ABSTRACT
This paper presents a case study on the management of a food fraud
associated with health risks: the illegal use of sulphites in meat
preparations and minced meat in Slovenia in 2019. The purpose is to
highlight the shortcomings of existing systems for ensuring food safety in
case of food frauds and highlight challenges for improvements. 
Sulphites are food additives but also have significant allergenic potential,
hence they may cause serious reactions in sensitized consumers. Labelling
of foods treated with sulphites is mandatory, and their use in meat and
meat preparations in Europe is not allowed. However, certain food business
operators may intentionally add sulphites into meat preparations to
improve the sensory properties; besides being a food fraud, this exposes
unaware consumers to health risks. 
The case started with the notification of an allergic-like reaction by a
consumer following the consumption of a meat product. While the public
authorities reacted by intensifying controls on markets and retailers, the
analysis of risk management and risk communication aspects showed a
number of shortcomings: slow response time; lack of recall of sulphite-
treated meat products and of an in-depth risk assessment.
The evaluation of this case study identified violations of food law
regulations and consumer protection legislation. Effective risk management
requires an interdisciplinary approach, integrating timely and targeted
official control and risk communication throughout the food chain to protect
consumers from unfair practices. Consistent, effective, and transparent
communication among all actors who share responsibility in ensuring food
safety is necessary to achieve improvements. 
This serious case of food fraud with actual risks to consumer health
provided an opportunity for lessons to be learnt regarding managing health
hazards from intervention to prevention.
Keywords: risk management, risk communication, food additives,
sulphites, food fraud, consumer protection
23
SANITARNO INŽENIRSTVO / International Journal of Sanitary Engineering Research
2023;16(1): 23-39. DOI: 10.2478/ijser-2023-0004
Risk management and
risk communication of an
illegal use of sulphites in
meat preparations
© 2023 Elizabeta MIČOVIĆ, Alberto MANTOVANI, Mojca
JEVŠNIK. This is an open access article licenced under the
Creative Commons Attribution NonCommercial- NoDerivs
license as currently displayed on
http://creativecommons.org/licenses/by-nc-nd/4.0/.
*Corresponding author: 
Assoc. Prof. Mojca JEVŠNIK, PhD, BSc Sanitary Engineering
University of Ljubljana, Faculty of Health Studies
Zdravstvena pot 5
1000 Ljubljana, Slovenia
Email: mojca.jevsnik@zf.uni-lj.si
   University of Maribor, Faculty of Agriculture and Life Sciences
Hoče, Slovenia
   Italian National Food Safety Committee Rome, Italy
   University of Ljubljana, Faculty of Health Studies Ljubljana, 
Slovenia
Elizabeta Mičović   , Alberto Mantovani   ,
Mojca Jevšnik* 
Original scientific article
Received: 24. 11. 2023 
Accepted: 21. 12. 2023
Published: 31. 12. 2023 
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Revija Sanitarno inženirstvo / International Journal of Sanitary Engineering Research Vol. 16 | Issue 1 | 2023
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INTRODUCTIONE. Mičović, A. Mantovani, M. Jevšnik
Food additives are intentionally added to food for a technological purpose in
the processing and preparation of food products [1]. The use of certain
additives is authorized in a certain quantity and only for one or more certain
food categories – considering food intake, characteristics of foodstuffs and
scientific knowledge, to ensure that use is safe also for a consumer with a high
intake of the food(s) for which the additive is intended. When scientific
evidence does not support safe use, then using certain additives in given food
categories is not allowed [2]. Food additives enable food safety and quality to
be preserved [3]  and their use is motivated by the need for longer shelf life and
increased production of high quality and safe food at an affordable price [4].
While food additives are assessed by EFSA and strictly regulated in the EU, the
use of additives is often perceived by a consumer as “non-natural” in foods and
potentially hazardous [5], [6], [7].  
