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Monday, 6 August 2018

Game of Thrones: The Food Safety and Quality Assurance Version


GAME OF THRONES: With its plots, perversions and power struggles as reported by commentators, one would almost think that GOT casts a spell on its enthusiasts except that an equally, if not more enthralling, reality exists in the food industry worldwide. The global food industry landscape bears many similarities to GOT’s Westeros

I have heard, read and learned enough about this TV series from enough sources, and I now wonder if I should be glad for not watching any episode. Unfortunately, I do not have the same freedom of choice with respect to my involvement in the food industry. I work in it as a food safety and quality assurance specialist. You and I, inevitably, are also consumers and I am getting increasingly appalled by what is happening in the industry.

It has been said that everybody in GOT's Westeros fights everyone else to gain control in a persistent struggle for power. In the food industry, the quest for more money drives the fight among food titans and stakeholders with an almost palpable air of distrust. At the same time, complicity enshrouds the various interactions. Fierce competition and contentions rage among those who wish to gain money-thrones in an expanding game of hoax (or game of fraud, if you wish)The food safety and quality assurance sector stands out as one of the arenas where opportunists are busy doing "food safety" through various schemes  and tactics to get more money. Individuals, businesses and organizations, as part of a money-grab complicity, contest or conquest, are either patting or stabbing each other on the back without improving the quality of food, or making it safe.

No argument or excuse diminishes the urgency: The food industry desperately needs to be liberated from the ferocious money-grab contentions. The highly damaging complicity must be stopped. Otherwise, fake food safety and quality assurance solution providers will continue to stand proud with the display of their concoctions for sale.

Commercialized Complicity:
I have elected to describe this disappointing state of affairs as "commercialized complicity". It involves no direct conspiracy or collusion. Those engaging in the complicity have no formal agreements or contracts to do so. 
Who are the actual participants?
What identifies them? 
With whom or what are they complicit? 
Do we have any need to pay attention? 
How much damage has or can this complicity cause?

The Participants:
Among some obvious players in the complicity, the industry has seen:
  1. Complicit scholars who conduct studies to support claims that are made by industry partners purely for commercial interests; 
  2. Complicit "experts" who, for some self-serving purposes, say the media exaggerates reports about food contamination and make them look like these have increased. They argue that food contamination only appears to have increased because detection methods have improved;
  3. Complicit food safety and quality assurance solution or service providers who, for the sole purpose of making money, merely sell solutions to industry that tend to conceal reality from consumers and/or customers.
Many of the participants, as a matter of principle, would not buy the solutions that they sell, or would not pay for the services that they provide. Yet, they proceed heartily because "there is money in it".

A number of opportunists (audit scheme owners, certification bodies, consultants, trainers, etc.), in competition against others, remain committed to expanding their sale of food safety and quality management solutions that they may not, in good conscience, support, except blindly. Through various manipulative means, they have captured the loyalty of naïve subscribers, although the solutions or services offered do not live up to the implied promises. Even as you read this, more food operations are falling victims to the tricks of cut-and-paste consulting services; rushed superficial training, and the allure of certification schemes.

With whom or what are the participants complicit?
By and large, effective solutions for most of the causes of food safety and quality failures are known. Yet, reported catastrophic food safety and quality failures stand as the undeniable evidence of the sector's boisterous but mostly fruitless activities. The news media has long been reporting preventable food safety failures. Meanwhile, the immediate question of why these failures persist and even appear to be spreading remain superficially addressed by those who claim to be offering solutions. In spite of the large numbers of so-called food safety consultants and trainers that are supposedly providing food safety and quality management solutions to countless operators, the industry continues to suffer huge losses due to failures. Could it be that they do not wish to provide real solutions in order to keep the victimized coming back to buy more of their solutions? Could this be part of the commercialized complicity? "Something smells fishy", as I've heard someone say. Clearly, in their search for real solutions, a good number of food operators are starving because of the ravaging effects of the insidiously expanding complicity to exploit them.

Like Westeros Vultures:
Providers of irrelevant, ineffective and inefficient solutions openly suggest that assuring the safety and quality of food is a difficult undertaking. They say: “Bad things happen” so that, when their spurious solutions fail, they point back and say: “We told you so, that bad things happen.” Meanwhile, they devise cunning ways of enticing solution seekers to pay substantial amounts of money for their concocted solutions. 

They cleverly make you and/or your operations do all the work. Some, under the guise of "neutrality rules", would not even tell you how to do the work that is necessary because it would be “conflict of interest consulting”. However, when you succeed through your own efforts, they quickly point to your success and attribute it to the efficacy of their solutions.

