A new Food Crime Unit within the UK Food Standards Agency (FSA) should be operational by the end of 2014, after British government ministers agreed to implement the main recommendations of a review into food supply networks.
The review was commissioned by government in response to the horsemeat scandal of 2013 and conducted by Professor Chris Elliot, a food safety expert at Queen’s University Belfast. He published an interim report last December. His final report was released last week.
In it, Prof Elliott makes eight main recommendations, designed to protect consumers, and taking a zero tolerance to food fraud. Included within those recommendations is the creation of the food crime unit. It is a response to concerns that, to date, there has been no clear leadership or co-ordination of effective investigations relating to food fraud.
Two major issues were highlighted as a result of the horsemeat scandal of 2013. Firstly, there was a raft of different statutory bodies involved in undertaking checks on food labels in processing and retail outlets (councils, government and the FSA). Secondly, for many enforcement officers, food fraud was low down their list of priorities.
However, the report by Prof Elliott puts the issue of food fraud high up the agenda. He wants to see the responsibility for food fraud placed firmly with the FSA and recommends it sets up a new unit based on an existing model in the Netherlands, where a food crime unit has been operational since 1988. It currently has 110 employees (up to half are ex-police) and, in 2012, investigated 24 suspected crimes, resulting in 77 people being charged with offences and the seizure of £5.3m of illegally gained assets.
The resultant crime unit in the UK might not have the same level of resource as the Dutch (Elliott envisages annual running costs of £2m to £4m), but the model proposed is one where there is a strong central team who can undertake criminal investigations, provide guidance to regulators (such as council inspectors) and co-ordinate intelligence gathering.
Why food fraud is key
In his report, Prof Elliott acknowledges that it is not possible to quantify the extent of food crime in the UK, but maintains there is strong evidence that it continues to happen.
He highlights that those most at risk of food fraud are lower income groups, who tend to spend a higher proportion of their income on food, and, in particular, processed foods, which are more susceptible to fraud. A number of surveys by local authorities in England have shown that a significant number of consumers using fast food outlets in inner city areas are buying food that is not what it is claimed to be.
There are also small businesses which are vulnerable to food fraud as they try to compete against those who cheat.
During the review, a number of trade associations were asked for information or evidence from members relating to food crime. The main reports of suspicious activity related to possible adulteration of product received from a third party. Some of the specific incidents of suspected criminal activity involved:
Mislabelling of chicken products from outside the EU with EU health marks.Goat casings imported as sheep casings from China.Meat supplied from unapproved slaughterhouses.Falsification of cattle breeds.Industry has role to play
A concern raised by Prof Elliott is the procurement of goods by major retailers at levels which are recognised as being well below a reasonable price. It is that pressure which many believe is one of the underlying reasons why horse meat was substituted for beef in processed food products.
In his report, Elliott cautions retailers against the procurement of goods at below-cost price, which he maintains is not good for the sustainability of UK farming or the integrity of the food industry (as it forces some to consider cutting corners). He suggests that where produce is sourced at low prices, it should be for the retailer to produce evidence that it checked there were no grounds for suspicion. Any party that can be shown to have profited from criminal property (food which has had labels altered), even knowing or suspecting it was such, would be culpable under the Proceeds of Crime Act 2002.
He would also like to see mechanisms further developed to allow industry and consumers to ‘‘whistleblow’’ and report general concerns about food crime to authorities.
He also recommends setting up a ‘‘safe haven’’ through which intelligence and information could be collected and shared by those involved in the food industry.
Where individuals and companies are found to have broken the law, the information should be shared across the various enforcement bodies via a central register of food law convictions. This register should be open to viewing by the general public, suggests Elliott. It is all part of a zero-tolerance approach to food crime.
Laboratory testing
Testing of the authenticity of food is undertaken by a number of both private and public sector laboratories across the UK.
Prof Elliott recommends that government must ensure that standard procedures are being used and that knowledge and capacity is being shared.
The official response to the Elliott review from government is that they accept the key principles outlined in the report, including the setting up of a Food Crime Unit within the FSA.
