Copyright © Global Coalition for Sustained Excellence in Food & Health Protection, 2011 and ALL subsequent years: Unauthorized use and/or duplication of this material without express and written permission from this blog’s authors and/or owners is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Global Coalition for Sustained Excellence in Food & Health Protection with appropriate and specific reference and/or link to the original content.

Monday, 30 December 2013

Where Water is Gold - A Challenge to Global Food Safety and Quality Assurance:

The shortage of clean water supply in many regions of the world poses a challenge to all of the king’s food safety sages (industry experts). The food safety problems facing the global food supply are not confined within the boundaries of countries where highly sophisticated food safety schemes and regulations can be consistently implemented or enforced. Many food safety problems exist in, and are imported from, regions of the world where these schemes are economically impossible, simply ignored or deliberately circumvented.

The issue of water shortage extends beyond its non-availability for drinking. The implications extend to difficulties in the assurance of food safety and quality. Incidentally, the underprivileged conditions leading to the shortage of water in parts of our world also lead to closely connected deprivation in other ways.

As a food safety specialist in a developed country, it is easy for me to theorize that every operation is able to consistently maintain effective and acceptable food safety measures. Many of the formalized systems for the management of food safety and quality in developed countries are based on assumptions that are clearly contrary to the realities in other parts of the world since the means for adequate management of food safety and quality are not as readily available in less developed countries. Some of these countries can only dream about the things that the developed world takes for granted such as the availability of water, utilities and amenities.

Even in developed countries, some small operators find it difficult to provide needed infrastructure and resources for the adequate management of food safety and quality. The challenges are multiplied several fold in less developed countries. As an example, without a well-formed industrial base for parts supply, the challenge of adequately maintaining operating buildings and equipment is enough to put existing operations out of business and prevent the establishment of new operations.

Even seemingly simple things pose almost insurmountable challenges where resources are scarce. The shortage of clean water in some less developed regions of the world provides a good demonstration of such challenges. It poses perennial difficulties in the maintenance of adequate sanitation practices. “Wash your hands” is a simple food hygiene instruction except where water is gold.

Situations of water shortage also exist where water is contaminated due to industrial wastes (hazardous chemicals or compounds, heavy metals, radioactive materials or nuclear wastes, etc.) Yet, operations from these regions, using dirty or contaminated water, grow, harvest and sometimes process certain food items that are imported by the so-called advanced or privileged countries. 

Also, food businesses in the less privileged regions often do not have the resources to manage highly formalized operation control systems. Many of the sophisticated food safety management standards that are the expected norm in developed countries are completely out of reach in parts of the underdeveloped and developing world. These realities present considerable challenges to the safety and quality of global food supply. What can and should importers in advanced countries do with exporters in the less developed world?

While regulatory enforcement at the import destinations is often thought of as the solution, this offers no more than simply barring imports from less effluent countries. This may work in terms of food safety and quality assurance for the importing country. However, where the countries imposing the barriers are not self sufficient in providing the barred items, this commonly applied regulatory enforcement solution leads to non-availability of a variety of certain food items. Thus regulatory prohibitions and barriers create a significant problem. Besides, the regulations and barriers are not absolutely reliable in providing complete and consistent protection for the importing countries' population.  

So, apart from regulatory barriers and standards which are unattainable by operators in less developed world, what solutions are possible in ensuring the safety, quality, sufficiency and variety of the global food supply? What food safety assurance measures are possible where water is gold?

Additional Reference
Canadian and World Issues -Adult Education Centre South: Water Crisis

Posted By Felix Amiri

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

Friday, 27 December 2013

An Invitation to a Noble Act

Opportunity for Positive Impact  - OPI

Can one human without divine powers change the world? No! But have single individuals contributed to improving human experiences? Yes! 
That's all that can realistically be asked of anyone.

You can demonstrate that you care beyond words 
by simply becoming a member of  GCSE-Food and Health Protection.

Free membership is offered and everyone is invited.
You now have several opportunities and options for participating in the conversation and keeping up with what is happening in the campaign. Please visit the main campaign web site often as it is continuing to be updated.

As part of the global action campaign, GCSE-FPH is committed to facilitating helpful information exchange among members and with the public. This means that every member is free to contribute information and every member is free to use information contributed. 

