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Friday, 28 November 2014

Food Fraud: The Date Change Kind

The National
THE NATIONAL | Nov 26, 2014

Stores caught cheating on best before dates

Hidden cameras reveal that packaged meat may be older than the labels suggest

We have other kinds of fraud that have not made the news like these reported findings: Read more on Systemic Fraud

Wednesday, 26 November 2014

After We Have Come this Far in Food Safety and Quality Management:

Some GCSE- Food & Health Protection blog posts are generating interests, questions and, in some instances, a reported “uneasiness”. Instead of “uneasiness”, I choose to describe what should be felt as challenges and encouragement. Uneasiness is felt only where a threat is perceived. There is no need for that. GCSE-FHP does not pose a threat. It seeks collaboration within the industry. You are invited to join the conversation.

You Have an Important Part in the Matter:

It will take companies and individuals who are determined to see real and measurable progress to dismantle barricades that purport to help but, in effect, hinder progress. Positive progress is invariably disrupted, if not altogether stopped, where ineffective complex systems are favored over simple effective alternatives. Entire industries, in fact entire civilizations, can be drawn into unnecessary enslavement and the punishing consequences of regression where unnecessary enterprises are not only permitted but also promoted as in the Aral Sea disaster

A Possible Consequence of Over-complicating Food Safety and Quality Assurance:

Regression inevitably occurs where companies are intimidated because of over-complicated food safety and quality management systems. As pointed out in the blog post “Demystifying Food Safety Assurance”, true mysteries pertain to realities more profound than the task of assuring the safety of food.

Complicated and Exasperating Food Safety and Quality Assurance Schemes:

Some companies and system managers who are forced into subscribing to certain complex but ineffective schemes know the facts about the ineffectiveness. These managers or companies may be backed into a corner and they play along but they are not fooled. They regularly do Reality Checks and will escape at the first opportunity.

A “Helpful Scheme Grading Scale” is provided in the "Common Assumptions" post. Check the grading scale and see how your current scheme measures up. You may also wish to review the evaluation chart for assessing the most suitable, helpful and neutral third party in food safety assessment.

Dangerous Misconceptions:

Debilitating Misconceptions should not be allowed to overtake the food industry. Some very small to very large operations have been conditioned to believe that it is almost criminal to ever skip one or more years in their certification programs even if they are maintaining strict and expanded control measures like the Cherry Processor is opting to do.

Measuring the Success of Food Safety and Quality Assurance Programs:

Have you measured or do you measure how much your company spends on redundant external impositions and reactive firefighting versus proactive continuous improvement activities? You need to measure against real goals. You should not simply imagine your product safety and quality management success based on fanciful documentation, accessibility of documents and a readiness to provide answers that auditors want to hear during audits. You need to quantify the success against the real goal in real terms with genuine and relevant data: A Simple Cost of Quality Calculation Chart.
Superficiality may carry a company only so far in its quest for business growth because business growth also means an inevitable increase in the opportunities for failure. Where there is real growth, the pressure also mounts for products to be actually safe and maintain good quality - "Breaking the Addiction to Superficiality

Adding Your Voice & Support:

Please feel free to share comments, questions and suggestions with this group. Someone learns something from every contribution: Join the Conversation. 
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate. 

Saturday, 22 November 2014

Food Safety in Search of the Most Suitable and Neutral Third Party

Organizations or groups involved in corroborative assessment of food safety, but do not engage directly in the production, processing or sales of food products are often referred to as third parties. This reference is most predominantly used in connection with audits conducted to verify the effectiveness of food safety, quality system and regulatory compliance. Third parties are also involved in other aspects that contribute to the assurance of food safety by providing, associated functions. These include laboratory and pest control services, scientific information sources, operation guidelines development, consulting services, education, training, et cetera.

Parties involved in the production, processing or sales of food products are typically described as first or second parties. In order to avoid biases due to the obvious commercial interests, members of this group are often precluded from providing corroborating evidence about the strength or effectiveness of the food safety programs implemented by other members of this group. Customers may assess suppliers directly and many do. However, such assessments tend to become excessively burdensome to suppliers with many customers. Hence the presumed need for third-party audits that are acceptable to all customers. Reported experiences and practices often prove otherwise. 

The need for third parties to provide any desired corroborating evidence is generally considered to be essential for business transactions within the food industry. Third parties occupy a supposedly neutral position from which to advise the major commercial players - major retailers and consumers. This, the industry feels, removes biases that may interfere with the integrity of the evidence provided. Through the process of audits typically conducted at the facilities of suppliers, the third parties are thought to be in a better (non-biased) position to advise the suppliers, customers and consumers about the integrity, completeness, consistency and effectiveness of the food safety and quality assurance programs implemented throughout the supply chain. Some, if not most, of the third-party assessment setups currently on the market involve as follows:
  • Third-party auditors or assessors are paid by the companies that they audit.
  • Although they may provide advice in general terms that often end up confusing the people advised, third-party auditors or assessors do not provide specific help because that may be viewed as conflict-of-interest consulting services.
  • The audited parties are expected to already know and are often viewed as being already capable of implementing what is assessed. Essentially, the audited parties pay third-party auditors to tell them (the audited parties) what they already know and/or show them what they can already implement (and must implement) on their own.
  • Third-party auditors or assessors do not offer any guarantees because it remains the responsibility of each audited party to know and implement effective food safety measures that are applicable to its operation.
Some commentators have expressed concerns about some of the things involved in the typical setups: Observations about Third Party Audits. Some of these commentators may like to see the involvement of only suitable and neutral third parties taking up the role of providing unbiased evaluation and certification of suppliers. But which groups qualify?