Usually, sulphites are added to many foods and beverages (fish, potatoes, wine,
dried fruits, etc.) to prevent oxidation and bacterial growth, thus achieving
longer shelf life. In Europe sulphur dioxide (SO ) and sulphites in foods and
beverages at concentrations of more than 10 mg kg–1 or 10 mg L–1 expressed
as SO equivalents are subject to mandatory labelling [8]. Their incorrect use
may entail health risks. Sulphites are allergens and may cause symptoms of
allergic reaction and intolerance in sensitized individuals, such as asthmatic
reactions and bronchospasms, occasionally severe hives, flushing, bradycardia
and gastrointestinal symptoms [9], [10], [11]. According to [12], serious
adverse reactions occur in 3 to 10% of the asthmatic population exposed to
these food additives and include dermal, gastrointestinal, and respiratory
symptoms. Bronchoconstriction is the most common adverse reaction and can
lead to an asthma attack [9]. In addition, other serious symptoms may include
urticaria, hypotension, angioedema, and anaphylactic other reactions [9], [13].
In 2022 EFSA carried out a re-assessment of the additives in the sulphur
dioxide-sulphite group and concluded that, due to significant gaps in the
toxicological data set, the previous temporary acceptable daily intake (ADI)
(0.7 mg SO /kg body weight/day) has to be withdrawn. EFSA derived a
reference point of 38 mg SO /kg body weight/day, based on neurobehavioral
endpoints in rats, and a margin of exposure of 80 for safety assessment: the
exposure scenarios raise safety concerns especially for high consumers of
sulphite-added foods. EFSA also re-stated the need for better data on the
origin, mechanisms, and dose-response of sulphite-related human
hypersensitivity, as these are definitely relevant for a more robust assessment.
The recent conclusion by EFSA, supported by reports of sensitivity/intolerance
reactions in humans, confirms that the use of sulphites is a potential safety
concern [14].
Food legislation requires mandatory labelling of allergens [8] with the aim of
ensuring consumers’ rights to safety, to be informed, and to make appropriate
choices [15], [8]. In accordance with Regulation (EC) No 1333/2008, the use of
sulphites (E220-228) in meat preparations, minced meat and fresh meat
production is not permitted [1]. Their unlawful use gives the product a more
attractive appearance, thus “masking” insufficient freshness [16], [17]. 
Sulphites are allergens and may
cause symptoms of allergic reaction
and intolerance in sensitized
individuals, such as asthmatic
reactions and bronchospasms,
occasionally severe hives, flushing,
bradycardia and gastrointestinal
symptoms [9], [10], [11]. 
The recent conclusion by EFSA,
supported by reports of
sensitivity/intolerance reactions in
humans, confirms that the use of
sulphites is a potential safety
concern [14].
In accordance with Regulation (EC)
No 1333/2008, the use of sulphites
(E220-228) in meat preparations,
minced meat and fresh meat
production is not permitted [1].
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Revija Sanitarno inženirstvo / International Journal of Sanitary Engineering Research Vol. 16 | Issue 1 | 2023
25 
Collecting information
The Minister of Agriculture, Forestry and Food has ordered a Decision on
appointing a Committee for internal audit of official control in the case of
additives in meat preparations and informing consumers (Committee). Members
of Committee were state employees of Ministry from different areas of
expertise (veterinary medicine, food technology, law and management). 
Although sulphites as allergens are subject to mandatory labelling [8], scientific
articles report on unauthorized use of sulphites in EU Member States including
Slovenia [18], [16], [19], [20], [17], [21], [22].
Food frauds occur when a Food Business Operator (FBO) intentionally deceives
consumers about the quality and/or content of the food to gain an, usually
economic, advantage for itself. Food frauds cover a broad range of cases
including intentional substitution, addition, tampering or misrepresentation of
food, food ingredients or food packaging, labelling, product information or false
or misleading statements made about a product for economic gain; these unfair
practices, may adversely affect the nutritional quality and/or safety of food,
hence, consumer health [23], [24].
The consumer community is vulnerable to food frauds, also because of
insufficient awareness about the increasingly complex nature of industrial food
processing for number of reasons. Food science, or even the basis of food
hygiene and nutrition, are generally not taught sufficiently in schools. On the
other hand, consumers have no direct means for the verification of their
expectations and have to rely completely on the food legislators and
responsible authorities - enforcement agencies [25]. Studies show that the
consumers are most worried about food and drugs adulteration, swindles and
food contamination [26], [7], [5]. The perception of risk by average consumers
may be greatly different from the perception of experts, as it is based on an
ensemble of a range of beliefs, intuition, attitudes, judgments, feelings,
opinions and culture, all of which differ widely among the population [27], [28],
[29], [30]. The expert perception of risk is based on evidence, subject to the
challenge of new research data and may include a risk-benefit approach [31].
