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Friday, 25 March 2016

Report Your Food Safety Concerns


Canadians Report your concern:






In the United States Report your concern:


In the U.K. Report your concern:

Further to the blog post - The Merits and Pitfalls of Engineered Focus in Product Safety Assurance

Many people in the food and health products industry (professionals and non-professionals) have been conditioned to think narrowly about product safety. Only a few are able to escape from the narrowly engineered focus and think freely? An example of the engineered focus is the usual understanding about what constitutes a safe food product. Some people may be able to think beyond the definition of a safe food product as that which is free of contaminants (biological, chemical, physical and other agents that cause unhealthy reactions such as allergens, and sensitizing agents). The majority of people do not think of food safety beyond this scope.

This could very well be an unproven hypothesis. So, let’s put it to the test. Responses to this post will prove or disprove the hypothesis. Here is the challenge: Do you know of anything that is left out in the definition of a “safe food product” as provided above?

You may read the comments posted in response to this question on LinkedIn: 

Wednesday, 16 March 2016

The SSQA 10

Moving beyond paper-based systems to a higher level of eased burdens, increased efficiency, reliable effectiveness and desired consistency. . . 
At least 10 things that adopting the SSQA concept does for a food business through the adoption of its strategies (ENTI-CE, Team-MATES, CARE, FACTS): 


1. Encourages an operation’s commitment to ensuring consumer safety security and satisfaction;
2. Encourages an operation’s commitment to ensuring that employees are properly trained, empowered and are committed;
3. Encourages the direct contribution from, and involvement of, front-line personnel;
4. Promotes the "rolled-up-sleeves" type of cooperation and collaboration through the entire supply chain from production to utilization; including full and strategic collaboration with regulatory agencies and ancillary service providers.
5.   Encourages open and active communication;
6.   Promotes chain-wide interaction in the identification and mitigation of risks;
7.   Requires clearly assigned responsibilities for the maintenance of controls;
8.   Calls for contribution to, and involvement in, problem solving and continuous improvement actions through the entire chain from production to utilization; with full participation by regulatory agencies and ancillary service providers.
9. Encourages operations to actively seek consumer feedback (positive feedback and complaints);
10. Makes provisions for on-going measurement and tracking of effectiveness through friendly scrutiny with implemented continuous improvement protocols.
http://gcse-food-health-protection.blogspot.com/2014/02/the-ssq-adventure-for-fearless-guardian.html




The SSQA Vantage Point 
Introduction Video

Tuesday, 15 March 2016

Subduing the Attitude of Surrender in the War against Food Fraud

Responding to the LinkedIn article by Dr. Sylvain Charlebois (see the full reference link below), I provided this comment:
 “ ‘ . . eliminating food fraud will give the entire food industry a chance to become more sustainable...’ This is a very hopeful statement. Some think that a complete elimination is not possible, that only a reduction to an acceptable level is possible. But what is an "acceptable level" of fraud?  I subscribe to the school of thought that recommends a complete elimination goal through continuous reduction strategies whereby every effort is made to retain conquered territories. The work may never be done but it is not to be pursued with a resignation of hopelessness. I also see the futility of fighting only the symptoms (specific instances of committed fraud) instead of systematically tackling the root cause. The SSQA concept provides such a systematic approach based on some basic facts, realities and dynamics that are both known and seen to be at play. . .”

This blog post, though it expands upon the comment above, only introduces the SSQA approach. The GCSE-FHP SSQA fraud prevention approach involves a commitment to: “. . . subduing the attitude of surrender and harnessing the power of positive influence” [SSQA Development and Implementation Manual,Section 2.4.7]. 

The role of regulatory and law enforcement agencies in the war against food fraud is recognized with the SSQA concept but it places the onus largely on the individual food companies. The use of emerging scientific and technological developments in fraud detection is also recognized. The main SSQA focus, however, is on systematically attacking the root cause of fraud. 

Detecting and dealing with fraud perpetrators have their place but the premise of the SSQA approach is this: Fraud would not need to be detected if it was not committed.

While the SSQA fraud prevention approach reflects the understanding that the food fraud war cannot be won on paper, it emphasizes that the war can be won. As reflected in the commitment statement, the SSQA approach clearly rejects any sentiments of surrender. Where SSQA is implemented, there is no yielding to a presumed inevitability of food fraud in the same way that crime is presumed to be inevitable in many societies.

SSQA implementation also goes along with the understanding that a war that is partially waged against an evasive enemy cannot be won. Hence SSQA fraud prevention principles are implemented with the determined intention of winning the war on all fronts. Pursuits with expectations of only partial success are regarded to be pointless under the SSQA approach.

