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SOFHTFOCUS - Society of Food ...
ISSN 2040-607X • ISSUE 90 • JULY 2019

SOFHTFOCUS
The Magazine of the Society of Food Hygiene and Technology             www.sofht.co.uk

ETHICAL
BUSINESS
PRACTICE
AND
REGULATION:
A NEW PARADIGM
FOR BUSINESS
AND REGULATION

                       CE markings are no guarantee of safety

                Transparent supply chains – is it all about blockchain?

             FSA advisors to review new evidence on VP and MAP foods

            Food waste prevention remains a priority for SOFHT members
SOFHTFOCUS - Society of Food ...
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SOFHTFOCUS - Society of Food ...
CONTENTS

THOUGHTS FROM
THE EDITOR…                             IN THIS ISSUE
Welcome to the
Summer SOFHT
Fo c u s .   We l l
                                        4
the weather is
trying …
What a great afternoon / evening
we had at the beautiful Coombe
                                        Welcome                           News                        5
Abbey, I hope you enjoyed it as
much as I did. It was good to see
so many old and new (members).
                                        10
The weather is at least warming         Ethical business
up, however the impact of so            practice
much rain is already placing            and regulation
challenges on harvests and
supply chains.
I hope you enjoy the articles in this
edition where we have focused
                                                                          16
on ethical practices. My thanks         CE Markings are
to the authors Professor Chris
                                        no guarantee                      Transparent
Hodges, Ruth Steinholt and David
Meller for their inciteful articles.
                                        of safety   14                   supply chains
We have also an interesting and
informative article from Andy           FSA advisors to review
Johnson on CE markings on PPE           new evidence on
and the common misconceptions
                                        VP and MAP foods
around their safety. Once again,
thanks go to Rick for supporting
me and pulling together these
                                        20
articles. Please do contact us if
you have something you’d like to
publish in the Focus or to suggest      24                                28
topics you would like to see.
We are delighted to welcome             Food waste                                       Training
our new SOFHT board members
Jonathan France, Tracey Colbert,
                                        prevention                                       Update
Fiona Sutherland and Jamie
Weall and say a fond farewell to        EDITOR
John Rigarlsford and Nagaraju           Dianne Waite                      Designed, produced & published by:
                                                                    The Society of Food Hygiene and Technology,
Sayamoni.                               SOFHT OPERATIONS
                                                                           The Granary, Middleton House Farm,
I wish you all a Happy Holidays.        DIRECTOR
                                                                                      Tamworth, Staffs B78 2BD
                                        Su Werran
Dianne Waite,                                                             Tel: 01827 872500 | Fax: 01827 875800
                                        ADVERTISING
Editor SOFHT Focus                      Contact the SOFHT office   Email: admin@sofht.co.uk | www.sofht.co.uk

                                                                           JULY 2019 | SOFHT FOCUS
                                                                                                           3
SOFHTFOCUS - Society of Food ...
INTRODUCTION

      Introduction
      FIONA KIBBY, SOFHT CHAIRMAN
      This edition of SOFHT Focus really highlights the challenging time we are working in
      across the industry. From new technology applications such as Blockchain traceability
      of products to challenges around the safety and guidance on vacuum packed (VP)
      and modified atmosphere packed (MAP) products this SOFHT focus packs a lot in.
      Another sign of the times was the excellent SOFHT Summer Lecture from Wayne Martindale of the University of Lincoln
      on the changing customer preferences and increasing focus on vegan, vegetarian and flexitarian diets. He raised some
      challenging points on the sustainability of these diets, reminding us to look at the carbon footprint and the environmental
      impact of all diets. As ever I am proud of the work that SOFHT is doing to produce such interesting, wide ranging and
      illuminating publications as well as events. I hope you enjoy the read and have a lovely summer and look forward to
      meeting more members at our upcoming events.

      Fiona Kibby

CHAIRMAN'S REPORT
In my first year in this role for             across the industry. Our purpose is            forward to seeing this event develop
the Society of Food Hygiene and               to ensure that all those who need it           year-on-year. Our November Lunch
Technology, I have been reviewing             can access support and information             and SOFHT Awards, which included
SOFHT’s purpose and strategy                  that promotes better hygiene and               some revitalised awards categories,
with Council members. We have                 safety in the food industry.                   were held at a new location, The
reviewed the events programme                                                                Brewery in London. Our guest
                                              This year has seen a new focus on
and are keen to develop a forward-                                                           presenter, TV personality Kate
                                              allergens in food, brought about
thinking plan for events over the                                                            Quilton, proved a huge success with
                                              through tragic circumstances,
coming months that will work for                                                             the audience.
                                              and we have been able to use the
our members. We are very clear
                                              expertise and experience of our
on keeping to our core topics and
                                              members to listen to the concerns
                                                                                             Media and PR
serving the food industry and those                                                          We have continued to be active on
                                              of allergy sufferers and support
who support it with practical access                                                         social media and have found this to
                                              consultations, and technical
to good speakers on relevant topics,                                                         be a useful way to keep in touch with
                                              discussions on the topic.
networking and information to help                                                           our members and followers. We
us all in our day-to-day activities.          Our membership has continued
                                                                                             have enlisted the support of SOFHT
                                              to be strong with new Supporting
We have also analysed our                                                                    Council members to improve our
                                              Company Members joining this
membership offer and have set out to                                                         response to media enquiries and
                                              year. We are grateful for their
simplify and clarify the membership                                                          to react to new opportunities that
                                              support and look forward to
levels. We consider ourselves to                                                             present themselves. This year we
                                              working collaboratively with them
be unique in being able to offer a                                                           have started to work with a new PR
                                              over the coming year.
membership that suits everyone                                                               agency – Zen Communications. We
that wants to be part of our SOFHT            We also very successfully held                 look forward to seeing how they
family, regardless of qualifications          several main events over the year,             can modernise the way we work to
or experience. SOFHT is there to              with a new Summer Lecture event                find new ways to connect with our
support the diverse sectors and               hosted by the SOFHT Council in                 membership and reach out to new
huge range of people who work                 Warwickshire. We are looking                   people across the industry.

