Prevention and Control of Food Emergencies

Prevention and Control of Food Emergencies

Prevention and Control of Food Emergencies

Himmat RaiDirector

Sentinel Safety Solutions Ltd

Himmat RaiDirector

Sentinel Safety Solutions Ltd

OutlineOutline

• Background

• Prevention and control of food emergencies

• Challenges for businesses

• Regulatory response

• Recent high profile cases

• Background

• Prevention and control of food emergencies

• Challenges for businesses

• Regulatory response

• Recent high profile cases

IntroductionIntroduction

Himmat Rai BSc (Hons) LL.M FCIEH FRSH CMIOSH

• Chartered Health and Safety Practitioner

• Enforced health & safety and food safety law for 9 years

• Author of ‘Food Emergencies: A Practical Approach to

Prevention and Control’

• Consultant since 1997

• Expert witness in criminal and civil proceedings

Himmat Rai BSc (Hons) LL.M FCIEH FRSH CMIOSH

• Chartered Health and Safety Practitioner

• Enforced health & safety and food safety law for 9 years

• Author of ‘Food Emergencies: A Practical Approach to

Prevention and Control’

• Consultant since 1997

• Expert witness in criminal and civil proceedings

BackgroundBackground

Definition of ‘Incident’:

“Any event where, based on the information available, there are concerns about actual or suspected threats to the safety or quality of food that could require intervention to protect consumers’ interests”

Source: Food Standards Agency (FSA)

Definition of ‘Incident’:

“Any event where, based on the information available, there are concerns about actual or suspected threats to the safety or quality of food that could require intervention to protect consumers’ interests”



In 2006 FSA investigated 1342 food incidents in the UK, of which:

– 28% environmental contamination (fire, spills/leaks)– 13% natural chemical contamination (mycotoxins, algal toxins) – 11% microbiological contamination (Salmonella, Listeria, E.coli O157) – 10% physical contamination (glass, plastic, metal etc)– FSA issued 81 Food Alerts to local authorities (& on website)


In 2006 FSA investigated 1342 food incidents in the UK, of which:

– 28% environmental contamination (fire, spills/leaks)– 13% natural chemical contamination (mycotoxins, algal toxins)– 11% microbiological contamination (Salmonella, Listeria, E.coli O157)– 10% physical contamination (glass, plastic, metal etc)– FSA issued 81 Food Alerts to local authorities (& on website)



Recall most likely due to:

• Microbiological, Chemical or • Physical contamination• Allergens• Radiological• Incorrect labelling

Recall most likely due to:

• Microbiological, Chemical or • Physical contamination• Allergens• Radiological• Incorrect labelling

Notable past food emergencies Notable past food emergencies• Diethylene glycol (anti-freeze) in white wine

(1985)

• BSE/vCJD from beef (From 1986)

• Botulism from hazelnut puree in yoghurt (1989)

• E.coli O157 in meat products (1996)

• Dioxin in feedstuffs and food products (1999)

• Diethylene glycol (anti-freeze) in white wine

(1985)

• BSE/vCJD from beef (From 1986)

• Botulism from hazelnut puree in yoghurt (1989)

• E.coli O157 in meat products (1996)

• Dioxin in feedstuffs and food products (1999)

Prevention of food emergencies Prevention of food emergencies

Hazard Analysis Critical Control Points (HACCP) based food safety management

• ‘Nil defects’ every time

• Internationally accepted system promoted by the Codex Alimentarius Commission

• Centrepiece of EC Food Regulation

Hazard Analysis Critical Control Points (HACCP) based food safety management

• ‘Nil defects’ every time

• Internationally accepted system promoted by the Codex Alimentarius Commission

• Centrepiece of EC Food Regulation

Why HACCP ?Why HACCP ?

• Concentrate resources where critical

• Measurable parameters removes ‘grey areas’

• Corrective action can be taken before food safety

compromised

• Reduction in wastage

• Fits well with Quality Management systems

• Due diligence

• Concentrate resources where critical

• Measurable parameters removes ‘grey areas’

• Corrective action can be taken before food safety

compromised

• Reduction in wastage

• Fits well with Quality Management systems

• Due diligence

Where prevention failsWhere prevention fails

Possibly due to failures at supplier end or post-production stages

• Food businesses must have a crisis management system to deal with all conceivable emergencies

• To enable suspect batch or consignment to be quickly and accurately identified followed by efficient removal from food supply chain (if necessary)

Possibly due to failures at supplier end or post-production stages

• Food businesses must have a crisis management system to deal with all conceivable emergencies

• To enable suspect batch or consignment to be quickly and accurately identified followed by efficient removal from food supply chain (if necessary)

Dealing with food emergencies Dealing with food emergenciesFood business response

Documented HACCP based food safetymanagement system incorporating:

• Intelligence gathering systems – internal and external

• Food complaint handling system

• Tried and tested crisis management system

Food business response

Documented HACCP based food safetymanagement system incorporating:

• Intelligence gathering systems – internal and external

• Food complaint handling system

• Tried and tested crisis management system

Dealing with food emergencies Dealing with food emergenciesObjective:

