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Friday, 27 September 2013

The Coming Shift - Product Safety and Quality Auditing

The thing with underground currents is that, like lava underground, they have the tendency to suddenly, sometimes painfully, catch the attention of people who ignored them.

Photo: On fire: Kawika Singson was shooting in the volcanoes of Hawaii, which was so hot his tripod and shoes caught alight, Courtesy of the Daily Mail: 15 July 2013 

An underground movement within the industry may suddenly catch the attention of people who have ignored it. This photo depicts some food safety assessment programs that focus on taking "spectacular" snap shots (snap shot audits) based on pre-set expectations without noticing the actual realities at the audited sites (the underground “lava”: Attitudes, business tendencies, wasteful traditions, cost burdens, time constraints, unnecessary time wasters and more). These are ever-poised to undermine the effectiveness of assuring the actual safety of the food produced.

The key issues addressed by Dr. Chris Elliot in his Interim Report show signs of the coming shift. One of the key suggestions includes: 

". . . a system where: industry, government and enforcement agencies always put the needs of consumers above all other considerations; this means giving food safety and crime prevention absolute priority over other objectives" 

This recommendation does not show the same details as the SSQA implementation guidelines but it should sound quite familiar, if you have become acquainted with the focus of the SSQA concept which is the actual protection (not the projected or anticipated protection) of consumers. This focus is clearly emphasized right from the title page of the implementation manual, through the outlined grassroots strategies that each food business should follow in organizing for success, to the outlined strategies for the broad collaboration of all stakeholders in SSQA implementation Step 4.

The SSQA concept is both fundamentally and practically different from audit schemes. The successful implementation of the SSQA concept is assessed with direct consumer input. As far as I have seen in the audit schemes to which many operations have subscribed, consumers have very little part to play in the assessment of success with food safety and quality management systems (i.e. if at all consumers have any part).

Except where death or severe enchantment has occurred, a hard knock unfailingly awakens the sleeper.
Some predictions are true prophecy when there are no real signs to show any possibility of the predicted events. This prediction of an impending shift in the way audits are done is not a true prophecy in that sense. It only reports things that have already happened and are continuing to happen at increasing frequency.

The industry may be pleased with its food safety and quality management and assessment efforts. A prevailing and incorrect assumption is that the success of a food business in assuring the safety and quality of food is only assessed either by regulators or 3rd-party auditors. Many companies are continuing to pursue 3rd-party certification to prove due diligence. However, as stated in the blog post - "Aftermath of the Killer Cantaloupe Devastation" - some companies are feeling superficially invincible because they are certified and are yet to suffer a fate similar to the likes of: Jensen Farm; Peanut Corporation of AmericaSunland IncorporatedXL FoodsMaple Leaf Foods.” The feeling of invincibility will last for only as long as it takes the next devastating event to occur. 

Are you aware of these events and are you ready for the next big shift in product safety and quality assessment models? The flood will come. The signs are everywhere.

Here are some marks of the present state of affairs: 
  • The pride of product safety quality certification drives the system more than the derived reality of product safety and quality consistency. 
  • Many operators view product safety and quality management as a "project" that is terminable at the point of certification. 
  • Upon obtaining certification these managers sigh and say: "Phew, we are finally certified". Consequently, the need to perpetually maintain the established systems as part of the normal operation slips. 
  • A great number of managers promptly go into professional sleep after each audit "pass" until a few days or a few weeks prior to the next audit. 
  • With much boasting about food safety advances due to more “sophisticated” and “expanded” auditing and certification schemes, some businesses have been lulled into sleeping certifiedan extended and temporarily soothing certification sleep.
  • For many operations, the current buzz about "food safety culture" does not go any deeper than compliance against the generic schemes suggested by parties that are more interested in selling the idea of food safety and quality management for profit instead of actually making food safe. 
The typical trustworthiness of a certificate lasts for no more than one year. In many instances, the trustworthiness becomes questionable as soon as the audit ends and certificates are obsolete as soon as they are issued. Certifying bodies readily withdraw certificates upon the first instance of a publicized product failure that may or may not have caused harm to consumers. The pride of certification is immediately lost. Although re-certification may be issued by the certifying bodies once “corrective actions” are implemented. Regaining the pride of certification and the respect of the consuming public after such incidences take longer.

