House of Commons - Agriculture

Select Committee on Agriculture Fourth Report

II. THE FOOD SAFETY PROBLEM

The food chain

52. The length of the food chain, from the farm (including its inputs) to the dinner plate in the domestic household, is well understood and attested. Changing consumer preferences, such as demand for convenience foods and chilled foods, have lengthened the traditional food chain and, arguably, introduced new food safety hazards or risk points[141] (though this was disputed by the Chilled Food Association[142]). The food chain is also very complex - perhaps it could more accurately be described as a complex of interlinked chains. At all stages of the chain there is potential for contamination or cross-contamination of food, and scope for the prevention of contamination, reducing or retarding the spread of pathogens, and, at certain points, eliminating them. Mr Colin Maclean, Director General of the Meat and Livestock Commission, encapsulated the issue in his description of the food chain: "to cause a problem of food poisoning three things basically need to happen: you need a source of the microbe that will cause the problem; you need to multiply it normally to a level at which the dose is right to infect you; and, thirdly, you need to fail to kill it"[143].

53. If the metaphor of the food chain has become a commonplace (together with the associated clichés "farm to fork" and "plough to plate"), so too has the observation that pressure must be applied at all points of the chain to improve food safety. One of the major benefits of the establishment of a Food Standards Agency should be its ability to survey the entire length of the chain and identify the critical points where intervention will have the most effect. We asked several witnesses where the greatest problems existed in the food chain, and received a variety of answers: Dr Cunningham referred to butchers' shops, abattoirs and the home[144]. Mr Richard Carden of MAFF thought that the Government needed to pay more attention to farming practices[145], as did the written evidence from the ACMSF, which said that a "major factor" in the increase in food poisoning notifications was "the extent to which output from the agriculture sector too often contains food poisoning pathogens"[146]. Both the Food and Drink Federation and the Chilled Food Association claimed that their members' food hygiene practices were fully effective, and that they did not introduce pathogens into produce but attempted to deal with their potential presence in their raw materials as well as the "knock-on effect of poor hygiene in catering practice"[147]. The Chilled Food Association called for the application of HACCP principles to the agricultural and farming sector[148].

54. It is probably, ultimately, a fruitless exercise to attempt to apportion responsibility and blame precisely through the various stages of the food chain. However, the BSE tragedy illustrates the importance of preventing contamination at the earliest point in the food chain, and the unpredictable consequences for the rest of the food chain of compromising safety at the early stages. The nature of activities, and the extent of control which can be exerted over pathogenic micro-organisms, is very different throughout the chain. The environment of livestock production on a farm cannot be compared to that of a food processing facility. Likewise, regulatory oversight differs considerably, from the close scrutiny of slaughterhouse hygiene by MHS inspectors, to occasional inspections of caterers and food retailers by EHOs. The Food Standards Agency will need to secure hygiene improvements throughout the food chain by a variety of methods, including a strategic review of the different sectors in the food chain to identify research priorities with clear targets and objectives to bring about the desired improvements in pathogen reduction and control. At the same time, it must not shrink from re-appraising the hygiene control strategies which are already in place when it begins its operations. The Agency must come to its own judgements about the hierarchy of risk within the food chain and may choose to adapt the existing regulatory framework to reflect that risk, balancing the need for regulation against producers' legal responsibilities to exercise "due diligence", under the Food Safety Act, in ensuring the safety of their produce and consumers' reasonable obligations. The Agency should also commission research on the practicability and desirability of simplifying and shortening the food chain with the aim of reducing risk.

55. One encouraging feature of the food chain, in relation to microbiological contamination of meat at least, is that it is stronger than its weakest link. Thorough cooking before consumption destroys all pathogenic micro-organisms. Full observance of basic and well-established hygiene rules by caterers and domestic consumers would slash the incidence of food poisoning in this country. However, particularly bearing in mind the fact that many food products are eaten raw or purchased already cooked, the onus to prevent incidents of food poisoning must not be placed solely upon the consumer. As the Chairman of the ACMSF has said: "ordinary household and small caterer hygiene cannot be expected to deal on all occasions with the unacceptable incidence of food pathogens found in the output of animal production and spread further in slaughter and primary butchery of carcasses"[149].

