Food Safety News – July 2010
Managing your food supply – do you have due diligence?
A customer buys a wrapped sandwich from your restaurant; they bite in and break a tooth. They find a piece of metal which is still in the sandwich. Far-fetched? Well, yes, but it does happen. Hands up you are guilty? Not necessarily.
The law relating to the liability for foods supplied to the final seller takes account of who was responsible, in this case, for the metal in the sandwich.
The Food Safety Act 1990 introduced the concept of “due diligence” to enable businesses who’re being prosecuted to prove they had done all they possibly could to prevent the contravention.
Businesses could also have a defence if they could prove it was the fault of another party, for example, the company who supplied the food. Guidance helps identify who has most liability, for example, if the food is sold open in a the shop or restaurant, or is it pre-packed and labelled by the manufacturer. Whoever is responsible, don’t you want to minimise that risk in the first place? Almost all businesses will say yes.
So how do we minimise the risks from supplied foods? Firstly you can use only approved suppliers, but approved by whom?
In the 1990s after the Food Safety Act was introduced and purchasers became aware of due diligence, suppliers were inundated with supplier audits from each of their bigger customers. QA Managers became like used car salesmen showing auditors around their factories often many times per week.
Then the British Retail Consortium (BRC) came up with a standard for suppliers to meet that would be accepted by the biggest of UK purchasers, the supermarket chains. Auditing companies registered with the BRC were able to inspect suppliers and issue approval certificates.
The BRC approval scheme is now well established with many suppliers registered to the standard. In addition, with the desire to use more local, often smaller suppliers, a similar but more approachable standard SALSA was introduced.
But do these systems provide an absolute guarantee of the safety of supplied foods? Not necessarily, the BRC and SALSA systems look at the management systems and the premises.
There have been occasions where ingredients used by approved suppliers have become contaminated beforehand and the Government has suggested a withdrawal of such contaminated foods. In such situations a good traceability system is essential.
Furthermore suppliers can be approved to BRC or SALSA standards and still have defects. Each BRC audit is a year apart when approved and there is a possibility that minor defects identified could get worse before the next annual audit.
Should you have a problem with supplied food then how you use that food could increase your liability. If you open, prepare and cook the food your potential liability will of course be higher than if it is pre-wrapped and just served. But even then you could have problems. All too often we see wrapped foods where the supplier has issued proper storage temperature requirements but these are not being followed because your staff are not reading the label for following the manufacturers instructions.
All too often when there is a problem with a food it is the place that served it that gets all the attention. In most cases the media will be down to the place that sold it with pictures in the papers the next day. Only later is it clarified that the shop or restaurant, who’ve already been blazoned over the pages, was not actually at fault. By then it is too late and your reputation is damaged or even fatally wounded.
What we do?
At Hygiene Audit Systems, we have maintained an independence from the main approval systems and work hard on behalf of purchasers and suppliers alike.
For purchasers we have developed and refined databases to hold information on suppliers on their behalf to ensure due diligence beyond approval status alone.
Should a problem occur our dedicated staff can quickly use this information and bring in our other experts on your behalf. If there is any doubt with a supplier or if you would like to get a critical supplier up to standard we can provide support to achieve this.
We offer a range of services to ensure due diligence for supplied foods from total managed solutions to administrative support. For further information on food supplier safety please call us on 01727 866779 or email to donna@hygieneauditsystems.com