Due to the obvious short lifespan of product safety and quality system certificates and auditing schemes, future shifts are inevitable in the way audits will be conducted. Those who have been in the industry for long enough know that shifts in auditing schemes have always occurred. Evolving systems will foster a properly managed scope of audits with specific attention given to the unique realities within each operation. Present generic (one template for many facilities) approach to auditing will become obsolete. 

With the increased capacity for resource optimization that they bring, internal assessment programs will increasingly gain proper attention and respect. Some operations will be driven into strengthening their internal assessment programs after some 'hard-knock" experiences. They will be jolted from sleeping certified.

Real-life incidents suffered by customers who presently buy from suppliers with external audit certificates will force them to initially switch suppliers. However, as the number of new suppliers to which a buyer can switch diminishes, customers will increasingly be forced to conduct or resume their own audits with diminishing attention given to the external certificates that the suppliers have to show. Some major customers are already conducting their own audits at their suppliers’ facilities in spite of available certificates.

Consumers are becoming more sophisticated. They will increasingly demand to see more than the “Food Safety Certified” flags that are currently flying on supplier buildings. They will more closely scrutinize the products and services with their 100% sampling opportunities. Whether or not we agree with the suspicions, conclusions and demands, outcries similar to the recent objections to the use of ADA (azodicarbonamide) in bread will increasingly continue to be heard -

A Flag of Fame or Shame?
The third party certificate is already being rendered inconsequential in the social media era. One mistake by a company and its raised "product safety and quality certified" flag becomes an object scorn. As messages and posts about bad experiences with the company's products flood the social media, people reading these posts will point to the "product safety and quality certified" flag and scoff. 

Posted By Felix Amiri
Felix Amiri is the current Food Industry Chair of GCSE-Food & Health Protection

Thursday, 26 September 2013

Assessment and Certification Arrangements for Product Safety and Quality Assurance

In the following examples, “suppliers” include manufactures, distributors and sales outlets. Customers” refer to other companies and institutional buyers. Consumers (those who use/eat the food) are not usually in a position to make any assessment and certification arrangements with suppliers or sellers. However, they are expected to examine the products they buy and decide whether or not to continue buying the products.

Does your operation have an arrangement similar to one of these examples A to E? As you read through the list, you may find that some arrangements are better than others. All of the listed arrangements require that operations must comply with all applicable regulatory requirements.
Some companies are already capable of running well but they remain content with learning to walk every year.

Arrangement A
-       Suppliers maintaining annual third party certification program;
-       Occasional customer visits to the suppliers’ facilities;
-       Minimal product inspection and testing by the customers (to minimize costs);
-     Annual third party re-certification costs are accepted as the cost of doing business and shared by both parties.

Arrangement B
-       Suppliers maintaining annual third party certification program;
-       No visits by customers (to eliminate the costs of such visits);
-       Minimal product inspection and testing by the customers (to minimize costs);
-       Annual third party re-certification costs are accepted as the cost of doing business and shared by both parties.

Arrangement C
-       Suppliers attain third party certification only for initial buying decision by the customers;
-       No mandatory requirement for annual re-certification;
-       Customers maintain regular product acceptance inspection and periodic testing with a strict requirement for the suppliers to conduct effective internal audits;
-       Occasional customer visits to the suppliers’ facilities;
-       Anticipated annual savings from no annual re-certification expenses are applied to supply price reduction.

Arrangement D
-       Customers do not care what suppliers do with internal or external audits or certification;
-       Customers maintain regular product acceptance inspection and periodic testing and base their decision to continue to buy on their findings;
-       Occasional customer visits to the suppliers’ facilities;
-       Anticipated savings from no external assessments and certification are applied to supply price reduction.

Arrangement E
-    Operations claiming to be “too small” to care about internal audits, external certification or any related arrangements;
-       Satisfied with “commonsense” monitoring of materials, processes and products;
-       Just content to do business as they have always done with “no customer complaints”

I cannot say that the above list covers all possible arrangements. You probably know about other arrangements that you think may work either for your operation or other operations. The arrangements suggested under SSQA are similar to arrangement C but they have additional elements that ensure greater collaboration for effectiveness, efficiency and cost control. The SSQA suggested arrangement for any operation is customized to the size, scope and nature of the operation. If you wish to learn about the kinds of arrangements suggested under the SSQA concept you may subscribe to receive SSQA Information

Join the SSQA Development (SSQA-D) Community – "the SQUAD"

Safety, Security & Quality Assurance (SSQA) Development Participation Opportunities:
  • SSQA provides the opportunity for food businesses to step into a brighter cost-saving future.
  • SSQA enrollment commission is continuing to be offered to food industry consultants and trainers. 
  • Individuals who know what SSQA is about are invited to join the presentation crew on tour to selected presentation locations. 
If you are interested in any of these participation opportunities, please contact the GCSE-FHP Team for further details.