HACCP

56. In recognition of the wide variety of food processing and handling practices throughout the food chain, increasing emphasis is being placed, in regulation, on establishing and encouraging the implementation of general hygienic procedures, rather than prescribing precise procedures for each type of foodstuff and each type of food business. The EU is undertaking a consolidation and simplification of its product-specific "vertical" hygiene legislation. The Government told us that "it is intended that the approach to food safety controls based on hazard analysis principles will be extended across the board, but prescriptive requirements will be retained where necessary to address risks specific to individual product types or sectors"[150].

57. The embodiment of this approach is the Hazard Analysis Critical Control Points (HACCP) methodology. HACCP consists of a seven-step approach to identify potential microbiological hazards and Critical Control Points (CCPs) where operational failures might create or fail to eliminate hazards. By establishing procedures to control and monitor CCPs, and to enable corrective action to be taken when needed, the HACCP philosophy imbues the businesses which adopt it with an explicit consciousness of potential risks and procedures which can reduce or eliminate those risks. HACCP has been formally introduced in the UK by the Food Safety (General Food Hygiene) Regulations 1995, which implement the EU's "horizontal" Directive 93/43/EEC on the hygiene of foodstuffs. This directive applies to food caterers and retailers, and manufacturers and processors of non-animal products (animal products are covered by vertical, product-specific legislation)[151]. However, the legislation only requires the implementation of the first five steps in the HACCP approach: it does not require verification to confirm that HACCP is working properly, or documentation and records, although the great majority of businesses applying HACCP will observe these practices.

58. Devised by NASA in the early 1970s because, in Professor Pennington's graphic phrase, of "the horrible thought that diarrhoea in zero gravity would be a bad thing"[152], HACCP has become the internationally-recognized standard for achieving the highest possible levels of microbiological safety of food throughout the food chain. It is enthusiastically supported by scientists and the food industry alike[153]. Miss Kaarin Goodburn, Secretary General of the Chilled Food Association, said "We have HACCP throughout, it is not like an optional extra, it is the core"[154]. The Joint Hospitality Industry Congress described HACCP as "clearly the correct approach"[155]. The institution of HACCP throughout all butchers' premises is seen as a key to preventing a recurrence of food poisoning outbreaks such as the one associated with E.coli O157 which took place in Scotland in 1996[156]. Even where it is not formally applied throughout the food chain, the basic principles behind HACCP remain valid. The steps which the public can take in their homes to minimize the danger of food poisoning - correct temperature control of stored food, the avoidance of cross-contamination, and thorough cooking - constitute an informal HACCP procedure. In that sense, the final Critical Control Points exist in the kitchen[157].

59. Is the widespread acclamation of HACCP wholly justified? Marks and Spencer cautioned that HACCP was "only a tool and not a universal solution"[158]. The Institute of Food Science and Technology said that it was a "demanding technique requiring rigorous application by well-trained people. It can be said that an inadequate HACCP study can be more dangerous if applied than not doing the study at all"[159]. We consider that an undeserved mystique has developed around the HACCP principle which may have led to a reluctance amongst small businesses to embrace the concept. In many respects, HACCP simply represents a codification of the good hygiene practice which all food businesses should follow[160]. The full implementation of HACCP will not, of itself, rid the food chain of microbiological hazards, but it will make a significant contribution to food safety, in conjunction with adequate training of food business managers and food handlers. We also consider that the sixth and seventh stages of HACCP should be made mandatory legal requirements. Nevertheless, the focus of HACCP on the processes adopted by individual businesses does not obviate the need for measurement of levels of microbiological contamination of businesses' raw material inputs and processed outputs, and for a co-ordinated approach to the reduction of pathogens throughout the food chain as a whole.

