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Tuesday, 30 December 2014

Distinction Hallmarks of SSQA


Encouragement through Adaptive Strategies
SSQA drives adaptive strategies in problem solving; rather than frustrate the process through formulaic impositions.

True Chain-wide Collaboration - SSQA Participatory Alliance (SSQA-PA) Principle and Process
No other system has this distinctive in as pure a form as in SSQA. The SSQA concept drives the direct engagement of the entire chain that goes much further than “supplier approval”. It has built-in strategies for gaining customer/consumer confidence and collaboration. SSQA stands out with unmistakable distinction above other systems. No claim of “customer/consumer communication” excellence made anywhere else comes close to the reality derived through the SSQA partnership with every interest represented in the food supply and consumption chain.

Guidelines for Regulatory Compliance Plans
From reviewing the historical context to assigning specific tasks to identified individuals with set timelines, plus an explanation on the anatomy of a regulation, SSQA provides a timeless and helpful guide at no extra cost to companies wishing to set up regulatory compliance plans (section 2.2.1.15 - Regulatory Compliance).

The HACCP-DIVE Process:
This process is encouraged as part of SSQA implementation to ensure appropriate actions in response to desired changes or those that must occur. The process is explained in section 2.2.2.1 of the SSQA Implementation Manual. With the SSQA HACCP-DIVE process in place, and having the DMS-HACCP fully in force, food establishments are able to deal effectively with sneaky failures like what is causing so many allergen recalls "due to undeclared presence" of so and so. SSQA is indeed well ahead of the times.

Internal Audit Techniques:
Food safety and quality management system audits can be conducted using techniques that are scenario-based or situation-based. These techniques are part of the deliberate methodologies used in the SSQA internal auditing process. Detailed guidelines are provided in section 2.6.1.4, page 55 of the SSQA Implementation Manual. A structured use of these auditing techniques significantly boosts the efficiency and effectiveness of internal audits. These techniques provide the tools for the effective and permanent prevention of the Familiarity Fatigue and Flow-Through Syndrome.

Paperwork Reduction MUD Scale:
SSQA identifies the main categories and types of documents with the (MUD) scale. With this scale, users are guided to know what kinds of paperwork to maintain and how. Redundant documentation becomes easily identified and discontinued. Even where electronic database systems are used, this scale helps to optimize the paperwork and increase the efficiency of using such systems.

SSQA, with its unique NODE (Nucleus of Dominant Effect) strategy, takes system management to beyond excellence. The NODE strategy applies to various aspects of systems development and implementation. It is particularly useful in program development, problem-solving, corrective actions, preventive actions, continuous improvement, regulatory compliance, etc.

Provisions for Utilizing Emerging Science and Technology:
SSQA recognizes the significant role that emerging science and technology plays in a company’s success. Hence it outlines strategies and makes provision for planned and effective use of emerging science and technology. Refer to sections 1.2.1 and  2.2.1.6, and Appendices 3 & 8 in the Implementation Manual


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, 24 December 2014

Confinement in Com-Zones

COMFORT ZONE: A place where stagnated people feel safe and are satisfied to remain with no desire for progress;

COMPROMISE ZONE: A place where people recognize the need for progress, engage in token activities to appear progressive but settle for regressing or flat-lined results at best;

COM-FALSE ZONE: A place where people think they are safe and progressing in spite of overwhelming realities that offer neither the evidence of measurable progress nor the basis for feeling safe.
COMPLACENCY ZONE: A place where people think they are safe and simply do not care until it is too late to escape the tragic results of the lackadaisical attitude.

Although he did not mention these zones specifically in his apt definition of insanity, Albert Einstein clearly demonstrated why nobody should remain in these zones. He defined insanity as: “. . . doing the same thing over and over again and expecting different results".


SSQA: A Counter-Com Zone in Food Safety and Quality Management:

For the food industry, the SSQA Concept provides an escape from com-zone confinement.

SSQA implementation is:
  • Timely because of too many recalls affecting too many companies and too many people;
  • Effective because it is based on reality and science;
  • Efficient because it cuts out external impositions, interferences, redundancies and red tapes;
  • Low cost because it is sponsored under the public interest and altruistic principles of GCSE-Food & Health Protection;
  • Suitable for any size of company because of its inherent customizable and expandable provisions;
  • Never outdated because of its inherent organic nature in immediately responding to changes as part of its on-going implementation without the delays of outside committee deliberations;
  • Confidence-building for consumers because they are the main focus of the concept;
  • Prudent because spending less to accomplish more is always a wise thing to do;
  • Good for your business because all of the above work together to ensure the survival and profitability of your business.
Posted By Felix Amiri
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Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

Tuesday, 23 December 2014

Not Letting Bed Bugs Bite:The Sacrifice and the Success

World’s first effective and affordable bait-and-trap developed by SFU scientists:

Letting bed bugs bite to prevent them from biting other people
“Over years of research, Prof. Regine Gries subjected her arms to approximately 180,000 bed bug bites from a colony kept at the school.”