          SOFHT FOCUS | JULY 2019
  4
SOFHTFOCUS - Society of Food ...
NEWS

Pret A Manger Joins SOFHT as a                                                        New Members
Supporting Company Member                                                             We are pleased to welcome the following
                                                                                      members to SOFHT who have joined
                                                                                      since the last issue of SOFHT Focus:
Pret A Manger, an international
sandwich shop chain based in
                                                                                      Supporting Company Member
the United Kingdom, popularly
referred to as Pret, has joined The Society of Food Hygiene & Technology (SOFHT)      Pret A Manger
as a Supporting Company Member.                                                       Corporate High 5
Supporting Company Membership (SCM) was set up by SOFHT in 2003 as part               Atkins & Potts Ltd
of a major drive to enlist the support of larger organisations within the food        N Wholesale Ltd
manufacturing, retailing and related industries.                                      Heavenly Baker Limited
SCM gives businesses access to a range of services from SOFHT such as market          Individual Premium
updates in food safety, training, seminars and events as well as the opportunity to   Lesley Hemson
network with industry colleagues. In turn, membership of high-profile companies
                                                                                      Individual Standard
such as Pret A Manger enhances SOFHT’s reputation as ‘the voice of food safety
and food hygiene’.                                                                    Sabina Marshall Buckley Foods
                                                                                      Sue Garlick
Kirsten Lawton, UK Head of Safety at Pret A Manger said:
"SOFHT has an outstanding reputation in our industry; their work is integral not      Students
only to us but also to our customers and throughout our supply chain. Our SCM         Charlotte Rennison
membership demonstrates our commitment to strive for excellence and we are            Weng Yee Chong
looking forward to becoming involved with the organisation and strengthening our
                                                                                      Karen Millar
technical expertise in food hygiene and food safety."

Summer                                                                                  Billy Blog
SCM Meeting                                                                             Billy has been
a success                                                                               enjoying the recent
Our summer meeting for Supporting          members at any time. This is a very          weather and sunning
Company Members took place in              important relationship for us and            himself on his annual
June at the National Liberal Club in       strengthens our position as the voice
London. Our guests were Rebecca            of the food industry. If there are any       summer holidays!
Sudworth, the new Director of Policy       issues that you want us to raise with
at the Food Standards Agency and           the agency please contact the office at
Chun-Han Chan, who heads up their          sofht.co.uk.
allergens team. This was a very timely
meeting and Rebecca and Chun-Han           After the meeting the weather was
gave us an overview of the recent          good enough for us to enjoy drinks
consultation on allergen labelling and     on the club terrace and, as always,
the likely outcomes. They also spoke       the excellent team at the club looked
about national and international work      after us very well. On overhearing that
on allergen research. We were pleased      one of our members had a very long
that Rebecca said that she was keen        trip home they presented her with a
to forge strong links with the society     goody bag of snacks for the journey –
and welcomed any enquiries from our        customer service at its best.

                                                                                      JULY 2019 | SOFHT FOCUS
                                                                                                                           5
SOFHTFOCUS - Society of Food ...
NEWS

Newly Elected
Board Members

                                                                         Fiona Sutherland                   Tracey Colbert
                                                                         Fiona has had a varied             Having graduated from the
                                                                         career spanning 25+ years          University of Salford with a
                                                                         across many aspects of the         BSc (Hons) in Environmental
                                                                         food industry as a technical       Sciences, Tracey registered
Jonathan France                     Jamie Weall                          manager, hygiene manager,          with the Environmental Health
                                                                         industry specialist and senior     Officers Registration Board and
Jonathan France is a qualified      Jamie completed a Trading
                                                                                                            then completed the NEBOSH
Environmental Health Officer,       Standards Degree in 1995 and         lecturer.
with a BSc (Hons) degree in                                                                                 Diploma in Health & Safety
                                    started working for a large          Her career has included            and a post graduate diploma at
Environmental Health from
Leeds Metropolitan University,      health food manufacturer in          positions with key dairy           South Bank University London
and is registered with the          its Regulatory department            producers, retail providers,       in Food and Safety Control. She
Environmental Health Officers       for three years. He then went        ready-to-eat manufacturers         has far-reaching experience
Registration Board. He also                                              and hygiene consultancies.         within the field, having held
                                    to work for a number of food
holds an MSc in HACCP from                                               Throughout this time, she          positions at government
                                    consultanc ies,      in c lud i ng                                      organisations, before moving
Salford University.                                                      has developed some strong
                                    Lawlabs      fo r   11   years,                                         into the hospitality sector
Jonathan served as District                                              customer relationships with
                                    FoodChain, NSF and Exova,                                               to senior positions at ASK
EHO to Rotherham Borough                                                 many blue-chip companies,
                                    advising and training on food                                           Restaurants Limited, Yum!
Council following his                                                    some of which have spanned
                                    labelling, food safety and                                              Restaurants International,
qualification, before moving                                             more than 15 years.                Tragus, later acquired by
to the private sector as            Trading Standards food related
                                                                         Alongside these varied roles,      Casual Dining Group, and now
an environmental health             issues. He advised large and
                                                                         Fiona has delivered an up-to-      at wagamama. Tracey sits on
consultant for Lawlabs,             small retailers, manufacturers,                                         the UK Hospitality Food Experts
Bodycote Testing, the Exova                                              date training provision, both
                                    importers and agents.                                                   Group and was instrumental in
Group and SVA. In 2013,                                                  with her varied employers and
                                                                                                            the publication of the Catering
Jonathan co-founded Trading         Since 2015 Jamie has been            the CIEH (Chartered Institute
                                                                                                            Industry Guide 2016.
Safely Ltd, a consultancy to        working for Aston Manor Cider,       of Environmental Health). She
the retail, manufacturing and                                            has supported this provision       A s D i re c t o r o f R i s k +
                                    the UK's second largest cider
hospitality industries. Working                                          with the completion of two         Compliance at wagamama,
                                    manufacturer where he is Head
as a board level expert advisor,                                                                            Tracey spearheads a range
                                    of Compliance. The group role        teaching degrees and many
Jonathan supports a variety of                                                                              of initiatives to drive ever-
                                                                         industry qualifications.
clients, from internationally-      means he is responsible for                                             higher standards and ensure
recognised supermarkets and         four sites to ensure that all        Fiona now spends her time          compliance at wagamama, a
multinational consultancies, to     are compliant from a legal,          supporting and educating           pan-Asian restaurant chain
NHS Trusts, local authorities,                                           the next generation of food        operating 200 sites in the
                                    technical and environmental
and care homes.                                                                                             UK, US and internationally.
                                    point of view. The role also         industry entrepreneurs and
Jonathan is a member of the                                              industry specialists as a senior   Tracey sets the strategic
                                    involves him being responsible
Food Standards Agency’s                                                  lecturer at the University of      vision in this area, ensuring
                                    for the company’s sustainability                                        wagamama remains a leader
(FSA's) Expert Advisory Panel                                            Lincoln (National Centre for
since 2016. He was appointed        agenda where he represents                                              in food, health, fire safety
                                                                         Food Manufacture). She is
as spokesperson for SOFHT           the company on the UK                                                   and compliance, and has
                                                                         course lead for the Advanced
in 2018 and has represented         Plastics Pact and, recently,                                            continually driven improvement
                                                                         Apprenticeships in Team
the Society on several high-                                                                                in standards and delivered best
                                    he has taken over the group’s        Leader and also Learning
profile television and radio                                                                                practice during her tenure.
                                    overall responsibility for health    and Development. She also
programmes in relation to                                                                                   Blessed with an abundance of
environmental health and food       and safety. Jamie is a member        supports on many of the            energy and can-do mentality,
safety, including Rip-Off Britain   of the Senior Management             other apprentice and degree        Tracey has steered the
and Food Unwrapped.                 Exec Board for Aston Manor.          programmes.                        company to new heights

