Richard Bradford- Knox of RBK Consultants and Simon Neighbour, Environmental Health Manager, Preston City Council, investigate the risk management of food safety and suggest how we can do better.
Introduction
The authors’ research findings to date lead to the conclusion that for food safety to be managed properly and effectively, organisations and individuals need to work more closely together. We propose the way forward is to develop food safety culture(s) in the food manufacturing and catering industries that result in all concerned having a positive attitude, recognising and assessing hazards and risks and, most importantly, fostering mutual trust. The way to do this as well as a synopsis of our past research is described in the book We Can Do Better - Approaches to the Risk Management of Food Safety[1].
Background
Food chains have changed dramatically because of technical and demographic changes over the last decades. Although efforts are made to ensure high quality and integrity, food-borne outbreaks, food scandals and incidents still happen to an undesired extent[2].
Since 2016 there have been further incidents, including in October 2017, when Food Manufacture Magazine published a report entitled ‘UK’s top supplier of supermarket chicken fiddles food safety dates’. An investigation by The Guardian and ITV News recorded undercover footage of workers altering the slaughter date of poultry being processed at a 2 Sisters Food Group plant. The group produced one third of poultry products eaten in the UK and supplied top grocers including Tesco, Sainsbury’s, Marks & Spencer, Aldi and Lidl.
Ranjit Boparan, the boss of 2 Sisters Food Group appeared before a House of Commons Environment Food and Rural Affairs (EFRA) select committee, where he agreed to fund Food Standards Agency (FSA) inspectors across all 2 Sisters plants as well as implementing CCTV in all areas and improving staff training to restore confidence in its poultry production[3].
Boparan declined to answer a direct question on whether there was a breach in food safety regulations but admitted there had been ‘mistakes’. The chairman of the EFRA select committee, Neil Parish MP, accused the UK’s main meat assurance schemes of being ‘culpable’ for the alleged breaches of food safety identified in this undercover press investigation at the 2 Sisters Food Group factory in West Bromwich[3].
The fact that 2 Sisters was supplying so many major retailers implied that their factories must be audited and inspected very frequently. Marks and Spencer and Tesco have their own high food safety and quality standards, as has the British Retail Consortium (BRC).
Many other food incidents that have resulted in serious illness and sometimes even death have come to the public attention over the last two decades. For example, BSE and the E. coli outbreak in South Wales[4]suggest that food safety controls, including auditing and inspection, need to be continually reviewed and improved[5].
For food safety to be managed properly and effectively, organisations and individuals need to work more closely together.
Regulating Our Future
The FSA has recognised the need for improvement in the way it delivers regulatory assurance and has launched a project called ‘Regulating Our Future’ (ROF) to address this.
With a target date for implementation of 2020, the intention is not to change existing regulations but, as described in the document entitled ‘Regulating Our Future – Why food regulations need to change and how we intend to do it’, to improve delivery of controls across the food chain, including those for animal feed, by prioritising improvement where there has been no modernisation of the system in recent years and where FSA perceives it is most needed.
The FSA believes that the existing ‘one size fits all’ approach for example, online retailers, food delivery services and private auditors. It also points out that many of these developments have created different risks resulting in increased risks in many areas.
Importantly, ROF seeks to reduce the regulatory burden on business. It suggests that appropriately trained and competent auditors will be able to inspect/audit businesses and pass the results of their audits to local authorities, which would then use the information to calculate an inspection risk rating – the frequency of inspection – but also the food hygiene rating.
Simon Neighbour, Environmental Health Manager of Preston City Council and co-author of this article, believes that some environmental health professionals employed in local government have concerns about this approach. Recent years have seen an increasing number of Environmental Health a wider spread of views. The authors suspect there will be some differences in the views of professionals in the different sectors. Broadly, local authority EHPs would prefer independent regulation and see this as yet another route to self-regulation.
The views expressed so far by EHPs are broadly reflected by Professor Liza Ackerley at a 2017 CIEH safe food conference[6]. Proposing a radically simplified single food safety assurance national scheme for all, she says: ‘Businesses don’t want someone going in and waving a great big stick and then someone else going in and doing a ‘good cop bad cop’ thing, so the visit they get, whether it’s from a local authority or a private sector auditor, needs to help them to get to the place where they need to be.’ For the food manufacturing industry this idea is not new.
Her proposed not-for-profit scheme, covering the catering in the public domain, it would not be subject to freedom of information requests: ‘Businesses do not want all of this data, which has previously been private, being requested by the Daily Mail.’ The central body holding the database would work with stakeholders to set standards and competencies for auditors, including training requirements. But she stressed: ‘We don’t want to put too many barriers up or to make this too expensive.’ It would not be compulsory for auditors to join the scheme.
She reassured her audience – ‘this is absolutely not about stealing EHO jobs.’ Under the new system, local authorities would still be responsible for enforcement activity, including awarding food hygiene ratings and re-ratings. But, in some cases, it would be informed by data from external auditors. ‘Local authorities would be doing exactly as they were before, but they would have access to a lot more information from more sources and they would be able to consider it as part of the whole picture in relation to food businesses.’
