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Thursday, 23 July 2015

The Familiarity Fatigue and Flow-Through Syndrome in Internal Audits

What have you heard about internal audits lately? I was recently reminded of the dangers of conducting your own audits during my attendance at a certification audit.

Under all of the schemes currently on the market, internal audits conducted by operations are required. At the same time, a common suggestion about internal audits is that auditing one's own work should be avoided at all costs. It is argued or assumed that a person auditing his or her own work (a self-audit) invariably overlooks things. Technically, all internal audits are self-audits (in one's own company or where one works). Therefore, by inference, all internal audits overlook things and should be unacceptable. Do you agree?

I believe that people do hasty and poor jobs of internal or self-audits when they do not fully understand the function of these audits. Anyone who understands the function of self-audits also knows that it is safest to maintain integrity in the process. Here is why: A person who cannot detect shortcomings in his or her own work is not qualified to do that work. A qualified person who hides his or her shortcomings during self-audits in order to look good, often achieves the opposite. When the hidden shortcomings are discovered by someone else, incompetence is credited to the person who does the work and hides the shortcomings. Incompetence never looks good and, if credited to a person, it almost always gets that person fired.

It appears that these schemes understand the value of internal audits. Ironically, the very schemes that mandate internal audits (self-audits) because of their value are the same schemes that view such audits with the greatest suspicion. These facts immediately expose two things that happen with audits conducted under the schemes: 1. The schemes do not trust the people conducting the audits but accept them anyway. 2 Scheme auditors may have observed and reported instances where the individuals auditing their own work have glossed over things but proceeded to issued “pass” grades anyway. Neither of these is acceptable. 

The distrust-but-accept and the gloss-over tendencies under scheme auditing must be addressed. The SSQA Concept provides a clear and effective solution, and, I believe, it is the only concept that provides such a solution. 

If you are already able to beat the Flow-Through Bug and the Familiarity Fatigue Syndrome in your internal audits, you do not need SSQA. If you have not been able to beat these, you need to either implement, or re-visit how you have implemented, SSQA Step 6 – “CARE” (Section 2.6 of the SSQA Manual). If you do not have this manual, check out what you may be missing.
 Posted By Felix Amiri
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

Saturday, 18 July 2015

Reported GMO Death in January 2015

This death was said to be due to the consumption of tomatoes containing fish genes which caused an allergic reaction - anaphylaxis. So, was it the GMO process? Could a non-GMO product containing undeclared fish protein to which Juan Pedro Ramos reacts have caused his death? On the other hand, could a label declaration showing the source of genes used have prevented Juan Pedro Ramos' death as does allergen declaration on non-GMO product labels? Other than this report, I am not aware of any substantial history of reported illness or deaths specifically due to GMOs. Does anyone know more and is willing to share? Legitimate sources of information are hard to find on both sides of this matter of GMOs.

Curbing GMO Emotionalism on All Sides:
On further examination of this case, evidence exists to demonstrate that GMO crops may very well save lives – Benefits of GMOs. One such crop has caused a death but what was the real problem that unfortunately caused Juan Pedro Ramos' death? Understanding that there were more than one player - the developer of the genetically modified tomato, the grower, the retailer and the consumer - who was most at fault and what was the fault? Are GMOs always deadly or are they always beneficial?
A July 13, 2015 article by Dr Nafeez Ahmed includes some arguments and counter arguments by different parties concerning the safety and benefits of GMOs. Anyone wishing to do further (balanced) investigation could look further into the studies by the various parties described by Dr. Ahmed in his article. A link to the article is posted below.

The conclusion from the Norwegian study leaves us with a crucial consideration: Not enough time has passed and not enough balanced and broad-scoped studies covering safety to humans, environmental safety, etc. have been done to date. As such, to make any absolute assertion about the safety or the dangers of GMOs appears to be irresponsible. 

The most balanced study group, in my opinion, would be free of biases. From the various groups listed by Dr. Ahmed, the world Health Organization appears to be the most unbiased.

