Sgs hot source - nov 2013 - complying with quality, safety and sustainability requirements





HOT SOURCE
EXPERT INSIGHTS INTO SAFE, SUSTAINABLE AND HIGH-QUALITY FOOD
ISSUE 3 • NOVEMBER • 2013
UPCOMING CHANGES TO ISO 9001 AND ISO 14001
UNANNOUNCED AUDITS: A GUIDE TO THE NEW BRC REQUIREMENTS
ISOTOPE TESTING BREAKS NEW GROUND IN FOOD TECHNOLOGY
GMO FOODS AND LABELING


DEAR READER,
Complying with quality, safety and sustainability requirements is an ongoing responsibility. To help you meet the challenge, this issue of Hot Source looks at forthcoming revisions to ISO 9001 and ISO 14001 and reminds us of the planned timetable. Many private label suppliers will also be affected by a major retailer's announcement that all suppliers must undergo BRC unannounced audits. We explain what you can expect and what will be expected of your team. Food contamination continues to make headlines. Understanding the issues and developments is key to your success; we look at the separate issues of honey contamination and the increased presence of pathogens in plants. In a similar vein we also examine the impact of sulphites in food, both good and bad.
Isotope testing has come into its own. As well as its use in food and nutritional research, this technology can also be applied to traceability. Find out more.
Product labelling impacts consumer protection, marketing and safety. Read about the latest GMO product labelling information for Europe and also the role labelling plays in the growing halal food industry.
Whether you are transporting, manufacturing or selling food, it all requires packaging at some point. Our new feature Packaging Corner offers insights into the latest industry issues.
For the complete range of SGS services and support visit: www.foodsafety.sgs.com.
SGS Agriculture and Food Team MARKET NEWS
Upcoming Changes to ISO9001 and ISO 14001 - Unannounced Audits: A Guide to the New BRC Requirements - Page 4 Halal Market Trends and Overview of Harmonisation Efforts - Page 6 Isotope Testing Breaks New Ground in Food Technology Page 8 Pathogens in Plants GMO Foods and Labelling - Honey and its Contaminants - Sulphites, Intolerance or Allergen, Declared or Undeclared - Packaging Corner - SGS FOOD NEWS & TRAINING
SGS Network News and SGS Webinars for Sept - Nov 2013 - Page 19 SGS FOOD TRAINING & E-SUBSCRIPTIONS
SGS Webinars and information on E-subscriptions to SGS Food Publications - FOOD WHITE PAPERS, SAFEGUARDS & FOOD EVENTS
The most relevant food-related SafeGuards from the past weeks and information on upcoming Food Events -


MARKET NEWS - ISO 9001 AND ISO 14001 UPDATES
UPCOMING CHANGES TO ISO 9001
AND ISO 14001
As part of their ongoing development, both ISO 9001 (Quality Management) and ISO 14001 (Environmental
Management) are currently under review, with the final revised versions due in 2015.
The current ISO timeline anticipates the following: Draft version of the revised Standards (DIS): Q2, 2014.
Final draft version (FDIS): Q1, 2015.
Final revised versions: Later in 2015.
Inevitably, this timeline may be subject to delay and date slippage.
At this stage, it is uncertain what the precise requirements of the final revised versions will be. However, we are aware of some of the changes that will be made. Following the adoption by ISO of ‘Annex SL' in 2012, all technical committees developing management system standards have to use the same structure, terms and definitions. In the same way, any future revision to ISO 22000 will have the same structure.
For this reason, we know that the Leadership and commitment; quality, Non-conformity, corrective action and revised version of ISO 9001, ISO 14001 environmental or food safety policy; and any other new or revised standards roles, responsibilities and authorities.
will have ten sections: Actions to address risks and Until the FDIS for both standards is 2. NORMATIVE REFERENCES opportunities, objectives and plans to issued in the early part of 2015, no Wording that is specific to the Standard achieve them.
organisation can realistically make (including its intende outcome).
any definite forecast about the exact 3. TERMS AND DEFINITIONS Resources needed for the chosen requirements. The current intention is Reference to common terms and Management System, personnel to have a three year transition period for core definitions outlined in Annex SL competence and awareness, existing users of ISO 9001:2008 and/or and any which are specific solely to communication and documented ISO 14001:2004 although this has still to Quality, Environmental or Food Safety be formally ratified. SGS will keep you Management, for example.
updated on new developments as they 4. CONTEXT OF THE ORGANIZATION Operational planning and control.
Understanding the organisation 9. PERFORMANCE EVALUATION For further information, please contact implementing the Standard, needs and Monitoring, measurement, analysis expectations of interested parties, scope and evaluation, internal audit and of its Management System.
management review.


MARKET NEWS - UNANNOUNCED AUDITS
UNANNOUNCED AUDITS: A GUIDE TO THE
NEW BRC REQUIREMENTS
A major UK retailer recently stated that any site producing products under their own label must undergo a
Full Unannounced audit. The Global Food Safety Initiative (GFSI) has also discussed the possibility, or at least
defining a minimum number of Unannounced audits in a given cycle. So what does this entail and how can a
company best prepare?
WHO CAN HAVE ONE?
For the extra scrutiny a successful For the British Retail Consortium (BRC) unannounced BRC audit provides, the Global Standard for Food Safety, the site will be rewarded with a + symbol requirements state that a company after the grade, demonstrating that they must have achieved either a Grade maintain their systems in good order A or B on its last audit, and opted for the Unannounced option within three months of their last certification.
WHAT DO I NEED TO DO?
As a direct result of the retailer's Once the Unannounced audit option has statement, the BRC is permitting any been selected, the certification body will site that has Grade A or B to transfer into ask the site to complete a form providing the Full Unannounced audit, even if they key information to enable the audit to go are beyond the three month period.
A Full Unannounced audit is where the Security – the certification body entire audit is conducted unannounced. will provide details of all auditors The BRC Global Standard has a second who may conduct your audit, and option for a partially unannounced audit will provide photographic proof of where the Good Manufacturing Practice identity on arrival. As with all audits, (GMP) or factory processes audit is a trainee auditor, or a witnessed unannounced whilst the systems audit assessment on an auditor may take is conducted as a planned and arranged place. These training and witnessed audits are conducted by strict rules, and do not affect the audit outcome.
WHY HAVE ONE?