Would you like to receive information about the SSQA concept, philosophy,
strategy, program and training opportunities? Would you like to learn the 6 steps to the adoption of SSQA? You May Subscribe to SSQA Information Updates.

SSQA Facilitators are needed by all food businesses:

If you are between jobs, becoming familiar with the SSQA concept and program may provide several opportunities for long-term engagements.

If you are a consultant or industry trainer wishing to expand the scope of your services, the SSQA program provides a solid base for various kinds of services that you could offer to your current and future clients.

Anyone who is seriously considering a career in product safety and quality management is invited to learn how to apply the SSQA concept and practical provisions in current or future system management engagements.

Companies interested in going beyond compliance will benefit from the adoption of the SSQA concept in their operations.

SSQA takes you off the fire fighting loop.

If you wish to receive updates about the SSQA concept and programs you may: REGISTER 
visit the Updates Page

Thursday, 19 September 2013

Product Safety and Quality Assurance Paperwork Reduction – Open for Discussion

Sophisticated and complex management systems with elaborate documentation do not necessarily provide greater guarantees of product safety and quality. You need to maintain only the optimum (not maximum) paperwork in your product safety management system. Systems that tend to create “more paperwork” for the sake of “documenting everything” without providing a strategic approach to the documentation process often become counter-productive systems.

The industry is overburdened with paperwork. Large operations often do not have as much of a problem with paperwork management. Many paperwork management solutions tend to be elitist (i.e. only for the medium to large operations that can afford the associated costs). 

A commonly suggested solution is the use of electronic systems for the collection, management and retrieval of information and data. Electronic data management systems are useful but they need to be carefully selected in order to be cost effective for the operation. Highly elaborate systems are not automatically useful to all operations.

Can a pileup of paperwork stop the train?

I must admit that I, like many others in the industry, feel that every operation must maintain applicable, adequate and a consistent trail of paperwork. Contracts, operating procedures and work plans or schedules are necessary but are many of the records that are mandated today necessary? Is the industry intimidated and driven into the avalanche of paperwork by a “Prove It” syndrome? Besides recorded information, are there other ways for operations to prove their commitment, consistency and success?

What are some feasible paperwork management solutions for small operations? Shall we say that the only solutions available to cash-strapped small operations are the usual advice for them to “just do the paperwork or leave the business”; or to “buy an electronic paperwork management system”?

Most importantly, can the paperwork currently mandated in the industry by various schemes be reduced to a more manageable volume by cutting out nice-to-have but redundant documentation?

Efficient paperwork management requires far more than its categorization according to the typical four levels of documentation.

GCSE-Food & Health Protection provides a simple Paperwork Reduction Guide that may be of interest to you. In the SSQA program implementation manual, the main categories and types of documents with a Mandatory, Useful and Discretionary (MUD) scale are also identified to guide decisions about what paperwork to maintain. A MUD-Scale assessment of every operation's documentation is highly recommended under SSQA.

You may REGISTER to receive SSQA Updates. Better still, you may obtain a copy of the SSQA Implementation Manual.

Posted By Felix Amiri

Felix Amiri is the current  Food Industry Chair of GCSE-Food & Health Protection

Saturday, 14 September 2013

HACCP and SSQA Concepts - Exceptional Synergy

According to Donald Rumsfeld: "There are known knowns. These are things we know that we know. There are known unknowns. That is to say,  . . . things that we know we don't know. But there are also unknown unknowns. These are things we don't know we don't know."
You probably know everything there is to know about HACCP but are you familiar with the synergy between HACCP and SSQA? Do you know that the SSQA implementation steps 3 through 6 concept can actively prevent your HACCP program from ever going stale? 