Far from dismissing as irrelevant consumer perception, these considerations
highlight the role of evidence-based risk communication and awareness raising
in the consumer community as an important support to risk management.
Different hazards as well as different levels of risk require special consideration
and specific ways of risk management and communication [32], [33] to build
trust in and support to the agri-food safety system. Risk management strategies
may use regulatory, advisory, and/or technological approaches, and take into
account factors such as the size of the exposed population, required and
available resources, costs of implementation, and the degree of scientific
uncertainty of the risk assessment [34]. Food fraud as intentional act requires
different approach as food safety issues that occur unintentionally.
This paper presents an important alert for the illegal use of sulphites in meat
preparations and minced meat in Slovenia. The aim of the case study is to
highlight the shortcomings of existing systems for ensuring food safety in case
of food frauds and highlight challenges for improvements.
E. Mičović, A. Mantovani, M. Jevšnik
METHODOLOGY
This paper presents an important
alert for the illegal use of sulphites in
meat preparations and minced meat
in Slovenia.
Studies show that the consumers
are most worried about food and
drugs adulteration, swindles and
food contamination [26], [7], [5].
Revija Sanitarno inženirstvo / International Journal of Sanitary Engineering Research Vol. 16 | Issue 1 | 2023
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The Committee started to work 17 October and finished 15 November 2019.
The main tasks of the Committee were:
- to investigate and evaluate all circumstances, procedures and facts during
official control of sulphites in meat preparations;
- to investigate and evaluate way of informing and communicating with the
public in this case;
- to prepare a report on findings.
Committee had access to all documentation in regional units of Competent
Authority in Slovenia, for each case of official control regarding sulphites in
meat preparation. During internal audit different actions have been
implemented to collect all information, facts and to identify all circumstances:
- checking all documentations: inspection records and other relevant
documentation was examined to determine whether the inspection procedure
was conducted in accordance with the provisions of EU food legislation and
with inspection legislation;
- interviews with responsible inspectors to understand decisions and measures
required by inspectors during official control; 
- meetings of the members of the Committee to exchange views and opinions
on findings.
After checking and evaluating all documentation for each case, Committee
performed interviews with responsible inspectors to clarify all possible gaps
and uncertainties with the aim of verifying official control procedures.
This approach of investigation provided all relevant information and findings
for Committee to prepare the final report for the Minister.
E. Mičović, A. Mantovani, M. Jevšnik
Alert identification and risk management
The alert started with a telephone notification by a consumer to the competent
authority - Administration for Food Safety, Veterinary Sector, and plant
Protection (Administration) in December 2017, regarding health problems
related to the consumption of meal, prepared from minced meat. However, this
first information received no response. Consequently, the consumer sent a
written complaint to the competent authority in March 2018 with a reference
to the previous telephone conversation and clearly described all the health
problems that occurred after consuming a meal with minced meat (severe
headache, burning sensation in the throat and stomach, stomach pain and
vomiting). At that time the competent authority had not received any other
complaints or information about untoward health effects from consumers after
consuming meal, prepared from meat and minced meat.
RESULTS
After checking and evaluating all
documentation for each case,
Committee performed interviews
with responsible inspectors to
clarify all possible gaps and
uncertainties with the aim of
verifying official control procedures.
Revija Sanitarno inženirstvo / International Journal of Sanitary Engineering Research Vol. 16 | Issue 1 | 2023
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In April 2018, food inspectors carried out official inspections at retail butcher
shops in Ljubljana, Slovenia's capital, where the use of the illicit additive in
meat preparations was not established. Inspectors looked at premises and at
the possible presence of unauthorized additives, but did not take samples of
meat preparations, and findings were recorded on an official note, without
official minutes. No feedback was provided to the consumer, despite his
request for information about his compliant.