A detailed explanation of how to actively pursue the stated commitment is provided in the SSQA Implementation Manual, Section 2.4.7. The key differences between crime (including organized crime) and food fraud provide the basis for the optimism that the war against food fraud can be won. These differences are explained along with strategies for harnessing the de facto positive realities and dynamics already at play in many companies. One of the pre-existing advantages explained is that many people withing the industry are already more pre-disposed to doing the right things than otherwise.

Part of the SSQA Manual explanation also points out that resources need to be efficiently channelled into fighting the real enemies instead of shadows or the “volcanic eruptions” as one of the other post puts it. The futility of fighting only the symptoms is perhaps the cause of the hopelessness that is often expressed by some well-meaning people. At best, only a temporary reprieve can be achieved with sporadic band-aid solutions. There may be many cores at different depths wherever fraud perpetrator operate but getting to the core of the problem in each instance gives greater hope that this war against food fraud can be won.

References:
  1. Charlebois, S., Dr. (2016, March 15). The Food Authenticity Killers. Retrieved March 15, 2016, from https://www.linkedin.com/pulse/food-authenticity-killers-dr-sylvain-charlebois
  1. Global Consumer Protection SSQA Development and Implementation: A Manual for the Food Industry [PDF]. (2014). Mount Forest: A.F.I.S.S. Website: http://www.afisservices.com/gcse-fhp/SSQAFullManual.html
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, 9 March 2016

GFSC 2016 Beyond the Fancy Talk: What exactly is GFSI contributing “Towards a world in which safe food is truly accessible to all”?

Have you read the GFSC 2016 Round-Up? A link is provided below.


Even the astute can be swept away to unintended places by euphoria. 



I did not expect the most crucial elements of global food safety management and concerns to be adequately covered during the GFSC 2016 and I wished to be proven wrong. I did not attend, so I'll ask those who were there. Did you hear anything about plans to address global inequality in food safety assurance? What perception did you take away from the conference about how GLOBAL the Initiative really was? Never mind other practical difficulties faced by the less privileged parts of the world, are even the certification schemes truly accessible to ALL? Did you hear anything at the conference about how the Global Food Safety Initiative certification schemes were going to be administered in the future among the less-privileged groups in the global community?

When the “GFSC delegates were called upon to ‘make the change’ towards achieving the global food safety vision”, what exactly was meant by this call? What change and how? Was a re-focus for GFSI considered? As I have challenged in the post Where Water is Goldwhat is the Global Initiative doing about these situations that are counter to assuring the safety of water and the safety of food? Addressing such situations has never been the intention of the GFSI may be the argument. What exactly then is the GFSI intention and the intentions of conferences like the GFSC 2016. Is an incomplete provision of needed solutions the intention? Is the global community to be content with GFSI solutions whereby assessors go to places that can afford to pay for the assessments while other places that also provide food for the global community struggle along?

It is easy to be caught up in the euphoria while in shiny conference halls. Once outside of the halls, we find that the realities are not as rosy and euphoric as the presentations. Perhaps there was some recognition of this fact in this Round-Up comment: “GFSI has achieved many things in its 15 years but it has not created a zero risk environment. Risk has an unfortunate and unwelcome offspring called crisis, which will always be a part of the working life for many of the delegates.” What exactly are the “many things” that GFSI achieved? Being a Global FOOD SAFETY Initiative, do any of the many accomplishments include any quantifiable reduction in food safety failures around the globe? If not, has it been a failing initiative and will the GFSC 2016 provided any hope that such reduction will be tracked and reported?

Amid the euphoria expressed in the GFSC 2016 Round-Up, some assumptive conclusions may have been drawn as reflected in this comment: "The message from the regulators was clear; certifications to schemes recognised by GFSI are now considered in their risk assessments. It appears that the message from the regulators was not sufficiently clear. The intention of including this statement in the Round-Up is obvious. It aimed to ascribe a unique consideration, presented as if there had been regulatory sanction, of "certifications to schemes recognised by GFSI". In my search, I have not found any regulators that have unequivocally sanctioned these certifications. Even if that was the case, evidence shows that such a sanction would be a serious mistake. The acknowledgement that "GFSI . . .has not created a zero risk environment. . .clearly supports the caution against such a regulatory sanction. It is time we moved beyond these kinds of assumptive inferences that merely mask realities. Rosy claims about third party audits and certifications have often been called into question.

Recommended Re-direction of Focus:

I propose a revised focus of the Global Food Safety Initiative. I propose a focus that turns from certification schemes to practical solutions. Let’s have a GFSI that provides the know-how to places with poor water supply for the development of sufficient potable water resources. Instead of the development of more assessment schemes, let GFSI get involved in the actual development of scientific and technological solutions to help food operations. In short, instead of making operations pay for certification audits and certificates, let them use that money to obtain tools and needed operating resources.Instead of the current hands-off mode of merely criticizing or praising the performance of operation based on generic audit templates, let GFSI actually roll up its sleeves and help operations in providing answers to challenges that are unique to each operation. Let the technical know-how within the GFSI be put to practical use (hands-on). The GFSC 2016 Round-Up, as much as I have seen, did not provide any statement pointing in this direction.

