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Emphasis on Integrity in BRC Version 7 Draft

Posted by Tony-C, in Food Safety Standards 01 June 2014 · 10,984 views

BRC have issued a draft version 7 of the BRC Global Standard for Food Safety which has a strong emphasis on product and raw material integrity and authenticity, quite obviously a result of last year’s Horsemeat Scandal.

The scandal in which horsemeat was substituted for beef in a range of products caused uproar with the public particularly in the UK and Ireland. As Professor Reilly, chief executive of the FSAI, said "It is not our culture to eat horse meat and therefore, we do not expect to find it in a burger".

Horse meat is not a risk in itself; however, it may contain the veterinary drug phenylbutazone also known as 'bute' of which there is not a recognised safe level in meat for human consumption.

So while not a direct food safety issue, the scandal revealed a major breakdown in the traceability of the food supply chain. In the majority of cases there were opportunities for fraudulent activities as the meat went from Slaughter house to a Trader or several Traders, then to Wholesaler who supplied a Frozen food producer who in turn supplied Brand products & Retailer own label products.

One major food group involved claimed problems with horsemeat contamination of their frozen beef products, which were again supplied to brand owners and major retailers, stemmed from buying meat from Poland via a wholesaler. If you look up these incidents you will see manufacturer quotes such as 'purchased these beef products in good faith'. One wholesaler involved was quoted as saying that it purchased the meat ‘in good faith’ and was ‘shocked and astonished’ to discover that equine content had been identified in products they had supplied.

As one columnist put it ‘Long business supply chains are corruptible and can hide a multitude of crimes if no one checks for fraud or criminal activity.’

It is difficult to gauge how long this type of food fraud had been going on and the extent to which the food chain has been breached in the past. As an example in April last year Dutch authorities announced that 50,000 Tonnes of meat supplied by two Dutch trading companies and sold as beef across Europe since January 2011 may have contained horsemeat. Both companies were owned by one man who had already previously been investigated by food safety officials. In total 500 companies in Europe were affected by the discovery.

During and after the scandal the food industry, particularly retailers and brand owners took some big hits from the media. The BRC itself did not come out unscathed either: The industry has previously boasted that it has full traceability of its supply chain which it audits frequently. The current scandal shows that that traceability is not worth the paper it is generally written on. Most of the factories caught up in the scandal have accreditation with mainstream auditing schemes such as that run by the British Retail Consortium but it failed to spot the problem.

The BRC clearly do not want to be ‘shocked and astonished’ by a repeat and with this in mind seem to have a focus on authenticity and integrity. Nowhere in the draft version 7 of the BRC Global Standard for Food Safety can I find ‘in good faith’ which, although nice, doesn’t wash when there are unscrupulous traders in the food chain. There is clear intent though to minimise the risk of purchasing fraudulent or adulterated raw materials and ensure that all product claims, descriptions and labels are legal, accurate and verified.

I'll go into detail about some of the proposed new requirements in a later blog.

Update 15 July:

GFSI have announced the GFSI Guidance Document with be updated to include requirements to prevent Food Fraud:

GFSI Position Paper on Mitigating the Public Health Risk of Food Fraud
PARIS, 15th July 2014

'In order to ensure transparency, the GFSI Board believes that the mitigation of food fraud is an integral part of a company's food safety management system, and has therefore decided to include new requirements specific to food fraud mitigation in the next full revision of the GFSI Guidance Document 7th Edition which will be released in early 2016.

The Think Tank recommends that two fundamental steps are taken by the food industry to aid in the mitigation of food fraud: firstly, to carry out a ‘food fraud vulnerability assessment’ in which information is collected at the appropriate points along the supply chain (including raw materials, ingredients, products, packaging) and evaluated to identify and prioritise significant vulnerabilities for foo d fraud.

Secondly, appropriate control measures shall be put in place to reduce the risks from these vulnerabilities. These control measures can include a monitoring strategy, a testing strategy, origi n verification, specification management, supplier audits and anti‐counterfeit technologies. A clearly documented control plan outlines when, where and how to mitigate fraudulent activities.'

