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Wednesday, 20 February 2019

Mayhem of a Disruptive Culture within a Desired Culture

You might have already seen these or similar requirements stated in the “new versions” of some popular certification schemes:
First Requirement:
  “The operation shall document a plan for the development of a food safety culture. The plan shall include:
                                                                        i.      defined activities that have an impact on product safety
                                                                      ii.     an action plan indicating how the activities will be implemented and measured within stated time-frames
                                                                     iii.     a review of the effectiveness of completed activities.”
Second Requirement:
The operation shall have a confidential (whistle-blowing) reporting system to enable employees to report concerns relating to product safety, integrity, quality and legality.
The mechanism (e.g. the relevant telephone number) for reporting concerns must be clearly communicated to all employees.
The operation's management shall have a process for documenting and assessing any concerns raised. 
Records of the assessment and, where appropriate, actions taken. . . .

Take a close look at the interrelationship between these stated requirements. You might immediately see that the second is a recipe for a disastrous disruption of the first.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Thursday, 6 December 2018

Seduction of Virtual Realities in the Food Safety and Quality Assurance Sector

If you dared to explore the non-virtual realities: 
What do you expect to find?  If you were to unpack what the certification circus actually held for food businesses and the demanding customers, what would you discover? I have found that many food safety certification subscribers and the so-called demanding customers do not thoroughly examine the widely promoted merits and reliability of this distraction. Where people fail to ask the right questions, they often leave themselves open to be led down garden paths.

I am posting these examples simply to demonstrate the extent to which the abandonment of reason has become endemic and insidious within the circles of food safety and quality assurance "experts". Professional digressions caused by the compliance and certification craze is no longer attributable to only a few individuals or organizations. A failure to carefully examine the evidence from every-day events has become widespread due to the seduction of virtual realities. 

Example 1:
Scheme stipulation mental block: You could easily test this example. Simply listen carefully to your assigned auditor during your next food safety certification audit. As this has become inevitable, you are likely to detect a pre-occupation with virtual realities, make-belief problems and the abandonment of his or her God-given right. Even where this right is exercised, the correct determinations and conclusions are quickly abandoned in favour of some generic, irrelevant and imposed scheme stipulations. 

Example 2:
A supposedly expert opinion article (posed this question and provided the answers that follow:
“Why Do Businesses Want or Need Food Safety Certification?

Food safety certification conveys to consumers and the marketplace, as well as to employees and key stakeholders, that a food sector business has successfully met the requirements of a national or internationally recognized best practice approach. Certification by an objective third party can be invaluable to any business as it signifies good governance and corporate responsibility.

With heightened awareness stemming from recent high-profile food recalls, consumers are demanding an increase in food safety standards throughout the global supply chain. Those businesses which become certified to a particular food safety scheme will gain a competitive advantage in the marketplace.”

Here are some mental alertness test questions:

1.     What are the obvious holes in these statements?

2.     What phrases reveal the dangerous captivation of otherwise sharp minds by the now endemic "compliance craze"? 

You should be better able to answer these questions after reading this blog post on "The Standardized Food Industry Mistake" among other posts.

If you wish, you may read the: full article 

Example 3:
A decoy study that could fool some people:

I say decoy because what was measured is not of first importance when the subject is clearly “food safety”, meaning the safety of food. What was measured had no clear link to the degree to which food became safe, that could not have been attained without certification.

The report listed three over-stretched benefits which were essentially one consideration with rough estimations, presumptions, hypothetical deductions that reveal the inconclusive nature of the findings, even if the report was not so demonstrably virtual. The reported benefits were also explained with undefined criteria like “complaints” without identifying the kinds of complaints.
The report stated as follows:
“Three quantifiable business benefits of certification stand out:
1.  Certification improves quality of service as measured by a reduction in complaints from customers by 23% on average.
2.     Because responding to complaints consumes roughly 1.53% of employee time, the reduction in complaints due to certification also reduces company labor costs significantly. Hypothetically, for a company with 25,000 employees who work 2,000 hours/year at $20/hour, the labor cost savings due to certification’s reduction in complaints would come to roughly $3.5 million/year.
3.  Certification is estimated to increase sales revenue by approximately 2.0%, presumably because it increases consumer confidence in the safety and quality of the food they purchase.”

Clearly, when reports are presented with "quantifiable" instead of "quantified" data, when the reports contain inconclusive statements, terms and no more than projections, they show their true value – little to none. Claims and studies like the above are impressive only where the God-given right to think has been abandoned.

Example 4:
Compliance-focused experts popping up everywhere: 
Someone claiming to be a food industry expert once stated to me that, if an idea like the SSQA concept is not a certification program that forces compliance, it would not work. She equated the "popularity" of the catch-and-punish mentality to efficacy and usefulness. A well-studied expert knows the difference.

With what seems like an attitude of reckless abandon, some experts completely ignore the undeniable events around certification. Some of these events are posted under “Cases of certified failures” in the post: “What does food safety certification do for a food operation?

