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Saturday, 30 March 2013

Product Safety - Beyond Compliance

There can be an escape from a helpless enslavement to industry’s worst kinds of self-deception such as the thinking that “compliance is enough in ensuring desired product safety”. Compliance is not enough because no set of man-made rules or standards can cover all situations and contingencies.

The industry should not be forced to engage in wasteful preoccupations by parties that are only seeking ways to make money at the expense of companies that fall for their tricks. In some instances, a blind preoccupation with trying to "comply" can lead to professional suicide. For example, if a food safety manager adopts a strategy of doing (complying with) whatever their superiors or customers say even when product safety is compromised, that can backfire. 
A blind preoccupation with "compliance" is like firing at the enemies' shadows or like holding up hands to stop the rain. Food safety custodians need to recognize and avoid such futility.

If a product fails, the usual scapegoats are the employees or managers responsible for food safety. It does not matter if they were doing everything the superiors or customers asked. This does not imply that instructions from superiors or customers are to be simply ignored wherever food safety is at stake. The instructions and possibilities of compromising food safety are to be discussed and resolved with the superiors and/or customers.

Under the guise of “compliance”, many managers stick to the futility of doing what has always been done even where outcomes are unsatisfactory or redundant. Alert managers tend to move beyond compliance to true commitment.

Compliance is merely an externally compelled behaviour. Whereas commitment is an internally resolved attitude.

Compliance and commitment may be defined as follows: “Compliance is doing what you are told whether or not it is the best thing that accomplishes the desired goal”; while “commitment is learning and consistently doing what is best whether or not you are told to do so”. Compliance often focuses on written or stated rules; commitment focuses on the desired outcomes. It is possible to comply without being committed; while it is almost impossible to be committed without complying.

Achieving compliance is too easy to be reliable. Compliance is only made complicated and complex because of the interference of personal opinions of the developers and assessors of the imposed rules. Compliance is easily achieved through simply becoming familiar with the semantics in the rules. Once the operator becomes familiar with the industry terminology and has a masterful paperwork juggling proficiency, compliance is easily attained. Compliance is also easily verified through paperwork-based and snap shot methods of reviewing its success. Therein lies its weakness and unreliability.

. . . beyond mere compliance and simply “gaining certification that everyone accepts” through inefficient cost management arrangements; SSQA is affordable everywhere and can be implemented anywhere to make eating safe . . . 

In contrast to mere compliance, commitment and competence in product failure prevention are not as easily and mechanically attained as mere compliance. These are also not easily verified through snap shot, paperwork-based assessment systems.

The manager with a product safety compliance mindset thinks that having well documented product safety and quality management programs with complete supporting records is of primary importance. To the compliance focused manager, products are incidentally safe once compliance is confirmed. 

The manager who is passionate about product safety thinks differently. To the food safety focused manager, having products that are consistently safe is of primary importance. Well documented product safety and quality management programs with complete supporting records are of secondary importance. Where efforts are directed at producing consistently safe products as the primary goal, programs are incidentally and inevitably well documented with necessary records, and compliance is more convincingly confirmed.

The passionate commitment of the product safety focused manager may look like OCD (obsessive compulsive disorder) but in a positive way. Their condition should actually be seen as OCO (obsessive compulsive order). Show me a product safety manager who thinks that it is abnormal to be committed to the point of appearing obsessed and I will show you a product safety manager who does not have sufficient passion for what he or she does. 

Ensuring product safety and quality requires positive and productive passion at all levels. In recognition of this fact, the advice to companies is to ensure commitment at every level and every stage of the operation. 

No need to stay stuck in the past:  
The importance of full commitment throughout the entire scope (from policy making to the emptying of trash) is stressed. While this kind of commitment is advocated through such avenues as system audit requirements, many companies and their managers stop at merely complying with the stated requirements. 

True passion is rarely demonstrated and sustained where operators are stuck in the compliance mode.

For example: Your operation has passed a third party audit. You have celebrated the pass with “pizza for all”. Your food safety system, as determined by the third party auditor, has met the requirements proposed by a committee that has little or no knowledge about the daily realities that your operation faces, now what? Will your consumers, because of their real experience with your products, celebrate your posted audit pass flag or mock it and demand a refund?

The challenge of this article is for companies to cultivate and sustain true passion for product safety at all levels and through all stages of their operation. This could be done in various ways through education, the right kind of ongoing motivation, empowerment, friendly collaboration, the development of a sense of ownership, et cetera. Do not stop until you see true passion for product safety sustained at every level. Do not stop because consumers (all of us and our families) can never be over protected from harm that can be caused by unhealthy food.

If you are involved in the food business, refuse to be part of a company that is stuck in the past. Move your company beyond compliance. This may require tapping into the Synergy between HACCP and SSQA: I make the SSQA (Safety, Security and Quality Assurance) plea without apologies. You may ignore it if you wish but our safety as consumers is not negotiable. We demand safe food of good quality.
Posted By Felix Amiri
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

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