Available online at www.sciencedirect.

com

ScienceDirect
Procedia Food Science 5 (2015) 247 – 249

International 58th Meat Industry Conference “Meat Safety and Quality: Where it goes?”

Food safety – flexible approaches to production and official controls

Milorad Radakovica,*
a
University of Cambridge, Department of Veterinary Medicine, Madingley Road, Cambridge CB3 0ES, United Kingdom

Abstract

Food production differs between the developed and developing world, and within these ‘two worlds’ there are regional and local
differences. An approach to safe food production and official controls depends on diverse and complex socio-economic factors in
the context of political and legislative framework within which food producers and official controllers exist. The common goals
of safe food production can only be achieved by competent people and through effective communication and collaboration at all
levels with flexible approaches to production and official controls implementation, in particular to small businesses.

© 2015
© 2015Published
The Authors. Published
by Elsevier by Elsevier
Ltd. This is an openLtd.
access article under the CC BY-NC-ND license
Peer-review under responsibility of scientific committee of International 58th Meat Industry Conference “Meat Safety and
(http://creativecommons.org/licenses/by-nc-nd/4.0/).
Quality: Where
Peer-review underitresponsibility
goes?” (MeatCon2015)”.
of scientific committee of The 58th International Meat Industry Conference (MeatCon2015)

Keywords: food safety; flexible approaches; official controls; small business; effective communication

1. Food Safety - roles and responsibilities

In 2010, the Food and Agriculture Office (FAO) of the UN, the World Organization for Animal Health (OIE) and
the World Health Organization (WHO), signed ‘A Tripartite Concept Note’ on sharing responsibilities and
coordinating global activities to address health risks at the animal-human-ecosystems interfaces1. Practically, this
global agreement is reflected, for example, in the EU legislative food safety framework2 with a number of
initiatives, one of them being that flexible provisions were adopted in legislation to protect the diversity of EU
agricultural production3, to serve consumers and the needs of small-scale producers4. Both Food Business Operators
(FBOs) and Official Controllers (OCs) share the same common goals; safe food and safe food production. These

* Corresponding author. Tel.: +441223765048

E-mail address: mr412@cam.ac.uk

2211-601X © 2015 Published by Elsevier Ltd. This is an open access article under the CC BY-NC-ND license
(http://creativecommons.org/licenses/by-nc-nd/4.0/).
Peer-review under responsibility of scientific committee of The 58th International Meat Industry Conference (MeatCon2015)
doi:10.1016/j.profoo.2015.09.063
248 Milorad Radakovic / Procedia Food Science 5 (2015) 247 – 249

common goals can only be achieved with an effective legislative interpretation and implementation by competent
people and through effective communication, collaboration, cooperation and coordination at all levels. In reality,
however these common goals lose their full meaning because both FBOs and OCs do not always understand the
proportionality of the risk posed from a particular food process or the food itself. Their focus is unnecessarily
diverted, for example, in some cases to less significant over-prescriptive (yet not comprehensive) interpretations of
structural and operational (production process) legal requirements. This is despite the fact that the current EU
legislation has been drafted to be less prescriptive, with a sufficient flexibility for interpretation that would benefit,
in particular, small and medium size businesses. There may be many reasons behind these ‘inflexible’ approaches,
but one of the main reasons is that interested parties do not communicate, cooperate or collaborate effectively, and
thus, they are unable to coordinate their activities to achieve common goals. Each participant in the food chain plays
an important part with clear roles and responsibilities. Producers are primarily responsible for safe food and safe
food production. After an initial official approval, for example in slaughterhouses, OCs (e.g. veterinarians) are
personally responsible for the outcome of ante and post mortem inspection tasks and for verification of all other
FBOs’ responsibilities, such as the structure and hygiene of establishments, by carrying out regular audits. In
establishments other than slaughterhouses, OCs also verify FBOs’ activities by carrying audits and inspections at
prescribed frequencies. Official controls should be flexible and proportionate to risk with a full appreciation of
cultural differences and small traditional businesses.

2. UK approach to flexibilities permitted under EU Hygiene Regulations

Following the introduction of the harmonized EU Food Hygiene Package in 2006, the European Commission
(EC) in 2009 initiated a number of fact-finding Food and Veterinary Office (FVO) audits of small-scale
establishments in EU Member States (MSs). Six EU MSs, including the UK, volunteered for FVO audits. The
purposes of these visits were to find out to which extent flexibilities were applied in the EU5, and in longer-term
consolidation and dissemination of ‘best practice’ guidelines through the Commission staff working documents on
the Understanding of certain provisions on flexibility provided in the Hygiene Package 6,7. In parallel with the EC
initiatives, the UK Food Standards Agency (FSA) formed a Current and Future Meat Control (CFMC) task group on
flexibility, and composed of the officials and industry representatives. The group faced a task to unwrap the fact that
EU hygiene regulations provide FBOs with a variety of flexibilities, including through the use of subjective terms
such as “adequate”, “sufficient” and “equivalent”. These terms have been interpreted for operators and officials in
the UK meat sector in the Meat Industry Guide (MIG) and the Manual for Official Controls (MOC). After some
deliberation the group provided a working definition of flexibility as ‘an alternative way of achieving compliance
through structure, production processes and official controls’. The group also agreed that any flexibility applied
must not result in any increased risk to public health, animal health and animal welfare. The task group produced
two specific documents, first being guidance on the flexibilities available for small food production establishments
in 20118 and then the flexibilities available for larger meat establishments in 20129 setting out a clear list of the
existing flexibilities in current legislation, which all operators can access and consider in light of their production
processes. Following this, a survey of all slaughterhouses was carried out in 2013 with the purpose of establishing
the extent that structural and operational (production processes) flexibilities have been taken up by FBOs and if not,
why not. The actual survey was also an educational opportunity for OCs and FBOs where they discussed in an open
and focused way the possible flexible approaches without compromising food safety. The survey also clarified that a
number of FBOs did not consider it appropriate to apply a particular flexibility at their establishment, or simply
were not interested in applying the available flexibilities: these considerations were accepted as the legitimate
commercial decisions. On the other hand, it is also worth noting that a number of small establishments already
benefited from available flexibilities e.g. simple Hazard Analysis and Critical Control Points (HACCP) records, and
in some cases it was made clear that some processes can be instigated, such as an alternative way of disinfecting the
knives to 82°C.
 Milorad Radakovic / Procedia Food Science 5 (2015) 247 – 249 249

