Copyright © Global Coalition for Sustained Excellence in Food & Health Protection, 2011 and ALL subsequent years: Unauthorized use and/or duplication of this material without express and written permission from this blog’s authors and/or owners is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Global Coalition for Sustained Excellence in Food & Health Protection with appropriate and specific reference and/or link to the original content.

Thursday, 31 December 2015

Food & Health Protection Mobilization


The Global Coalition for Sustained Excellence in Food & Health Protection has been launched to encourage a worldwide mobilization to:

 protect public health
 promote regulatory compliance
 produce sufficient, nutritious, affordable and safe food (including safe water supply),
 produce reliable pharmaceutical and other health products
 keep products fresh and within reasonable shelf life
 avoid wastage
 ensure equitable and efficient distribution of food and health products
 encourage social responsibility
 maintain environmental sustainability
This small step can make a huge difference. If you think this mobilization makes sense, cast your vote in support.


Wednesday, 30 December 2015

SSQA Consultants and Trainers Events - The next stop could be near you:

If you provide food safety and quality management training services, you could become an SSQA training provider and your organization could serve as a training centre. Did you also know that consultants have the opportunity to receive SSQA enrolment commission?

Consultants and trainers who provide SSQA implementation services or training to their clients, may also submit a brief synopsis of their overall services and related information for FREE LISTING by GCSE-Food and Health Protection as a way of gaining additional exposure. You may contact the SSQA-D Team via the email address below for additional details.

GCSE-Food & Health Protection is planning SSQA program introduction and partner workshop events for Toronto, Montreal, Edmonton and Vancouver. We need a minimum of 50 participants to confirm each location and the number of participants will also determine the size and cost of the venue selected at that location – the more the number, the lower the cost. We are currently gathering the numbers. Please cast your vote for your nearest city by sending an email to the SSQA Team via the address below. The events will be scheduled according to the order in which the cities reach 50 participants or more. 

If you are interested in becoming an SSQA consultant or trainer and wishes to attend the event in any of these cities, please send an email to gcse@afisservices.com  indicating the city of your choice. The next stop could be near you. Even if a city near you is not named above, you could suggest one. There may be enough people wishing to attend the event in your suggested city.

video

You could qualify to receive a free copy of the SSQA implementation manual if:
 5 other participants indicate that you invited them to attend the event at your preferred city.
OR
You suggest a city and invite at least 4 other participants to the event.
OR
You are a food safety consultant or trainer and you help one of your clients to enroll in the SSQA Program.
Contact the GCSE-Food & Health Protection Team for details: 

You may  also contact the 
GCSE-Food & Health Protection (SSQA Development) Team 

GCSE-Food & Health Protection Blog Popularity

The GCSE-Food & Health Protection thought and action inspiring message is continuing to gather worldwide interest. What is the GCSE-FHP Message?

You are invited to read the blog posts and JOIN THE CONVERSATION: 

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You are invited to read the thought-inspiring posts and JOIN THE CONVERSATION:
 

Tuesday, 29 December 2015

Taking a Stand versus Fence-Sitting

Taking a stand for what is right is never wrong.

Unfortunately, some people take stands to which they have given little thought. Such stands may be taken because they are fashionable.

There are belligerent ways of taking a stand and there are civilized ways to do so. I (and I believe most people would) prefer the latter. Taking a stand also does not automatically involve antagonism. Yes, a stand can be taken against something, but it can also be with others. 

Taking a stand is inevitable and it involves thoughtfulness. To take no stand is taking a stand “not to” do so (albeit it is of the fence-sitting variety which is typically not helpful to, and certainly not considerate of, others). 

Fence-sitting kills decision-making efficiency. Even in situations where there are neutral options, taking a stand is inevitable. The stand taken (and should be declared) in such a situation is usually a stand that both options are acceptable. 

In every instance of taking a stand, thought must be given to the stand taken with due consideration of moral obligations, social responsibility and even environmental accountability, etc. Not taking a stand is essentially selfish and irresponsible.

The Reality:

When you take a stand for what is right but it appears as if things will not go well as a result, they actually go well: You will be at peace; losses are re-gained under better circumstances perhaps; you may or may not know this but you will be secretly admired for taking a stand for what is right; you may not be openly vindicated but you will be. You see, what is right is always right even if vindication is delayed or not openly recognized but you will feel no shame. Conversely, the selfish fear that prevents a person from taking a stand always backfires. The consequences may also be delayed or not openly recognized but undesirable and painful all the same with endless shame.

