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Thursday, 26 November 2015

Examining the Narrative and Considerations in Your Food Safety and Quality Management:

Do the following with respect to your food safety and quality management considerations and narrative:

Instead of "3rd party requirements" or "3rd party standards", replace that with "consumer needs".

Instead of “compliance to standards or requirements”, replace that with “commitment to assuring the actual consumer experience of having safe and good quality products

Now answer these questions:

a.) Is the actual food safety and quality performance of your company’s product currently good enough and can you keep it good enough without the imposition of 3rd party requirements?

b.) Do you have the required knowledge about your business and products to produce safe, legal and good quality products or do you feel this knowledge must be acquired from imposing 3rd party requirements?

Has this exercise changed your thinking about your inability to do without 3rd party standards?

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

Wednesday, 25 November 2015

Process Validation versus Scheme Certification

Any food business that feels lost without a food safety scheme certification is a food business that is lost and is in need of rescue.

If lost without certification, that business will remain lost with certification because what is lost is direction; not the corroboration of external parties.

Never mind a possible overnight improvement within the entire food industry, the rate of progress in your food business operation could increase exponentially if good process validation is done instead of scheme certification.

What are the differences?
Under the SSQA concept, process validation is the confirmation that a process actually achieves its purpose. Unlike the generalized approach of "one audit checklist fits all" in scheme certification programs, the proper validation of an operation’s processes relate directly and specifically to that operation. Therefore it allows the operation to implement real time corrections and improvements that are relevant to that operation.
The rules that must be followed under scheme certifications are not specific to any particular operation. Therefore they can lead only to operation improvements that are generic in nature. Such improvements may or may not even be relevant to the operation simply because they are based on generic theories that may not apply to the operation. For example, all operations under a scheme certification program may be required to have scheduled management meetings with recorded minutes. However, in some operations where the managers are also the plant floor supervisors and operators, such meetings sometimes end up doing more harm than good since the customers want products; not meeting minutes delivered on time. A scheme certification auditor would want to see the minutes to confirm that management meetings are taking place regularly. On the other hand, a process validation approach examines the real-life outcomes to verify that all company personnel are collaborating and cooperating to achieve the continuous improvement of the operation.

Scheme certification is pre-occupied with policing and reporting on defaulting or complying operators according to the generic (often irrelevant) requirements of the scheme. Process validation, through the examination of outcomes, causes and effects, provides real-time guidance to an operation. This guidance covers the entire scope of considerations that are directly related to the operation, its experiences, obligations and goals.

The food supply chain is presently a highly fragmented system with a growing number of subversive elements who are getting increasingly sophisticated in their evasive ways as they seek furiously after financial gains. They have, and continue to put on well camouflaged superficial performances to pass scheme certification audits. This is only possible with assessments that are conducted against generic sets of requirements because compliance to those kinds of requirements can be easily faked. Certification and the adopted policing approach can only go so far because it does not even make any attempt to detect real causes and effects.

Process validation, on the other hand, focuses on the actual accomplishment of the desire goals. It looks at the causes and effects. Therefore, it naturally discourages subversive behaviour. Actual outcomes cannot be faked. Besides, many reasonable operators want and do validate their processes against the desired outcomes. They recognize that scheme certification is only a window-dressing activity that helps them retain the customers requesting such certifications.

Comparative chart of key characteristics:

Scheme Certification
Process Validation
(under the SSQA Concept)
The goal is the certification;
The goal is the validity of processes;
Assumes that if food safety management systems are in place, the ultimate goal of food safety would be met;
Confirms that the ultimate goal of food safety has actually been met;

Superficially assesses how the certified organization does its scientific validation tests without conducting any actual tests;
Through actual tests, confirms the accuracy of an organization’s scientific validation tests  to show that all processes are achieving the desired practical (real life) outcomes;
Verifies that applicable validation tests or evaluations are conducted but does not actually conduct tests to validate the validation test results;
Determines if the scientific validation test or evaluation parameters are the right kinds for the processes in question and actually conducts tests to validate the validation test results;
Limits its examination and conclusions to the test results as the ultimate validity;
Does not limit its examination and conclusions to the test results, but considers both the validity of the test results and the practical (the real life) outcomes linked to the processes as the ultimate validity;
Operation records are mostly examined as proof of compliance;
Operation records are mostly analyzed used as gathered intelligence for operation improvement.
Allows certification bodies to stand aside and apart as spectators of actual improvement plans and activities (through the avenue of disclaimers that certification auditors are not consultants and that certification provides no guarantees);
Engages validation partners  as direct participants in the development and implementation of improvement plans and activities (through the proper interpretation of validation results);
Under the guise of conflict of interest avoidance, does not take part in the correction of detected ineffectiveness and completely ignores the efficiency of processes. It merely provides “compliant” and “non-compliant” criticism without providing direct assistance.
Cuts the chains of misapplied conflict of interest rules and provides direct assistance in the correction of process ineffectiveness and inefficiencies. It provides the relevant solution information and data needed for the proper re-tooling that ensures improved effectiveness and efficiencies where weaknesses are detected.