Block out dates – with a Full Unannounced audit, a maximum of It is a common myth that prior to an 15 days can be blocked out (10 days audit, a company goes into overdrive; for a Partial Unannounced audit), fixing holes, painting walls, revising when an audit cannot take place. documents, training staff and getting These should be used when the internal audits up-to-date. Whole site is not in production either for timetables of HACCP reviews, shutdowns, or for refurbishment.
management reviews and recall tests are scheduled to happen just prior to the Shift patterns and earliest time of audit. Managers suddenly run around briefing people how important it is that it Where the auditor is to report on all "looks good on the day".
arrival at the site, who to ask for and A Full Unannounced audit is a way to a nominated deputy.
demonstrate that a company works to Pre audit info – HACCP summary, the same standards every working day, process flow, simple site plan, not just brushing up for a couple of days organisation chart, types of products


MARKET NEWS - UNANNOUNCED AUDITS
The certification body must be notified of HOW DOES IT HAPPEN ON THE DAY?
deputies should still be able to manage any significant changes to the site, key The auditor will report to the agreed the audit process. The BRC protocol contacts or changes to the scope of the point on site and ask for the nominated does not permit an audit to be cancelled person (or deputy), explaining it is for an because personnel are not available.
Unannounced BRC Certification audit. If access is not granted, then the WHEN CAN I EXPECT TO HAVE ONE?
From that point, the requirement is that BRC protocol stipulates that the site's The BRC protocol states the potential the auditor is granted access to the current certification can be suspended date range for an audit is anywhere from production facilities within half an hour.
or withdrawn, so it is important that any nine months before the re-audit due During these 30 minutes, any relevant personnel who may be at the nominated date, although it will most likely occur in health and safety points, a brief opening reporting point are briefed on how to the last four months of the cycle.
meeting, and issue of any relevant communicate the arrival of the auditor.
The audit will only happen on a weekday, personal protective equipment needs SGS is the largest certificating body for and the earliest start time will be based to be completed. If your site has any BRC, IFS and FSSC 22000 certificates on the shift patterns and agreed with the specific health and safety requirements, around the globe.
certification body in advance.
it will pay to notify the certification body Jeremy Chamberlain in advance of these, or provide a briefing The audit will not take place on any of Global Product Manager - BRC document, to save time on the day.
the blocked out days previously supplied.
SGS United Kingdom Limited If key members of the site are not available on the day, the site's defined t +44 1934 522 917 MARKET NEWS - HALAL FOOD
HALAL MARKET TRENDS AND OVERVIEW OF
HARMONISATION EFFORTS
Rapid growth and interest in halal food has captured significant attention from the food industry. According to
the World Halal Forum, the global halal food and beverage trade is currently estimated to be around ca. USD 1.4
trillion annually (Farouk, 2013).
The halal food market is currently worth an estimated 16% of the total global food industry with Asia, Africa and Europe accounting for 63%, 24% and 10% respectively. A growing Muslim population, as well as growing economic development and disposable income in Muslim countries, are considered to be the main drivers of halal growth, while halal has become the world's biggest brand (in Farouk, 2013). Worldwide the number of Muslims has been calculated as 1.62 billion, representing 23.4% of an estimated 2010 world population of 6.9 billion. Europe's Muslim population is currently estimated at 44.1 million Muslims, ca. 2.7 % of its total population and is younger and growing faster, as a whole, at a rate of 1.8% per year (in van der Spiegel, 2012).
control measures in the halal food chain, ensuring that blood, a potential source Survey-type studies have shown that which is as long and complex as any of bacterial contamination is removed, 75% of Muslims living in the US and other food chain. The most common resulting in healthier meat. 84% of Muslims in France always eat cases of fraudulent adulteration of halal halal meat. Religion is not thought to be meat involve the substitution of meat LOOKING FOR GLOBAL
the sole motive for adhering to religious tissue with collagen and offal, as well as dietary requirements, such as halal. using pork fat in place of other animal Health, respect for animal welfare and a fat. The problem also extends to the use Muslim consumers increasingly desire degree of acculturation have also been of cheap pork proteins and mechanically and demand the adoption of a quality noted as important drivers (in Bonne and recovered meat (MRM) from pig assurance approach that guarantees the halal process standards. Such Halal is a process associated with an approach would require a formal ROOM TO GROW
religious belief and as such it would certification and labelling strategy to reassure consumers of the quality The retail exploitation of the Muslim be difficult to control and guarantee. and authenticity of halal meat and market segment has been delayed From the consumer point of view it improve shopping convenience and by a lack of insight into Muslim food is difficult to evaluate and verify even choice. Halal certification is not yet purchasing and consumer behaviour. after consuming the product. Therefore, globally standardised but its need is Furthermore, confusion over halal consumers have to largely rely on internationally recognised. Apart from specification and certification schemes, the seller and/or trust the information its religious significance and its ‘seal of as well as the lack of halal food chain provided on the product label to guide quality' perception amongst consumers, logistics hinders the effective traceability their purchase. In the case of halal, halal certification provides reliable and and authenticity of halal products, such trust on product labelling would independent authentication, a means of especially meat. The recent incidence be all about the halal process attributes claim substantiation. ‘Authentic halal' is a of pork DNA found in halal school and including handling and safety. The latter cause of controversy amongst certifying prison meat in the UK earlier in the has been linked with the effectiveness bodies and Muslim countries, as halal year highlighted the high risk of cross- of the slaughtering process leading to is widely defined by the choice and contamination and the lack of effective complete animal bleed out therefore MARKET NEWS - HALAL FOOD
effectiveness of stunning methods used bodies around the world, including local in animal slaughter. government departments that have According to EU legislation (EC/93/119, taken charge of halal certification in and EC/1099/2009 that came to effect countries such as Malaysia, Indonesia, on 1st January 2013) stunning before Singapore, Thailand and the Philippines. slaughtering is a mandatory requirement It is believed that global politics in Europe and is performed to ensure and government involvement may that the animals are unconscious, discourage a general consensus on a ensuring slaughter doesn't cause them harmonised halal certification approach, anxiety, pain, suffering and distress. as each country is attempting to This legislation has caused significant establish themselves as the global hub dispute amongst Muslims as there is for halal certification based on their own the concern that stunning could also kill national and regional interests. animals prior to slaughter or make them A recent attempt to harmonise halal standards has been made by the In many EU countries, religious slaughter Organisation of Islamic Cooperation is exempt from stunning in line with (OIC) that appointed the United Arab the religious freedoms granted by Emirates (UAE) chair of the technical Article 9 of the EU Convention on committee for halal food and cosmetics. Human Rights (www.dialrel.eu). Hence, UAE was given the task of producing a slaughter without stunning is carried out unified standard that would be applied in licensed slaughterhouses or during across all 57 Islamic countries within religious festivals to ensure that the the next three years (e.g. Halal Focus, animal is healthy and has suffered no 2012). Such an initiative has already been injury prior to slaughter. This conflict met with scepticism, but if successful, around animal protection prior to it is believed that it will act as a further slaughter is guided and affected by the boost to the global halal market. In view different perceptions of what constitutes of the disputes previously mentioned, ‘authentic halal'. In turn, this prevents available options for the development the development of a global halal of a global halal standard seem to be standard and hinders harmonisation. limited and would involve either an For example, the Malaysian standard element of compromise, or acceptance that initially identified stunning as "not of the diversity and differences amongst recommended" was revised in 2009 the different Islamic ‘schools of thought' to include a reference to pre-slaughter and likely to consolidate only a few stunning under certain conditions. Despite the differences, both the pre- As a leading provider of certification, agricultural scientists, accompanied stun and non-stun approaches have been verification, inspection and testing with by members of Muslim institutions, embraced by major UK retailers selling a global reach, we are happy to discuss to assess compliance against halal meat from both pre-stunned and non- your halal certification, training or other stunned animals in their stores and food requirement anywhere in the world. Evangelia Komitopoulou, PhD outlets in an attempt to respond to their SGS currently offers halal certification Global Technical Manager - Food customers beliefs.
