Introduction

We have come across one too many food poisoning cases in schools since May this year, as reported by the local dailies. We can not sit on our laurels and risk lives of sensitive groups of the population. We need not wait for a casualty of food poisoning before the relevant authorities take concrete action to eradicate poor quality and unsafe food served to any one in Malaysia more so students. We need integrated and proactive measures from government, industry (food producers, handlers) and the community.

Just when we thought the incidents of food poisoning (including the ones involving the milk programme) have been resolved another round of incidents as reported by BERNAMA yesterday (8th August, 2007) took place in Kedah and Kelantan.

Food Safety Problems in Schools

First of all, the manner in which some of the canteen operators have been dealt with implies that the relevant regulatory and administrative bodies are not keen at all in solving this problem. Based on the compilation of food poisoning reports in the local print media (newspapers) by the Malaysian Association of Standards Users, we discovered that more than 2600 people have fallen victim to food poisoning. (see Table 1). But we are very sure this figure is way under represented. The reason we say that is because we have not included a concise report by the Sarawak State Health Department which shows that till May 2007, there were 15 incidents of food poisoning in the State of Sarawak alone (9 occurred in schools; whilst others occurred in other educational institutions like polytechnics) . The cumulative incidents (including institutional and non institutional) is 234 as of April 2007.  We would like to express our sincerest appreciation to the Sarawak state government for being transparent and prompt in keeping the records updated and easily accessed online. Sadly, all the other states have failed to emulate such good practices.

Even more under represented is the statement by the Deputy Minister of Education Datuk Hon Choon Kim saying that there were ONLY 19 food poisoning cases which had occurred in schools over the last 6 months. Excluding national service training camps (1) and polytechnics (1) and individual food poisoning (1), we have compiled a total of 37 cases of food poisoning in schools – see Table 1 below (out of which 11 cases involve the School Milk Project or SMP or PSS Projek Susu Sekolah). The table below is compiled based on archives of UTUSAN MALAYSIA the STAR, Bernama, NST and Berita Harian. We would like to express our appreciation to all the print media which allowed free access to their news archives.

About the Desktop Study of Food Safety Incidents in Malaysia 2007, by the Malaysian Association of Standards Users (Standards Users)

Table 2 shows the schools, number of victims and types of food suspected to have caused poisoning among secondary school children. A total of 859 students have become victims of food poisoning. Almost all had their meals prepared by canteens or hostel canteen operators. SMK Sains Sultan Mohamad Jiwa had food poisoning incidents on 2 occasions and the same goes for SMK Ayer Hitam; both schools in Kedah.  We believe that both are residential schools. Among the two SMK Sains Sultan Mohamad Jiwa had the highest number of victims i.e a total of 248 students, while SMK Ayer Hitam had a total of 144 student victims.
 
The latest incident was reported on 9th of August 2007 at a residential school in Sungai Buloh involving 81 students.

Table 3 shows details of the SMP which involves primary school children. The SMP is only provided to primary school children. According to reference from the Prime Minister’s Department the Projek Susu Sekolah (PSS) or the SMP was officially launched at national level on 9th December 1983 by the first lady (then) Datin Seri Dr. Siti Hasmah Binti Haji Mohd. Ali. It was then implemented by the Ministry of Education together with Syarikat Nutritional Products Sendirian Berhad.

The essence of the SMP or PSS was to help poor and underprivileged students to have access to nutritious food. Many food experts and nutritionists will concur that milk is definitely a complete food with proteins, fat, carbohydrate, vitamins and minerals needed for children. The noble idea by the Ministry of Education then was to provide an opportunity to poor students to enjoy some form of quality food at least at school.

The project implementation has entered its 24th year. Since we (Standards Users) have no access to more than 20 yrs data on food poisoning or food poisoning caused by milk from the SMP, we are unable to verify if there has been an increase in the poisoning incidents. Not even for the past five years. But, a review of food poisoning cases all the way back to 2002, in the archives of UTUSAN MALAYSIA yielded no poisoning cases due to milk supplied through the SMP.

Based on Table 3, there have been 11 cases on food poisoning cases due to milk supplied through the SMP endangering the lives of 506 students. The state of Kedah as most of us have discovered tops the list with the highest number of cases.

