Frank de Bok: ‘What we have to test is laid down in Regulation 2073/2005. It lays down microbiological criteria for the various food categories. The General Food Law has been in force since 2005. This obliges every producer to indicate the origin of raw materials and the contamination of ingredients, semi-finished and finished products. Since then, companies are also obliged to immediately report harmful errors to the NVWA. Furthermore, producers are also responsible for the quality and safety of their products and their recovery.’

Last year, the European Commission amended the Hygiene Regulation: changes were made to the redistribution of food, the food safety culture, and the handling of food allergens. For example, the prevention of cross-contamination with allergens was previously not explicitly mentioned in the legislation. By adding two paragraphs, this is now a legal requirement for the primary sector and for the rest of the food chain.

“The food safety culture has only been an integral part of the main certification schemes for a few years now”, says Aldo. “At the end of 2018, GFSI (Global Food Safety Initiative) published a position paper: ‘A Culture of Food Safety’. Shortly thereafter, the BRC, IFS, and FSSC included the subject in their certification requirements. A food safety culture says something about the intrinsic motivation of employees. Namely that they want to do what’s right without needing supervision or coercion. BRC 8 goes into much more detail here than IFS 7. Where IFS 7 only says that you must record the food safety culture in your policy and include it in your management review, BRC 8 requires you to develop this into a plan for improvement and provide it with a review. This forces you to measure it. The draft version of BRC 9 (the final version will be released in August) shows that the standard will even more explicitly dictate what you must do. Moreover, the food safety culture has been removed from the paragraph on the standard and added to the Fundamental in chapter 1. If you do not comply with this, you are not BRC-worthy. In the draft version of IFS 8, there are no additional requirements for food safety culture.”

Marjan: “With regard to allergen management, the SimplyOK Foundation has developed a certification scheme. The five basic pillars of allergen management, as also included in this certification scheme are:

1. raw material information from suppliers;

2. recipe management;

3. label design;

4. preventing the mix-up of raw materials, semi-finished products, and labels;

5. preventing cross-contamination and performing a quantitative risk assessment using VITAL®.”

Aldo: “In order to guarantee food safety, it is essential that you set up a HACCP system. If you do this well, train your HACCP team and let them contribute ideas, most risks will be identified. You can then assess their risk level in order to take measures accordingly. For example, by training your staff or performing analyses.”

Frank: “Lab research is in fact no more than a verification that manufacturers are complying with the rules for producing safe products. The safety of your products must be guaranteed in the factory; there you have to eliminate the risk of contamination with dangerous micro-organisms and ensure that the risks of marketing unsafe products are controlled.”

“The HACCP approach, based on the process steps that the product goes through, just does not align with allergen management”, Marjan responds. “Allergen management is then often limited to preventing cross-contamination at every step of the process by cleaning. However, companies that clean very well also have allergen recalls. Often things go wrong in processes that are not specifically seen as food safety issues, but that focus on the right information for the right product. Think of swapping labels or products, making a recipe change without putting it on the label, connecting the wrong silo, or a big bag that wanders through the company without identification and is then incorporated into the wrong finished product. You have to look at your processes in a different way. We use all five basic pillars of allergen management as a foundation. Preventing cross-contamination is just one of them.”

A kind of corporate blindness?

Marian: “Exactly! Product quality and safety is often equated with hygiene, which people are usually well trained in. Only when we explicitly point out where things can go wrong do they see it. Our Allergen Scan teaches them to look differently at their own processes, including the supporting processes. Allergen management is very often like kicking at an open door. It is often only in the practical situation that it becomes clear what we mean. A lot can be achieved with plain common sense and the structuring of all processes.”

Aldo: “The simple fact is that things go wrong, at any given company. That is why it is so important to ensure that these matters are brought to light and that they are addressed. Many companies make a hazard analysis once and then pay little to no attention to it. While this should be a living document. Did something happen at a competitor? A recall, a complaint, an incident? Then you should immediately check whether you have implemented sufficient control measures and monitoring to prevent a similar problem. Both management and employees overestimate themselves. We hold a mirror up to them.”

How do you do that?

“By mapping the food safety culture. To do this, we start by collecting data via an anonymous survey”, Aldo replies. “Do they feel safe in the company? Can they report it if they or someone else makes a mistake? Is such a report handled within the company? We then conduct an on-site assessment. Does the result of the survey match what we hear and see in the workplace? If it turns out that management punishes mistakes instead of addressing them, you can take that as a point of attention. You can train middle management in positive leadership. You can also do a root cause analysis for a complaint or incident and think about the question: who could have seen this and why was it not reported? You can include that in your root cause analysis (RCA).”

What are the most important points for attention or points for improvement that you encounter?

