Preventing and Managing Major Food Incidents

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Preventing and Managing Major Food Incidents

• Kaarin Goodburn
• Secretary General
• Chilled Food Association

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Mission

• To promote and defend the reputation
• of the chilled food industry through the
• development and communication of
• standards of excellence
• in the production and distribution
• of chilled food

3
CFA Focus

• Non-competitive issues
• Chilled food technology
• Predominantly food safety hygiene
• Common ground for all members

4
UK Retail Chilled Foods

• Ready meals and side dishes
• Dressed salads (with or without protein)
• Dry salads (e.g. mixed leaf)
• Prepared vegetables stir fry mixes
• Pizzas
• Fresh pasta (plain and filled)
• Soups, Sauces, Dressings and Dips
• Sushi
• Sandwiches and sandwich fillings
• Delicatessen products
• Prepared fruit
• Fresh juice
• Desserts
• Predominantly multicomponent
• Ready to Eat

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UK Retail Chilled Foods

• gt95 retailer own label - unique market
• 9,000 SKUs, most made every day
• 30 annual product churn not unusual
• Seasonal raw materials, year-round production
• Pan-global sources meeting UK standards
• Raw material sources specified by retailers
• Sources risk assessed/audited

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UK Retail Chilled Foods

• Multicomponent
• Prepared
• Short shelf life
• Made to order, generally on day of despatch to
  retailer
• Hygiene/safety critical
• Unpreserved, often ready to eat

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Chilled Food Association

• Represents 90 of the UK and 60 of EU chilled
  prepared food markets
• Chilled prepared 10 of UK retailed food market
  by value (7bn)
• UK market 65 of total European
• European Chilled Food Federation
• CFA is Founder Member and key player
• CFA guidelines basis of ECFF guidance

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Chilled Food Association

• Develops and promotes standards of excellence in
  chilled food production
• Best practice emphasis - safety hygiene
• Whole chain approach raw material selection
  controls

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CFA Membership Criteria

• Competence based
• Commitment to compliance with CFA Guidelines for
  GHP in the Manufacture of Chilled Foods (HACCP
  core) and
• Successful UKAS-accredited audit vs. BRC Global
  Standard Food, or
• Compliance with International Food Standard (IFS)

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CFA Strategy

• CFA promotes its standards to regulatory bodies,
  policymakers and other stakeholders (retailers,
  non-members, sister associations)
• CFA Members promote CFA standards throughout
  their supply base
• CFA catalyses action on issues broader than the
  chilled food sector alone

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• Founded October 1991
• by CFA SYNAFAP (France)
• Promotes safety and quality in the production and
  distribution of chilled foods
• ECFF Guidelines
• 1996 based on CFAs 1993 GHP Guidelines
• 2006 based on CFA 1997 Guidelines

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ECFF

• Represents
• Turnover 8bn, gt400 plants, gt10,000 products,
  58,000 employees (mostly UK)
• Members
• Belgium - BReMA
• Finland - ETL
• France - SYNAFAP
• Germany - Feinkostindustrieverband
• Italy - APPF, UNIPI
• Netherlands - Unilever Bestfoods
• Switzerland - Convenience Food Association
• UK - CFA

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ECFF

• 2003 ECFF invited Accession States Associations
  to be observers/join
• Interest from Malta and Slovenia but
• No uptake from any invitee, due to lack of local
  market/industry development

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CFA Members Major Customers (Brand Owners)
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UK Chilled Food Shelf Life

• Quality-based primarily (spoilage)
• The shortest in Europe 2-35 days, e.g.
• 2d sandwiches
• 7-10d ready meals, pizza
• 8-12d bagged salads
• 12-21d dressed salads, soups, sauces, dips,
  dressings
• 35d max fresh pasta
• Positive release is not generally an option

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UK Chilled Food Shelf Life

• Dependent on high performance chill chain, target
  5ºC, established in the 1970s
• Reliant on exceptional distribution systems,
  particularly for shortest shelf lives Just In
  Time