A Qualification Scorecard for some of the Major Third-Party Groups

Among the groups that could qualify as third parties, we have:
  1. The World Health Organization
  2. The World Trade Organization
  3. The International Accreditation Forum
  4. Global Food Safety Initiative
  5. Certification Bodies
  6. Accreditation Bodies
  7. Government Regulators
  8. Independent consultants
  9. Educational and training Institutions
  10. Operation-Related Service Providers (including Auditing Companies and Auditors)
To qualify as a suitable and neutral third party that issues certification, the group or organization is expected to have no business interest or direct gains from its interaction with the first and second parties within the industry. Preferably, the most suitable and neutral third party would have a humanitarian commitment with no commercial (i.e. profit-making) or favour-seeking interest. If an organization or group receives fees from, sells anything to, or supports paid membership of companies or businesses belonging to the first and second group, that organization technically no longer qualifies as a neutral third party certification body. The truly neutral party with respect to food safety and quality certification or accreditation should have no check mark under any of the columns to the right of the column that indicates its certifying or accreditation role (i.e. no check mark under fees, sales or paid membership).

Name the Most Suitable and Neutral Third Party:
From this list, which group is (or groups are) most suitable to issue food safety certification to individual companies as far as you are able to tell? You may download the MS Word version of the chart below.

Has Humanitarian Commitment
Has FSQS Certification/
Accreditation Role
Paid Membership
The World Health Organization (WHO)
The World Trade Organization (WTO)
The International Accreditation Forum (IAF)
Accreditation Bodies

Global Food Safety Initiative (GFSI)
FSQS/GFSI Scheme Owners
Certification Bodies
Private Auditing Companies and Auditors
Government Regulators
Independent Consultants
Educational and training Institutions
Operation-Related Service Providers (laboratories and other contracted services)
OTHER(s) [Describe in the rows below]:
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Friday, 21 November 2014

If Canada's Food Safety System Ranked World's Best . . .

With the claim made in the above press release that Canada's food safety system ranked world's best, the following questions immediately come to mind:
  • Why are so many food recalls still reported in Canada?
  • Does Canada have fewer reported recalls than the other countries to which it was compared (Australia, Austria, Belgium, Denmark, Finland, France, Germany, Ireland, Italy, Japan, Netherlands, Norway, Sweden, Switzerland, United Kingdom, and the United States of America)?
  • What exactly is the measure of a "world's best food safety system” in lieu of the goal of food safety management system?
  • Is how well food safety failures are assessed, managed and communicated an acceptable and sufficient indicator of success?
The boasting about Canada’s food safety system appears to be based on the examination of the wrong criteria. Even if interviewed Canadian consumers expressed confidence in the strength of Canada's food system (should this be the claim by Minister of Health Rona Ambrose), such expressions of confidence can be misleading. Interviewed consumers may not have considered the full scope of health problems that are linked to food while responding to the questions about how much confidence they have in the Canadian food safety system. They may not even be aware of how many food-related problems affect them directly. For example, how many stomach upsets they have suffered in a given period, whether they have one of many chronic conditions caused by food such as obesity, diabetes, heart problems, etc.
The most appropriate measure of a successful food safety assurance system is the actual absence of food-related health problems. Any legitimate claim about food safety success must include real data to support at least a clear, consistent and continuing reduction in food-related health problems. Anything else constitutes an attempt to deceive.
Posted By Felix Amiri
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

Saturday, 8 November 2014

Food Poisoning and the Economy – “Upset stomachs cost UK 11 million working days”

What part does our food-related health play in the national and global economy? How many people call in sick and stay home from work each day because of food poisoning in your country and worldwide?

Estimation of the global burden of foodborne diseases – final report to be released in 2015

All cases of food poisoning are not reported because the symptoms are often not recognized as food poisoning. Also many people simply weather the storm and carry on with life except where the individuals belong to the vulnerable population and further complications or even death may occur. Next time you feel queasy, you may want to check two things: 1) If there was any unhygienic behavior and 2) What or where you ate prior. 

Regarding the food you eat, be sure  to avoid anything suspicious. Doing so will be good for you and the economy. In fact, the good is for all of us since the economy and related taxation implications affect all of us in small bites perhaps but certainly.

With food poisoning, not going to work hurts the economy but going to work hurts the economy even more where the causative agent can be spread to other workers. Going to work provides the opportunity for more people to spread the agent and the punishment. Products may also end up being recalled to increase the food cost burden for all of us. In some instances, going to work while ill could also mean no more work for you thereafter. The scope of the burden is endless. Although we may be able to absorb these costs, something is always lost with every instance of food poisoning. The only solution is to ensure that effective control measures that prevent food poisoning are consistently enforced throughout the chain, from production to consumption.