In May 2019, the competent authority received a notification by telephone
that indicated the use of this additive in the meat products sold in a national
retail chain. Based on this report, an inspector carried out an emergency
inspection at this supermarket in June 2019 and examined two samples: a
sample of a meat preparation and a sample of minced meat, both of which
were positive for sulphites.
The inspector informed the responsible person of the internal control of the
retail chain but did not issue any further inspection orders or inform the
director of Competent Authority. At the same time, in June 2019, the inspector
also performed an official check at a supermarket in Ljubljana from another
retail chain. The person responsible for the supermarket’s retail meat sales
admitted using sulphites; nevertheless, the inspector merely made a written
note about it, but no sampling was performed. The meat preparations still in
the display case were destroyed by the FBO in accordance with the legislation.
The inspector did not order any corrective measures or penalties; in addition,
no order or request was issued to the FBO to recall the meat products already
sold on that day, or the previous days.
Eventually, the inspections made in May-June 2019 triggered a follow-up. In
the second half of August 2019, inspectors began monitoring to determine the
presence of sulphites in meat preparations, fresh meat and fish with the aim to
evaluate the possibly wider incidence of this unfair practice. Five samples
were taken in the eastern region of Slovenia: four samples of meat preparation
for ‘čevapčiči’ (traditional minced meat dish) and one sample of fresh salmon
with skin: one sample of meat preparation was positive for sulphites. Based on
this positive result, the inspection procedure went on by issuing an oral
decision as well as, within seven days, a written decision, and initiated an
offence procedure; however, a tracing and recall of the food product was not
requested. During this inspection, the inspector also found sulphites in a
butcher shop and the retailer admitted the use of the illicit additive and his
responsibility. In the same period, outside the monitoring plan, two positive
samples of meat preparation were found during an inspection at a
hypermarket in the Savinjska region (North Slovenia). The amount of sulphur
dioxide ranged from 170 +/- 28 mg/kg to 400 +/- 60 mg/kg, and samples were
identified as unsafe food [35].
In September 2019, the official veterinarian from competent authority, acting
within a different control plan carried out an inspection, where the responsible
person of FBO gave a statement that the use of sulphites has been a common
practice for a long time. The inspector duly fulfilled the procedures by issuing
oral decision, written decision and final decision within the time limit.
However also in this case a requirement for a recall was not issued.
E. Mičović, A. Mantovani, M. Jevšnik
Five samples were taken in the
eastern region of Slovenia: four
samples of meat preparation for
‘čevapčiči’ (traditional minced meat
dish) and one sample of fresh salmon
with skin: one sample of meat
preparation was positive for
sulphites. 
The person responsible for the
supermarket’s retail meat sales
admitted using sulphites;
nevertheless, the inspector merely
made a written note about it, but no
sampling was performed.
Revija Sanitarno inženirstvo / International Journal of Sanitary Engineering Research Vol. 16 | Issue 1 | 2023
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E. Mičović, A. Mantovani, M. Jevšnik At the same time, in September 2019, the competent authority required
additional official control regarding unauthorized use of sulphites in fresh meat
and meat preparations. Unfortunately, inspectors did not have clear general
guidance and instructions on the notification procedure in cases of finding non-
compliant and dangerous foodstuffs. In fact, these instructions were still in the
drafting phase. Although the instruction refers to Regulation 178/2002, recall
of the food product was not required [36].
To summarize, the risk management efficiently dealt with identified cases, yet,
there was insufficient awareness about the health risks associated with the
illicit use of sulphites in frequently consumed foods (minced meat
preparation): such insufficient awareness may explain why tracing and recall
actions were not triggered as well as why a more systematic investigation on
the use of sulphites was not launched.
Risk communication and public perception
Figure 1 provides the timeline of risk management and risk communication
regarding illegal use of sulphites in Slovenia in 2019. The responsible Minister
was informed about the illegal use of sulphites from a journalist’s question
received on 4 October 2019. In accordance with Article 24 of the State
Administration Act, the Director General of the Competent Authority must
report regularly to the Minister on the work of the inspectors and inform them
of any important cases [37]. Official information regarding sulphites in meat
preparations was only received by the Minister on 7 October 2019, despite the
fact, that the Competent Authority received the report on the first two positive
results on sulphites in food products on 13 June 2019.
