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Saturday, 17 November 2018

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

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

Analogous to the mosquito bite, food safety certification bites also irritate and they produce a perceivable soothing feeling with the "successful" annual re-certification (scratching exercises). The soothing perception may feel real but who gains the most from it?

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. 

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 (infected) operations.

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 in reality. The sellers only have to trick you with soothing words into believing some virtual realities  that draw you into an enslaving loyalty to their exploitation. Many people have fallen prey and still fall for these tricks.

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", etc. These alluring words have drawn many food businesses into a lop-sided relationship that is far from being symbiotic. It is exploitative and only those who stop to take stock are able to discover the seeping losses and the manipulative intentions of the purveyors.

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 that (in their fine prints) acknowledge their inability to deliver what they explicitly or implicitly promise.
Posted by Felix Amiri
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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. Have you heard the expression about the pooling of ignorance? It 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: 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.” https://www.linkedin.com/feed/update/urn:li:activity:6443998645162385408

My response went something like this:

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 misguided conclusions create furrows of investigation or assessment tunnels that effectively dull visionary thinking.

Every gap assessment must be based on what may be described as the "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 and quickly comes to naught.

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

Pontification of Food Safety

If you are interested in food safety, you need to read at least these statements:

 "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. Food safety is intimately linked to health as billions of people are exposed to potentially harmful viruses, bacteria, parasites, toxins and heavy metals in their foods. At least one in ten people suffer from eating unsafe foods[2]. Better food safety can be linked and mainstreamed into improvements in productivity, food accessibility, and the affordability of nutritious foods, although we do know that some of the most nutritious foods (animal source foods and fresh produce) can be the riskiest and some of the least nutritious foods (oil, sugar, salt, highly processed) less likely vehicles for food borne disease.

Food safety and malnutrition need to be addressed in concert. The rise of diet-related NCDs as contributors to the burden of disease illustrates that healthy diets necessitate the consumption of safe food and the consumption of nutritionally appropriate combinations of safe foods."

I applaud those who gathered and came up with this “Final Statement of the Workshop on Workshop on Food Safety and Healthy Diets”. It is quite a long statement with sufficient emphasis on the assurance and equitable distribution of safe food. I did not see any instance of food safety certification mentioned. Could it be that the people gathered recognized the superficiality and the prevailing propensity for offering certification mostly for economic gain than for providing any meaningful solution? Could there have been a recognition that the certification landscape has become overrun by deliberate or unwitting intentions to defraud? Such propensities clearly go against the moral stance of many who participated at the workshop, I am sure.

When I first spoke of an expanding undercurrent that runs against the certification circus back in a 2013 post - https://gcse-food-health-protection.blogspot.com/2013/09/the-coming-shift-product-safety-and.html - I did not anticipate that it would be expanding so broadly and quickly. I still feel the momentum is not growing quickly enough. The food industry and all who depend on it need to be urgently liberated from the grips of commercialized complicity. No participant in the food supply chain (producers, processors, manufacturers, distributors, retailers, food service, restaurants, canteens, food hospitality, etc.) should be left or caught #napping. These are urgent times. We have neither the space nor should we have the tolerance for institutionalized circuses.
Posted by Felix Amiri
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Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.


Thursday, 18 October 2018

Practical Look at Common-sense Update 82:

"If all you do is to simply follow . . ."  

If any supplier, because of its food safety certification, expects to be treated differently from the way other suppliers are treated by the customer, that supplier needs to re-examine things. A certificate no longer serves as a differentiating accomplishment. Any supplier can easily obtain a food safety certificate. 

If any customer expects to command more of the market share simply because it enforces all of its suppliers to obtain food safety certificates, that customer needs to re-examine things. Any customer of any size can issue a policy or communique to demand food safety certification from all of its suppliers. Any customer can obtain copies of certificates and keep them on file for certification auditors to see.


Realistic differentiation is made of sterner stuff and comes from where many have ignored in favour of certification programs.

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

Wednesday, 3 October 2018

Some 2018 US FDA Warning Letters to Food Companies



Company 
Letter Issued
Issuing Office
Subject
02/16/2018 
Dallas District Office 
CGMP/Food/Prepared, Packed or Held Under Insanitary Conditions/Adulterated  
06/29/2018 
Minneapolis District Office 
CGMP/Food/Prepared, Packed or Held Under Insanitary Conditions/Adulterated  
05/16/2018 
Center for Food Safety and Applied Nutrition  
CGMP/Food/Prepared, Packed or Held Under Insanitary Conditions/Adulterated  
05/17/2018 
Atlanta District Office 
CGMP/Food/Prepared, Packed or Held Under Insanitary Conditions/Adulterated  
03/19/2018 
Kansas City District Office 
CGMP/Food/Prepared, Packed or Held Under Insanitary Conditions/Adulterated  
03/21/2018 
Seattle District Office 
CGMP/Food/Prepared, Packed or Held Under Insanitary Conditions/Adulterated  
03/09/2018 
Cincinnati District Office 
CGMP/Manufacturing, Packing or Holding Human Food/Adulterated/Insanitary Conditions  
03/16/2018 
New York District Office 
CGMP/Manufacturing, Packing or Holding Human Food/Adulterated/Insanitary Conditions  
01/26/2018 
Kansas City District Office 
Food/Egg/Prepared Packed or Held Under Insanitary Conditions/Adulterated