It may appear impossible to assemble an unbiased study group. However, I believe that pulling well qualified scientists from all sides to work collaboratively is perhaps one way to effectively neutralize the typical biases that plague this subject. The group should consist of scientists with ties to the economic benefits derived from the commercialization of GMOs; scientists with avowed commitment to protecting the environment; scientist committed to the safety of food for humans; and scientists from academia who are only interested in seeing results of studies one way or another. I am not aware if such a study group already exists at the World Health Organization. The focus of the studies should also not be on validating the claims of any side. It should rather be on answering the key questions regarding GMOs through the scientific method and reliable (not biased) experimental design aimed at addressing each question investigated/studied.

The goal of course should be to make the world food supply safe, healthy, sufficient, accessible, affordable, without endangering the environment. This is for the benefit of us all.

In response to one of my connections on LinkedIn, I provided my opinion regarding each of his points of inquiry as follows:

“The Global approach to GMO”:
I would recommend strategies and practices that capitalize on the known benefits while minimizing or eliminating the known risks and regional inequalities among developed, developing and under developed regions

“The statutory and regulatory preparedness of most African Country's on GMO foods”:
In the absence of conclusive, non-biased, reliable and time-tested studies, no country is sufficiently prepared to enact more than cautionary statutes and regulations. Some countries in Europe, North America and elsewhere simply now have cautionary regulations that require “sufficient” studies done on proposed GMOs and clear label declarations. What is considered to be sufficient study is not well defined in many, if not all, instances.

“The myths linked to eating GMO foods”:
The myths present another case for conducting good scientific studies and clearly communicating valid and unbiased results to the public.

“Social and economic implications of adopting GM Crops”:
A case can be made for the plausible socio-economic benefits of GM crops. Such benefits have been catalogued, particularly by parties that stand to gain from an expanded production and acceptance of GM crops. Although propelled by the anticipated economic windfalls, some of the benefits described and demonstrated appear to be good for society. A reduction in the use of pesticides in farming could have some health benefits that may require further investigations in connection with the environmental protection implications.

“Reported cases of illnesses linked to GMOs”:
With the example of the reported case of allergic reaction and death in January 2015, published information about likely health issues linked to GMO are mostly projections, predictions or suspicions. These require further and specific studies by unbiased parties like the World Health Organization and its scientists. The World Health Organization advises that individual GM foods and their safety should be assessed on a case-by-case basis. Also, according to the World Health Organization, and generally speaking, no effects on human health have been shown as a result of the consumption of such foods by the general population in the countries where they have been approved. Clearly, this does not provide an absolute guarantee about the safety of GMOs. It only means that real life experiences of adverse effect on health have not been linked directly to GMOs. Read the WHO Frequently asked questions on genetically modified foods. 
The vigour (or rigour) of risk assessments conducted by the relevant authorities before authorization of GMO in the market”:
Regulatory or other authorities need to work with reputable non-biased scientific community in determining the best course of action with respect to the authorization and regulation of GMOs.

Additional Reading:
The July 13, 2015 article by Dr Nafeez Ahmed:

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

The Wool-Over Eyes Game

Who do you think has the upper hand in the wool-over-eyes game?

Where this game is played, some food operators think they are pulling the wool over the eyes of auditors when they hide things that do not, and I quote: “comply”. Meanwhile, the auditors are making the operators pay for paper certificates while they (the operators) are saddled with the work of ensuring the safety of their products as well as the survival and growth of their businesses. So, who has the upper hand in the wool-over-eyes game that has become  endemic as part of the Standardized Industry Mistake?

Many victims of the paper certificates deception or those who have become addicted to seeking these certificates, believe they would lose customers if they do not have such certificates to, and I quote another popular phrase: "prove compliance". A large number of unquestioning passengers are still boarding the deception-train, confined in the tunnel and are being made to believe in fanciful schemes until sad realities hit. They soon realize that they can still lose customers even with their paper certificates. They are yet to learn from real experiences: Peanut Corporation of AmericaJensen FarmSunland Inc. The list goes on.
Meanwhile, outside of the tunnel, the SSQA  concept exposes the usual fallacies and creates an environment where tunnel games are passionately and successfully avoided.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Friday, 10 July 2015

Defining First, Second and Third Party Auditing:

Let me try to clarify some things about these auditing and certification arrangements that may still be confusing to some operators in the food industry or any business for that matter.

