“Good enough” is never good enough
The food chain, or at least most food sectors, has shown over the last two years an incredible resilience in the face of the Covid-19 pandemic, with seemingly fewer outbreaks of foodborne illness despite operating difficulties due to labour shortages. Yet in the last three months, outbreaks in the United States (Cronobacter spp. in powdered infant formula) and Europe (Escherichia coli STEC 026 in flour and frozen pizzas, Salmonella spp. in chocolate products) have shaken consumer confidence in the ability of major food business organisations to ensure safe food production and provide full transparency. Two factories in France and Belgium are now closed and facing criminal investigations initiated by Paris and Brussels.
These three episodes of microbial contamination are not unheard of, and a history of previous outbreaks should have prompted the relevant organisations to put in place appropriate risk mitigation control measures. Yet, these episodes still occurred. From the external information available, these three episodes share at least one common root cause: inaccurate (outdated, flawed, incomplete) microbial risk assessments. Bad risk assessments drive inappropriate management decisions and create opportunities for incidents to occur.
Many criticisms have been raised in the wake of these episodes, mostly from consumer associations who request more controls and stricter supervision. The lack of controls and obscuring control results from authorities are put forward as a primary cause of the outbreaks. But are they really? Would have it helped to do more? We can’t be so sure. Testing for the sake of generating results without challenging their relevance does not ensure safe food production. The point is not to do more, but to do better.
In Europe in particular, food business operators lean too heavily on compliance with EU2073/2005 and its microbiological criteria for foodstuffs to defend themselves against incriminations when their focus should be on the general principles and requirements of regulation EU178/2002 that finds food business operators themselves are best placed to devise systems for supplying safe food. The devil presently lies in the misunderstood detail that microbiological criteria should not be pass/fail but, rather, form the basis of performance objectives that are driven by a commitment to deliver acceptable levels of protection. To comply with a particular criterion, the analysis per se is not the point but, rather, the array of control measures that are put in place to keep performance up to the expected standards.
This approach is embedded in the Plan-Do-Check-Act Deming cycle: never settle, always challenge, seek to do better. When it comes to food safety, we must learn from other episodes, update our knowledge to answer new challenges, and use the most relevant analytical tools. “Good enough” is never good enough. There are always opportunities to do better. Food business operators will always face the operational challenges of cost and business orientation associated with new decisions and actions. But what is food safety for a business operator? It’s no less than the freedom to operate. FAO’s mantra is “if it’s not safe, it’s not food.” And if it is not safe, one does not produce and is forced out of business. Act before that happens.
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