The Public Relations and Promotion Service at the Ministry requested that the
public be informed properly, in a transparent and clear way, about all the
important facts regarding this case. On 9 October 2019, the report and press
release regarding sulphites in meat and meat preparations were forwarded by
the Public Relation service to all media and published on the Ministry website.
Unfortunately, inspectors did not
have clear general guidance and
instructions on the notification
procedure in cases of finding non-
compliant and dangerous foodstuffs. 
Official information regarding
sulphites in meat preparations was
only received by the Minister on 7
October 2019, despite the fact, that
the competent authority received
the report on the first two positive
results on sulphites in food products
on 13 June 2019.
Revija Sanitarno inženirstvo / International Journal of Sanitary Engineering Research Vol. 16 | Issue 1 | 2023
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E. Mičović, A. Mantovani, M. JevšnikFigure 1. Timeline of risk management and risk communication regarding
illegal use of sulphites in Slovenia in 2019
The competent authority website enables information on unsafe food in the
market through the RASFF system. On this website, different notices or news,
various information, recommendations, and reports can be published.
However, regarding this case, prior to 7 October 2019 there was no
notification on the website, nor did the competent authority inform the public
about sulphites in meat: nevertheless, there is an applicable Protocol of
Communication and Information on Risks in the Republic of Slovenia in the
field of ensuring safe food and feed (Protocol). This Protocol, however, was not
implemented in practice [38]. Neither the competent authority nor the FBO
recalled the unsafe food in the RASFF, which was not in line with Regulation
178/2002.
However, regarding this case, prior to 7
October 2019 there was no notification
on the website, nor did the competent
authority inform the public about
sulphites in meat: nevertheless, there is
an applicable Protocol of Communication
and Information on Risks in the Republic
of Slovenia in the field of ensuring safe
food and feed (Protocol). 
Revija Sanitarno inženirstvo / International Journal of Sanitary Engineering Research Vol. 16 | Issue 1 | 2023
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E. Mičović, A. Mantovani, M. Jevšnik The media reacted with great interest to the report on the implementation of
additional controls on the use of sulphites in meat preparations. News about
the results of official controls was published in various media: national and
commercial television, national and regional radio stations, different
newspapers, websites, and social media. They also raised reasonable
questions as to why the public received no information about the presence of
sulphites in meat preparations in June, and why the additional, stricter
controls were carried out only in September.
Due to high public interest, the competent Minister imposed an internal audit
on the work of the competent authority regarding the official controls on
possible use of sulphites in meat preparations. The results of the internal
audit and subsequent corrective measures were presented by the Minister at
a press conference in November 2019, aiming to enhance better and effective
official control and to eliminate food frauds. Special focus was placed on
improving risk communication to protect public health as well as consumer
rights to food safety and to keep the public informed [39]. The media also
reported on the press conference, the findings of the internal audit, and
corrective measures requested by the Minister.
Overall, the case study identified a communication gap between food safety
bodies and policy makers, as well as a positive role of media, goading
authorities to timely and transparent action to protect the public health.
This case study illustrates risk management and risk communication on the
illegal use of sulphites: this food fraud represents unintentional harm to
consumer's health caused by an intentional act for economic gain. This is one
main difference compared to unintentional food safety incidents  [40].
Sulphites had been added to food illegally to preserve the appealing red
colour of the meat, giving it the appearance of a fresh meat preparation.
Meanwhile sulphites are allergens, and the information on their presence in
foods is of crucial importance to consumers, while lack of information is
detrimental to food safety. The illicit addition of sulphites to meat preparation
relates to several violations of core legislations. This practice represents a
deliberate misleading of the consumer about the properties and composition
of the food, which runs counter to the basic legislation governing food [41], [8]
and consumer protection [42]. The FBOs intentionally omitted the labelling of
sulphites in meat preparation, knowing that the use of sulphites in this food
category is illegal. Thus, the provisions of Regulation (EC) No 1333/2008 and
Regulation 1169/2011 stipulating the mandatory labelling of allergens, such
as sulphites, were violated. The FBOs also violated the Consumer Protection
against Unfair Commercial Practices Act [43], which lays out misleading
practices, including the intentional omission of mandatory labelling.