Every smart manager can and must see the vultures: Paying any amount of money for these concoctions must be avoided. Otherwise, these providers of bogus or ambiguous solutions will continue to overrun the industry, enticing and financially enslaving food businesses. With their cleverly devised tricks in this environment of commercialized complicity, they openly exploit individuals and operations that do not deploy the right vulture-repelling safeguards. 

The exploitation is not all that hidden in the certification arena where enslaved food operations are cleverly enlisted to do the dirty work of enslaving other food businesses. They are required, as part of subscribing to the schemes, to force their suppliers to subscribe, who must also force their suppliers to subscribe in an unending chain of forced subscriptions. It has been a very clever scheme really. Some major industry titans (corporate customers if you wish) are first convinced to demand certificates. Intimidated by the giants, small to medium food businesses feel powerless to defend their positions.
There's money to be made for sure. Several of the solution providers only pretend to care about you making money in your business. Sadly, it is only so you could pass on to them as much of it as they could swindle you into giving to them. 

Have you ever wondered why there are so many extra "modules" or "addendums" tagged on to the main certification schemes? Do you know why auditors and food businesses have to pay for scheme version-specific training every time there is a change? Must the audit frequency be every year to no end? 

These provide very good vehicles for making you pay more money out to the complicit scheme merchants.You give, they take in their proposed "give-and-take" game. You will hear them say: "It is your cost of doing business" - your cost; their gain.

Path to Sustained Success:
The games of hoax or thrones must go if the food safety and quality assurance sector hopes to have sustained success in dealing with the real enemies of food safety and quality assurance. Food businesses must take some drastic steps against hoax enterprises in this sector.

Food businesses of all sizes must abandon, at least avoid, pursuits that do not present a flattering picture of the collective intelligence of proposers, predators, participants or defenders. Wherever or in whatever the imaginary Westeros kinds of plots become realities within the food industry, food business operators must mount effective safeguards against all forms of exploitation and exercise their obligations to protect consumers against all threats that their products could pose.

Much effectiveness and efficiency in the assurance of safe food could be almost instantaneously gained if solution providers were to be held legally accountable and liable where the solutions provided are found to have failed to deliver what they explicitly or implicitly promised.
Posted by Felix Amiri
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Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Monday, 25 June 2018

Major Customers and 3rd-Party Food Safety Certificates:

Contrary to the growing number of companies needing their own supplier audit programs, let's just say that all major customers are demanding 3rd-party food safety certificates from their suppliers, as many people still think.

Does buying food only from third-party certified suppliers provide a reliable safeguard?

When people say: "We only buy from third-party certified suppliers", what do you hear, prudence or naïveté? A devotion to "buying only from certified suppliers" could place a food operation at a significant disadvantage or even at risk.

Consider the following points:
  • The near impossibility of having absolutely all suppliers certified to 3rd-party schemes
  • Some needed food or ingredients may only be available from non-certified suppliers
  • Certification does not always ensure knowledge and consistency of applied control measures
  • Non-certification does not always mean lack of knowledge that leads to inconsistency of applied control measures
  • Some non-certified suppliers could be highly regulated with frequent scrutiny by the regulatory authorities 
  • Due to sheer size that poses operation personnel management  challenges, some large suppliers that could afford to be certified could be less consistent in ensuring the safety and quality of food than smaller non-certified suppliers that could not afford to be certified (e.g. family-owned with family pride).
  • Customers tend to be less stringent with the monitoring of suppliers because of the false sense of security that is often associated with third-party certification
In ensuring the safety and quality of food, are there alternatives to buying only from third-party certified suppliers? Could we even say that buying only from third-party certified suppliers provides a worthwhile safeguard, if at all it provides any?
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, 24 May 2018

John Spink on Food Fraud Prevention 2018

MSU FF Workshop Lecture BRC v3 Evolution of Food Fraud Prevention 2018


I most certainly agree with this slide #4 since it reflects the thought that I shared in my March 2014 post about fraudsters attending conferences or courses that teach how to "catch and punish" them: "Fighting Fraud – Like Fighting Volcanic Eruptions"

Do you also know that fraudsters may even be willing to financially or otherwise support superficial anti-fraud efforts as these provide sufficient distractions, and that the distractions take the focus of industry away from doing what actually prevents them from carrying out their fraudulent activities?

Here is another fact worth considering about food fraud, fraudsters and victims: The most successful fraudulent activities in the industry are those funded and defended by the victims. The scope extends far beyond the usual list of things done directly to, or with, food.
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, 23 May 2018

Response to Prof. Alan Reilly's Whitepaper on Food Fraud

In his whitepaper, “FOOD FRAUD:UNDERSTANDING THE IMPACT OF FOOD FRAUD IN ASIAProfessor Reilly has provided an excellent discourse from the perspective of mitigating the effects of fraudulent practices in the food industry. The premise and points correctly reflect the general understanding, experience and suggestions for mitigation action, although certain realizations are not reflected. For example, the detection and avoidance of fraudsters and their products largely remains an after-the-fact approach by the industry.

