The co-location of human and pet food, manufactured side-by-side
The Food Standards Agency (FSA) launched a new policy just before Christmas. The policy now allows both meat for human consumption and meat for pet food to be produced in the same food plant, or Food Business Operator (FBO), as the FSA call slaughterhouses, cutting and food producing companies.
The co-location of food for human and non-human food carries a few risks that the guidance does not consider. Chief among them is that the industry regularly demonstrates the potential to cut corners or commit food fraud. The National Food Crime Unit was created in the FSA to deal with such fraud, but it already has a substantial workload.
Some readers will remember the recent Russell Hume investigation that cost taxpayers over £750k and led to the loss of 300 jobs. The FSA found that the mislabelling of use-by dates was due to “significant and systemic” inadequate food safety management systems.
This new guidance states “The Food Standards Agency (FSA) has received a number of enquiries from Food Business Operators (FBOs) and local authorities…” Why is there such an increase in demand, especially as the consultation on the policy took place in March 2018? Currently, FBOs need to have in place a Hazard Analysis and Critical Control Point (HACCP). The FSA acknowledge that to co-produce pet food with human food will mean the HACCP needs to be changed. This is to avoid cross-contamination and manage risk. However, the question that needs answering is whether any FBO is suitably set up to have two separated areas, and procedures to guarantee that the labelling is distinct for each food type. A further question is what level of demand there is from FBOs to produce pet food for our non-human animal friends.
The guidance makes clear the need for “A robust internal traceability system for both the pet food and food for human consumption, ensuring there is no re-introduction of pet food into the food chain under the HACCP principles.” What does a “robust” system represent in practice?
In the section ‘Approval and registration’, added burdens are placed on local authorities that are under significant and ongoing pressures with their budgets, with grants slashed, income falling dramatically due to COVID-19, and many staff being redeployed elsewhere to deal with the pandemic. Yet, it will fall on trading standards officers and environmental health officers locally to protect the public from eating pet food in their spaghetti bolognese.
UNISON works with civil society groups, for example, Unchecked UK. Unchecked published a report in November that showed a 52% fall in net funding for trading standards services in England along with a 51% fall in the FSA's budget between 2009 and 2019.
The cuts to regulatory services mean less regulation of the industry that can so easily send us a horse burger instead of a beef burger or mislabel use-by and end dates.
When the FSA talk about enforcement, they state, “The risk-based inspection and enforcement of the co-located pet food manufacturing area and associated activities will be the responsibility of difference enforcement bodies, depending on the location of the establishment.”
Risk-based approaches mean gaps in checking and enforcement, as they are based on a paper exercise collated after infrequent regulatory visits while the FBOs check their own standards. That has not worked well in the past, not least because FBOs have conflicting priorities, like maximising their own profits.
The guidance also talks about best practice – not legal and binding requirements on industry. Food processing areas and equipment can also now be shared. And it gets juicier:
“It is advisable to follow a specific working pattern to clearly separate the two processing operations, e.g. pet food manufactured at the end of the day or on separate days to that of food for human consumption.” This is a recipe for disaster, open to potential food fraud and/or cross-contamination by the lax following of procedures or mistakes by staff.
The FSA continue, “Although the storage of the pet food manufactured on-site must remain separated from food, the same chillers or freezers can be shared, provided all the final products are clearly identified/labelled, completely marked and clearly designated for food and pet food.“ Remember the Russell Hume scandal was about mislabelling.
This new guidance followed a consultation back in March 2018; but it was published just before Christmas 2020, in the middle of one of the worst crises the country has faced since World War II, and at the point where the UK Government was agreeing agreed a new trade deal with the European Union (EU).
Risk-based regulation is not really regulation - it is a lottery. How might this end? Food consumers, food regulators and citizens should be vigilant over the next few months. If many FBOs want to produce meat for humans and meat for pets, in the face of new export requirements arising from the new trade deal with the EU, we fear that mistakes may happen. These mistakes will only come to light if the industry is honest about them, or if the regulators find them. But it would be far better for the FSA to revise their approach and prevent mistakes from happening in the first place.
Paul Bell, National Officer, UNISON lead for members working for the FSA, and TSOs and EHOs in local government.