Take a stand with GCSE-Food & Health Protection. We are looking for people with a heart and passion for common good worldwide. Join Us!
Posted By Felix Amiri
____________________________________
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

Monday, 28 December 2015

The Invitation to “Future-Proof” My Food Safety Organization

I received an invitation to download a whitepaper that will help me develop my corporate vision for food safety compliance. The whitepaper largely addressed compliance with future regulatory rules and/or third party standards. 

My Response:
If "food safety" assurance is desired, "compliance" is important but it constitutes a distracting direction to focus my corporate vision. Also, if future-proofing means the preparedness to comply with all future regulations, I find at least two things that are immediately wrong with this suggestion:
1. Compliance to regulations must naturally be reactive since even regulators do not know what rules they may be forced to impose in the future. Therefore, the idea of proactively “future-proofing” my food safety organization to be in compliance is counter-intuitive. Whatever I do now to “future-proof” my food safety organization with a focus on “compliance” is almost guaranteed to miss the regulatory mark(s).
2. If the future-proofing is also as focused on “compliance” as this invitation suggests, invested resources, efforts or strategies are bound to be swallowed up in the futility of aiming at, and missing the constantly moving target. The rules are continuously evolving. The actual fortification (the shock-proofing) of my food safety assurance system is bound to be short-changed by any pursuit of compliance to future regulatory rules.
Contrary to the suggestion in this invitation I will not “future-proof” my system with a narrow focus on compliance. Instead, I will fortify (shock-proof) my food safety assurance to prevent undesirable food safety events in the future. Secondly, I will future-enable my food safety organization to correctly respond to food safety events in the future. Then thirdly, I will future-enable my food safety regulatory compliance preparedness so that it correctly responds to any future changes to regulatory rules.
I do not need, as proposed, a . . . 
whitepaper that lays out the macro trends in food safety compliance” and shows me how to “future-proof” my food safety organization with a narrow focus on “compliance.The suggestion is not only self-contradicting, it could lead to wasted resources.  What I need is perfecting and improving the proven and relevant practices that are known to work in the production and delivery of safe and quality products to consumers. Compliance with regulations is only an incidental part of the process and should not consume all of my focus or vision to the detriment of actual production systems tracking and fortification.
Posted By Felix Amiri
____________________________________
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

Thursday, 24 December 2015

A Series of Unfortunate Misconceptions:

Misconception 20 “Processed food is harmful" - False: 

Processed food becomes harmful only when processors infuse it with incompatible substances and adopt careless processing practices in its production. Some foods that are often considered safe could actually be more harmful if not processed (e.g. the manioc plant naturally has cyanide that is inactivated through proper processing - Food and Agriculture Organizationhttp://www.fao.org/docrep/t0207e/t0207e08.htm).

Misconception 19 - “An operating practice is automatically acceptable if it is documented as a Standard Operating Procedure." False: 
Nonsense can be documented and blindly followed as standard practice where relevant knowledge is lacking..

Misconception 18 - “A third party certificate shields and exonerates the holder in the event of a lawsuit” False: 
Ask lawyers from the Law Firm of Marler Clark. 

Misconception 17 - “Anything that increases the profit margin for a company is good” - False: 
Not so, says the astute manager! Profits gained through dishonest, illegal or oppressive means are never good and may vanish quicker than they are realized. Also, profits gained through playing tricks on consumers may turn the joke around on the trickster.

Misconception 16 - “The primary purpose of product safety and quality system audits is to help operations gain more business” False: 
Gaining more business is the secondary purpose of product safety and quality system audits. The primary purpose is to assess if the audited system is actually capable of ensuring product safety and quality consistently.

Misconception 15 - “Conflict of interest can be completely avoided through the observance of strict rules of business and professional engagement” False: 

There is no such thing as complete neutrality. While blatant gain-seeking interests can be detected and discouraged, the complete elimination of conflict of interest in any business or professional engagement is impossible because ulterior motives are difficult, if not impossible, to detect. The best that can be achieved through rules of conduct is to reach a point of accepting or ignoring the inevitable but subtle ulterior motives and interests in business and professional engagements. Even with such altruistic gestures as giving ALL of the profits from business enterprises or payments received from professional engagements to charity, there are underlying motives and interests.

Misconception 14 
- “A short-duration scrutinizing process that is infrequently used at a given location, and measured against pseudo-parameters of success (the superficial artefacts of its implementation), can be rigorous enough to be trustworthy” False: 
This is a misleading suggestion. If scrutiny is necessary, it must be frequent, constant and consistent. The measure of its success must look at the real outcome that it is intended to produce – not the superficial artefacts of its implementation. 

