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Friday, 25 March 2016
Further to the blog post - The Merits and Pitfalls of Engineered Focus in Product Safety Assurance
This blog post has been moved to the author's eBook. Check it out here:
Wednesday, 16 March 2016
Tuesday, 15 March 2016
Subduing the Attitude of Surrender in the War against Food Fraud
This blog post has been moved to the author's eBook. Check it out here:
Posted by Felix Amiri
___________________________________________________________
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.
Wednesday, 9 March 2016
GFSC 2016 Beyond the Fancy Talk: What exactly is GFSI contributing “Towards a world in which safe food is truly accessible to all”?
This blog post has been moved to the author's eBook.
Posted by Felix Amiri
___________________________________________________________
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.
Tuesday, 1 March 2016
CODEX: International Guidelines for Monitoring the Performance of National Food Control Systems
CODEX
is continuing to pursue initiatives with the Committee on Food Import and Export Inspection and Certification Systems (CCFICS) and the Guidance for Monitoring the Performance of National Food Control Systems(NFCS)
What
do or should these CODEX initiatives mean for international food trade? What
should these initiatives mean for local and international food businesses?
Benefits
to Participating Countries
The U.S. is a key contributor to the CODEX National Food Control Systems (NFCS) initiative, yet FDA appears to be ignoring it in the Foreign Supplier Verification Programs (FSVP) under FSMA - http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm361902.htm. Little is said about NFCS in the proposed FSVP rule if it has even been mentioned or considered.
The U.S. is a key contributor to the CODEX National Food Control Systems (NFCS) initiative, yet FDA appears to be ignoring it in the Foreign Supplier Verification Programs (FSVP) under FSMA - http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm361902.htm. Little is said about NFCS in the proposed FSVP rule if it has even been mentioned or considered.
In the
Globe and Mail report of Mar. 01, 2016, the U.S Agriculture Department gave the Canadian Food Inspection Agency
until mid-March to fix significant food safety and sanitation concerns found
during an audit of Canada’s meat, poultry and egg inspection systems.
In a news release as far back as November 20, 2014, Canada was
said to rank first out of 17 countries (including the U.S.) on food safety
performance. So which observation is correct, or what has gone wrong?
With
a common frame of reference that CODEX will be able to provide for assessing
the acceptability of food shipments among countries, one can immediately see
the value of the CODEX Guidelines for Monitoring the Performance of National
Food Control Systems. Even in the example of the spat between the U.S and Canada,
the usefulness can be seen. The U.S. and Canada are identified as participants
in the CODEX initiatives. The benefits will predictably spill over to local and
international food businesses within the participating countries.
Re-direction of Focus and Elimination
of Wasted Resources for Food Businesses
While the kinds of wrangling between
nations as reported between the U.S. and Canada take place, food businesses
that cannot avoid being caught in the crossfire remain buried in the redundancy
of private certification schemes. Clearly, food companies need to wake up and
smell the coffee. The real battles are being fought on fronts where private
certification schemes have little if any effect beyond forced and fictitious
claims.
The truth cannot be more clearly
exposed. Private certification schemes do not carry the force of law nor do
they currently serve any arbitrator role in resolving cross-border trade wrangling
as exemplified in the Canada-U.S. example. In fact, the respective country’s regulations
rightly grant only a limited credence or acceptability to private certification
schemes as presented in the FDA FSMA comments on GFSI and the CFIA policy on private certification.
Where it really matters, private
certification schemes also do not seem to have any quantifiable and verifiable results
that show any significant reduction of product failures. They certainly do not
provide litigation reprieve when illness is the onlyproof required.
The argument about the acceptability
of private certification schemes as the savior of international trade is
getting further weakened as CODEX pursues its initiatives with the CCFICS and the NFCS. Empty claims
are frequently made about the superiority of private certification. In reality,
the certification process distracts and places the burden of wasted resources
on food businesses due to the unnecessary duplication of requirements already
imposed by regulations. This reality belies any assumptive conclusions about
the synergy that exists between regulations and private certification schemes.
It has been reported that private
certification will grow to $19 billion plus by 2019. This makes it very
attractive to prospectors who would almost defend the merits of certification with
their lives. Given the demonstrated redundancy of certificates, one can easily
see the gains to be made if the $19 billion were to be used for fortification
programs instead of certification schemes.
Conclusion:
A common ground for monitoring the performance of national food
control systems provided by CODEX, a body that is internationally recognized,
and with the direct participation of the nations involved is much needed. It
should prevent unproductive and often baseless international wrangling.
Food businesses also have much to
gain from the CODEX initiatives. They will suffer less cross-fire casualties.
Besides, the initiatives provide the opportunities for food businesses to optimize
the use of their resources in pursuing profitable regulatory and scientific solutions
instead of wasting such resources in pursuing superficial certificates. It is
not s secrete that current certification schemes merely regurgitate CODEX guidelines
anyway. They may use other sources that are also already available to food
businesses. Information from these sources are merely put together by the
schemes and used for their pre-occupation with offering no more than criticisms.
These schemes (under the guise of avoiding conflict of interest) refuse to get
involved in providing real and practical solutions.
Food businesses need to simply focus
on fortifying their food control systems according to the emerging CODEX guidelines
and the applicable national regulations. These, along with the specific
scientific and technical knowledge that applies to each operation, provide adequate
technical and management information to make private certification redundant.
Private certification is already of little to no consequence in less privileged parts of the world. Yet food comes to the more affluent part from these less privileged regions. This calls for a different mobilization in addition to the Codex CCFICS and NFCS initiatives. It is the mobilization against inequality. It is the mobilization of collaboration where more affluent nations provide financial and technical assistance to the less privileged.
Private certification is already of little to no consequence in less privileged parts of the world. Yet food comes to the more affluent part from these less privileged regions. This calls for a different mobilization in addition to the Codex CCFICS and NFCS initiatives. It is the mobilization against inequality. It is the mobilization of collaboration where more affluent nations provide financial and technical assistance to the less privileged.
Posted by Felix Amiri
___________________________________________________________
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.
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