according to the Qibla Food Control SGS United Kingdom Limited (QFC) standard. This is a halal quality STEPS IN THE RIGHT DIRECTION
standard developed by Muslims and food t +44 7824 089985 experts. Audits are exclusively carried It is estimated that there are currently out by expert Muslim auditors, such as around 122 active halal certification veterinarians, food technologists and Bonne, K., and Verbeke, W. (2088) Muslim consumer trust in halal meat status and control in Belgium, Meat Science, 79, 113-123.
Farouk, M.M. (2013) Advances in the industrial production of halal and kosher red meat. Meat Science, 95, 805-820.
Halal Focus (10/12/2012) UAE kicks off halal standardisation worldwide. (Available online at: http://halalfocus.
net/uae-kicks-off-halal-standardisation-worldwide/; Accessed: 23/08/13).
Van der Spiegel, M., van der Fels-Klerx, H.J., Sterrenburg, P., van Ruth, S.M., Scholtens-Toma, I.M.J. and Kok, E.J. (2012) Halal assurance in food supply chains: Verification of hala certificates using audits and laboratory analysis, Trends in Food Science & Technology, 27, 109-119.
MARKET NEWS - ISOTOPE TESTING
ISOTOPE TESTING BREAKS NEW GROUND IN
FOOD TECHNOLOGY
Identify the natural and anthropogenic properties of food, feed and related products with isotope testing.
WHAT IS AN ISOTOPE?
The term isotope is formed from the Greek roots isos (equal) and topos (place) meaning "the same place". Thus, an isotope is one of two or more atoms of a single element which have an equal number of protons but contain different numbers of neutrons. This means that each isotope of a given element has a different mass, even though they occupy the same position in the periodic table.
Both stable and radioactive isotopes exist in nature. Stable isotopes are energetically stable and do not spontaneously decay, as opposed to radioactive ones. They can be measured using various Mass Spectrometry (MS) techniques, such as Isotope Ratio Mass Spectrometry (IRMS) or Inductively Coupled Plasma – High Resolution Mass Spectrometry (ICP-HRMS).
ISOTOPES IN RESEARCH
Stable isotopes, both at the natural abundance level and artificially enriched, are used for research in drug discovery, nutrition, energy (both nuclear and petrochemical), healthcare diagnostics, and key scientific studies in physics, chemistry, environmental science and materials science.
FOOD INDUSTRY INTEREST
Applications are now being developed to use these capabilities within the food industry to enhance research into plant growth and human nutrition. Substances may bear a unique isotope ratio fingerprint, characteristic for the processes they undergo during their formation (e.g. photosynthesis) and/or subsequent environmental transformations (e.g. oxidation/reduction/evaporation), or anthropogenic activities (e.g. fraud).
MARKET NEWS - ISOTOPE TESTING
Consequently, most natural products' delivers sufficient evidence to identify geographic origin and exposure to natural There are several practical applications a claim of fraud. This applies to origin, and anthropogenic alterations can be for isotope testing. It is possible to relate drug discovery, chemistry and material identified through isotope testing. For the origin of hormones in meat to the example, the testing of naturally grown natural production by the animal itself, botanical and animal species or parts to animal feeding, or to intramuscular EXPERIENCE AND NEW APPLICATIONS
of them, allows the comparison and injection. Milk and its products are tested verification of geographical origin or SGS is applying its expertise and to determine and verify the origin of natural vs. anthropogenic influences. experience in the mineral industry and cheese and butter products. Similarly, Equally, this testing can be applied to the field of environmental testing to the the origin of bottled water, or water used water and minerals. challenge of extending isotope testing in production of various spirits can be into consumer markets such as food Animal species that have been living verified. Fraudulent addition of ethanol and feed. We are starting to identify and in different geographical regions and to whiskey, brandies or wine can also be record relevant product compositions exposed to different environments can and elements.
be identified. Upon investigation of old Geographic identification requires bones discovered in tombs dating back For further information on our isotope the mapping, drawing and testing of to the Neolithic times, it has even been testing capabilities, contact: samples known to originate from specific possible to determine the areas in which Marc Van Ryckeghem locations. These results are then added our human ancestors travelled and lived. Laboratory Manager to an identification matrix. Trials need to This research has opened the testing SGS Belgium N.V.
be conducted to demonstrate whether industry's eyes to the potential use of the data contained in such a matrix this capability for more projects. MARKET NEWS - PATHOGENS
PATHOGENS IN PLANTS
Common pathogens like Salmonella spp., Echerichia coli, Listeria monocytogenes and Campylobacter spp.,
traditionally associated with animal products, are increasingly entering the food chain through contaminated fruit
and vegetable products.