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CFA Standards Key Elements

• Massive investment in hygiene and technology
• Well managed supply chain
• Not wholesale, i.e. audited, traceable
• Integrated systems
• forecasting
• orders
• management
• distribution systems
• GMP/GHP HACCP core

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CFA Standards Key Elements

• High standards of factory hygiene including
  segregation of raw cooked
• High Care Area
• Only RTE components, including uncooked, e.g.
  salad
• High Risk Area
• Only RTE fully cooked components
• Separate staff, equipment, utensils

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Temperature

• CFA GHP Guidelines stipulate 6D thermal processes
  targeting key pathogens, dependent on shelf life
• Up to 10 day shelf life ?70ºC/2 mins (Listeria
  monocytogenes control)
• gt10 day shelf life ?90ºC/10 mins equiv or other
  demonstrably effective control measures
  (psychrotrophic Cl botulinum)
• UK high performance chill chain

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CFA Publications Safety, hygiene quality

• Guidelines to GHP in the Manufacture of Chilled
  Foods
• European Chilled Food Federation Guidelines
• Handwash training poster
• High Risk Area Best Practice Guidelines
• Hygienic Design Guidelines
• Microbiological Guidance for Produce Suppliers
  English, Spanish and Finnish versions
• Packaging Hygiene Guidelines
• Pesticides Due Diligence Guidance
• Veterinary Residues Management Guidance
• Water Quality Management Guidance

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SQA Supplier Quality Assurance

• HACCP-focussed systems, documented procedures
• Raw materials purchase
• to agreed specifications via approved/audited
  suppliers
• not on the open market (spot)
• Risk assess to identify risk management strategy
• All raw materials
• Suppliers capabilities, performance, systems
  certification
• Certificates of Analysis spot checked/tested
• Suppliers audited to ensure compliance with
• Commercial specifications
• Legal requirements

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Self Regulation

• UK own label system - HACCP core
• 1989 CFA recommended creation of EFSIS to audit
  CFA accreditation scheme
• 1990s
• Auditor competencies ? UKAS
• BRC Global Standard Food
• CFA Guidelines provide detail
• 2000
• International Food Standard
• Global Food Safety Initiative CIES

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Traceability

• Traceability throughout the supply chain is a
  non-negotiable, integral part of chilled food
  management systems
• Traceability is a consequence of HACCP
• for minimally prepared foods

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Traceability

• CFA members use
• Known Suppliers
• Known Standards
• Known Sources
• Partnership throughout the supply chain
• Standard own label chilled food systems exceed
  requirements of 178/2002

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Effective Traceability

• Must link a lot or batch with its source and any
  treatment it has received
• Will allow rapid access to product information
• Can limit the potential scope of a problem
  associated with a raw material (forwards)
• Can help identify where the source of a problem
  may be (backwards)

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Traceability and Prepared Produce An Example

• Lot number tells
• Date of harvest
• Identity of the farm (plot/field), producer,
  country of origin
• Chain of ownership of the material from grower to
  recipient
• Agricultural inputs (e.g. manure/fertiliser,
  irrigation, pesticides)
• dates of application
• input lot numbers

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Traceability Incident Management

• Internal Procurement Technical Partnership
• External Supplier Partnership
• Materials traceability to source
• Thorough
• Rapid
• Note
• Need good quality information on the precise
  problem, viz. raw material /or lot /or
  plant/line codes i.e. full RASFF

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What is an Incident?

• Draft definition under discussion by the
• FSA Task Force on Food Incidents
• 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
• potential incident?