Misconception 13 
- “The most important thing in product safety assurance is for an operation to maintain paperwork that demonstrates due diligence and will stand up in court.”False: 
Maintaining the optimum level of paperwork that is properly organized is important but it is not the most important thing. It is easy to create paperwork that may appear to demonstrate due diligence and will legally stand up in court. What is really most important is for the operation to actually implement and diligently maintain processes and practices that ensure product safety. The paperwork that follows will stand up in court and will demonstrate due diligence.

Misconception 12 - “Self-monitoring and/or self- regulation is taboo. It does not have as much built-in accountability and high standards of expectation as the monitoring done by a second or third parties.” False: 


Evidence shows, and external monitors and regulators even admit that they cannot guarantee that monitored parties will consistently comply when the external monitoring or regulating personnel have left the scene. The external parties even demand that operations must internally monitor and regulate their systems. A key understanding of a good control measure in the internationally accepted HACCP and similar concepts is that a control measure is best applied and most effective when it is consistently, correctly and completely applied at the point/place where it must be applied. Regulation/or control from any party that is external to an operation is by nature and by practice intermittent, inconsistent and incomplete. Industry must learn or be guided (or trained) to genuinely, and with integrity, self-monitor and self-regulate. This is necessary for there to be any hope of a consistent, complete and effective control of systems that must protect consumers. Self-regulation is not taboo where there is good knowledge and integrity. Self-regulation is essential and mandatory if consumers are to be protected as consistently and completely as possible.

Misconception 11 - “It is best for business to yield without questioning customers' uninformed and unreasonable demands, even where these are detrimental to the customers.” False: 
This may seem smart at first but it is suicidal: What happens to the customers trust and confidence when they eventually learn that you did not show enough concern and initiative to provide helpful guidance even though you knew that their demands were detrimental to them? They will pack their bags and leave.


Misconception 10 -“Comprehensive and detailed product safety and quality system assessments by third parties are to be requested only after the systems are fully established.” Alas! We have a case of misplaced wisdom of verifying, after the fact, that the right things have been done. 
The correct approach is for operators and competent assessors (third party audits if you wish) to pro-actively and concurrently ensure that the right things are done at each step.

Misconception 9 
-“Gaining a third party certification will give the purchaser confidence about the safety and quality of your product” False: 
This claim represents an unfortunate diversion from the correct basis for the purchaser's confidence. It is not the gaining of certification that should give the purchaser confidence; it is the demonstrated reality of a safe and quality product that should give the purchaser confidence. Incidentally, a third party certification is only a snapshot corroboration of the reality that can already be demonstrated in the product - hopefully and wisely.

Misconception 8 
-“You have to pay more to get more.” False: 
You don’t!
With a combination of thorough needs assessment, investigation of the merits of what you are paying for, good planning, and a strategic capitalization on the economy of scale opportunities, you can actually pay less for more. 

Misconception 7 -“Only the defaulting businesses suffer the undesirable consequences of their unsafe and poor quality products.” 
False: 
Consumers suffer some of the consequences. Innocent employees within the businesses suffer the possibility of lost jobs. Businesses offering the same line of product suffer adverse publicity consequences. In some jurisdictions, the tax payers (all of us) foot the bill for some activities of the respective governments in dealing with resulting problems (health problems, economic loss problems, loss of employment problems, et cetera). 

Misconception 6- “More stringent regulatory requirements imposed on producers and manufacturers will produce a safer food supply” -
 False: 
There are several problems with this: 
i). Producers and manufacturers constitute only one link (two links at the most) within the supply chain. Food distribution, food service (restaurants, canteens), consumers, etc., are some of the other links in the chain. ii) More stringent standards will certainly exacerbate the already tense atmosphere between regulators and operators who think regulators are out to put them out of business. This in turn leads to deliberate attempts by operators to circumvent the rules. Some operators are smart enough to do the barest minimum that will make them appear compliant. iii) With more stringent requirements must come the expanded enforcement in terms of the number of enforcers and enforcement opportunities. The general observation is that many enforcement agencies are adopting enforcement contraction instead of expansion strategies. Enforcing more stringent regulatory requirements is not the preferred approach to ensuring a safer food supply.

