The horsemeat issue has raised a number of questions which have challenged the way in which the food industry and technical professionals consider traceability. Primarily those involved in supply chain management and holding responsibility for developing and undertaking audits need to incorporate suitable mechanics that can account for the likelihood of fraud. In the first instance this should include a mindset to ‘think like a criminal’ and approach the supply chain with a detailed technical knowledge in addition to considering the points within it that are susceptible to or attract the temptation to defraud. Such risk points may be complex supply chains, multi-step processing, and high value items. These aspects must be analysed in terms of commercial value as well as provenance and origin. It may, in fact, be appropriate to consider the risk of fraud, where such risk is identified as high, within the context of HACCP. Positioning such risk and temptation within HACCP is productive in that it can force the implementation of structured plan of action to mitigate the perceived risk.
In addition to the inclusion of ‘temptation of fraud or adulteration’ as a critical control point, it is also important to consider the impact of external regulatory, environmental and social changes that could impact on the product supply chain. This can only be achieved by a wider horizon scanning activity such as commercial intelligence, knowledge of supply chain shortages and the consideration of downstream impact. Such external events should be recognized as ‘red flags’ and trigger an appropriate HACCP review to account for and risk assess the perceived risk and where necessary implement control measures. The control measures may include enhanced auditing and testing schedules in line with a strong Quality Assurance and GMP philosophy.
The activity of those involved in managing the integrity of the supply chain is largely exemplary and the IFST GMP6 is an essential tool in implementing adequate and fit for purpose control mechanisms, such as those reflected in paragraph 6.12 and chapter 10. However it is difficult to say whether the horsemeat scandal could have been avoided or predicted by application of even more robust auditing protocols. As with all issues, safety, adulteration or otherwise the existing processes need to be reviewed and additional controls implemented where necessary. It is now evident that considering the potential and temptation for fraud for commercial gain must become a key part of food safety and quality control.
This statement was prepared by Steve Osborn B.Sc.(Hons), M.Phil. MIFST, in cooperation with IFST’s Consultancy group.