          SOFHT FOCUS | JULY 2019
  6
SOFHTFOCUS - Society of Food ...
NEWS

Summer Lecture at Coombe Abbey
On the 4th July, the Board of Directors     Fiona had the following to say:
welcomed members to the 3rd SOFHT
                                            "Jessica took a very interesting focus
Summer Lecture Event. It was again
                                            with her research by investigating the
a gloriously hot and sunny day. We
                                            point of view of the allergen sufferer
were treated to a fascinating talk
                                            and comparing with the opinion of a
from Dr Wayne Martindale, Director
                                            restaurant employee; a very topical
of Food Insights and Sustainability
                                            subject at this time."
at the UK National Centre for Food
Manufacturing. His talk was entitled:       "Weng Yee's focus on the cleaning
‘How a meat-free revolution gave us         of ready to eat salads was very
insights that built sustainability into     interesting and topical with the
all food supply chains'. He explored        current focus on the reduction of
this and a wide variety of related          chemicals in food processing. The
topics including waste, sustainable         comparison of Inertial Cavitation
technologies and the impact of              and Non-inertial Cavitation was very
generational and technological              interesting as the surface damage
change on our food supply. Wayne did        of leaf is integral to customer
a brilliant job delivering against the      satisfaction."
noise and intermittent gusts of the         Congratulations to Jessica and Weng
large fans that were endeavouring to        Yee.
cool his audience.
                                            Following the awards, everyone
T h e S O F H T st u d e n t a w a rd s ,   migrated to the terrace to network
sponsored by NSF International,             and enjoy the barbeque, kindly
were presented to this year's winners       sponsored by Pal International,
by Fiona Sutherland, Senior Lecturer        with drinks sponsored by Hygiene
at the University of Lincoln and new        Improvement Solutions, while being
Director on the SOFHT board looking         entertained by a live saxophonist – a
after student membership.                   perfect end to the evening.
The winners were Jessica Lemon in           We are keen to receive feedback on
the 'undergraduate' category, and           this event. If you attended, please
Weng Yee Chong in the 'part-time            complete the feedback form which
students/apprentices in employment'         you will have received or speak
category.                                   directly to one of the SOFHT team.

                                                                                     JULY 2019 | SOFHT FOCUS
                                                                                                               7
SOFHTFOCUS - Society of Food ...
NEWS

  Food Safety
  Level 4 Course
  Exam Results
  Congratulations to Ian Finlayson, from
  Practical Solutions International, who has
  passed the SOFHT Food Safety Level 4
  Course with a Distinction.
  Ian says: "I would really recommend the Food Safety
  for Manufacturing Level 4 course, run 1 day a month
  for 5 months. The course is run concurrently for
  manufacturing and catering which gives interesting
  insight, and great sharing of experiences between
  attendees. It suits those with some experience,
  and those wanting a refresher/ update on the latest
  thinking. There is homework to do, but this is helpful!"

The ‘voice’
of SOFHT
members:
have your say
We are very keen to encourage
industry collaboration and to
represent the views of our members
on relevant industry topics.

With this in mind, we intend to set
up and run regular SOFHT Members
Technical Meetings. As we all know,
allergens have been a high profile
issue for some time, and back in
December 2018 SOFHT held its first
Technical Meeting on the subject of         tragically died of anaphylaxis on 17   to help provide advice and support to
‘Allergens in the food industry’. Since     July 2016 after eating a sandwich      members. Our intention is to provide
then, there has been a government           from Pret A Manger, which – unknown    a forum where concerns can be
consultation on the labelling of food       to her – contained sesame seeds, to    raised and also where government
prepacked for direct sale.                  which she was allergic.                and non-government organisations
                                                                                   can discuss emerging issues with
This was followed by the recent             The purpose of these technical
                                                                                   industry members.
announcement         about     the          meetings is to share knowledge,
implementation of ‘Natasha’s Law’,          experience and best practice           The next SOFHT Members Technical
which comes into force in summer            with a view to supporting position     Meeting is planned for the Autumn of
2021. It is named after 15-year-old         statements from the society, eg        2019. Please let us know if you have
Natasha Ednan-Laperouse, who                responses to consultations and also    ideas for suitable topics of discussion.

         SOFHT FOCUS | JULY 2019
  8
SOFHTFOCUS - Society of Food ...
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SOFHTFOCUS - Society of Food ...
ETHICAL BUSINESS PRACTICE AND REGULATION

   Ethical business
   practice and
   regulation:
   a new paradigm for
   business and regulation
There is a growing consensus among businesses and regulatory                            Leadership’s role is to consistently
                                                                                        reinforce and apply the values. They
organisations that operating ethically makes good commercial
                                                                                        must encourage constructive inquiry
sense. Professor Christopher Hodges and Ruth Steinholtz                                 and challenge through conversations at
explain the reasoning behind this.                                                      all levels to determine what is the right
                                                                                        thing to do, especially in grey areas. A
Ethical Business Practice (EBP) is a       Principles on Business and Human             learning culture, where fair, honest and
new paradigm by which businesses can       Rights. Institutional investors are          open feedback is given and received,
achieve outstanding success. The core      increasingly seeking evidence of long-       focusing on accountability rather than
idea is that the people involved in the    term sustainability.                         blame is key. This approach delivers
business focus on creating a values-                                                    continuous improvement, as people
                                           The themes of social purpose, values,        become more comfortable speaking up.
based culture that enables them to
                                           culture and trust are all now appearing
consistently do the right thing, and                                                    EBP involves two frameworks: a focus
                                           in corporate governance requirements
produce evidence that they – and the                                                    on leadership and culture as well as
business – can be trusted.                 such as the G20/OECD Principles of
                                                                                        on values-based ethics and compliance
                                           Corporate Governance and the 2018
EBP involves all stakeholders; including                                                that together produce the desired
                                           UK Corporate Governance Code. The
directors, managers, workers at every                                                   behaviours and therefore evidence that
                                           UK’s OFWAT (the Water Services
level, customers, suppliers, external                                                   the organisation can be trusted.
                                           Regulation Authority) has inserted
communities, investors and regulators                                                   The components of these two frameworks
                                           similar requirements on purpose,
in a way that recognises and supports                                                   develop and support EBP; however each
                                           strategy, values and culture into its
their various interests.                                                                organisation must consciously adapt
                                           licence conditions.
                                                                                        them, depending on their particular
SUSTAINABLE CORPORATIONS                   An effective ethical culture is the result   values, situation and risks. There is no
Culture eats strategy for breakfast,       of genuine positive values put into          one culture or set of values that will
so EBP is sound commercial strategy.       practice by the organisation, beginning      guarantee compliance and business
It responds to multiple issues that        with leadership. The foundation is a         improvement in every organisation. The
concern businesses today, such as          clear social purpose and it is created       very process of developing the elements
sustainability, community, environment     where managers lead by example and           of the frameworks itself is an important
and human rights, as required by the UN    all staff consistently strive to put their   contributor to the outcome. Relevant
Global Compact, the OECD Guidelines        ethical values into effect. This requires    evidence of an effective ethical culture
for Multinational Enterprises, the ISO     conscious alignment of purpose,              should be holistic, coming from staff,
26000 Guidance Standard on Social          values, structure and processes,             suppliers, customers, investors, society
Responsibility, and the UN Guiding         including incentives.                        and regulators.

