Many have been taken by copy paste experts (consultants and trainers). Hopefully, you have not fallen for the many tricks of the opportunist traders that come in different shades.
I
strongly believe that once people think a bit more and decide accordingly about
what they are buying, and once they start to challenge the sellers' promises
about their proposed solutions, many "snake oil" purveyors will get
off the market.
With things like new versions of
industry audit schemes and emerging food regulations, particularly the U.S.
Food Safety Modernization Act (FSMA), the Safe Food for Canadians Act and Regulations (SFCA/R) and similar national initiatives elsewhere, you must refuse to be taken by anyone who will simply read back to you what you can already read for yourself and leave you to do all the work.
Many will come promising you a world of solutions but hand you a replica of the globe. You will have a real replica. It may even be golden but useless in terms of solving your real world problems. The proof of the pudding, they say, is . . .
Let’s take a moment to focus on the FSMA requirement for companies to have Preventive Control Qualified
Individuals (PCQIs). This tops the list of acronyms that I find infuriating. It represents
a qualification that appears to be conferred on people who merely rush through
learning about elements in the US-FSMA (Act and Regulations). One wonders about the
following:
1. How much is covered within a
week of training for such a "preventive control" qualification to be
conferred?
2. Is that amount of
training time sufficient to go through enough of the scientific hazard/risk
assessment considerations applicable to each represented operation?
3. Are actual mitigation actions
that are relevant to the varied situations and circumstances faced by the usual
pool of training recipients covered?
If you are thinking of enlisting a trainer or consultant,
here are some fraud detection tips:
First ask the trainer or consultant if they know how the
FSMA final rules relate to the USC-Title 21, the Code of Federal Regulations (CFRs) and the Federal Food, Drug and
Cosmetic Act. If they fumble in describing the relationship, do not hire them.
If they demonstrate a good
knowledge of the relationship, proceed to ask them how they are going to help
you in identifying all of the potential hazards that pertain to your operation
and products according to the categories of hazards listed in the stated
requirements below:
United States Code, 2006 Edition, Supplement 4, Title 21 - FOOD
AND DRUGS
CHAPTER 9 - FEDERAL FOOD, DRUG, AND COSMETIC ACT
SUBCHAPTER IV - FOOD
Sec. 350g - Hazard analysis and risk-based
preventive controls
The owner, operator, or
agent in charge of a facility shall, in accordance with this section, evaluate
the hazards that could affect food manufactured, processed, packed, or held by
such facility, identify and implement preventive controls to significantly
minimize or prevent the occurrence of such hazards and provide assurances that
such food is not adulterated under section 342 of this title or misbranded
under section 343(w) of this title, monitor the performance of those controls,
and maintain records of this monitoring as a matter of routine practice.
The owner, operator, or
agent in charge of a facility shall—
(1) identify and evaluate
known or reasonably foreseeable hazards that may be associated with the
facility, including—
(A) biological, chemical, physical, and
radiological hazards, natural toxins, pesticides, drug residues, decomposition,
parasites, allergens, and unapproved food and color additives; and
(B) hazards that occur naturally, or may be
unintentionally introduced; and
(2) identify and evaluate
hazards that may be intentionally introduced, including by acts of terrorism;
and
(3) develop a written
analysis of the hazards.
If the hazard analysis that they help you to conduct only involves the
listing of what has been published elsewhere without considering your unique situations,
environment, facilities, operation setup, supply sources, input materials,
other incidental materials used, operation practices (including personnel
practices and habits), processing steps, products, product delivery format,
delivery channels, destinations, customer/consumer profiles, consumer behaviour
that can be anticipated, etc., do not hire them.
Preventive Controls:
Secondly, ask them to provide an analysis of a "Preventive Control". See if they are able to accurately differentiate between "preventive controls" and "critical control points" as well as state the relationship between these. If they do not understand that "preventive controls" is the umbrella term that covers both critical control points and system control measures, do not hire them.
The
foregoing list is the minimum. It is not exhaustive, depending on your
particular operation, location, etc. Your hired trainer or consultant must
cover these plus any other considerations that can be identified in your unique
case. If they are not able to identify what applies in your operation; if their
focus is only on reading the regulations and fumbling with the interpretation,
do not hire them.
Also assess how much your prospective consultant or trainer can actually help you regarding the control of radiological hazards, etc. that are now included in the FSMA list of hazards. If they identify CCPs for controlling some of these hazards (for example a CCP for controlling radiological hazards in purchased raw materials), they may not be sufficiently knowledgeable about the relationship between preventive controls and CCPs, the proper application of CCPs, and the current global food trade practices. You should not hire them.
The food industry needs problem solvers; not opportunists. It needs practical solutions; not the snake oil variety of solutions.
Posted by Felix Amiri
___________________________________________________________
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.