In more ways than one, we are all punished to some degree by the fall out from  Indifference towards food safety control measures. 

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

Wednesday, 5 November 2014

A Look at One Argument Supporting Unannounced Audits

Should food companies be forced to comply with regulations or standards through unannounced audits or inspections? If so, when should food businesses feel the most enforcement pressure?
  • Long before the audits or inspection
  • Right before the audits or inspections
  • Right after the audits or inspections
  • Long after the audits or inspections  
  • Never feel pressure
  • Always feel pressure
How many unannounced audits does it take to build sufficient trust in the party audited?
Other posts that may be of interest to you:

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

Tuesday, 4 November 2014

Equal Offenses

As a food industry professional, are you sometimes driven to the point of exasperation as you interact with other professionals who should know better but fail to demonstrate adequate knowledge or concern about essential food safety considerations and measures? I am not talking about professionals who are starting out in their careers. The inexperience of young professional is understandable because we all start out with such inexperience. I am talking about individuals who have been in the industry for very long and claim to be knowledgeable. Lately I am finding myself almost always encountering this sort of thing but I realize that, as professionals, we have to be patient with each other. Both causing and showing exasperation are equal offenses. For the sake of achieving real progress in the industry, we need to be open to learn from and educate each other. 
The saying is true in more ways than can be imagined: "A little knowledge is dangerous."

Do you have additional advice for fellow professionals?
Posted By Felix Amiri
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection 

Sunday, 2 November 2014

The Cherry Processor and the Ice Cream Topping Manufacturer:

It's not even a contest between David and Goliath when Goliath has abandoned commonsense:

What if you tried something different like this cherry processor with no certification costs, no certification stress, no customer loss but operation fortification and improvements are achieved? What if this something else was SSQA implementation?  What if the SSQA implementation imposes no certification pressures but provides product safety and quality fortification strategies that go beyond snap shot audits. What if SSQA exceeds certification schemes and your expectations in its scope, effectiveness, efficiency and practical reality? What if you could easily go back to what you were doing with certification as the cherry processor in this narrative was prepared to do without losing anything? (Warning: the desire to go back to the unnecessary stress and costs  is likely to die a natural death once you have tried the SSQA way). Take a quick look at things you may be missing without the SSQA Manual. 

The Reality-Based Narrative:

A small frozen cherry processor supplies to a manufacturer of toppings for ice cream and other desserts. The topping manufacturer has an extraneous matter specification of “less than 2 quarter inch pieces of stem and/or pit in a single 20 LB pail of frozen cherries. The Cherry Processor has completed its food safety and quality assurance program development to the point of going for external certification audit at the GFSI level. 

During the past 12 months, the topping manufacturer recorded five instances of more than 5 cherry stems and/or pits found in single pails of frozen cherries. These instances were reported to the supplier through a supplier non-conformance incident tracking procedure implemented by the topping manufacturer.

In response to the observed instances of non-conformance, the cherry manufacturer added more line inspectors to the cleaned and pitted fresh cherry inspection stations. There had been two inspectors but the number increased to five before the last two instances of more than 5 cherry stems and/or pits in separate pails of frozen cherries. Meanwhile, the cherry processor is proceeding with a third party food safety and quality system certification process. From this account, should these five instances of non-compliance to the supplier’s specification prevent the cherry processor from receiving a third party audit certification?

The cherry processor has also investigated the possibility of installing an automated cherry processing system with better capabilities of removing stems and pits. It will have to borrow the money for acquiring this system with a borrowing cost that is just a little more than the cost of the anticipated annual certification audits. The processor is contemplating stopping the certification process for a while (the next 3 years) in favor of the automated cherry processing system. Is this a good move? 

If the cherry processor goes ahead with stopping the certification process, acquires the automated system, and is successful in eliminating the observed non-conformance, should the topping manufacturer, in spite of the quality improvement success, drop this processor as a supplier because it stopped the third party certification process for more than 1 year?

Suppose the topping manufacturer allows the 3-year certification hiatus and encounters no further food safety or quality issues originating from the cherry processor, should the topping manufacturer stop buying from this processor after the 3 years are past and the processor still does not have a third party audit certificate? Suppose the unit price of the supplied frozen cherries are increased to absorb the expected annual cost of the third party audit and certification, should the topping manufacturer pay the increased price and continue to push for the certification?

Upon appropriate investigation, the frozen cherries processor finds that installing a blast freezer improves the integrity of the frozen cherries and, therefore, the quality of the manufactured ice cream topping by the topping manufacturer. Installing the blast freezer again means the possible cessation of the third party audit and certification process for a while to manage costs. With no food safety or quality issues encountered and now the improved quality but no third party certificate, should the topping manufacturer go to other suppliers until this cherry processor resumes third party certification? Suppose such a move by the topping manufacturer results in the processor not being able to afford the third party audit and certification process, would you say the move is prudent?
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.