         SOFHT FOCUS | JULY 2019
 10
ETHICAL BUSINESS PRACTICE AND REGULATION

                                                                    BUSINESS SUCCESS
                                                                    There is clear evidence that values-based business leads
  " The food sector is ripe for EBP and EBR,                        to sustainability and success. Both profit and compliance
  as a response to globalisation and chains                         are outcomes of ethical practice, rather than driving goals.
  of digital evidence"                                              Research has shown evidence of a positive relation between
                                                                    employee satisfaction, corporate cultures of integrity, and stock
                                                                    returns, in long-term business success.
An illustration of one type of EBP is the idea of ‘conscious        A 2017 McKinsey study of 600 firms showed an elite of 27% that
capitalism’ – pioneered by Whole Foods Market – that considers      focused on the long-term performed better than the 73% that
all stakeholders: staff, suppliers, customers, regulators,          were short-termist. A Gallup study found that organisations
communities, investors – and takes their needs and interests        with highly engaged employees have 3.9 times the earnings
into account.                                                       per share growth rate compared with organisations with low
The paradigm developed in Ethical Business Practice and             engagement in the same industry. Data from 5,000 German
Regulation is based on evidence from many sources, especially       establishments demonstrated that firms that adopt trust-based
behavioural science, i.e. scientific research on how people         work contracts tend to be between 11 to 14% more likely to
                                                                    improve products.
actually behave. It shows that people are not the ‘rational
actors’ in making decisions portrayed by pure economic theory.      A 2014 analysis of 57 US public and private companies, and
Instead, humans are subject to many cognitive and other biases      15 companies from other parts of the world, identified as
and needs that influence behaviour. For example, we often           operating as ‘firms of endearment’ that adopt a comprehensive
make decisions quickly based on shortcuts, and follow others        approach of delivering the needs of all stakeholders, showed
in our group, whether or not their behaviour is in line with our    cumulative shareholder returns for these firms over 15 years
values. We must therefore create cultures where individuals         were 1,681% and 1,180% respectively, as against Standard &
are not able to rationalise unethical behaviour. In addition, the   Poor 500 companies’ rate of 117%. They called culture the
ethical elements of decisions should be recognised, and not         ‘secret ingredient’, and society the ultimate stakeholder.
forgotten through pure cost-benefit thinking.                       Ernst & Young’s 2016 survey of 100 Board members of FTSE
                                                                    350 companies found that 92% said that investing in culture
SUMMARY OF ASPECTS OF THE CULTURE AND                               had improved their financial performance, 55% believed that
LEADERSHIP FRAMEWORK OF EBP                                         investing in culture had increased operating profits by 10%
                                                                    or more, and 86% said that culture is fundamental or very
THE FOUNDATION                                                      important to strategy.
• Belief that ethics is everyone’s responsibility
                                                                    An outstanding example of the establishment of a cultural
• Clearly articulated social purpose and core values, arrived at    approach by organisations throughout a sector is that of
  through internal consultation
                                                                    civil aviation safety. The key concepts are an ‘open culture’,
• Commitment to fairness “just” culture and continuous              in which everyone engages constantly by feeding back data,
  improvement                                                       asking questions of themselves and others, and challenging
                                                                    assumptions, and a ‘just culture’ in which people are
PEOPLE AND ETHOS                                                    accountable for the open culture and for the tasks for which
• Leadership committed to all aspects of EBP                        they are responsible, and action will be taken for breaches of
• Employee involvement, i.e. as ethics ambassadors                  trust.
• Collaborative, cross-organisational working, where dissent        The focus has shifted from ‘that person did something
  is encouraged                                                     blameworthy’ to ‘why would any human behave like that in those
                                                                    circumstances so how can we reduce the risk of recurrence?’ It
ALIGNED SYSTEMS AND PROCESSES                                       is critical that blame is removed from the general culture. Both
• Performance management and incentives aligned with                an open and a just culture have to apply consistently throughout
  values                                                            all parts of the system. The outcome of this approach is that
• All other policies, systems and processes supporting doing        commercial air travel is extremely safe.
  the right thing, directly in the business where possible          Conversely, there are many examples where corporate failure
• Cultural measuring and monitoring to enable continuous            can be attributed to the absence of an ethical culture, such as
  improvement and basis for trust                                   Volkswagen and Wells Fargo.

                                                                                             JULY 2019 | SOFHT FOCUS
                                                                                                                                 11
ETHICAL BUSINESS PRACTICE AND REGULATION

