Traceability Problems

Drazenka Tubin-DelicDeputy Head of Incidents Branch

Food Standards Agency

TAIEX Workshop on Incident Management – RASFF, traceability, withdrawal and recall procedures, Zagreb 6-7th

June 2011

Outline

• Rationale for traceability

• Case Studies: feed incident meat incident EC exercise

Rationale

• Interests of stakeholders: consumers government and industry

• Consumers; protect food safety by effective products recalls, avoidance of specific foods/food ingredients

• Government; protect public health, control of zoonotic diseases, help prevent food fraud

• Industry; comply with legislation, prompt action, minimise the impact, protect brand reputation, consumer confidence

Practical Problems

• No specific requirements

• Global nature of the food chain

• Complex nature of the food chain

Case Study 1: Salmonella in brewer’s yeast

• Involved 2 batches of brewer’s yeast contaminated with 2 different strains of Salmonella (Virchow and Senftenberg)

• Used as an ingredient for animal feed prefixes

• Notified by UK distributor – following testing by its customer

• Product originated from Portugal

• 20 tones consignment – distributed to various animal feed manufacturers in UK and Republic of Ireland

Case Study 1: Salmonella in brewer’s yeast (cont)

• Risk Assessment: due to potential patogenicity all animal feed premixes to be quarantined and tested

• UK supplier very cooperative• Traceability was detailed and clear throughout

distribution chain • All of animal feed mixes and blends – pelleted and

heat treated blends were tested (all negative, remained on sale)

• One blend for horses was not heat treated and pelleted, tested positive and was recalled

• Two pet products were also recalled• FSA informed the EC via RASFF

Case Study 1: Salmonella in brewer’s yeast (cont)

Outcome:

– Excellent traceability records throughout the distribution chain

– Prompt action– Minimal quantities recalled

Case Study 2: Milk and meat from cloned animal offspring

Overview• An article in USA (29/09/2010) reported that

unnamed UK dairy farmer claimed to be including milk from an offspring of the cloned cow into the food chain

• EC asked for assurances from the UK that neither meat nor milk from the cloned offspring was entering the food chain

• Traceability exercise involved tracing 2 cattle embryos from a cloned cow in the USA imported into the UK in 2006 and their offsprings

Case Study 2: Milk and meat from cloned animal offspring (cont)

Legislation• Food from cloned animals is treated as a novel

food Reg EC 258/97 – can only be legally marketed if

formally authorised

• No concerns about the safety of the milk/meat from healthy offspring of cloned animals

• EC did not consider that the novel food legislation applies

Case Study 2: Milk and meat from cloned animal offspring (cont)

• FSA worked closely with Defra (responsible for legislation on importing of cloned embryos)

• Investigations revealed that three animals have entered the food chain

• No milk entered the food chain

Case Study 2: Milk and meat from cloned animal offspring (cont)

• DIAGRAM from one of the farm

Import of embryosImport of embryos

Farm AFarm A

Bull - BBull - BUKxxxxxxxxxxxUKxxxxxxxxxxxBorn 5/12/06Born 5/12/06

Farm BFarm B

Slaughterhouse ASlaughterhouse A

Bull ABull ASlaughtered Slaughtered 27/7/1027/7/10

Remainder of Remainder of herd sold at herd sold at auctionauction5/3/085/3/08

Imported early 2006Imported early 2006 8 embryos from 8 embryos from cloned animalcloned animal

Bull – ABull – AUKxxxxxxxxxxUKxxxxxxxxxxBorn 3/3/07Born 3/3/07

Sold 28/2/08Sold 28/2/08

Bull BBull BSlaughtered Slaughtered 23/7/0923/7/09

38 progeny of 38 progeny of Bull BBull B

58 progeny of 58 progeny of Bull ABull A

Meat Meat disposed of disposed of as Category as Category 1 ABP1 ABP

V7 – 4/8/10 4PMV7 – 4/8/10 4PM

Meat goneMeat gone

Still on farmStill on farmNot being milked Not being milked (all female)(all female)10 have died10 have died

Farm CFarm C

Female – BFemale – BUKxxxxxxxxxxxUKxxxxxxxxxxxBorn 2/12/06Born 2/12/06

Farm CFarm C

Son* of Female BSon* of Female BBorn 5/8/09Born 5/8/09

Sold 27/2/08Sold 27/2/08

Sold 25/11/09Sold 25/11/09

* - calf from implanted embryo – not considered a novel food* - calf from implanted embryo – not considered a novel food

Being fattened Being fattened for slaughter. Not for slaughter. Not used as sireused as sire

Female AFemale AUKxxxxxxxxxxUKxxxxxxxxxxBorn 24/4/07Born 24/4/07

Died 17/5/07Died 17/5/07

Daughter 2 of Female BDaughter 2 of Female B(Same owner as above)(Same owner as above)

Female BFemale BMoved 29/7/10Moved 29/7/10

Still on farmStill on farm

Daughter of Female B Daughter of Female B UKxxxxxxxxxxxxxxUKxxxxxxxxxxxxxxBorn 16/4/09Born 16/4/09

Still on Farm CStill on Farm C

Milk not Milk not entering food entering food chainchain

V8 – 6/8/10 10AMV8 – 6/8/10 10AM

Case Study 2: Milk and meat from cloned animal offspring (cont)

• Intensive media coverage and number of interviews given by CEO

• Collaborative working with Defra and devolved offices

• Scoping and stakeholders meetings held

• Correspondence with EC , local authorities, briefings for Ministers

Case Study 3: EC exercise – RASFF traceability 2010

• EU-wide exercise to test traceability systems and the use of RASFF by EU Member States

• Held in September 2010

• Began with purchase of a pork product from London retailer

• Product ‘contaminated’ with an unauthorised veterinary medicine product

Case Study 3: EC exercise – RASFF traceability 2010 (cont)

Required;

• Tracing the batch of pork used in production of the product back to the farm of origin

• Identifying any other recipients of the batch in question

• Identifying all products manufactured with the batch in question

Case Study 3: EC exercise – RASFF traceability 2010 (cont)

Information provided;

• ‘XYZ’ brand – Extra trimmed un-smoked back bacon

• Use by date• Pack size• Producer code (UK company)

Case Study 3: EC exercise – RASFF traceability 2010 (cont)

Action Taken:

• LA for the UK producer contacted to establish traceability (backwards and forwards)

• UK producer supplied 5 UK retail chains

• UK producer sourced pork from Spain and Belgium via 2 UK intermediaries (RASFF issued)

• Identified that pork in question originated from a Spanish supplier able to identify the limited number of potential farms of origin

Lessons Learnt

• The implementation of traceability varies between businesses and sectors

• It comes with cost

• But the cost of not having it or having insufficient systems may be severe for consumers, individual companies, governments

Thank you very muchHvala na paznji

Drazenka Tubin-Delic Incidents Response Branch

Food Standards Agency

drazenka.tubin-delic@foodstandards.gsi.gov.uk