounced official controls (including inspections and testing) directed at combating food fraud and the Commission wish to be able to impose (not just recommend) coordinated testing programmes in specific cases, in particular in case of fraud. The out-workings of the above plan will determine much of what will be put in place in the UK in the future and it is timely that Regulation 882/2004 on official controls is under review.
The approach also must deal with imports into the EC again using risk analysis to identify the countries and products most likely to be subject to fraud and substitution.
The food industry and government should work collaboratively using intelligent systems and data sharing to combat fraudulent practices allowing resources to focused and used more effectively.
3. How can government, food businesses and regulators better identify new and emerging forms of food fraud?
We suggest that proactive ‘policing’ of food authenticity in the future, identification of any product or group or products where significant money can be made by fraud and substitution. We also suggest global intelligence gathering and sharing on food fraud which allows better identification for new and emerging forms of food fraud. This should not be limited to high volume low cost meat or meat-like products, but also for example oils and high value spices to name few.
4. Food supply chains have variable economic factors impacting on price at every stage. Which factors in relation to risks of potential fraud are most influential and are there trends developing?
Scarcity, protein demand and cost, easy of manufacture/distribution and sale, cost benefit, provenance, easy of detection.
5. Do consumers fully understand the way industry describes the composition and quality of the products on sale?
We do not believe that consumers fully understand the way industry describes the composition and quality of the products on sale but that smarter labelling will help. If anything we need to make labels simpler, and easier to understand in the seconds or less that a consumer actually has to read them. Often the call is for more labelling, but actually labelling which consumer reads is needed – and this does not mean using logos instead of text as the logos are just as prolific.
There is a need for a consumer education related to the labelling and food choices. Challenge is to improve knowledge of a complex food system and motivate consumers to choose food which is proven to be produced minimising any possibilities for the negative interference to food safety and integrity.
6. Has the consumer developed unrealistic expectations of the food industry and if so, what role is there for the food industry and government in doing something about it?
In some senses consumers have developed unrealistic expectations of the food industry, for example there is little appreciation of the true economics of meat production and especially the cost of diversion or disposal of carcase parts not readily consumed in the UK. Government should campaign together with food industry and other professional bodies to make food supply chain more transparent and explain how safe food reaches our tables and the constraints the food industry has faced.
7. Do government decisions about regulation and inspection get the balance right between producer, processor, retailer and consumer when it comes to food? Do further measures need to be taken by the EU or by the UK government to increase consumer trust?
We support Commissioner Borg’s 5 point action plan (see above) but having said that we believe that rather than impose further measures government should ensure that there is sustainable pre-planned centrally coordinated and effective enforcement of the measures already available.
Also global intelligence gathering and sharing on food fraud which allows better identification for new and emerging forms of food fraud would increase consumer trust.
8. What impact could fraud have on the safety of food consumed in the UK?
Fraud has the potential for huge impact on food safety. It places unknown risks into the supply chain e.g. unwitting consumption of allergens, microbiological problems, pesticide and veterinary residues, illegal additives, methanol, etc. Food fraud also poses real potential problems of the ‘unknown’ variety.
9. What implications do the recent changes to the public health responsibilities of English local authorities have for food inspection and enforcement regimes?
IFST is not commenting to this question.
10. What control systems do food businesses have in place for assuring themselves that the food they supply is of the nature and quality they expect? How have these systems been tightened since the horsemeat fraud was identified?
This should be assessed in the light of guidelines such as IFST GMP 6th Ed and the use of GFSI recognised schemes such as BRC6. There are currently, in development, a number of industry driven initiatives that will ensure control mechanisms are in place in relation to potential fraudulent activity however there should be a coordinating body to ensure the best possible result for initiatives to develop to a solid guidance which is distributed widely to the all relevant parties.
11. How can large corporations relying on complex supply chains improve both information and evidence as to the traceability of food?
