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Tuesday, 29 November 2016

Examining Food Safety Certification Promises

A part of this was initially posted as a response to an update published elsewhere. I withdrew that post because I learned from an ensuing conversation that my intentions might have been misunderstood. The intention was and still is completely to help with the articulation of the promises made regarding food safety certification programs. My comments are to be seen as cautionary suggestions, rather than accusations since there are no specifically named parties to accuse. These comments only suggest a close examination of promises made in connection with food safety certifications.

Only Promise What You Can Deliver: 
For anyone promising to certify anything, I suggest as follows:  If you cannot completely (i.e. 100%) stand by, and/or stake your reputation on, what you certify 100% of the time, do not certify. Remember that where such certification relates to what can cause harm to another person, there are legal liability implications for the party granting the certification. If you run a certifying body, this question must be truthfully answered: If you are held legally liable for what you certify, will you still certify it? On what basis will you continue to certify whatever it is? There  are also the aspects of moral obligation and social responsibility to consider. It is fraudulent (although it may be legally acceptable) to grant certification and cleverly, immediately and effectively withdraw the certification in a fine print disclaimer. A genuine sense of moral obligation and social responsibility precludes such disclaimers. It is safer to truthfully, correctly and clearly state and stand by what is actually done.

If such certification promises are made to you, it is advisable for you to check and confirm your understanding of what is promised, and that what is promised is actually delivered. Of course, you must first establish that what is promised is what you need. 
All food businesses must think beyond acronyms, platitudes and the pursuit of empty promises.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Monday, 28 November 2016

CFIA Suspension or Cancellation of Operating Licences and Registrations

Licences and registrations of federally registered establishments or companies can be suspended, cancelled or refused renewal for failure to comply with relevant CFIA Acts and Regulations
View the list of suspensions and cancellations published by 
the Canadian Food Inspection Agency (CFIA)

Saturday, 26 November 2016

Real Food Safety Solutions – The Emerging Wave of Change

The food industry may be waking up to an emerging wave of change. The call for this change has long been made as part of the GCSE-Food and Health Protection campaign. If you have not been following the posts, take a look at this 2013 post about the coming shiftSome of the things predicted are already happening.

In the 2016 announcement about the acquisition of BRC Global Standards by LGC, Mark Proctor, BRC Chief Executive Officer stated as follows:
“I wanted to personally let you know that BRC Global Standards is in the midst of an exciting strategic transition from being a Standards owner to a brand and consumer protection organisation with a range of products and services to help its customers deal with the challenges of producing safe, high quality products for the end consumer on a global basis.” -
It is about time. Perhaps now BRC, under the LGC ownership, would just admit the certification hoax and get out of that business altogether. The same hope is held for other parties that are still blindly captivated by the superficial certification idea.

For a few years now I have been calling on the industry (particularly the third-party certification sector) to stop the “certification” hoax. In its place, I have suggested the provision of real solutions to food businesses. I wonder if LGC and BRC have been listening and this has led them to this announcement of a strategic transition from being a Standards owner to a brand and consumer protection organisation”.

The desire to move away from superficial certification of food safety and quality management systems appears to be growing. Evidence of this desire can be seen in the reported new regulatory direction proposed by the EU in its Food and Feed Safety (30-08-2016) News Report and the UK-FSA's Regulating Our Future: Why food regulation needs to change andhow we are going to do it” that was published July 2017
,the SQFI Recalls data reporting attempt that covered from 2013 to 2015 (although it is a failed attempt at reporting on the effectiveness of the SQF program), and the announcement about BRC transition under LGC ownership.
These pronouncements and attempts are encouraging but the war is not won. The recognition is spreading but the transition is slow and appears to be momentarily stuck in the mud. Amidst loud superficial claims of success that mask the reality-check of whether food has actually become safer, the certification enclave is continuing to enslave many players unnecessarily. Many have failed to realize this fact: A business that cannot do without certification does not have the wherewithal to be certified.

