Scottish Food Enforcement Liaison Committee – 5 December 2014

15 attendees included EHOs and reps from SFDF and Scottish a Bakers.

Under matters arising from previous meeting – Are you ready for new Labelling regulations, ML commented that there was nothing online to advise businesses and EHOs of the current approach. This is causing problems for both business and enforcers.

It was considered at the previous meeting that the best approach is to be “pragmatic and reasonable” going forward, highlighting that there is a problem with the labelling and that this will take time to change. Comment that the new regulations will be unenforceable for some time to come.

It was confirmed that a similar committee to SFELC will exist after FSS comes into being in April 2025. Suggestion that the name SFELC should remain the same but with slight updating of terms of reference. Geoff Ogle and Ross Finnie will be invited to the February meeting.

New Food Body update
Lorna Murray reported. Stage two of bill is complete, stage three expected 9th December and on track. Development of the brand is underway (SFMTA have been included in consultations). Website that is fit for purpose is under construction. Nutrition will return to the FSS website. Domain name will be fss.gov.scot. Still a working title because Ministers have the right to change the name. Chair (Ross Finnie) and CEO (Geoff Ogle) have been named (seven board members are sought and have been interviewed). Vision and Mission Statements will be ambitious but achievable. Future structure/team is under consideration. Move to new office will be to the new Aberdeen office. Budget has not yet been set because of negotiations on transfer of responsibilities.

Better Regulation Update
FSS will build on experiences in England.

FSA Private Water Supply Consultation
Guidance is currently out for consultation. NFUS are being involved. SFELC felt that the guidance was helpful.

Food Standards Sub -Committee
Satisfactory survey reports were received for Bakery products and Bacillus Cereus

Food Standards Agency in Scotland
New minister, Maureen Watt was being briefed that date. 1146 establishments now Eat Safe. Campylobacter campaign had been successful on a minuscule budget using social media.

UK FSS draft report on sampling priorities
Update was given by Lynne Howat of FSAS

There had been a history of sampling emphasis on imports but there had been an increase in UK produced products. Microbiological testing and training for pathogens. Failing had a trend of revealing failures in meats from Poland. Surprisingly no real increase on testing for substitution. Mince and sausages viewed as potential. Carry over would be tested at a level of more than 1% but accepted that in butchers shop situations there would only be concern if the substitution was felt to be blatant.
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The following recommendations are made by the SSWG for food sampling and surveillance activities in Scotland between 1 April 2015 and 31 March 2016:

The food sampling data presented in this report was reviewed by the SSWG at their meeting on 19 November 2014. The findings were considered in conjunction with information collected from FSA's emerging risks programme, and local intelligence provided by SSWG members to develop a series of recommendations for food sampling and surveillance activities in 2015/16.

The following recommendations are made by the SSWG for food sampling and surveillance activities in Scotland between 1 April 2015 and 31 March 2016:

General sampling focus
The results of sampling during the period reinforce the importance of effective sampling plans as important components of each local authority's food safety enforcement toolkit.
Local authorities should continue to operate sampling plans which mirror the profile of their premises and which support authorised officers during their routine food safety and food standards inspections.
It is important that sample failures continue to be followed up by local authorities and that those contraventions are pursued in terms of each council's enforcement policy.

Specific sampling priorities
As part of their sampling plans local authorities are encouraged to prioritise the undernoted topics. In line with the Scudamore recommendations, FSA will seek statistical advice to determine an appropriate sample number to be collected nationally for each topic with the suggestion that these are divided amongst the local food liaison groups who can then allocate and monitor sampling within their areas.

Microbiological quality of imported foods
This year's data indicates that the percentage of unsatisfactory samples is no higher for imported foods than UK sourced foods. However, Listeria monocytogenes was identified in a number of samples of food from a variety of countries. Focussed sampling of ready to eat imported (EU and Third Country) foods, including Listeria examination, would allow any trends to be investigated.
Microbiological quality of herbs and spices used by caterers
Examination of data on UKFSS shows a continuing issue with the microbiological quality of some samples of herbs and spices, however there is limited data available for these types of products. Sampling would be targeted at catering premises. The intention would be to collate information on the quality of herbs and spices intended for addition to ready to eat food.

Meat substitution and use of additives by caterers
Meat substitution and the use of colours are current sampling priorities for 2014/15 sampling plans. It is apparent that failures continue to be identified and targeting should continue. It is also apparent that sampling for monosodium glutamate has reduced in recent years and increased sampling would allow compliance, and any need for further engagement with the trade, to be assessed.
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Emerging and local issues
SSWG discussed a number of topics which were considered to be emerging or to affect limited, or localised, groups of premises. In each case there is no, or very limited, sampling data on UKFSS.
FLGs and local authorities are asked to consider whether the food business profile in their area would merit sampling of the following products. No sampling targets are recommended by SSWG.

1. Campylobacter in rare duck and other game birds
Campylobacter is a known risk in raw and undercooked poultry however evidence is lacking on the risks associated with duck and other game birds. Intelligence gathered at local level has indicated that it is increasingly fashionable for restaurateurs to offer these products rare or “pink”. Sampling of raw and cooked birds would provide useful data.

2. Microbiological quality of rare burgers
Evidence for the increasing market for rare burgers, coupled with reported cases of foodborne illness that have been linked to undercooked burgers have suggested that this could be an emerging area of food safety risk in Scotland.

3. Microbiological quality of sous-vide food
Recent years have seen an increase in the number of sous-vide foods being cooked at low temperatures (e.g. 42°C to 70°C). There is a lack of information for pathogen growth and thermal death models in the range of about 40° to 60°C. This makes it difficult to assess the safety of these new sous-vide foods that are cooked in a water-bath at around 50° to 70°C.

4. Fat content of minced meat
The EU Food Information for Consumer Regulations introduces standards for fat and collagen content, as well as labelling of minced meat. The Scottish regulations take advantage of a derogation relating to the labelling of minced meat.

Meat substitutions 1% carry over tolerance creates real difficulty in businesses where work multi species is handled.

Concern raised that Ecoli O157 testing is not popular (because of costs to local authorities) and there is evidence of more non O157 Ecoli. Proposal to include more sampling of this going forward given the prevalence of O 157 in Scotland. There would be a real difficulty of collecting samples of rare duck, rare burgers and sous vide produce.

The review of the Sampling programme is to create better value for money and to deliver the best results.

SFMTA described the support given on Allergen advice to all 440 butchers shops and farm shops in membership.

Carrier bag charge in relation to food safety risks. Committee made aware by SFMTA that possible mass disobedience by independent butchers. Suggested SFELC discuss this with David Barnes at Resource Efficient Scotland.

Date of next meeting: Friday 20 February 2015.
Venue: Glasgow Novotel Centre