Complex supply chains are here to stay and are not only limited to large food businesses but can also be seen in many other industries. Promises made to source items from the UK are helpful, but are only relevant obviously for things we can produce in the UK and there are still many items we have to source as imports. Unfortunately UK sourced does not mean a guarantee of authenticity – fraud can and does happen anywhere there is money to be made. We suggest that strict adherence to guidelines such as IFST GMP 6th Ed. and compliance to GFSI recognised schemes such as BRC6, where there are a number of requirements which place specific emphasis on best practice product procurement such as supplier approval and monitoring, product analytical programmes, specifications, traceability and complaint handling.
12. Should there be legislative requirements for tamper proof labelling, and/or to advise competent authorities of mislabelling if it is discovered in the supply chain?
Tamper proof labelling has no real bearing on food fraud as there are very good examples where the packaging itself may be counterfeit e.g. Alcoholic drinks. Tamper proof packaging does add a level of security in relation to deliberate malpractice or accidentally damage, but again the main function of tamper proof packaging is to highlight any malpractice within the food supply chain.
In relation to mislabelling the notification should be based on the principles supporting the EU General Food Law where the food business operator must inform the competent if there has been or suspects there has been unsafe product placed into the supply chain.
13. What additional information does the public need to be offered about food content and processing techniques? How can this information be conveyed in an easy to understand manner?
Challenge is to find an interesting way to educate food consumers and fill the large gap between what customers know about food production and what actually happens. As a consequence of industrialisation of society and the move away from a rural economy it is more difficult be connected with food and the origin and content of it. Food consumer is not likely to be interested of the food processing techniques however access to all the additional information should be available if easily if needed. Food labelling is one way of communication this and it has to be honest and transparent labelling argument however it has its limitations. However, the key word in the question is “offered”. So, this means available if wished for, so not on every label by default. There are many means nowadays for interested customers to find out more, from simply asking at the customer service desk, to following web links and Q-codes and no doubt more around the corner. In terms of being easy to understand, that is a matter for wordsmiths and such like to use their skills.
14. Whose responsibility is it to give the public assurances about the safety and quality of food?
Public assurances about the safety and quality of food is the responsibility of the food industry supported by sustainable and convincing regulation and enforcement of food law involving everyone from farmer to retailer/restaurant, government and professional bodies.
These assurances provided by either party should be open, trustworthy and comprehensive. When consumer trust is in question we have seen the media play a role in which tends to focus upon Government, which in most cases is not helpful. One should look at the lessons learned after the Sudan 1 incident in 2005 where the media challenged the Food Standards Agency rather than the food manufacturers and food retailers.
15. How should information about traceability be presented to the public? What level of public understanding is there about traceability and food adulteration?
Born, reared and slaughtered information seems to be well understood, but unfortunately are only relevant to meat. The issue on traceability goes beyond meat to all food and drink products and ingredients. Public would not necessarily understand or need to understand the detail behind traceability systems but should understand the principles that food should be controlled and identifiable within the food supply chain. For example if compound product consist a recipe meal with 20+ ingredients there is no purpose of presenting the traceability of the 20+ ingredients for the consumer. Such information does not prevent fraud. If someone earlier in the chain has substituted an ingredient then any subsequent labelling is irrelevant.
The EU General Food Law is not helpful here either as this lays down the minimum legal requirements, which in virtually all cases the food industry exceeds e.g. the requirement for full internal traceability.
16. Where multiple ingredients are used in food processing to create a dish, should country of origin information be made available for them all? What do the public care most about?
Public cares about integrity of the food product most of all but country of origin information doesn’t contribute to the stopping fraud. Cost impacts to the food industry has to be also considered in the situations where an ingredient maybe sourced from a number of countries and in some cases blended from a number of sources. The food industry is looking for ingredients of specified quality and attribute but irrespective of source must be safe. A good example would be vegetable oil which may be sourced from a number of countries (due to factors such as cost, seasonality and availability) and in many cases blends are used.
There has to be another system in place to stop food fraud than making country of origin information available for all ingredients. Public cares about the food integrity and the forum to communicate product meeting the expectations has to easily accessible for example on the website of the product.
Public is likely to care most about high value / high cost ingredients and bulking agents such as water.
17. Should caterers/restaurants and those providing food ready to eat direct to the consumer be required to provide more information? For example, should an item such as ‘Fish and Chips’ on a menu always state which fish has been used?
