FSANZ releases guide on re-opening food businesses in COVID19 era but not on food fraud mitigation
FSANZ releases guidance for food businesses to use when preparing to recommence pre-restriction operations.
The checklist is available to help businesses ensure they have good food safety and hygiene practices before reopening or returning to dine-in operations. The checklist provides further detail under the following headings. Follow the link to the checklist for further details:
1. Check your business can re-open
2. Staff availability, skills and knowledge, health and hygiene
3. Check that the premise is suitable for preparing or handling food
4. Cleaning and sanitising Areas used for food preparation and serving will need to be thoroughly cleaned, and food preparation surfaces and utensils cleaned and sanitised before use to ensure there is no risk to food safety.
5. Food in refrigerators, cool rooms and freezers Check whether fridges, cool rooms and freezers have been without power, as the safety of stored food may have been affected.
6. Sourcing new supplies
7. Local Council Inspections
This checklist will be updated by FSANZ when new information comes to hand.
Over here at Food Labelling Matters, we would like to discuss point 6 a little more. Critically, food businesses manufacturing foods required to bear a label for sale may find their ingredient suppliers no longer operating. Or a food sourced internationally is no longer easily available. Sourcing from new suppliers may introduce new risks. This is critical to food labelling compliance. You are required to proactively mitigate this new risk in the interest of food safety and public health.
The evidence is the risk of food fraud has increased in the age of COVID19 for a number of reasons. The World Health Organisation warns food safety authorities around the world are now operating at a significantly reduced capacity to maintain fully functioning food inspections and testing capacities, ultimately increasing the risk to the integrity of the food supply chain from food fraud. This means food businesses selling food in Australia and New Zealand can not rely on previous assurances foreign food safety systems are operating to check food authenticity. Food fraud risks are throughout supply chains. Food businesses must ensure sourced food ingredients are of the true nature and substance declared.
Beyond the reduced capabilities of established government food safety programs checking food safety risks, scientists and academics in the EU and UK remark COVID19 directly influences the risk of food fraud on supply chains and impacting your food business. In the UK's 'The Grocer' magazine, James Donarski, head of food authenticity at Fera Science states “All the drivers have shifted with the Covid-19 pandemic on to the side of the bad guys, unfortunately.”
Foods are vulnerable to frauds when the opportunity to dilute/substitute (or otherwise replace high value or in-demand ingredients with cheaper replacements) couples with motivation to commit fraud, and where control measures are absent. In the wake of COVID19, food businesses have collapsed across the globe; creating a glut of some ingredients and scarcity of others. Eoghan Daly, director of forensic services at Crowe UK notes, “There will be suppliers in the food and drink industry under absolutely huge pressure and they’ll make decisions they wouldn’t have made, or they’ll turn a blind eye when maybe they wouldn’t have done so before." Dr Nick Lord, professor of criminology at the University of Manchester, argues (in The Grocer article) food businesses should focus on understanding who is supplying their food. We know food fraud can not be combatted through authenticity testing alone. Dr Lord advises that "identifying suppliers that could be under financial pressure or with opaque supply networks can help".
Supply chain integrity-related research is critical in the era of COVID19. Changes in ingredient supply/demand dynamics may be enduring, creating enduring risks. Depending on your food organisation's systems of supply, your food business may be at an enhanced risk of food fraud now and into the future.
Whether you already have a food fraud strategy or have only just heard of the term, you need to assess the risk of food fraud and identify reasonable mitigations to protect their business (and consumers). Food Labelling Matters' sister business Food Fraud Protection helps food businesses identify and control their risk of food fraud occurring in their organisation. A Food Fraud Initial Risk Assessment tool is available to food businesses for download. You are invited to take this easy first step to think about your organisation's food fraud risks in the time of COVID19. Following the initial assessment, food fraud vulnerability assessments are conducted to identify the areas for mitigation. Maybe you haven't had the need (or reason) to check these risks before now. The experts think the time to control these risks is now. Contact Dr Janine Curll and arrange a convenient time for a confidential chat: email@example.com.
FSANZ advises further: 'If your food business is preparing to re-commence operations following the easing of COVID-19 restrictions, it's important that you check for any specific guidelines or requirements that apply in your state or territory.
Food regulators have developed a helpful checklist for food businesses preparing to recommence operations.'
See also, WHO references:
FAO/WHO. 2010. FAO/WHO framework for developing national food safety emergency response plans https://www.who.int/foodsafety/publications/emerg ency_response/en/
WHO. 2020. Modes of transmission of virus causing COVID-19: implications for IPC precaution recommendations, Scientific brief. https://www.who.int/newsroom/commentaries/detail/modes-of-transmissionof-virus-causing-covid-19-implications-for-ipcprecaution-recommendations COVID-19 and Food Safety: Guidance for competent authorities responsible for national food safety control systems: interim guidance -5-
FAO/WHO. 2009. Codex Alimentarius. Food hygiene: Basic texts http://www.fao.org/3/a1552e/a1552e00.pdf
WHO. 2020. Laboratory biosafety guidance related to coronavirus disease 2019 (COVID-19) https://www.who.int/publications-detail/laboratorybiosafety-guidance-related-to-coronavirus-disease2019-(covid-19)
Responding to food safety emergencies (INFOSAN) https://www.who.int/activities/responding-tofood-safety-emergencies-infosan 6. Coronavirus disease (COVID-19) advice for the public https://www.who.int/emergencies/diseases/nov el-coronavirus-2019/advice-for-public
Q&A on coronaviruses (COVID-19) https://www.who.int/news-room/q-a-detail/qa-coronaviruses
FAO/WHO, 2020. COVID-19 and Food Safety: Guidance for Food Businesses https://www.who.int/publications-detail/covid-19- and-food-safety-guidance-for-food-businesses