Whenever there is a major crisis, there are learnings and opportunities, whether it be war, civil disaster or as we are now experiencing, a global pandemic. Andy Kerridge is Vice-Chair of the IFST’s Food Safety Group and runs his own food safety consultancy. Below he provides his expert opinion regarding the opportunities for improving food safety assurance processes.
“Out of adversity, comes opportunity” ~ Benjamin Franklin
This quote attributed to Franklin, crystallises the situation I think we have at the moment. Undoubtedly, we have adversity with tragedy and economic stress, but we are also seeing people adapting and innovating – and despite what we have heard about the innovative food fraudsters, the majority of the innovation is good.
The old ‘System’
In terms of the food supply chains and assurance, I think it is obvious that the GFSI and the various standard owners were caught unprepared for what the pandemic would mean in terms of audits and supplier assurance. We had a brief appearance of remote or desk audits from one scheme owner, but then that was not allowed and we were offered certificate extension instead; then another scheme owner did not allow certificate extension and left the decision to the manufacturer’s customers. Now it seems that the GFSI has made some progress towards allowing remote audits. Let’s be clear – remote audits, and the technology around it, were possible before the pandemic and have been for some time, it is just that the pandemic has brought forward adoption of what was, maybe for the last ten years, already out there, but the ‘System’ simply had not allowed for these technologies or was not able to keep pace with them.
So, where do we go now?
Once auditors are ‘allowed’ on sites, we could go back to the way things were before, but I think that is unlikely. The door has been opened on technology and remote monitoring of some sort, and we can therefore (somewhat grudgingly it seems) accept remote audits as part of the new way of doing things. But that is not all. This as an opportunity to ask, “what do we want to achieve with assurance, and how do we do it?”
I think most people involved in the food supply chain will agree that today we are some distance from the ideal. When we started with EFSIS and BRC all those years ago (the first BRC standard was 22 years ago), the aim was to stop the duplication of retailer audits. One standard accepted by all, but then it became two standards, then three, and now it is up to six depending on the sector. ‘Accepted by all’ is also demonstrably not true, with some sites having 20 or 30 (or more) audits a year.
Of course, not all audits are by retailers; some are enforcement, some are foodservice and some B2B. Sites now employ staff specifically to deal with audits. When you add in the time taken for opening and closing meetings attended, often (rightly) by up to 10 staff, as well as other staff involved during site tours and the traceability exercise, an audit is a substantial drain on site resources. Doing it once a year is one thing, but doing it 20-30 times or more a year is surely not the right way?
To make matters worse, a number of these audits cover very similar ground, with some actually being a copy/paste of the GFSI benchmark standards, and others have large sections that are identical. How many times do we need to look at a pest control contract or a cleaning schedule? Don’t get me wrong, non-conformances are found; but are they really that significant in the greater scheme of things? Most of these additional audits are, to be honest, ticking boxes for the people requesting them and we all go along with it. Let’s remember that horsemeat was not found by audit, neither was melamine in milk.
Auditor numbers, motivation and calibration
We then have issues of auditor numbers, auditor motivation and, inevitably, auditor calibration. The GFSI audits are getting more complex and longer, but there is not time during such an audit to follow suspicions. I remember someone saying that they had worked out that the time allowed for a BRC certification audit meant about 2.5 minutes per clause – you cannot do much more with these 2.5 minutes than simply look and report.
Passing is the aim, but what about the rest of the year?
Lastly, there is too much emphasis on passing and grades. Technical managers boast on LinkedIn about their achievements getting sites through another XYZ audit – is that what this is all about? What about the other 360 or so days of the year?
So, with all this, do we just fix these issues, tinker with the edges so to speak, or do we do as we require sites to do when producing non-conforming product (and I submit that our current way of assurance is non-conforming product); i.e. a root cause analysis, dig deep, and then dig even deeper again into why these issues are occurring?
Time for a fresh start
Root Cause Analysis is one way, but that assumes that the basic underlying system is the right one, and I don’t want to make that assumption. I prefer and recommend that we start from a blank sheet of paper and build up what the desired way of assuring safety and quality and compliance and so on, would look like. Inevitably, elements of what we have today will be used.
But, if we start with a blank sheet of paper and build up, the end result will not be where we are today, I am sure. And of course, I do not have the answer, but I have some ideas – thinking along the lines of continuous assessment rather than all being on one annual ‘exam’. I still absolutely see a place for an independent site visit, but that is only part of the process, and should not be the whole process.
Collaboration is a necessity
If we asked the question to all the stakeholders, I am sure we would get many answers. We therefore need to involve them all and I am not sure all of them are currently involved, considering small-medium enterprises, for example. In my view, there is not one specific group within the existing matrix that can have all the answers or can decide on the future road map – they each have their own interests at heart, and it is highly unlikely that one size will fit all. We will need to take account of different types and sizes, and capabilities of business. We need to start that discussion now, and not continue to assume that what we currently have, simply needs some fine tuning.
The Institute of Food Science & Technology (IFST) is the UK’s leading professional body for those involved in all aspects of food science and technology. We are an internationally respected community, supporting food professionals through knowledge sharing and professional recognition. Our aim is to provide evidence based, reliable and authoritative, scientific information that the public, policy makers and our members can trust and use. We also aim to be a source of professionalism in our field that reflects the dynamic and innovative nature of food science and technology. Our membership comprises individuals from a wide range of backgrounds, from students to experts, working across a wide range of disciplines within the sector.