The open public forums include existing social media:  LinkedIn:

In addition to the open forums, members have the opportunity to request and receive assistance from the GCSE-Food & Health Protection Team:

Some assistance may also be requested from the GCSE-Food and Health Protection Panellists. These are highly knowledgeable and experienced individuals in matters pertaining to food and health protection, food and health product safety, quality management, auditing, training, regulatory requirements, consumer affairs and other areas of expertise. GCSE-Food & Health Protection has enlisted and continues to enlist members who serve as Panellists from around the world.
A member who wishes to be assisted with any technical question or issue pertaining to food and health protection submits a request to the GCSE-FHP Team. The Team contacts the Panellist members who are most suited to provide answers or guidance and the Team coordinates the information exchange.

For details about how this works, you may consult the Membership Guide for registered members.

Tuesday, 24 December 2013

Rescue Mission for Food Operations – the Strategic Integration of SSQA

In all disaster situations, 
hope drives a rescue mission; 
but hopelessness shrouds a recovery exercise.
Systems and concepts for product safety and quality management are common in the food industry. It is difficult to find a food business that has not, for example, heard of HACCP (Hazard analysis and Critical Control Point). More elaborate systems have also been implemented by a number of operations. As a food safety enthusiast, I cannot overemphasize the need for operations to implement systems that can help them to consistently ensure product safety and quality. The focus and effectiveness of implementing these systems are governed by a very basic recognition that has sadly eluded many operations: The robustness of the implemented systems is not the goal. The systems are simply part of the means for achieving the goal.

Implemented product safety systems and programs are tools if you will and, as such, they must efficiently and effectively aid the users. Just as the right wrench is needed for the right job but a well polished wrench is not the goal, adopted concepts and systems must fit and accomplish the job but their robustness is not the goal. Where overwhelming evidence shows that the job has not been accomplished, polishing the tools is nothing but a futile engagement.

After nearly 20 years of managing, auditing and reviewing product safety and quality management systems, I have found that many of them fall into one of two categories of drowning systems. Some systems that may superficially appear to be effective are drowning in inefficiency. Others that may seem to be efficient are drowning in ineffectiveness. In either case, it is unwise for the struggling business to reject a rescue rope simply because it has never tried such a rope. SSQA serves as a rescue rope to many businesses that are currently in operation.

Many of the operations with which I have worked appear trapped within the strangle-hold of product safety and management systems (tools) that are like under-sized or oversized wrenches. At times they are the wrong tools altogether for the operations. Even large operations have spent a lot of resources to implement elaborate, costly, but inefficient systems. These situations are all in need of rescue through an integrated, effective and efficient system for the sake of consumers.

A practical, effective and efficient product safety and quality management system is mandatory for every food operation. In the case of new operations, this mandatory requirement can be met through the strategic integration of the SSQA concept right from the start. Operations adopting the SSQA concept early in the development of their product safety and quality management systems stand to benefit greatly in terms of the effectiveness and efficiency. However, operations that may not have adopted it right from the start are able to easily adapt their systems to SSQA. This is one of the key advantages of the SSQA concept. With the right guidance, SSQA concepts can be readily and productively integrated into existing management systems. While this flexibility is very useful, there is nothing like laying a solid foundation right from when the idea is first entertained to establish the operation or business. Adopting the SSQA way of thinking is crucial even before building the new facility and commencing operation.

The good news is that most implemented programs can be rescued. The bad news is that some need recovery after disastrous recall incidents. It is rather late when a business needs recovery. Worse still, it often becomes impossible for some operations to recover from overwhelming losses that are suffered when harmful products are recalled. With operations that need to be and can be rescued, the task often includes the re-arrangement of more than the documentation. A total renovation of the system and culture may be necessary.

Like all renovation work, some parts may need to be dismantled and rebuilt. Many of the implemented systems that I have examined only cover parts of SSQA implementation step 2. Some more elaborate systems sporadically cover traces of the remaining five steps (1, 3, 4, 5, & 6). To have a fully integrated SSQA system, all six steps need to be covered. An important point to note is that while the steps are numbered 1 to 6, they do not need to be implemented in that order. Each step is able to stand alone although it is independently incomplete. This shows why the so-called elaborate systems that have covered only parts of step 2 are essentially incomplete systems although they may appear to be independently functional. The six steps of SSQA implementation are briefly described under the heading “Other Differentiating Key Concepts and Strategies” in the post: “Adopting the SSQA - Safety, Security and Quality Assurance Model”.

Posted By Felix Amiri

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

Saturday, 21 December 2013

Food Safety and Your Reaction:

While unfortunate events like Ebola and MERS outbreaks that threaten our world get much publicity, an everyday reality is sadly ignored. If not more, just as many people in the so-called civilized world are dying of food poisoning events and other risks associated with food

When “food safety” is mentioned, which of these best describes your reaction?

