In June I had a unique opportunity to attend and speak at a Global Food Safety Summit in Shanghai, China. One of the speakers was the associate commissioner at the Shanghai equivalent of our FDA, and some of the comments he made struck a chord with me.
The food safety laws in China have now been updated for the fourth time. The first laws in their current iterations were published in 1982, and then revised in 1996, 2009 and, most recently, just several weeks ago. The current version of the law will become a requirement on Oct. 1 this year.
This column is from the blog and newsletter of the Acheson Group, a consulting firm for food and beverage companies with a focus on strategic risk management. Founder and CEO David Acheson, M.D., has more than 30 years of medical and food safety experience, and was associate commissioner for foods in the FDA.
I won’t go into details other than to say China is getting really serious about food safety. They have increased the number of items, or sections, in this new food safety law from 104 in the last version to 154. The associate commissioner did, however, focus on one key component: traceability.
While his organization has oversight of only Shanghai, he pointed out that that jurisdiction has a population of approximately 24 million people. Within that he has oversight of 217,659 food establishments of which 1,543 are manufacturers, 150,022 are distribution centers and 65,871 are restaurants. As he is saying this, I'm thinking that he doesn’t get to these places very often, despite the message that he and his organization take food safety so seriously. But wow was I wrong!
The associate commissioner said that in 2014 his organizations did a total of 308,000 inspections, which works out to on average of 1.5 inspections per year per facility. During 2014 they found 150,000 different food safety issues for which they took action. He did not say exactly what that action was for most of them; however he did share that during 2014 there were 7,708 infractions that resulted in fines totally 52,820,000 yuan (approximately $8.5 million). They also arrested 250 people who had violated food safety laws. He pointed out his agency is able to dish out stricter punishments and more prosecutions for criminal offenses.
Not only are they doing a lot of inspections and apparently taking actions, they are also doing a lot of testing. My understanding is they established a testing program in 2005 that now tests food from about 500 different locations and monitors about 25 different types of food from each location. They look at close to 450 indicators in each sample, thus generating over 250,000 data points each year. For 2014, 96.7 percent of tests were in the appropriate level.
When it comes to the number of illnesses, I found his numbers to be a little on the low side. He said in 2014 they identified only 126 cases of foodborne illness and that the overall rate of foodborne illness in Shanghai was 0.53 cases per 100,000 population. Interestingly most of these illnesses were due to either salmonella or norovirus. To contrast this with the U.S., 2014 CDC FoodNet data identified 19,542 cases of infection, 4,445 hospitalizations, and 71 deaths. The number and incidence per 100,000 population were as follows: salmonella 7,452/15.45, campylobacter 6,486/13.45, shigella 2,801/5.81.
The associate commissioner said his major challenges are that the fundamentals of food safety are still weak, and that he has to check up on lots of small vendors who have little idea about food safety. As he pointed out, with 24 million people to feed in Shanghai, most of the food consumed is coming in from outside his jurisdiction, or as he interestingly characterized it, as “imported” food. His biggest challenge was figuring out where the food came from, and thus one of his major initiatives was focused on traceability.
This brings me to the second key point, and one of the major areas of focus for Chinese regulators, which is traceability. The new laws appear to require full pedigree traceability. It was evident that the associate commissioner was not only happy about this but was going to use it to full effect.
He made it clear his intent was to require full supply chain traceability – maybe not for all foods but for those that were deemed high risk – at least at first. By doing this he pointed out he can then test the food and, when he finds a problem, trace it back to figure out where the problem occurred and take appropriate action.
This prompted the question that this seems to be a reactive, not preventive, approach. How is this going to get farmers and others in the supply chain to do the right thing on a regular basis? The answer he gave was surprising until one remembers that this is China, and that the food safety laws have some major teeth if one gets on the wrong side of them. He answered that the fear of being caught will drive behavior change all the way through the supply chain. If you are caught you may be heavily fined, imprisoned or even executed, depending on the level of the crime.
My take on all of this is that China is moving fast on food safety – really fast. They know they have a lot to do and have the challenge of lots of small operators who have no clue about food safety. So while the ability to track down the perpetrator may improve, and the consequences of being caught may be dire, there was no mention of how to actually educate the small vendors on how to do it right.
Not discussed was the technology challenges to make this work. It appears the goal is to create a massive online platform to store all this information. Clearly this is a huge challenge, and in my view will take a long time and a lot of money to make it work. But clearly the desire to drive food safety hard in China is loud and clear.
As a final point, the associate commissioner went so far as to say that the government needs to be more transparent in terms of what it is doing. So he recognizes there is work to do all round.
This is not the China that I first worked in almost 10 years ago. But the risks for U.S. food companies in China remain significant because as these system begin to roll out and suppliers are implicated, my concern is the message that will be heard is not that Supplier X has a problem, but that Supplier X, who supplies a major U.S. food company, was not doing things right. The onus will be on the international brand name, not on the supplier that got things wrong.
So as these systems take shape, U.S. food companies have to stay out in front, they need to really get their arms around the supply chain and enhance their own traceability systems. Also, U.S. food companies need to build solid proactive communication strategies about what they are doing for food safety in order to stay ahead of potential negative media and be ready to move really fast when things go off the rails.