Rapid and effective removal of food not in compliance with food safety requirements from the food supply chain

Outcome will depend on the preparedness of the food business to manage such an incident

Objective:

Rapid and effective removal of food not in compliance with food safety requirements from the food supply chain

Outcome will depend on the preparedness of the food business to manage such an incident

Dealing with food emergencies Dealing with food emergencies• Anecdotal evidence suggests 50% of food

businesses have no crisis management system in place

• Best prepared are likely to be large manufacturers, processors, distributors and retailers (usually certified to recognised standard)

• Anecdotal evidence suggests 50% of food businesses have no crisis management system in place

• Best prepared are likely to be large manufacturers, processors, distributors and retailers (usually certified to recognised standard)

Key requirements for Product Recall Key requirements for Product Recall

• Product Recall Policy (endorsed by Board)

• Product Recall Plan

• Risk assessment

• Incident Management Team

• Communication strategy (inc Public Relations)

• Product Recall Policy (endorsed by Board)

• Product Recall Plan

• Risk assessment

• Incident Management Team

• Communication strategy (inc Public Relations)

• Record keeping (‘due diligence’)

• Traceability & Production records

• Data on suppliers and customers

• Contacts – regulatory bodies, media, police

• Resources – personnel, IT, transport, storage

• Training & testing


• If potential recall situation exists:

• Step 1 - Convene Incident Management Team

• Step 2 – Risk assessment

• Step 3 – Notify competent authorities

• Step 4 – Scope of recall

What product (s) implicated?

• If potential recall situation exists:

• Step 1 - Convene Incident Management Team

• Step 2 – Risk assessment

• Step 3 – Notify competent authorities

• Step 4 – Scope of recall

What product (s) implicated?


• Step 5 – Depth of recall (how far along chain?)

Trade and/or consumers ?

• Step 6 – Recall communication

• Step 7 – Check effectiveness of recall communication

• Step 8 – Response rates and termination of recall

• Step 9 – Post recall assessment

• Step 5 – Depth of recall (how far along chain?)

Trade and/or consumers ?

• Step 6 – Recall communication

• Step 7 – Check effectiveness of recall communication

• Step 8 – Response rates and termination of recall

• Step 9 – Post recall assessment


Challenges for businessesChallenges for businesses

Serious implications for food businesses affected directly or indirectly by food incidents:

• Cost of recall– Even small-scale recall may cost £500,000 or more– Insurance take up on the increase– 70% of medium-sized businesses have no product

recall/malicious tamper insurance (anecdotal) – Companies with a turnover of less than £50m,

supplying a single product to one or two retailers most at risk

Serious implications for food businesses affected directly or indirectly by food incidents:

• Cost of recall– Even small-scale recall may cost £500,000 or more– Insurance take up on the increase– 70% of medium-sized businesses have no product

recall/malicious tamper insurance (anecdotal)– Companies with a turnover of less than £50m,

supplying a single product to one or two retailers most at risk


• Inadequate technical, legal & PR resources:– When to trigger a recall?– Scope & depth of recall?– Managing public relations

• Inadequate information from regulators– Quantity & quality of FSA/FA communications– Divergence on test methodologies to be applied

• Inadequate technical, legal & PR resources:– When to trigger a recall?– Scope & depth of recall?– Managing public relations

• Inadequate information from regulators– Quantity & quality of FSA/FA communications– Divergence on test methodologies to be applied


• Traceability– Internal traceability (Guidance: Standing Comm. on the

Food Chain and Animal Health) – Large quantities of food implicated unnecessarily

• Nature of food supply chain– ‘Just in Time’ processes– Relationship between manufacturers and retailers

• Traceability– Internal traceability (Guidance: Standing Comm. on the

Food Chain and Animal Health)– Large quantities of food implicated unnecessarily

• Nature of food supply chain– ‘Just in Time’ processes– Relationship between manufacturers and retailers

Role of FSARole of FSA

• React to information from EC, food authorities, HPA, food industry, surveillance, media etc..

• Food alerts – Action or Information

• Co-ordination• Enforcement – emergency controls over wide

geographical areas

• React to information from EC, food authorities, HPA, food industry, surveillance, media etc..

• Food alerts – Action or Information

• Co-ordination• Enforcement – emergency controls over wide

geographical areas

Role of Food AuthoritiesRole of Food Authorities

• React to information from consumers, FSA food

alerts, food industry, GP’s, NHS

• Investigation

• Inspection, detention and/or seizure of food

• Prosecution

• React to information from consumers, FSA food

alerts, food industry, GP’s, NHS

• Investigation

• Inspection, detention and/or seizure of food

• Prosecution

Regulatory responseRegulatory response

Depending on the nature and scale of incident, possible use of provisions of the following:

• Food Safety Act 1990 (As amended)

• Food and Environment Protection Act 1985

Depending on the nature and scale of incident, possible use of provisions of the following:

• Food Safety Act 1990 (As amended)

• Food and Environment Protection Act 1985


General Food Law Regulation (EC 178/2002)

