How much product safety enforcement by how many outside
agencies is sufficient for each establishment?
Although a much calmer and efficient route can be taken to achieve consumer protection, regulators and corporate customers have elected to take a route with unavoidable turbulence. They are sticking with the current methods of policing food safety.
Heard about the person whose house caught fire and they set up a fan "to blow the flames out"?
The Coming FSMA Fee Bite:
From the answer to the Frequently Asked Question F1.2 posted by the FDA, a reasonable
deduction could be that a company would be able to minimize the fees it pays by complying
and avoiding re-inspection. Unfortunately, a level of compliance that precludes
re-inspection is almost impossible to achieve, given how the U.S. Food Safety Modernization Act (FSMA) and similar
initiatives are currently setup.
Intensifying Turbulence:
Food businesses of all sizes must brace themselves as they approach the intensifying turbulence ahead. With the U.S. FSMA, the Canadian Safe Food for Canadian Regulations (SFCRs), and similar new food safety rules in other jurisdictions, confusion expands and the pressure is mounting for food businesses everywhere. Meanwhile, customers are increasingly demanding food safety certification by outside parties. With all of these demands and developments, suppliers must adapt their systems to meet expanding expectations (even the unreasonable ones) while fully absorbing the costs of implementing various programs plus inspection/audit fees. If you have not already done so, this is the time to lay solid foundations and implement strategies that will enable your business to withstand the approaching compliance turbulence.
The wind is picking up. The U.S. FDA under the Food Safety Modernization Act (FSMA) and the Canadian Food Inspection Agency under the new Safe Food for Canadians Act (SFCA) do not accept third party food safety certifications as equivalent compliance. In other words, a food business cannot be certified to a third party food safety scheme and expect to have met regulatory requirements without further regulatory scrutiny. The regulators are essentially saying that a food business may certify to whichever scheme it wishes, that does not preclude regulatory scrutiny according to established regulatory requirements. The obvious implication is that operations wishing to certify have to simultaneously ensure compliance to third party schemes as well as to regulatory requirements.
Keep in mind that beyond compliance, there can be another cause of uncomfortable or even deadly turbulence. This has to do with actual product failures. Such failures tend to readily and disastrously clip the wings of a company's business jet.
With new regulatory
rules emerging everywhere, and the ever-evolving versions of
confusing and often redundant third party requirements, smart operators are
increasingly focusing on meeting regulatory obligations while concentrating on
satisfying essential customer obligations such as product specifications and
performance expectations. They are returning to the basics of assuring consumer
safety and product quality. They are realizing that some redundant things like
make-work certification programs must simply go for the sake of maintaining
sanity and realistically ensuring business survival. They are no longer yielding to the empty
threats of business loss if they do not have redundant certificates.They know that businesses that efficiently concentrate their resources in the actual fortification of their product safety and quality assurance measures are the ones that will survive. For them, paper certificates no longer hold the power that they appeared to have held in the past. As more certificates are crumpled and thrown in the trash during published court cases, more operators will abandon the certification craze and "fortify" rather than superficially "certify".
Start the ascent now if you wish to rise above the turbulent clouds.
While superficial
compliance is possible on paper, the real test of a company’s success in food
safety assurance is the actual elimination of product failure turbulence. So,
here is my often repeated advice: Just because you will be quite busy trying to
comply with the mounting regulatory and customer demands, do not let this drive
you into finding ways to superficially comply. You will make friends of the
inspectors and auditors but they are fair-weather friends. They will abandon
you to face the turbulence alone as soon as you suffer a significant product
failure. Take the withdrawn certification of Sunland Inc. for example: You must build strong product safety, quality assurance programs for
the protection and satisfaction of consumers in order to avoid the discomforts of
turbulent times. Start the ascent now! You need to take your operation beyond "compliance".
Climb to higher altitudes with the SSQA turbo engine! Find out about Adopting the SSQA Concept!
Posted By Felix Amiri
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