Interestingly, in the case of illegal use of sulphites we can recognize all three
elements needed for a crime to occur according to the Routine Activity Theory
(RAT), i.e., the presence at the same time and in the same place of a suitable
target, motivated offender as well the lack of a suitable guardian to prevent
the crime [44], [15]. In our case study: the motivated offender as the FBO, the
suitable targets as consumers and lack of a suitable guardian as insufficient
official control.
POLICY IMPLICATION - DISCUSSION
Special focus was placed on
improving risk communication to
protect public health as well as
consumer rights to food safety and
to keep the public informed. 
The FBOs also violated the
Consumer Protection against Unfair
Commercial Practices Act, which
lays out misleading practices,
including the intentional omission
of mandatory labelling.
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The competent authority issued warnings and other corrective measures
regarding this case. In accordance with the Inspection Act, a warning can be
imposed as the mildest inspection measure in case of a lower level of risk for
consumers. Such a case enables “softer” action if the FBO is aware of its non-
compliance and of the need to correct it [45]. The inspector is obliged to make
their own decisions regarding procedures and measures to be imposed based
on reports of positive samples for sulphites content, the employee recognition
of the use of such an additive and the risk assessment, e.g., an exposure
assessment based on the detection of unacceptable substances in widely
consumed foods, such as meat preparations. In this case, the action taken by
the competent authority was too late, occurring only in mid-October 2019.
Where there is a confession of the offender and a positive report on the unsafe
sample, this provides evidence of committing a violation of food law [41] and
such food product should not be put on the market. Production and selling of
unsafe foods are illegal and should be prosecuted by the competent authority
[46]. Besides the possible risk for the general population exposed to excessive
levels [14], sulphites in food represent a recognized danger to the health of
people who are hypersensitive to sulphites. By destroying meat preparations
without sampling, official inspectors violated the obligation of securing
evidence. As the confessions of the responsible persons were not supported
by evidence (no samples taken), the prosecution of this unfair practice and
food fraud was not feasible.
When the competent authority identifies non-compliance, it shall take action
to ensure that the FBO remedies the situation. Such action shall include
monitoring and if necessary, ordering the recall, withdrawal and/or destruction
of food [46]. In this case, the inspectors did not act against the FBO by
requesting a recall for the sold meat preparations, though they demanded the
withdrawal and destruction of the unsold quantity.
The competent authority knew about the first finding of sulphites in five
samples of meat preparations from the butcher’s shops of retail chains in June
2019. Additional, closer control by the inspectors was carried out for the first
time in September 2019. The first official report and informing the public
occurred in October 2019 [35]. Consumers were not warned on how to handle
meat preparations that they had already purchased: indeed, some consumers
who bought meat products in the summer may have frozen a certain unused
amount for later use. In this regard, the competent authority informed
consumers that the freezing of meat preparations was not a common storage
practice [36]. Otherwise, the food label would indicate that it is not suitable for
re-freezing. Consumers should have been informed about it, but they were not,
which was also pointed out by the Slovenian Consumers’ Association; they also
emphasized that freezing meat preparations was not an unusual consumer
practice [47]. Overall, three problems were identified in regard of consumer's
information: i) consumers hypersensitive to sulphites were not informed of the
hazardous foods present on the market, neither through the RASFF system nor
by relevant statements of the competent authorities in the media; ii) the
consumers were not instructed in time to dispose of any purchased and frozen
minced meat and meat preparations in the period from June 2019 and October
2019; iii) even the rights of consumers who are not allergic to sulphites have
been affected, as all consumers have the basic right to be informed of all the
ingredients in the food they consume [8].
E. Mičović, A. Mantovani, M. Jevšnik
By destroying meat preparations
without sampling, official
inspectors violated the obligation of
securing evidence. 
Consumers were not warned on
how to handle meat preparations
that they had already purchased:
indeed, some consumers who
bought meat products in the
summer may have frozen a certain
unused amount for later use. 
