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Saturday, 14 October 2017

Unannounced Audits: A Needless Regression

Why is the industry going back to the past days of sneaking up on food operators to catch the deviants?

With all of the growing euphoria around unannounced audits and the fake sense of attainment, here is a reality check question: What will happen differently when operations fail to meet the stated requirements during the unannounced audits that is not already happening without them? This question needs to be examined from two perspectives: From the perspective of operations that can afford and have the setup for unannounced audits and from the perspective of operations that cannot afford and have inadequate setup for unannounced audits. Perhaps a third perspective can be added for an operation that can afford and has the setup for unannounced audits but sufficiently negligent to warrant unannounced audits. From each of these perspectives, what is likely to happen during unannounced audits that is not already happening during announced audits in terms of required follow up actions?
Proceeding with unannounced audits is a regression. In a food industry that claims to have attained higher levels of scrutiny, systems should have also developed to the point where the right things are done as a normalized routine. Incidentally, this normalized routine is the expectation behind the suggestion of unannounced audits. Only a small number of issues are expected to be found during unannounced audits. If only a few issues are expected, it is needless to have such audits. If, on the other hand, things have not developed to the point of expecting only a small number of issues, then it should already be known that significant issues will be found. In that case, unannounced audits are equally redundant.

Where the audited parties cannot be trusted and deemed to need unannounced audits, the battle is already lost. The untrustworthy parties cannot be trusted on the day following the conclusion of the unannounced audit. Keep in mind also that as soon as the auditor arrives, the audit is no longer unannounced. The auditor cannot physically and at once see everything, everywhere in the facility when he or she arrives. Those who cannot be trusted and must be caught red-handed are also predisposed to, and are adept at, cunning ways. They will have tricks that they can play even during unannounced audits. They can still put up appearances. On the other hand, if operations can be trusted because of their integrity and commitment to doing what is right at all times, it is a futile engagement to try to catch them red-handed. They do not need unannounced audits.
From all angles of view, unannounced audits do not represent progress. They are a needless regression.

The pursuit of unannounced audits debases the intelligence and level of commitment attained by many food operations, particularly the operations that can afford such audits. The already attained level can and needs to be further raised but it is certainly much higher than is portrayed by the suggestion of unannounced audits.
By the way, the notion of "being audit ready" leads to doing everything only for the audit and only within the narrow confines of stated requirements. Everything should instead be done to consistently ensure the safety and satisfaction of the consumer. With respect to all that must be done by every operation to protect the consumer, the typical audit (announced or unannounced) does not cover nearly enough scope, nor does it proceed with sufficient precision. Even the accuracy of the typical audit in detecting realistic concerns in every situation is, at best, questionable.

It is not disputed that current arrangements are in dire need of modification. However, the proposal of unannounced audits is regressive. If the food industry is to see substantial, meaningful and productive progress, audit proceedings need the infusion of a different kind of thinking. Audit proceedings need different methodologies and different criteria for assessing success or attainments than are currently pursued by many parties in the industry.
Posted by Felix Amiri

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

Friday, 29 September 2017

Another Failure-Revealing Review:

“These standards have both advantages and disadvantages and their effectiveness depends on several factors such as the competency and skills of auditors and the standard used in each case. Although the industry continuously invests in developing and improving these systems, the number of foodborne outbreaks per year appears to be quite stable in both Europe and the United States. This may be an indication that additional measures and techniques or a different approach would be required to further improve the effectiveness of the food safety and quality management systems.”

Kotsanopoulos, K. V., & Arvanitoyannis, I. S. (2017, August 03). The Role of Auditing, Food Safety,and Food Quality Standards in the Food Industry: A Review. Retrieved September 29, 2017, from

CRF3-2016-0015 Submitted 12/29/2016, Accepted 7/3/2017. Authors are with
Faculty of Agriculture, Univ. of Thessaly, Fytoko St., Nea Ionia Magnesias 38446, Volos,
Greece. Direct inquiries to author Kotsanopoulos (E-mail:
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate. 

What food safety and quality management model works?

