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Monday, 19 December 2016

More About: “Food regulators seize adulterated milk products for food safety violations”

Do you have any questions about this? You are likely to arrive at more conclusions about different things after reading the following information:

“During an FDA inspection of Valley Milk from July – September 2016, FDA investigators observed poor sanitary practices and reviewed the company’s records, which showed positive results for Salmonella in the plant’s internal environmental and finished product samples. FDA investigators observed residues on internal parts of the processing equipment after it had been cleaned by the company and water dripping from the ceiling onto food manufacturing equipment. In addition, environmental swabs collected during the inspection confirmed the presence of Salmonella meleagridis on surfaces food came into contact with after being pasteurized. Throughout the investigation, the FDA worked closely with the Virginia Department of Health and Virginia Department of Agriculture and Consumer Services.”

“These products are not sold directly to consumers, but are used as ingredients in a number of foods such as bakery products. While these milk and buttermilk powder products received extensive testing by Valley Milk and no harmful agents were identified, the US Food & Drug Administration (FDA) has raised concerns regarding the cleaning records for the drying equipment used to produce these products, casting doubt on whether these products may have contained salmonella. Testing by FDA as well as the Commonwealth of Virginia did not identify salmonella in any of these products; however, in order to ensure that its customers receive the highest quality and safest products possible, Valley Milk is initiating this voluntary recall.”

“These products are not sold directly to consumers, but are used as ingredients in a number of foods such as bakery products and distributed by brokers. None of the recalled finished product tested positive for Salmonella but environmental sampling performed by the FDA was positive for Salmonella. Valley Milk is currently investigating the cause for the positive environmental samples.”

If this SQFI certificate was issued following an annual audit, one wonders if the audit found or missed the same things discovered during the FDA inspections from July – September 2016. One also wonders if the SQFI certification is still valid until July 2, 2017.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Sunday, 18 December 2016

Food Import Restrictions

Caribbean Sub-regional Director of the Food and Agriculture Organisation (FAO), Dr. Lystra Fletcher-Paul says Caribbean nations should seriously consider restricting the importation of certain foods once they are in a position to produce healthier substitutes. Is she right?

According to the article by Denis Chabrol in AgriculturBusinesNews October 27, 2016, Dr. Fletcher-Paul reportedly said: We are eating ourselves to death with the imported foods we eat.

If every country takes a similar approach, what will be the likely outcome for the global food market? Related thoughts are presented in this 2013 post on "National Food Safety Programs and Initiatives"

No country is completely self-sufficient. Even for wealthy countries, food import restrictions are bound to limit available varieties of food. 

In some instances, food import restrictions could potentially cost lives. Take, for instance, this June, 2016 Food and Agriculture Organization of the United Nations report about food insecurity in Yemen. One of the reported causes of food insecurity is food import restrictions. War may have a big part to play in this instance but varied are the situations that necessitate global food trade and/or exchange. 

Saturday, 17 December 2016

Honest Trade & Transactions: Genuine versus Mechanically-Sustained “Transparency”

I recently came across a posted article with this caption: “Creating Transparency and Trust in Global Food Chains”
Although the intention of this suggestion is clearly noble, the idea of "creating", an effort-reliant concept, is inconsistent with the concepts of transparency and trust that are character-reliant. Character (such as the honest and transparent character that is under examination) may be developed through practice but there must be a pre-existing disposition towards honesty in order for the development to go in that direction. As such, orchestrated and mechanically-sustained honesty or transparency only works to deceive. A forced exercise of honesty or transparency is a counter-reality to the very concepts of honesty, transparency and trustworthiness.
Even where other people are influenced by the honest and transparent behaviour of another to likewise be transparent and honest, the transparency and honesty are not “created”. These are only kindled in persons who are naturally predisposed to being transparent and honest. Those who are not this way inclined will only take advantage of those who are, and to their own detriment. Contrary to certain deceptive beliefs or assumptions, dishonesty and honesty are often rewarded accordingly.
Transparency is not so much an effort to be maintained in order to gain trust. As soon as it is an effort, it loses its authenticity (and perhaps its genuineness). Transparency or honesty is also not a skill to be learned and performed in order to gain trust. Transparency (i.e. honesty) is essentially a character pre-disposition that leads to behaving in trust-worthy ways that in turn lead to being trusted.
A person or organization that is naturally, characteristically, completely and consistently honest and transparent warrants trust and can be trusted.
For anyone or organization serving the public in any way, the matter goes beyond trust.  A selfless component goes with serving, as do humility, genuine care, etc. The foundation and driving force for all of these is a genuine sense of moral obligation and social responsibility. For honest and trustworthy food businesses owners, managers and workers, the SSQA Concept provides the inspiration to remain naturally genuine and socially responsible.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Thursday, 8 December 2016

What is a successful food safety and quality audit?