A.         It is of no concern to you.
B.         You’d rather let the food industry and the government worry about it.
C.         You believe the hype is to generate work that provides income for people in that field.
D.         You take it seriously and you are interested in actions to ensure it.
E.         You actually feel directly involved and you take real actions to ensure it.
F.         You are scared to eat commercially processed or prepared food.
G.         You feel there are more serious issues in the world than the safety of food.

H.         Your reaction is a combination of: _____________________________ 

I.         Your reaction is completely something different: _____________________________ 

 "Fatal Indifference" 

Wednesday, 18 December 2013

Product Labeling and Claims - The Reality, the Law and the Litmus Test

Transparency, The Law, Label Declarations, and Consumer Protection

Hypothesis 1:
The law must be based on reality and, therefore, must address real issues. Otherwise, it is futile and serves merely as grounds for senseless and irresponsible argumentation.

Hypothesis 2:
Claims about the benefits that consumers derive from a product must be based on truly confirmed reality (scientific or otherwise). Claims that are based on hasty tests or personal opinions are irresponsible and fraudulent.

Hypothesis 3:
Information about possible adverse effects of food on vulnerable populations must be honestly and clearly declared. It is irresponsible and fraudulent to use language that causes confusion or print sizes and information placements that evade notice.

Further Examination of the Hypotheses:
The different players in the label declarations arena have their respective roles as follows:

Law makers’ determination to protect the public from any deceptive claims by food merchants about their products is commendable. However, proposed or enacted laws that attempt to cover every possible scenario create more confusion than they resolve because a complete coverage of all possible scenarios is impossible.

Food labeling laws in many jurisdictions require the label (or product information) to identify all ingredients, the sources and potential hazards such as allergens and sensitizing agents present in the product. A departure from this otherwise realistic requirement occurs as soon as certain ingredients, materials or substances are specifically named as requiring mandatory declaration. Even where scientific studies and/or actual consumer experiences have shown that such materials need special usage precautions or prohibition, a prescriptive focus on such materials in any law is a mistake. The specific naming of a material in a law other than to serve as an example of materials of concern is a departure from practical reality. Along the same lines, prescribing allowable limits for specific materials in any law is a departure from practical reality. The likelihood exists that some consumers could have adverse reactions to levels outside the prescribed limits. Even if instances of adverse reactions are very few, they are not insignificant. A person who actually suffers the adverse effect is not likely to view that as insignificant.

Product merchants are entitled to claim the credit for any benefits derived from their products. They also have the full responsibility, culpability and liability for any harm caused by their product due to any cause within their control. Product merchants must ensure full disclosure of product information, particularly the composition, origin, special processing or production methods, etc., that are or should be of interest or concern to consumers. 

The scientific community and industry experts serve the law makers, product merchants and consumers. Their investigations and (realistically) proven findings provide the basis for labeling claims, regulations and consumer choices. Any label claims and regulations that are based on such unbiased investigations are closer to the reality than otherwise. In every case of a claim made by merchants, the introduction of new type of food item or ingredient, a regulatory restriction, a legal prohibition, et cetera, unbiased, thorough realistic and extensive studies that are free of ulterior motives and lobbyist pressures are necessary.

Consumer advocates are usually on the side of protecting consumers. They act to ensure that consumers are fully informed and prevented from eating food that may cause them harm. They also act to ensure other interests or needs of consumers such as nutritional needs, fraud prevention, fair pricing, social responsibility of food merchants, etc.

Consumers rely on the scientific (usually health & safety professionals), industry experts and consumer advocacy for information that guides their choices. This makes the provision of realistic and relevant information to the consumers all the more crucial.

A Case Study:
by Karlene Lukovitz, November 20, 2014, 7:26 AM

Litmus Test:
With GCSE-Food and Health Protection, the health of consumers is of higher priority than the economic benefits to the merchants although this is important. Thus, with the stakes clearly stated, and remembering that regulatory approvals can be subject to lobbyist pressures without the physical presence of the lobbyists, a simple litmus test can be applied: Check the motives behind every instance of a claim made by merchants, the introduction of new type of product, a regulatory approval, et cetera; check to see if the proposals and approvals are for health reasons, for financial gains or other economic reasons; and check the motives behind regulatory approvals to see if such approvals are because they (the regulators) wish to enhance public health, to boost “the economy” or simply to advance some political aspirations.

So we have the possible motivators: consumer health, financial gain, the boosting of public health, the boosting of economic activity, political agendas, etc. There may be other motivators but given those listed, which do you think are most likely to drive the pursuit of reality in investigations prior to label declarations and regulatory approvals?
Posted By Felix Amiri
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

Friday, 13 December 2013

Distrust - A Critical Industry Consideration

Breaking News - January 6, 2014:

Do not be deceived: Any system that is driven by distrust cannot earn trust.