This reported success in the development of an affordable and effective bait-and-trap solution for bed bugs may be of very little interest to the affluent world, but for a great many people in our world, this is great news.

Monday, 15 December 2014

The Standardized Food Industry Mistake

The Food industry seeks after harmonizing the code of practice for industry performance in food safety and quality management but appears to have gone about this the wrong way: Why are CODEX Alimentarius (Food Code) guidelines and national regulatory standards not sufficient for assessing industry performance?

One of the enduring mistakes in the food industry is the setting up of so-called food safety and quality management or auditing "standards" under various names against which to assess the performance or compliance of companies. These so-called standards, more appropriately described as schemes, are growing increasingly complex because of knee-jerk reactions to events occurring in the industry. With so many schemes blindly forced upon the industry by the industry, the target at which to aim was already constantly moving. Now it is moving ever so rapidly. The problem is continuing to expand with knee-jerk reaction rules that are more confusing than helpful to operators. Many of the prefabricated solutions proposed by "expert committees" have the same predictable success rate as the enterprise of fitting shapes according to colour.

The industry urgently needs to make significant changes to the current food safety and quality system auditing arrangements. The disconnect and mounting complexity of food safety and quality assurance rules and proposed solutions can be attributed to the fact that  the so-called expert committees making the rules or suggesting misfit solutions do not have direct accountability for the implementation success. Scheme owners appear to simply wish to out-do each other in an almost juvenile "mine is better than yours" competition. All the while, each scheme owner's goal is market expansion for greater profit instead of greater effectiveness in the assurance of safe food.

The complexity of rules will continue  to be untamed for as long as the rule makers are not duty-bound to show measurable results that demonstrate success in achieving the primary purpose of the rules. 

Complex and almost impossible rules are easily and readily imposed by individuals who do not bear any burden (effort, time, cost, and other consequences) for keeping them. With little to no room allowed for innovative thinking, some of the rules actually stifle the creativity of system managers who could otherwise solve many food safety challenges more efficiently and effectively. 
Just because they are able to catch some rain drops in their hands, unsuspecting and obedient food safety system managers are being led to believe that they are stopping the rain of food safety and quality failure incidents by simply obeying commercialized certification rules. These rules, many of which are redundant, force food safety system managers to stand in the rain and hold up their hands. 

Voluntary Yet Mandatory Subscription:

Although a company or its customers may choose the scheme to follow, subscribing to a scheme has become a mandatory requirement for doing business at some levels. The schemes are also beginning to include clauses that force a wider subscription. For example, some schemes have included requirements for a subscriber to accept scheme certificates from its suppliers as evidence of satisfying certain aspects of the required programs. These suppliers are essentially forced to subscribe to the same schemes or run the risk of losing business. The forced subscription further drives the superficial (cat and mouse game) compliance tendencies among reluctant operations that simply want to obtain certificates in order to gain more business. With many untested assumptions about the successful implementation of the schemes, some operations quickly become entrenched and somewhat enslaved to initially selected schemes. The schemes tend to stress the need for subscribers to match their exact formats in setting up their systems otherwise they cannot expect to do well in audits conducted against the schemes. Thus, due to the time constraint and the cost of switching from one exact format to another, subscribers are systematically discouraged from switching schemes. The subscribers are essentially forced to stay with the initially selected schemes. How voluntary then is the "voluntary subscription"? Beyond that, a form of mental enslavement is taking place that keeps companies obedient to the commercialized certification rules while holding to a sense of freedom that is more mental than real.

The enslaving schemes have several things in common. If the profit-driven intentions are set aside, the schemes could easily be replaced by fewer non-commercialized options. Their number could be greatly reduced where attention is given to what they have in common. The common grounds include the presupposed (often pretentious) intention of enabling food businesses or establishments to ensure the safety of food. They, of course, have more that food safety assurance pretenses in common:

Common Foundations:
The schemes generally look at the same things. They have differentiating formats that frustrate any attempts by subscribers to switch from one scheme to another but the format does not contribute anything that makes one scheme better than others in the delivered effectiveness. In that sense, the schemes are the same. This begs the question of why the industry needs so many versions of the same thing. Current assessment schemes are essentially pre-set requirements about what a company needs to do and have in order to ensure product safety and quality. The main considerations, with only minor variations in the individual schemes, typically include some requirements about management policies and operation control procedures. The bulk of the requirements dealing with general controls as well as the Hazard Analysis and Critical Control Point (HACCP) system follow the guidelines provided by the Codex Alimentarius (Food Code) Commission. This commission was established in 1963 by the World Health Organization and the Food and Agriculture Organization of the United Nations to develop international food standards to protect consumer health and to facilitate fair food trading practices. 

