Scotland is planning a new food sampling strategy to tackle challenges associated with the current approach to testing.

The proposed model has four strands of surveillance managed and funded by Food Standards Scotland (FSS), and is separate from the verification sampling by local authorities as part of their routine inspections.

It was presented at the latest FSS board meeting with members backing the planned strategy. Implementation will start with parts based on existing programs such as the targeted surveillance priorities, carried out with local authorities. As in previous years, this sampling is expected to begin in July.

Annual local authority data shows the number of samples collected declined by 35 percent between 2014 and 2019. In 2020-21, sampling dropped to its lowest recorded level with 2,558 samples, which is a reduction of 77 percent compared to the number taken in 2015. Sampling activity increased in 2021-22 as COVID-19 pandemic restrictions eased, with 3,500 samples projected to be taken.

There are four Public Analyst (PA) laboratories in Aberdeen, Dundee, Edinburgh and Glasgow. Resource pressures, including a declining budget, have reduced the ability of local authorities to visit food businesses to take samples, or to fund PA labs to do the testing. A lack of funds to upgrade equipment, implement new techniques and train staff has also hampered the ability of PA labs to keep pace with scientific advances and emerging risks.

Higher costs but wider scope
FSS’s sampling budget is currently about £150,000 ($197,000) per year. Estimates of the new program show it could require an annual budget of £600,000 ($788,000).

The hope is it will help address the ongoing reduction in sampling without placing additional burdens on local authorities; provide data to support environmental health professionals with official controls; and a funding stream to help Public Analyst labs maintain scientific capability.

The first part of the strategy involves looking at a variety of commonly eaten foods at retailers, and analyzing them for a range of chemical and microbiological parameters and nutritional properties. This non-targeted approach could detect previously unknown or emerging issues and provide an overall picture of the safety and standards of food sold to the consumer. The plan is to do one such project every five years starting in 2023-24.

The second bit is more targeted, to test hypotheses in response to intelligence or emerging hazards identified through horizon scanning. It also helps enforcement by informing targeted official controls by local authorities. A list of sampling priorities would be created annually by FSS, which would identify commodities and the hazards to test for. The number of samples would be around 40 to 60 per commodity.

Imports and wider picture
The third arm is surveys that focus on a single commodity, with a large sample size that provide the basis for policy and regulatory decisions and generation of data to support risk assessments. In addition to microbiological or chemical contamination issues, these surveys may be used for the prevalence of allergens and risks associated with particular sectors such as takeaways. Such work is foreseen once every two years.

The fourth element aims to support official control sampling that will be required to verify the safety and standards of products coming into Scotland. The country previously relied on import checks by other European Union nations or Border Control Posts (BCPs) at ports elsewhere in the United Kingdom but this is set to change now that the UK has left the European Union. It is also likely there will be a shift in the countries of origin and products imported.

Parts two and four would be delivered through the public analyst laboratories, with sampling by local authority staff. Parts one and three are larger and may need a third party specialist.

Another paper, to be presented at a board meeting in June, will look at issues affecting food lab services in Scotland. The board will be asked to invite ministers to commission a business case for a national food and feed laboratory service that will safeguard scientific capacity and capability.

Concerns have been raised that the lack of lab capacity will have consequences for the work of FSS and local authorities as well as wider public health and food policy, including the ability to investigate outbreaks, monitor the impact of food standards interventions and support trade assurance.

Feeder mice outbreak
The March board meeting also heard about a Salmonella Enteritidis outbreak traced to feeder mice imported from Lithuania that was initially reported to FSS in April 2018. Since April 2014 there have been 950 cases reported across the UK with 61 in Scotland. More than 400 of those sick are children younger than 9 years old. Poor handling and the shedding of snake skin have been identified as possible causes of human infections.

In summer 2021, UKHSA (formally Public Health England) identified a spike in cases. Public Health Scotland reported one Scottish case in 2022.

The UK wrote to Lithuanian authorities a number of times to investigate and improve control measures, however no responses were received. Monkfield Nutrition suspended imports of feeder mice in December 2021. Local authority sampling confirmed the outbreak strain by whole genome sequencing, which led to a product recall in December to remove the mice from the market.

A letter sent in December to the EU Commission outlined the problem and asked for action to address the issue. The response did not address the concerns or give assurances sought by the UK so a ban was put in place in February 2022.

Finally, the sixth meeting of the Global Alliance on Food Crime took place in December with FSS and FSA colleagues joined by officials from the United States, Canada, Australia and New Zealand. Objectives of the group include building enforcement capability and capacity and developing a global information sharing network. A joint operational activity is planned for this year.

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