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Monday, 15 December 2014

The Standardized Food Industry Mistake

The Food industry seeks after harmonizing the code of practice for industry performance in food safety and quality management but appears to have gone about this the wrong way: Why are CODEX Alimentarius (Food Code) guidelines, national regulatory requirements, and proven industry practices not sufficient frame of reference for assessing industry performance?

One of the enduring mistakes in the food industry is the setting up of so-called food safety and quality management or auditing "standards" under various names against which to assess the performance or compliance of companies. These so-called standards, more appropriately described as schemes, are growing increasingly complex because of knee-jerk reactions to events occurring in the industry. With so many schemes blindly forced upon the industry by the industry, the target at which to aim was already constantly moving. Now it is moving ever so rapidly. The problem is continuing to expand with knee-jerk reaction rules that are more confusing than helpful to operators. Many of the prefabricated solutions proposed by "expert committees" have the same predictable success rate as the enterprise of fitting shapes according to colour.

The industry urgently needs to make significant changes to the current food safety and quality system auditing arrangements. The disconnect and mounting complexity of food safety and quality assurance rules and proposed solutions can be attributed to the fact that  the so-called expert committees making the rules or suggesting misfit solutions do not have direct accountability for the implementation success. Scheme owners appear to simply wish to out-do each other in an almost juvenile "mine is better than yours" competition. All the while, each scheme owner's goal is market expansion for greater profit instead of greater effectiveness in the assurance of safe food.

The complexity of rules will continue  to be untamed for as long as the rule makers are not duty-bound to show measurable results that demonstrate success in achieving the primary purpose of the rules. 

Complex and almost impossible rules are easily and readily imposed by individuals who do not bear any burden (effort, time, cost, and other consequences) for keeping them. With little to no room allowed for innovative thinking, some of the rules actually stifle the creativity of system managers who could otherwise solve many food safety challenges more efficiently and effectively. 
Just because they are able to catch some rain drops in their hands, unsuspecting and obedient food safety system managers are being led to believe that they are stopping the rain of food safety and quality failure incidents by simply obeying commercialized certification rules. These rules, many of which are redundant, force food safety system managers to stand in the rain and hold up their hands. 

Voluntary Yet Mandatory Subscription:

Although a company or its customers may choose the scheme to follow, subscribing to a scheme has become a mandatory requirement for doing business at some levels. The schemes are also beginning to include clauses that force a wider subscription. For example, some schemes have included requirements for a subscriber to accept scheme certificates from its suppliers as evidence of satisfying certain aspects of the required programs. These suppliers are essentially forced to subscribe to the same schemes or run the risk of losing business. The forced subscription further drives the superficial (cat and mouse game) compliance tendencies among reluctant operations that simply want to obtain certificates in order to gain more business. With many untested assumptions about the successful implementation of the schemes, some operations quickly become entrenched and somewhat enslaved to initially selected schemes. The schemes tend to stress the need for subscribers to match their exact formats in setting up their systems otherwise they cannot expect to do well in audits conducted against the schemes. Thus, due to the time constraint and the cost of switching from one exact format to another, subscribers are systematically discouraged from switching schemes. The subscribers are essentially forced to stay with the initially selected schemes. How voluntary then is the "voluntary subscription"? Beyond that, a form of mental enslavement is taking place that keeps companies obedient to the commercialized certification rules while holding to a sense of freedom that is more mental than real.

The enslaving schemes have several things in common. If the profit-driven intentions are set aside, the schemes could easily be replaced by fewer non-commercialized options. Their number could be greatly reduced where attention is given to what they have in common. The common grounds include the presupposed (often pretentious) intention of enabling food businesses or establishments to ensure the safety of food. The schemes have more than food safety assurance pretenses in common:

Common Foundations:
The schemes generally look at the same things. They have differentiating formats that frustrate any attempts by subscribers to switch from one scheme to another but the format does not contribute anything that makes one scheme better than others in the delivered effectiveness. In that sense, the schemes are the same. This begs the question of why the industry needs so many versions of the same thing. Current assessment schemes are essentially pre-set requirements about what a company needs to do and have in order to ensure product safety and quality. The main considerations, with only minor variations in the individual schemes, typically include some requirements about management policies and operation control procedures. The bulk of the requirements dealing with general controls as well as the Hazard Analysis and Critical Control Point (HACCP) system follow the guidelines provided by the Codex Alimentarius (Food Code) Commission. This commission was established in 1963 by the World Health Organization and the Food and Agriculture Organization of the United Nations to develop international food standards to protect consumer health and to facilitate fair food trading practices. 

Common Faults:
Common to all of the schemes are readily identifiable faults: The first fault is the excessive commercialization and competition among the schemes. With the established requirements that are essentially the same, it is inevitable for some of the scheme owners to resort to competitive tactics that undercut other schemes. The net casualty is of course the consumers. Audited companies actually stand to gain from the competition among schemes. This competition is a fault in itself since the audited companies are supposed to be subjected to strict scrutiny. Competition among those who are responsible for the strict scrutiny weakens their resolve to be strict.

A second fault is the financial burden and compensation arrangement that sees the companies audited paying for the audits. Even with the proclaimed absence of conflict of interest and its intended enforcement among auditors, the hidden agendas are not so deeply hidden. Astute observers are able to see right through the fa├žade and many of them have expressed their opinions in published observations.