GFSC 2016 Round-Up: http://www.mygfsi.com/news-resources/news/476-gfsc-2016-round-up-the-food-safety-journey.html
Posted by Felix Amiri
___________________________________________________________
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

Tuesday, 1 March 2016

CODEX: International Guidelines for Monitoring the Performance of National Food Control Systems




What do or should these CODEX initiatives mean for international food trade? What should these initiatives mean for local and international food businesses?

Benefits to Participating Countries

The U.S. is a key contributor to the CODEX National Food Control Systems (NFCS) initiative, yet FDA appears to be ignoring it in the Foreign Supplier Verification Programs (FSVP) under FSMA - http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm361902.htm. Little is said about NFCS in the proposed FSVP rule if it has even been mentioned or considered.

In the Globe and Mail report of Mar. 01, 2016, the U.S Agriculture Department gave the Canadian Food Inspection Agency until mid-March to fix significant food safety and sanitation concerns found during an audit of Canada’s meat, poultry and egg inspection systems.

In a news release as far back as November 20, 2014, Canada was said to rank first out of 17 countries (including the U.S.) on food safety performance. So which observation is correct, or what has gone wrong?

With a common frame of reference that CODEX will be able to provide for assessing the acceptability of food shipments among countries, one can immediately see the value of the CODEX Guidelines for Monitoring the Performance of National Food Control Systems. Even in the example of the spat between the U.S and Canada, the usefulness can be seen. The U.S. and Canada are identified as participants in the CODEX initiatives. The benefits will predictably spill over to local and international food businesses within the participating countries.

Re-direction of Focus and Elimination of Wasted Resources for Food Businesses

While the kinds of wrangling between nations as reported between the U.S. and Canada take place, food businesses that cannot avoid being caught in the crossfire remain buried in the redundancy of private certification schemes. Clearly, food companies need to wake up and smell the coffee. The real battles are being fought on fronts where private certification schemes have little if any effect beyond forced and fictitious claims.

The truth cannot be more clearly exposed. Private certification schemes do not carry the force of law nor do they currently serve any arbitrator role in resolving cross-border trade wrangling as exemplified in the Canada-U.S. example. In fact, the respective country’s regulations rightly grant only a limited credence or acceptability to private certification schemes as presented in the FDA FSMA comments on GFSI  and the CFIA policy on private certification.

Where it really matters, private certification schemes also do not seem to have any quantifiable and verifiable results that show any significant reduction of product failures. They certainly do not provide litigation reprieve when illness is the onlyproof required.

The argument about the acceptability of private certification schemes as the savior of international trade is getting further weakened as CODEX pursues its initiatives with the CCFICS  and the NFCS.  Empty claims are frequently made about the superiority of private certification. In reality, the certification process distracts and places the burden of wasted resources on food businesses due to the unnecessary duplication of requirements already imposed by regulations. This reality belies any assumptive conclusions about the synergy that exists between regulations and private certification schemes.

It has been reported that private certification will grow to $19 billion plus by 2019. This makes it very attractive to prospectors who would almost defend the merits of certification with their lives. Given the demonstrated redundancy of certificates, one can easily see the gains to be made if the $19 billion were to be used for fortification programs instead of certification schemes.

Conclusion:

A common ground for monitoring the performance of national food control systems provided by CODEX, a body that is internationally recognized, and with the direct participation of the nations involved is much needed. It should prevent unproductive and often baseless international wrangling.

Food businesses also have much to gain from the CODEX initiatives. They will suffer less cross-fire casualties. Besides, the initiatives provide the opportunities for food businesses to optimize the use of their resources in pursuing profitable regulatory and scientific solutions instead of wasting such resources in pursuing superficial certificates. It is not s secrete that current certification schemes merely regurgitate CODEX guidelines anyway. They may use other sources that are also already available to food businesses. Information from these sources are merely put together by the schemes and used for their pre-occupation with offering no more than criticisms. These schemes (under the guise of avoiding conflict of interest) refuse to get involved in providing real and practical solutions. 

Food businesses need to simply focus on fortifying their food control systems according to the emerging CODEX guidelines and the applicable national regulations. These, along with the specific scientific and technical knowledge that applies to each operation, provide adequate technical and management information to make private certification redundant.

Private certification is already of little to no consequence in less privileged parts of the world. Yet food comes to the more affluent part from these less privileged regions. This calls for a different mobilization in addition to the Codex CCFICS and NFCS initiatives. It is the mobilization against inequality. It is the mobilization of collaboration where more affluent nations provide financial and technical assistance to the less privileged.

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