The correct answer may be either obvious or a surprise to you. Which do you think correctly describes a Successful Audit?

A. One with few non-conforming findings

B. One with many non-conforming findings

C. One that thoroughly examines against the goal or objectives of what is audited

You may also wish to read about the "Compliance" stupor that is overtaking the food industry.

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

Tuesday, 29 November 2016

Examining Food Safety Certification Promises

A part of this was initially posted as a response to an update published elsewhere. I withdrew that post because I learned from an ensuing conversation that my intentions might have been misunderstood. The intention was and still is completely to help with the articulation of the promises made regarding food safety certification programs. My comments are to be seen as cautionary suggestions, rather than accusations since there are no specifically named parties to accuse. These comments only suggest a close examination of promises made in connection with food safety certifications.

Only Promise What You Can Deliver: 
For anyone promising to certify anything, I suggest as follows:  If you cannot completely (i.e. 100%) stand by, and/or stake your reputation on, what you certify 100% of the time, do not certify. Remember that where such certification relates to what can cause harm to another person, there are legal liability implications for the party granting the certification. If you run a certifying body, this question must be truthfully answered: If you are held legally liable for what you certify, will you still certify it? On what basis will you continue to certify whatever it is? There  are also the aspects of moral obligation and social responsibility to consider. It is fraudulent (although it may be legally acceptable) to grant certification and cleverly, immediately and effectively withdraw the certification in a fine print disclaimer. A genuine sense of moral obligation and social responsibility precludes such disclaimers. It is safer to truthfully, correctly and clearly state and stand by what is actually done.

If such certification promises are made to you, it is advisable for you to check and confirm your understanding of what is promised, and that what is promised is actually delivered. Of course, you must first establish that what is promised is what you need. 
All food businesses must think beyond acronyms, platitudes and the pursuit of empty promises.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Monday, 28 November 2016

CFIA Suspension or Cancellation of Operating Licences and Registrations

Licences and registrations of federally registered establishments or companies can be suspended, cancelled or refused renewal for failure to comply with relevant CFIA Acts and Regulations
View the list of suspensions and cancellations published by 
the Canadian Food Inspection Agency (CFIA)

Saturday, 26 November 2016

Real Food Safety Solutions – The Emerging Wave of Change

The food industry may be waking up to an emerging wave of change. The call for this change has long been made as part of the GCSE-Food and Health Protection campaign. If you have not been following the posts, take a look at this 2013 post about the coming shiftSome of the things predicted are already happening.

In the 2016 announcement about the acquisition of BRC Global Standards by LGC, Mark Proctor, BRC Chief Executive Officer stated as follows:
“I wanted to personally let you know that BRC Global Standards is in the midst of an exciting strategic transition from being a Standards owner to a brand and consumer protection organisation with a range of products and services to help its customers deal with the challenges of producing safe, high quality products for the end consumer on a global basis.” -
It is about time. Perhaps now BRC, under the LGC ownership, would just admit the certification hoax and get out of that business altogether. The same hope is held for other parties that are still blindly captivated by the superficial certification idea.

For a few years now I have been calling on the industry (particularly the third-party certification sector) to stop the “certification” hoax. In its place, I have suggested the provision of real solutions to food businesses. I wonder if LGC and BRC have been listening and this has led them to this announcement of a strategic transition from being a Standards owner to a brand and consumer protection organisation”.

The desire to move away from superficial certification of food safety and quality management systems appears to be growing. Evidence of this desire can be seen in the reported new regulatory direction proposed by the EU in its Food and Feed Safety (30-08-2016) News Report and the UK-FSA's Regulating Our Future: Why food regulation needs to change andhow we are going to do it” that was published July 2017
,the SQFI Recalls data reporting attempt that covered from 2013 to 2015 (although it is a failed attempt at reporting on the effectiveness of the SQF program), and the announcement about BRC transition under LGC ownership.
These pronouncements and attempts are encouraging but the war is not won. The recognition is spreading but the transition is slow and appears to be momentarily stuck in the mud. Amidst loud superficial claims of success that mask the reality-check of whether food has actually become safer, the certification enclave is continuing to enslave many players unnecessarily. Many have failed to realize this fact: A business that cannot do without certification does not have the wherewithal to be certifiable.