In an industry where friendship must be maintained, distrust appears to reign supreme. A simple mathematical relationship exists between friendship and distrust: 

Distrust: This highspeed train, full of fuel and at the peak of its acceleration, has lost its brakes in the highly populated food production, distribution and consumption community. The industry is increasingly becoming unable to control this runaway train through the many sharp bends.
Although the industry and regulators are busy trying to stop the train, much of what is done is like supplying more fuel and applying lubricants to the brake pads. How does this make you feel? Is this actually happening? The answer is quickly found by taking a look at the incessant reports about fraudulent behaviour in the industry.

Fraud is overtaking the industry. Unfortunately, most anti-fraud strategies aimed at punishing the culprits end up adding more fuel to the runaway train's fuel tank. Adopted strategies force many fraudulent operators to go underground. Meanwhile, the adopted blanket approaches that cover all operators (a scope that is far too large for effective control) sufficiently divert and diminish the attention that should be paid to the actual culprits. Thus, with the added fuel as well as the diverted and diminished attention serving as the lubricant on the brake pads, the industry continues to have a slippery success in stopping this runaway train.

Much damage has already been done and more heartbreaks await the industry and consumers. This train continues to accelerate. The casualty toll mounts and everyone everywhere is on the path of this train. Even fraudsters are defrauded. Royalties and rulers; rural and city dwellers; the wealthy, the poor; highly educated or under privileged; everyone is affected by the carelessness and scheming of fraudsters. Fraud-tainted food and health products are consumed by all with some immediate, prolonged, visible or hidden adverse health effects. Everyone is affected by the increased cost of food due to self-imposing but fraudulent food safety management or corroboration schemes.

All hope is not lost but the industry urgently needs to think and act differently. If this train is to be stopped, the industry must re-orient its thinking about compliance enforcement. It is not reasonable to think that distrust can be completely stopped but the industry can at least stop doing things that encourage it or things that are counter-productive in stopping it.
The time to act is now. As stated in the introduction to the GCSE-FHP membership guide, “Attaining perfection is impractical. However, a sustained level of excellence is possible if we work at it and if we work together.” 

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

The Bald Persons and Hairnets Debate:

A debate on the question of bald persons needing to wear hairnets is going on among some members of the industry. It is quite intriguing to see the debate prolonged to the extent that it has. While many good comments have been made, others leave me wondering. 
Has "the rule" become more important than "the reason behind the rule"? Is anyone concerned about the level of understanding (or lack thereof) in the industry that makes it necessary for such considerations as "one rule for everyone"? If this is the level of understanding that the industry has to work with, and considering that we have more issues than the wearing of hairnets by bald people, what is the real danger faced by the industry?

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

Thursday, 12 December 2013

Change – Hated and Halted or Desired and Designed

Change is inevitable. Much of it is deterioration or degradation unless something is deliberately done to counter that trend. 

  It takes no more than one instant of positive thought to start the process of positive change.

In spite of the boasting by some businesses about maintaining consistency through the years, change is inevitable. Change affects from very small companies to multi-national businesses. If nothing else changes, the weather does and sometimes with devastating consequences to operations. Each operation has changes that go beyond the weather. These changes may be planned, predictable or unpredictable. Irrespective of the nature, all changes need to be properly managed for any operation that wishes to survive. 

Undesirable changes that must be halted occur in very operation. At the same time, positive changes are desired and deliberately designed into the normal operation where the organization is forward-looking. The common phrase for deliberate design is "continuous improvement". 

Where businesses boast about doing the same things consistently, what they are in fact saying is that they have consistently managed disruptive changes. In other words, the focus on ensuring consistency through many years does not show the absence of change. What it shows is the the management of inevitable changes that occur with time whether deliberately or involuntarily.

Conceptions, Conceptualizations and Change

Change, to re-state this for emphasis, is inevitable and must be properly managed. Managing change calls for the methodical pursuit or adoption of conceptions (i.e. what is known, verified and ideally tested to be correct, valid, repeatable, etc. ) and conceptualizations (i.e. the phase of dreamy imaginations about success or the mere anticipation of success). Sometimes, irrespective of conceptions and conceptualizations, change is forced by unforeseen circumstances that are not subject to mathematical projections.

