Four lessons have been identified involving regulation during COVID-19 by the Food Safety Authority of Ireland (FSAI).

They include the role of early warning and emerging risk systems to help authorities respond quickly to new threats and how by accepting an impact on official controls, agencies can maintain high priority activities during crises and still protect public health.

Restrictions during the ongoing pandemic have affected the food industry, the FSAI and official agencies in charge of regulation. They resulted in significant disruption to the supply chain, suspension of some official controls and other related activities, halting of business-to-business food safety verification and restrictions on the nature and frequency of official controls. The supply chain became vulnerable to fraud and food safety problems as due diligence checks on suppliers decreased because of movement restrictions and suspension of third-party audits.

The FSAI and enforcement officers found it a challenge to ensure businesses kept a focus on food safety when they were trying to comply with COVID-19 health and safety measures and impact of the pandemic on the workforce. Problems were particularly acute in Irish meat and poultry plants which had a number of COVID-19 outbreaks amongst workers, according to the report.

Flexible rules and fewer inspections
Supply chain problems meant that firms had to rapidly identify alternative ingredients. This resulted in breaches of food labeling legislation. However, given the situation, the FSAI provided advice that focused on compliance with safety aspects of food law like allergen labeling ahead of non-health related issues such as origin labeling. Overlaying of product labels was allowed but firms were warned not to overlook the allergen, chemical and microbiological safety aspects of new ingredients.

COVID-19 impacted the inspection activities of all official agencies but in March to June 2020, the biggest disruption on official controls was at the Health Service Executive (HSE), which is mainly responsible for checks in retail businesses and firms manufacturing foods of non-animal origin. Official laboratories operated by HSE were also affected as some were reconfigured to test for COVID-19 rather than food.

The decrease in official controls capacity was offset to an extent by the fact that many businesses in the food service sector closed due to COVID-19 public health measures, although a smaller proportion either continued to provide existing takeaway services or altered their business model to provide new takeaway options.

HSE data showed a 36 percent decrease in the inspection count in establishments. Figures from the Department of Agriculture Food and the Marine (DAFM), which does controls on-farm as well as manufacturing and wholesale of food of animal origin, showed inspections fell by 39 percent from 12,214 in 2019 to 7,408 this past year.

At the Sea-Fisheries Protection Authority, which is responsible for controls in seafood plants, the inspection count was more stable at 1,911 compared to 2,121 in 2019. A similar trend was reported by local authorities wher veterinary officers carry out controls in small meat sites. Here inspections decreased by 12 percent from 4,320 in 2019 to 3,790 in 2020.

More unregistered operations but food poisoning reports down
Overall, there was a reduction of 30 percent in the number of samples taken for analysis from 28,374 in 2019 to 19,951 in 2020. The biggest decline was 48 percent for food samples from premises under HSE supervision.

FSAI became aware of a surge in food businesses in inappropriate premises during the pandemic. These illegal firms were often not hygienic and had little or no food safety systems in place. One example involved closure orders being served on sushi operations from the bedroom of a rented house in Santry, Dublin in October 2020. The number of unregistered businesses uncovered by the FSAI and other official agencies rose from 19 in 2019 to 47 in 2020.

Complaints to FSAI’s advice line dropped in 2020 compared to 2019 to 2,772 from 3,460, influenced by many businesses being closed during the three lockdowns.

Calls about suspect food poisoning fell from 22.9 percent of complaints in 2019 to 15.5 percent in 2020. This was unexpected given the number of outlets that went from eat-in only to takeaway models which raised food safety concerns around these new unfamiliar processes, according to the report.

However, it is possible numbers were affected by other factors like a decrease in food eaten in/from food businesses, a simplification of menus or an increase in underreporting due to reduced willingness of sick people to visit general practitioner’s surgeries.

Wider picture

Revised EU regulation also permitted flexibility. It allowed official controls to be carried out using a nominated person in place of the authorized inspector and tests to be done in any unofficial laboratory on a temporary basis provided that it was designated by the national authority for that purpose. Border checks could use electronic documentation and physical inspections substituted by other means of communication.

Reports from China suggested SARS-CoV-2 could be transmitted via packaging of frozen food and the surface of such foods, particularly seafood and meat. Authorities implemented sampling and testing of cold chain food and packaging. Chinese government figures in late 2020 stated the PCR positive rate from testing imported cold chain food was 0.48 positives per 10,000 tests. This is one positive for every 20,000 tests.

At that level of defective product, FSAI calculations show that to have 95 percent confidence that a shipping container carrying 50,000 packs of 500-gram frozen seafood was free of SARS-CoV-2, an inspector would have to sample 40,000 packs or 80 percent of food packs in the container. Irish officials said this shows it was not practical or protective of public health to implement PCR testing of imported cold chain foods for SARS-CoV-2.