A third fault, by virtue of the audit scores associated with the schemes, is their tendency to create an atmosphere that encourages cat and mouse or hide and seek games where auditors play the detectives who must find what system managers may be hiding to get higher scores. 

A fourth fault is the superficiality of conclusions reached and the certifications granted following audits conducted against the schemes. To curb runaway costs, audits under the schemes must essentially be time limited. They are therefore snap shot audits. As noted in the “Aftermath of the Killer Cantaloupe Devastation” post:

“Snap shot audits are sampling-based. Due to cost considerations, these audits only provide a short duration or window of opportunity to assess and observe the operations. Other factors affecting the reliability of the audits include auditor knowledge and experience, competition for business among certifying bodies, the suitability of the auditing guideline, etc. As a result of these limiting factors, third party audits cannot be and should not be relied upon to provide food safety guarantees. Third Party audits serve a different purpose.”

The Attribution of "almighty" Powers to the "Certificate"

The certificates issued following snap shot audits end up certifying no more than the time the audit was conducted. Even the usual auditor disclaimer acknowledges this fact. Consequently, the issued food safety certificates only stand to say the requirements of the scheme used were met, and only at the time of the audit. The certificates do not automatically attest that the products from the audited businesses are safe and meet the expected quality standards. In that sense, certificates are like fanciful adornments that do not necessarily reflect the character of the wearer. On the other hand, the systems for obtaining these certificates are sometimes involuntary, painful and restrictive with no lasting reformation of character where the wearers are hardened in non-compliant ways. Mind you, companies may mean well but the employees may not all be on board regarding compliance.
The legitimacy of certification in any industry is lost if operators that provide safe products are forced out of business due to the economic pressures of not being able to afford the costs of meeting imposed generic rules that govern food safety certification or regulation while operators that can afford the costs, but produce unsafe products are honoured and permitted to continue in business, riding on superficial certificates.

Common Failure:
As far as I know, and I am willing to be otherwise convinced, no scheme has presented data to demonstrate its effectiveness in achieving the goal of safer food. Several objectives can be shown to have been achieved by the schemes such as increasing the popularity of the schemes; getting many companies to enlist; enforcing system documentation and record keeping as evidence of "compliance" or "due diligence"; increasing the number of certificates issued; increasing the scheme owners' revenue growth; etc. However, the quantified degree to which the intended goal of safer food has been achieved and the scope of that achievement remain elusive. I call this the common failure to demonstrate the achievement of the intended goal. 

The Misunderstanding Leading to the Mistake:
Many certificates are issued after a review of what a company does and was doing during the certification audit. Very little attention is given to the consumer experience resulting from what is done by the audited company. In other words, the “who”, “what”, “how” and “when” are assessed but not the “outcomes”.

Since auditors wish to come in, do their jobs quickly and get out, the clamour in the food safety and quality assessment industry is for "AUDITABLE" food safety and quality management systems on paper. This has led to the creation of paper-based and "auditable" but ineffective systems.

How to do things may be standardized on paper but it is not the standard for measuring what is done. The actual results obtained constitute the standard against which what is done is measured to determine its validity and effectiveness. 

The goal, and therefore the results must be relevant, correct and linked to the ultimate purpose of what is done.  For example, well organized documentation, good plant floor behaviour during an audit and the existence of completed records are not the ultimate purpose and therefore not the goals of a product safety and quality management program or audit scheme. It may surprise you to know that many companies, managers, industry consultants and trainers misunderstand these to be the goals. Hence the widespread promotion of “what to do to pass third party audits”. The typical advise on “passing” third party audits have very little to do with the real-life experiences of those who use or consume the products.

Long, confusing, stressful, fast-spinning but fruitless certification trek:
In the commercially competitive market for "food standards" (I have always maintained that these are schemes; not standards), the harmonization of food standards may be a challenge for a long time. I do not see why it should be because the industry already has such a standard or standards - HACCP and CODEX Guidelines. The "audit standards" industry, due to an overpowering commercial interest, is only refusing to fully acknowledge and adopt what already exists, and stop selling and imposing their suggestions as "standards". The industry is opting instead to create, sell and impose variously named schemes as "standards" even though they are not able to create these "standards" without falling back to what already exists - HACCP and CODEX Guidelines. With new versions of schemes that are continuing to be released because of the underlying fruitlessness, the long, confusing, stressful and essentially distracting trek continues. The industry may wake up to this fact some day and be done with the enchantment as well as the cat-and-mouse games. 

If you find yourself on the spinning wheel because of demands from outside parties, you need to get off and rise above the illusion. Progress is not made simply because the wheel is spinning faster.

Thank You for Reading
If you are taking the time to read this, I have cause to believe that your company is on track towards becoming a shining example of how things ought to be done. Unfortunately, you have to deal with the interference of mandated systems that appear to be necessary but poorly setup, incorrectly focused and improperly administered by the industry. I anticipate marked changes to the way things are currently done as more and more companies suffer regrettable consequences because of undue dependence on things that offer only a false sense of security. Getting off the treadmill is possible. Hopefully your business does not have to be knocked off by a terrible incident.

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

1 comment:

  1. Another problem not mentioned is the fact that the many binders of paperwork seen in the average plant. Often contain sheets with incomplete data, unreadable penmanship, or missing pages. I often talk to people in the plant that tell me this is the situation. Food safety and traceability are too important and the cost of man hours are too high for plants to keep doing it the old way.