No Food Standards Agency (FSA), local authority or private third-party audit of the plant would have been likely to pick up the hygiene failures identified by the investigation carried out during August at the factory by The Guardian and ITV, they claimed.
Contrary to suggestions from some commentators, the problems exposed by the undercover press investigation could only be avoided in future by having the correct food hygiene culture – together with appropriate whistleblowing procedures – at the West Bromwich plant, claimed former Food FSA head of local delivery John Barnes and third-party hygiene auditing expert David Edwards.
These were apparently absent at the 2SFG factory, they added. “The standards and practises shown in the footage [from The Guardian and ITV undercover reporting] are clearly unacceptable,” said Barnes, who is now a director with food safety consultancy Enmoore.
In a letter to The Guardian last Monday (October 2) following the reports of slaughter dates allegedly being illegally altered and other unacceptable hygiene activities at the 2SFG West Bromwich plant, Professor Emeritus Erik Millstone suggested the undercover footage from the factory, demonstrated why cuts to FSA and local authority funding and moves under the FSA’s Regulating Our Future (ROF) programme to greater reliance on industry third-party hygiene audits would jeopardise food safety.
But Barnes and Edwards disputed this argument.
“While I fully support the continued need for properly resourced public agencies, it is incorrect to imply a regulator would be any more able to detect these types of failings than independent auditors working for accredited assurance bodies,” said Barnes.
“This is evidenced by the failure of the FSA to detect the issues both during their routine, unannounced inspections and audits of the plant prior to the incident and in their subsequent investigations when they were provided with the footage.”
Barnes suggested the problems more likely reflected “a failure of culture at the plant”. They are better identified and addressed through an intelligence-led, targeted and investigatory approach, rather than via routine or increased regulatory inspections or audits, he added.
More effective whistleblowing
“Key in this case are [the need for more effective] whistleblowing policies and training at the company or via the FSA’s own whistleblowing hot-line,” Barnes argued.
“Some have used this incident to criticise the FSA’s ROF programme,” said Barnes. “However, I do not see the ROF changes being about reducing regulatory resources and replacing official inspections with self-regulation as some critics are suggesting.
“It is about regulators making better use of current industry assurance and compliance data to target the public resource – a co-regulatory model. Whatever the level of public resource, this makes sense.”
Barnes added that incidents like this, however, demonstrated the continued need for strong national and local regulators and proper checks on any private assurance that potentially might be taken into account by regulators to target their own activity, to ensure it is robust, independent and trustworthy.
“Anyone with auditing experience would understand that the sort of practises that appear to be evident at the 2SFG West Bromwich factory would not in all likelihood be picked up by a routine inspection, whoever undertook it – even one that was unannounced,” claimed Edwards, a director at food hygiene consultancy Bayesian and formerly with international third-party auditing specialist CMi.
“In situations like this the staff involved are likely to know full well that what they were doing was unacceptable – even illegal – and, as such, would be removing all evidence of the practise while the visiting inspector is signing in at the reception.
“What is wrong is a company culture that supports organised behaviours like this.”
Edwards called for a different sort of assessment in situations like this; “something quite different from an audit that takes a much closer look at wider issues”, such as productivity targets and margin pressure that could drive such behaviours. He also called for more effective whistleblowing procedures that were simple to use, anonymous and routinely tested.
Meanwhile, read why one industry insider told FoodManufacture.co.uk the undercover investigation raised questions about the calibre of 2SFG’s management.