Consumption of fresh produce has PROXIMITY INCREASES RISK
SURVIVAL ON AND IN PLANTS
increased in recent years, prompted by Zoonotic pathogens are not commonly Pathogens in water used for spraying healthy eating campaigns in the USA, present in fruit and vegetables in nature. can remain on fruits and vegetables and Europe and other parts of the world. Human intervention and commercial survive on these new carriers. Studies However, compared to previous years, food production practices have brought have shown that some enteropathogens fruit and vegetables are now being the two into close proximity.
are quite adept at surviving on the leaf identified more frequently as the source surface (phylloplane). A study showed of a growing number of outbreaks Pathogens may be naturally present that E. coli applied to lettuce could be associated with zoonotic pathogens.
in soil, or may become incorporated in the soil from organic wastes added as isolated from the plant for a further Between 2003 and 2008, the food fertiliser, or by accidental contamination. 15 days. Fruit and vegetable plants vehicles identified in 1,565 outbreaks For example, water supplies used react differently to enteropathogens. reported to the Centers for Disease to wash and irrigate crops can be Some have been shown to actively Control and Prevention (CDC) are a broad contaminated with faecal material (and its support their survival, while others spectrum of animal- and plant-derived pathogens) by run-off from nearby fields resist. Effective washing and exposure foods (picture 1). The list of implicated and livestock farming. The risk of to UV radiation can typically deal with foods is regularly expanded as new contamination under these circumstances surface contamination. While UV ones are identified during outbreak is far greater than the chances of radiation is traditionally used to minimise investigations. Between 2006 and early accidental contamination caused by the contamination, successful phylloplane 2012, 15 new specific food types were intrusion of wild animals and birds into bacteria typically colonise sites that are identified as food vehicles in outbreaks affecting the United States. It is curious that while many of the pathogens have animal reservoirs, many new food vehicles are plant derived. This includes plant-derived processed foods, like peanut butter, peanut paste, and spinach powder; spices such as black and white pepper; tree nuts and fresh produce items.
Consumer demand for greater choice, variety and year-round availability of fruit and vegetables, as well the vogue for convenient ‘ready to serve' products, such as bagged salads, has driven the globalisation of supply chains and increased pressure on the food industry. Unfortunately, this may compromise safety. The standard of water used for irrigation, as well as hygiene at harvest and during storage, can vary widely between countries, potentially exposing consumers to increased numbers and varied strains of these pathogens.
Intensive farming is not new. It is becoming apparent though that lessons learned in livestock farming can also impact fresh produce growing and processing.
MARKET NEWS - PATHOGENS
protected from UV, such as the base of Image 1: Distribution of illnesses by food type in 1,565 foodborne outbreaks caused structures (trichomes). by a single food type and reported to CDC's National Foodborne Disease Outbreak Pathogens do not always die on leaving the host animal, but may find a new carrier in the form of plants. Plants GRAINS - BEANS
sprayed with contaminated water, either during growing or processing, can absorb pathogens through any wounds to the flesh. This is a particular issue with popular consumer items such as pre-prepared lettuce and salads. The cut surfaces exude nutrients and supply pathogens with the means to survive, penetrate to the internal tissue and LEAFY GREENS
grow – beyond the reach of chemical (TOMATOES,
sanitisers. Internalisation of pathogens into plants may also be possible through stomata and hydathodes (permanently open water pores). Normally used to secrete water from a plant, a study has shown that under certain conditions pathogens can enter leaves through its hydathodes and move into the vascular system, which may even result in the potential to make consumers ill and in consumer. This is preferable to suffering internal translocation of the bacteria rare cases cause death.
a product recall as a direct result of inside plants. Furthermore, contaminated All HACCP plans should be reviewed an outbreak. Product recalls cost the irrigation water can be taken up by a regularly. They must deal not only with industry more than just money. They plant's root system and any pathogens questioning whether the water at a also damage consumer confidence and can be stored within its flesh.
facility is safe to use, but also if that devalue the brand involved.
As a result the food industry must water source is trusted and protected innovate and identify for ways to better against potential contamination. Post- END PRODUCT INTERVENTION
protect and improve the microbial quality harvest contamination is also known to Global supply chains mean that of fruit and vegetable produce.
result from poor food handling processes contamination issues in one part of and poor worker hygiene. Processors the world can quickly spread. Existing PREVENTION, BETTER THAN CURE
need to ensure that HACCP plans are food safety systems have focused on There is little that consumers can robust, documented and perhaps most post-harvest safety, hygiene, handling do to protect themselves from fruit importantly, implemented. Poorly trained and testing. Improving food safety going and vegetable contamination, as employees are potentially the weakest forward will likely rely on increased these products are often not cooked. link in any plan.
awareness of public health issues and Washing them has little effect on any enforcement of regulations in new contamination and being invisible to END PRODUCT INTERVENTION
and developing markets. This should the naked eye it becomes increasingly The food industry has, out of necessity, be complemented by increased focus important to prevent contamination invested heavily in microbiological on identifying contaminations earlier, occurring in the first place.
testing and surveillance programmes. preventative in-field solutions and In theory, existing regulations and Fruit and vegetable products can introducing stricter practices more in line the food industry requirement that undergo microbiological testing at any with livestock farming.
all processors and manufacturers stage of the supply chain but are most For further information please visit our implement hazard analysis and critical commonly checked as the end product. control point (HACCP) strategies, should This enables processors to identify any prevent environmental contamination pathogen contamination before goods Global Food Testing Business reaching the consumer. Overall evidence reach the point of sale.
Development Manager suggests that actual contamination of An integrated testing programme can fruit and vegetables with pathogens is verify the microbial quality of products low. However, any outbreak has the and in the event of contamination being identified, prevent them reaching the MARKET NEWS - GMO FOODS
GMO FOODS AND LABELLING
Genetically modified food, products and ingredients, are a contentious subject. Safety concerns persist amongst
both consumers and some governments, despite extensive research and industry assurances, regarding the
consumption of foodstuffs containing genetically modified organisms (GMOs).