Misconception 5 - “We are better at detecting product safety issues. Therefore we are better off in spite of the increased incidences of reported product safety issues” 
False:  
Without a measurable and progressive reduction in product safety issues, advances in issue detection techniques have not produced the desired effect. The industry is not better off since product safety issues persist.
Misconception 4 - “Compliance is sufficient” False:  
Compliance is insufficient if it is without the consistent protection and satisfaction of consumers. Standards of compliance are relevant only where the stated standards to be complied with provide sufficient confidence that the desired effects will be achieved through compliance. Therefore, conclusions about compliance should mean that the desired effects and goals of the standards are achieved. If any conclusion of compliance to the standard fails to produce the desired effect or goal, it inevitably means that the standard is either faulty or it is improperly applied. Since rules and regulations governing commercially available products are generally for the protection of the consumers/users, any rule or regulation that does not ensure the safety and satisfaction of the consumer ought to be discarded. Compliance to such rules or regulations is redundant and wasteful.


Misconception 3 -“The audit 'standard' is only rule that must be obeyed” False: 
Those who hold to this misconception are invariably subjected to the tyranny of the “audit standard”. They are therefore bound in fetters of meaningless enterprise because no so-called audit standard (checklist or guideline) is sufficiently comprehensive and complete. The industry needs to replace the mentality that causes audit "standards" to be tyrannical and focus more on the essential bodies of knowledge that it already has to protect the consumer. Much depends on how consumers are well served (effectively, efficiently and consistently).

Misconception 2 - “Food and Health product companies that are not run by the government are the PRIVATE sector” False: 
Nothing can be more public than producing products for public consumption. As many companies that have suffered the consequences of producing harmful products can attest, it is not such a PRIVATE matter.

Misconception 1 - “Rank and file jobs are menial jobs and these rank lower than the roles of managers or leaders” False: 
Managers leaders serve a smaller scope but equally significant purpose as the rank and file. Managers only serve the rank and file and the company; while the rank and file serves the larger scope and equally significant purpose of delivering safe products that satisfy the interests of consumers namely: the safety, security, quality and usefulness of products.


Friday, 18 December 2015

The Food Safety Certification Debate

You are invited to join this debate.

#CertificationDebate

The Debate Topic
Whereas the food industry currently encourages third party certification, in the matter of assuring the safety of food, be it resolved that third party certificates are useless.

Pick your side and join. You may argue for or against any point raised, or raise another point. It should be clear from your argument if you are for or against the stated resolve:


For:
Against:
Felix
Ogunranti

US Food Study

1.
Ogunranti: I disagree that a third party certification is a waste.

Felix: I maintain that third party certification is a waste. Some things may be gained from the process and related interaction. However, what is gained cannot be credited exclusively to the certification process as if to say what is gained is not possible without the process. In other words, without certification, operations are able to achieve even more with less resource expenditure and, possibly, less stress. Third party certification is also a waste because the certificate is the first thing to be discarded as soon as an undesirable incident that relates to the claim of the certificate is encountered. Also, those who issue the certificates do not stand by its claim without some attending disclaimers. The points listed under Undeniable Facts remain true.

2.
Ogunranti: Third party audits help to keep quality in focus,

Felix: Incidentally, many operations involuntarily enlist in third party audit programs only because it is demanded by their customers. The reluctance is because they feel they are already focusing on meeting the customers’ needs for safe and quality products. Therefore they see third party audits as being redundant. Where the enlisting is voluntary (albeit blindly), it is driven by the focus on product safety and quality that the operation already has. Again, the point about third party audits helping to keep quality in focus is mute.    If the safety and quality of products are not already and always in focus for an operation even before enlisting in a third party audit program, how can these be expected to remain in focus after the auditor has left the scene which, more often than not, is the case? On the other hand, if the safety and quality of products are always in focus while the auditor is not present, why is the auditor needed to keep quality in focus?

3.
Ogunranti: . . . audits help to increase knowledge because new ideas can be shared.

Felix: . . . but so much more knowledge is available and, in many instances free of charge. Besides, the knowledge brought by the auditor is limited by that fact. The auditor is one person with only one person’s knowledge. The operation has a team. Also, the same set of requirements that the auditor reads to perform the assessment is the same set already available to the operation’s management team. If the team cannot interpret the requirements, how can they be expected to implement programs that meet them (the requirements)? If the team is that ignorant about the operation and must rely on the knowledge of one person from outside, should that team be running the operation?

4.
Ogunranti: Don't also forget, third party certifications can help your products!

Felix: I am still wondering how a third party certification helps my products when, under the guise of not being a consulting activity, the process of certification offers no concrete help. Auditors offer criticisms but no definite solutions because that would go against their "conflict of interest rules". If the solution is left up to me in this manner, how does that help me?

