Professor Chris Elliott’s interim report reviewing the integrity and assurance of food supply networks, was published in December 2013. His final report is expected at the end of summer 2014. Whilst praising the work the UK food industry does in delivering “perhaps the safest food in the world” the underlying theme of Professor Elliott’s review and recommendations is that significant changes are needed to deal with the threats of fraudulent activity that exist along complex supply chains and the culture that underlies how food fraud is perceived and received.
Due Diligence
As far as industry is concerned it is a timely report and should act as a due diligence wake-up call, even for those unaffected by recent food crimes. A due diligence defence is obtainable if a company has established it has taken all reasonable precautions and exercised all due diligence to avoid committing an offence. What is ‘reasonable’ will depend on the facts in each case, the knowledge implied or otherwise of the company as well as its’ size and resources. Professor Elliott in a particularly descriptive passage states: “Understanding your supply chain, and how it works, must be much more than maintaining an appropriate paper trail. When things go wrong, waving a piece of paper will not provide a defence against allegations of negligence or handling counterfeit foods (which constitute criminal property under the Proceeds of Crime Act 2002.)”
In this new, post-horsegate dawn, both the over reliance on paper audits and their unnecessary profligation are criticised. Instead, there is a need for an intelligent assessment of circumstances; commodity prices are a clear indicator of where risk can lie, agreed descriptions of what the product is and correct labelling, contracts with specific and defined requirements and validation processes provide accurate requirements. The cultural change required would be in prioritising authenticity and adherence to labelling as being on a par with safety. Lack of knowledge of the provenance or indeed species of your product clearly undermines the entirety of the careful risk assessments and hazard analysis critical control point steps a producer would have undertaken and more importantly undermines the consumers trust in the product and brand.
Summary
Food companies need to make an intelligent assessment of their supply chains and processes, rather than the blanket reliance on paper based auditing.
The final form of Professor Elliott's report is awaited with interest.
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