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Tuesday, 11 October 2016

Sensible EU Proposal

In contrast to the generic and highly commercialized 3rd party certification vogue, this EU proposal makes a lot of sense. It is a very good example of cutting nonsense out of the business of assuring the safety of food:

Here is why:
·        It defines the frame of reference as safe food:
These requirements are the key elements to ensure the safe production of food, preventing contamination with biological, chemical or physical hazards . . .”

·        It recognizes the need to customize solutions according to each establishment:
“. . . taking into account the size and nature of the establishment on: . . . the flexibility provided for certain food establishments, in particular SMEs, by EU legislation related to the implementation of PRPs and HACCP).”

·        It identified sensible administrative levels:
at sectorial and national level to be directly applicable in specific establishments.”
Compared to the generic impositions of 3rd party certification programs with requirements that are often irrelevant to specific establishments, this approach is clearly more cost effective. It also promises better results with respect to the production of safe food.

The U.K. Food Standards Agency (FSA) is following suit with a “. . . move away from a‘one-size-fits-all’ approach to regulation”. The Agency states:

"Our purpose is to make sure that people have safe food, food they can trust, and that it is what it says it is. We need to change the way food is regulated in England, Wales and Northern Ireland, so we can be confident this stays the case for the food people buy and eat.”

This FSA statement, as does the EU Proposal identifies the same "safe food” purpose that GCSE-Food & Health Protection (GCSE-FHP) advocates. The FSA statement also recognizes the same things that have been identified as failure-prone food safety regulation and certification arrangements in several GCSE-FHP postings. In particular, consideration 18 of “the motion” essentially calls for what is now being attempted with the EU and the U.K. FSA proposals. Hopefully, these proposals will be developed to full adoption not only by the U.K. and EU, but by other jurisdictions around the world.

Along the same lines, the idea of generic food safety certification schemes need to give way to practical, customized and collaborative pursuit of solutions by and for the food establishments worldwide. Superficial food safety certification, though with flamboyant promotions, have produced much less than stellar results of safe food. Published results from the adoption of the certification schemes mostly show virtual success. Meanwhile, the reality everywhere is that of recurring recalls by many food establishments (including certified establishments) and many health hazards suffered by consumers.

The U.K. FSA is proposing ". . . a model that continues to use inspections and visits alongside the information . . .” gained . . . “from business’s data and accredited third party audits. . .”. For at least three reasons, I would change “accredited third party audits” to “credible audits conducted by any party (including the internal audits of the establishment)”. 1. A third party is not necessarily credible because it is accredited. 2. Third party audits often involve additional costs to establishments that may not be necessary. 3. The thought of having third party audits is usually due to lack of trust. If the U.K. FSA proposal is to truly succeed, it must be pursued in an environment of full collaboration and trust among all parties involved.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

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