Securing food safety: FSS on combating crime and staff shortages

In this Q&A, New Food speaks to Heather Kelman, Chair of Food Standards Scotland (FSS) about the “Our Food” report released in collaboration with the Food Standards Agency (FSA).

The report itself outlines various concerns from the regulators, including how staff shortages in the sector could make it harder to identify food safety threats.

Previously, Professor Susan Jebb, Chair of the FSA, shared with New Food: “I think it’s important that we’ve made our concerns public, and I hope that this will help stimulate the action that is needed.” Passing the microphone over to FSS, Assistant Editor Grace Galler spoke to Kelman about regulator’s three top priorities aimed at fortifying the integrity of the food industry.

In her responses, Kelman highlights why the FSS believes it is important to collaborate with stakeholders to address various issues including the shortfall of Environmental Health and Food Safety officers, the imperative for information sharing to combat food crime costing up to £2 billion yearly, and the ongoing quest for advancements in food safety, particularly focusing on pathogenic microorganisms and allergen management.

What are three priorities the FSS would like the food industry to take away from the “Our Food” report?

Heather Kelman (HK): Confidence in the food system underpins an industry worth £240 billion and supports good animal welfare, farmers, food processors, international trade and the UK’s vibrant food culture. That’s why FSS and the FSA want to work closely and collaboratively with the food industry – and other important stakeholders such as government, professional bodies and local authorities –  to achieve the following:

• Recognise that the shortfall in local authority Environmental Health and Food Safety officers could affect the reputation of the food industry and our ability to export and collaborate with us and other stakeholders to modernise food law enforcement.
• Share more and better-quality information across the food industry to help stop criminal gangs and tackle food crime that costs the UK up to £2 billion per year; and
• Continue to collaborate on improvements in food safety. In particular focusing on work to reduce pathogenic microorganism contamination and allergen management

Why are staff shortages a key concern at this moment in time? How do they impact food being kept safe?

HK: An effective food law enforcement regime is a crucial foundation for protecting public health and for a flourishing food sector.  Environmental Health teams deliver the vast majority of food law controls in Scotland. The interventions that they undertake include ensuring the food that we eat is safe; is described and labelled appropriately; and, provides the necessary assurance in the Scottish food sector to facilitate trade, including international trade.  It is essential that there are a sufficient number of officers to deliver the necessary interventions to deliver this, and these limited resources need to be protected. Our system is preventative (i.e., designed to stop food borne illness, not simply accept the consequences) and without sufficient resources, the risks to consumers will increase. Other means of assurance for example sampling have also been cut so we now have reduced sampling volumes and reduced staffing levels which is not a good place to be.

How would FSS like the government, local authorities, professional bodies and industry to address the decline in local authority Trading Standards officers, Environmental Health and Food Safety officers?

HK: FSS is working with colleagues from across Scottish Government, CoSLA, Local Authorities and other stakeholders to address the issues facing Environmental Health, and food law enforcement.

As part of this, FSS is developing a programme of work, the Scottish Authorities Food Enforcement Rebuild (SAFER) to ensure the future delivery of an effective food law enforcement regime.  It aims to achieve this across three broad objectives:

• increasing resources to deliver food law, through enabling additional officers to become involved and ensure additional financial resources are available;
• reducing demand by increasing business self-service and targeting intervention where most beneficial; and
• increasing efficiencies, implementing digital solutions, utilising data and intelligence using intelligence (e.g. outputs from third party assurance and internal quality control processes) to inform decision making.

How will combatting the shortage of Official Veterinarians positively impact the food sector?

HK: Official Veterinarians (OVs) are legally required for two main activities for the food sector, these are: statutory Official Controls at slaughterhouses and trade (both export certification and import controls). Combatting OV shortages will ensure both these areas are suitably covered, leading to: adequate meat availability within the food supply, protection of animal welfare, unaffected trade with other countries and UK standards being met. It is easy to forget that the last Foot and Mouth outbreak was identified in an abattoir and it cost the industry billions.

Could you elaborate on the strategies or specific measures being considered to facilitate the sharing of information within the food industry to address the prevalence of food crime?

FSS will soon launch its new Food Crime Prevention Strategy, which sets out a vision for a safe, healthy, and sustainable food environment that benefits and protects the health and well-being of everyone in Scotland. Three of the priority outcomes are that food is safe and authentic, responsible food businesses are able to thrive and FSS is trusted and influential. 

Workforce shortages and food safety: Insights from FSA’s Chair

Its application aims to prevent, reduce, and deter crime and criminals impacting on the food supply chain. It creates the opportunity to develop an approach to food crime and criminals which emphasises proactivity towards identifying supply chain vulnerabilities and learning to reduce crime occurrence or re-occurrence.

FSS long term goal is to have a process that will enable effective and efficient analysis of information. This will then inform FSS and partners’ proactive prevention activity with an emphasis on protecting consumers and helping food businesses reduce their vulnerability to food crime. FSS meets regularly with the Food Industry Intelligence Network (FIIN) to share information. These meetings, along with regular meetings with a variety of other industry bodies, focus on exploring areas where we can work collaboratively to tackle food crime.

How has FSS already made strides in tackling food crime in 2023?

HK: In 2023 the SFCIU have reported a number of food crime investigations to the Crown Office and Procurator Fiscal Service that are under consideration and in due process.

In addition, the SFCIU recently launched its Food Crime Risk Profiling Tool (FCRPT) to provide support, guidance, and advice to food businesses on food crime.

In relation to the proposed import controls on food from the EU to mitigate risks associated with unsafe food entering the UK, could you outline the key aspects or mechanisms of the proposed import controls on EU-sourced food items? How do you anticipate these measures will bolster food safety standards and mitigate the potential risks posed by imported goods?

The UK Government Border Target Operating Model (BTOM) will use a risk-based approach to global imports into GB of animals, animal products, plants, and plant products, applying different controls to goods in different risk categories. Given the imperative of protecting Scotland from biosecurity threats, and the need to offer long-awaited clarity for businesses, the Scottish Government will adopt the UK Government’s Border Target Operating Model in Scotland. While the FSS/FSA report highlights that, since 2021, there has been no significant change in safety based on available border data and intelligence and compliance levels for non-EU import controls, which remained stable, there is no comparable data available on imports from the EU. The introduction of border checks on EU imports will provide assurance that EU food and feed imports meet our safety standards and allow us to identify and stop potentially unsafe food at an earlier stage.

How does the FSS perceive the role of ensuring confidence in the food system to support not only economic aspects but also animal welfare, international trade, and the broader cultural significance of food?

HK: Confidence in the safety and standards of our food and food system is not only important for consumers, but remains critical to supporting Scotland’s renowned food and drink sector, whether trading domestically or internationally. FSS has a statutory duty to protect food and feed safety and consumer interests in relation to food and feed in Scotland. We recognise that maintaining food safety standards in new trade deals negotiated by the UK Government, and having robust scrutiny arrangements in place for assessing the impacts of trade agreements on human health, is paramount to consumers’ trusting their food and assuring stakeholders too.

As noted in the report, FSS and FSA also recognise that consumers are interested in understanding the production standards of imported foods, including for example their environmental and animal welfare standards. Being able to assess the production standards, like animal welfare or environmental standards, of imported food on a comparable basis to UK food, is essential if we as watchdogs are to be able to assess whether the food standards of the food the UK consumes has been maintained.

The report’s findings suggest these areas require further attention and will be something we continue to explore with the FSA – while also continuing to co-operate with partners across government to make sure consumer interests are recognised.