Consolidation of food safety standards benefits everyone

‘The key reason for investing in management systems and the related certification should be business improvement and compliance to legislation’, says Jeffrey McDonald, Executive Vice President, SGS Systems & Services Certification. FS talks to him about his support for the consolidation of food safety standards and how they will benefit stakeholders within the industry, along with a discussion about the necessity of simple public awareness campaigns to explain what the EU commission is doing to enhance food safety.

FS. Can you outline the current major issues food processors and manufacturers face when it comes to carrying out food safety auditing and certification in the EU?

JM. A major issue that a lot of food processors in Europe face is what to do in an ever changing environment. With the number of recent food scares along with evolving regulations there continues to be a lot of confusion in the market. With the major changes in the European food regulatory framework organizations, such as the Food Safety Association are trying to assist and have produced guidelines for organizations to better understand how to comply with legislation. Besides the regulatory environment there are also a range of standards that exist for food supply chains and the critical areas, such as primary production, processing, production, manufacturing and retailing. The existence of multiple, often parallel standards such as HACCP, EUREPGAP, GMP, IFS, and BRC, to mention a few have added to the confusion as producers are pressured to implement specific standards by different stakeholders. Compliance to different standards with several audits and the adherence to evolving legislation have added to that. Just understanding what is relevant to which organizations can be challenging enough as the EU has some of the most stringent legislation in the world.

FS. What are the biggest challenges faced by SGS in delivering its inspection and certification processes?

JM. As a certification body, the biggest challenge we face globally is being able to ensure we have a sufficient number of auditors for multiple certification programs. Delivering certification in more than 100 countries even for a common standard, such as ISO 9001 requires training along with the calibration and interpretation of auditors. Besides knowing the standard, the auditors also need to understand all the associated legislation as majority standards require compliance to it. Being able to deliver a correctly compliant service to our customer whether they are in Panama or the UK or in any other place in the world has many challenges.

FS. Have any new techniques or developments improved your ability to carry out accurate and reliable auditing?

JM. Probably the single biggest initiative that could assist certification bodies in carrying out more accurate and reliable auditing is the recent development and the release of the ISO 22000 Food Safety Management Systems standard. The comprehensive ISO 22000:2005 standard includes the most of the requirements of all the major food standards. It covers a wide-scope of activities while also contains requirements on continuous improvement.

The challenge with reference to any industry consolidation under a specific standard depends on the actual support and recognition received from the industry.
Early trends tend to suggest, though that producers or the suppliers of food products are very much supportive of the standard. For many, having to comply with multiple standards means significant amounts of redundancy. What suppliers recognize is that the ISO 22000 standard covers all the areas within the supply chain. It also requires compliance to all relevant legislations from primary producers to retailers and includes satisfying clients’ requirements for legislative compliance being dependant on the countries that the products are being exported to. For all producers it allows streamlining the whole process.

SGS issued its first ISO 22000 in November 2005. Why was the standard introduced, and what impact has it had on the food industry so far?

We’ve issued over twenty ISO 22000 certificates until now. We are currently working with some of the major food producers and manufacturers for ISO 22000 implementation and we expect that there will be pressure for these producers to cascade the standard down throughout their supply chain throughout the world. Because of the support from producers and manufacturers, there is a lot of discussion at the retail level. Some of the smaller retailers are saying they will accept it, but some of the big retailers continue to stay behind more specific retail schemes such as BRC and IFS. If you read through the ISO 22000 standard it really does cover all the requirements of all the other standards, and more. It does include the overall focus on improvement which a lot of the other specific food standards don’t necessarily cover.

Complying with standards can be a financial burden on those in the food industry. Would you agree with this and what strategies would you advise to help mitigate these costs?

Complying with any management system standard requires some financial investment. The financial investment required is in acquiring the relevant knowledge of the standard’s requirements and then how to adapt and design processes and systems to be implemented to meet all of the requirements. The compliance to such standards is thus a two-step process. First, people need to be trained so as to be able to document, design and implement new systems. This can take in some cases up to 12 months or longer, and often organizations select experienced consultants to assist them. Once systems have been implemented, organizations carry out internal audits and checks to verify compliance and identify and implement corrective actions where gaps in the system are identified. The second step is audits conducted by an independent, third-party certification body. Key objective during these audits is to check that the organization’s management systems are compliant to a specific standard. Once an organization has passed this final step, a certificate is issued and regular surveillance audits are carried out usually annually. The actual cost of the final audit is a much smaller percentage of the overall cost than the investment in establishing and implementing the systems. The majority of standards that require things like management review, internal auditing, specific programs for corrective and preventive action focus on an overall quality assurance. The purpose is to prevent problems from happening before they are found either by the customer, or at the end of the inspection or testing line that an organization may be utilizing.

