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Verifying traceability; MSC certified seafood passes the test
The Marine Stewardship Council (MSC) has published a report describing the results of a DNA survey on MSC certified fish from 16 countries.
Businesses that handle MSC certified sustainable seafood are required to comply with the MSC Chain of Custody Standard to ensure that they have effective traceability systems in place. This helps to ensure that the consumer receives fish that are from sustainable fisheries, as promised by the MSC sustainable seafood label. MSC conducts a survey every two years to verify the effectiveness of the standard and to ensure that distributors, processors and retailers trading in MSC certified sustainable seafood are complying with the standard.
The results of the latest survey are really positive. The MSC sampled fish and fish products carrying the blue MSC certified label from 16 countries. Of the 256 samples tested, only one of those was identified as being mislabelled. Upon further investigation MSC found that the mislabelled ‘Southern rock sole’ was in fact ‘Northern rock sole’; it was an accidental misidentification of two closely related species, rather than a deliberate fraud. So it seems that the MSC Chain of Custody Standard is working really well across the world.
Interestingly, the final pages of the report include a discussion about how the results compare with similar surveys conducted by other organisations. Those other surveys included species testing of many fish types, within many countries, mostly from retail outlets. The levels of mislabelled fish species were generally low in Europe, with more than 90% being of the samples being accurately labelled. The only countries that had less than 70% accuracy were Belgium, USA, South Africa and Canada. Sadly, the Canadian results were the poorest, with less than 60% of samples in that survey being accurately labelled. The Canadian results were also the oldest, being from 2011, with most of the European results from 2015. Perhaps seafood labelling in Canada has improved in the last five years, just as it has in Europe.
Fish mislabelling; malicious fraud or sloppy supply chains?
Nice one, Food Standards Scotland.
What looked at first to be a number of cases of deliberate fraud was given some sensible attention and analysis by Food Standards Scotland (FSS), with unexpected results. The organisation surveyed fish products supplied to their public sector food outlets, including hospitals and schools, to get a snapshot of the degree of species mislabelling. Of the 264 samples tested, around 6% of those (15) were mislabelled.
Any mislabelling is a breach of trust and a breach of food laws, but a result of 6% is relatively low and not likely to have a large economic impact. Nevertheless, FSS investigated each of the incidences, retested products and spoke to the suppliers directly.
Product labelled as haddock was the type most often found have been mislabelled during the survey, with ‘haddock’ found to be another fish species in 8 of 50 samples (16%). As you would expect when considering fish species fraud, the most common substitute for haddock was a cheaper fish, whiting, the two types of fillets having similar appearance, flavour and texture. Interestingly, however, almost half of all the ‘fraudulent’ samples were in fact an expensive fish (haddock) mislabelled as a cheaper species (whiting or coley). Those results are obviously not ones you would expect to find when investigating fish fraud, and they are unlikely to be the result of any deliberate attempt to gain an economic advantage.
To the credit of the FSS they uncovered the cause of the mislabelling for most of the incidences; suppliers of the mislabelled fish admitted that they sometimes had trouble identifying incoming block fillets. Some also admitted that they were not adequately separating or labelling different fish species during processing, handling and packing operations. The suppliers in question have implemented improvements and have requested better labelling of their suppliers to prevent future occurrences; good news for the Scottish seafood industry.
Traceability myth #3: Traceability equals authenticity
Traceability in the food supply chain leads to authentic food: it’s a myth. In this third and final look at common misconceptions about traceability, I examine the links between traceability and authenticity of food.
Traceability can be difficult with a complex food, but it’s not impossible. At the simplest level it is about knowing where every ingredient in a food product has come from and being able to identify the ingredients in each batch of your product to their own individual lots. If you are a food business that has managed to achieve a transparent supply chain then in addition to basic traceability you will also know the sources of each of your suppliers and their suppliers, resulting in a ‘trail’ that leads all the way back to the farm or fishing boat.
Knowing where your ingredients have come from and being able to trace them back to your suppliers is a great start when it comes to protecting the authenticity of your finished product. Knowing more about your supplier’s suppliers can also give a food business peace of mind when assessing the risk of receiving fraudulent materials. Unfortunately, though, even within a completely transparent supply chain there can be opportunities for fraudulent adulteration, substitution or misrepresentation of food materials.