3. Benefits of flexible approaches to food production and controls?

A structured, well-communicated and coordinated approach to flexibilities is considered to benefit all in the
farm-to-fork food chain, including consumers. FBOs are provided with guidance on options available to them in
order to comply with the regulations, which may also simplify processes, preserve traditional food production and
have concomitant cost benefits. OCs are provided with consolidated guidance to assist them in carrying out
approval, inspection and auditing tasks. Officials at the national level (Policy/Strategy) are provided with guidance
that helps with a more consistent national approach, achieving better regulation and/or improving existing guidance
and further discussions at international level. Consumers, on the other hand, benefit from a diverse choice of safe
food from different sources. For example, compared to a few years ago, in the UK the word ‘flexibility’ is now
taken in a more positive context with much better understanding and application of the flexibility approaches in food
production. However, further work needs to be done by both industry and officials in promoting the optimal use of
available flexibilities and measuring their impact. It must be said that the concept of flexible approaches to food
safety production and official controls could be rather controversial because food safety risks can be either
unnecessarily amplified or diminished. However, there is no need to act in such a way if all stakeholders
acknowledge that zero risk is unachievable and it is neither possible nor necessary nor appropriate to prescribe every
real life scenario in legislation or in guidance. A science risk based assessment and management with a common
sense practical approach would achieve the common goals with no food safety being compromised. With so many
competent people, why, then, do effective and flexible approaches to food safety risk and official controls nit always
take place particularly in small establishments? Perhaps, better communication is all that is needed.

References

1. The FAO-OIE-WHO Collaboration. Sharing responsibilities and coordinating global activities to address health risks at the animal-human-
ecosystems interfaces. World Health Organization. A tripartite Concept Note, 2010. [cited 2015 June 16]. Available from:
http://www.who.int/influenza/resources/documents/tripartite_concept_note_hanoi_042011_en.pdf.
2. Relevant food safety legislation. (EU). Available from: http://eur-lex.europa.eu/homepage.html.
3. European Commission. Protected Geographical indications and traditional specialities quality schemes. (EU). [updated 2015 June 09; cited
2015 June 16]. Available from: http://ec.europa.eu/agriculture/quality/schemes/index_en.htm.
4. The European Commission Report. Report from the Commission to the Council and the European Parliament on the experience gained from
the application of the hygiene Regulations (EC) No 852/2004, (EC) No 853/2004 and (EC) No 854/2004 of the European Parliament and of
the Council of 29 April 2004. EC 2009. [cited 2015 June 15]. Available from:
http://ec.europa.eu/food/food/biosafety/hygienelegislation/docs/report_act_part1_en.pdf.
5. Food and Veterinary Office report. FVO General report of a mission series – Regarding the application of the Hygiene Regulations in small
establishments – DG (SANCO) /2010 -6150; EC 2011. [cited 2015 June 15]. Available from:
http://ec.europa.eu/food/fvo/overview_reports/details.cfm?rep_id=15 .
6. The European Commission working document. Commission staff working document on the Understanding of certain provisions on flexibility
provided in the Hygiene Package Frequently Asked Questions Guidelines for the competent authorities. EU 2010. [cited 2015 June 15].
Available from: http://ec.europa.eu/food/food/biosafety/hygienelegislation/docs/faq_all_public_en.pdf .
7. The European Commission working document. Commission staff working document on the Understanding of certain provisions on flexibility
provided in the Hygiene Package Frequently Asked Questions Guidelines for food business operator: EU 2010. [cited 2015 June 15].
Available from: http://ec.europa.eu/food/food/biosafety/hygienelegislation/docs/faq_all_business_en.pdf .
8. Food Standards Agency. Small and low throughput establishments: Examples of EU hygiene regulation flexibilities. UK 2011. [cited 2015
June 16]. Available from: http://www.food.gov.uk/business-industry/guidancenotes/hygguid/euhygieneregulationsflexibilities/#anchor_2.
9. Food Standards Agency. Larger meat establishments examples of flexibilities. UK 2012. [cited 2015 June 16]. Available from:
http://www.food.gov.uk/sites/default/files/multimedia/pdfs/exhygienregstable.pdf.