Even in the process of verifying and testing ideas, a change accommodation model approach produces the best results. This model permits well managed change in response to findings that would lead to taking the best courses of action. Where positive or progressive change is deliberately pursued, the change accommodation model is evoked right from the point of initial conceptualization to the point of actual success.  

Contributions of the SSQA Concept

The SSQA concept encourages change management considerations for any size of operation. The extent to which an operation goes with its change management depends of course on available funds and personnel with adequate knowledge and experience to properly mange change. An operation may take a stance of simply shutting the door to the initiation of changes. It may only concern itself with being prepared to deal with unanticipated changes. This would be the crudest form of change management. More sophisticated approaches may have incremental degrees of preparedness to deal with unanticipated changes in addition to varying degrees of deliberately planned changes. Those who deliberately plan improvement changes understand fully well that consistency is a good thing. What they refuse to accept is a resignation to the notion that change is only disruptive. Change, particularly a well planned change, can be good. Where it is not, it must be managed well so as to derive good from an otherwise undesirable change.  

Crude or sophisticated, the proper management of any form of change includes at least clearly assigned responsibilities and ongoing course correction. In more advanced systems with formalized change management, improvement changes are planned and implemented. The concept of continuous improvement is customarily embraced as an integral part of change management in such systems. Also, in more sophisticated systems, the following features may be included:
  • A well articulated and documented change management process;
  • A change justification and approval flow sequence with some predetermined criteria for decisions to go ahead with the change;
  • A process for implementation evaluation of approved changes prior to the full adoption/commissioning of the changes; and
  • The re-evaluation of implemented changes.
The outlined components of a change management process may be pursued under a separate change management program or incorporated into the top management review and action planning process. The GCSE-Food & Health protection SSQA program has an integrated approach. Change management is implicit at all steps of SSQA implementation but it is most directly integrated with the audit review, management review and cost accounting/return on investment analysis programs. These programs constitute parts of the SSQA implementation step 6 - “CARE”.

An introduction to the SSQA concept and its implementation steps are provided in this post: Adopting the GCSE-Food & Health Protection SSQA 

You may also REGISTER to receive SSQA Updates.
Posted By Felix Amiri

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

Useful Information Links for the Handling and Processing of Produce and Leafy Green Salads:

The processing of fresh produce or salads may appear to be a simple operation. However, with the potential for contamination in the open agricultural fields and the usual minimal processing prior to consumption, strict measures must be followed to ensure the safety of consumers.

If you have just started with such an operation or thinking of going into a fresh produce or salads operation, the following information may be helpful. These food safety information links relate to the handling/processing of produce, leafy green salads and some Eastern Mediterranean traditional foods: PLUS AN ALL-IMPORTANT DOSE OF COMMITMENT TO CONSUMER SAFETY

Hazard analysis and critical control point generic models for some traditional foods: a manual for the Eastern Mediterranean Region (Out of print but available online):
Website Source: World Health Organization - Regional Office for the Eastern Mediterranean (EMRO) - See page 69/70

You may provide additional suggestions or comments in the space provided below:

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

Tuesday, 10 December 2013

10 Reasons for Quality Initiatives Failure – An Understated Number

LNS Research article 10 Reasons Your Local Quality Management Initiatives are Failing [Posted by Mehul Shah on Fri, Dec 06, 2013]

Why the focus on quality management. In the food industry for instance, product safety is also of equal, if not greater concern. Tens of reasons can be cited for food safety and quality management failures. 

Although it has not gone far enough, this LNS Research article contains some overtones of what I have stressed that the food and health sectors need to seriously consider, if significant improvements are to be achieved in product safety and quality assurance. 

You may have noticed the “policing” mentality that is cited as reason 6 in this LNS article as a reason for failure. Incidentally, that is one of the main things stressed in several GCSE-FHP posts dealing with the failures of enforcement. The article also mentions internal education/training but it does not go far enough to describe the type of training that works as was described in the post on personnel training – Mercenary or MOM. The idea of “incentivizing quality improvements”, more commonly referred to as personnel, company and/or partner motivation in the GCSE-FHP language, is stressed in several posts. In fact, a whole department is assigned the responsibility under the proposed GCSE-FHP-SSQA concept as described in the post: Organizing for Product Safety and Quality Management Success

SSQA is shifting the paradigm from policing to facilitating the safety of food. While "beating operations into compliance" may seem like the right thing to do, it is often counter productive. It encourages the practice of hiding unacceptable situations from inspectors and auditors. If the same inspectors and auditors were seen as facilitators, help will be sought from them regarding issues that need to be resolved. 

Other posts that provide further details on the points mentioned in the LNS research article include the following:

-       Company Commitment

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