                                                                                   About the authors
                                                                                   Christopher Hodges
                                                                                   is Professor of Justice
                                                                                   Systems and a Fellow of
                                                                                   Wolfson College, Oxford;
                                                                                   head of the Swiss Re
                                                                                   Research Programme on
                                                                                   Civil Justice Systems at the
                                                                                   Centre for Socio-Legal Studies, Oxford; and
                                                                                   a Fellow of the European Law Institute.
                                                                                   He is a leading expert in regulatory,
                                                                                   enforcement and dispute resolution systems
WHAT IS ETHICAL BUSINESS REGULATION?                                               and advises many governments and
Ethical Business Regulation (EBR) is a relationship between a business, or         businesses. He is a founding member of the
                                                                                   Executive of the International Network for
a group of businesses, and a regulator, or group of regulators, in which the
                                                                                   Delivery of Regulation (INDR), created at the
business produces evidence of its on-going commitment to EBP and the
                                                                                   request of UK Government, that includes
regulator recognises and encourages that commitment.                               experts from across the globe.
A surprising number of UK regulatory authorities aim to distinguish between        Recent books include Ethical Business
businesses that aim to do the right thing and those whose intent is criminal.      Practice and Regulation (with Ruth
They have amended their enforcement policies and practices, using deterrent        Steinholtz); Law and Corporate Behaviour;
                                                                                   Redress Schemes for Personal Injuries
penalties only on the criminal group rather than on everyone. The regulators
                                                                                   (with Sonia Macleod); Delivering Collective
that are effective are those that have – and use – a ‘front end’ regulatory
                                                                                   Redress: New Technologies (with Stefan
structure, which they use to develop an adult-to-adult ongoing regulatory          Voet); Consumer ADR in Europe (with Iris
relationship with businesses.                                                      Benöhr & Naomi Creutzfeldt), The Costs and
                                                                                   Funding of Litigation (with Stefan Vogenauer
They have changed the regulatory relationship and aim to support businesses
                                                                                   and Magdalena Tulibacka).
that have demonstrated they wish to improve. They retain a wide toolbox
of enforcement powers, and select appropriate tools for use depending on           Ruth Steinholtz’s mission
the behaviour of the organisation and people in question. Firm enforcement         is to make a difference
remains required as a response to deliberate (criminal) wrongdoing. But            in the world by changing
imposing massive fines on banks over a decade from 2008 failed to stop             attitudes and practices
                                                                                   relating to ethics and
corporate wrongdoing and led the Financial Conduct Authority to ask: ‘Why?
                                                                                   compliance. Following
What have we not learned?’
                                                                                   a varied international legal career, she
Elements of EBR can be identified in the approach of a wide range of regulators,   founded AretéWork in 2011. Areté is the
such as pharmaceuticals, medical devices, health and safety, environment,          Greek concept of excellence and virtue ethics
                                                                                   – being the best one can be.
energy, food and the UK’s Primary Authority scheme. The food sector is ripe
for EBP and EBR, as a response to globalisation and chains of digital evidence.    Previously, as General Counsel, Group
                                                                                   Security Coordinator and Head of Ethics at
                                                                                   Borealis AG, Steinholtz developed a values-
REGULATING BY PURPOSE,                                                             based approach to ethics and compliance –
ALIGNED VALUES AND CULTURE                                                         employing ethics ambassadors throughout
Regulating by culture is the next breakthrough. But it is not possible for         the company. Organisations around the
                                                                                   world have since adopted this approach.
regulators to impose or ‘regulate’ the culture of another organisation. Culture
is indeed created within an organisation. This realisation is the essence of the   She is a member of the UNODC E4J panel
EBP and EBR models.                                                                of experts on Ethics & Integrity and is a fully
                                                                                   certified Barrett Values Centre’s Cultural
Organisations should decide if they wish to base their activities on ethical       Transformation Tools (CTT) consultant. She
values, and then work on demonstrating that they do so, building up evidence       co-authored with Professor Christopher
of this over time. Cultural measuring tools such as the Barrett Values Centre’s    Hodges Ethical Business Practice and
                                                                                   Regulation: A Behavioural and Values-Based
Cultural Values Assessment enable leaders to understand and where needed
                                                                                   Approach to Compliance and Enforcement.
transform their cultures and provide the evidence. All their stakeholders –
staff, customers, suppliers, investors, regulators, communities – can then         e: ruth@aretework.com        @ruthsteinholtz
                                                                                   www.aretework.com
evaluate relevant evidence and treat the organisation accordingly.

         SOFHT FOCUS | JULY 2019
 12
All Laboratories
are not the Same

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CE MARKINGS ARE NO GUARANTEE OF SAFETY

  CE markings are no
  guarantee of safety
Contrary to popular belief, not all CE-marked personal                                 surveillance testing, despite carrying
                                                                                       the CE mark. With the two main causes
protective equipment is safe. Andy Johnston discusses                                  of injury within the food and drink
the unseen risks for your business.                                                    sectors being slips, trips and falls and
                                                                                       manual handling, the failings of boots
Although we enjoy the benefits of           effort is still required to ensure the     and gloves could be catastrophic.
working in one of the safest places in      reduction continues. This includes the
the world, with the lowest incident rates   supply of high quality, compliant PPE to
of work-related deaths in the EU, there     the workforce.
                                                                                       “Ensuring that safety
is a gap in the compliance process that
                                            Employers may believe that their people    equipment provided
is putting UK food and drink industry
workers at risk of injury – even though
                                            are fully protected and compliant when     to employees for
                                            they specify or buy PPE. The reality is
they are using CE-marked personal
                                            that some CE-marked PPE is failing,        protection is compliant is
protective equipment (PPE) they believe
will protect them.
                                            putting wearers at high risk of injury     paramount”
                                            and businesses and individuals at risk
CE is a certification mark that indicates   of loss of reputation, fines and even
                                                                                       This industry-wide compliance issue
conformity with health, safety, and         possible imprisonment.
                                                                                       can be down to a number of issues,
environmental protection standards
                                            The evidence is undeniable, particularly   including manufacturers of PPE
for products sold within the European
                                            in the area of a number of CE-marked       swapping materials, safety components
Economic Area.
                                            safety footwear and gloves that are        and changing processes after receiving
While UK food and drink manufacturing       freely available on the UK market.         the initial CE certificate. This results in
has seen significant reductions in          Independent laboratory testing showed      a product appearing on the market that
injuries and occupational ill health over   that around 40% of non-metallic            does not protect the user from the risks
the past 20 years, continued targeted       footwear and 30% of rigger gloves failed   it claims to or may itself be unsafe, as

         SOFHT FOCUS | JULY 2019
 14
CE MARKINGS ARE NO GUARANTEE OF SAFETY

it no longer meets the requirements
of the CE-marking process. Many
safety experts within the UK, including
Arco, believe this is down to a lack of
governance and independent scrutiny
around the CE process.

With around 600,000 workers each
year reporting that they have suffered
an injury at work, and over a quarter
of all manufacturing injuries occurring
in the food and drink sectors, the
consequences of failing to apply due
diligence to PPE purchasing are
enormous. Without a robust process
in place, accidents and injuries could
be life changing and not just for end
users but for the individuals, and the
businesses they work for, who are
involved in specifying and purchasing
the equipment.

