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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
Testing for Life From our accredited laboratories, Eurofins Food Testing offers comprehensive analysis of all of the 14 main allergens. Our ongoing investment in allergy testing has allowed for the use of the latest ELISA technology, increased laboratory capacity and reduced turnaround times, enabling us to offer positive release service if required. Eurofins Food Testing UK are proud to support the Anaphylaxis Campaign and Allergy UK in their efforts to raise awareness and support those living with allergic disease. www.eurofins.co.uk | sales@eurofins.co.uk 0845 604 6740
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
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
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
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
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
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
Nationwide food hygiene specialist Over 30 years experience providing the highest standards possible • Hygiene consultancy • Auditing • Interim hygiene managers • Skilled hygiene operatives • Contract cleaners For more information contact us on: 0114 2455201 Or John Hessey on: 07428 055125 John.hessey@hislimited.co.uk admin@hislimited.co.uk Richard.mitchell@hislimited.co.uk Fiona.mitchell@hislimited.co.uk www.hislimited.co.uk O�ce 8 Haywood House Hydra Business Park, Nether Lane, She�eld S35 9ZX
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
10ETHICAL 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
11ETHICAL 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
12All Laboratories
are not the Same
Find out why so many manufacturers entrust their
work to ALS for the complete testing service.
Unbeatable Service Uncompromising
Nationwide sample quality standards
collection service available UKAS/INAB accredited to
through our modern fleet ISO 17025
of refrigerated vehicles Approved by M&S, Tesco,
7 food testing laboratories DEFRA & Kraft
located across the UK to Unrivalled industry
help get your samples on expertise ensures that
test quickly eve r y test re s u l t i s
delivered with accuracy
and integrity
A ‘One Stop Shop’ of Helping your business
tests and services every day
Microbiological – including Industry-leading web-
Shelf Life Trials, Pathogen based portal ‘WebTrieve’
Determination and provides quick and easy
Challenge Testing access to your test results
Nutritional Testing, Meat In-house Consultancy
Content and Speciation Service to help optimise
your testing schedule and
Food Allergens, assist with food safety
Contaminants, Pesticide issues
Residues, Vitamins and
Additives Regular Training Workshops held across the country offering
technical guidance on a range of topics
All this AND competitive pricing. Why look elsewhere?
www.als-testing.co.uk I 01354 697028 I sales.uk@alsglobal.comCE 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
14CE 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
15TRANSPARENT 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
16TRANSPARENT 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
17TRANSPARENT 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
18SOFHT 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
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©The Society of Food Hygiene and TechnologyFSA 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
20FSA 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
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