Take for example a bottle of virgin olive oil on the shelves of an inner city specialty grocer; the retailer purchases from a wholesaler who has a direct relationship with the olive processor which processes olives for a collective of farmers from a small olive growing region. It’s a short supply chain and very transparent. The retailer knows exactly where the oil comes from. But that does not mean that the retailer knows what was going on at the oil processing facility. Perhaps the most recent local harvest was very poor, perhaps the processor was under financial stresses and was tempted to dilute the pure local oil with cheaper bulk oil from another region or country. Maybe the wholesaler was tempted to switch labels on some of his olive oil ranges to increase his profits… Each of these scenarios result in fraudulently adulterated, diluted or substituted product. If the retailer is selling the oil with regional provenance claims, organic claims or claims about special grades or standards of oil and the oil has been adulterated, diluted or substituted he is then unwittingly committing food fraud himself. It’s an unpleasant scenario, and one that is unfortunately common.
Transparency has many benefits to supply chain management, and can provide some assurances against food fraud but it does not automatically guarantee authentic food ingredients and food products.
Traceability myth #2: Traceability is expensive
My recent article Traceability myth #1 ‘Consumers want transparency’ discussed how consumer attitudes to transparency are positive, but may not have much affect on purchasing decisions.
Traceability myth #2 explores the myth that traceability is expensive for food businesses. This myth is based on the belief that traceability can only be achieved through the use of specialised business software. Let’s explore this myth in more detail.
Specialised business software is expensive but it is not the only way to achieve traceability. Traceability is the ability to access information about all the ingredients of a food product down to the individual batch or lot of the ingredient, to understand the disposition of all the ingredients and intermediate materials within a production process and to know where the food product went after it was manufactured. The information should be accessible to the food business and able to be retrieved within four hours.
Why is traceability important? Safety of consumers is the number one reason for traceability; it allows fast and effective recall of food products that have been affected by unsafe raw materials or improper processing. Every food safety management system standard includes requirements for traceability. Traceability can also be a huge benefit to market access; put simply, if you have robust traceability systems in place, more retail and food service customers are going to be willing to purchase your foods. Thirdly, traceability comes with huge cost savings in the event of a recall or withdrawal situation; a food business that can accurately trace affected product down to individual lots can save huge sums of money by recalling only those lots that are affected. This can also have a positive affect on insurance premiums.
How to implement a traceability system without using expensive software? The most important thing you will need is a traceability ‘champion’ who is dedicated to the task and who has the support of top management. As the system is implemented it is this person who will check that things are working as they should, that information is being recorded and that their colleagues in the business understand the process and the reasoning behind it. A good first step is to start by editing production record worksheets, such as batch sheets and packing sheets and adding spaces to record a number or code that will identify each lot of finished product and intermediate product. This code should ‘follow’ the lot through the production process, any quality checks and all the way to dispatch. It should be able to be linked to the best before or use-by date on every pack; this can be done with a simple batch number book that contains a list of unique numbers and space to add date of manufacture, product and (afterwards) final disposition of the lot next to each number.
Production records will also need to be amended so that batch numbers or other unique identifiers for raw materials can be recorded. Records need to be kept for all ingredients, intermediate foods and primary packaging materials that go into the process. Personnel responsible for ‘batching’ or adding materials to the process will need to be trained and re-trained to remind them to record these numbers religiously; in a paper-based manual system, these operators are the difference between an effective traceability system and one that will be full of holes.
Raw materials and incoming goods systems are the next part of the implementation; if any of your materials are not supplied with a unique identifier or batch code you will need to create your own and attach it to each lot of material as it is received. This same code will need to accompany any portion of the material as it moves around the facility. Work in progress, re-work, faulty product and product that is on hold awaiting quality checks also need to be labelled.
The final piece of the puzzle is with the sales and dispatch operations; your operators will need to keep a record of which batch lots were dispatched to which customer. The result is a batch number book that contains a unique identifier for each lot of product, with the product and final disposition (sold, destroyed, discarded) accompanied by sets of records for incoming goods, production , quality checks, on-hold or destruction records and sales or dispatch records that can all be linked back to the numbers in the batch book.
Paper-based traceability systems can be simple and relatively inexpensive but they need constant vigilance to ensure that every person who is supposed to be recording batch numbers is doing so in a conscientious manner. All records should be cross checked by a supervisor before being filed and a traceability exercise should be conducted on each product line on a regular basis to make sure the system is working properly.
There are many advantages to be gained from an electronic traceability solution, because they typically allow for more efficient ordering and stock management processes, as well as removing much of the ‘fiddly’ and tedious work from the record-keeping processes and improving access to records. If you have a complex business or are working with materials with a short shelf life, business management software can be worth its weight in gold. However, paper-based systems can and do work very well and are perfectly capable of meeting the traceability requirements of the most picky customers and stringent standards. All you need is a champion.
Traceability myth #1; consumers want transparency
Traceability myth #3; traceability equals authenticity