If we look at Tables 3 and 4, it is obvious that approximately one third of all primary school food poisoning victims are victims of poisoning due to milk from the SMP. The other two third are victims of food poisoning caused by meals taken at school canteens or provided by external caterers.

Again, review of the Malay daily’s archives shows very few incidents of food poisoning cases for the past 5 years but an increase in frequency was observed in 2006 (9 cases; of which 6 involved schools). Again Kedah topped the list.
 
Incidents of food poisoning in 2006 – according to news archives of UTUSAN MALAYSIA.

Based on Figure 4, in addition to dangers posed by contaminated milk from the SMP primary school students also fall victim to contaminated food served at their school canteen or by external caterers (more than secondary school students). We calculated that 26 cases out of the 37 cases of food poisoning took place at primary schools. This could be due to few reasons among which are:

1.    the primary school students are exposed to 2 sources of poisoning; from milk and meals prepared at the canteens.
2.    children 12 yrs and younger may be more sensitive to contaminated foods and beverages than teenagers.
3.    perhaps these group of consumers have lesser awareness on importance of hygiene than teenagers

With such issues, preparing meals for this group of students requires the utmost attention and care.

Causes for Concerns

1.    The denial of suppliers of their responsibility towards poisoning caused by the milk supply under the SMP (NST 9th August 2007) shows how irresponsible and inconsiderate they are or would have been. As a supplier of sensitive food products to sensitive group of consumers they should take all the responsibilities in ensuring that the products are handled in a safe manner from farm to table. EVERYONE in the food supply chain is totally responsible.

The investment for the School Milk Programme is said to be a whooping RM 23.9 million annually. It is now more of a liability. The media reported that 560, 169 pupils should benefit from the programme. That amounts to approximately RM 40.50 per student. Some of the UHT milk is actually produced by renowned manufacturers of famous brands and have or may have the good manufacturing practices in place in their manufacturing facilities. However, in the case of their products being supplied to schools, they have failed miserably to control the supply chain to ensure that the products are handled properly till it is consumed by the intended consumers.

2.    The landmark response of an irresponsible supplier is – “their job is to deliver and it is not their fault when there other players in the supply chain”. The suppliers after their meeting with the Deputy Health Minister said that “it was not part of their contract to check on how the milk was handled after delivery to schools”!!!

In the first place let us set the record straight about the benefits of the UHT technology in liquid milk production.

About UHT (Ultra High Temperature)

First of all, let us set the premise based on the fact that UHT or Ultra High Temperature is a form of treatment to terminate harmful bacteria and is the preferred treatment for liquid milk. The preference showed for this form or treatment is because of the fact that UHT milk can be kept without refrigeration at normal room temperature (25degC) approximately up to 6 months.

BUT the key aspect of its ability to increase shelf life is also because of aseptic packaging. The aseptic packaging system is unique that it fills a sterilized package with a sterile food product (or in this case UHT milk) within a confined sterilized environment. The process of aseptic packaging should be monitored to ensure that the aseptic packages are sealed tight. Care should be taken to minimise contamination during subsequent handling after final packaging.

The discovery of the aseptic packaging is a boon for populations which have very little access to nutritious food and are unable to invest on controlled storage infrastructure for food distribution. Aseptic packaging has allowed critically needed food products to reach vulnerable populations in least developed countries or parts of countries. Even the Red Cross (or Red Crescent) requests for aseptically packaged food products for disaster relief. Packaging materials used for aseptic packaging are also environment friendly. The drink box combines thin layers of paper, plastic, and aluminium to form a unique, high-performance beverage and liquid-foods container that is both compact and lightweight. Each material used in the drink box plays an important role in protecting food safety and quality.

Aseptically packaged milk is often preferred where clean drinking water is difficult to find thus making powdered milk unusable.

The Institute of Food Technologists (IFT), a non-profit scientific society working in food science and technology has called the aseptic packaging as the most significant food science innovation of the last 50 years.

In order for UHT milk to last, it has to be packed aseptically.