Agricultural and farming practice

60. The Royal Institute of Public Health and Hygiene argued that too often in the UK, "the past philosophy has been that food safety and hygiene is a matter for outside rather than inside the farm gate"[161]. There is a need to examine closely the requirements of current commercial animal production systems in the search for significant improvements in food safety. There is little doubt that modern intensive farming practices have increased the scope for cross-contamination between animals. Most dairy cows, for example, are Campylobacter-positive, and once colonised the animals remain positive for life. It is essential that in order to measure the impact of any pathogen reduction strategy, we have accurate information on the carriage of pathogens by the various animal species in the food chain. It is therefore of concern, for example, that there have been no surveys of the prevalence of Salmonella in healthy animals. Data on the incidence of Salmonella in cattle, sheep and pigs is mainly derived from the investigation of clinical disease[162]. In relation to E. coli O157 in various animal species, little is known about the proportion of herds or flocks which are infected, the prevalence of infection within herds or flocks and causes of the spread of infection. A survey is planned in order to establish the level of VTEC O157 in faecal samples from cattle and sheep presented for slaughter. Given the fact that both Salmonella and E. coli O157 are well established pathogens capable of causing serious illness, it is of some concern that basic research such as this has not been undertaken before[163]. A serious attempt to identify strategies which seek to reduce the levels of pathogens in animals on farms will also have an impact on slaughterhouse hygiene. Definitive information is needed on what the current pathogen levels are in animals destined for food production and the potential for reduction associated with different intervention strategies. This is a task which the Food Standards Agency will need to address urgently.

61. The application of good agricultural practices and progressive husbandry methods can make a significant contribution to the safety of farm produce. Considerable success is being achieved, for example, in reducing the incidence of Salmonella in poultry. There is undoubtedly scope for further improvement in this and other sectors. On the other hand, as the NFU said, "complete elimination of [zoonotic organisms] from livestock is very difficult and would, indeed, be pointless unless animals were kept in sterile sealed conditions to the detriment of their welfare"[164]. The Federation of Fresh Meat Wholesalers argued that it was anomalous, given the degree of regulation at other parts of the meat food chain, that livestock producers were not required to operate under licence, but the then President of the NFU, Sir David Naish, rejected the idea of licensing farmers, preferring a voluntary approach[165]. We believe that MAFF, together with the Food Standards Agency, will need to review the relationship between modern farming practices and food safety, once the basic research on carriage of pathogens in livestock has been carried out. While we do not consider the licensing of livestock producers to be necessary, we are in favour of the promotion of HACCP principles within the farming industry. It is important to remember that extensive and intensive livestock production methods, in food safety terms, both raise their own specific problems which the FSA and MAFF must address on their merits.

Slaughter and primary processing

62. There is no doubt that animals which are dirty due to faecal material and/or soil, and subjected to unnecessary stress in transportation are more likely to be contaminated with pathogens. The implementation of a Clean Livestock Policy, managed by the Meat Hygiene Service, is a welcome initiative and provides a semi-objective approach to the assessment of the hygienic status of individual animals presented for slaughter. The Meat and Livestock Commission stated quite clearly "that dirty livestock should not be accepted for processing"[166].

63. The Meat Hygiene Service has responsibility for enforcing meat hygiene, inspection and animal welfare at slaughter legislation in licensed slaughterhouses, cutting plants and cold stores. Hygiene Assessment System (HAS) scores for each plant subjected to inspection are published in the Hygiene Bulletin. Whilst no specific studies have been carried out by MAFF or the MHS to compare the microbiological quality of finished product from slaughterhouses and cutting plants with their HAS scores, a limited study has been undertaken as part of a wider MAFF-funded research project. This study concluded that HAS scores are a useful indicator of an abattoir's capability of producing carcasses to a sound microbiological status. It is essential to have sound objective measurements of the value of the inspection process, so that judgements can be made about the proportionality of the slaughterhouse inspection regime to the food safety risks involved. In the context of this and other inquiries, we are particularly concerned about the poor-quality "tail" of slaughterhouses with low HAS scores which exists in this country. We recommend changes to the licensing system for slaughterhouses to make it far more difficult for slaughterhouses with unsatisfactory hygiene levels to operate, by banning individuals with a record of running unhygienic establishments from gaining or retaining licences. This should punish the guilty without imposing undue regulation on well-run smaller slaughterhouses.

