Alec Kyriakides and Denis Treacy are on hand to answer delegate questions from the Food Safety Innovation Conference 2024.

One of the most popular segments of the Food Safety Innovation Conference 2024 had to be the Q&A session. Giving delegates the opportunity to have their questions answered by industry experts, this portion of the day was packed full of brilliant information and actionable takeaways. So much so, the segment ended with an additional list of questions in need of answering.

And who better to do this than central figures: Alec Kyriakides and Denis Treacy?

Chair of the conference, Alec is the former Head of Product Quality, Safety & Supplier Performance at Sainsbury’s. He returned for the second year running to deliver a presentation on Food Safety in the last year.

Drawing on his experience as the former Chief Officer for Safety and Quality at Pladis Global, Denis chaired the FSI’s afternoon panel session – sharing his own thoughts as the panel discussed the key learnings of the day, along with the best strategies for tackling future food safety challenges.

Now, Denis and Alec have come together to answer the remaining delegate questions. There is valuable guidance in each section, but you can use the links below to skip to the question that best relates to your operation.

You can also click here to jump to the questions from the Morning Q&A and click here to jump to the questions from the Afternoon Panel Session.

Attracting Young Talent

Q: What innovation is planned to attract young talent to Food Safety roles?

Denis Treacy

The food industry has struggled for decades to attract young talent into roles across the board. As we all know, life in the supply chain can be as tough as it is rewarding, so for many, it is not an attractive career choice.

Together with the formal academic routes, we are hopeful that increasing investment in vocational training and apprenticeships is a serviceable route to such careers. Organisations such as the IFST are also big champions of supporting routes from education into food supply chains.

Alec Kyriakides

Individual businesses in the food supply chain, trade associations, and academic institutions all have a role to play in working with the educational sector to promote careers in the industry. There are many initiatives linking individuals in all of these sectors with prospective candidates in schools and further education colleges throughout the UK.

It is also incumbent on food businesses and the wider industry to develop jobs and career paths that can be truly fulfilling and rewarding for individuals to ensure that we not only attract but retain the best talent to help our industry thrive now and in the future.

Supporting Smaller Businesses

Q: How do we ensure Food Safety information and support is more accessible to smaller businesses?

Denis Treacy

There is a wealth of information already available to food producers of every size, prepared by organisations, local authorities, and industry experts.

The best route to this information is through supporting networks such as trade bodies, The FSA website, and food organisations such as the IFST, CIEH, and the FDF. You should also explore the brilliant information and links provided by business partners such as Klipspringer and FoodClean. It is worth noting that all of this information is free to access.

Alec Kyriakides

The challenge is making sure smaller businesses are aware of the information available. Then, it is a case of the businesses having sufficient time and resources to access, read, understand and apply their learnings.

From Trade Associations to Local Authority Enforcement Officers (i.e. Environmental Health Officers), all of the organisations interacting with smaller businesses have a critical role to play in making them aware of the available resources. This responsibility also falls to auditors.

Food Safety Risks of direct-to-door meals

Q: With an increase in direct-to-door meals being ordered online, how do you feel about the potential food safety risks of the delivery systems?

Denis Treacy

The risks surrounding food that has been sourced over the internet are as serious as those related to medication.

Thankfully, UK-based, online food retailers are still subject to the scrutiny that is faced by other food producers. The reality is, we will probably have to increase and adapt that focus as a result of the ‘lessons learned’ from failures and issues.

Alec Kyriakides

Food delivery represents a large and increasing proportion of grocery and hospitality sales. However, this is a very broad sector with differing risks. Ultimately, the onus rests with food business operators to manage the risks through the application of established food safety management approaches – underpinned by HACCP.

In the most part, this operates really well in the UK, but I can see the real challenge being how regulation and enforcement can keep pace with a sector that is rapidly growing in size, complexity and stealth.

For more information, the FSA provide very useful guidance on the requirements for food businesses selling food for delivery.

Inspiring Front Line Operators

Q: How do we make Food Safety relevant to front line operators through the end-to-end supply chain, without diluting the importance of the message?

Denis Treacy

Food Safety is a simple outcome of an activity. In order to ensure that it is a repeatable and predictable outcome, an operation must be fully risk assessed, the controls clearly identified, and those who are charged with executing that process must be competent and appropriately trained to follow clear and unambiguous processes.