This form of labelling should not be mandatory, again as this would add significant cost and possibly lack of flexibility of production for the reasons given above. In the majority of cases the caterer/restaurant will have direct knowledge of the product and source and this information should be available, if requested. There is also in place Trade Description as well as Food Labelling legislation to be considered here.
18. Are there shortcomings in the inspection and enforcement tools available to the FSA and local authorities?
We believe better coordination, publicly available information on outcomes, funding for targeted speculative sampling and analysis and agreed coordinated planning for the future of enforcement will assist.
19. Can substitution or adulteration ever be considered ‘harmless’?
Given the level of control required under current legislation these practices should be considered as being potentially harmful and by definition unsafe.
20. Is it appropriate to base inspection and enforcement action on perceptions of risk, or should a zero tolerance approach be taken to all food fraud?
A balanced view on this is required but as with ‘volume crime’ we believe DNA techniques can be used to address ‘volume food fraud’ so that a zero tolerance approach can be approximated.
21. Does current intelligence make best use of the evidence available, and take adequate account of risk factors such as commercial reputation and public confidence?
Food businesses are well aware of commercial reputation and public confidence, but in relation to the use of evidence and intelligence the systems currently under development will look at these factors and develop best industry practice on vulnerability.
22. Does the Five Point Plan proposed by Commissioner Borg contain the necessary levers to achieve effective change? What further actions might be needed?
Creative thinking on funding will be required to support Commissioner Borg’s plan.
23. Is there evidence that the machinery of Government changes in 2010 for England (which led to Defra taking over responsibility for authenticity and compositional policy) have made food supply networks more vulnerable to fraud?
The changes did not help, and whilst there was the potential for disruption, it appears that in spite of this officials worked well together after the machinery of government changes. It has to be said though that the interruption in continuity and the decline in food authenticity surveys may have played a part in the vulnerability to fraud.
24. Are there gaps in analytical approaches to support food testing, to verify authenticity and to enforce food law? Which areas in food authenticity should be prioritised for method development and validation to support testing?
For the meat industry, the detection of designated meat in mixtures with legitimate meat and quantitative DNA approaches to meat speciation are important as are the recently publicised methods for verifying country of origin. .From an overall food industry perspective, there must be continued investment in, and confidence in the competence of, the official control system.
Additionally vulnerability assessments must also the shared between industry and Governments to allow the prioritisation of the developments of analytical techniques to accurately verify food authenticity.
25. What are the cost burdens and financial benefits to food businesses of current approaches to assurance, information and regulation? What have been the financial and other impacts of recent food frauds?
IFST is not commenting to this.
26. What impact does increased sourcing of locally produced foods have on food authenticity and food prices? Is a shortening of supply chains likely to improve traceability?
It is possible that increased local sourcing will increase prices/reduce availability of some items, thus making them perhaps candidates for fraud; the most likely would be claiming to be local when not. Shorter supply chains make traceability simpler, but do not guarantee that there will not be any fraud. A complex supply chain can and should still have effective traceability.
27. If additional testing of food products for authenticity is required across a wide range of commodities, can this be kept proportionate, relevant and timely?
Planned rotation of audit and testing through the known possibilities for food fraud following regular vulnerability assessments.
28. Additional testing for food authenticity across a wide range of commodities will have a significant cost. Who should be responsible for absorbing these costs?
All in the production chain, from farmers, producers, importers, retailers/restaurateurs, and customers.
Any testing carried out by Government should not be passed onto the food business operators.
29. Other than for allergens, how significant are the issues raised by trace contamination from carry-over from equipment previously used for other food types? What can be done to reduce the level of carry-over while ensuring that the response is proportionate? At what level of trace contamination is there a need to require separate production lines for different products?
The level of advantageous contamination in relation to GMO can be considered as a precedent. This is regarded as industrial best practice in the sectors affected by possible cross contamination of GMO.
We also suggest the outcomes of current research commissioned by Defra from LGC should be awaited
On the behalf of the institute of Food Science and Technology
Marjo Kiiveri
Technical and Registration Officer