Common Faults:
Common to all of the schemes are readily identifiable faults: The first fault is the excessive commercialization and competition among the schemes. With the established requirements that are essentially the same, it is inevitable for some of the scheme owners to resort to competitive tactics that undercut other schemes. The net casualty is of course the consumers. Audited companies actually stand to gain from the competition among schemes. This competition is a fault in itself since the audited companies are supposed to be subjected to strict scrutiny. Competition among those who are responsible for the strict scrutiny weakens their resolve to be strict.

A second fault is the financial burden and compensation arrangement that sees the companies audited paying for the audits. Even with the proclaimed absence of conflict of interest and its intended enforcement among auditors, the hidden agendas are not so deeply hidden. Astute observers are able to see right through the fa├žade and many of them have expressed their opinions in published observations.

A third fault, by virtue of the audit scores associated with the schemes, is their tendency to create an atmosphere that encourages cat and mouse or hide and seek games where auditors play the detectives who must find what system managers may be hiding to get higher scores. 

A fourth fault is the superficiality of conclusions reached and the certifications granted following audits conducted against the schemes. To curb runaway costs, audits under the schemes must essentially be time limited. They are therefore snap shot audits. As noted in the “Aftermath of the Killer Cantaloupe Devastation” post:

“Snap shot audits are sampling-based. Due to cost considerations, these audits only provide a short duration or window of opportunity to assess and observe the operations. Other factors affecting the reliability of the audits include auditor knowledge and experience, competition for business among certifying bodies, the suitability of the auditing guideline, etc. As a result of these limiting factors, third party audits cannot be and should not be relied upon to provide food safety guarantees. Third Party audits serve a different purpose.”


The Attribution of "almighty" Powers to the "Certificate"

The certificates issued following snap shot audits end up certifying no more than the time the audit was conducted. Even the usual auditor disclaimer acknowledges this fact. Consequently, the issued food safety certificates only stand to say the requirements of the scheme used were met, and only at the time of the audit. The certificates do not automatically attest that the products from the audited businesses are safe and meet the expected quality standards. In that sense, certificates are like fanciful adornments that do not necessarily reflect the character of the wearer. On the other hand, the systems for obtaining these certificates are sometimes involuntary, painful and restrictive with no lasting reformation of character where the wearers are hardened in non-compliant ways. Mind you, companies may mean well but the employees may not all be on board regarding compliance.
The legitimacy of certification in any industry is lost if operators that provide safe products are forced out of business due to the economic pressures of not being able to afford the costs of meeting imposed generic rules that govern food safety certification or regulation while operators that can afford the costs, but produce unsafe products are honoured and permitted to continue in business, riding on superficial certificates.

Common Failure:
As far as I know, and I am willing to be otherwise convinced, no scheme has presented data to demonstrate its effectiveness in achieving the goal of safer food. Several objectives can be shown to have been achieved by the schemes such as increasing the popularity of the schemes; getting many companies to enlist; enforcing system documentation and record keeping as evidence of "compliance" or "due diligence"; increasing the number of certificates issued; increasing the scheme owners' revenue growth; etc. However, the quantified degree to which the intended goal of safer food has been achieved and the scope of that achievement remain elusive. I call this the common failure to demonstrate the achievement of the intended goal. 

The Misunderstanding Leading to the Mistake:
Many certificates are issued after a review of what a company does and was doing during the certification audit. Very little attention is given to the consumer experience resulting from what is done by the audited company. In other words, the “who”, “what”, “how” and “when” are assessed but not the “outcomes”.

Since auditors wish to come in, do their jobs quickly and get out, the clamour in the food safety and quality assessment industry is for "AUDITABLE" food safety and quality management systems on paper. This has led to the creation of paper-based and "auditable" yet ineffective systems.

How to do things may be standardized on paper but it is not the standard for measuring what is done. The actual results obtained constitute the standard against which what is done is measured to determine its validity and effectiveness. 


The goal, and therefore the results must be relevant, correct and linked to the ultimate purpose of what is done.  For example, well organized documentation, good plant floor behaviour during an audit and the existence of completed records are not the ultimate purpose and therefore not the goals of a product safety and quality management program or audit scheme. It may surprise you to know that many companies, managers, industry consultants and trainers misunderstand these to be the goals. Hence the widespread promotion of “what to do to pass third party audits”. The typical advise on “passing” third party audits have very little to do with the real-life experiences of those who use or consume the products.