When it comes to energising and motivating operators at every level to deliver repeatable and reliable outputs, the trick is to make the ‘right way, the easiest way’, which will avoid following a path of least resistance. This needs to be supported by a work environment that encourages and rewards following a process, delivering required outcomes, and celebrating improvement observations. In contrast to a work environment that is littered with workarounds, concessions, contradicting views, variable choices, and personal preferences.

Alec Kyriakides

It is also essential that good practice is continuously recognised and reinforced under the principle of ‘what gets measured, gets done’. For example, if a manager pays no attention to food safety practices when observing or talking with colleagues then there is a danger that individuals will come to believe such practices are not important. Likewise, if concerns raised by colleagues about food safety compliance challenges are ignored, non-compliance may be implicitly endorsed.

Unannounced Audits and Employee Wellbeing

Q: The benefits of unannounced audits are clear. However, more often than not, it is the QA team leading the audit and this can take its toll on their mental health. Do you predict any relaxation of unannounced pressures in the future?

Denis Treacy

As the need to secure risk grows, the consequence of failure becomes more impactful, and the cost of insuring food supply chains increases, it is likely that the auditing of supply chains will be increasingly unannounced and out of hours.

The impact this has on the wellbeing of the staff involved should be a matter for the business being audited, and those who do put undue pressure on one small section of staff will inevitably enjoy less successful outcomes than those who collaborate internally – sharing the burden of such challenges across wider functions, as should be the case.

Alec Kyriakides

The challenge here is a cultural one. No-one should fear an unannounced audit as every business should be audit ready 365 days of the year. The issue is that auditing has now become synonymous with a ‘right of passage’ for the business with their customer. As a result, the perceived stakes of ‘failing’ an audit have become high.

However, the audit is actually a mechanism to support the delivery of an effective food safety management system – providing an independent assessment of a food business in their implementation and compliance to their food safety management system.

So, in reality, audits should be used as a mechanism for continuous improvement in food safety management. But all too often, they are viewed as a box that needs to be ticked in technical/commercial relationships between businesses. There needs to be a reset in the way audits are being used in the industry to avoid this ‘pass / fail’ culture and the false ‘pressure’ it creates. We need to move towards a more progressive use of auditing as part of continuous improvement.

Developing Predictive Modelling Tools

Q: My question relates to the impact of climate change, specifically regenerative agriculture and the effect on crops. Are businesses considering, or already developing, predictive modelling tools to understand and react to future hazards?

Denis Treacy

All businesses should consider all threats to operational delivery at a strategic level. This should ideally be chaired by the head of the business and driven by a Multifunctional Risk or Oversights Committee which considers both strategic and operational risks – including materials sourcing – along with the indicators and controls needed to mitigate these risks.

Modelling of such risks is an option to consider and the outputs included in any control measures, but this is not the only consideration. There are now businesses – such as Agroknow – using AI enhanced modelling to provide as much information as possible, in order that the ‘Risk Committee’ of a business can make as informed strategic decisions as is currently possible.

Alec Kyriakides

It is also important to recognise that many of the risks associated with climate and agricultural practice are entirely predictable, but may just occur more frequently. For example, climate change may bring a greater propensity for higher rainfall events in certain areas, but we already know that this results in an increased risk of the spread of enteric pathogens from land to crops.

Consequently, we need to implement measures to mitigate risks that we already know about, whilst also working in parallel to predict new and emerging risks that climate change and different practices could bring our way.

Food Safety & Collaboration Across Retailers

Q: There has been a lot of discussion of collaboration across retailers. What forums are in place to enable active participation from all retailers?

Denis Treacy

Definitely one for you Alec – for my part, there are a few retailers who actively encourage collaboration across their own supply chains, creating forums for shared learnings, discussion, and workshops. This should be actively encouraged for the good of the reduction in risk to all consumers.

Alec Kyriakides

Retailers are subject to strict anti-competitive rules, but collaboration on food safety matters does happen and has a long history of bearing outcomes of general benefit to the supply chain.

Industry bodies such as the British Retail Consortium provide a forum where retailers can collaborate on sectoral issues, and other bodies such as the Institute of Grocery Distribution allow for cross-sector collaboration between all parts of the food chain.

