Keoghs Insight


Ivor Long

Contamination in the grocery supply chain

Food for Thought Winter 18-19

The risk of food contamination and spoilage is a serious issue for suppliers, third party logistics (3PL’s) operators and retailers, especially given the recent adverse publicity surrounding the tragic death of a teenager exposed to a food allergen not immediately labelled on packaging.

There is an ever present risk of cross-contamination during transit and careful consideration must be given to which food products are being transported together, the risk of breakage and spillage onto other products and the subsequent handling of such items throughout the supply chain and at the point of storage and/or sale.

In the event of an incident affecting a consumer, the retailer will be looking to pass the issue down the supply chain, and both the supplier and 3PL operator will need to show that they have robust procedures and processes in place which are backed up by relevant documents.

Equally, both retailers and suppliers will also want to see that these documents and processes are adhered to as part of their due diligence. 

Effectively every aspect of the supply chain will come under scrutiny.

3PL audit checklist

3PL operators will need to be able to demonstrate how the product was treated under their care from the point of collection, possible storage and through to delivery.  Depending upon whether this involves ambient, chilled or frozen food products such records will need to include:


  • Pre-load operation and inspection - cleaning regimes
  • Pre-load trailer inspections by drivers and loaders – beyond the safety of the load itself and the potential for load movement during transport and the possibility of breakage, spillage and cross-contamination
  • Driver training needs to be far more detailed around these potential issues
  • Refrigerated trailer pre-planned maintenance and records 
  • Temperature and humidity control records during transit - telematics is now commonplace to assist with evidencing this
  • Breakdown and business continuity plans – what happens when there is a vehicle or trailer failure and how do you ensure that the product has been maintained at a safe temperature – back up systems and batteries?
  • Process for dealing with breakage, spoilage and handling procedures to ensure the integrity of other products is maintained
  • Cross-contamination avoidance procedures – especially with regard to manual handling and the risk of food allergen contamination of non-allergenic products


There is an ongoing issue with the lack of availability of LGV drivers, meaning all 3PL operators are competing for a small pool of qualified drivers which is insufficient to satisfy demand.This can lead to delays in goods being transported on time and potentially being held for longer than anticipated in storage depots.

I have also seen loaded refrigerated trailers standing in yards under charge because there is no available driver or tractor unit

Consider the following scenario:

  1. Fresh tuna packaged for retail sale is loaded onto a refrigerated trailer for distribution to store outlets.
  2. Following sales there is an outbreak of alleged scombroid food poisoning due to raised levels of histamine in the fish.
    It is tasteless, has no odour and is unaffected by cooking with consumption generally resulting in a rash, fever and stomach pain.
  3. Retailers then look to pass responsibility on to supplier and/or 3PL operator.

What evidence do you have to support safe transport and distribution?

How can you show that the issue is more likely to lie with either the factory processing or post-delivery storage?

Unless you have the appropriate procedures and processes in place and are in a position to evidence this with the necessary documents as set out on the left, you and your insurers may be looking at a significant cost for claims, stock loss and possibly product recall.

All of these issues also give rise to the possibility of regulatory interest, enforcement and the additional negative publicity surrounding any prosecution together with the very large fines that can be imposed as part of the recent uplift in sentencing guidelines.

A failure to implement and fully document the necessary procedures can place any business at risk with their brand reputation and commercial contracts