As well as the legal implications of not
getting it right, there is also a moral
aspect employers need to bear in
mind, as this can cause reputational       About the author
damage to the organisation as well as
                                           Andy Johnston is head of sector for food
affecting morale among employees.
                                           at Arco, one of the UK’s leading products
As the overall injury rate in food
                                           and services safety companies with a
manufacturing is higher than the           core purpose of keeping people safe
average for manufacturing generally,       at work. He has worked for the safety
ensuring that safety equipment provided    company for over 30 years, developing
to employees for protection is compliant   his knowledge and experience within
is paramount.                              the food and drink industry. Managing
If you are concerned about the risks       the food sector team with a range
of failing CE-marked PPE leaving           of distinguished clients, Andy’s
you and your business exposed, visit       understanding of safety requirements
knowyourrisk.co.uk to watch a short        within the sector is extensive.
film about this important issue and        Through its dedicated in-house experts, Arco helps to shape the
get a clearer understanding of the risk    safety world in order to ensure UK workers go home safe every night.
and what you need to know to ensure        It distributes a world-class range of over 170,000 quality assured,
compliance.                                branded and own-brand products, including PPE, workwear, safety
                                           footwear, gloves, workplace safety and hygiene products. It also
Those of us with a responsibility
                                           provides professional services encompassing training, consultancy
to help shape the safety agenda to
                                           and site services.
make the workplace safer for all are
keen to promote the UK as one of the       Arco is committed to providing safety equipment that is genuine and
safest places in the world to work.        compliant with relevant standards and regulations. To do this, it has a
Therefore, it’s important to realise       five-step product assurance process and is the only safety distributor
that CE markings do not guarantee          with an independently accredited testing laboratory. Additionally, it is
compliance and as an employer or           a member of the British Safety Industry Federation Registered Safety
health and safety manager, you have        Suppliers Scheme.
an obligation to ensure that whatever
you buy is compliant.

                                                                                  JULY 2019 | SOFHT FOCUS
                                                                                                                      15
TRANSPARENT SUPPLY CHAINS – IS IT ALL ABOUT BLOCKCHAIN?

Transparent supply chains –
is it all about blockchain?
David Meller, Responsible Sourcing Director at NSF                                  However, the world moves on. Brands
                                                                                    are working to many more imperatives
International, looks at the drivers and trends in the                               – including environmental, social and
development of transparent and ethical supply chains in                             ethical concerns.

the food industry and the role that blockchain can play.                            Animal welfare has been high on the
                                                                                    list of issues for a long time and recent
There is increasing pressure on brands   This is how British Retail Consortium      media coverage has put the spotlight on
to become more transparent about all     (BRC) Issue 7 came into existence,         waste and climate change. Government
aspects of their operations, and the     requiring suppliers to carry out           and industry initiatives are placing ever-
focus on their supply chains continues   vulnerability and threat assessments
                                                                                    increasing targets and demands on the
to gather momentum. The drive to         on their products and ingredients. The
                                                                                    supply chain. As importantly, there has
evidence-responsible sourcing has at     original concept was based on the need
                                                                                    been a shift from the relatively simple
its root the fraud and food poisoning    for food safety and brand protection.
scandals that caused regulators and      This was very much about information       need for compliance to a need to create
industry bodies to react with demands    that could help brands keep customers      and maintain consumer trust in a much
for new, higher standards of due         safe and demonstrate, in the event of an   wider sense. There has been a blurring
diligence in the areas of provenance     incident, that all reasonable steps had    of the drivers, in which consumer
and authenticity.                        been taken to avoid such an occurrence.    sentiment leads the way. Why?

        SOFHT FOCUS | JULY 2019
 16
TRANSPARENT SUPPLY CHAINS – IS IT ALL ABOUT BLOCKCHAIN?

Consumer trust
There is no doubt that the food
industry lost a significant amount of
consumer trust through the scandals
in horsemeat, Salmonella in eggs and
numerous others. The industry has
taken on board the need both to act and
to be seen as acting to regain consumer
trust. Brands that have taken a clear
position on responsible sourcing of
their product and ingredients have been
rewarded by stronger brand equity and
customer loyalty.

Today, the main driver toward
transparency in supply chains is
consumer trust and consumers are
starting to dictate how trust can
be earned and good faith can be
demonstrated by brands.

The millennials have come of age. This
huge consumer group, aged between 20
and 40, now numbers about 1.8bn people      “Millennials have much greater            In processed foods like ready meals the
worldwide with an estimated spending                                                  sheer multiplicity of ingredients makes
power of several trillion dollars. Unlike   concern over product safety and
                                                                                      tracking and rendering transparent
the older, more consumerist population,     younger Americans are generally           the details a nigh on impossible task.
millennials are far more concerned
                                            more trusting of claims made on           Moreover, corporate systems are
about the world in which we live and the
                                                                                      rarely seamless and communications
future for themselves and their children.   social media”                             between suppliers in the chain may not
They have a more responsible attitude
                                            Expectations of information are now       even be digitised. Transparency is not a
to the environment and ethical and
                                            very high and just as consumers might     simple issue.
social issues, like meat-eating,
                                            expect to see the view from their hotel
biodiversity and plastic waste. To a                                                  Nevertheless, some brands have
                                            balcony before they book their holiday
large degree this is owing to the hugely                                              successfully embraced a culture
                                            or want to read reviews from other
increased access they have to media                                                   of openness, and transparency is
                                            customers before going to a restaurant,
information about these topics, so they
                                            they expect information just as readily   increasingly being seen as an important
are better informed than the majority
                                            about their food and its composition,     marketing tool to engage consumers
of previous generations. Technology
                                            source and production. Surveys have       and share values with a like-minded
has informed this group and it has also
empowered them.                             shown that millennials are willing        and loyal consumer base. They show
                                            to pay more for brands that support       how a culture that embraces ‘doing
An online survey conducted for NSF          causes they care about.                   the right thing’ can demonstrate
International in February 2019 found
                                                                                      due diligence and compliance, while
that millennials have much greater
                                                                                      simultaneously creating a competitive
concern over product safety and younger
Americans are generally more trusting
                                            Culture change                            advantage.
of claims made on social media. It also     The culture change for the food
                                                                                      In this respect, blockchain is becoming
discovered that 74% of millennials are      industry is immense. Not only is there
                                                                                      an enabler because of its ability to
concerned about potentially harmful         a fear of letting go of competitively
                                                                                      lock down data at every step of the
food and other consumer products. By        sensitive information and historically
                                                                                      production process and deliver the
comparison, only 64% of Gen X and 53%       a culture of tending to keep the lid on
of baby boomers are concerned about         issues rather than sharing them for       information, formatted in an accessible
the safety of these products. Nearly half   the good of all, the food supply chain    way, to the consumer as they shop via a
of millennials (48%) and half of Gen Xers   is fast moving, with regular changes in   simple quick response (QR) code on the
(51%) trust claims on social media.”        suppliers and ingredients.                product packaging.

                                                                                      JULY 2019 | SOFHT FOCUS
                                                                                                                          17
TRANSPARENT SUPPLY CHAINS – IS IT ALL ABOUT BLOCKCHAIN?