A post subject to the modification of expressed thoughts depending on productive comments, contradictions, criticisms and conversations:

The question about what food safety and quality management model works best is one of the questions that emerged for me from the recent GMP summit in Chicago. The focus of this question is not on particular schemes since these also fall within the adopted models. The focus is on the external and internal instruments and influences involved in the management and monitoring of systems for ensuring the safety and quality of the food delivered to the consumers. The “model” idea is with the specific consideration of the roles and processes of regulations, industry “standards” (i.e. schemes, industry knowledge and best practices), and other motivating factors that drive what operations do to ensure the safety and quality of food.

The Main Question:
What system management model should a food operation follow for the development, implementation and monitoring of safety and quality assurance measures?

To businesses satisfied with simply following the crowd, this question may be of little significance. For the sake of those running businesses that wish to be leaders in the industry, let’s take what I mean by “system management model” a bit further. One is able to easily see generally, although exceptions are rare, that the food industry only has the following models:

  1. Cottage Industry Model:
Operations adopting this model are often not aware of applicable regulations beyond the powers of local enforcement officers. Though governed by the existing regulations, the operation and assessment activities are not typically designed and carried out in response to the regulations unless they are forced to do so. The predominant motivating influences are the drive to make money and personal concern for the well-being of close friends, customers with a relationship that is on a first-name basis and family who form the consumer base.

  1. Simple Compliance Model:
Operations adopting this model are often aware of applicable regulations and, after doing what they understand to be sufficient for compliance to the minimum requirements, wait to be told about what else to do. These operations may not even be aware of existing industry “standards”. The predominant motivating influence is the drive to make money that is often insufficiently mitigated by concerns for the well-being of consumers.

  1. Sophisticated Compliance Model:
The operations adopting this model are generally aware of applicable regulations and industry “standards”. They often claim to take a proactive approach in ensuring compliance with all requirements. The predominant motivating influence is the drive to make money. The predominant motivating influence is an almost insatiable profit-making drive with consumers seen only as opportunities. The well-being of consumers is the least of the concerns with this model.

Based on simple considerations (since the industry does not customarily measure the relevant assessment criteria), the model with the highest degree of genuine and sustained commitment to the safety and satisfaction of consumers from among the three may surprise you. Likewise, the model that is likely to be the least wasteful in resource utilization versus returns on investment may surprise you.

Sadly though, upon a careful examination of the motivating influences, you will find that none of these models provides sufficient guarantee and consistency of assuring the safety and quality of food. Claims about the commitment of operations and personnel can be made with any of these models. However, the reality often proves contrary to such claims. Besides, the subjects and objects of many an acclaimed commitment are vague. Commitment in what and to what?

As far as you can tell, what model has your operation adopted? Is there a better model? Does the food industry need a better model? Is a better model even possible? To all three questions, I would say: YES. That model has already been developed and only needs an expanded adoption. It is the SSQA model. It respects the need to make money but drives and supports the adoption of principles for doing so in ways that are morally, socially and environmentally responsible. It is inclined to providing more tools than rules. It leads to fortification instead of certification. Adopting operations are commitment-driven instead of compliance-crazed or conformance-confined. With SSQA, the idea of commitment has an unwavering ultimate focus – ensuring the safety and satisfaction of the consumer. The differentiating hallmarks are many.

What do you think? I also welcome your comments or questions.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Wednesday, 16 August 2017

Wednesday, 21 June 2017

To those for whom Food Safety Certification remains enticing:

Company X has been assessed and "certified as meeting" the food safety and quality management requirements set out in Standard Y by the Standard Owner Z.
Now, who says that Standard Y, when followed, actually achieves safe food any more than simply following the common knowledge of what should be done to prevent food safety risks?
What does “certified as meeting Y Standard” actually mean with respect to any consistency in the production of safe and desirable quality food?
Is it possible that the desired food safety management consistency is actually only achieved through the commitment of Company X in hiring knowledgeable individuals with a focus on working according to the common knowledge of risk prevention, and not through certification?
Could it be that the certification parties are taking unwarranted credit for the success that Company X is able to achieve on its own? Could it be that certification schemes are actually lulling food safety managers into sleeping certified like those who are managing or who have managed these certified failures?
Have the demanding customers become so effectively blindfolded?
Yours truly,
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.