The GCSE-FHP campaign against superficiality, misdirected focus, wasted resources and failing efforts at ensuring the safety of food must continue. To beat the plague of superficiality and wasted efforts, the adoption of the SSQA concept will continue to be highly recommended. All parties involved in the assurance of food/consumer safety need to drop the “certification” idea and focus on SSQA-style FORTIFICATION.

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

Saturday, 12 November 2016

Food Safety Training: The Cost of Not Knowing

I have seen it and it is painful to watch. Due to not knowing enough about these things, many people have, and continue to fall for rampant food safety training fraud. 

Many so-called training providers are out there poised to take advantage of desperate and unsuspecting people who are seeking to know more about managing food safety. Individuals and some companies are made to pay outrageous amounts of money for training that offer nothing more than opportunities for the trainers to spew industry jargon. Those "trained" who may not have been previously exposed to the jargon may be impressed. They may learn and speak the same jargon. They may take a few distracting proposals from these training activities back to their operations for implementation. Meanwhile, no real progress is achieved in assuring the safety of food in their operations any more than they were able to achieve prior to the training sessions. 
Here are some typical rates that are charged for short-duration training courses that offer nothing more than the regurgitation of information that is available at not cost:
Basic HACCP 
Special Claim Certification Training (for Organic, Gluten-Free and Similar Programs)
GFSI Certification Schemes training
FSMA-Preventive Controls for Human Food

The prices charged by some training providers may even be higher. What have you been asked or temped to pay?
Did you know that the information provided by some training outfits can be obtained at no cost? Why should the trainers obtain the information at no cost and then make you pay for it? On the other hand, why should you pay for information that you are able to obtain for free from the rightful owners and providers? Prudence demands a thorough search for available (good) information that is either free or cost very little. If you wish to learn more about sources of good training information that cost little or nothing, you could start your search with the sources provided by CODEX Alimentarius Do not buy into fake training. You should understand the essential elements of real and effective training and proceed accordingly.

Essential Elements of Good Training

Real training must go far beyond lecture hall or on-line presentations. For all practical purposes, the best site for staff training and motivation is your operation site. Real training, to be effective, must be fully practical and realistic. It needs to deal with situations that are real to your operation; not the fictitious anecdotes of pre-packaged training. Effective training requires time investment, rolling up of sleeves as it were, getting in the front lines to understand the real and specific needs of your operation, and designing the training that is relevant. Real training involves continuous culture development and changing of wrong beliefs. Clearly, real training cannot be accomplished in a matter of hours or a few days. Real and effective training requires consistent commitment; not sporadic lectures on a sporadic array of topics from sporadic people who are essentially strangers to the realities that are unique to your operation. Some advertised training activities and the prices charged constitute a form of the food industry fraud. 

You need to look past fanciful advertisements with nicely coined jargon that essentially lack substance. You need to very carefully examine what is offered and measure it against the real needs of your operation. If the information promised in the advertised training activity can be obtained at little or no cost from the rightful source, you should obtain that information from that source. Then you should design and implement your training for effectiveness rather than for show. Don't let the purveyors of quick, drive-by and superficial training sessions that are often overloaded with fanciful industry jargon keep your operation on training wheels for ever.

You could seek outside help in designing and implementing the training that uniquely suits your operation but do not pay for any off-the-shelf training that is excessively priced and does no more than rob you of your money and your time. For the individual, the best place to seek training or self-education beyond the initial job entry qualification (typically obtained through formal education) is in and at the job. By implication, food businesses should be providing training in and at the job for their employees. Certain professional certifications may be obtained by individuals from reputable organizations like American Society for Quality and food safety and quality management scheme owners.

Help may be sought from an invested outside party to design and implement training that must become organic (i.e. kept alive and on-going). The "an Invested" is underlined and in bold letters for a reason. Drive-thru training, on-line training or training through the airwaves by people who have vested interest only in the fees paid to them; but not in your operation is mostly ineffective.

. . .now you know & you can take the helm.

You may have questions or suggestions about other available learning opportunities that cost little to nothing. Please feel free to contact me or post your comments below.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Tuesday, 18 October 2016

Allergen Recalls - What is the cause of the problem?