5.
Ogunranti: Some organisations won't do business with you unless they are sure you are safety compliant in food.

Felix: I agree. It is a shame to see this kind of blindness that has overtaken those organizations. Any organization that bases its confidence in a supplier's product on the results of a snapshot audit, needs to re-examine the realities a bit more closely: 
Read more here: http://gcse-food-health-protection.blogspot.com/2013/08/breaking-addiction-to-superficiality.html

6.
Ogunranti: Now to the main reason, if you do all it takes to put your product in order, have great team, avoid contamination and ensure proper control points, you still need a neutral party to ascertain your efforts are effective.

Felix: No! I do not need a neutral party. I need the actual product evaluation results to ascertain the effectiveness of the efforts being made to ensure the safety and quality of the products offered for sale. You actually left out the usually common argument that “it is always good to have a different set of yes looking at things” In response I would say: The internal team already has many different sets of eyes that know more intimately the weak points to check. An outside neutral party can only come with a generalized and theoretical knowledge that may not be relevant to the immediate experiences and surroundings of the operation. The internal team should already have the knowledge that the neutral party brings. Otherwise, how does the team know if the operation is ready for the neutral assessment? On the other hand, if the team does not know whether or not the operation is ready, should this team be running the operation?

7.
Ogunranti: You cannot implement your own plans and still be the one to ascertain it's effectiveness.

Felix: I very much hope (for the sake of my safety and satisfaction) that the producers of the food products that I buy are ascertaining the effectiveness of their own food safety and quality control measures and plans before they ship their products into the market. I would certainly do this if I was selling a food product. In fact, I would ignore the snapshot 3rd party certification audit results and ascertain the effectiveness of my control measures daily as it were.

8.
Ogunranti: You cannot be your own judge.

Felix: . . . but you are your own judge every day that the auditor is not at your premises. You are making judgment calls every day as to whether you will or will not ship products depending on your assessment (or audit if you will) of the safety and quality performance of the products. This is where the judgment calls really matter. Few third party audits/auditors actually sample the product outputs, assess them against the established specifications and judge them fit or unfit for sale. In other words many (if not all current) third party audits and the subsequent certifications do not assess the actual outcomes. So what exactly are they judging that is of immediate significance to the outcome?

9.
Ogunranti: . . . third party certifications help a lot

Felix: Are you able to quantify the “a lot”? Those offering these certifications have yet to publish any quantifiable data that categorically show how much food safety and quality problems were encountered before certification and how much reduction in such problems have been seen after the certifications. The statistics that they often share about how many operations have enlisted and how many certificates have been issued and in how many countries are useless in terms of the intended goal. The ultimate goal of the certification process which is to reduce food safety and quality related problems are not reflected in those statistics.
Take a look at the certifications (including GFSI certification)  listed for the company with the top listed outbreak involving 4 deaths and 838 sickened – Certifications List

10.
A strong argument in favor of food safety certification is presented in this article:
Food Safety is Good for Business
Features - Business Management
US Foods Study Proves Economic Benefits
By Lisa Lupo, March 31, 2015

Felix: A very rosy picture in support of certification that may fool some people is presented in this article. I am not fooled. Here are some questions to consider:
  1. What has the trend been since 2011, has it been steadily improving or fluctuating?
  2. Were the gains made even because of certification, considering that most businesses work to improve their operations anyway?
  3. Can it be conclusively claimed that similar results were impossible without certification?
  4. Could following guidelines such as the WHO CODEX food safety guidelines, a nation’s regulatory food safety guidelines or even a properly and consistently implemented pre-requisite and HACCP programs without certification produce similar results?
  5. Without certification, could similar results be achieved through following proven management principles such as: TQM (Total Quality Management); Six Sigma; 5 or 6-S (Sorting, Stabilizing or Straightening, Sweeping or Shining, Standardizing, Sustaining the Practice) system;  the SWOT (Strength, Weakness, Opportunity, Threat) analysis; FMEA (Failure Mode and Effects Analysis) model; Lean Manufacturing approaches?
  6. Would there be a relapse to worse results if the certification process ceases but established food safety policies, programs and procedures are maintained?
Any food business that feels lost without certification is a food business that is lost. Ask Bill Marlehow many food safety certificates have prevented lawsuits.


11.
Certification is a proof that indicts more that it acquits where the certified party fails to live up to what certification implies or represents.