Food Standards Australia New Zealand (FSANZ) has released its
report on the September 2018 strawberry tampering incident in Australia where sewing needles were found in fresh strawberries by consumers. While acknowledging the timeliness of government response to the incident, the report highlights key areas for improvement in food incident response systems and processes.
In completing this report, FSANZ consulted with government and industry stakeholders. Communication, coordination, industry preparedness and product traceability along the supply chain were identified by these groups as key areas for improvement in food incident response.
Both government and industry representatives identified clear and consistent communication as a key area for improvement in response to food incidents. This is because initial communications to the public caused issues for the police and industry alike. Asking consumers to dispose of strawberries risked destroying potential evidence, and the naming of strawberry brands that were not part of the police investigation was "very damaging" to the industry.
The public response to the incident, especially copycatting and social media posting, was also unexpected. Government representatives identified a need for increased media training and communication expertise across industry and government to improve communication in the event of future food incidents.
Roundtable discussions convened by FSANZ highlighted how communication issues were exacerbated during the strawberry tampering incident by a lack of coordination between government agencies and the industry. As a result, industry representatives stressed the need for an incident management process and a well-funded national representative for the strawberry industry to assist communication and coordination efforts during food incidents, as well as to ensure the resilience of the industry.
Government representatives emphasised the need for a central incident spokesperson to manage public messaging and the need for improved operational relationships between government agencies, especially in relation to incidents which necessitate criminal investigations. The report notes that in New Zealand the Ministry for Primary Industries (MPI) and the police aligned public messaging in response to the three complaints involving exported Australian strawberries, commenting on New Zealand having good operational arrangements between MPI and the police following the 2014 threat to contaminate infant formula with 1080 poison.
Product traceability along the supply chain was also identified as a key issue in responding to and managing the strawberry tampering incident, as deliberate product tampering may have occurred at any stage of the supply chain. In particular, the fragmented and complex nature of the sector, lack of industry oversight and regulatory requirements, difficulties in monitoring seasonal work, and frequent co-mingling of produce along the supply chain were all identified as significant tracing challenges. The report accordingly suggests the introduction of lot coding and blockchain technology to improve and enhance traceability.
In consultation with government and industry representatives, FSANZ makes seven key recommendations in the report:1
All government jurisdictions should review their food incident protocols – in particular ensuring that formal linkages between regulators, health departments and police are in place for incidents involving intentional contamination.
When a food tampering incident occurs across jurisdictions, a central agency should be engaged to ensure national coordination of messaging and information associated with the incident.
Police should be included in national food incident debriefs when intentional food tampering is involved.
Triggers for activation and management of intentional contamination of food under the National Food Incident Response Protocol (NFIRP) should be reviewed by the food regulatory system.
A representative body for the horticulture industry is required to support crisis preparedness and response in the sector.
Traceability measures within the horticulture sector need to be strengthened. Government and industry should work together to map the current state of play and identify options and tools for enhancing traceability.
Work on traceability should include collaboration with research bodies and other stakeholders to evaluate technical and innovative solutions (including, for example digital track and trace technologies such as blockchain, along with other technologies such as smart sensors and packing) to improve quality assurance through the supply chain.
The release of this report provides an excellent opportunity for the food sector industry to review their food incident responses, both nationally and internationally, paying particular attention to communication and coordination strategies, potential supply chain vulnerabilities and industry preparedness.
Bell Gully's food law experts are available to help businesses in the event of a food contamination issue, including assisting with food incident responses, food recall protocols and responding to media enquiries. We are also able to provide advice regarding compliance with the Food Act 2014 and associated legislation and regulations. If you or your business has any questions regarding any of the issues raised in our article, please contact one of our team or your usual Bell Gully adviser.
This publication is necessarily brief and general in nature. You should seek professional advice before taking any action in relation to the matters dealt with in this publication.