Compliance-focused experts also appear to be virtual-reality-blinded. They tend to remain unidirectional in promoting or defending the merits or necessity of the compliance certification tunnel. This sufficiently proves the capacity of the tunnel to diminish the vision of otherwise sharp minds who now simply follow the crowd. 

The Distraction Tunnel:

The confining tunnel remains comfortable only for people who have actually surrendered to the distractions. Except where the deception has gone so deep as to cause a compelling blindness, opening the certification treasure chest reveals much emptiness. 

Distractions often entice and compel. They may even appear useful or harmless. Otherwise they would not distract anyone from worthy pursuits. Such is the distraction of the certification pursuit by so many food businesses that has cannibalized and diminished the pursuit of finding true scientific solutions for the internal failures and the problem of food recalls. Certification pursuits often come with enough CARs and irrelevant make-work projects to keep food businesses sufficiently pre-occupied throughout the year.

Among the groups on the food supply chain, the most fooled by the certification circus, and the most deluded about what makes food safe, are demanding customers who strongly rely on the food safety certificates from their suppliers. Other thoroughly deceived groups include those (even some professionals in this sector) who swear by food safety certification as an inevitable pursuit for food companies.  

You should strive to stand your grounds in the debate. Stand out from among the certification compliance-crazed crowd.
Posted by Felix Amiri
Felix Amiri is the current food sector chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Saturday, 24 November 2018

Why, Where and How the World Needs Real Food Safety and Quality Leaders and Experts:

Why, as a matter of great urgency, does the world need a task force suggested in this LinkedIn article? You'll have the answer to this question from simply following the news and published findings from workshops like the one conducted by the Pontifical Academy of Sciences (PAS) & the Global Alliance for Improved Nutrition (GAIN). 

You may have already heard the recent CNN report that romaine lettuce is at it again in the US and Canada. If you do a further search through the news you'll find other health hazard food recalls around the world. The problem is simultaneously multi-faceted and requires a simultaneous multi-input approach in its resolution efforts. The search for solutions must be broadened beyond the usual narrow scope suggested by industry contributors with only commercial interests.
With well-defined and relevant objectives, the global food safety problem can be solved. A global initiative of a different kind, instead of a narrow preoccupation with food safety certification of only commercial food operations, is urgently needed. The "Final Statement" from the PAS and GAIN workshop as provided in the "Pontification of Food Safety" post states:  
"Food safety is a neglected dimension of the food and nutritional security challenge, and bold leadership is needed at the global and national levels to give it the necessary policy attention and resources."
This statement implicitly expresses a regret that the widely hyped food safety and quality certification circus, although it is fondly described as a "global initiative" is failing woefully.
I fully support the PAS and GAIN final statement. The world urgently needs a working task force to drive meaningful considerations and action at the policy development levels. Then the world needs fully engaged implementation force everywhere (in food production, food engineering, the factories, food distribution, food service outlets, other industry-related services, regulatory agencies, etc.). 

The implementation force must be educated to full proficiency on the significance, obligations, methodologies and merits of their work. The academic curriculum versions at institutions offering related programs may need to be reviewed and revised to accomplish the required education and training. The scope of education may even need to be expanded to all levels (i.e. not limited to college and university levels). The interconnection of on-the-job training pertaining to various aspects of food operations may need to be reinforced and pursued. Regulators may need to expand, actualize and intensify their public education efforts.
Posted by Felix Amiri
Felix Amiri is the current food sector chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Saturday, 17 November 2018

Something Itchy in the Food Industry - A Reality-Exposing Analogy

Mosquito bites irritate, and they produce a perceivable soothing sensation when scratched but who gains the most from mosquito bites? The World Health Organization identifies six mosquito-borne diseases 

Analogous to the mosquito bite, the bites of many activities in the food industry, such as the imposition of food safety certification on food establishments, particularly the small ones, also irritate. A superficial soothing sensation is also felt with the "successful" annual re-certification and conference serving as the scratching exercises. The soothing sensation may feel real but who gains the most from these scratching exercises?

Like the mosquito-borne parasites and viruses described by the World Health Organization, the certification process also has its parasitic annual obligations. How about the virus-like requirements for certified parties to force their suppliers to also get certified? This may be seen as a good way for ensuring that all food businesses and their suppliers are "doing the right things" except these right things simply fill the pockets of certification merchants in the same way as described in the "Systemic Fraud – closer than it appears in the mirror" post. In fact, some of the schemes have proposed "certification" requirements that include fraud "vulnerability assessments". It does not take a genius to see that many of the proposals are just part of an attention diversion game where a finger is pointed outward while three point inward.

Viruses, in the form of "approved" or "certified" service providers, are also cleverly set up to offer scheme-specific services and training for the advancement of the certification enterprise. Many people have fallen and continue to fall for these schemes that disrupt more than they benefit the seduced and enlisted operations. 