Given Donald Rumsfeld’s apt description of “known knowns, known unknowns and unknown unknowns”, I am happy to say that the synergy between HACCP and SSQA may fall into the category of “known unknown” for you and it can easily become a “known known”. Don’t let it remain an “unknown unknown”. 

You can connect with the  Dynamic Trio and begin to make these things happen for your company:

  • Optimize your company’s spending on food safety and quality management resources by focusing on what is essential and cutting redundancies
  • Break free from the institutionalized food safety management myths
  • Work with the actual realities faced by your company instead of remaining unnecessarily burdened by the virtual realities imagined and imposed from some far away boardrooms or desk tops
  • Go beyond mere compliance and actually fortify your operation against both anticipated and unanticipated product safety and quality failure issues
  • Mount a full scope partners shield against errors, failures and negative tendencies
  • Maintain a rewarding commitment to your company's social responsibility
  • Empower your company in its determination to maintain its moral obligation and meet all regulatory mandates
A Closer Look at the Main Drivers in a Well Fortified System (HACCP and SSQA)

HACCP = Hazard Analysis and Critical Control Point system.
SSQA = Safety, Security and Quality Assurance.

If HACCP is a tool, and it is, SSQA provides the discipline for the proper use of this tool. The SSQA concept is essentially a reality-based approach to the implementation of HACCP along with other strategic product safety and quality management measures. Like HACCP, SSQA is based on science and industry experience. It also has a set of principles and steps to follow in its implementation. However, SSQA offers much more. SSQA is more than a concept. It is also a practical philosophy that goes beyond the usual commercial interests surrounding the implementation of product safety management programs. SSQA is a culture and a strategy. It ensures the validity and effectiveness of all product safety and quality management programs, including HACCP. The synergy between SSQA and HACCP ensures the strength and consistency of implemented control programs in any operation. SSQA keeps HACCP from going stale.

Signs of a stale and flat-lined HACCP program:
Wherever there are random spikes and lows in the occurrence of unacceptable product incidents (related to safety or quality), the HACCP program has gone stale.

Where a decrease in the occurrence of unacceptable product incidents is no longer seen (i.e. the number has flat-lined), the HACCP program has also flat-lined.
___________Here are more things to consider___________

Like the game of soccer, poor and rich operations can play. Both SSQA & HACCP can automatically be customized  according to the size and resources of the operation.

Some industry players operating outside of the SSQA mindset ask whether or not they are required to have HACCP.” Such questions do not even cross the minds of SSQA operators. They understand that outsiders are not the ones to determine if the implementation of HACCP is required. Every SSQA operator demonstrates a true determination to protect consumers through the implementation of good control programs. HACCP is a good control program. Therefore the SSQA operator does not need to be forced to implement HACCP. Complete product safety management programs, including HACCP, are adopted as the every-day practical, cultural and collaborative reality by SSQA operators. Unlike some non-SSQA operators that put on fake appearances of commitment to satisfying the customer and the auditor, the SSQA operator remains genuinely determined to protect the consumer. Genuine (i.e. properly developed and implemented) HACCP programs are the stuff of SSQA with serious attention given to hazard analyses and risk assessment that includes the consideration of difficult-to-manage situations that exist in every operation. Even the newly proposed United States FSMA-HARPC (Food Safety Modernization Act - Hazard Analysis and Risk-Based Preventive Controls) does not mention any consideration of difficult to manage situations in its hazard identification and analysis requirements. Very few systems, if at all such systems currently exist, are as comprehensive, yet with simplified implementation and practical effectiveness as the SSQA-HACCP synergy.
Under SSQA, the principles of HACCP are adopted with the practical (as opposed to theoretical) collaboration of the entire supply and consumption chain associated with the operation. The SSQA system demands and provides opportunities for such collaboration.

Irrelevant conclusions are also prevented through the adoption of SSQA principles. For example, conclusions are not drawn about the sufficiency of pre-requisite programs (PRPs), operation pre-requisite programs (OPRPs), or supporting safety measures (SSMs) without meeting certain conditions. The key condition to be met is that thorough hazard analysis and risk assessment must be conducted. Every SSQA operator understands that conclusions about the sufficiency of PRPs or CCPS are not a matter of opinion. The SSQA operator understands that the only reasonable basis for reaching such a conclusion comes from proper hazard analysis and risk assessment. The implementation of critical control points may not be necessary for an operation if there are no critical health risks posed by the operation's processes or products. In such instances, non-SSQA operators may hastily conclude that HACCP is not required. SSQA operators do not draw such hasty conclusions. The absence of critical control points does not automatically warrant the abandonment of the “HA” (hazard analysis) in HACCP. In other words, an operation cannot simply decide that HACCP is not necessary without proper hazard analysis and risk assessment. 