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Incident Classification

• Class I incident
• there is a reasonable probability that the use of
  the product will cause serious, adverse health
  consequences
• Class II incident
• there is a remote probability of adverse health
  consequences from the use of the product
• Class III incident
• the use of the product will not cause adverse
  health consequences

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Incidents and Action
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CFAs Role - Incidents

• Services for Members
• 24/7 incident monitoring and management
• CFAs main aim is to ensure clarity
• Incident Management Manual
• General protocol
• Contact details agencies, retailers, research,
  media

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Withdrawals and Recalls

• Pre-planning required, considering
• People involved, their responsibilities, contact
  details
• The type and extent of information to be
  gathered
• Communication mechanisms
• Simulate periodically, document review
• Classify incident, determine action to take
• Carry out and document corrective actions
• Recall/withdrawal closure
• Effectiveness evaluation

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Recalls Industry

• Brand manufacturers
• Report incidents to FSA and the LA
• Issue public recall notice as appropriate
• Retail own label manufacturers
• Report incidents to brand owners
• Provide detailed information required to the
  brand owner
• All manufacturers
• Liaise with FSA and the LA and other involved
  agencies, e.g. HPA

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Recalls and Retailers

• Report own label incidents to FSA LA
• Liaise with other involved agencies
• For own label products issue public recall notice
  as appropriate
• Display point of sale information
• the scope of any withdrawal
• any action taken by the retailer/supplier
• any action required of consumers

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Authorities Responsibilities

• FSA
• Alert industry/companies to potential issue
• Seek information to scope it
• Name the brand owner, not own label producer
• Confirm reasons for scope of any recall
• Outline any action
• taken by authorities
• required of consumers
• FSA, EFSA and Local Authorities
• Coordinate on risk assessment / management /
  communication to all audiences

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CFA Communications

• Sector communications hub to/from
• Industry (Members)
• supply chain (inc international)
• other relevant associations
• Authorities and Agencies
• Media

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CFA Incident Communications

• Facilitates rapid info flow to/from industry
• Ensure involved members kept informed
• Provides authorities with industry standards and
  systems information, e.g.
• Controls in place
• Likely supply chain/s involved, e.g.
  wholesale/retail, UK/abroad
• Generates a media response/QAs
• Liaises with www.sciencemediacentre.org
• Provide clear information on science,
  any quantifiable risk

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Spices as ingredients - Key controls
(SQA)

• Subcomponent specifications
• Chilled food manufacturers risk assess
• Spices (as with all raw materials)
• Suppliers capabilities and performance
• Supplier approval
• Approved suppliers audited, systems verified
• Industry supplied with
• Contracts
• Confirmation of legality and
• Certificates of Analysis
• BUT

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Spice Assurance Limitations

• Spices often only available from third world
  countries
• controls at source/HACCP?
• Generally traded on the open market
• identity preservation/traceability?
• controls at (non-EU) borders?
• Spice traceability
• To source can be limited
• One up one down (legal requirement) not a problem
• Range of potential contaminants ?

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Spice - Current Regulatory Approach

• Impact so far
• Loss of confidence in government/EU controls at
  borders
• Economic (200M in the UK?)
• destruction of food
• loss of consumer confidence and consequent loss
  of market
• potential for moving food businesses elsewhere
  (loss of UK jobs)

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Spice going forward

• Highly advanced traceability systems
• ? rapid identification of 4th, 5th or even 6th
  generation products, irrespective of detectable
  presence
• Supplied stock quality at issue
• Focus on raw material practices and controls at
  source, not on finished product recalls
• Enhanced practical solution at source under
  development

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Summary

• UK retail chilled prepared food industry
• Emphasises supply chain process control
• Has robust and rapid traceability to source
• Different levels of development in other
  countries
• Wholesaled ingredients/commodities systems
• Emphasis on the need for industry systems
  integrity varies
• Key best practice management principles
  applicable irrespective of company size or country

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Summary

• Need common incident management approaches,
  linking
• risk assessments (EFSA) with
• risk management (EC, Member States) and
• risk communication (EC, EFSA, Member States)

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CFA Standards Online

• Downloadable copies of
• Microbiological Guidance for Growers
• Pesticides Due Diligence
• Hygienic Design Guidelines
• High Risk Area Best Practice Guidelines
• Packaging Hygiene Guidelines
• Water Quality Management Guidelines
• www.chilledfood.org/content/guidance.asp
• Hard copies other publications
• http//shop.chilledfood.org/acatalog/shop.html

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• cfa_at_chilledfood.org
• www.chilledfood.org