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

Saturday, 7 November 2015

The Blight and Plight of Restaurants

Challenges Faced by Restaurants and Similar Food Outlets

The well reported E. coli outbreak at Chipotle restaurants is by no means going to be the last of such cases. There is no restaurant that can boast about having a handle on preventing situations like this. With these incidents, the quick solutions that are often suggested by some food safety experts to restaurants include the implementation of effective HACCP food safety programs and the training of employees. These are good suggestions in theory. They are not easy fixes for restaurants as some proponents seem to make them.

HACCP implementation is a tried and tested solution for the food industry in general but it fails too frequently in a restaurant setting. The suggestions that restaurant management must be committed to HACCP and train their employees on HACCP principles, as well as the stipulation that employees must keep HACCP records are good suggestions. Unfortunately, they do not always work as smoothly as suggested even where intentions are good. Where efforts are half-hearted, the implementation of HACCP tends to be a restaurant’s undoing. It may sound almost sacrilegious to say this, but HACCP can even make matters worse for a restaurant or any food establishment if implemented with simplistic assumptions. This is particularly so if the HACCP program is implemented only as a window-dressing “demonstration of due diligence”. This is often the case. Food establishments tend to do whatever it takes to "just pass third party audits or inspections". Passing third party audits or being "certified" or having inspection pass grades is presumed by too many people in the industry as the goal to pursue. HACCP does not derive its validity from certification but from its effective implementation.
A restaurant or a food establishment must build the right foundations before or while implementing HACCP:
The foundations that are needed go far beyond the usual HACCP pre-requisite programs that are quite limited in scope. HACCP is not a magic potion or a panacea and should not be viewed or implemented as such in any setting, much less in a restaurant setting. There are at least three significant but solvable challenges faced by restaurants that can quickly undermine a theory-based implementation of the HACCP concept. Since HACCP itself does not address these challenges, they are ever poised to derail any due diligence that is purported to be demonstrated through the implementation of a HACCP program. Unless these challenges are properly addressed, even the most perfectly documented HACCP program with consistent records quickly becomes useless. Failure is almost inevitable if these common challenges faced by many restaurants are not addressed prior to, or concurrently with the development of a restaurant’s HACCP Program.
The “Busy Times of Day” Challenge
If you run a restaurant, you probably already know this all too well. Precautions tend to go out the window during the busy times. This creates ample opportunities for undesirable incidents to occur at the worse times. With the increased number of patrons causing the restaurant to be busy, one is not sure whether to see it as a blessing or a curse. The chances are that much increased for undesirable incidents to actually affect more patrons. With more people likely to be affected, it goes without saying that this expands the scope of the negative publicity and increases the liability for restaurant owners and managers. This challenge is solvable but not through a simplistic implementation of HACCP.
The “I Need the Money” Challenge
Another solvable challenge is well reported. One such report is provided in this International Business Times article:
Financial pressures often force restaurant employees to go to work even at those times when they are most likely to spread illness-causing germs. They would go to great lengths to hide their illness and go to work. 

The Rapid Employee Turnover Rate Challenge
Many fast food restaurants employ students who, as a matter of course, must leave to pursue their dreams. Where the employees are not students, many are in a perpetual state of looking for “the better job” elsewhere. The food safety challenges with rapid turnover rates need no further introduction. As trained employees are lost, the hiring and training of new employees is rushed. Inconsistencies in employee practices are heightened by the inexperience of employees who have not done the job for long enough. On top of these challenges, employees with all sorts of negative attitudes may end up being hired because of the hasty hiring process. These are soon fired and the cycle continues. Does HACCP solve these challenges? Of course not! Instead, these challenges render HACCP useless if they are not effectively addressed.
Before and Beyond HACCP
To successfully combat these situations and avoid the associated liabilities, restaurant owners and managers need to develop strategies that are unique to their situations and experiences. This can be done by conducting relevant studies and implementing positive culture-building strategies. These strategies make HACCP work. Without them "HACCP" can quickly become a "HANDICAP". If you run a restaurant or work in one and you have questions about how to implement effective strategies for food safety and quality success, your best bet is to adopt the  Safety, Security and Quality Assurance (SSQA) way of thinking.
The recommendations in this post are not “easier said than done”. They are easier done with SSQA. Once you have learned and adopted the SSQA concept and its Difficult-to-Manages Situations (DMS) HACCP provisions, your only regret will be that you did not know about this concept sooner. The good news is that this regret quickly turns into re-assurance as your SSQA implementation efforts are rewarded. Unlike the common practice of implementing HACCP that is mostly demonstrated and assessed on paper, the results of SSQA implementation are seen and assessed from the product perspective. Products must actually be safe as the proof of success. Complete documentations and copious amount of records mean nothing until the product is actually proven to be safe from reported consumer experiences. As such, the joy of the SSQA journey increases for a company in the SSQA-D as time passes.
The following news items may be disturbing for some to read:

Waiters: Listen carefully to avoid being sued - Quebec waiter arrested after seafood puts allergic customer in coma - 

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