Aldo: “Recognition and appreciation are definitely number one. It goes awry when this is lacking. A second point of attention would be communication, and in particular the feedback after reports. The explanation of certain control measures could also often be better. The environment is number three. We regularly report that irritation arises about basic conditions if the building is insufficiently maintained: why should I wear a hairnet in a room where peeling paint can also cause contamination in the product?”

Marjan: “When we visit companies, we often see isolated data. The quality department has an Excel file with recipes and provides the label information on that basis. In production, however, a different file is used and R&D uses yet another one. These files and therefore recipes are not always the same. Sometimes you see a product being weighed in the herb chamber and someone is scribbling what is in the bag with a marker. That’s asking for trouble. Automation can be of real use here. Make sure that everything is clearly identified, use a sticker with article and batch number plus a date. We must ensure that consumers with allergies can make their own safe choices with the correct product information. That is the basis. Data management is essential for that.”

 Frank: “One point for improvement that I would like to mention is that producers must base their research much more on the risks that the product entails, reasoning based on the raw materials it contains and the production process used to make it, rather than on a legal obligation. Unfortunately, too little attention is paid to food safety and testing policy. If there is no criterion at all, it will not be tested for. For smoked salmon, for example, it is not stated in the legislation that you have to test it for Salmonella. The relevant producers thus do not do this either, and therefore an outbreak in 2012 with this bacterium was only noticed very late. Another example: in England, strict laws and regulations apply to Clostridium botulinum. Manufacturers who export to England are obliged to monitor for this bacterium. In the Netherlands, however, it is hardly a problem and the NVWA does not enforce it. So it is hardly ever checked. Yet it is a very dangerous bacterium, it could even be fatal.”

Aldo: “Or take ethylene oxide, for example. That was not in the standard package that most companies use to analyze. It was discovered more or less by accident in sesame seeds from India. Only then did everyone start testing for it and it turned out to be in many more raw materials. And before horse meat was ever found in beef, no one did a DNA test on beef.”

Frank: “It requires the necessary knowledge of microbiology to be able to make a good estimate of what is really needed. Some food pathogens only pose a risk in a product if they are given the opportunity to grow. About five years ago, the NVWA started to check much more strictly for Listeria monocytogenes. It then became apparent that many producers did not control the risk that this bacterium can entail. They thought they had been doing it right all these years, but were blatantly failing to comply with the legislation.”

So what was going on?

“Listeria is not allowed to exceed a certain value within the shelf life”, Frank explains. “What was overlooked was that you can’t assume that if you don’t find anything, the risk has been controlled. The chance that you will miss something in your research is great. The chance that you are missing something in your research remains. It’s always about probability and incidence. The government wants – in the Netherlands, they are very strict about this – you to be able to demonstrate that if a bacterium ends up in the product, it cannot pose a risk as a result of excessive shelf life. As a result of the NVWA inspections, producers shortened the shelf life or added more preservatives to the product. Retailers, on the other hand, want longer shelf lives and consumers want fewer additives in their products. A tricky dilemma.”

What developments are you concerned about?

Marjan: “We have lost the balance when it comes to allergen warnings. The knowledge that someone with an allergy can die from a product containing an allergen has led to too many packaging containing warnings. But not every quantity is life-threatening. The basic principle must be that you inform the consumer when there really is a risk, otherwise the consumer will not take the warning seriously and will ignore it. If there is a chance of cross-contamination, which cannot be prevented, you must make a very well-considered choice based on a good risk assessment, as with VITAL. There is still a lot of work to be done in this regard, also for the supply chain.”

“Lentils, for example, grow with a support crop that is also harvested. Usually, that is wheat; an allergen. The lentil farmer could also choose a different support crop. Or consider what is happening in the slaughterhouses with laying hens that are processed into meat. They can still be carrying an egg. During the slaughtering process, egg ends up on the meat. Then you sell the consumer a chicken product that may contain egg; an allergen. The supply chain is often not aware of these risks.”

“Nevertheless, the Netherlands is one of the safest countries when it comes to food”, says Frank. “I do, however, think that stricter action should be taken against producers who do not comply. Don’t keep giving them warnings, just close the factory! That is more effective than adding new criteria to the criteria that already exist.”

Aldo: “What I hope is that, now that the food safety culture has also been included in the Hygiene Regulation, every company, not only the BRC, IFS, or FSC2200 certified companies, will do something with it. And that as a result, we will see a decrease in the number of incidents. A recall costs a lot of money, you suffer reputational damage, and you are playing with people’s health. It is a serious threat to your business continuity. Look at Ferrero in Aalten, for example, who had a salmonella contamination of the Kinder Surprise eggs or Offerman with its Listeria problem. Those factories are closed. End of story.”