BFFF Industry Forum

14 September 2016 Martin Forsyth, Head of Technical

BFFF

Introduction

Looking back: Member Queries TxG Discussions

Current Issues/Extrapolate Forward Possible Future Role of BFFF/Membership Groups Possible Future inc Brexit

Looking Back Member Queries

150 – 250 queries per year Huge variety of interests from members

How do we answer? PA scheme – Food Safety/Food Labelling Experts Policy making contacts in Government departments Other organisations expertise especially Europe IP/Historical BFFF expertise

Looking Back - Member Query Trends

Total 96 queries to mid August 2016 30% Labelling/General/DoFF/COOL 13% Glaze (specific issue) 11% Hygiene & Temp Controls 7% Certification/Shelf Life 6% Imports and Exports 5% Nutrition 27% Spread of Other Items – Fish/Meat Additives/Analytical/Official

Controls/Misc

Looking Back

TxG Discussion Items (2016) Technical Expert Group 20 Technical Directors (or equivalent) senior personnel Valuable practical experience of all food issues Help to all BFFF members Aid to influencing and contact support

Looking Back - Technical Expert Group Trends Detailed Discussion Items over the past year (19) Plus over 200 other items/projects and technical papers

TRENDS Future of Food Regulation Food Fraud – lively discussion around emerging science Biocides and Chlorates

Cutting Red Tape Review BFFF Administration Food Fraud Future Food Regulatory Strategy Date of First Freezing Chlorates Giving Food to Good Causes Acrylamide Product Information Management in the Foodservice

Supply Chain Biocides

Addressing the Challenges in Food Waste Distribution

Review of National Food Crime Unit Childhood Obesity Plan Glaze on Seafood Nutrition Halal – Food Fraud BFFF Joins Anaphylaxis Campaign Date of First Freezing Country of Origin (COO)

Current Issues/Looking Forward

Explore just 5 areas in detail: Future of Food Regulation Labelling Issues including DoFF Food Fraud Biocides and Chlorates Food Waste

Future of Food Regulation including Approval of Cold Stores

Current model unsustainable FSA led review of both EHOs/TSOs controls and Meat Hygiene Service Likely to recommend an earned recognition approach Higher Standards = lighter touch However “IF THEY CARE THEY WILL PAY” Extends to standalone cold stores where most facilities should now be approved

and not just registered

Future of Food Regulation

Earned recognition positive factors Outside accreditation eg Red Tractor/BRC Primary Authority relationship Data sharing

Risk Assessment process Likely implementation 2018 - 2020

Labelling Issues including DoFF

FIC (2011) – still accounts for 30% of member queries Developing ‘interpretation’ COO for meat/meat as an ingredient over 50% etc DoFF still not agreed which products it applies to nor format but it’s coming Increasing evidence of EU variation in ‘difficult to reach consensus’ areas Implementation: Now to 2018

Food Fraud

Continuing live issue but moved on since ‘horsegate’ Maturity developing for sources of risk assessed information and databases Risk techniques also developing eg PAS 96/TACCP/Carver & Shock Analytical techniques improving DNA techniques offer long term advantage for industry testing Implementation: Now

Biocides and Chlorates

More of a food manufacturing issue but large implications for all food industry Issues is how much residue of a cleaning chemical active ingredient to allow EU complexity

Is it a food hygiene matter? eg control of listeria and other microbes Is it a chemical matter? eg previously registered as a pesticide

Currently not a sufficient balance between food hygiene concerns and theoretical residue effects

Why not just wash it away? Problem is chlorates in water also above the theoretical limit!

Food Waste

Frozen is part of the solution Evolving and maturing voluntary sector Understanding of the ‘rules’ is weak Freezing instructions vary Infrastructure constraints Recognition of the above is leading to improvements via retail

Future Technical Possibilities

WGS COO – Stable Isotope Ratio Analysis Traceability and provenance techniques are improving DNA and PCR analysis improvements Allergen testing improvements Recall systems improvements

Future Technical Possibilities

All laboratory techniques improving in accuracy Understanding of the answers is lagging behind eg ‘Free From’/allergen

thresholds Sandwich DNA example

Possible Futures including Brexit

Our relationship with Europe – not clear Our regulatory regime – not clear Most food law comes from Europe therefore BIG impact whatever

happens

Assumptions

UK is part of single market or has some preferential access EU food legislation is imported wholesale into UK law and modified at a

later date Imports and Exports will increase – expertise required But only 20% of food and drink manufacturers currently export and very

little of the rest of the food sector

Brexit

EU legislative process has issues Process obscure and complicated

Complexity of Regulation is Everywhere

EU all MS eg 852/2004 and 853/2004 EU all MS except some differences eg FOP – UK, COO – France & soon

Italy/Lithuania/Romania/Portugal UK – England, Wales, Scotland and NI Except there are differences

Food Information Regulation 2014 – actually 4 separate regulations (one for each country) All the same except for Scotland where sanctions are criminal (not based on improvement

notices)

Other Examples: Wales – mandatory Food Hygiene Rating Scheme display Scotland – NHS nutrition standards are different Plus many other examples

Role of Membership Body - BFFF

Recognise Complexity Be prepared for it – help members overcome the complexity Plan for more complexity Keep awareness of the EU single market legislation – if we have access

Future BFFF Role More high quality advice across a wider range of issues Legislation trackers for both EU and UK devolved administrations Contact with other organisations eg ear to the ground

Summary

We can sum up the BFFF T&L approach to Brexit and indeed the Technical and Regulatory challenges:

“Stop being an Inner or an Outer and start being a Doer” Head of L&G Financial Services

Thank you for listening