The first stage in setting up this unit is to be completed by the end of 2014, with progress to be reviewed in two years. It will be overseen by a board made up of government departments and relevant criminal enforcement agencies.
It remains to be seen whether the crime unit actually delivered within the FSA will be the same as that originally envisaged by Prof Elliott.
Change required in audit and inspection regime – Elliott
One issue that often draws complaints from the local food industry is the time and staff resources that are now required to deal with the raft of audits and inspections by enforcement bodies and customers for product.
In his review, Prof Elliott concludes that these inspections and audits are variable, and many of the requirements are either futile or unreasonable and often assessing the same basic food safety requirements. ‘‘The growing number of audits commissioned by retailers is not achieving the intended purpose. The auditing regime has, in some cases, become an industry in itself,’’ states the report.
The solution put forward is that wholesaler and retailer customers should collectively work towards a system involving fewer, but more effective audits.
In this scenario, certification bodies (for example, those offering the BRC global standard) would use a modular system of auditing that would entail a core food safety and integrity audit.
There could then be individual retailer modules designed according to business priorities, undertaken at the same time as the core audit.
In addition, Elliott suggests that the industry should move to unannounced inspections as the norm and that auditors should undertake regular product sampling as part of the inspection process.
Those food businesses which show best practice during an audit would then have their inspection frequency reduced (for example, fewer inspections by environmental health officers), in line with the principle of ‘‘earned recognition’’ being developed by the FSA.
Supply chain
One particular area singled out by Elliott in his report is the need for checks throughout the supply chain, not just at processor level.
He recommends unannounced audits (including outside normal business hours) and sampling of product in storage facilities such as cold stores.
He also recommends new accreditation standards to cover meat traders and brokers and the use of tamper-proof seals on containers in transport.
Elliott would also like to see more checks done on animal by-product kept in cold stores.
Current regime
He is critical of the current inspection regime and suggests that, when frozen, Category 3 material (suitable only for pet food) looks no different to material fit for the human food chain.
Selling Category 3 material (as fit for human food consumption) has the potential to be a very profitable activity.
A new Food Crime Unit within the UK Food Standards Agency (FSA) should be operational by the end of 2014, after British government ministers agreed to implement the main recommendations of a review into food supply networks.
The review was commissioned by government in response to the horsemeat scandal of 2013 and conducted by Professor Chris Elliot, a food safety expert at Queen’s University Belfast. He published an interim report last December. His final report was released last week.
In it, Prof Elliott makes eight main recommendations, designed to protect consumers, and taking a zero tolerance to food fraud. Included within those recommendations is the creation of the food crime unit. It is a response to concerns that, to date, there has been no clear leadership or co-ordination of effective investigations relating to food fraud.
Two major issues were highlighted as a result of the horsemeat scandal of 2013. Firstly, there was a raft of different statutory bodies involved in undertaking checks on food labels in processing and retail outlets (councils, government and the FSA). Secondly, for many enforcement officers, food fraud was low down their list of priorities.
However, the report by Prof Elliott puts the issue of food fraud high up the agenda. He wants to see the responsibility for food fraud placed firmly with the FSA and recommends it sets up a new unit based on an existing model in the Netherlands, where a food crime unit has been operational since 1988. It currently has 110 employees (up to half are ex-police) and, in 2012, investigated 24 suspected crimes, resulting in 77 people being charged with offences and the seizure of £5.3m of illegally gained assets.
The resultant crime unit in the UK might not have the same level of resource as the Dutch (Elliott envisages annual running costs of £2m to £4m), but the model proposed is one where there is a strong central team who can undertake criminal investigations, provide guidance to regulators (such as council inspectors) and co-ordinate intelligence gathering.
Why food fraud is key
In his report, Prof Elliott acknowledges that it is not possible to quantify the extent of food crime in the UK, but maintains there is strong evidence that it continues to happen.
He highlights that those most at risk of food fraud are lower income groups, who tend to spend a higher proportion of their income on food, and, in particular, processed foods, which are more susceptible to fraud. A number of surveys by local authorities in England have shown that a significant number of consumers using fast food outlets in inner city areas are buying food that is not what it is claimed to be.
