They say: “You will be left in the rain” if you do not buy the shield but what is offered is only a paper shield.
It should be common knowledge, if not experience, that the demonstration of due diligence is not likely to win a court case faced by a company if it sells a product that causes injury.
Failed Objectives of Standardized Supplier Assessment Programs
Although "uniform standards" and the use of outside auditing and regulatory agencies promise cost reduction, impartiality, elimination of self-regulation by suppliers, a “level playing field” and satisfied retailers, these objectives are only marginally realized. The industry generally accepts illusions of success along with the notion that uniform assessment standards automatically lead to strong product safety systems.
The frequent incidences of product recalls that are affecting large "food safety certified" companies, even in advanced countries, point to an undeniable systemic failure in the global product supply chain. Some of the significant product recalls involve companies that have enlisted in the “level playing field” and external party assessment systems. This forces the admission that the external assessment processes do not offer any guarantees of product safety. So what do they offer?
Some may argue that these uniform assessment schemes help customers choose among possible suppliers or co-packers and nothing more. Where product safety and quality form the bases for the choice among suppliers or co-packers, this argument hardly justifies doing the same things, getting the same results (without product safety guarantees) and resting satisfied.
Should the industry continue with this “level playing field” and “due diligence” game or should the focus be the actual protection and satisfaction of consumers? How comfortably should retailers rest with these “level playing filed” and “due diligence” proposals or claims? Will consumers who are harmed by, or who are dissatisfied with, supplied products simply accept their fate and say the suppliers' certifications demonstrated sufficient “due diligence” under the circumstances?
The presents he standard owners derive the so-called uniform standards from the same knowledge pool with the standards simply packaged in different formats. Even the acceptance of different standards on criteria that are drawn from the existing knowledge pool. Essentially, the standard owners and standards unification bodies “uniform standards”.
Many users of these different “uniforms standards” appear to draw a fallacious conclusion that they constitute the foundations upon which to build successful product safety and quality management systems. In reality, the true foundations are science and real-life experiences by the industry and consumers. Incidentally these true foundations form the basis for any product safety and consumer protection confidence. Where proposed standards do not correctly and completely reflect these true foundations, they simply serve as decoys and any operation relying on them is badly mistaken.
Mr. Linford expressed what clearly represents an illusory concern of many industry participants today. Mr. Linford stated as follows: "If there is a move away from third party audits then you will move away from uniform standards into individual customer and supplier standards as before, this can work but when things go wrong for whatever reason it is more difficult to demonstrate due diligence in the absence of compliance to a recognized standard."
Failures will continue irrespective of how the same old things are packaged and re-packaged. All claims about any successes with the current arrangements need to be seriously re-examined.
In a separate conversation, Mr. Linford said what must be said to jolt the kind of right thinking that is very much needed today. He said: “. . . the key point for me is that there has to be a framework which is recognised in law (such as an industry standard) , I don't believe any of the current standards are perfect and all need to be used as a framework rather than a rigid set of rules i.e. using basic common sense. I am interested in food safety and risk assessment and am currently working independently so have cast off my corporate shackles and can say it as I see it. Many of the Tech Managers in the UK would have issues in expressing their views in case they did not chime well with their customer base, by the same token standard developers are also bound by what is commercially acceptable rather than taking a purist approach there is much up for discussion from your innocent questions. My answer to the single question audit was similar to yours, ‘ what measures have you in place to assure the safety of your consumers? ' and clearly the answer to this is not ‘we passed an audit’ "
A paradigm shift is clearly needed. One area of such shift is in the strengthening and utilization of internal audits as part of the controls for ensuring product safety. Let me stress that the idea of “internal audit” does not preclude the contracting of qualified external providers of audit services to conduct such audits. This can be done in the same way that employees are hired under contract to perform different roles. This shift of focus to internal audits is not altogether a novel idea. Customers have and will a rely on the suppliers’ consistency in maintaining good control of all aspects of their operation. Strong internal audit systems ensure the completeness, consistency, regularity and effectiveness of internal control measures with or without external audits. External or third party audits may verify that these controls are in place. However, consumer safety and satisfaction with products from suppliers depend more on the day-to-day internal controls (including the internal audits) that are maintained by the suppliers’ personnel or contracted external parties. Many providers of external third party audit services also recognize
The term “internal” does not mean “for internal eyes only”. In an environment of complete transparency, customers may scrutinize the results of internal audits in the same way that they may scrutinize the records of all other internal control measures: production monitoring, quality control, risk assessment, implemented HACCP programs, corrective actions, environmental control (temperature, humidity, ventilation, air quality, etc.), sanitation, employee training, customer communications, et cetera. Customers may demand better internal audit performance where necessary in exactly the same way as they would for external party audits.
If the anticipated problem with internal audits is the lack of integrity shown by the audited parties, third party audits do not solve this problem. Rather, the problem actually worsens in some instances. A good portion of the resources that could be applied to strengthening the internal control programs are inevitably expended in maintaining needless external corroborations. The premise of distrust that drives the presumed need for external audits in order to gain customer trust is counter-productive. If suppliers cannot be trusted to run internal audits with adequate knowledge and integrity, how can they be trusted to run their operations with adequate knowledge and integrity after the external auditors have left the scene? The battle is already lost if suppliers cannot be trusted. On the other hand, if suppliers can be trusted to run their operations with integrity in the absence of external auditors, they will run their internal audits with integrity. Trustworthy operators can be counted upon to demonstrate good ethical and moral judgments. They are also socially responsible and do not need to be subjected to external scrutiny except where this is a redundant corroboration. All well informed and wise operators do not need outside parties (third party auditors or regulatory inspectors) to force them into operating with integrity. They almost naturally act with integrity because they understand that business survival is most assured where honesty and integrity are maintained. The outcome is that customers or brand owners can have confidence and consumers are well protected.
Customers’ concerns about damage to brand reputation cannot be alleviated through snapshot third party audits. As soon as the third party auditor leaves the scene, the facility that lacks integrity and control will relapse into practices that are engendered by such lack of integrity and lack of control. In the absence of supplier integrity and good internal controls (including good internal audits), there will always be this concern about possible damage to brand reputation. If, on the other hand, a supplier shows integrity and control, the customer can rest assured with the supplier’s effective internal audit program. The brand is protected in the process.
This discussion calls for companies to seriously re-examine current arrangements along with all of the erroneous pre-suppositions. Reactions to this blog post are anticipated. Please feel free to provide your thoughts. It will certainly be beneficial to have input from more people with an open-minded approach. There must be such open mindedness, clarity of thought, shared knowledge, properly harnessed pool of expertise and frequent reality checks in order for the industry to successfully deal with the product safety challenges that it faces.
Felix Amiri is currently the chair of GCSE-Food & HealthProtection. He is also the Director of Technical Services at Amiri Food Industry Support Services (AFISS) and the Canada/U.S representative for the World Food Safety Organisation.