• ‘Unsafe food’ not to be placed on the market• Food deemed to be unsafe if:- Injurious to health- Unfit for human consumption

• Notification to competent authority immediately• Withdrawal or recall of suspect food

General Food Law Regulation (EC 178/2002)

• ‘Unsafe food’ not to be placed on the market• Food deemed to be unsafe if:- Injurious to health- Unfit for human consumption

• Notification to competent authority immediately• Withdrawal or recall of suspect food


Penalties for criminal offences under food law:

• Summary conviction – Up to £20,000 or up to 6 months imprisonment or both

• Conviction on indictment – Unlimited fine or imprisonment up to 2 years or both

Penalties for criminal offences under food law:

• Summary conviction – Up to £20,000 or up to 6 months imprisonment or both

• Conviction on indictment – Unlimited fine or imprisonment up to 2 years or both

Small scale localised incidentSmall scale localised incidentIf food appears to fail food safety requirements: If food appears to fail food safety requirements:

Detention of food notice

Seize and bring before magistrate

OR

CondemnWithdraw notice

Possible compensation

Serious localised incident or wider emergency Serious localised incident or wider emergency

• Food authority alerts FSA

• If food poisoning incident - Food authority/CCD

set up Outbreak Control Team

• FSA may issue a Food Alert and press release

• Food authority may also issue own press release

• Food authority alerts FSA

• If food poisoning incident - Food authority/CCD

set up Outbreak Control Team

• FSA may issue a Food Alert and press release

• Food authority may also issue own press release

What if food business fail to act voluntarily? What if food business fail to act voluntarily?

If voluntary procedures likely to be ineffective

– Powers to detain or seize– If imminent risk of injury to health -

Emergency Control Order (ECO) – ECO may incorporate special powers to

exempt food authority from liability

If voluntary procedures likely to be ineffective

– Powers to detain or seize– If imminent risk of injury to health -

Emergency Control Order (ECO) – ECO may incorporate special powers to

exempt food authority from liability

Major emergencies concerning food, food sources or contact materials

Major emergencies concerning food, food sources or contact materialsIf emergency covers a wide geographical area:

• ECO (FSA 1990) or

• If affected food is at primary production stage Eg. farms, food animals, sea, then usually – Sec. of State or FSA may make an Emergency

Order to impose prohibitions (F&EP Act 1985)

If emergency covers a wide geographical area:

• ECO (FSA 1990) or

• If affected food is at primary production stage Eg. farms, food animals, sea, then usually– Sec. of State or FSA may make an Emergency

Order to impose prohibitions (F&EP Act 1985)

Recent high profile casesRecent high profile casesSudan 1 (illegal food dye) contamination of Worcestershire sauce supplied by Premier Foods February 2005

- Originated in red chilli powder imported from India before EU controls implemented. Premier unaware of any problems at the time of use as ingredient - Worcestershire sauce supplied to over 160 companies - Approximately 500 different products affected

Sudan 1 (illegal food dye) contamination of Worcestershire sauce supplied by Premier Foods February 2005

- Originated in red chilli powder imported from India before EU controls implemented. Premier unaware of any problems at the time of use as ingredient - Worcestershire sauce supplied to over 160 companies- Approximately 500 different products affected

Recent high profile casesRecent high profile cases

- Largest food recall in the UK

- FSA adopted ‘zero tolerance’ approach in contrast to

some EU countries (up to 0.5 mg per kilo permitted)

- Speculation that recall cost approximately £150m

- Food authorities found no grounds for prosecution

- April 2007 FSA announced review of Sudan 1 incident

- Largest food recall in the UK

- FSA adopted ‘zero tolerance’ approach in contrast to

some EU countries (up to 0.5 mg per kilo permitted)

- Speculation that recall cost approximately £150m

- Food authorities found no grounds for prosecution

- April 2007 FSA announced review of Sudan 1 incident


Salmonella in Cadbury Chocolate 2006

- Salmonella spp. identified in chocolate crumb in January 2006- Linked to 42 consumers who fell ill- June 2006 recalled over a million chocolate products- Net direct costs of the UK product recall £30m - Estimated adverse impact on underlying results £30 –35m on revenue and £5-10m on underlying profit (Ann Rep 2006)

Salmonella in Cadbury Chocolate 2006

- Salmonella spp. identified in chocolate crumb in January 2006- Linked to 42 consumers who fell ill- June 2006 recalled over a million chocolate products- Net direct costs of the UK product recall £30m - Estimated adverse impact on underlying results £30 –35m on revenue and £5-10m on underlying profit (Ann Rep 2006)


- Prosecuted in July 2007 for placing ‘unsafe’ food on the market, failing to notify competent authorities and hygiene offences

- Fined a record £1 million with £152 K costs

- Cadbury state that they have spent more

than £20m on improvements so far

- Total cost of incident………..?

- Prosecuted in July 2007 for placing ‘unsafe’ food on the market, failing to notify competent authorities and hygiene offences

- Fined a record £1 million with £152 K costs

- Cadbury state that they have spent more

than £20m on improvements so far

- Total cost of incident………..?

Thank youThank you

Prevention and Control of Food Emergencies

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