The biggest challenge though is how to quantify the benefits of having compliant management systems. Many organizations do not measure the return on investment from such an exercise, hence these activities are easily seen as a cost.

How to mitigate these costs? An organization really should be measuring the overall efficiencies or the cost of their production prior to implementing a standard. They should not simply be implementing a standard to meet a standard requirement, but more to implement a standard as business management tool. This is true of ISO 22000, ISO 9000 and a whole range of other standards. The first reason for implementation of any management system standard should be business improvement and to adapt and go beyond what the requirements are where there are additional benefits to be gained within the organization. The other component would be to use these standards as tool to ensure compliance to legislative requirements. A standard such as ISO 22000 for the food industry does have a broader appeal than many other more specific standards such as IFS and BRC as it does cover the many of the requirements of these other standards. Specific retailers probably would argue though that their programs have been specifically designed to meet their requirements and requirements for the supply chain hence are better positioned to meet their specific requirements. The organizations who are then challenged are the suppliers who may have to implement a variety of different standards and have these certified to meet the needs of their customers – the retailers.

There are two aspects – implementing a system as a business tool and not simply to meet the requirement of a piece of paper or a standard, and also to select broad-based standards that cover and have acceptance rather than focusing on getting a certificate which is perhaps just meeting the specific requirements of individual clients. Unfortunately, as producers are required to get the piece of paper as evidence of standard compliance hence they seek the quickest and the easiest way out which undermines the whole objective of the standards.

A recent poll conducted by the European Commission and the European Food Safety Authority (EFSA) revealed that two-third of Europeans think that EU food safety laws are strict enough, but less than half consider they are properly enforced. Would you agree or dispute these findings?

In my experience as a food safety auditor, many organizations (even prior to a third-party audit) will tell you up-front that they meet all the requirements, and that the only reason they are getting a third party in, is just to get a piece of paper. Nine times out of ten an auditor with good knowledge will go in and find areas that do not comply with their own systems and policies or with legislation. Hence, the process of implementing management system standards does assist in the enforcement of legislation. Compliance to the EU food safety issues is the same as compliance to any legislation; it is something that needs to be policed. In any industry and even in the best organizations in the world with the best intensions, you always find non-compliances with legislation. Hence, management systems and independent auditing has a real role to play in the industry. Not only in policing legislation, but to ensure that some of the common sense things within the food industry are actually being adhered to. It also gives organization another aspect on what they are actually doing. They might think what they are doing on a daily basis is compliant, but having an independent person come look at it gives them a different view.

Do you think there is a need for the public to be made more aware of EU food safety legislation including its aims and achievements?

Yes, but how to go about doing this is more the question. Recently there have been a lot of food scares and issues within the EU. I’m sure if you asked the general public what sort of food standards were in place most wouldn’t know. There needs to be some kind of realistic education program to explain what the EU commission is doing as far as this goes, but not to run on a specific scare campaign. The other side of it is that if you go on the internet and do a search in EU food legislation you find plenty of complex directives. Basic, simple awareness campaigns for the general public would go a long way.

Food regulations in the EU have been criticized for being overly complicated, and many are calling for them to be simplified. Would you agree and, if so, is enough being done to achieve this?

I believe that the regulations in the EU are extensive. However, we have to consider the population and the densities within the EU. We must also consider factors such as the existence of open transport in the country for livestock etc. I think it is unlike any another region in the world. Hence, I do think you need a level of control. Any food problem or outbreak in one specific area in the EU, if not controlled or policed directly, could quickly spread throughout the continent. There are many new member states in the EU, and some countries do not have developed mechanisms to deal with food safety. I do think a high level of legislation and requirements in such an area like the EU are necessary. However, I also think things can always be simplified. I think what the EU was trying to do under the European Union Food Safety Association and through the European Commission was to get one main body to oversee food safety legislation in the EU. In the US, the FDA is responsible for some parts and the Department of Agriculture responsible for other parts. However, there aren’t as many challenges in the US – the US isn’t growing as fast and doesn’t have boarders being opened as extensively for trade and for commerce.

How are regulations likely to change in the future, and how are the changes or trends likely to impact on both companies such as SGS and your customers?

I don’t know in large detail how regulations are going to change. What seems to be quite clear, however, is that governments are going to continue to support food standards. They are structured in such a way to ensure that organizations comply with those standards and meet the safety and legislative requirements for that particular region, and areas where they export to. It essentially satisfies the interest of the stakeholders as in any country these groups have an interest to make sure legislation rules are being adhered to. One of the areas that SGS will focus on is the continual training and development of our auditors. We also offer training courses to our customers.