Working as a technical manager in the food industry can seem like a thankless task; caught between a rock and a hard place; and constantly running around putting out fires. Grappling with BRCv7 compliance and the new Vulnerability Assessment requirements can definitely make you feel that way.
Before horsemeat and the requirements of BRCv7, most food safety teams found themselves seriously under-resourced after many years of budget cuts. Decisions to spend your budget on replacing staff who have moved on, coupled with the difficulties of recruiting suitably skilled staff and incurring the costs of recruiting processes are ever more challenging.
The industry as a whole is currently losing many experienced people who are retiring, leaving the industry, or moving into consulting for higher rewards and lower stress levels. Without the influx of excellent technical resources from abroad, I believe the industry would be in grave danger of falling over completely. We cannot rely on immigration to plug the gaps in our skills base for the longer term.
Horizon scanning isn’t working
Horizon scanning has entered our toolbox as a timely and useful tool to assist with the identification of fraud and adulteration risks. However, we are trying to achieve this by using historic data from sources such as RASFF; which is an incomplete data source.
This means that we are not achieving true horizon scanning, we are merely studying history to provide us with an indicator of the future. At the moment it’s all we have. It is certainly a useful model, but calling it horizon scanning is rather stretching the definition.
We need more appropriate intelligence
Most food businesses operate on their own, they will have some information from trade bodies and associations but it cannot cover all risks.
We are being encouraged to pass our own intelligence to the FSA; but we are not receiving any intelligence from the FSA in return, that we can use to help defend ourselves. I do understand that the FSA has no wish to alert criminals to the fact that they are being monitored, but the FSA is itself suffering from limited resources. A public-private partnership where intelligence is more easily shared, would increase the levels of monitoring in areas of risk; and could potentially help to deter criminals.
Are Vulnerability Assessment requirements of BRC7 an over-reaction?
In response to the horse-meat scandal and the Elliott Report, the industry was forced to react, but there is a high risk that Vulnerability Assessments on their own, may not work. Where will that leave us as an industry? Is it reasonable for the food industry to shoulder this burden on its own?
Fraudsters are better resourced and more agile
Europol has recently issued a warning about the level of sophistication and resources that are available to the fraudsters. A sophisticated fraudster with extensive resources is in a good position to probe weaknesses in the defences of our industry to discover which can be exploited, and then to move quickly and decisively to take full advantage.
Consider the quantities of illegal drugs, tobacco and alcohol that are brought into the UK, despite a vast Police and enforcement effort. What chance do we have in the food industry?
Fraudsters can collaborate for mutual gain
Combined sophistication and extensive resources alongside cross-border collaboration, gives the fraudsters a distinct advantage. Rules, Regulations and Standards do not apply. Yet as an industry it can be very difficult for food companies to sit down together and share intelligence, so yet again we are battling against further disadvantage.
The unknown unknown’s
Fraud and adulteration across global food supply chains have too many unknowns. Even with the best vulnerability assessments, there will be unknowns which may result in failures.
Every cloud has a silver lining
While I may sound pessimistic, I believe that the food businesses who implement robust vulnerability assessments are increasing their defences substantially, and these increased defences will reduce risk.
As we all know risk cannot be eliminated, but can we hope for the possibility that the fraudsters will seek out easier targets…?