In the race to the generic certification finish line, many enlisted (infected) food operations often ignore, by-pass, neglect, or abandon things that could be customized to more realistically, effectively, and efficiently make their systems management and control stronger.

I have found that when people are not held accountable for what they sell, they will attempt to sell anything to you, including virtual solutions for fabricated needs that you do not have. The sellers only have to trick you with soothing words into believing some virtual realities. Through clever manipulation, they would draw unsuspecting victims into an enslaving loyalty to their exploitation. In the ensuing confusion, a large number of industry participants have become conditioned to think that food safety monetization is the same thing as its materialization.

The scheme certification programs are frequently sold as providing symbiotic benefits. You only need to do the math to discover the resource and energy draining capacities of these programs with no significant returns. The exploited gain nothing more than the virtual or feel-good (the soothing scratch) promises like: "It strengthens your programs",  "major customers now want it", "certification guarantees that you will gain new business", "it is the only way to do business these days". etc. These alluring words have drawn many food businesses into a lop-sided relationship that is far from being symbiotic. Few business relationships are adisruptive, distracting and exploitative. Only those who stop to take stock are able to discover the seeping losses and the manipulative intentions of the scheme peddlers. 

With the rapid spread of commercialized complicity and the excessive pursuit of profit that also drives things like the widely decried food fraud, the call for everyone to be vigilant against all schemes must be urgently made. Clearly, many have become overly captivated by different schemes. These very schemes, in their fine-print disclaimers, acknowledge their inability to deliver what they explicitly or implicitly promise.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Friday, 16 November 2018

The Real Gaps in Food Safety & Quality Assurance GAP Assessments

Do you know what or where the real gaps are in your operation or any operation that you know? Do you also know that every "compliance" or "conformance" focused thinking is regressive?

Stop for a moment and listen! You will hear people from companies that are certified to some food safety schemes saying "we have gone far past the GAP assessment stage". You may hear them say things like "we fully comply with or conform to this or that "standard". Such assumptions can be deadly because the real "standards" at play often extend beyond what is conceivable to bands of similarly-focused individuals. Misleading assumptions could be a debilitating reality even among some committees of "experts".

You are probably thinking that the answer to the question about the real gaps in an operation is obvious. Let's consider another related question that may start to unravel the usual assumptions and misconceptions: What should a good GAP assessment consider and/or where should assessors be looking to confirm any GAPs that may exist?

Even the usual approach of assessing the gaps in a food operation's programs frequently fail to look at very important considerations. For example, many assessment reports grant passing grades and seem to find no gaps in the training of employees once the establishments confirm that their employees have received GMP, HACCP and technical operation training. The auditors may confirm that the training was done by external or internal trainers. They may ask to see the certificates of attendance, etc. Now, other than reviewing the training records or interviewing personnel on the operation floor, where else and how should an assessor look for evidence of gaps that may exist in employee training? What provisions for such examination does your favorite gap assessment template have?
In a LinkedIn post on this subject one commentator (Dr. Vinay Putta) stated as follows:

I do frequent GAP AUDITS. For me, it all depends on the root line of assessment / Now that business strategies are very deep, I generally choose to AUDIT each part separately. In a food processing ( restaurant or manufacturer / producer) case, I have my Own formula - PEMCUI, stands for Product, Employee, Maintenance / Machine , Cleaning / Chemicals, UTILITY / Tools, Infrastructure.”
My response contained two questions:
In your frequent GAP AUDITS, do you ever consider as follows: 
1.     That an operation`s practices could work better for the operation than some of the typical standards against which it is compared? 

2.     That gaps which may need to be closed could exist in the assessment standards (or templates) when assessed against the operation's established good practices?

The usual condescending assumptions in the prevailing approaches to gap assessment only provide a one-direction answer to the question of Who has the gaps? The failure to properly address this question on all sides leads to the conclusions that only the audited operations have gaps; that the schemes or templates used as the basis for assessing the audited parties have no gaps. Without identifying and working towards the main objective of the gap assessment, these erroneous conclusions often lead to the almost guaranteed failure of the systems developed according to their counsel. These misconceptions and wrong conclusions create furrows of investigation or assessment tunnels that effectively dull visionary thinking.

For the sake of relevance, every gap assessment must be based on a "root" objective or goal (the actual desirable outcome) of what is assessed. This root goal must be properly defined. In the absence of a well-defined root objective or goal, any effort made in assessing the possible gaps proceeds without a proper focus. Such improperly focused assessments inevitably lead to misguided "corrective" actions that hinder more than they help operations.

Defining the proper goal for a gap assessment eliminates any confinement to opinions. A properly defined goal brings the assessment results closer to the actual and beneficial reality. The industry certainly needs a practical think-tank on these matters, particularly in these days of expanding misinformation, commercialized complicity, misdirected focus repeating failures, squandered resources, etc.
Posted by Felix Amiri

Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.