Part 4: Safety, assurance & integrity — inspection, sampling & testing capacity & capability

I spoke to three aspects of food safety, assurance and integrity, the first being inspection, sampling and testing capacity and capability.

Are we in crisis when the resources and people needed to carry out inspection of food premises and the sampling and testing of food stuffs has been so reduced that it’s hardly happening at all?

The large supermarket retailers have the resource to carry out rigorous controls, so we can count on their produce to be safe, and it is what it says on the label. If a supplier to one of the large retailers slips up, or or a procedure is carried out badly, they’re on it immediately.

David Roos, then Aldi’s Technical Director described what happened in this interview with Nick Booth a few months ago:

Although supermarket produce conforms to the high food standards and regulations, you can’t be sure that eating out does, whether in a Michelin starred restaurant or a dodgy kebab on a street corner. The safety, assurance and integrity of that part of the system, which provides just under half of what we eat, isn’t transparent.

There wasn’t time to go into much detail about the dearth of inspection, sampling and testing capacity & capability in the UK. For that, see (1).

I did, however, mention the relaxation in food regs with the first Covid lockdown, without review or when they would be reimposed (2), that inspection and sampling, was worryingly low before Covid (3), that in nine seven years to 2019, i.e. pre-Covid, there had been a whopping 140% increase in food poisoning reports (4), that there are only a few food testing laboratories in the UK (5).

What I didn’t mention is the impact of Brexit already n food safety, assurance and integrity; for example, it is not possible to test perishable fresh produce quickly enough within the UK given our limited laboratory capacity and, since the ending of the transition period, non-tariff barriers mean samples requiring certain tests cannot be sent to EU27 labs. (6)

Nor did I mention the planned changes in food regulation as a result of post-Brexit trade deals.

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Arguably, we’re in one of the worst of all worlds, high food regulation and standards, but zero enforcement. Consumers therefore assume what they’re eating is safe, is what it says it is . . . but it might quite well not be. Moreover, such a situation is an invitation for the unscrupulous to cut corners and the outright criminal to exploit us all, sometimes with lethal effect.

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Given all of this, are we in crisis? If we not, we soon will be.

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(1) This blogpost, one of a series assessing the National Food strategy, Criterion 2: What are their recommendations about ensuring food safety, assurance and integrity? contains info, and access to relevant evidence, regarding food safety, assurance and integrity.
(Remarkably, there is no mention of it in the strategy itself, nor any rationale for its omission.)

I add this point here: Are we in crisis when none of the criteria we used to assess the National Food Strategy was met?
see this blogpost: National Food Strategy: None of our criteria was met. Does this matter?

(2) As we pointed out in our submissions to the Commons EFRA Select Committee on Covid and food supply in May 2020 and January 2021, the relaxation of regulations at the beginning of the pandemic needed to be subject to review and time-limited. For example, the inclusion of virtual or self-reported inspections inevitably provides opportunities for the unscrupulous and the criminal or, as a senior supermarket executive said to us, an ‘invitation’ to them.

(3) There has been decline since the 2014 Elliott Review (set up after ‘horsegate’) in inspection sampling and enforcement as well as testing. For example, in December 2014, Birmingham had 15 FTE EHOs covering food standards, inspections, hygiene and food crime; see pp6-9 of this 2015 update on food crime.
By 2019, Birmingham City Council declared it was ‘unable to fulfil food safety function without external help‘ (which wasn’t forthcoming).
The 2019-20 Local Authority Enforcement Monitoring System (LEAMS) data indicate the city had only three FTE EHOs working on food-related matters in 2019-20 (i.e. pre-pandemic). Worryingly, the highest number reported in any authority was 8, the median being only 1.5 FTE Environmental Health Officers (EHOs).
In December 2021, the FSA’s National Food Crime Unit (NFCU, set up in 2015) reported that food fraud cost businesses £11.6bn per year, reported in this article in the Food Manufacture. (Notice in an eafrlier paragraph that the NFCU was ‘celebrating its first successful sentencing of a food fraudster’ [my italics].

(4) The 2020 FSA study estimate there are currently about 2.4 million cases a year compared to approximately one million in 2013.
he 2013 figures state that, of the one million cases, 20K people were hospitalised and 500 died, stating also there were 10 million cases of infectious intestinal diseases. When we researched the 2013 figures (published in 2014) for our Response to the draft London Food Strategy in 2018, the data was no longer on the FSA website, though it was on the Leigh Day site, and still is here.
note: It is concerning that data that was once easily accessible is no longer available.The hospitalisation data for 2018 (upon which the FSA based their 2020 study) estimate between 16,439 and 26,116 cases of hospitalisations, substantially lower than would be anticipated from the 2013 figures. They do not provide any mortality figures. They refer to the 2013 figures for infectious intestinal diseases without comment.

(5) When the Elliott Review was published in 2014, there were only six local authority Public Analyst laboratories in England, today there are three — in Hampshire, Kent and Lancashire. There are four public laboratories in Scotland (Aberdeen, Dundee, Edinburgh and Glasgow), one on the Isle of Man, one on Guernsey, none in Northern Ireland, three in Ireland (Cork, Dublin and Galway).
Two commercial companies run laboratories in the UK: Eurofins, global company with its HQ in Luxembourg, and Minton Treharne & Davies, a privately-owned group of companies with its HQ in Cardiff.

see: http://www.publicanalyst.com/about_us/the_laboratories/

(6) The range of Brexit-related food issues, including safety, assurance and integrity can be gleaned from these The Grocer articles, and the number of food issues listed in this #BrexitReality twitter thread from @DanielKelemen.
note: The National Food Strategy has only two mentions of Brexit: On page 148 Recommendation 3 and in relation to qualifications in the light of post-Brexit skills shortages in hospitality, and on page 281 in the Glossary: Following Brexit, the UK will no longer participate in the EU’s Common Agricultural Policy (CAP).

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Previous blogposts in this series about my Lunar Society presentation Food security: Is the UK in crisis?

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This  is the fourth blogpost in the Lunar Society series, others all listed in this link: Food security: Is the UK already in crisis?

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