The GCSE-FHP campaign against superficiality, misdirected focus, wasted resources and failing efforts at ensuring the safety of food must continue. To beat the plague of superficiality and wasted efforts, the adoption of the SSQA concept will continue to be highly recommended. All parties involved in the assurance of food/consumer safety need to drop the “certification” idea and focus on SSQA-style FORTIFICATION.

Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Saturday, 12 November 2016

Food Safety Training: The Cost of Not Knowing

I have seen it and it is painful to watch. Due to not knowing enough about these things, many people have, and continue to fall for rampant food safety training fraud. 

Many so-called training providers are out there poised to take advantage of desperate and unsuspecting people who are seeking to know more about managing food safety. Individuals and some companies are made to pay outrageous amounts of money for training that offer nothing more than opportunities for the trainers to spew industry jargon. Those "trained" who may not have been previously exposed to the jargon may be impressed. They may learn and speak the same jargon. They may take a few distracting proposals from these training activities back to their operations for implementation. Meanwhile, no real progress is achieved in assuring the safety of food in their operations any more than they were able to achieve prior to the training sessions. 
Here are some typical rates that are charged for short-duration training courses that offer nothing more than the regurgitation of information that is available at not cost:
Basic HACCP 
Special Claim Certification Training (for Organic, Gluten-Free and Similar Programs)
GFSI Certification Schemes training
FSMA-Preventive Controls for Human Food

The prices charged by some training providers may even be higher. What have you been asked or temped to pay?
Did you know that the information provided by some training outfits can be obtained at no cost? Why should the trainers obtain the information at no cost and then make you pay for it? On the other hand, why should you pay for information that you are able to obtain for free from the rightful owners and providers? Prudence demands a thorough search for available (good) information that is either free or cost very little. If you wish to learn more about sources of good training information that cost little or nothing, you could start your search with the sources provided by CODEX Alimentarius Do not buy into fake training. You should understand the essential elements of real and effective training and proceed accordingly.

Essential Elements of Good Training

Real training must go far beyond lecture hall or on-line presentations. For all practical purposes, the best site for staff training and motivation is your operation site. Real training, to be effective, must be fully practical and realistic. It needs to deal with situations that are real to your operation; not the fictitious anecdotes of pre-packaged training. Effective training requires time investment, rolling up of sleeves as it were, getting in the front lines to understand the real and specific needs of your operation, and designing the training that is relevant. Real training involves continuous culture development and changing of wrong beliefs. Clearly, real training cannot be accomplished in a matter of hours or a few days. Real and effective training requires consistent commitment; not sporadic lectures on a sporadic array of topics from sporadic people who are essentially strangers to the realities that are unique to your operation. Some advertised training activities and the prices charged constitute a form of the food industry fraud. 

You need to look past fanciful advertisements with nicely coined jargon that essentially lack substance. You need to very carefully examine what is offered and measure it against the real needs of your operation. If the information promised in the advertised training activity can be obtained at little or no cost from the rightful source, you should obtain that information from that source. Then you should design and implement your training for effectiveness rather than for show. Don't let the purveyors of quick, drive-by and superficial training sessions that are often overloaded with fanciful industry jargon keep your operation on training wheels for ever.

You could seek outside help in designing and implementing the training that uniquely suits your operation but do not pay for any off-the-shelf training that is excessively priced and does no more than rob you of your money and your time. For the individual, the best place to seek training or self-education beyond the initial job entry qualification (typically obtained through formal education) is in and at the job. By implication, food businesses should be providing training in and at the job for their employees. Certain professional certifications may be obtained by individuals from reputable organizations like American Society for Quality and food safety and quality management scheme owners.

Help may be sought from an invested outside party to design and implement training that must become organic (i.e. kept alive and on-going). The "an Invested" is underlined and in bold letters for a reason. Drive-thru training, on-line training or training through the airwaves by people who have vested interest only in the fees paid to them; but not in your operation is mostly ineffective.

. . .now you know & you can take the helm.

You may have questions or suggestions about other available learning opportunities that cost little to nothing. Please feel free to contact me or post your comments below.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.