In the News:

The airwaves are abuzz with recalls "due to undeclared" presence of allergens. When you read the notices, the reasons given often start with the phrase "due to . . . " these actually point to the problem; not the cause. We are left with the question: What is the cause of this problem?

First check these twitter posts, and then check to see all of the solutions to the problem that have been published. Here is one from the University of Nebraska: “Allergen Control in the Food Industry

So why are these recalls not abating but seem to be increasing for food allergens that have been long known to exist?

The challenge is expanding in Australia and New Zealand. On 25 May 2017 lupin was added to this list of allergens that must be declared.

Does the SSQA concept have any solution to offer?
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Saturday, 15 October 2016

The Larger Conversation: Video Clips from the Wall Street Journal Global Food Forum

The Larger Conversation
(Beyond the 3rd Party Audits Small Talk)

In this larger conversation, we need real solutions in the matter of ensuring safe, accessible, affordable, sufficient, sustainable, and quality food. Solutions that are partial, superficial and cater only to the wealthy parts of our world should be abandoned for the sake of consumers in all nations, the affluent and the less affluent.

Use Twitter hashtag  #wsjglobalfood; #thelargerconversation
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Tuesday, 11 October 2016

Sensible EU Proposal

In contrast to the generic and highly commercialized 3rd party certification vogue, this EU proposal makes a lot of sense. It is a very good example of cutting nonsense out of the business of assuring the safety of food:

Here is why:
·        It defines the frame of reference as safe food:
These requirements are the key elements to ensure the safe production of food, preventing contamination with biological, chemical or physical hazards . . .”

·        It recognizes the need to customize solutions according to each establishment:
“. . . taking into account the size and nature of the establishment on: . . . the flexibility provided for certain food establishments, in particular SMEs, by EU legislation related to the implementation of PRPs and HACCP).”

·        It identified sensible administrative levels:
at sectorial and national level to be directly applicable in specific establishments.”
Compared to the generic impositions of 3rd party certification programs with requirements that are often irrelevant to specific establishments, this approach is clearly more cost effective. It also promises better results with respect to the production of safe food.

The U.K. Food Standards Agency (FSA) is following suit with a “. . . move away from a‘one-size-fits-all’ approach to regulation”. The Agency states:

"Our purpose is to make sure that people have safe food, food they can trust, and that it is what it says it is. We need to change the way food is regulated in England, Wales and Northern Ireland, so we can be confident this stays the case for the food people buy and eat.”

This FSA statement, as does the EU Proposal identifies the same "safe food” purpose that GCSE-Food & Health Protection (GCSE-FHP) advocates. The FSA statement also recognizes the same things that have been identified as failure-prone food safety regulation and certification arrangements in several GCSE-FHP postings. In particular, consideration 18 of “the motion” essentially calls for what is now being attempted with the EU and the U.K. FSA proposals. Hopefully, these proposals will be developed to full adoption not only by the U.K. and EU, but by other jurisdictions around the world.

Along the same lines, the idea of generic food safety certification schemes need to give way to practical, customized and collaborative pursuit of solutions by and for the food establishments worldwide. Superficial food safety certification, though with flamboyant promotions, have produced much less than stellar results of safe food. Published results from the adoption of the certification schemes mostly show virtual success. Meanwhile, the reality everywhere is that of recurring recalls by many food establishments (including certified establishments) and many health hazards suffered by consumers.

The U.K. FSA is proposing ". . . a model that continues to use inspections and visits alongside the information . . .” gained . . . “from business’s data and accredited third party audits. . .”. For at least three reasons, I would change “accredited third party audits” to “credible audits conducted by any party (including the internal audits of the establishment)”. 1. A third party is not necessarily credible because it is accredited. 2. Third party audits often involve additional costs to establishments that may not be necessary. 3. The thought of having third party audits is usually due to lack of trust. If the U.K. FSA proposal is to truly succeed, it must be pursued in an environment of full collaboration and trust among all parties involved.
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Sunday, 9 October 2016

Food Fraud: A 2-Question Quiz

1. The Motive is the Cause of Food Fraud: Is this statement true or false?

      A - True

      B - False

2. Which would you say is the Root Cause of Food Fraud that incorporates the rest of the listed options?

      A - Economic Gain

      B - Lack of Integrity

      C - Lack of Moral Commitment

      D - Inconsiderate attitude

      E - Lack of Knowledge

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