The UK food regulator has published a guidance to help manufacturers improve the safety of their products and deal with contamination incidents when these occur.
EU and domestic regulations and consumer demands are forcing manufacturers to scrutinise their food safety procedures.
While breaches in hygiene can cost a company huge sums in recalls, a loss of trade and potential fines, implementing robust preventative measures and procedures to deal with incidents are also highly expensive.
A Food Standards Agency's (FSA) taskforce, which published the guidance, said the contents were not legally binding and did not replace existing regulatory obligations. The guidance aims to summarise current best practice that producers could use to create their own plans.
The taskforce, set up by the regulator to reduce the risk of future contamination incidents, includes representatives across the food industry including enforcement officers, consumer and industry organisations such as the Food and Drink Federation (FDF), as well as independent members.
Julian Hunt, FDF's director of communications, said the development of the guidance is fully supported by FDF.
"We worked closely and constructively with FSA and other key stakeholders within the food incidents taskforce on its creation," he said. "Sharing experience and promoting good practice across the industry should help to minimise the number of incidents and help deal with them effectively if they occur."
Food manufacturers are advised to consider the taskforce checklist of controls concerning products, premises and personnel. The guidance includes procedures for monitoring supplier competence, quarantine requirements, and foreign body control.
Premises should be designed to enable good hygiene and there should be maintenance schedules in place, as well as waste management procedures, among others.
Appropriate training should be provided to medically screened workers with the hygiene procedures they perform documented.
The guidance said that these measures should be in place before a manufacturer implements a hazard analysis and critical control points (HACCP), as this will enable the system to focus on significant product and process food safety hazards that requires specific controls.
The guidance gives step by step instructions on how a manufacturer can develop a HACCP system tailored to their specific operations.
Good practice guides are constantly being created across all sectors to support the application of new EC food safety regulations.
Several new guides are expected to be published, and manufacturers following recognised guides can use this activity in support during assessment of regulation compliance.
The guidance suggests traceability procedures are put in place as they improve the effectiveness of recalls and reduce the risk of fraud.
A section on industry incident response represents the best practice manufacturers can follow in the event of a product withdrawal or recall. Suggested procedures prioritise consumer safety in the event of initial procedures running into problems.
Articles 19 and 20 of EC Regulation 178/2002 requires the withdrawal or recall of unsafe food, and that the relevant authorities are notified.
An action plan checklist that manufacturers can adopt to meet incident challenges is provided in the guidance. Creating a policy and a dedicated team to make decisions are some of the suggestions outlined. The key steps a manufacturer should incorporate into an effective incident management process are risk assessment, risk management, implementation of management decisions, and risk communication.
The methodology of how the FSA approach incidents is also detailed in the guidance. This prepares manufacturers in what response they can expect from the regulator if it becomes involved in an incident. Although the procedure the FSA is much the same as the action plan they suggest manufacturers develop, the execution and requirements are different.
The guidance also provides manufacturers with information on what they can expect in enforcement authorities become involved. This only occurs once the FSA or food authority becomes aware that food or labelling fails to meet prescribed standards.
Food authorities dealing with food incidents must act in accordance with the statutory Food Law Code of Practice made under Section 40 of the Food Safety Act 1990. Food Authorities are required to have regard to the Code when discharging their duties.
Scale will largely determine the level of action taken by an enforcement authority, which will assess the situation on bases published in the guidance including, the type of injury that a contaminant may cause, the ability and willingness of a distributor or producer to implement an effective recall or withdrawal.
The code sets out what action can be taken, and these, which include prosecution, are listed in the guidance.
Further guidance is expected to publish in due course, which will further help manufacturers to implement food safety plans.