Chances of faults happening with the aseptic packaging process are likely if:

1.    product or milk is not properly treated – poor temperature control, process monitoring and verification of effectiveness of processing parameters to produce the level of bacterial spore reduction preferred for long storage;
2.    packaging environment not sterile;
3.    packaging materials not sterile;
4.    sealing is not tight;
5.    perhaps, it could even be that the raw material (raw milk) was already with high bacterial load; and
6.    Stacking of finished product – if stacking of packed product on top of the other is too high, the bottom-most packs may experience weakening of the seals or sealing points. Openings which are not visible to the naked eye can allow germs to penetrate and cause spoilage of the milk or even poisoning to the consumers.

Spoilage often results in blown packages due to bacteria growth.

Even if the process of UHT and aseptic packaging has gone well, storage at higher room temperature (more than 25degC) may allow for changes in chemical composition of the milk. Since milk has significant amount of fat and protein certain chemical reaction is accelerated under high storage temperature. This results in changes in taste and appearance (aesthetic changes) due chemical browning and fat rancidity.

Responsibilities of Players in the Food Supply Chain.

Having briefly explained about UHT, we now direct our comments, demands and recommendations to the suppliers, producers, the parties offering and approving the tenders and all other parties in the food supply chain.

Comments:

Based on the compilations of incidents below, the milk programme is not the only source of food poisoning cases in Malaysia affecting children in schools. Table 2, 3 and 4 shows that out of the 37 cases at schools 11 of them involve contaminated milk from the School Milk Programme (SMP). The other 26 cases involve meals prepared by canteen operators (most frequent) or external caterers. The total number of victims is a staggering 2382 students (both milk and canteen meals).

What kind of an education and public health system allows this to happen to vulnerable groups?

School Milk programme:

It is the responsibility of the producer to ensure that their products reach the intended consumers without compromising product safety. If they can not assure that then they should not be supplying them or should be banned from supplying to consumers.

Certification of the producers who have been certified with HACCP (Hazard Analysis of Critical Control Points), but can not ensure safety of products from ‘Farm to Table’, should be revoked. If their certification body (CB) keeps renewing their certificate despite repeated safety problems, that CB should be de-listed from the list of accredited CBs by the Department of Standards Malaysia.

The very concept of HACCP and GMP (Good Manufacturing Practice) is, safety is ensured from the minute the seed is planted (primary production) till the final product reaches the table of consumers; thus the phrase ‘Farm to Table’.

The government especially the Ministry of Health and in this case also the Ministry of Education should not strive to please the industries. Theirs (the ministries’) is a noble task of ensuring better health and access to quality education and life long learning, respectively.

The US FDA and Food Standards Agency (UK) impose bans and closure of premises found to have caused food borne illness outbreak. A food borne illness outbreak is when two or more or a group of individuals suffer the same symptoms after consuming the same type of food.

Have we categorised our situation here in Malaysia as an outbreak? No. There is no sense of urgency in dealing with the matter which obviously is an outbreak, when 40 cases or may be more have been reported till 10th of August this year. Actions should have been taken to rid the market of all the consignment and the supply chain scrutinised to eliminate the source of the problem.

The order for the milk supply to be approved by SIRIM was misplaced since SIRIM has been corporatised and became a GLC since 1996. SIRIM Berhad provides testing and other technical services and SIRIM QAS the subsidiary of SIRIM Berhad provides product certification services and management system certification services. Unless and until the relevant standards are made mandatory testing does not guarantee safety of the milk consignment. Testing is made on samples and not 100% of the consignment which leaves a factory. Who does the sampling and testing just before the milk consignment is delivered to the schools?

Milk is a wholesome food and the programme is targeted at poor students to have sound body and mind to pursue their education. We believe that there is no suitable or equivalent replacement for milk. Scrapping the programme is just like sweeping the problem under the carpet or out of sight out of mind situation.

Food poisoning:

Ever wonder why many of us still patronise unhygienic eateries and complain most of the time when restaurant operators increase prices of their food items? Can the school be a place to cultivate or practise what was learnt in classrooms and books about food hygiene? We suppose that children have grown in an environment where they have accepted the hygiene level in their school canteens as a norm. The same situation is accepted and accommodated when they leave school.

We will never get anywhere with improvements in safety of ready to eat food i.e at restaurants or catering services if we allow future generations to accept, accommodate  and tolerate sub standard food handling methods or environment.

We have visited secondary schools in Klang, where the canteen operators do not even provide soap at hand wash areas. The school management also does not prepare soap in the student toilets.