New blockchain                                As businesses are discovering, the very     Transparency in all these areas will
                                              complexity of supply chains mitigates       grow, especially as more brands
service                                       the successful implementation of            recognise that the flip side of an issue
At NSF International, we have taken our       blockchain. If tracking products with       that used to be about compliance
first steps into the world of blockchain.     multiple ingredients is complex, how        and due diligence is also a marketing
In March of this year we launched our         do we then add other factors like           opportunity. However, in many ways the
NSF Verify blockchain service. Initially,     labour issues and carbon production?        issues remain the same as they have
it will focus on bringing the consumer        These are areas in which we are only        always been: people are the main risk in
the story behind the beef they see on         just starting to find effective ways to     any supply chain. It is their behaviours
the supermarket shelf. It will enable         measure and to combat misuse?
                                                                                          that create mistakes, fraudulent activity,
farmers for the first time to be part
                                              So, we believe that blockchain will         contamination and malpractice.
of the marketing of their own produce
                                              be a hugely important tool and will
to consumer decision-makers via a                                                         The best way to avoid these problems
                                              undoubtedly have its place in creating
scannable QR code on the pack.                                                            is the development of a healthy
                                              supply chain transparency. But it cannot
                                                                                          culture that values people, encourages
NSF is now kicking off the pilot with two     be the panacea for all ills.
                                                                                          empowerment and openness, and
major retailers and has already learnt
a lot, with undoubtedly a huge amount                                                     drives the right behaviours. Long-
                                                                                          term, trusted supplier relationships,
more to learn as the pilots progress.
Based on a three-factor authentication
                                              Modern slavery                              which are beneficial to all parties, lay
system that combines an individual            Modern slavery is one intractable           the foundations for good behaviours
animal’s DNA data, geo-fencing of             problem that many brands are                and ethical practices – more than any
the farm and farmer ID, together with         grappling with. Although the Modern         blockchain system or certification
digitised records of the animal’s life        Slavery Act came into force in 2015,        programme can do.
events and the processing steps post          it appears that some companies have
                                                                                          The good news in the long term is
slaughter, it provides traceability that is   still not published their modern slavery
                                                                                          that the right culture, where doing
unprecedented.                                policy as they are legally required to
                                                                                          the right thing is valued, can be good
                                              do, let alone put in place measures to
The benefits of blockchain are many, but                                                  for the bottom line. At its simplest
                                              ensure that the labour used in their
at NSF we do not believe that it is by any                                                there may be less waste and more
                                              supply chain is legally sourced and
means the only solution for traceability.                                                 efficient production, and at best the
                                              responsibly managed.
For a start we can never guarantee that                                                   brand reputation and customer loyalty
a system is fraud-proof forever – history     New tools are however emerging to
                                                                                          that accompany brands that are seen
has shown that fraudsters will always         help businesses, such as Clearview
                                                                                          to be doing the right thing are a vital
get ahead of any system at some point.        certification, which enables labour
                                                                                          component of success.
Constant vigilance and governance             providers to demonstrate that they
are also required in the complex eco-         operate responsibly, legally and            I predict we will be seeing a lot more
systems of participants and input             ethically in their sourcing and supply of   focus on how to create effective and
sources created by blockchain systems.        workers.                                    positive cultures in 2019.

   About the author
   David Meller is a graduate in Food Technology from Reading University.

   As Responsible Sourcing Director at NSF, David leads NSF’s activity around responsible
   sourcing and ethical trade in food and non-food, including aspects such as responsible
   recruitment, modern slavery, social compliance and animal welfare.

   Prior to joining NSF, David was the Director of Product Integrity at the Fairtrade Foundation
   overseeing the licensing of the Fairtrade Mark. He spent 20 years at Sainsbury’s in a number of
   technical and commercial roles and was latterly responsible for sustainable sourcing.

          SOFHT FOCUS | APRIL 2019
  18
SOFHT 40th Annual
                                                      Lunch & Awards 2019
            Thursday 14th November 2019 • The Brewery, 52 Chiswell St, London EC1Y 4SD

POINTING THE FINGER,                                                                                                                       Programme
DISHING THE DIRT                                                                                                                           10.00 Welcome and Coffee
                                                                                                                                           10.45 Introduction by Matt Allwright
The Society of Food Hygiene and                                                                                                            11.00 Interview with Felicity Wingrove &
                                                                                                                                                 Matt Allwright
Technology presents television
                                                                                                                                           11.45 Open forum
presenter and journalist Matt Allwright.
                                                                                                                                           12.00 Networking Reception
Does naming and shaming still work? Matt Allwright                                                                                         13.00 40th Annual Lunch and
talks about the difficulty in bringing individuals and                                                                                           presentation of the SOFHT Awards
organisations to account in an age of diminishing responsibility.
                                                                                                                                           16.30 Close
It sometimes seems as though respect for established institutions is crumbling. Funding
for detection and enforcement has been slashed. The result of this appears to be that                                                             SOFHT
what we call ‘The Authorities’ perhaps no longer bear the authority they used to, and
tolerance and attention span for being preached at is at an all time low. It’s also an age
of moral equivalence – where those accused can easily counter with the failings of the
                                                                                                                                             Awards
accuser, whether it’s the BBC, central and local government or the police.
                                                                                                                                             Hosted by
                                                                                                                                             Matt Allwright    2019
So, in a world where no-one wants to be told what to do, how do we perform our
roles in sharing information and enforcing rules which can protect people and possibly
even save their lives? Matt shares some thoughts from his own unique perspective and
twenty years of experience of bringing rogues to book.

Matt Allwright is a prime-time television presenter and journalist with integrity and his
own distinctive style. Full of originality and ideas, he brings something fresh to every                                                     After lunch entertainment by Tenors Unlimited
project he works on.

His trademark programme is BBC1 hit Rogue Traders, but his abilities stretch beyond
the consumer journalism where he’s made his name. More recently, he has been                                                               Booking
making programmes on the subject of Britain’s housing crisis. He’s also been a                                                             Table of 10 (Members)
mainstay presenter and reporter on the One Show for over a decade.                                                                         £2115 / Individual £265 (all + VAT)

                                                                                                                                           Table of 10 (Non-Members)
This year’s Annual Lunch
                                                                 We are proud to be supporting
                                                                                                                                           £2400 / Individual £305 (all + VAT)
is kindly sponsored by
Pal International                                                Cystic Fibrosis Care.
                                                                                                                                           To book a place contact Su Werran,
                                                                 Registered charity in England
                                                                                                                                           Operations Director 01827 872500
Drinks are kindly                                                and Wales No. 1162445
sponsored by Lloyds                                                                                                                        or email: suwerran@sofht.co.uk
Register

Administration Details: All bookings will be acknowledged and tickets will be sent on receipt of payment. Cancellations/returns must be
notified prior to 14th October 2019 by letter, fax or email and will be subject to an administration charge of £30 + vat per person. Payments
can be made by BACS or credit card. There will be a £1 administration charge for payments via cheque. The organisers reserve the right
to modify the sessions without prior notice. Data Protection - The personal information provided by you, will be held on a database. The
Society sends out promotional material about its activities. Please inform the Society’s office if you do not wish to receive this information.
©The Society of Food Hygiene and Technology
FSA ADVISORS TO REVIEW NEW EVIDENCE ON VP AND MAP FOODS