Professor Reilly suggests that: “The onus is now on food companies to develop documented systems for Food Fraud Vulnerability Assessment (FFVA) and to implement measures to mitigate the public health, economic and reputational risks that may result from the food fraud”. Although this suggestion has some preventive overtones, it does not sufficiently address the root-cause (the almost insatiable appetite for economic gain).

The appetite for profit spreads to more institutionalized activities than what is done directly to, or with, food for economic gain. I have often maintained that we should be talking about “industry fraud” instead of the narrow focus on “food fraud”.  I have also mentioned elsewhere that the emerging business of selling partial food fraud mitigation solutions expands the very problem that the purveyors are purporting to address. By their own admission, those who sell partial and ineffective solutions, particularly through the 3rd-party certification route, agree that their solutions do not solve the problem. So, why do they continue to sell them? It requires very little imagination, if at all, to know that a company can complete a documented Food Fraud Vulnerability Assessment (FFVA), implement measures that it sees as sufficient to mitigate food fraud that affects its operation, get certified, then commits fraud. In fact, under current 3rd-party certification arrangement, it is very likely that one company may judge another company as presenting a low risk of committing food fraud if that second company is certified against the same scheme. In other words, the food fraud mitigation solutions that have been suggested under the certification arrangements are not only short in their anticipated effectiveness. They could actually be counter-productive instead of being preventive.

Truly preventive measures should address all root-causes. As such, even the “catch-and-punish” approach taken by the industry needs the necessary intelligence force and instruments that only law enforcement and judicial authorities have. The industry must therefore rely on these authorities and actively work with them.

It is really unfortunate that it comes down to this because of human greed. The industry must actively seek and participate in the necessary collaboration with law enforcement agencies among other parties that have helpful contributions like the academia, private consulting organizations, etc.  This collaboration must be done concurrently with any approach taken by the industry if any effectiveness is to be achieved with the adopted deterrent measures. It is not at all out of place for the industry to also have an enforced obligation to report identified incidents of fraud to the authorities once confirmed.

Also, as we know, elaborate deterrent operations have been undertaken by various law enforcement agencies, including the Interpol. While such operations must continue in attempts to curb the activities of subversive elements, the frequently reports about fraudulent activities in the industry show the insufficiency of all of the deterrent efforts. Something else is needed that is often not fully addressed. While it is important to educate food businesses on methods for catching fraudulent activities, it is equally important to educate would-be fraudsters on what could be done to avoid committing fraud, as well as on the need, advantages and merits of complete business integrity.

I still maintain that a holistic approach to solving the fraud problem is the only thing that warrants the effort. Insular solutions within individual silos, particularly in the forms of vulnerability assessment and mitigation action implemented by individual establishments will not do the job. Such solutions merely lead to finger-pointing and give the appearance of relevance, particularly when what is suggested can be done to gain certification or unwarranted trust with hidden intentions to commit fraud. Keep in mind that often when one finger points outward, three fingers point inward.

Let's be honest. In reality, only one solution exists for food fraud and fraud in general if everyone is committed to it. Anyone selling anything for fraud prevention that does not lead to this solution is either a fraudster or an accomplice.


Related Posts on this subject:




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, 9 May 2018

Food Safety & Quality Management with Warranted, Shaky or No Confidence

What is the relationship between a food operation's level confidence and 3rd-party certification audits?  Here are some points to consider:
A food operation that has warranted confidence in its established food safety and quality management programs does not normally feel the need, nor in fact need, to seek special affirmation by a 3rd-party. The established programs are usually self-affirming through the consistent delivery of safe and desirable quality product.

If, in spite of having the confidence that its programs are able to deliver safe and desirable quality products, a food operation feels the need to seek the affirmation of a 3rd-party, the felt need shows a shaky confidence which is not confidence.

A food operation that lacks confidence in its food safety and quality management programs often feels the need to seek special affirmation by a 3rd-party. The lack of confidence demonstrated by the felt need for a 3rd-party affirmation provides sufficient evidence for the 3rd-party sought not to affirm that the established programs are able to consistently deliver safe and desirable quality product. There is also an often silent legal accountability until a real situation arises that leads to an actual lawsuit.

Could the latter be why the declarations on many 3rd-party “certificates” do not clearly affirm the reliability of examined programs to ensure the consistent delivery of safe and desirable quality products? Could this also be why the lifespan of a 3rd-party certificate does not go beyond the date of the audit?


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