The Changing State of Food Safety
Food safety in 2025 and beyond - a global perspective
As the creator of the popular independent newsletter, The Rotten Apple, my job is to stay on top of all the food safety news from around the world every week. It’s kind of overwhelming at times!
Many food safety principles don’t change from year to year… we still need to keep our facilities clean, train our staff and have robust systems in place to stop consumers from getting sick. Our major food pathogens still pose the same risks as before, and we still use the same controls as we have for decades to keep them from causing illness.
But things change too, and in the past two years I have felt the zeitgeist shift for certain elements of food safety. To my mind, this shift has become noticeable compared to previous years.
In this post, I attempt to crystallise the vague feelings and cultural shifts that appear to be coalescing around certain topics in food safety, from both within and beyond our industry, starting with the awkward topic of ultra-processed foods (UPFs) and their safety - or lack of safety - for consumers.
UPFs: awkward
Why are UPFs an awkward topic for a food scientist? Well, as a scholarship recipient of perhaps the most famous carbonated beverage company on the planet and a former product development technologist for a major international snackfood brand, I get that food scientists and food safety managers don’t want to be caught up in existential debates about the rightness or wrongness of ultra-processed foods.
Writing about nutrition is not my thing.
But food safety is my thing, and ultra-processed foods are increasingly being recognised as a food safety issue rather than just a nutrition issue– at least in the broader community.
The evidence for the unsafeness of ultra-processed foods has become very strong in the past two years and public commentary on the issue is getting louder.
Just this month, the mechanisms for the negative health effects of UPFs have been elucidated in a way that is more compelling than in past research. We’ve progressed from knowing that UPFs are linked to overconsumption of calories to knowing why, with research published this year showing that reduced chewing, hyper palatability and high energy density are almost certainly to blame for the 1000 calories per day difference between high UPF and low UPF diets.
So while the healthiness or not of UPFs isn’t a food safety issue in the traditional sense, it’s begun to be seen as one by people outside our industry… people who are in a position to make big changes that will affect the big food companies many of us work for. The Make America Healthy Again campaign by the US Republican Party is one such influence.
What does all this mean for traditional food safety? We don’t know yet. But as is often the case, a lawsuit by a disgruntled American consumer could signal the start of a major change in community attitudes.
The lawsuit, which alleges ultra-processed foods are harmful and addictive, was filed in Philadelphia last week against major food companies – the first of its kind, and perhaps the first of many.
It’s no coincidence the lawsuit was filed soon after the release of new research by Kevin Hall which is being hailed as the strongest evidence yet for the mechanisms behind the overconsumption of UPFs.
This evidence gives the lawsuit a better chance of being successful than ever before, and it could signal the start of major changes to consumer and government perceptions about the safety of food with respect to diseases of overconsumption.
During 2024 I noticed a subtle but definite shift in the way the mainstream media talks about ultra-high-calorie diets. Until now the language has subtly placed the blame on overweight consumers for diseases of overconsumption such as type II diabetes, heart disease and fatty liver disease, attributing the diseases to poor dietary choices, poor nutrition education and a lack of self-control.
In the past year, however, the dialogue has shifted. Now it’s food companies that are being blamed for overconsumption, not consumers. Nutritionists and policy-makers are increasingly blaming the irresistibility and addictiveness of foods for consumers’ diet-related health problems.
There is also wider recognition that food companies have deliberately designed foods to be addictive and effective at circumventing the body’s natural defences against overeating.
The days of blaming the consumer for diet-related health problems – particularly diseases of overconsumption – are coming to an end.
I expect we will see major changes to the regulatory environment in years to come. There are already calls for more government intervention and regulation around the nutritional characteristics of manufactured foods, which could ultimately have big impacts on our employers.
If nutritional characteristics impact food safety - as many now argue they do - perhaps one day food safety professionals will work with product developers to make sure new food formulations aren’t too delicious, in order to protect consumer health. Now that would be something!
Allergens
We made good progress in 2024 with allergen awareness and internationally harmonised thresholds. More food businesses and regulatory authorities are recognising the risks faced by allergic consumers. Valuable guidance on allergens of importance, allergen ‘safety’ thresholds, labelling rules and exempt ingredients was published by WHO/FAO in April.
Sadly, there are still many preventable food allergen labelling mistakes, leading to deaths and recalls. In fact, recalls due to undeclared allergens are at an all-time high in the United States and Australia, with the United Kingdom also reporting a major problem with allergen-related recalls (Issue 143 and Issue 133).
What’s new is that food safety professionals are now being held personally accountable for allergen deaths in the legal system, with a lawsuit filed against a food business and several of its employees, over the death of Órla Baxendale who ate cookies containing undeclared peanuts and died despite using an EpiPen in January.
The wrongful death lawsuit contains allegations that the food business’s labelling control systems were “broken, unreliable, inherently dangerous, undependable, untrustworthy, erratic and deplorable.” (Issue 143).
This new development is worrying for food safety professionals who are working for businesses that don’t properly prioritise allergen risks.
Standards and food regulations
GFSI benchmarked standards and food regulations have changed in recent years.