‘The new paid-for service would be based on the British Hospitality Association’s Catering Guide, with reference to Annex 5 Food Standard’s Agency’s food law code of practice. She argued that it would simply regularise what is already happening in the marketplace, with businesses receiving advice, guidance and coaching from many bodies but that it would give added value and public reassurance to the businesses signing up. Small businesses that do not currently receive many inspections from EHOs would benefit.
Giving the example of SALSA, as described in Alex Kent’s artice in the December 2017 Issue of FST, as an effective existing accreditation scheme, she said: ‘we want to make sure that the scheme is not difficult or expensive for anyone to join, that it would have transparent governance and that it would enjoy the trust of consumers and local authorities.’ This is interesting because SALSA currently only covers food manufacturers not catering establishments. However, it could certainly be adapted following its present principles of being user friendly, providing support, guidance and training as well as policing the food industry[7].
Regulating and managing food safety using audits and inspections is key in both private or public food industry bodies.
Audits, inspections and standards
Food safety and quality audits and inspections are used widely in the food industry for various reasons (to evaluate management systems, obtain certifications to food safety and quality standards, assess the condition of premises and products, confirm legal compliance, and so on). Nowadays, the increased interest of consumers in food safety and quality matters, triggered mainly by recent food scandals, has enabled the public and private food sectors to develop a variety of food safety and quality standards. These standards have both advantages and disadvantages and their effectiveness depends on several factors, such as the competency and skills of auditors and the standard used in each case. Although the industry continuously invests in developing and improving these systems, the number of foodborne outbreaks per year appears to be quite stable and has not reduced in both Europe and the United States. This may be an indication that additional measures and techniques or a different approach are required to further improve the effectiveness of food safety and quality management systems[8].
In the view of the FSA, the prime reasons for governmental inspections and audits as described in the ROF are to ensure that food businesses meet legal regulatory requirements. The reasons for private or food industry audits carried out by the various bodies, like the British Retail Corporation (BRC), major retailers and those that have special interests or requirements in standards of food, differ in that they are not limited to food hygiene and food safety legal standards. They are based on their own requirements for best practice, quality and ‘special interests’[8].
For example, the Soil Association is concerned with ‘Organic Foods’ and Red Tractor to ensure food is traceable, safe to eat and has been produced responsibly. It covers animal welfare, food safety, traceability and environmental protection but is restricted to food that has been farmed, processed and packed in the UK.
In the paper ‘Approaches to and the management of the audit process in the food industry’, one of the key findings was that the frequency and number of audits and inspections in the food manufacturing sector, unlike inspections carried out by local government, are not risk based[9]. They appear to be based on custom and practice. i.e. the annual auditing of food premises is the common or subjective norm rather than being risk related. This appears to be contrary to the principle and legal requirements that the food safety management of food premises must be risked based as per Article 6 of 178/20025, and food businesses shall produce food in accordance with the risk-based approach described in Article 5 of Regulation (EC) No 852/2004.
In the authors’ view, as part of the management and control of food hygiene across the food chain, appropriate interventions, which ensure a consistent level of compliance with food law and maintenance of hygiene standards to ensure food is safe for human consumption, must be achieved without entailing excessive cost, while satisfying consumer concerns over integrity.
Regulating and managing food safety using audits and inspections is key in both private or public food industry bodies.
Audit frequency
The number and frequency of audits and inspections is also driven by other factors:
1. The number of customers a business has, who they supply and whether they are required to meet certain specialist areas of supply and claims made about their products. e.g. gluten free, organic or religious requirements.
2. A lack of trust between auditing bodies in the integrity of audits carried out by, and on behalf of, other retailers and other auditing bodies. The British Retail Consortium auditing system was set up in the UK and many parts of the world as one of the most prominent standards. It was originally developed in 1998 as a common minimum standard for food safety in response to the concerns of British retailers about the variations characterised by the different requirements and approaches to third-party auditing[10]. Apart from its aim of becoming a recognised global standard its main objective was to reduce the duplication of auditing of suppliers by the customers and their representatives.
3. Economic and commercial factors. The cost of auditing can be high for those paying for the audits and inspection. This can be the buyers of the products or raw materials and /or the suppliers, the latter being the most common. When government bodies bear the cost, the number of audits or inspections can be limited by their budgets.
The authors propose that the current situation can result in one of two situations. Firstly, there is a possible risk that many higher risk businesses are not audited as frequently as they should be and conversely that many lower risk businesses are audited or inspected more frequently than is necessary. It can also be argued that having a variety of different types of audit or inspection may give ‘better coverage’ and help to ensure that all aspects of food hygiene and food safety are addressed and that any weaknesses are exposed. It may also be argued that a high frequency of audits can only be desirable and potentially ensures safer food for consumers.
There are other factors that need to be considered in appraising the effectiveness of auditing and inspecting food premises. These include the quality of the audits and costs in terms of time and money.