PCR TESTING
Testing for GMOs is performed with Polymerase Chain Reaction (PCR) based DNA technology that can determine the presence and/or the quantity of a specific GMO. DNA-based quantitative PCR testing utilises GMO strain standards to determine GMO levels from 0.01 per cent to 5 per cent. This can be conducted on seeds, ingredients and foods. As a result the determination of GMO in substances is possible in order to ensure proper labelling is possible. LABELLING REQUIREMENTS
In Europe, labelling is required on all products that consist of GMO or contain GMO and products derived from GMO, The food industry has long battled Another concern is choice. Consumers but no longer containing GMO, if there with questions about the benefits and want to know what they are buying and is still DNA or protein resulting from safety of GMO products. In the face to have the choice to buy and eat GMO the genetic modification present.4 of resistance from regulators, non- products, or to avoid them. Labelling To NGOs the major concern is the governmental organisations (NGOs) is the only mechanism that allows position taken by the US FDA, which and consumers, GMO products have in shoppers to identify whether or not a is that the labelling of a GMO product recent years gained some acceptance product contains any GMO and they is not required, providing there are no in parts of the world, like USA, and are base purchasing decisions on what they significant differences between the traded and sold with varying degrees GMO derived and non-GMO foods.5 The of restriction. Like all other aspects of US FDA does however state that any the food supply chain, GMO growers, allergen or nutritional difference must producers and manufacturers are be declared on the label or labelling. overseen by regulators and must meet In Europe, the European Food Safety Otherwise, the labelling of GMO strict quality and safety standards.
Authority (EFSA) has defined an substances in the US is voluntary.
application process to evaluate and verify However, issues of trust arise. the safety of a GMO.1 In the United Including the European Union (EU), there Assurances from the industry and even States, oversight of GMOs is conducted are currently 64 countries that require governments are not always sufficient. by a combination of government the labelling of GMO products.6 In part, this is because countries and agencies, primarily the United States regions allowing GMO production are, Department of Agriculture (USDA), US US LABELLING EXCEPTIONS
rightly or wrongly, perceived to have less Food and Drug Administration (US FDA) robust oversight procedures than NGOs On 19 June 2013, a NGO announced and the US environmental Protection and consumers would like.
that the USDA Food Safety Inspection Agency (US EPA). Service (FSIS) had approved a non- GMO label claim for meat and liquid egg products.7 Products that are allowed to make the claim must demonstrate that the animals' feed was free of genetically modified corn, soy, or other feed. The USDA FSIS allows companies to demonstrate on their labels that they erified Label Receives Approval for Meat, Liquid Egg Products MARKET NEWS - GMO FOODS
are meeting third party organisation 2013, providing four additional states While no immediate action is being taken standards or claims, providing those pass similar legislation, one of which at a federal level, 25 states are currently claims are truthful, accurate and not must border Connecticut and the total with legislation or ballot legislation.12 misleading.8 The USDA and US FDA population of those states exceeds 20 Additionally, there is one US retailer that viewpoint has not changed. They million people.10 will require GMO labelling in their store stand by the evidence that approved On 12 June 2013, the State of Maine bioengineered crops and feedstuffs passed LD 71811 that requires food and are safe to consume and do not feed produced from GMOs to have significantly differ from crops developed a disclosure statement of "Produced through traditional plant breeding and While it appears that there may be with Genetic Engineering". Disclosure they therefore do not require different possible GMO labelling in the future in is to take place within 18 months. The the US, it doesn't appear that this will compliance enforcement date is 1 be performed by federal law as once Additionally, on 4 June 2013, the State July 2019 and does not apply to foods again the US congress voted down GMO of Connecticut passed Bill HB 65279 with less than 0.9% GMOs, alcoholic labelling in May 2013.13 that requires infant formula, or baby beverages, restaurants, unintentionally food, that is produced from GMOs to commingled products and other be labelled as "produced with genetic conditions set forth in the law. The law engineering". This labelling is to will be repealed if a similar law is not GMO testing and food nutritional start 1 July 2015 and the compliance adopted in at least five states, or states labelling services from SGS can support enforcement date is 1 July 2019. This with a population or combined population the food industry and ensure national law becomes effective 1 October of at least 20 million people. and international labelling requirements are met.
Consumer Testing Services Food Scientific and Regulatory Affairs SGS North America, Inc.
GMO Labeling Bill Voted Down In Senate [email protected] +1 973 461 1493 MARKET NEWS - HONEY CONTAMINATION
HONEY AND ITS CONTAMINANTS
Humans have been collecting honey for food, for more than 8,000 years and production is on the increase.
Today though, honey contamination, adulteration and honey-bee colony losses pose a raft of twentieth century
challenges.
Table 1. Honey & Beekeeping - Sources of Contamination TYPES OF HONEY CONTAMINATION
Environmental contaminants Acaricides: lipophilic synthetic compounds and nontoxic substances such as organic acids and components of essential oils Heavy metals such as lead, Antibiotics used for the control of bee brood cadmium and mercury diseases, mainly tetracyclines, streptomycin, sulfonamides, and chloramphenicol Radioactive isotopes Paradichlorobenzene, used for the control of wax moth and chemical repellents Organic pollutants, polychlorinated biphenyls (PCBs)Pesticides (insecticides, fungicides, herbicides and bactericides)Pathogenic bacteriaGenetically modified organisms Source: The Scientific World Journal, Health conscious consumers and and taufluvalinate. The use of found to be above the regulatory increasing globalisation are driving the chemicals inside a beehive risks direct standards for food.
honey markets. In the five years to contamination of honey. Additionally, Bacteria, moulds and yeast microbes are 2010 global honey production increased in agriculture, pesticide use is common also found in honey. The presence of by 10%, from 1.4 million tons to 1.54 practice as a means of increasing these microorganisms has the potential million tons. By 2015, the global market productivity. Pesticide residues include to affect honey quality and safety. for honey is projected to exceed 1.9 acaricides, organic acids, insecticides, Fortunately, most bacteria and microbes million tons.
fungicides, herbicides, and bactericides. cannot grow or reproduce in honey but Honey's properties as a natural product Uncontrolled application can cause spore forming microorganisms, such as make it popular in existing and emerging contamination to the environment, Bacillus cereus, Clostridium perfringens markets. However, it is susceptible animals and humans. More than 150 and Clostridium botulinum, can survive in to contamination from a variety of different pesticides have been identified honey as spores for a long time.
environmental sources. Bee products, in colony samples.
