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Wednesday, 8 June 2016

GCSE-FHP - Student Representatives

Weina YU,  Centennial College, Toronto, Canada 
We express our sincere thanks and congratulations to Ms. YU, our first volunteer student representative as of June 8, 2016.



Reaching Out to Students Everywhere: More student representatives are needed at other colleges or universities world-wide. You may add your name to the list.

Friday, 3 June 2016

Possible Back-Door FSMA Surprise for Canadian Food Businesses


FDA Recognizes Canada (Health Canada and CFIA) as “Having a Comparable Food Safety System to the U.S.” and Canada recognizes the U.S back.

You may read the full text of the Agreement:

What are the implications of this agreement? For example, should food companies in Canada and the U.S. rejoice or regret? Will meeting the Canadian food safety modernization requirements under the Safe Food for Canadians Act (SFCA) exempt food companies in Canada from needing to meet the U.S. Food Safety Modernization Act (FSMA)?

While the SFCA implementation regulations are still being drafted, the U.S. FSMA Compliance Dates have been published:

Will the development and enforcement of the SFCA regulations now be hastened in honour of this agreement?

For any food business that conducts interprovincial trade in Canada but is not exporting food to the U.S. and therefore thinks that the FSMA is a distant rumble, this agreement will soon change that perception. The logic is simple: Every food business engaged in interprovincial trade must meet SFCA requirements. The SFCA needs to be equivalent to the US-FSMA in honour of this agreement. Therefore, food businesses in Canada that conduct interprovincial trade must meet FSMA requirements. This back-door FSMA imposition is so predictable that it is even a joke to say it will be a surprise. 
Posted by Felix Amiri
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Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Monday, 2 May 2016

Funding Opportunities Offered by FDA & USDA

The food industry, at least in the U.S, should be elated to learn about announced funding opportunities. These include the funding opportunities that are intended to help small establishments in their efforts to comply with FSMA. You may search for other US funding opportunities on this page: http://www.grants.gov/web/grants/search-grants.html

The announced FSMA funding plans appear to be terminable in nature which is a bit disappointing. An ongoing funding arrangement is a better option to encourage and support future operation startups. It is also likely that the grants will be awarded to the more savvy establishments that are able to work the system. This can be remedied through a careful determination of the criteria for selecting qualified establishments and how the funds are administered.

Essential Qualification Criteria and Administration Considerations:
Providing funds to struggling operations is an incentive approach that needs proper implementation and management. This incentive needs to be properly balanced to encourage those who deserve to be encouraged and appropriately motivate those who would ordinarily attempt to dodge or disregard regulations.

If the FDA, USDA or other government agencies were to adopt the SSQA principles in administering funding opportunities, some of the key considerations would be as follows:
  • Remove politics from the process
  • Link the criteria for receiving funding or grants to the inspection process and findings (such that more detected deficiencies that are due to lack of resources receive more funding or grants)
  • Implement fair and effective strategies that extend funds only to operations that need such funding (with interest-free pay-back arrangements to help prevent the abuse of the opportunities)
  • To prevent the misuse of funds, don't give funds directly to establishments; pay for verified improvements instead. 
  • Optimize the positive effect of the funding provisions and properly track the return on investment (ROI)
  • Implement industry collaborative contribution strategies to reduce the financial burden on the regulatory inspection program by contracting, rather than expanding the food safety regulation budget (Adopting SSQA Principles should also assuage anticipated budget constraints for regulators and the industry - 
Questions about the SSQA concept and the governing principles may be directed to the SSQA Development Team at: gcse@afisservices.com
Posted by Felix Amiri
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Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Wednesday, 6 April 2016

Summation from an Industry GFSI Discussion Event on April 1, 2016


This blog post has been moved to the author's eBook. Check it out here: 
Posted by Felix Amiri
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Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.