CFG
24/06
Letter from Foodaware
dated 6 September 2006 to John Bates, Chemical Safety Division, Branch
3, Food Standards Agency
Dear Mr Bates
Preventing and responding to food incidents
The draft document produced by the Food Incidents Task Force brings
together people with experience from food production, retailing, consumer,
and enforcement bodies and as such is valuable and practical. By identifying
and listing the key stakeholders likely to be involved in food related
businesses, it is a useful source document and guide to the legal
position. The sections relating to carrying out a HACCP analysis are
particularly clear and may help the Agency achieve its target to reduce
the number of high and medium risk incidents by 25% by 2010.
However, as the document itself acknowledges, reducing the number
of food incidents ‘requires the Agency and the industry to strengthen
the current system of checks and safeguards throughout the food chain’.
It will not be enough for this document, when finalised, just to be
circulated. The Agency and those responsible for food law enforcement
must check if it is being used in practice, particularly in medium
and high risk situations and by companies.
There are three areas where we consider that the document (or FSA
advice) could be strengthened:
- Accredited Laboratories. Chapter 1, paragraph 28, states
that laboratories must use methods that are fit for purpose and
sensitive enough both to demonstrate compliance with any limit
and/or to perform a suitable risk assessment. This is undoubtedly
necessary, but does not require the laboratory to meet approved
standards. We think that laboratories should be accredited so
that they can provide the necessary level of assurance of the
reliability of the tests carried out and, as a result, confidence
in the results. There may be no legal obligation to use accredited
facilities but it is highly desirable that companies should do
so in order to protect the public.
- Traceability. Paragraphs 34-40 concern traceability,
which is a vital element both in ensuring that companies know
the origin and content of the components of the food they supply,
and more so, that they can be traced back through the audit process
if there is a problem. Recent incidents (particularly Sudan Red)
have demonstrated the complexity of the supply chain, and that
suppliers have too little knowledge of the compound ingredients
they are using in processed food. Yet there is no requirement
for internal traceability, and whether the document itself could
have prevented the Sudan Red incident and withdrawal of foodstuffs
is doubtful. However, the advice may simplify the investigations
during an incident if improved records are kept as a result of
this document.
- Notification Procedures. Chapter 2 considers the actions
to be followed if there is an incident and paragraph 9 on page
23 offers examples of incidents which have been notified. Again,
it does not give definitive advice about what should be notified,
and the level at which potential microbiological contamination
has to be reported is unclear. Indeed, by citing ‘significant
outbreaks/cases of food poisoning/suspected food poisoning’
as an indicator of the need to notify, the FSA appears to be expecting
a lesser requirement to notify than was illustrated by its response
to the recent incident involving a potential link between a particular
strain of salmonella and chocolate. This should be tightened up
in line with current expectation and practice.
Foodaware is content for its views to be made public.
Yours sincerely
Barbara Saunders
pp Susan Knox
Chair
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