Source GFSI here

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Thanks nice read. Do you think other standards will follow this like FSSC 22000?

Thank you for your comment.

I certainly think there will be more emphasis from auditors on product integrity and authenticity. ISO 22000 is generic with regard to it's requirements but does require as per clause 7.2.3 That when 'selecting and/or establishing PRP(s), the organization shall consider and utilize appropriate information [e.g. statutory and regulatory requirements, customer requirements, recognized guidelines, Codex Alimentarius Commission (Codex) principles and codes of practices, national, international or sector standards]'

ISO 22000 is overdue a revision but is a food safety standard that ISO seem not to want to infringe on ISO 9001 their quality management system standard.

It is more likely that the prerequisite programmes family TS ISO 22002 will be revised to include these requirements. For example for food manufacturers section 9 (Management of purchased materials) of Technical Specification ISO/TS 22002-1 Prerequisite programmes on food safety — Part 1: Food manufacturing could easily be revised to cover this area.

I am sure GFSI will look at revising the purchasing section of their guidance document for benchmarking food safety management system certification schemes and if they do all the leading schemes will follow.




Respectful thanks for your update.

Nice work Tony.

at last something I understand !:)..all the manufacturing stuff goes way over my head..nicely written tony ..its good to see the FSAI recognised ..they do a really good job here very proactive..the horsemeat scandal was a massive story here and still has a bad lingering odour ..however It all seems  to be about allergens now and our new labelling laws coming into effect from December...major panic with management , I wish we were more concerned with the basics ..food fraud to my mind can be a very parochial thing ...sure it will be grand , what they don't know wont harm them ..!!!! 

Professor Chris Elliott’s final report into the integrity and assurance of UK food supply networks has been published by the UK Government's Department for Environment Food & Rural Affairs today.


This has sparked the introduction of a new Food Crime Unit:


The UK Government has responded to Professor Chris Elliott's report into the food integrity and assurance of food supply networks:

'All of the recommendations in the Elliott report on food integrity and assurance of food supply networks have been accepted by the government, Environment Secretary Elizabeth Truss announced today.

This includes the establishment of a new Food Crime Unit, which the Environment Secretary said would strengthen consumer confidence in Britain’s high quality food'.

Today 2 Sisters have yet again, inadvertently, made the national press




This following on from last weeks Premier Foods fiasco.

Update from Issue 7 Released 7th January 2015


'The focus of attention for this issue has been on:
- continuing to ensure consistency of the audit process
- providing a Standard with the flexibility to include voluntary modules to reduce the audit burden
- encouraging sites to put systems in place to reduce their exposure to fraud
- encouraging greater transparency and traceability in the supply chain
- encouraging adoption of the Standard as a means of improving food safety in small sites and facilities where processes are still in development

FSA lamb takeaway survey finds undeclared meat in 21% of lamb takeaways

The Food Standards Agency has today published the results of its survey of undeclared meat in lamb dishes from takeaway outlets across the UK.

Of the samples tested, 223 (73%) were fully compliant with food legislation, 65 samples (21%) failed because of the presence of non-declared meat, 12 samples (4%) tested  positive for the presence of undeclared allergens, including peanut and almonds proteins, and 7 samples (2%) were non-compliant because of the unauthorised use of additives.

FSA lamb takeaway survey report

This is a response to an article in Which? published in April 2014 that claimed 40% of lamb takeaways tested contained other meat.

FSA welcomes horse meat sentencing

The FSA welcomes the conclusion of the first prosecution brought as a result of the investigation into the horse meat incident in 2013.

Peter Boddy was today fined £8000 at Southwark Crown Court after he admitted failing to comply with food traceability regulations. He had admitted to selling horses for meat but failed to keep proper records to show who bought them. David Moss was given a four-months suspended prison sentence for falsifying an invoice. They were each asked to pay costs of more than £10,000.

Jason Feeney, Chief Operating Officer at the FSA, said: 'We are pleased with the successful conclusion of this prosecution. The rules on food traceability are there to protect consumers and legitimate businesses.