“Third Party Auditing” = “Corroborative Witness Auditing”. In this arrangement, one party (the first party - supplier) does business with another party (the second party - customer). A third party (audit services provider) audits the first party and informs the second party how the first party is doing. Trust is weakest in this auditing arrangement.
“Second Party Auditing” = “Vested Interest Auditing”. In this arrangement, the second party (the customer) wants to see with its own eyes, so to speak, and be sure that the first party (the supplier) is doing everything necessary according to the second party’s needs, specifications and expectations. Trust is moderate in this arrangement and corroboration by a third party is not necessary but outside audit services providers may be utilized.
“First Party Auditing” = “Internal Auditing” = “Vested Interest, Customer and Consumer-centric, Self-Motivated, Inevitable Business Management, Improvement and Survival Strategy”. That almost says it all except to add that outside audit services providers may also be utilized providing that these service providers are brought into the fold, so to speak, and given the opportunity to thoroughly understand and experience the customs and challenges of the first party as members of a collaborative team with the first party. Trust is strongest with a self-motivated, well-intended and properly managed internal auditing system. Customers find no cause to spy on suppliers or police them.
"Regulatory Auditing" = "Both Second and Third Party Public Protection/Education Auditing" In its purest form, regulatory auditing should be without other vested interests except regulators are also consumers and they report to consumers as they must.

The above descriptions merely represent current market understanding of these categories of audits. My understanding of what they are does not mean that I blindly accept them. Naturally, I am inclined to go with where trust is strongest – the “first party auditing” option.

Calling an audit a "third or second party audit" is actually a misnomer that creates an artificial distancing of auditors from the realities at play. Every auditor is a consumer and should naturally have vested interest in the audit. If audits are conducted from that perspective, things could get really hot for deviant operators and that is not what we want. On the other side of this consideration is the fact that every operator has vested interest as the business owner. However, the operator or business owner is foremost a consumer. Hence the operator or business owner should also naturally have vested interest in audits. Even regulators should have vested interest in audits since they too are consumers. Essentially, all audits are first party audits since consumers are auditing businesses owned by other consumers, etcetera.

I understand but I do not condone the wrongly applied guards against conflict of interest that appear to have led to this misleading classification of audits. The food safety auditing industry, in an over-generalized fashion, prevents expert auditors from assisting the companies they audit for fear of conflict of interest. This only appears to be wise on the surface. If auditors cannot be trusted to show integrity in conflict of interest situations, how can they be trusted with anything else?

The same food safety auditing industry that imposes unnecessary conflict of interest rules (with wrong assumptions about conflict of interest), sets retailers up as the best guardians of consumers without seeing the blatant conflict of interest.

The Hypocrisy
The industry has seen bands of retailers or other commercial interests coming together to create auditing schemes called “standards”. Where these schemes are not directly created by retailers or other commercial interests, they (the schemes) are heavily sponsored by the commercial interests. Even if these arrangements do not expose the hypocrisy, retailers are clearly not the best guardians of consumers – at least not in the current retailing environment that is steeped in greedy competition, corruption and fraud. Retailers also rarely subject themselves to audits against the standards they have created. 
It is true that retailers only buy and sell, and manufacturers need to be monitored. On the surface, this argument may appear to be made “for the sake of consumers”. Is it? Are retailers that much more trustworthy than manufacturers? Do retailers really care so much about the welfare of consumers that they should or could be their guardians? Do they actually wish to go beyond protecting their businesses against liabilities by doing what they fondly refer to as exercising due diligence? Is it any surprise that superficiality has overtaken food safety monitoring and auditing in the current marketplace?
What is too frequently forgotten in the food safety auditing business is that we are indeed all consumers. The urge to simply make money appears to have overtaken the food industry at large. Some sanity needs to be brought back. 

Assessing the success of food safety assurance efforts by food businesses must have the right focus - the protection of consumers. Giving this consumer protection no more than lip-service is shameful. That is out right self-defrauding and somewhat suicidal. I admit that these are strong words but what else will awaken the industry from its current stupor?
With the above explanation, it becomes immediately clear why efforts are to be collaborative. The question is: Are they? If efforts are truly collaborative the modus operandi of conducting audits in the marketplace today will be significantly different. The policing approach will give way completely to the kind of collaborative effort that is a Hallmark of the SSQA concept.

If you are still not sufficiently clear, you may contact the author.

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