I was intrigued by the terms of reference which narrowed the scope of the review to “any recent intelligence on the threat of substitution”
Horizon scanning within the food industry is a long term science / dark art, but this review seems to feel that the “looking back over previous months” is a sufficient time scale. I am not sure I agree.
The report states that many industries and the FSA itself do have systems to identify emerging issues. For example the FSA has in place an ‘Emerging Risks Programme’ and a Food Fraud team, who use intelligence to inform targeted enforcement action. This incident has demonstrated the need to strengthen this horizon scanning and intelligence analysis, but it is not possible to say that this adulteration would have been detected even with a more substantial programme. It is acknowledged that electronic systems including open information systems and web crawlers can also provide valuable information.
A finding of the report is that an intelligence management system should be developed which includes horizon scanning, intelligence gathering and analytical capability, that is the right people to ask the right questions. The FSA should take the lead in building capability, but a collaborative approach will be essential. This process should be further backed up by targeted sampling programmes, delivered by not just the FSA and local authorities, but also by industry.
But the real gem for me is buried at the bottom of page 17 of 21 pages and it states that “a further point highlighted in this incident is the complexity of the food supply chain and the role of food brokers within this. Further consideration is needed in relation to the classification of food businesses operators.
I may be missing something but how will tweaking the classification of food business operators address the role of brokers in a complex food supply chain.
Time and time again we know that unscrupulous brokers who are trading food products unseen, with inappropriate food safety risk assessment and supplier assurance are a threat and remain a threat to our entire industry.
The full report is available to download from the Food Standards Agency website.