The Ministry of Health and in this case the Ministry of Education have again shown no sense of urgency in solving the food poisoning problems at schools which is very obvious when they have allowed a 6 times violator to continue to operate the canteen at SK Guar Nangka, Perlis. The contract of the operator should be immediately terminated and never to be renewed or reinstated. The owner or the food handlers should be banned from setting up restaurants or any form of mass catering business.

Both MOH (Ministry of Health) and MOE (Ministry of Education) are looking into grading canteens. We would like both the Ministries to highlight the criteria established to grade the canteens. The criteria established for grading and the operating guidelines established for a canteen operator will indicate the seriousness of both the Ministries to solve the problems of food poisoning cases at schools.

Standards Users have reviewed the grading system used by three local governments (i.e MPSJ, MPK, and MBPJ). All three differ in requirements and thus the certificates offered are not based on standardized or harmonized requirements. Furthermore, the grading criteria are not based on any established national standards. How can anyone be sure that the restaurants are as hygienic as required when grading criteria differ?

We suggest that all canteen operators are trained on Mass Catering Standards established by Codex .

Strong Requests:

The Food Safety and Quality Division (FSQD) under the Ministry of Health must:

-    investigate every aspect of the supply chain to find the root cause of the milk consignments going bad. Detailed outcome of the investigation to be published and easily accessible.
-    publish the names of the producers and suppliers involved / who neglected their responsibilities
-    publish details of the investigations, findings / results and actions taken to prevent recurrence
-    immediate ban on operators who is responsible for the food poisoning cases in schools. License should be revoked and operators blacklisted. List of which must be readily available.
-    immediately adopt/ impose strict standards and enforce them industry wide – requiring extended responsibility of producers to control and ensure safety of food upstream and down stream of the supply chain.
-    make data on food poisoning cases readily available to stakeholders and that definitely includes consumers.
-    adopt mass catering standards (based on CODEX) as mandatory to be used by all canteen operators in schools, and any other educational or learning institutions.
-    amend the Food Act 1983 and Food Regulations 1985 to spell out mandatory compliance with GMP and HACCP standards for the manufacturing, sales, distribution and retail operations of sensitive products (such as products from animal source: milk, egg, meat, poultry, fish etc) for sensitive groups (children and infants).
-    show some bite in enforcement activities. They should not be depending on irresponsible industry players to respect self regulation.
-    pre-requisite for certification bodies (including MOH) and the relevant laboratories to be accredited by the Department of Standards Malaysia.
-    amend the relevant Acts or speed up the process of finalising the Regulations below:
        o    Food Hygiene Regulation (adoption of GMP, HACCP and Codex Mass catering standards)
        o    Food Import Regulations (include recalls and anti dumping elements) and
        o    Food Analyst Act (guarantee independence; strict enforcement and chain of custody of samples etc)
-       a transparent process for drafting regulations and Acts will involve comments from stakeholders (again this means consumer organisations)
-    conduct a nationwide inspection to establish safety and compliance status of food intended for the consumption by infants, children, pregnant mothers and the elderly or the health wise compromised consumers.
-    establish a fast and effective outbreak response infrastructure – involving hotlines, incident reporting by both public and private hospitals and practitioners and other medical officers or institutes.

Summary

We strongly reiterate that the MOH’s and the Ministry of Education’s functions definitely does not include protecting the business and profitability of food industries and ready-to-eat meal service providers but rather protecting the general public from harm and inculcate good human values and producing responsible citizens respectively.

We also reiterate that:

-    Mandatory compliance with GMP, mass catering standards and HACCP is paramount now more than ever to indicate that both Ministries are genuinely finding ways to solve the problem with food poisoning and also to show that improving quality of life and education is their focus.
-    Milk should not be substituted. If root cause is not found and solved any food products will pose the same danger to children. Milk is a complete meal. UHT technology aims to also preserve most of the nutrition in the milk, thus enabling access to nutritious and safe meal for the under privileged.

We welcome the idea to eliminate the distributors and the producers to handle the delivery of the milk directly to schools. But then again both Ministries have to also put in place quality control points and checks to assure safety of consignment when it reaches the children. Records of monitoring and quality control system should be submitted periodically to agencies responsible for monitoring the SMP at either Ministry.