Processing, distribution, retail and catering

64. The food manufacturing industry in the UK processes a wide range of products using a variety of raw materials sourced from both within and outside the UK. When one considers the volumes of foodstuffs which are sold, there are relatively few incidents of foodborne illness associated with manufactured foods retailed from large and responsible sales outlets. In the UK, a relatively small group of large retailers have played a significant role in contributing to the high standards of food production. Most major retailers work very closely with their supplier base to undertake product development, implement risk analysis techniques and audit the hygienic operation of processing factories. However, it is important not to be complacent, since a number of potential problems do exist. Whilst the larger companies are not immune from food safety issues, there is growing concern that medium and smaller sized businesses do not have access to the same level of food safety expertise. These are the companies who may not implement HACCP fully, usually because of lack of technical resources. We were pleased to see that the Chilled Food Association recognized the need to provide technical support and assistance to such businesses[167].

65. Legislative oversight of this section of the food chain is embodied in the HACCP approach as set out in the Food Safety (General Food Hygiene) Regulations 1995. Together with the requirement to introduce HACCP, the Regulations set out "a requirement for all food handlers to be supervised and instructed and/or trained in food hygiene matters commensurate with their food activities"[168]. They also promote the concept of voluntary industry guides to good hygiene practice[169]. Much guidance and advice has been published by the Government, the local authorities who enforce food hygiene legislation, and by the industry itself. The importance of proper training of food handlers has been stressed by many in evidence to us. The Joint Hospitality Industry Congress, for example, provided us with a copy of the catering industry's guide to good hygiene practice, which is admirably clear in setting out the levels and types of training required by different categories of staff within the catering sector. Mr Clive Wadey of the JHIC did agree, however, that there was an issue involved in "who is checking whether this training is carried out and how effective that training is, the quality of training and how much can people remember? We have to keep reminding people"[170]. By its nature, the catering industry has a high turnover of staff. The Transport and General Workers' Union stated that: "Poor working conditions, unhygienic practices and high staff turnover will have a negative impact on both food quality and food safety. We believe that minimum training standards for all workers in the food chain should be met before a worker is allowed to handle or process food"[171]. Mr David Smith, who has studied the effectiveness of food hygiene training at the European and UK levels, submitted evidence to us highlighting weaknesses in the system, which he described as having a "miserable record"[172]. We are concerned that the admirable principles which are espoused by the JHIC and other industry associations in relation to food hygiene training are not being implemented in practice throughout all food businesses. The withdrawal of mandatory funding of food hygiene courses by the Further Education Funding Council is a retrograde step[173]. The effective implementation of HACCP depends crucially on well-trained managers and employees in food businesses. The FSA should be encouraged to comment publicly on the adequacy of such training.

The consumer

66. While most food poisoning outbreaks occur in restaurants, the second highest number take place in private homes[174], at parties, barbecues and the like. The great majority of individual food poisoning cases occur in the home. A number of reasons have been advanced for the apparent increases in the incidence of food poisoning in the home in recent years. These include:

shopping at supermarkets once a week, leading to increasing reliance on fridges and freezers to keep food fit to eat;

preferences for chilled foods and ready-to-eat meals, which require close observation of storage and preparation instructions; and

lack of familiarity with the safety issues surrounding microwave cooking[175].

The MLC, for example, relating the UK experience to other developed countries, said that "traditional forms of food preservation, such as freezing, smoking and other methods are less acceptable to consumers, who now seek fresh products free of additives and preservatives. The consumer trend to use processed meats and ready meals provides further potential for food poisoning episodes"[176]. A number of witnesses also claimed that public knowledge of the potential hazards associated with food, and of the correct treatment of food within the home, was less developed than in previous generations.

67. Consumers have a right to expect the food which they buy to be as free of pathogenic contamination as is practicably achievable. Nevertheless, as the ACMSF said, "for the foreseeable future it must be assumed that raw food materials entering the domestic environment will on occasions contain harmful pathogens"[177]. The message that consumers need to treat food with care and respect does not excuse the food production and processing industries of their responsibilities - indeed, it is in a sense an indictment of those industries - but it is indubitably the case that most, if not all, cases of food poisoning originating in the home could be prevented.

