chicken sashimi
20th October 2017

A joint investigation by ITV and the Guardian into the 2 Sisters Food Group Factory in West Bromwich revealed some pretty appalling activity including workers reportedly changing slaughter dates to extend the shelf life of meat. Yet when the Food Standards Agency(FSA) visited the premises shortly after these allegations aired, they found standards to be very good with “no evidence” of any breaches. This is not actually that surprising as the issues that were identified in the reports are examples of what may be consciously made decisions rather than a general failure of hygiene standards. As such, once the dirty laundry has been aired, it can be quickly removed from sight….at least until the next time an operator starts to feel comfortable and relaxes back into old habits.

Changing labels, re-using returned stock and mixing older products with fresh are all practices that require conscious decision making and choice; they are not accidental, neither are they issues stemming from a lack of awareness. Staff would have to be told to mix older stock with new or replace one old label with another, newer one and, as such, they are indicative of a poor food safety culture led by persons of authority, whether that’s lower, middle or upper management. Such a model is not one which will instil any confidence in the quality or safety of foods.

It is a very sorry state of affairs.

Of course it is entirely plausible that one maverick within the company has simply decided that in order to improve their P&L margin, they would implement such poor practices, however with the amount of external audits in place it’s likely that they would have been identified at an earlier stage. The company has said that nine audits took place in July and August 2017, five of which were unannounced.

A lot has been written in recent years about food safety culture. BRC Global Standards has gone so far as to create a food safety culture module to sit within their additional voluntary module offerings. The culture within a business sets the tone and the approach to safety. Many companies have shiny policies stating that safety is their priority – indeed following the ITV report airing, 2 Sisters stated “Hygiene and food safety will always be the number one priority within the business” – yet there is often an underlying problem that can result in system failures. People will always make mistakes and even the best systems are never really fool proof, however if food safety culture is not driven from the top of a company’s management structure all the way down through all aspects of the company then there are likely to be longer lasting failings which can, on occasion, result in issues such as those reportedly found here.

The FSA recently outlined its plans for the future of food safety regulation which discussed the use of third party accredited audits as part of either official controls or food hygiene rating scores.

Herein lies a problem.

Currently official controls are enforced by local authority Environmental Health Officers (EHO’s) and the FSA, which means there is no confusion, self interest or obvious discontent or mistrust from members of the public. Official controls are there to protect the public. By adjusting this approach to potentially reduce the number of official control visits paid to premises by EHO’s, instead relying on what may become announced visits and audits conducted to differing standards paid for by the food supplier, could lead to a significant decrease in public confidence in the scrutiny of such food suppliers by giving the impression that food safety controls are being watered down.

Third party audits are a very powerful tool. The standards set, including the BRC Global Standards, STS Codes of Practice, ISO 22000 etc. require a much higher level of compliance than official control inspections do. The principal behind this from an auditor’s perspective is that we generally work on a system of continual improvement against best practice. Presently these visits are largely announced, meaning that a company can prepare for them. This means that in those companies where scruples may be somewhat lacking, dubious practices such as those revealed in these reports can be put away for the time being and paperwork adjusted accordingly; the auditor then arrives at the planned date and time and finds a well presented and managed factory. Fast forward to a few days after the audit and other practices can slip back into use without fear of being discovered…

The BRC already has an unannounced scheme for audits which is a requirement for suppliers to certain retailers, including Asda and the Co-operative group. Here at STS we are moving to a completely unannounced scheme by 2020. Bearing in mind the move within the FSA proposal to consider the use of third party audits, it’s certainly my belief that any third party audits used in order to reduce the number of official control visits MUST be of an unannounced nature in order to give some element of confidence in the system.

2 Sisters is a very large player in the food supply chain so it’s not at all surprising that this story has garnered so much coverage. Parliament has announced that there will be a review into food safety practices and the role and performance of regulatory and accreditation bodies, hearing evidence from the CEO of 2 Sisters, the FSA, Assured Food Standards and the British Poultry Council. Quite what difference this will make, or the evidence that the enquiry will find, will become clear on 25th October but it is safe to say that we will be watching and listening carefully to find out the potential ramifications of these allegations on the poultry sector and, indeed, the wider food chain.


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