It is also possible for sector and cross sectoral groups to be formed to address common industry challenges such as the Food Industry Initiative on Antimicrobials and the Food Industry Intelligence Network. In relation to specific policies such as food safety management standards and associated audits, most retailers accept GFSI-recognised schemes such as BRCGS Global Food Safety Standard as a baseline, although many have additional policy requirements, ‘bolt-on’ audits, or their own additional audit.

It has always been the hope that individual retailer requirements could, in time, be incorporated into GFSI-recognised schemes, and each scheme does seek input from retailers and the wider supply chain as part of working groups formed to review each updated version of their respective food safety standards.

The Morning Q&A Session

Is the drive within the food industry to be more sustainable and efficient making food safety easier or harder? 

Maddy: The ideal would be that food safety becomes easier. Ultimately, as we look to become more sustainable and efficiently effective in our approach, we should be embedding food safety within that. We need to understand where those risks and opportunities present themselves, so we go in eyes wide open.  

Is there a plan to make BRCGS START! a recognised programme of the GFSI? SMEs are asked by retailers to be GFSI recognised, but it can be a stretch to meet the expectations of the BRCGS Global Food Safety Standard, Issue 9.

Lalaina: I think it’s important to remind ourselves that the GFSI recognition process is a voluntary system. We invite people to come to us for recognition with the certification programme they own, but we do not impose that.  

Where there is a desire to go through that process, we will consider every application. If successful, that will lead to GFSI recognition. 

In terms of the gap between BRCGS START! and Issue 9 of the BRCGS Global Food Safety Standard, again it is down to the CPO to decide how they want to position that product. We are open to considering every application submitted to the GFSI for recognition.  

Alec: Just in terms of my understanding, from a Global Markets perspective, BRCGS START! is an entry-level tool to help people, but there is no intention for it to be some form of recogonised standard.  

Lalaina: As to my knowledge to date, it is not a certification programme.

How can we better share the root causes of allergen recalls to aid improvement by all manufacturers? FSA recall notices often only give an allergen recall reason (e.g. incorrect coding, an artwork mistake, or cross-contact), but more details could support an in-depth root cause analysis.  

Rebecca: In terms of the recall notices, I will pass on your feedback to the team. But, as you can imagine, there are limits to the amount of detail we can go into, as we need to make sure the information we provide is accurate and appropriate.  

Even so, the broader message behind your question is absolutely right and reflects what we want to do. We want to share the root causes of incidents with you so that you can also learn from them.  

Alec: As chair of the board Rebecca mentioned in her speech, one of our primary intentions is to do what this question gets to the heart of and that is to pick some really good examples that we can share as case studies. This will allow you to get into the real depth of what went wrong and what mitigations could be put in place to prevent the same thing from happening again.  

With Arla being such a large company with lots of sites and people, do you find it challenging when changing and embedding new culture? How do you overcome this?

Rob: It can be a challenge. For example, we have sites across different countries, so there are inherent cultural differences to consider.  

In terms of rising to the challenge, at Arla, we have a saying: ‘Freedom within a Framework’. So, if we’re launching something new as a central team, we consciously avoid telling our wider team exactly how to do something. We will tell them what we want to launch, but we give individual sites the freedom to identify the way forward that works best for them.  

Why are Germany’s food safety recall results different from other countries? 

Alec: This is because different regulatory regimes focus on different elements of food safety hazards. Most people would recognise that Germany places a lot of emphasis on chemical hazards. So, when you look at their official testing programmes, they have focused very heavily on the areas that drive recalls. In short: ‘when you look you find’.  

Will there be a requirement for unannounced audits to become mandatory as part of your review of benchmarking and harmonisation?

Lalaina: This is covered under various requirements which ask that certified sites are audited at a set frequency or that the COP contacts a member of the certification audit to a set ratio. This is a target that certified sites have to meet in order to be aligned with GFSI requirements. 

However, you can rest assured that there is no intention for all audits to be unannounced.  

The Afternoon Panel Session

Food Fraud is on the increase, which ingredients do you think are most at risk over the next 12 months?  

Simon: A lot of this is driven by pricing. For example, cocoa prices are at a record high and the price of sugar has also increased. It will also come down to how easy it is to hide one substance within another. We work very closely with our procurement teams to consider everything from failed harvests to fluctuations in price.  