      FSA advisors
      to review new
      evidence on VP
      and MAP foods
The Food Standards Agency (FSA) is unlikely to change its much                          In her article, Goodburn, who is also
                                                                                        director of the Chilled Foods Association,
criticised 2017 guidance on vacuum packed (VP) and modified                             noted that the revised guidance could
atmosphere packaged (MAP) food until a specialist advisory                              compromise food safety and the
                                                                                        viability of huge sectors of the UK food
group of microbiologists reports back in 2020 after reviewing
                                                                                        industry including fresh meat, which is
new evidence. Rick Pendrous reports.                                                    now explicitly within scope for the first
                                                                                        time. While there is a long history of
A specialist committee of experts on      The decision made by the ACMSF to set         safe use of VP/MAP chilled foods under
microbiology, which advises the Food      up the WG at its meeting in London on         existing controls, Goodburn said the
Standards Agency (FSA), has set up a      27 June follows complaints made by            2017 guidance potentially undermines
                                          representatives of the food processing        the viability of the fresh meat sector
working group (WG) to evaluate new
                                          industry that the 2017 revised guidance       in particular – without enhancing food
evidence following widespread concern
                                          from the FSA places UK manufacturers          safety with respect to non-proteolytic
about the FSA’s revised guidance on
                                          at a distinct disadvantage compared with      Clostridium botulinum.
vacuum packed (VP) and modified
                                          their overseas competitors.                   She also claimed there is no other
atmosphere packaged (MAP) foods
issued in 2017.                           It also comes after an article published      equivalent guidance internationally
                                          in the April issue of SOFHT Focus by          and the guidance could be used as a
But, since the WG will not report back                                                  technical barrier to trade post-EU exit,
                                          food safety and microbiology expert
to the Advisory Committee on the                                                        while increasing waste and cost – but
                                          Kaarin Goodburn, titled ‘Industry’s
Microbiological Safety of Food (ACMSF)                                                  without a clear scientific basis.
                                          beef with vacuum packing guidance’
which set it up until early 2020, the     criticised the guidance. It highlighted the   At its meeting in June, ACMSF agreed to
FSA is unlikely to change the guidance    “deep concerns” of the industry about         establish a WG to look into new evidence
it currently provides to environmental    the revised FSA guidance. Establishment       relating to the development of the
health officers (EHOs), it has emerged.   of the WG also follows the publication of     pathogen non-proteolytic Clostridium
And that is a problem, since food         new scientific research that supports         botulinum in VP and MAP foods. The
businesses argue the guidance is          the safety of existing UK food safety         plan is to gather evidence and report
seriously flawed.                         practices with VP/MAP chilled foods.          back to the ACMSF early in 2020.

         SOFHT FOCUS | JULY 2019
 20
FSA ADVISORS TO REVIEW NEW EVIDENCE ON VP AND MAP FOODS

                                                                                                 “The estimation of the
                                                                                                 level of protection and
                                                                                              the results from the new
                                                                                           challenge test experiment
                                                                                          both support a shelf-life of
                                                                                                  greater than 10 days”

                                                                                         It then went on to state: “The estimation
                                                                                         of the level of protection and the results
                                                                                         from the new challenge test experiment
                                                                                         both support a shelf-life of greater than
                                                                                         10 days for fresh chilled beef, lamb
The current FSA guidelines in this area      used a risk assessment approach and
suggest that, unless suitable grounds for                                                and pork held at 3°C to 8°C, and also
                                             carried out a challenge test experiment
extension are proven, the shelf-life of VP                                               support currently-applied UK shelf
                                             to establish whether a shelf-life of
and MAP chilled foods, including fresh                                                   lives combined with current production
                                             greater than 10 days can be applied to
meat, held at temperatures from 3 to                                                     standards.
                                             fresh chilled meat.
8°C is a maximum of 10 days. Industry                                                    “The ability not to be constrained by a
has regularly challenged the basis for
                                             New risk assessment                         10-day shelf-life, as indicated in present
this and claimed that for many of these                                                  FSA (2017) guidelines, and the freedom
products, a longer shelf-life would be in
                                             research
                                                                                         to adopt a shelf-life greater than 10
place in other countries. Other aspects of   In a final report on the study published    days at 3°C to 8°C for fresh chilled
the guidelines have also been challenged.    and funded by Meat and Livestock            beef, lamb and pork is of significant
                                             Australia Ltd and prepared by QIB           economic/social/sustainability benefits
At an ACMSF’s meeting in May 2018,
                                             Extra’s Professor Mike Peck presented       to producers/processors/retailers. Such
the secretariat was asked to look at
                                             to the ACMSF meeting, it stated in the      freedom removes a technical barrier to
what information had been published
                                             executive summary: “A search of the         trade. There may also be environmental/
or made available over the past 10
                                             literature failed to uncover any cases of   consumer benefits through lower food
years which might be relevant to the
                                             botulism associated with fresh chilled      wastage.”
issue of Clostridium botulinum and VP/
                                             VP or MAP meat.”
MAP foods. This was summarised in a
paper presented to the committee and         Using a risk assessment approach,           ACMSF working group
discussed at its meeting in October 2018.    it was established that the current
                                                                                         At its meeting on 27 June, the ACMSF
Members identified several aspects           industry practice provides a high level
                                                                                         agreed that it was now appropriate to
which would need to be considered if         of protection with respect to non-
                                                                                         establish a short-life WG to review the
a WG was established and noted that          proteolytic Clostridium botulinum ,
                                                                                         evidence on key aspects relating to
some industry-funded experimental            estimated as >10.8 safety units
                                                                                         the risk of non-proteolytic Clostridium
work was still underway at that time.        (decimal number of products (i.e.
                                                                                         botulinum and VP/MAP foods. The
                                             >1010.8) marketed per number causing
The industry-funded risk assessment                                                      meeting agreed the WG’s draft terms of
                                             botulism).
study undertaken by QIB Extra Ltd in                                                     reference, commented on its proposed
relation to fresh meat and referred to       Importantly, it added: “There is no         membership, the timescale envisaged
in Goodburn’s article in SOFHT Focus         evidence that currently-applied UK shelf    and structure of the meetings and
in April has now been completed and          lives combined with current production      expected outputs. It was also agreed
the FSA has been asked to revisit            standards are unsafe. If changes are        that, where appropriate, other risk-
the guidelines in relation to this new       made to industry practice, then these       related evidence relevant to this topic
evidence. This QIB Extra project has         may affect the level of protection.”        would also be considered.

                                                                                          JULY 2019 | SOFHT FOCUS
                                                                                                                              21
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