Long, confusing, stressful, fast-spinning but fruitless certification trek:
In the commercially competitive market for "food standards" (I have always maintained that these are schemes; not standards), the harmonization of food standards may be a challenge for a long time. I do not see why it should be because the industry already has such a standard or standards - HACCP and CODEX Guidelines. The "audit standards" industry, due to an overpowering commercial interest, is only refusing to fully acknowledge and adopt what already exists, and stop selling and imposing their suggestions as "standards". The industry is opting instead to create, sell and impose variously named schemes as "standards" even though they are not able to create these "standards" without falling back to what already exists - HACCP and CODEX Guidelines. With new versions of schemes that are continuing to be released because of the underlying fruitlessness, the long, confusing, stressful and essentially distracting trek continues. The industry may wake up to this fact some day and be done with the enchantment as well as the cat-and-mouse games. 

If you find yourself on the spinning wheel because of demands from outside parties, you need to get off and rise above the illusion. Progress is not made simply because the wheel is spinning faster.

Thank You for Reading
If you are taking the time to read this, I have cause to believe that your company is on track towards becoming a shining example of how things ought to be done. Unfortunately, you have to deal with the interference of mandated systems that appear to be necessary but poorly setup, incorrectly focused and improperly administered by the industry. I anticipate marked changes to the way things are currently done as more and more companies suffer regrettable consequences because of undue dependence on things that offer only a false sense of security. Getting off the treadmill is possible. Hopefully your business does not have to be knocked off by a terrible incident.

You may also want to read these related posts:



Posted By Felix Amiri
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Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

Friday, 28 November 2014

Food Fraud: The Date Change Kind

The National
THE NATIONAL | Nov 26, 2014

Stores caught cheating on best before dates

Hidden cameras reveal that packaged meat may be older than the labels suggest

We have other kinds of fraud that have not made the news like these reported findings: Read more on Systemic Fraud

Wednesday, 26 November 2014

After We Have Come this Far in Food Safety and Quality Management: (A Medley of Blog Posts)

Some of the GCSE- Food & Health Protection blog posts are generating interests, questions and, in some instances, a reported “uneasiness” within the food industry. Instead of “uneasiness”, I choose to describe what should be felt as challenges and encouragement. Uneasiness is felt only where a threat is perceived. There is no need for that. GCSE-FHP does not pose a threat. It seeks collaboration within the industry. You are invited to join the conversation.

You Have an Important Part in the Matter:

It will take companies and individuals who are determined to see real and measurable progress to dismantle barricades that purport to help but, in effect, hinder progress. Positive progress is invariably disrupted if not altogether stopped where ineffective complex systems are favored over simple effective alternatives. Entire industries, in fact entire civilizations, can be drawn into unnecessary enslavement and the punishing consequences of regression where unnecessary enterprises are not only permitted, but also promoted as in the Aral Sea disaster

A Possible Consequence of Over-complicating Food Safety and Quality Assurance:

Regression inevitably occurs where companies are intimidated because of over-complicated food safety and quality management systems. As pointed out in the blog post “Demystifying Food Safety Assurance”, true mysteries pertain to realities more profound than the task of assuring the safety of food.

Complicated and Exasperating Food Safety and Quality Assurance Schemes:

Some companies and system managers who are forced into subscribing to certain complex but ineffective schemes know the facts about the ineffectiveness. These managers or companies may be backed into a corner and they play along but they are not fooled. They regularly do Reality Checks and will escape at the first opportunity.

A “Helpful Scheme Grading Scale” is provided in the "Common Assumptions" post. Check the grading scale out and see how your current scheme measure up.

An evaluation chart for assessing the most suitable, helpful and neutral third party in food safety assessment is also provided in this post.

Dangerous Misconceptions:

Debilitating Misconceptions should not be allowed to overtake the food industry.

Some very small to very large operations have been conditioned to believe that it is almost criminal to ever skip one or more years in their certification programs even if they are maintaining strict and expanded control measures like this Cherry Processor is opting to do.