Another concern is about honey including honey, are polluted via different Apiarists use antibiotics to treat bacterial contaminated with pollen from sources of contamination (Table 1). diseases in the hive. As a result, genetically modified organisms (GMO). The main concerns for the industry traces can be found in the honey itself. In the European Union (EU), such a relate to pesticides, antibiotics and Next to others, oxytetracycline and honey product is considered as ‘Food chloramphenicol residues have been produced from GMO' and would require found above the regulatory standards Pesticides are used worldwide to legal approval and respective labelling in honey. Oxytetracycline is commonly control bee diseases and pests in before it could be offered for sale. used to treat European foulbrood disease apiculture. However, in most instances and American foulbrood diseases. Other Because of its high nutritional value and their administration is uncontrolled antibiotics are also used, including unique flavour, the price of natural bee and they are applied without approved but not limited to, erythromycin, honey is relatively much higher than protocols. The substances are used to lincomycin, monensin, streptomycin, that of other sweeteners. Therefore it control varroatosis and ascospheriosis and enrofloxacin. Antibiotic residues are is also susceptible to adulteration with such as acaricides amitraz, celazole, predominantly the result of improper cheaper sweeteners. Sugar syrups and bromopropylate, coumaphos, flumethrin beekeeping practices and have been molasses inverted by acids or enzymes from corn, sugar cane, sugar beet and MARKET NEWS - HONEY CONTAMINATION
syrups of natural origin such as maple antibiotics in food stipulates that each have all been detected in adulterated antibiotic must have an MRL, as listed honeys. Adulteration of pure honey with in Regulation No 37/2010 before it can synthetic honey (based on C4 plant be used on a food-producing species. sugars) has become more prevalent However, there are no MRLs for honey, in recent years. In addition, there has which means the use of antibiotics recently been a major adulteration for the treatment of honey-bees is not problem in honey from the Far East.
allowed. All honey exported to the Therefore it is no surprise that in EU must be monitored for residues recent years, the market has seen the in compliance with Directive 96/23/ introduction of legislation to ensure EC. Moreover, the honey must be the honey quality and consumer safety in product of one of the countries allowed major markets. This has resulted in major to send honey to the EU. Each year, the producing countries like China, Turkey EU updates this list. The current list can HONEYBEE COLONY
and Argentina cleaning up production to be found in Commission Implementing facilitate trade. However, contamination Decision 2012/302/EU. Finally, EU remains an issue. Between 2002 and requirements on honey intended for Since 2006, the US and EU have 2004 honey originating from China was human consumption laid down in seen large-scale unexplained banned in the EU, due to contamination losses of 30-90% of honey-bees in with antibiotics. In 2001, the USA In the US, there are no import some colonies. The phenomenon, introduced an anti-dumping duty on restrictions specific to honey. However, described as colony collapse disorder Chinese honey, which was linked to the exporters must comply with US food (CCD), was partly responsible EU ban. Imports to the USA declined standards in relation to food safety for a 2% decline in world honey to just 1,530 tons in 2011 and remain and the use of additives and veterinary production in 2006-2007.
low today. On the other hand, from medicines. MRLs for antibiotics in 2001-2011, USA imports of Indian honey food are set by the US Food and Drug As of 2012, CCD remains an ongoing increased from 20 tons to 26,837 tons Administration (USFDA) and listed in problem for the honey industry, accounting for 20% of the volume in Title 21, Part 556 3. There are no specific with the US being hardest hit. In the 2011, up from 9% in 2006. According limits for antibiotics in honey but no EU, CCD is expected to contribute to a 2011 US report, there is strong food in the US may contain residues to a decline in honey production, suspicion that a considerable portion of of nitrofurans, chloramphenicol and particularly in southern European imports from India are of Chinese origin countries (Portugal, Spain, Italy raising the need for identification of and Greece) and further north in geographical origin. In June 2010, the Poland. These losses impact global EU banned Indian honey due to a lack of honey markets, as the US and traceability regarding origin, adulteration, With no sign of honey's popularity EU compensate for lost domestic and contamination by heavy metals and abating the market will continue to grow, and bans and restrictions will enable new No definitive cause has yet been players like Ethiopia to enter the market. identified for CCD. Most researchers Producers and exporters must continue believe it is a combination of to monitor environmental contaminants contributory factors, including: Supporting these policies, the EU and and use third-party testing and USA have introduced regulations to certification to ensure products meet the The invasive varroa mite guide and qualify exporters before regulatory requirements of destination New or emerging diseases, such honey can be traded to these important as Israeli Acute Paralysis virus For further information please visit our and the gut parasite Nosema In the EU, exporters must meet the Pesticide poisoning, through requirements of European Commission exposure to pesticides applied to Regulations No 178/2002, No 852/2004 Global Food Testing Business crops, or used for in-hive insect/ and No 853/2004 and have an HACCP Development Manager based food safety system implemented. Bee management stress Maximum residue limits (MRL) for pesticides are listed in Regulation Modification of bee foraging No 396/2005. The EU's standard for Research into the potential causes continues.
MARKET NEWS - SULPHITES IN FOOD
SULPHITES, INTOLERANCE OR ALLERGEN,
DECLARED OR UNDECLARED
Sulphites and sulphate ingredients play an important role in the food industry, but as well as preventing spoilage,
they have also been linked with food intolerance and allergies.
Many countries require that sulphites REACTIONS CAUSED BY SULPHITES
baked products as a dough conditioner and sulphate ingredients must be Sulphites are known to increase and dried beverage mixes for colour declared on labels as a food allergen, or symptoms in 5% of asthmatics. In some intolerance additive, providing certain people adverse reactions include hives, Sulphites were recognised by the Greeks conditions apply. Typically, declaration is swelling and anaphylaxis symptoms.2 and Romans as a means to preserve required when these additives are added Other reactions more associated with wine. Then around the 1880s sulphites directly and/or present at levels of 10 intolerance to sulphites are nausea, were applied to meat products produced mg/kg (ppm) or greater in a product. The abdominal cramping and diarrhoea.3 in South America and Australia that United States (US) goes a step further. In were being shipped to England. In the the US the label declaration applies if the WHY USE SULPHITES
20th century the use of sulphites on sulphite is added to an ingredient that is processed fruits and vegetables became added to the finished product unless it Sulphites prevent spoilage caused by has no technical effect on the finished microbial growth, prevent oxidation and food and is less than 10 mg/kg.
prevent browning or colour degradation The wide variation between countries of food and wines. Other uses of In some areas/countries, such as and regions as to what foods sulphites sulphites are on seafood products such European Union5 and those that follow can be applied to products and at what as shrimp and prawns. Their use on Codex Alimentarius6 standards, the levels, creates problems for people who pickled vegetables is fairly common regulations and labelling requirements suffer a reaction to sulphites.
but less known is that they are used in MARKET NEWS - SULPHITES IN FOOD
are fairly straightforward. In the US, the foodstuffs when using Sulphur Dioxide. UNDECLARED OR EXCESSIVE SULPHITES
requirements for sulphites are controlled The United States Department of Since all these countries require specific by four different government agencies Agriculture is responsible for meat, labelling and set acceptable levels of creating a degree of confusion, albeit poultry and processed egg products, sulphites one would believe that this mainly for companies importing products catfish and partially for organic issue is being controlled but each week into the country. Alcoholic beverage products while the US Food and Drug there is a related product recall. In June sulphite labelling and requirements is Administration is responsible for the 2013 Rapid Alert System for Food and controlled by the Bureau of Alcohol, remaining of the food and feed products. Feed (RASFF) reported: "Sulphite: Tobacco, Firearms and Explosives. The Canada last year required sulphites to be too high content (904 mg/l) in chablis US Environmental Protection Agency listed as an allergen because of issues in wine, following a consumer complaint. is responsible for the fumigation of regard to sulphite sensitivity.7 Origin France, distributed also to United Kingdom"8 and in Canada on 25 May 2013 – undeclared sulphites in a white grape juice, on 4 June 2013 snacks with undeclared sulphites and on 29 April 2013 – undeclared sulphites in golden seedless.9 In the US, on 3 May 2013 dried whole shrimp with undeclared sulphites was recalled.10 As with all allergens and sensitising food ingredients, packaged food must be correctly labelled, but it is even more important to know all of the substances in the ingredients. When undeclared or excessive some ingredients, including sulphites, can cause reactions in people that result in illnesses and even death. Until the industry conducts due diligence to verify that all known substances are either declared or at the proper levels, then these recalls will continue and sensitive individuals will suffer for the industry's improper action.
Jim CookConsumer Testing ServicesFood Scientific and Regulatory Affairs ManagerSGS North America, Inc.
[email protected] +1 973 461 1493 MARKET NEWS - PACKAGING CORNER
PACKAGING CORNER
Focusing on the food packaging industry, this regular feature will examine issues affecting the industry. In this
issue we look at some of the certification standards that are currently available for packaging materials.
As most of you are probably aware, in GFSI benchmarking has been developed with. This also includes items related 2011 the Global Food Safety Initiative to introduce a key set of benchmark to the protocol aspects of the standard, (GFSI) initiated a programme to produce requirements that every packaging not just specific product/process based a benchmark document for packaging standard would be expected to comply standards. To reflect stakeholders and with. Standard owners wishing to be Standards that have already been standards effectively, this document was GFSI benchmarked could then submit compiled in co-operation with several their standard to the committee, who will key standard owners and relevant parties evaluate it against these requirements.
BRC/IoP Global Standard for Packaging and Packaging Materials – from the packaging industry, as well as The benchmarking document itself High Hygiene Risk support providers such as SGS.
comprises a number of criteria that a standard must demonstrate compliance FSSC 22000 Food Safety Management System – category M Food Packaging SQF Code edition 7 – Module 2 and 13 All packaging standards must have a risk-based element to them, with Food Safety System Certification (FSSC) and Safe Quality Food (SQF) focusing on the use of hazard analysis and critical control points (HACCP). British Retail Consortium (BRC) and Institute of Packaging (IoP) do not require any specific risk tool to be used.
The standards all require a documented management system to be in place, with associated quality documents and records being adequately controlled and maintained.
Likewise, all standards require pre-requisite programmes to be in place, with the FSSC standard focusing patriculalry on these through the additional requirements related to PAS223.
In the next issue we will take a more detailed look at the standards and consider their impact on packaging businesses.
SGS is able to offer accredited certification to all of these standards.
Neil MilvainGlobal Product Manager - PackagingSGS United Kingdom [email protected] +44 (0) 7785 464696 SGS FOOD NEWS
SGS BREAKFAST SESSION AT GFSI 2014 ON:
‘ALLERGEN MANAGEMENT, AN INTEGRAL
PART OF A SAFE FOOD SUPPLY CHAIN'
SGS, leading global solution provider in SGS will host a breakfast session on food safety, quality and sustainability will Friday, 28 February 2014 at 08:00 – be a main sponsor of the Global Food 09:00 AM about ‘Allergen Management, Safety Initiative (GFSI) Global Conference an Integral Part of a Safe Food Supply on 26-28 February 2014 in Anaheim, US. Chain'. In this session, the participants The overall theme of the conference is will hear perspectives and practices of ‘One World, One Safe Food Supply'. three professionals on how allergen The conference will bring together management, one of the fastest growing over 800 leading food safety specialists consumer trends and concerns, is from over 50 countries around the implemented in their organizations as an world to advance food safety globally. integral part of food safety practices. The Our company has been supporting this audience will also be able to hear new event as a sponsor for several years insights on the subject from the broader now as we believe that the Global Food market as a result of a global survey; Safety Conference is the world's leading To join the conference, please sign up business-driven food safety event.
at http://tcgffoodsafety.com. Following that, you will be invited to confirm your attendance in the breakfast session. SGS ACCREDITED TO OFFER FSSC 22000
CERTIFICATION TO FOOD PACKAGING
INDUSTRY
We are pleased to announce that
following a recent review of our
management processes, JASANZ, the
Joint Accreditation System of Australia
and New Zealand, has now approved
the scope extension of the FSSC 22000
standard to include packaging.
"SGS is proud of achieving this milestone as it is now even in a stronger position to be able to support our clients in the Food Packaging Manufacturing industry worldwide with food safety management systems through accredited FSSC 22000 certification", states Naghmeh Raiyat, Global Business Manager, Food at SGS.
Please contact us at: [email protected] on how to become a SGS FOOD NEWS
PARTICIPATE IN OUR SURVEY:
CURRENT PRACTICES ON ALLERGEN
CONTROL & MANAGEMENT
Awareness of risks from food allergens has evolved fast and it continues to develop. Food allergies and intolerances are now well recognized as a food safety issue, yet they need to be managed increasingly better.
The main purpose of this survey is to understand current industry practices relating to allergen control and management. Sharing your current practices, issues and suggestions will help us and the industry improve the consistency of allergen management, methods and practices. SGS will communicate the overall results and trends with industry as an aid to improving related management systems even further. However, individual responses to this questionnaire will be kept strictly confidential. Responding to the survey will take about 10 minutes of your time. SGS will share the industry feedback in a future issue of Hot Source and in our breakfast session during the 2014 GFSI Global Conference.
