Pollution in the food chain or in processing can disrupt the most efficient of operations - whether this is 'pollution' by bacteria, via a virus (foot and mouth/bird flu), chemical (dioxin contamination) or radiation from a nuclear accident following an earthquake as most recently occurred in Japan. These crises may have domestic, European or global repercussions for production, customers and supply chains.
Different levels of control apply to the safety of food and feed depending on the type of pollution or contamination. Food Business Operators must have appropriate internal controls in place as set out under the General Food Regulation 178/2002, and they must comply with food and feed hygiene and quality regulations throughout the various stages of production and supply. Domestic UK incidents may result in an Emergency Control Order and EU/global measures may require the suspension of the marketing or use of the feed or food in question, or such use and marketing may be subject to special conditions or another appropriate interim measure. Specific EU emergency measures must be proportionate and weigh up the requirements of the so-called Precautionary Principle.
The earthquake in Japan in March 2011 and the subsequent accident at the Fukushima Daiichi nuclear power plant resulted in EU controls on imports of food and feed from certain regions of Japan, where production could be affected by radiation. This has resulted in special import measures being imposed, as set out in Regulation 297/2011, which are reviewed every month.
Only 0.1% of food imports received by the UK come from Japan. Currently, there is no evidence of risk for the EU consumer by increased radiation levels in food and feed products imported from Japan.
The German dioxin contamination incident that occurred in January 2011 caused a much greater impact on supply chains. However, the efficient action by the German authorities resulted in the EU concluding there was no risk of potentially contaminated food or feed being placed on the EU market or being distributed to third countries after the incident was notified. In the UK, this incident resulted in the voluntary removal by some retailers of the small number of products still in date that may have been processed with potentially contaminated egg, despite the UK Food Standards Agency concluding that the potential in these cases was not significant enough to breach the food safety requirements. Therefore, consumer confidence as well as regulatory standards should be considered as a possible benchmark for a voluntary withdrawal of food or feed in a supply chain.
Management of a Food Contamination Risk
Companies should consider the following precautionary and planning measures:
- Maintain a detailed and up-to-date crisis management plan, listing key decision makers, experts and responsibilities. This should be regularly reviewed/tested and any recommendations implemented.
- The crisis management plan should be linked to a business continuity plan. Are there alternative supply locations for key ingredients? Alternative production facilities?
- Check product recall insurance policies and terms.
- Check contractual terms of supply and distribution agreements.
- Health and safety legislation obliges employers to provide a safe as reasonably practicable environment for staff and visitors; suitable risk assessments for employees and other persons affected by the work activities should be carried out.
- Keep abreast of new developments - legal, scientific and medical that may affect your products.