Measuring the Success of Food Safety and Quality Assurance Programs:

Have you measured or do you measure how much your company spends on redundant external impositions and reactive firefighting versus proactive continuous improvement activities? You need to measure against real goals. You should not simply imagine your product safety and quality management success based on fanciful documentation, accessibility of documents and a readiness to provide answers that auditors want to hear during audits. You need to quantify the success against the real goal in real terms with genuine and relevant data: A Simple Cost of Quality Calculation Chart.
Superficiality may carry a company only so far in its quest for business growth because business growth also means an inevitable increase in the opportunities for failure at the same time that the pressure mounts for products to be actually safe and maintain good quality - "Breaking the Addiction to Superficiality


Adding Your Voice & Support:


Please feel free to share comments, questions and suggestions with this group. Someone learns something from every contribution: Join the Conversation. 
Posted By Felix Amiri
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Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection


Saturday, 22 November 2014

Food Safety in Search of the Most Suitable and Neutral Third Party

Organizations or groups that are involved in the promotion or assessment of food safety, but do not engage directly in the production, processing or sales of food products are often referred to as third parties. This reference is most predominantly used in connection with audits conducted to verify the effectiveness of food safety, quality system and regulatory compliance. Third parties are also involved in other aspects that contribute to the assurance of food safety by providing, associated functions. These include laboratory and pest control services, scientific information sources, operation guidelines development, consulting services, education, training, et cetera.

Parties involved in the production, processing or sales of food products are typically described as first or second parties. In order to avoid biases due to the obvious commercial interests, members of this group are often precluded from providing corroborating evidence about the strength or effectiveness of the food safety programs implemented by other members of this group. Customers may assess suppliers directly and many do. However, such assessments tend to become excessively burdensome to suppliers with many customers. Hence the presumed need for third party audits that are claimed to be acceptable to all customers in theory. Reported practical experiences often prove otherwise. 

The need for third parties to provide any desired corroborating evidence is generally considered to be essential for business transactions within the food industry. Third parties occupy a supposedly neutral position from which to advise the major commercial players. This, the industry feels, removes biases that may interfere with the integrity of the evidence provided. Through the process of audits typically conducted at the facilities of suppliers, the third parties are presumably in a better (non-biased) position to advise both the suppliers and the customers about the integrity, completeness, consistency and effectiveness of the food safety and quality assurance programs implemented throughout the supply chain. Some, if not most, of the third party assessment setups currently on the market involve as follows:
  • Third party auditors or assessors are paid by the companies that they audit.
  • Third party auditors or assessors do not provide specific help because that may be viewed as conflict-of-interest consulting services.
  • The audited parties are expected to already know and to be already capable of implementing what is assessed. Essentially, the audited parties pay third party auditors to tell them (the audited parties) what they already know and/or show them what they can already implement (and must implement) on their own.
  • Third party auditors or assessors do not offer any guarantees because it remains the responsibility of each audited party to know and implement effective food safety measures that are applicable to its operation.
Some commentators have expressed concerns about some of the things involved in the typical setups: Observations about Third Party Audits. I imagine that some of these commentators may like to see the involvement of only suitable and neutral third parties taking up the role of providing unbiased evaluation and certification of suppliers. But which group qualifies?

The Qualification Score Card for some of the Major Third Party Groups

Among the groups that could qualify as third parties, we have:
  1. The World Health Organization
  2. The World Trade Organization
  3. The International Accreditation Forum
  4. Global Food Safety Initiative
  5. Certification Bodies
  6. Accreditation Bodies
  7. Government Regulators
  8. Independent consultants
  9. Educational and training Institutions
  10. Operation-Related Service Providers (including Auditing Companies and Auditors)
To qualify as a suitable and neutral third party that issues certification, the group or organization is expected to have no business interest or direct gains from its interaction with the first and second parties within the industry. Preferably, the most suitable and neutral third party would have a humanitarian commitment with no commercial (i.e. profit-making) or favour-seeking interest. If an organization or group receives fees from, sells anything to, or supports paid membership of companies or businesses belonging to the first and second group, that organization technically no longer qualifies as a neutral third party certification body. The truly neutral party with respect to food safety and quality certification or accreditation would have no check mark under any of the columns to the right of the column that indicates its certifying or accreditation role.

Name the Most Suitable and Neutral Third Party:
From this list, which group is (or groups are) most suitable to issue food safety certification to individual companies as far as you are able to tell? You may download the MS Word version of the chart below.

ORGANIZATION
Has Humanitarian Commitment
Has FSQS Certification/
Accreditation Role
Fees
Sales
Paid Membership
The World Health Organization (WHO)
The World Trade Organization (WTO)
The International Accreditation Forum (IAF)
Accreditation Bodies





Global Food Safety Initiative (GFSI)
FSQS/GFSI Scheme Owners
Certification Bodies
Private Auditing Companies and Auditors
Government Regulators
Independent Consultants
Educational and training Institutions
Operation-Related Service Providers (laboratories and other contracted services)
OTHER(s) [Describe in the rows below]:
Posted By Felix Amiri
____________________________________
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection