Food fraud, food safety and inspections

Looking at the history of (food) fraud, it tends to happen when there are opportunities. And I am not speaking of incentives like price hikes and short supply. To successfully commit food fraud, you need to know about the expectations of the customers you deceive (e.g. food manufacturer) and how they perform their controls to ensure what they buy is in line with specifications.

In the days of Upton Sinclair, when he published his novel “The Jungle” about the issues in the American meat packing industry, some of the opportunities were created because meat inspectors just “looked away”. It was well known that meat unfit for human consumption was still processed and sold.
The Chicago Tribune printed a modified child’s poem:

Mary had a little lamb,
and when she saw it sicken,
she shipped it off to Packingtown,
and now its labelled chicken

Upton Sinclair describes in his report how the inspectors responsible for meat inspection often turned a blind eye.

So how does this relate to the report of the European Commission? It was mid-September that the European Commission published the report about official controls between 2014 to 2016. The key statements it contains are:

  1. [There are…] “clear signals from Member States that staff resources for controls are increasingly limited and that a potential further reduction risks negatively affecting the levels and/ quality of controls and the capacity to respond to emergencies.”
  2. “The Member States reports presented evidence that overall, the established trend in the Member States towards increasingly risk-based controls continues”
  3. “However, and as confirmed by audits by the Commission services, risk-based controls are not applied in all areas where such controls are warranted.”

So, in plain English: we cannot fulfill our duties of protecting European consumers with the ever-decreasing resources we have. This is by no means a new revelation. Listening to many colleagues and friends in government control authorities, I learned their workload increases while the number of staff is continuously reduced.

While I am the last person to support governments wasting money (which they are known to do on a regular basis on non-safety related items– according to the German Bundesrechnungshof), when it comes to food safety, where controls are protecting the health of consumers, I do not understand the causality which leads to decisions to disband committees or reduce staff.

As one example, the UK Food Standards Agency used to have committees dealing with animal speciation, led by a very knowledgeable colleague who now runs the UK Food Authenticity Network. At the time in 2001, we were developing methods for the detection of horsemeat and donkey meat for government control. The UK FSA shut down those committees. I wonder if horsemeat would have happened, or if it would have happened to the same extent we saw in 2013, if those activities had been maintained by FSA. And while the horsemeat scandal was not related to food safety, melamine in 2008 certainly was.

So, if “risk-based controls […] where such controls are warranted” cannot be performed due to staff shortage – it means putting consumers at risk.

And we have seen how non-transparent government authorities’ communication was when the fipronil scandal broke. It took days, if not weeks to assess how widespread the scandal was and how many egg-producing farms were actually affected. Do you remember the empty shelves at some retailers?

Such incidents are likely to rise if fraudsters know that governments cannot even perform their risk-based controls where warranted! Do private certification schemes help? All of the GFSI-benchmarked private certification schemes have a section on food fraud and vulnerability assessment. While the situation has certainly improved over the past years, sourcing certain product groups from small-hold farms in remote areas of India, China or Africa cannot always be controlled at this point in time – and I do accept that some blockchain-evangelists think differently – but I surmise that most may have not been out there trying to source in remote places themselves.

Certification schemes alone will not remedy the problem. At Codex Alimentarius level there is a proposal which would give governments access to data of private certification schemes – apparently to improve risk assessment. I wonder how useful that is if there is no staff at government level to inspect what they found to be high risk.

Reducing the risk of food fraud needs a combination of private-public partnership, i.e. certification schemes plus inspections. Reducing staff at government control bodies is creating opportunities for fraudsters, putting food safety and consequently consumers at risk in the European Union. Saving here means saving at the wrong end.

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