Preventing and Managing Major Food Incidents

1. Preventing and Managing Major Food Incidents Kaarin Goodburn Secretary General Chilled Food Association

2. 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]

5. UK Retail Chilled Foods • >95% 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

6. 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

7. 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

8. 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

9. 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)

10. 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

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

12. ECFF • Represents • Turnover ~€8bn, >400 plants, >10,000 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

13. 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

14. CFA Members’ Major Customers (Brand Owners)

15. 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

16. 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

17. 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

18. 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

19. 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) • >10 day shelf life: 90ºC/10 mins equiv or other demonstrably effective control measures (psychrotrophic Cl botulinum) • UK high performance chill chain

20. 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

21. 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

22. 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

23. 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

24. 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

25. 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)

26. 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

27. 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

28. 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?

29. 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

30. Incidents and Action

31. CFA’s Role - Incidents • Services for Members: • 24/7 incident monitoring and management • CFA’s main aim is to ensure clarity • Incident Management Manual • General protocol • Contact details – agencies, retailers, research, media

32. 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

33. 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

34. 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

35. 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

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

37. 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…

38. 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 = ?

39. 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)

40. 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

41. 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

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

43. 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

44. cfa@chilledfood.org www.chilledfood.org