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Will Elliott recommendations prevent another Horsegate?

Elliott report2As a country, the UK has a very good record for food safety and indeed one of the safest food supply chains. By and large British consumers should be able to shop with every confidence that the food and drink that they buy contains exactly what it says on the label.

Nevertheless, business reputation and consumer confidence is a fragile thing and one that, once damaged, can take some time to rebuild. The biggest food fraud scandal in many years was undoubtedly the ‘Horsegate’ crisis of early 2013 where a significant number of processed meat products such as burgers and lasagne were found to contain horsemeat, rather than beef. However a spate of television programmes and newspaper articles also revealed that other types of food fraud and food crime were not uncommon in certain circles – especially where ingredients or goods had been imported.

The much-anticipated final report of the ‘Elliott Review into the Integrity & Assurance of Food Supply Networks’ was published yesterday (4th Sept 2014). In it Professor Chris Elliott, Professor for Food Safety and Director of the Institute for Global Food Security at Queen’s University, Belfast, details robust recommendations for a national food crime prevention framework designed to better protect food businesses and drive consumer confidence.

The report is based on what the Professor refers to as ‘eight pillars of food integrity.’ These are:

  1. Putting the consumer first – i.e. Government, industry and regulators should work together to maintain consumer confidence in food, but also make them aware of food crime, food fraud and its implications. They should also prevent contamination, adulteration and false claims about food and make food crime extremely difficult to commit. Professor Elliott also urged the implementation of an annual targeted testing programme based on intelligence, data collection and well-structured surveys.
  1. Zero tolerance on food fraud and food crime – This recommendation includes industry scrutiny of the food supply chain, from initial deals with suppliers (e.g. are some deals just too good to be true?) to sampling, testing and supervision of supplies at all stages of the chain. Whistleblowing is encouraged to stamp out bad practice, as are incentives to reward responsible procurement.  Further safeguards include the incorporation of opportunities for food fraud/crime and mitigation in company risk registers as well as guidance on the validation and assurance of food supply chains and education and advice on the prevention and identification of food crime.
  1. Intelligence gathering – There should be an emphasis on the gathering, collation, analysis and dissemination of intelligence and information relating to food crime and food fraud. This should be led by the Food Standards Agency but actively involve the food industry.
  1. Access to laboratory services – It is Professor Elliott’s recommendation that those involved with auditing, inspecting and enforcement must have access to ‘resilient, sustainable laboratory services that use standardised, validated approaches.’ The ultimate goal is to create ‘Centres of Excellence’ with frameworks for standardising food authenticity testing. Working partnerships between public sector organisations, local authority labs and Public Health England are to be encouraged, as is the regular comparison and rationalisation of food surveillance. An integrated shared scientific service around food standards was also proposed.
  1. Auditing – According to the review, audits should be fewer but more comprehensive and should include forensic sampling. Importantly they should be unannounced. The Government is advised to work with industry and regulators to develop specialist training and advice about critical control points for detecting food fraud and dishonest labelling. It should also be recognised that food fraud can occur at any point in the supply chain, for instance during transportation or in storage facilities. In the meat industry, for example, incidences had been found of cheap meats from different species being mixed with other meat in cold stores.
  1. Government support – For the war against food crime to be effective, the Government needs to play a vital role in supporting the Food Standards Agency, Local Authorities and the food industry itself. Professor Elliott recommends that the support needs to be SMART (i.e. Specific, Measurable, Attainable, Realistic and Timely.) A National Food Safety and Food Crime Committee is to be set up.
  1. Leadership – The Review uncovered the requirement for clear leadership and co-ordination of effective investigations and prosecutions relating to food fraud and food crime. Significant penalties should be imposed on those found guilty of serious food crime and this should be actively enforced. In line with this recommendation food crime should be included in the work of the Government Agency Intelligence Network and a new Food Crime Unit should be created which would be hosted by the Food Standards Agency and report to a governance board.
  1. Crisis Management – The Elliott review recommends that the Government and Food Standards Agency liaise on the development and implementation of clear crisis management policies and contingency plans in the event of a serious food safety or food crime incident. Roles and responsibilities need to be defined in advance of such an occurrence.

The above is a brief synopsis of the full, detailed report The Government issued a press release in response to Professor Elliott’s report yesterday in which it pledged to set up the new Food Crime Unit, ensure that there was a resilient network of food analytical laboratories to test food consistently, and improve co-ordination across government to protect food integrity and tackle food crime.

In addition it is introducing new Country of Origin labelling from next April and improving public procurement of food and catering services so that more high quality British food is delivered in to schools and hospitals. It is hoped that this will also help to boost the UK farming industry.

The recommendations within Professor Elliott’s report are encouraging and, if implemented effectively, should help to tighten up the incidence of food crime in the UK. But can they prevent the incidence of another ‘Horsegate’ scandal? The answer is that we can’t be sure.  Certainly unannounced auditing and regular testing for authenticity will go some way to its prevention, especially if shorter, UK-only, supply chains are used. However the Government must also provide the necessary funding to enable the recommendations to be implemented. Arguably food crime has been able to take place undetected in the past because there simply has not been the facilities and resource to deal with the problem. This was due, in part, to Government cuts to Local Authority funding.

There is also the worry that current supermarket price wars could lead to corner-cutting. You only need to read the label of a ready meal and it soon becomes obvious that the number of ingredients sourced from several different countries means long and complex global food supply chains which are difficult to police.

The key to preventing damage to the food industry’s reputation and maintaining consumer confidence is vigilance and the adoption of stringent processes and testing throughout our own supply chains.