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What are your biggest challenges in compliance management?
What are your biggest challenges in safety management?
In what way are supply chains affecting food safety & quality?
To what extent does advanced technology play a role in your food safety program?
To what extent are budgets constraining food safety & quality improvements?
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Your food safety auditing stories
About 30 years ago I wrote a paper for a conference called "red pens and red herrings". We used to get audited by a couple of UK supermakets. The auditors they sent were fresh out of college and we had no problem dealing with the questions and we always passed. However we never got the business - it always went to a cannery just down the road that at the time had no roof ................
As we look to advance auditing it would be really good to get some auditing stories from "the front line" so tell us your auditing stories, for example
1 - What's your experience with sites performing true CAPA for audit findings and preventing the recurrence of findings in subsequent audit
2 - What challenges have you faced during audits, and how did you overcome them?
Time for an honest conversation about auditing
The standards against which food companies are audited are constantly being up-dated, the number of audits being carried out goes up and yet so do the number of recalls. This is probably well illustrated by a recent Listeria incident in the US where a facility had been audited numerous times, significant findings made, and yet the facility continued to operate and again in the UK where a local branch of a well known supermarket chain was operating with known hygiene violations.
I believe when carried out properly audits can be a useful tool and help drive up food safety. What I have a problem with, however, is people not recognising the limitations of the current approaches in food safety auditing and failing to have an honest conversation about how they can be addressed.
So something is going on and it's time we had an honest conversation about it.
Audit Fidelity
Are you a supplier receiving multiple audits from your customers? If so why do you think that is?
Intersection between Food Safety and the Green agenda
In the previous piece in this series on Enterprise Risk Management (ERM) a question was asked as to whether your company is using ERM to manage the intersection between Food Safety and the Green Agenda.
The FAO has indicated 5 ways climate change (rising temperatures) can impact on Food Safety:
Increase food and waterborne diseases
Increase uptake of toxic heavy metals in staple crops
Increase spread of fungal infections
Increase spread of plant pathogens driving an increase in pesticide use
Increase harmful algae in sea food
But are there other ways that companies response to addressing the Green Agenda may impact on Food Safety. The answer is yes: many years ago, and in an early attempt to do the right thing in terms of the environment a multinational food company switched to using recycled cardboard for its outer packaging. The unintended consequences was the unexcepted migration across the plastic inner packaging of unlooked for chemicals present in the recycled cardboard. When the issue was discovered and reported by NGOs it resulted in large and expensive recalls and significant damage to the company’s reputation, even though the intentions were undoubtedly good.
The answer to the question – can you use ERM to manage the intersection between Food Safety and the Green Agenda – the answer is yes. So the answer to the question – should I be using ERM to manage the intersection between Food safety and the Green agenda – is also yes.
The method/process involves identifying what are the main areas where the Green Agenda will impact your supply chain (e.g. water use, recycled packaging, changes in agricultural practice including reduced pesticide use and regenerative agriculture) and identifying the potential impact of these changes on the know hazards (microbiological, chemical, physical). The final steps are then identifying the correct risk response (avoidance, reduction or acceptance) and setting the correct monitoring.
Questions
Which of the following elements of the Green Agenda are likely to impact your business´s food safety controls – Energy use reduction, water recycling in agriculture or manufacturing plants, regenerative agriculture, reduced plastic use, reduced sanitiser use, packaging recycling?
Will the consumer accept lower levels of food safety as part of a company response to meeting is sustainability objectives?
Is your food safety budget increasing to help meet the increasing complexity of meeting both the food safety and sustainability commitments?
How well do you believe your companies senior execs and Board understand the impact on Food Safety of meeting sustainability commitments?
I'd love to hear other FSQ Network members' thoughts in this thread.
Enterprise Risk Management
Kimberly, Nico and I have shared a brief overview on Enterprise Risk Management here, and we'd be very interested to hear everyone's responses to the following questions.
Is your food company using ERM and if so, does the ERM process include food safety?
Is the process annual or more flexible to deal with evolving risks as they occur?
Does your company use external reports like the World Economics Forum risk report as input into the ERM process?
What are the KPIs and do they focus narrowly on number of audits, audit scores, recalls, or do the KPIs reflect the big areas of risk such as water availability, international conflict, and the intersection between food safety and the green agenda?
Is there somebody on the companies Board who really understands the food safety elements of risk and can interrogate whether they are being managed, ensuring learning leads to prevention?
Please share your thoughts to any of the above questions in this thread - looking forward to hearing from you.