The HACCP concept, though badly implemented by operators too numerous to count, is vital to every operation. Without a careful examination, irrelevant conclusions can be drawn about whether or not to implement HACCP, CCPs or what CCPs to implement. The adoption of SSQA principles and strategies will prevent such irrelevant and sometimes detrimental conclusions.

The SSQA system also expands the typical HACCP to the DMS-HACCP. This is HACCP with consideration given to Difficult to Manage Situations (DMS) based on FACTS that are real to the operation.

SSQA programs are reality-based and are designed to stand up against real-life tests.  Where reason and reality prevail, SSQA programs will stand up to any kind of audit or scrutiny that focuses on product safety and quality.

If you have not already seen it, you may also be interested in this post:  Adopting the SSQA - Safety, Security and Quality Assurance Model

Posted By Felix Amiri

Felix Amiri is the current  Food Industry Chair of GCSE-Food & Health Protection

Saturday, 7 September 2013

Watch, Guard and Protect - Internal Assessment Programs

Good guards do not leave their posts. This is FORTIFICATION. A system that provides such guards is far superior to that which provides time-constrained CERTIFICATION through the use of intermittent assessors who leave their post for long periods of time.

  Employing the right guards and battalions
is a sure way to win 
the food safety assurance war.

These may be linked but a clear difference and a clear choice exist between FORTIFICATION and CERTIFICATION  if a company must choose.
All well fortified companies may not be certified and all certified companies may not be well fortified. In any case, only well fortified companies stand to win the food safety assurance battles. 
All superficially robust, elitist and resource-draining product safety management schemes must give way to systems that truly address everyday realities. Otherwise, subscribers to the superficiality will continue to play the fools or unwittingly make fools of themselves.

Evolving systems will allow program managers and assessors to effectively focus on areas with real benefits and/or issues. The evolving systems will largely be managed internally within a framework of productive collaboration such as is possible with the SSQA concept.

The evolving systems will also foster a properly managed scope of audits with specific attention given to the unique realities within each operation. Present generic (one template for many facilities) approach to auditing are destined to become obsolete. With the increased capacity for resource optimization that they bring, internal assessment programs will increasingly gain proper attention and respect.

A properly designed and managed internal assessment program is a key feature of SSQA implementation step 6. The SSQA approach to managing internal assessment programs is based on the universally proven strategy of “divide and conquer”. This strategy can be adopted by companies in all sectors to ensure effective internal assessment programs.

At first, the divide and conquer strategy may appear to create more audits. What it actually does is optimize the time spent on auditing with the net effect of quicker improvements to the overall system.

It is essential to note that while this strategy works well for internal assessment programs, expecting external certification schemes to adopt this kind of strategy would be unfair. It would be impractical for the certification schemes and the costs would be astronomical for certified companies. However, for internal purposes and according to the SSQA Implementation Guide instructions for managing this strategy, its adoption can be properly focused, effective and exciting.

The “divide and conquer” strategy involves the categorization of audits or assessments as provided under the SSQA Implementation step 6 – “Continuing Analysis of Realized Effectiveness and Efficiencies” (CARE). Examples of listed audit or assessment categories include:

Overview Audits:
1.     Capture All Audit
2.     Programs Implementation and Effectiveness Assessment

Specialized Audits
1.     Management system Audit
2.     Traceability, Recovery and Yield Efficiency Audit
3.     Employee Awareness and Motivation Audit
4.     Partners Audit
5.     Contamination/Cross-Contamination Audit
6.     Incident Response Forensic Audit

What is involved in these overview and specialized audit categories are further explained in the SSQA Implementation Manual. This manual also provides some instructions about how to set up and manage the internal assessment program so that resources and the personnel involved are not overwhelmed.

I will be glad to address any questions that you may have about this topic. Meanwhile, here are links to posts that may also be of interest to you: 

Felix Amiri is the Food Industry Chair of GCSE-Food & Health Protection