Revija Sanitarno inženirstvo / International Journal of Sanitary Engineering Research Vol. 16 | Issue 1 | 2023
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E. Mičović, A. Mantovani, M. Jevšnik The identified shortcomings in risk management may be due to different
causes, such as:
- insufficient communication and co-operation among offices;
- insufficient collection, storage, analysis, and utilization of data at regional
and/or central level, as well insufficient awareness about the health risks due
to sulphites and lack of basic training of inspectors and other risk managers in
risk assessment [34].
Finally, the crucial role of the FBO in ensuring food safety was missing in the
risk management of the Slovenian sulphite alert. The FBO should have
immediately initiated procedures to withdraw the food from the market.
Where the product had reached the consumer, the FBO should have effectively
and accurately informed the consumers of the reason for its withdrawal and
should have recalled from consumers the products already supplied to them,
to achieve a high level of health protection.
Meat preparations represent important sources of SO   exposure, especially in
adults and young people in many countries [18], [16], [19], [20], [17], [21],
[22]. Risk assessors and risk managers should be aware that in today’s
technological age, a purely reactive response to the various types of food
frauds is neither efficient nor effective [48], [49], [50]. In the run for profit in a
global, competitive market consumers are easy targets for unlawful acts by
importers, producers, wholesalers, or retailers who intend to increase profits
with less capital and equipment, while avoiding detection [26], [51], some
cases, like the illegally import of bush meats [52] are potentially linked to
criminal activities. In any case food fraud is a food-industry issue where the
effect is often a public health threat, yet the cause or motivation is economic
[40].
Any plans and actions to mitigate or prevent the risks associated with food
fraud should consider a whole food chain approach. Using a HACCP-like
approach, sulphites in meat preparation may be readily identified as a likely
hazard in a country like Slovenia, due to widespread consumption of meat
preparations like “čevapčiči”, the wish to attract consumers with a “fresh
meat look” and the easy availability of sulphites. In addition, beyond the
traditional food safety scope, some activities against food frauds may require
applying methods closer to criminal investigation [33]. In any case food fraud
is, indeed, a food-industry issue. It is important to emphasize that although
the cause or motivation is economic or financial, the effect is often a public
health threat [40].
Our case study highlighted the key importance of risk communication
addressed to policy makers, the media and general public as well as
stakeholders (FBOs, consumer associations). Food safety situations that
require urgent communication to prevent or reduce the risks of significant
harm are often associated with many gaps in knowledge. Where there is
uncertainty, this should be acknowledged and explained, together with what is
being done by risk assessors and managers to address the uncertainty, and
the implications for target audiences [53], [54], [31], [34], [55].
Moreover, risk communication cannot be a pure one-way process. Risk
communicators should understand and respect risk perceptions of average
consumers. 
Where the product had reached the
consumer, the FBO should have
effectively and accurately informed
the consumers of the reason for its
withdrawal and should have
recalled from consumers the
products already supplied to them,
to achieve a high level of health
protection.
In any case food fraud is a food-
industry issue where the effect is
often a public health threat, yet the
cause or motivation is economic.
Using a HACCP-like approach,
sulphites in meat preparation may
be readily identified as a likely
hazard in a country like Slovenia,
due to widespread consumption of
meat preparations like “čevapčiči”,
the wish to attract consumers with
a “fresh meat look” and the easy
availability of sulphites. 
2
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33
E. Mičović, A. Mantovani, M. JevšnikIt is important to recognize and respect differences in perception, which may
be due to economic, social, or cultural differences [23], because they could
contribute to disagreeing views between experts and the public about
managing risk [56], [29].
 
In general, consumers are more ready to accept information that is consistent
with their previous beliefs [6] meanwhile, negative emotions such as fear,
confusion and worries about their health are major factors in the public's risk
perception during food safety alarms [57], [31], [6], [57]. In the case of
chemical hazards, consumers often perceive chemicals in food as high-risk to
their health [5] and/or posing unacceptable concerns because they are
involuntary, unrecognized hazards presenting an unknown effect on health
[58], [59]. The presence of perceived benefits mitigates the risk perception [7],
[60].