Version 6 of the FSSC 22000 scheme was published in 2023 and implemented on 1st April 2024. The big changes for version 6 are in the areas of food safety culture, quality standards and systems for managing loss and waste (Issue 130).
GLOBALG.A.P.'s Integrated Farm Assurance (IFA) version 6 replaced IFA v5.2 and v5.3-GFS on 1st January 2024.
IFS Food version 8 was released in 2023, and became mandatory for all certified companies starting January 1, 2024 (Issue 49).
The long-awaited US food traceability rule, (FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods) was finalised in January 2023 with compliance due in January 2026. However, a bill to delay enforcement of the rule was introduced to Congress in March - no result yet.
The European Union Deforestation Regulation (EUDR), which is predicted to disrupt supply chains for soya, beef, coffee, palm oil and cocoa was due to be enforced from December 2024 but has been delayed by one year.
Food safety culture
Food safety culture systems requirements are now fully embedded in all GFSI-benchmarked standards. Knowledge about how to measure and build food safety culture has increased but it remains a common source of non-conformances in audits and continues to be a hot topic among food safety professionals.
We explored the 8 Key Non-conformances in Food Safety Culture Implementation in Issue 145 and I shared the latest best practices in food safety culture systems in October.
Chemical contaminants and microplastics
Last year also saw a change in attitudes towards chemical hazards in food, as the long-term health effects from ingesting small doses of harmful chemicals become more widely recognised.
Again, these issues are not typically a priority in traditional food safety, but I think expectations are slowly changing - and not before time.
In 2024 we witnessed the fallout from the lead in cinnamon apple puree recall in the US, as consumers were (rightly) horrified to discover the vulnerabilities in children’s food supply chains.
The initial problem, with (likely) fraud-affected cinnamon powder used in products manufactured in Ecuador, was followed by a spate of recalls of unrelated cinnamon powders for elevated lead levels across the USA.
Was there more lead in the food supply? Unlikely. The recalls were probably due to increased testing as a result of increased awareness following the initial recall.
Certain food dyes were recognised as harmful by the state of California and banned by the state government, in a move that may be repeated at the US federal level before too long.
Concern about PFAS chemicals and microplastics in food and drinking water also increased markedly across the globe in 2024. There is increasing evidence for the harm caused by ingesting such materials and food suppliers will increasingly be expected to pay more attention to understanding and controlling low concentrations of chemical hazards.
Bird flu (H5N1) in milk
The biggest surprise in food safety for 2024, to my mind, is the slow-motion train wreck of bird flu in dairy cows in the US. It is likely to have long-term global consequences.
It started in March as an unexpected ‘blip’ which took everyone by surprise, according to a USDA official. But as the world watched on, horrified, it grew into a major biosecurity disaster. One that has already spilled from cows into poultry and humans and now threatens to become a breeding ground for a new strain of influenza that spreads easily from human to human.
Biosecurity controls were not enacted, despite the USDA admitting they knew that the movement of cows, farm workers and milking equipment was responsible for the spread of the virus (Issue 148)
In April, an FDA survey of 297 samples of milk from retail outlets found inactive virus particles in 20% percent of samples. At around the same time, researchers revealed that milk contaminated with live virus was capable of infecting animals that drank it.
Meanwhile, shockingly, sales of raw milk soared in the US, a phenomenon some specialists attributed to mistrust in governments and ‘big food’ (Issue 148).
By August, the H5N1 outbreak in dairy cows had showed no signs of slowing down, and had begun to spread to poultry as well as to people who work with cows. Some experts believe the virus will become endemic in dairy herds.
At the time I reported that the commentary had progressed from “this is a blip” to “this could be the new normal” (Issue 153).
The longer the virus stays in cows, the more likely it is to develop the ability to easily infect other mammals, increasing the chances of a mutation that allows it to spread rapidly from human to human.
The USDA says their current response protocols are “adequate” for controlling the outbreak in cows, while infectious disease experts disagree. “We’re still totally in a state of confusion,” said Michael Osterholm, an infectious diseases expert at the University of Minnesota in August. Another told reporters “They (federal officials) have had every possible warning that this is a virus that could go pandemic (in humans).”
“They’ve had every possible warning that this is a virus that could go pandemic.” Dr. Tom Peacock, a virologist at the Pirbright Institute in Britain, via The New York Times
Final thoughts
While the basic principles of food safety don’t change much over time, I’m noticing a shift in expectations about what safe food means to consumers and policy-makers.
Food safety professionals are increasingly being asked to consider the impacts on human health from overconsumption and from the ingestion of low-dose harmful chemicals such as heavy metals, microplastics and PFAS chemicals in foods.
Allergen management principles have not changed but food safety professionals are now being held personally accountable for allergen deaths in the legal system, such as in a lawsuit filed against a food business and several of its employees, over the death of an allergic consumer who ate cookies that were improperly labelled.
Finally, the intersection of food safety and animal safety has been brought into the spotlight by the unfolding disaster of highly pathogenic avian influenza in dairy herds and milk in the United States.
I’ll be keeping my eye on all these issues for you over the coming year. Stay tuned for updates.
This article originally appeared in Issue 169 of The Rotten Apple.