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Co-incidence - I have just finished writing a presentation for the up-coming EFFoST conference. Building trust is everyone’s responsibility. That means all stakeholders, Regulators, Scientists, Industry and NGOs; and we as individuals all have a role to play. Trust in the whole is the sum of the integrity of the parts – your integrity
Dear All - I have received from Erica Sheward GFSI Director some clarifications around the GFSI discussions in the recent auditing roundtable which I am sharing below for you to digest and share your thoughts on - I hope you find them helpful.
They are her comments and she has asked me to pass them on.
From Erica Sheward GFSI Director. They are her comments and she has asked me to pass them on.
Dear All - I am very happy to see this group discussing auditing and also delighted to see such a constructive debate which I would very much like to encourage to continue.
I have some clarifications around GFSI that I need to add and I hope you find them helpful.
1/ There is not in fact a GFSI standard - There are GFSI Benchmark Requirements which the Certification Program Owners (CPOs) use to develop their standards. The comment around lack of flexibility of the GFSI Standard is therefore difficult to understand. However I do agree that it is debatable as to whether strict adherence to checklists is the best way of delivering rigorous audit outcomes.
2/ The comment in the document about auditors not always having the technical knowledge matching the processes being employed at the food facility and the suggestion that auditors experience should match the facility being audited should be addressed by our up-coming Auditor Technical Professional Development program (ATPD) - at least for 3rd party audits carried out under GFSI recognised programs. More on this will be announced at the conference in Dublin.
3/ I found the question raised about root cause analysis and the link to pass/fail audits extremely interesting. It would be an interesting debate to look at this in more detail at least from the point of view of 3rd party audits. I strongly support the sentiment around the desire to promote learning from and resolution of issues with the goal of prevention.
Wishing you all the best and I hope the debate continues and hope to see some of you at GFSI.
Building on the discussion and a topic I will be addressing at the up-coming Food Sure Summit in Madrid - The Intersection between Food Safety and the Green agenda
In the previous piece in this series on Enterprise Risk Management (ERM) a question was asked as to whether your company is using ERM to manage the intersection between Food Safety and the Green Agenda.
The FAO has indicated 5 ways climate change (rising temeratures) can impact on Food Safety
But are there other ways that Companies response to addressing the Green Agenda may impact on Food Safety. The answer is yes: many years ago, and in an early attempt to do the right thing in terms of the environment a multinational food company switched to using recycled cardboard for its outer packaging. The unintended consequences was the unexcepted migration across the plastic inner packaging of unlooked for chemicals present in the recycled cardboard. When the issue was discovered and reported by NGOs it resulted in large and expensive recalls and significant damage to the company’s reputation, even though the intentions were undoubtably good.
The answer to the question – can you use ERM to manage the intersection between Food Safety and the Green Agenda – the answer is yes. So the answer to the question – should I be using ERM to manage the intersection between Food safety and the Green agenda – is also yes.
The method/process involves identifying what are the main areas where the Green Agenda will impact your supply chain (e.g. water use, recycled packaging, Changes in agricultural practice including reduced pesticide use and regenerative agriculture) and identifying the potential impact of these changes on the know hazards (microbiological, chemical, physical). The final steps are then identifying the correct risk response (avoidance, reduction or acceptance) and setting the correct monitoring.
Questions
1/ which of the following elements of the Green Agenda are likely to impact your business´s food safety controls – Energy use reduction, water recycling in agriculture or manufacturing plants, regenerative agriculture, reduced plastic use, reduced sanitiser use, packaging recycling?
2/ Will the consumer accept lower levels of food safety as part of a company response to meeting is sustainability objectives?
3/ is your food safety budget increasing to help meet the increasing complexity of meeting both the food safety and sustainability commitments?
4/ how well do you believe your companies senior execs and Board understand the impact on Food Safety of meeting Sustainability commitments?
All: good discussion topic! My answer and comments below :
1 - yes
2- at least two times a year with a leadership team to review progress, and one owner per risk to ensure progress and execution of agreed actions
3 - not really, however they have assessed the process with consultants
4- each risk has a template with objective, team members , actions, etc. This also includes KPI’s for each risk. Food safety includes audits, complaints and plant risk profile. New and proactive KPIs such as program implementation %
5- partially. They assess compliance .. some FS knowledge
comments: a proactive approach is needed. For instance, we should Measuring : CAPA closure % and its effectiveness, culture and behaviors, FS capital approval and execution. Technology to track execution, maturity of the programs is key
Hi Hugo - I agree we need to move towards more proactive approach looking at the KPIs - Going forward I am convinced we need to move away from looking at food safety in just terms of compliance. I would also add that the best dialogue will be with people who have been practitioners in the field.