Denis: I’ve worked with Food Standard Scotland to develop a Risk Assessment model. At no charge, you can go online and complete a Food Fraud Vulnerability Assessment. During this process, you challenge yourself against forty statements and as a result, you receive a unique profile that highlights the areas where your business is vulnerable to Food Fraud.  

In terms of sustainable diets and the push to reduce high fats, salt, and sugar, what are your views on the fact that most replacers for allergens are ultra-processed foods? Also, what is the potential microbiological impact of using such ingredients?

Maddy: As it stands today, there is no legal definition for ultra-processed foods, so we need to be mindful of this when it comes to customer understanding and the potential for misinterpretation. This is especially important when you consider that some ultra-processed foods, such as bread and baked beans, provide a lot of nutritional benefits for a high percentage of the population. It’s a complex space and I think we need to work together to navigate it.  

What are your views on Precautionary Allergen Labelling and the restrictions it places on allergy sufferers?

Simon: There’s this idea within the industry today that if you put a PAL statement on a product, you are covered.  

At the moment, there might be a PAL statement because someone has carried out a thorough risk assessment, but equally, there might be a PAL statement because there wasn’t a risk assessment at all – I think we need this to be regulated. We have done a lot of work with Anaphylaxis UK and, talking to their members, we know that 30% take risks when it comes to PAL statements.  

Is there a drive to standardise retailer codes of practice?

Maddy: Speaking on behalf of myself and the team at Waitrose & Partners, we don’t want to add any unnecessary complexity to your lives. We are very aware of the sheer number of demands you have to comply with.  

So, there’s a real opportunity to make sure that where there is a common ground, we can rely on standards that can drive simplicity within the industry.  

We will always have our nuances as individual retailers, but where we can, we should be making things easier in terms of compliance and understanding. 

When it comes to legislation surrounding contaminants, microtoxins ect... what do you think about the potential impact of divergence between the UK, EU, and even within the EU?

Simon: We have a unique opportunity to regulate precautionary allergen labelling. We’ve now got sufficient clinical data to be in a position where we can set safe thresholds, so why not lead the way on this and prove to the rest of the EU that this is a science-based approach? Let’s view this as an opportunity to get rid of the tons of precautionary allergen labelling we currently see. 

Maddy: In terms of pesticides, there is an annual report taking place at the moment, and many of us are collecting data to publish.  

One thing I would say is that it’s not just about what we’re doing here in the UK, but it’s also about the countries we source from. We need to be aware of the changes they are making, especially when we face challenges in terms of the climate and what pesticides we can use. Ultimately, we need to be up to date with legislation, but also driving it forward in regard to what we should and shouldn’t be using.  

A final point is that transparency is key. If not today, at some point in the future, it will be an expectation from our customers in terms of what we are using on our crops.

What do you think about the potential of AI when it comes to using historical data to predict future incidents?

Rob: I think there is massive potential. One thing that comes to mind from today’s workshop on AI is that it doesn’t have to be perfect, it just has to be better than what we can do independently. I think there is a massive potential to use AI to pick out the trends that we can’t see and analyse the amount of data that would take someone a year to work through. I think it’s about starting with the simpler aspects, but ultimately, AI needs to help us look back at historical events in the hopes of preventing similar incidents from occurring as we move forward. 

Maddy: There is a massive data lake of information that we are all trying to make sense of, but it is worth remembering that there are already businesses who have taken this data and provided really helpful insights. A lot of the heavy-lifting has been done, so it’s about turning our focus to the ‘so what?’ learnings, instead of reactively looking at data on an individual basis. 

Simon: We are all looking at digital quality and how we can get better at predicting the next big thing. For us, it’s all about identifying what we might have in our business that could suggest we have an issue with one of our own manufacturing plants or with one of our suppliers. We are currently identifying those key data sources: quality notifications, absentee levels ect… We are then looking at different modelling solutions that incorporate generative AI to help with that effort.  

Reineke: AI can also be used within the industry to make life easier regarding food production and the end-of-life waste stream. For example, it could help your site to ensure waste materials are recycled properly instead of going straight to landfill or incineration.  

So that brings us to the end of this informative Q&A. A huge thank you to Denis and Alec for taking the time to answer each question in such detail. And of course, a huge thank you to the expert speakers and panellists highlighted throughout this article.

If you have any further questions relating to Food Safety, the Klipspringer team would be happy to provide support. You can contact us on 01473 461800 or Alternatively, you can use the form below to arrange a free consultation.  

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