The frequency of audits is assessed on the level of risk a food business presents and other relevant criteria. For example, carrying out unannounced visits is potentially more effective than regular, anticipated audits. The view of many professional auditors is that unannounced visits keep businesses ‘audit ready’ at all times. This in turn has the potential to reduce frequency of visits and therefore duplication of effort[9].
Further duplication of effort and cost can also be averted if an audit or inspection has been carried out recently by a recognised body.
Sharing information and culture
Further duplication of effort and cost can also be averted if an audit or inspection has been carried out recently by a recognised body. This approach is dependent on trust and would entail different auditing bodies recognising each other’s integrity and an exchange of information between them. This would include providing and sharing audit reports between auditing bodies, suppliers and buyers. Thereby enabling all parties concerned to be aware of the strengths and weaknesses, special circumstances or interests covered by the audit(s). From this information a judgment can be made as to when the next intervention should occur.
As described in the FSA’s Food Law Code of Practice (FSA 2017) the system used for determining the frequency of local authority inspections is by identifying a number of risk criteria and allocating a number points against each one according to the perceived level of risk presented. The higher the points the higher the risk and the need for more frequent inspections.
The criteria summarised from the Food Law Code of Practice are:
1. Type of food and method of handling.
2. Method of processing method
3. Consumers at risk
4. Level of (current) compliance
5. Confidence in management/ control procedures
6. Where the production of or the service of high risk foods take place to the vulnerable e.g. hospitals, care homes and children’s nurseries.
The above approach is focused on the easily identified ‘what is happening’ and ‘how is it happening’ approach, with very little opportunity to understand ‘why’. The HSE (Health & Safety Executive) has published a topic note on safety culture. Understanding culture is likely to be an involved and time-consuming task, but offers insight into why employees behave the way they do. Over a period, it should be possible to actively seek to understand the culture of an organisation and thus make appropriate interventions through engagement to protect public health.
Richard Bradford-KnoxMSc., CSci., MIFST Registered IFST Food Safety Auditor & Consultant, Author and Researcher– Food Safety, Business & Risk Management SALSA Auditor & Mentor
Emailrbkconsult@gmail.com
Telephone07906 135558
Co-authorSimon Neighbour, Environmental Health Manager, Preston City Council Author and Researcher
References
- 'We Can Do Better - Approaches to the Risk Management of Food Safety: Attitudes to food safety management, cooperation, collaboration and what influences behaviour'. Richard Bradford-Knox Publisher: LAP LAMBERT Academic Publishing (9 Aug. 2017 ISBN-10: 6202016310 ISBN-13: 978-6202016315
- Kleboth et al (2016) Kleboth J.A., Luning P.A., Fogliano V., ‘ Risk -based integrity audits in the food chain - A framework for complex systems’ . Trends in Food Science and Technology 56 (2016) 167-174.
- Food Manufacture https://www.foodmanufacture.co.uk/Article/2017/10/26/Chicken-boss-agrees... . https://www.foodmanufacture.co.uk/Article/2013/10/02/Breaking-food-safety-laws-costs-2-Sisters-153k. Accessed 26th November 2017
4. Pennington, H (2009), The Public Inquiry into the September 2005 Outbreak of E.coli O157 in South Wales, © Queen’s Printer and Controller of HMSO
5. A Case Study of the U.K. Bovine Spongiform Encephalopathy Crisis. Public Administration Review, 65(4), 396-408. Retrieved 11 13, 2017, from http://onlinelibrary.wiley.com/doi/10.1111/j.1540-6210.2005.00467.x/abst... Beck, M., Asenova, D., & Dickson, G. (2005). Public Administration, Science and Risk Assessment:
6. EHN (Environmental Health News (2017) ‘Assurance poses 'no threat to EHOs' Will Hatchett 16/11/2017. http://www.ehn- online.com/news/subsectionhub.aspx?fid=198. Accessed 19th November 2017.
7. Safe and Local Supplier Approval – A case study of the third party supplier approval scheme for micro and small food businesses
Richard Bradford-Knox, Kevin Kane (pp. 30-47) Retrieved 11 19, 2017, from http://ijmar.org/v1n1/14-003.pdf
8. Kotsanopoulos, K. V., & Arvanitoyannis, I. S. (2017). The Role of Auditing, Food Safety, and Food Quality Standards in the Food Industry: A Review. Comprehensive Reviews in Food Science and Food Safety, 16(5), 760-775. Retrieved 11 29, 2017, from http://onlinelibrary.wiley.com/doi/10.1111/1541-4337.12293/pdf
9. Richard Bradford-Knox, (2017a) "Approaches to and the management of the audit process in the food industry", British Food Journal, Vol. 119 Issue: 4, pp.759-770, https://doi.org/10.1108/BFJ-10-2016-0484
10. Mensah L.D, & Julien ,D (2011) “Implementation of food safety management systems in the UK”, Food Control 22 pp.1216-1225