In our case study, there was a low perception of the risks of sulphites among
the Slovenian general consumers, and a deficient communication by the food
safety authorities (the experts) to the policy makers, as political
representatives of the general public. Meanwhile, the media and the
consumers association played a goading role that helped to stir a more
effective response. In fact, rather than the usual one-way communication, in
several instances experts and the public engage in an interactive exchange, as
the increasingly relevant field of Citizen Science shows [61]. Our case study
shows that public authorities may profit from inputs by media and citizen's
organizations in food safety alerts.
Finally, the case of sulphites in meat products in Slovenia highlights the role of
continuous and timely information exchange. There is no such thing as “zero”
risk in food safety, or in life more generally, despite the efforts of governments
and inspection bodies to prevent food fraud [25]. Nevertheless, all evidence
should be collected, and efforts should be made to reduce the risks. This is the
reason why the European Commission set up the Food Fraud Network as a
network of the Commission, the European Union Agency for Law Enforcement
Cooperation (Europol), the liaison bodies designated by the Member States,
and where relevant, the European Union’s Judicial Cooperation Unit (Eurojust).
Since 2013, EU Member States and some other European countries
(Switzerland, Norway and Iceland) exchange information and cooperate in
matters where they are confronted with violations of the EU agri-food chain
legislation of a cross-border nature. The EU Food Fraud Network allows
assisting and coordinating communication between competent authorities and
transmitting and receiving requests for assistance. The liaison bodies are
required to exchange information necessary to enable the verification of
compliance with EU agri-food chain legislation with their counterparts and, in
certain cases, with the Commission, where the results of official controls
require action in more than one country [62].
At the international level, the International Food Safety Authorities Network
(INFOSAN) managed jointly by the Food and Agricultural Organization of the
United Nations (FAO) and the World Health Organization (WHO) is an important
global network. It includes national food safety authorities and provides an
mportant platform for the rapid exchange of information during food safety
emergencies and for sharing data and information [40].
In the case of chemical hazards,
consumers often perceive chemicals
in food as high-risk to their health
and/or posing unacceptable
concerns because they are
involuntary, unrecognized hazards
presenting an unknown effect on
health.
Our case study shows that public
authorities may profit from inputs
by media and citizen's organizations
in food safety alerts.
There is no such thing as “zero” risk
in food safety, or in life more
generally, despite the efforts of
governments and inspection bodies
to prevent food fraud.
Revija Sanitarno inženirstvo / International Journal of Sanitary Engineering Research Vol. 16 | Issue 1 | 2023
34 
SUMMARY AND CONCLUSIONSE. Mičović, A. Mantovani, M. Jevšnik
This article highlights critical aspects of risk management and risk
communication as important stages of ensuring food safety in case of food
fraud. Despite the clear and unambiguous legislative rules and provisions, the
implementation in practice by the FBOs as well as by the competent authority
was not optimal, possibly also due to insufficient awareness of sulphite-related
health risks. Other shortcomings concerned insufficient communication
between food safety responsible and policy makers as well as here lack of
understanding of consumer’s risk perception; meanwhile, media and
consumer's association had a positive goading role. The traditional food safety
approaches may not be the most effective option for detecting or deterring
food fraud. Prevention of risks from food fraud requires an interdisciplinary
approach with new methods and corrective measures combining criminology
with other expert fields: food safety, public health, food science, consumer
protection, supply chain management, and social anthropology [33].
Providing corrective measures against food fraud by the responsible authority
needs to be improved by means of clear standard operating procedures,
including decision trees for issues requiring a case-by-case approach.
Consumer awareness of risks and mitigating measures (such as disposal of
frozen foods purchased in a certain period) are of paramount importance to
integrate the official measures taken by authorities. 
Ineffective, improper risk management in this case reflects a lack of effective
training for inspectors as well as a lack of internal risk communication. Late
and incomplete notification is unacceptable in ensuring food safety and
consumer protection. It shows a clear disregard for the basic principles and
objectives of effective risk communication: timeliness, transparency,
consideration of consumer perceptions, their legitimate concerns, and fears.
Recognizing the hazard, defining the problem, and understanding the nature
and level of the risk are crucial before developing prevention, intervention, and
response plans in case of food fraud.
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