'Criminal activity like this across Europe contributed to the horse meat incident. Consumers need to know that their food is what it says it is on the label. The FSA continues to support the ongoing investigations into the incident.'

In addition to the on-going investigation, the FSA and other Government departments have been implementing the recommendations from the Elliott Review into the integrity of the UK food chain.

This includes the establishment of the Food Crime Unit, which is giving greater focus to enforcement against food fraud by analysing intelligence, initiating investigations and liaising with other criminal and regulatory enforcement agencies. Andy Morling was announced today as the Head of the Food Crime Unit. He starts in his role this week.

Source FSA Website

Prof Chris Elliot: 'Willy Selton trades horsemeat for porridge (2.5 year's worth)'

More from rte.ie news: Horse meat trader jailed in the Netherlands

A Dutch court has jailed meat wholesaler Willy Selten for two-and-a-half years for selling horse meat passed off as beef during Europe's massive 2013 meat scandal.
"As boss of two companies he [Selten] was guilty of forging invoices, labels and written declarations and using these forged documents to trade meat," the court in Den Bosch said in its judgment.
Prosecutors in court papers said they have found 33 examples of false accounts, including at least one statement where meat was processed as "100 percent beef" when in actual fact it contained beef and horse.
In other instances, receipts were made up for meat deliveries that were never made, the papers showed.
Selten, 45, was arrested in May 2013 for allegedly selling 300 tonnes of horse meat labelled as beef during one of Europe's biggest food scandals.
Dutch prosecutors suspected Selten of major involvement in the continent-wide consumer outrage, prompting recalls of meat products from Ireland to Greece.
The horse meat scandal first erupted in Ireland and in Britain in January 2013, when it was found that frozen burgers supplied to several supermarkets including major retailer Tesco contained horse DNA.
Meatballs at Ikea stores, sausages in Russia and frozen burgers in Britain were pulled from the shelves by the millions as a result.
Dutch food and consumer watchdog the NVWA arrested Selten on charges of "false accounting and fraud" after a widespread probe in the Netherlands.
The NVWA then asked hundreds of companies across Europe supplied by Selten, who imported the horse meat from Ireland and Britain, to check their products.
Prosecutors said the horse meat was processed as beef at the company's headquarters in Oss.
In April 2013, Selten failed to quash a massive order by the NVWA recalling 50,000 tonnes of potentially contaminated horse meat that had passed through his plant.
Selten protested his innocence in an interview denying he deliberately passed off horse-contaminated beef.
"Beef cuts and horse cuts were stored in the freezer with the same article number," Selten told the Dutch ANP press agency.
"I forgot to give them different numbers and it's wrong what happened. Of course we should have exercised better control," he said.
Thousands of DNA tests on European beef products after the scandal revealed extensive food fraud across the European Union.

FSA in Northern Ireland welcomes Freeza Meats Ltd guilty plea to food fraud offences

A meat processing company has today been prosecuted at Newry Magistrate’s Court for a number of offences relating to serious food fraud. Freeza Meats Ltd, based in Newry, pleaded guilty to a total of twelve offences against the Food Safety Order (NI) 1991 and the General Food Regulations (NI) 2004.

They were fined a total of £42,500, as well as awarding £71,902.73 court costs and a £180 offender’s levy.

Newry Mourne and Down District Council brought about this court action against this company following a complex and lengthy investigation, supported by the Food Standards Agency in Northern Ireland.

Meat processor Freeza Meats Ltd was charged with twelve offences relating to:
Substitution of meat ingredients with cheaper product, ie hearts, and subsequently not declaring hearts as an ingredient on the label, therefore not only misleading a major supermarket retailer, but also deceiving customers.
Failure to provide on request by Newry & Mourne District Council information relating to whom they supplied meat products (traceability) on nine occasions.
Misdescription of product as Halal when non-Halal ingredients were used.
Obstruction of authorised officers by ‘knowingly providing false and misleading documentation’.


Source FSA NI