There are also small businesses which are vulnerable to food fraud as they try to compete against those who cheat.
During the review, a number of trade associations were asked for information or evidence from members relating to food crime. The main reports of suspicious activity related to possible adulteration of product received from a third party. Some of the specific incidents of suspected criminal activity involved:
Mislabelling of chicken products from outside the EU with EU health marks.Goat casings imported as sheep casings from China.Meat supplied from unapproved slaughterhouses.Falsification of cattle breeds.Industry has role to play
A concern raised by Prof Elliott is the procurement of goods by major retailers at levels which are recognised as being well below a reasonable price. It is that pressure which many believe is one of the underlying reasons why horse meat was substituted for beef in processed food products.
In his report, Elliott cautions retailers against the procurement of goods at below-cost price, which he maintains is not good for the sustainability of UK farming or the integrity of the food industry (as it forces some to consider cutting corners). He suggests that where produce is sourced at low prices, it should be for the retailer to produce evidence that it checked there were no grounds for suspicion. Any party that can be shown to have profited from criminal property (food which has had labels altered), even knowing or suspecting it was such, would be culpable under the Proceeds of Crime Act 2002.
He would also like to see mechanisms further developed to allow industry and consumers to ‘‘whistleblow’’ and report general concerns about food crime to authorities.
He also recommends setting up a ‘‘safe haven’’ through which intelligence and information could be collected and shared by those involved in the food industry.
Where individuals and companies are found to have broken the law, the information should be shared across the various enforcement bodies via a central register of food law convictions. This register should be open to viewing by the general public, suggests Elliott. It is all part of a zero-tolerance approach to food crime.
Laboratory testing
Testing of the authenticity of food is undertaken by a number of both private and public sector laboratories across the UK.
Prof Elliott recommends that government must ensure that standard procedures are being used and that knowledge and capacity is being shared.
The official response to the Elliott review from government is that they accept the key principles outlined in the report, including the setting up of a Food Crime Unit within the FSA.
The first stage in setting up this unit is to be completed by the end of 2014, with progress to be reviewed in two years. It will be overseen by a board made up of government departments and relevant criminal enforcement agencies.
It remains to be seen whether the crime unit actually delivered within the FSA will be the same as that originally envisaged by Prof Elliott.
Change required in audit and inspection regime – Elliott
One issue that often draws complaints from the local food industry is the time and staff resources that are now required to deal with the raft of audits and inspections by enforcement bodies and customers for product.
In his review, Prof Elliott concludes that these inspections and audits are variable, and many of the requirements are either futile or unreasonable and often assessing the same basic food safety requirements. ‘‘The growing number of audits commissioned by retailers is not achieving the intended purpose. The auditing regime has, in some cases, become an industry in itself,’’ states the report.
The solution put forward is that wholesaler and retailer customers should collectively work towards a system involving fewer, but more effective audits.
In this scenario, certification bodies (for example, those offering the BRC global standard) would use a modular system of auditing that would entail a core food safety and integrity audit.
There could then be individual retailer modules designed according to business priorities, undertaken at the same time as the core audit.
In addition, Elliott suggests that the industry should move to unannounced inspections as the norm and that auditors should undertake regular product sampling as part of the inspection process.
Those food businesses which show best practice during an audit would then have their inspection frequency reduced (for example, fewer inspections by environmental health officers), in line with the principle of ‘‘earned recognition’’ being developed by the FSA.
Supply chain
One particular area singled out by Elliott in his report is the need for checks throughout the supply chain, not just at processor level.
He recommends unannounced audits (including outside normal business hours) and sampling of product in storage facilities such as cold stores.
He also recommends new accreditation standards to cover meat traders and brokers and the use of tamper-proof seals on containers in transport.
Elliott would also like to see more checks done on animal by-product kept in cold stores.
Current regime
He is critical of the current inspection regime and suggests that, when frozen, Category 3 material (suitable only for pet food) looks no different to material fit for the human food chain.
Selling Category 3 material (as fit for human food consumption) has the potential to be a very profitable activity.
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