68. The Food and Drink Federation commissioned a survey in 1996, as part of its foodlink initiative, to examine knowledge and behaviour relating to safe handling of food in the home. The results of this survey demonstrate a patchy awareness of the potential hazards of food: fewer than half of adults, for example, said they always followed storage and preparation instructions on food packages, or kept raw foods below cooked foods in the fridge. Only one in four adults claimed to know the correct temperatures of fridges and freezers, and fewer than half of these people were actually right[178]. All the authorities involved in food hygiene run public information campaigns[179], although the impact of these initiatives is questionable. As the ACMSF has noted, recipes using raw eggs are routinely presented in cookery magazines and programmes despite the Chief Medical Officer's warnings about the dangers of raw eggs for vulnerable groups. Public information is one area where we believe that the Food Standards Agency must devote sufficient resources, assessing the problems by opinion surveys and using the information to increase public awareness of food hygiene issues, to inform consumers about changes in best practice and bring about a substantial reduction in food poisoning cases (see also paragraph 99 below). We welcome moves currently under way to raise the profile of the subject of food hygiene in school curricula[180].

69. The standards of domestic kitchen equipment, especially fridges, freezers and microwaves, have important implications for food safety in the home. Too many fridges lack thermometers or temperature indicators which would allow people to be sure that they were storing food at 5°C or below, retarding bacterial growth. Likewise the variety of microwaves on the market means that the cooking instructions on food packaging may not be fully appropriate to all makes. Mr Joe Hattle, of the Chilled Food Association, said "we have to make an allowance for the fact that there is a variation in these things and build that extra safety margin into our instructions. You get phrases such as "ensure that it is piping hot", it is not a terribly good phrase to use but at the end of the day it is so difficult to say something else that helps the consumer"[181]. Some welcome developments have taken place. The Food and Drink Federation, through its Foodlink Campaign, has distributed 40,000 fridge thermometers via local Environmental Health Departments[182]. The Food Standards Agency must have an important role to play in encouraging manufacturers to achieve higher and more uniform standards in domestic kitchen equipment, particularly fridges and microwaves, to assist the public in maintaining the safety of food.

Traceability and labelling

70. From a food safety point of view, the traceability of produce throughout the food chain is of substantial benefit. Multiple retailers have recognized this, and effectively audit their produce from the level of the farm until it arrives on their shelves. Safeway, for example, has applied farm assurance standards to all its meat products since April 1996, and inspects abattoirs and meat packing plants. The result of this policy is that "Safeway fresh meat is traceable from the retail pack back to a batch of supplying farms"[183]. As well as allowing multiple retailers to influence production methods in response to changing consumer preferences, assurance schemes and traceability assist greatly in pinpointing food safety problems when they arise. Marks and Spencer cited the 1997 recall of 12,000 tons of frozen hamburgers produced by Hudson Foods in the USA as an example of the disastrous commercial consequences of failing to maintain traceability[184]. Public health authorities also have a clear vested interest in being able to trace a food safety problem back to its precise source, whether it be a retailer, a processor, a slaughterhouse or a farm. The PHLS recommended the introduction of labelling regulations "to require all foods sold at retail or to caterers to contain sufficient information to trace food back to the producers if the food is implicated in an outbreak"[185].

71. We seek the maximum provision of information to consumers about their food, through labelling, where possible, and other means, and we support the Government's general approach to this subject. Consumers are entitled, in our view, not just to comprehensive and clear information on the ingredients contained in their food, but to as much information as possible about the provenance of that food, the producers and processors involved in its production, and the methods of its production. We recognize that space on labels is finite, and that complete traceability cannot be assured for all foodstuffs, especially those containing numerous ingredients. Nevertheless we feel that a radical overhaul of the labelling of food on sale in the UK is long overdue. Food imported into the UK must be subject to the same traceability and labelling requirements as domestically-produced food.

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