Where’s the beef?

In the last four weeks Europe has witnessed the most significant crises to hit the beef sector since BSE in the late eighties and early ninety’s. Once again, consumer confidence has been shattered in the wake of the horse meat controversy calling into question the quality, safety and provenance of the food we eat. Since the news hit the headlines key questions still remain unanswered as the food sector and regulatory authorities struggle to gain control and clear the confusion. These questions are fundamental to the legality and safety of food in the global supply chain.

Risk Communication

The controversy first emerged following DNA testing conducted by the Food Safety Authority of Ireland (www.fsai.ie) on beef burgers which found the presence of horse DNA in a number of samples. Investigations quickly focused on processing plants in Ireland including a major beef processor where one burger sample contained 29.1 per cent horse DNA. At this stage retailers and regulatory agencies were busy communicating the message to the general public that while unacceptable there was no food safety risk – comforting news for many. But for those of us old enough to remember the days of BSE we recalled a sharp lesson concerning food safety issues – beware the risk of risk communication. In 1990 the UK government and Minister John Gummer undertook a campaign to tell the public there was no risk to human health from beef. Eventually in 1996, the UK government admitted there was a link between BSE and the human form of the disease, new variant CJD. While very different in nature, the two events share a common theme regarding the communication of risk. Communicate only what is factually known and be clear to the public on the gaps in the current body of knowledge. Otherwise trust between shareholders and the public is eroded. In recent weeks as the ‘no food safety risk’ message was being communicated, events overtook that message.

Late last week the Food Standards Agency (FSA) in the United Kingdom announced that meat in beef lasagne products recalled by Findus contained 100% horsemeat. Findus said it did not believe it was a food safety issue. The chief executive of the Food Safety Authority of Ireland said that until test results for the equine veterinary medicine phenylbutazone were known, the potential health risk to the public remained unclear. Consumption of horse meat is in itself not a food safety risk but this is not necessarily the point. Whether or not a food safety issue actually exists (and of course we look forward to confirmation of this) the damage has already been done. Confusion, conflicting messages, delays in getting the facts; all contribute to a general feeling of malaise and cynicism among consumers. The message of ‘safety’ was communicated before proper risk assessment had been completed, before an investigation of exposure was undertaken and before hazard analysis was completed. Where was the coordinated response by the Commission and its member states? Where are the principles of risk analysis required under food safety regulations arising from the BSE and dioxin issues of the 1990’s? Consumers don’t always want the best news story. Often they crave the real story based on the available information at that time and this must include uncertainty! The public may wish that the authorities and food sector have all the answers available immediately. Failing this they want to trust those leading the management of the issue. As it stands now, we appear to have neither.

Traceability – where’s the beef?

One of the key remaining questions is how did horse meat enter the food chain and find its way into products labelled as beef? To answer this question we must first answer where did it come from? Four weeks on we still do not have the answer. Irish authorities stated that the source was Polish. The chief veterinary officer in Poland claimed that his country was not the source of the contamination. Attention has now turned to Romania as the source of the horse meat in the Findus recall. This has led to an angry reaction from Romanian politicians.

EU Regulation No 178/2002 – general principles and requirements of food law sets out specific requirements on traceability. According to the European Commission’s Health and Consumer Protections Directorate General Factsheet ‘Traceability is a risk-management tool which allows food business operators or authorities to withdraw or recall products which have been identified as unsafe. It is a cornerstone of the EU’s food safety policy.’ The same fact sheet goes on to painfully state ‘traceability allows targeted withdrawals and the provision of accurate information to the public, thereby minimising disruption to trade.’ For food businesses the legal framework requires them to be able to identify where their products have come from and where they are going and to rapidly provide this information to the competent authorities. I am not suggesting that anyone in this controversy has failed to meet these obligations. What I am saying is that four weeks on we appear to be struggling to determine the exact source(s) of the horse meat. Is it unreasonable to expect that after four weeks this information would be available? If not legally, does the spirit of regulation 178 not suggest that four weeks is excessive? Given the disruption to the trade, the loss of business and jobs already in this controversy many might feel that the collection of data has not been timely and the principles of traceability have failed.

Third Party Certification and Retailer Inspections

A number of the food plants at the centre of the controversy were certified under global food safety standards and were subject to technical audits from large retailers and food service brands. From the non-expert perspective it is legitimate to ask how this issue could arise under this level of third party verification. For me the question is not that simple. Those of us in the area know that auditing programs are often sampling exercises and testing programs while audited are not usually defined by auditors in terms of their scope. Nonetheless the horse meat issue and similar controversies have the potential to damage the credibility of schemes under the GFSI and third party certification at a time when they are gaining significant momentum globally. It is essential that the benefits of certification are not lost in consumer indifference.

Recent Events

It is understandable that those responsible for the management of this issue should be anxious to get out the message that there is no food safety risk. After all this is the most important issue – protection of public health. However it is just as important that the consuming public have confidence in those businesses and authorities responsible for the legality and safety of the food supply chain. The on-going horse meat issue follows on from the Germany bean-sprout / E.coli outbreak. Alarmingly both can be characterised by the confusion for the public, poor risk communication, blame directed towards other member states and erosion of public confidence.

For me they both raise a more fundamental issue – that of the role of the European Commission. The BSE and dioxin issue resulted in many lessons for the food industry and a root and branch redrafting of food safety legislation. Few would dismiss the advances made from the resultant legal framework. However events have highlighted weaknesses such as the lack of a single enforcement agency not bound by national considerations.

It also raises the question of traceability as a risk management tool. In both cases the intent of Regulation 178 had not happened in practice or at least in a timely fashion. There is also evidence that individual member states may not always be best placed to deal with issues with a pan-European character. The emerging blame culture by one member state against another is unseemly and not I believe in the interests of a common food market or the consumer.

Perhaps it is time for the Commission, member states, food businesses, retailers and certification schemes to review the excellent progress made in food safety management arising from BSE and other global food safety issues. Perhaps this should be followed up with clear identification of the lessons to be learnt from more recent events. Perhaps this could lead to positive changes in the legal and commercial framework and how we manage these issues. I believe the consuming public would not judge them too harshly and recognise that with the passage of time every system of control needs improvement and development. In the spirit of the GFSI perhaps it is time for a Management Review meeting.