GLOBAL FOOD SAFETY -
SURVEY ON TRAINING PRACTICES
Campden BRI, Alchemy, BRC, SGS This survey is designed to take and SQF have teamed up to organize a approximately 15 minutes and all global benchmarking exercise on food responses will be treated in confidence, safety training practices. Distributed to remain anonymous and be used for over 25,000 food companies worldwide, research purposes only.
the information collected will provide How does your training programme a global analysis of the situation and compare to others on a global scale? trends in food safety training. By filling Find out by submitting the survey linked out this survey, you will receive a report of our findings which will help you to benchmark your training program and learn about best practices used around the world.
SGS FOOD TRAINING & E-SUBSCRIPTIONS
SGS FOOD WEBINARS
For a complete list of SGS seminars, courses and webinars, please check our
WEBINAR STATUS & LINK
Allergens Management: Basic principles Live on November 26 - Register @ and overview of available guidelines Food Packaging - An overview of available Standards and Implications on Food Safety GFSI - A Comparative Look at Various FSMS & their Suitability for your Business Food Defence: Current Guidelines and FSSC 22000: A Step Further from ISO 22000 + PAS 222 for animal feed BRC IOP for Packaging FSSC 22000 with PAS 223 UTZ Certified – A Sustainability Program for Coffee, Cocoa and Tea IN THE KNOW & IN THE NOW
news management tool. Whether you already subscribed to various SGS publications or this is your first try, our
publications management page will help you choose the right types of newsletters, alerts or reports from our
stable of international and country-specific publications. The main international Food-related publications and
bulletins include:
CONSUMER COMPACT – embracing all SAFEGUARDS - a technical bulletin SEED & CROP SERVICES - the latest consumer product segments it covers concentrating on new product news highlighting developments and international and product news, industry standards, regulations and test methods. specific capabilities in the Seed & Crop articles and stories about our activities. It SafeGuards is usually published weekly.
Services industry segment. is published quarterly. SGS EXPERT DOCUMENTS
OUR WHITE PAPERS - LEARN MORE ABOUT
FOOD QUALITY, SAFETY & SUSTAINABILITY
UNDERSTANDING THE US FOOD SAFETY
MODERNIZATION ACT (FSMA)

This document introduces the Food and further developed by a comparison with, Drug Administration (FDA) Food Safety and discussion around, Global Food Modernization Act (FSMA) and how its Safety Initiative recognized schemes proposals are likely to impact the food and the simpler move from these industry. The key provisions are detailed certifications to complete preparedness and compared against current industry- for FSMA compliance.
standard GFSI-recognized schemes.
Download your copy of: Advice is provided on how to prepare to meet the FSMA requirements, including a step-by-step process guide. This is MANAGING PERFORMANCE IN FOOD
SUPPLY CHAINS

SGS has recently published the white prevent adverse food supply chain paper ‘Managing Performance in Food related incidents and to increase the Supply Chains'. It discusses the impacts, performance of supply chains. Taking opportunities and challenges arising from these actions has the additional benefit managing food supply chain performance of protecting and enhancing the and protecting both producer and reputation of the organisations involved.
Download your copy of: In addition, it provides an overview of steps that can be taken to UNDERSTANDING SUSTAINABILITY IN
FISH AND SEAFOOD

Recently published, SGS's white paper reaching a harmonised understanding ‘Understanding Sustainability in the Fish of sustainability across the industry. and Seafood Industry and the Related Seafood is essential to the world's ability Certification Schemes and Consumer to feed the human population; adopting Guides' explores the industry's approach a long-term vision and investing in to sustainability and generating sustainability can only help to define its consumer conference. This paper discusses the current state of Download your copy of: global seafood stocks and how to meet current demand without endangering their future, including the difficulties in FOOD SAFEGUARDS & EVENTS
SAFEGUARDS
STAY ON TOP OF REGULATORY CHANGES WITHIN THE FOOD INDUSTRY!
SafeGuards, are SGS technical bulletins concentrating on new product standards, regulations and test methods.
They are written by SGS experts and dispatched on a weekly basis. Find below a selection of Food-related
SafeGuards titles from the past weeks. Subscribe to SafeGuards: www.sgs.com/ConsumerSubscribe
Browse the SafeGuards Library: www.sgs.com/safeguards
THE LATEST SAFEGUARDS
USDA Finalizes Bovine Import Regulations to Meet International Health Standards - US FDA cGMP, Hazard Analysis and Preventive Control for Animal Food Proposa EU Report on the Food Crisis, Fraud in the Food Chain and the Control Thereo European Food Safety Agency (EFSA) Highlights Risks from Potential Carcinogen in Vegetable Fats - EU Update of Import Controls on Certain Feed and Food - Amendment to EU Directive 2006/141/EC-Protein requirements for Infant and Fol ow-on Formulae - Recent US FDA Recal s - 60 Percent Due to Undeclared Al ergens - EU To Require Warning Labels on Products with Plant Sterol and Stanol Esters - New EU Regulation on Food for Specific Groups (FSG) - Safety Concerns with Whey Protein Concentrate Contaminated with Clostridium Botulinum - UPCOMING SGS FOOD EVENTS
.
EVENT TYPE
FOR ENQUIRIES
2013 SGS SA. All rights reserved. This newsletter is a publication of SGS SA. It is intended to provide general information on a particular subject or subjects and is not an exhaustive treatment of such subject(s). Accordingly, the information in this newsletter is not intended to constitute consulting or other professional advice or services. This newsletter is provided "as is" and SGS SA does not warrant that the information contained therein will be error-free or will meet any particular criteria of performance or quality. SGS SA expressly disclaims all implied warranties including, without limitation, warranties of merchantability, title, fitness for a particular purpose, non-infringement, security and accuracy. The information may not be quoted or referred to in any other publication or proceeding without the prior written consent of SGS SA.
SGS Group Management SA – 2013 – All rights reserved – SGS is a registered trademark of SGS Group Management SA

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Final notice: michael john allin

FINAL NOTICE Michael John Allin MXA01272 1.1. For the reasons given in this notice, the Authority hereby imposes on Michael John Allin ("Mr Allin") a financial penalty of £9,900. 1.2. Mr Allin agreed to settle at an early stage of the Authority's investigation and therefore qualified for a 30% (stage 1) discount under the Authority's executive settlement procedures. Were it not for this discount, the Authority would have imposed on Mr Allin a financial penalty of £14,100.