Food Safety Magazine, February/March 2013

MANAGEMENTare now keen to “keep the label clean”by eliminating such ingredients, therebyreinforcing the trend.Lastly, there seems to be an emergingtendency to treat even contaminants forwhich a maximum residue level has beenlegislated on a zero-tolerance basis. Thethinking behind this appears to be thatdetected levels may vary case by case,that the presence of a contaminant indicatesthe possibility that other samplesmight exceed limits and that a positivedecision to allow the product into themarket might in the end be seen as negligentand indefensible.Risk- or Hazard-Based:Does It Matter?The problem with the above examplesis not so much that people shouldbe forced to eat what they don’t wishto eat, or that food safety would benefitfrom lax rules and enforcement. Theproblems are inherent in the concept ofhazard-based food safety approaches, asthe underlying drivers are on a collisioncourse:• Analytical methodology becomesever more sensitive and selective. Thatholds for chemical as well as microbiologicalanalyses, in which recentadvances have shown that multiple,different strains of organisms couldbe detected where traditionally noneor only one would be found. On thechemical/analytical side, we will getever closer to the point where everypossible environmental substance canbe detected in every substrate. Anelegant example was already shown inthe 1980s, when low levels of BTEX(benzene, toluene, ethylbenzene andxylene) components were detected inolive oil, which caused great concern,mainly in Germany. Much negativepublicity resulted until it was proventhat the mere exposure of olives tothe exhaust fumes of normal traffic ata significant distance for a few days(essentially just storing the olives in ashack off road) would cause the levelsfound and that consumers would beexposed to higher levels of these substanceson a regular basis by filling up“Hazard-basedapproaches tend todevelop a runawayinternal logic that drivesdevelopments to theirlimits...”the gas tanks of their cars. Only thendid public concern fade away.• Allowing hazards to be designated onother than strictly scientific grounds,or pushing scientific requirements toallow for fast-track hazard designation,is helping increase the numberof hazards. Furthermore, these aversion-basedhazards have a tendencyto end up in the zero-tolerance categoryeither directly (GMO example)or indirectly (SudanRed dye example).Additionally, inmany countries, authoritiesmust nowbe informed aboutany noncomplianttest results—even ifthey are tentative orotherwise dubiousor unconfirmed.This obligation hasbeen implementedto prevent real issuesfrom beingcovered up ornecessary communication from beingdelayed, but in practice it oftenmeans that authorities will be underpressure to warn the public from thevery first moment a potential issue issuspected. Once a warning has goneout, there is, in practice, no way back.• As methodologies are continuallyrefined and more zero-tolerancehazards are added, noncompliant testresults can be expected to becomeever more frequent, leading to evermore “scandals,” recalls, feelings ofuncertainty in the general public andperfectly acceptable food being destroyedas if it were toxic waste. Thefeelings of uncertainty also typicallydrive calls to carry out more tests andat lower levels of sensitivity, turningthe circle ever faster.Hazard-based approaches tend todevelop a runaway internal logic thatdrives developments to their limits: forexample, the recall of Sudan Red-relatedproducts only on the basis of traceability.As the logic, once adopted, seemsimpossible to argue with, different approachesare normally only possible inan entirely different setting. The FoodStandards Australia New Zealand agencysaw things differently: “… the authoritybelieves that Australians are safe. For astart, because the amounts of the dye inthese products are so small, and becausethe link to cancer in humans hasn’tbeen proven, the overall risk to healthis small.” A similar pattern was seen inother cases—the BTEX controversy inolive oil was never asbig outside Germany.Solid risk-based approachesgenerally donot have this inherentlyinescapable logic.In addition, the ongoingpursuit of thesecases diverts effortsfrom more urgent foodsafety priorities—mostof which have to dowith implementingbasic HACCP/hygienemanagement systemsin the food chain—indeveloping as well as developed countries.The certification and general foodsafety awareness level for suppliers inEurope and elsewhere still needs improving,and significant work is required toraise standards.So What Can Be Done About It?The main goal must be to target ourfood safety efforts toward the preventionof actual harm. With the ongoinghigh incidence of foodborne illnessaround the world (the World HealthOrganization has mentioned 1.8 millionfatalities), most of which are expected tobe due to microbiological issues, thereis every reason to continue working onbasic hygiene and HACCP in our marketsand in other countries, where someof our products are grown, farmed ormanufactured.This includes ongoing training, certificationefforts and the developmentof analytical methodology to tracepathogens involved in outbreaks [onereason the German enterohemorrhagicEscherichia coli (EHEC) outbreak of 201130 F o o d S a f e t y M a g a z i n e