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Saturday, 3 August 2013

Breaking the Addiction to Superficiality

The Silliness and Hypnosis of "Paper Certificates":

External audits, never mind the "paper certificate", provide a good review of implemented programs. Suppose we have collaboration in place of certification? That should at least eliminate the so-called conflict of interest safeguards that presently stifle the full and productive interaction between external auditors and the audited operations.

Have you ever contemplated a time when strong internal audits will be preferred over outside “certification” audits?

What leads to the actual safety of products?

If your current external certification system goes beyond a superficial show to get more business and actually leads to safer products,  by all means continue. If not, why not try an approach that works with your actual situations on the ground to assure product safety and quality? Keep in mind that business growth also means an inevitable increase in the opportunities for failure. This is at the same time that the pressure mounts for products to be actually safe and maintain good quality. Also keep in mind that externally imposed audit requirements will continue to grow increasingly complex. They will absorb much of your time in learning to first understand every new twist with which you must "comply". They will lead to fanciful paperwork but produce little to no effect on the actual safety of your product beyond what you have already achieved in previous years. By the way, many external systems also come with the disclaimer of providing no guarantees with the "certificates". Does yours?

Observed and Predictable Developments

The present enchantment by superficial “certificates” will fade away as more and more operations suffer the pains of costly recalls in spite of having “top-level certifications”. At the time this post was first written, there was a recall of about 50,000 pounds of ground beef products by a Kansas company over fears of E. coli contamination.
The USDA news release includes the name and location of the affected company.

Here is another example:

Other examples of recalls may be viewed here: List of other recalls and public alerts

Several of the affected companies have one form of outside certification or another. For example, the Kansas company’s website lists its Certified Locations and the BRC Site Listing identifies this company as certified to “Grade A” BRC (at the time of this posting):

Many operators may remain addicted to the “certification magic" but wiser companies are beginning to establish stronger internal scrutiny systems while maintaining superficial certification (at unwarranted costs) because customers are still demanding these certifications. The enchantment will fade in time as the effectiveness of these certification programs continues to be weighed against the real life results and costs.
The Pride of Product Safety Certification:
  • What is the typical lifespan of this pride?
  • What sustains the pride?
  • What happens to the pride in the event of a widely publicized product failure and harm to consumers?
Re-assessing the Power of Your Certification:
1. What exactly is certified?
2. How much guarantee comes with your certification?
3. Does certification mean that the certifying body is prepared to defend what is certified?
4. Is the certifying body willing to formally recommend your product and/or services to customers on the basis of the certification?
5. In the event of a court case because your product caused illness or injury while your certification has not expired, is the certifying body willing to testify that your certified systems and/or products are reliable?
6. Are existing external audit schemes not useful without certification?
Assumptions and Facts about Certificates

  • It is often assumed that certificates are issued after a supposedly careful assessment of the certified operation by well qualified and accredited auditors. Whereas the thoroughness of the examination within a restrictive time frame is questionable.
  • 3rd-party certificates are supposedly issued to an operation as a means for convincing customers that the operation can be trusted to provide safe products that meet regulations and acceptable quality expectations. However, it is doubtful that customers are fully convinced to the point of ignoring other more reliable scrutiny of supplied products simply because the suppliers submitted 3rd-party certificates.
  • Certificates are usually flat. If large enough, they may provide the CYA (preferably CYB) effect, but only from one direction. Other areas are often exposed. Besides, the real life evidence such as the 2011 Jensen Farm and other listeria outbreak cases have shown that CYB certificates are often tossed aside or used as indicting evidence with the certifying bodies (realistically and rightly) insisting on having offered no guarantees.
  • 3rd-party certificates needed for CYB purposes that are sometimes described as the demonstration of due diligence and some people are fooled. 
  • A genuine and effective exercise of due diligence is almost immediately and directly evident in an operation's products.  Where due diligence is theoretically demonstrated in order to obtain certification, the due diligence is most likely only for show. Where due diligence is genuinely exercised and not merely demonstrated (for show), certification is not necessary.
  • In an environment of a genuine, consistent and effective exercise of due diligence, failures leading to litigation are at least minimized and obtaining certification to demonstrate due diligence becomes unnecessary. 
  • Unlike its genuine exercise, the mere demonstration (for show) of due diligence is only evident on the surface and product failures leading to possible litigation are more likely.
  • 3rd-party certificates are presumed to provide legal cover for the operations should things go wrong. However, it is doubtful that the 3rd-party is always ready to defend the certified operation in the event of legal proceedings.
  • All considered, if an operation needs legal cover due to product failures, it should not be certified by an external party. It should instead be helped. If, on the other hand, the production and control systems of an operation can be certified by an external party as an expression of confidence in the operation's ability to maintain the desired outcomes (safe and acceptable quality products), the operation does not need paper certificates. The desired safe and acceptable quality products serve as better and sufficient evidence of the operation's capability.
  • The assessment by the qualified and accredited auditor is almost always within a limited time scope. The issued certificate technically covers only that time scope since the auditor cannot possibly know what happened at the operation before or what happens after the assessment time window. Hence the certifying auditor is justified to take a non-committal position immediately outside of the assessment time window.
  •  If a business can be trusted outside of the assessment time window, they do not need the certification except where the assessors know more or can see more than the operators of the business, which is rarely the case. 
  • If outside assessors know more and can see more than the operators of the business, these operators need to be trained and/or educated more than assessed. The effectiveness of the training may be assessed but not so much for an annual re-certification of the operation, but for operator re-training purposes until adequate operator proficiency precludes annual external coaching.
  • Customers who rely on certificates without carefully examining the supplied products take no less risk than customers who are committed to carefully examining supplied products without requiring outside certificates. 
  • External corroboration over a short assessment window provides no greater credibility than the supplied product that credibly and consistently proves to be safe, meets regulatory and quality requirements. 
  • Where the supplied products cannot credibly and consistently prove to be safe, meet regulatory and quality requirements, external certificates offer no more than a blanket cover for undetected failures, infractions, deviations and/or deficiencies. Under such circumstances, the certifying body remains justified to withdraw certification upon the detection, discovery or exposure of erstwhile hidden infractions, deviations and/or deficiencies. In addition to already being non-committal outside of the assessment time window, certification essentially comes to naught under such circumstances.
Related Posts

For now, we must continue to make the case for the development of strong internal audits:

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

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