By Chris Dunn

For decades manufacturers, retailers and trade organizations have promoted voluntary compliance of government food safety standards; initial focus was on product quality.

More recently, global retailers and manufacturers have been working to find common ground with schemes that focus on the underlying quality of management systems involved in the production of food. Better documentation correlation and more consistent methods with less defects and better quality are essential.

The double helix of DNA[1], with its two strands connected together for strength, represents a model to join quality of product with quality of management systems. Hazard analysis and critical control points (HACCP[2]), training and inspection (verification) become the links and together form a ladder for continually improving beverage quality.

First strand: product certification
Product certification started about 25 years ago. Non-profit organizations, such as NSF International, began to set consensus standards built around voluntary guidelines. These were designed to provide checks and balances inside the manufacturing process, which could then be verified through laboratory testing and plant audits. This type of standard is specific to a product and validates performance against governmental organizations requirements such as the US FDA, Health Canada or European Food Safety Authority (EFSA).

The foundation of product certifications is transparency of what is required and the independence of the certifying entity. Standards are validated by food safety expertise, scientific method, objective observation, quantitative measurement and physical inspection to verify compliance. The foundation is built on the verification of a functioning HAACP plan, physical plant inspection and laboratory testing of the product. Once the benchmark is achieved, there are re-inspections and re-testing at least once annually.

Governments recognize qualified third-party standards. They know that a product obtaining certification has a working HACCP plan supported by prerequisite programs built around good manufacturing practices (GMPs), sanitary and standard operating procedures (SSOPs and SOPs).

They also know a physical audit has been conducted and laboratory tests have been performed to verify product safety. While third-party standards are not a replacement for government oversight, they provide public affirmation of compliance. Some regulators reference third-party standards as guidance to people asking for help to meet government regulations.

Retailers value product certification because of the brand protection it offers their private label products. Because retailers often do not have the technical expertise in all product categories, their risk management strategy can use published standards to insure their co-packers are fully complying with all the regulations via third-party verification.

Manufacturers appreciate product certification as support in helping them achieve ‘best practice,’ as well as demonstrate to their customers they have world-class quality that has been validated by an independent third-party.

Faced with a plethora of choices, a certification mark on the product is a key factor in consumers choosing one brand over another. Knowing that a certified product has met all applicable requirements provides peace of mind for consumers.

Trade associations, such as the International Bottled Water Association (IBWA), have also helped to advance bottled water quality by promoting their Model Code and plant inspection programs, which impact the majority of the U.S. bottled water industry. NSF has been providing inspection and audits of IBWA member facilities since 1984. About half of the U.S. states use IBWA Model Code as the basis for their own regulations.

Second strand: Global Food Safety Initiative
Global sourcing and distribution of food and beverages has increased the complexity and interconnection required to produce consistency and uniformity. Retailers have in the past set their own criteria, especially for their own private-label brand, and have done their own inspections. While this benefited some individual retailers, it also resulted in redundancy.

Trying to reduce the negative impact on cost and efficiency, an organization called the Food Business Forum (www.ciesnet.com) took action. This Forum was founded in Europe by seven global retailers (Carrefour, Tesco, Metro, Migros, Ahold, Wal-Mart and Delhaize) and supported by major manufacturers like Kraft[3]. This group sought a solution that would reduce redundancy, while assuring members consistent, high-quality products.

The retailers chose their focus to be on the process (management systems) rather than individual products. This would result in a program that would be as applicable to fresh produce as to canned soup. Better systems would cause manufacturers to adopt better controls and thus improve quality.

The Forum harmonized minimum standards to insure competing programs delivered the same basic requirements. Under the banner of Global Food Safety Initiative (GFSI[4]), four schemes now exist and are deemed interchangeable: 1) British Retail Consortium (BRC[5]); 2) Safe Quality Food (SQF[6]); 3) International Food Standard (IFS[7]); and 4) Food Safety System Certification 22000 (FSSC22000[8]).

Each of the schemes covers all food and beverage categories, versus a specific product. They also promote systemization and documentation that guides a manufacturer in any food category to implement and manage a food quality and safety program focused on processes, measurement and documentation. These systems support complex product formulas and manufacturing processes, as well as upstream and downstream supply chains that often span the globe.

Similar to product certification, management systems are built on a HACCP foundation. With the intensity of processes and documentation, these programs start with a management commitment to provide the resources, as well as sign-off on system documentation. There is often linkage to corporate IT systems to collect and manage data.

These are complex programs that require in-house experts to implement and create the documentation. After everything has been systemized and documented according to the program guidelines, an approved auditor (certified by the GFSI program itself) does a desk audit of all documents and systems.

After verifying the systems and documents are in place, a verification of the system implementation takes place. This includes the physical plant inspection, as well as document review and usage.

Any non-conformances are noted and must be corrected before certification is granted. Annual follow-up visits are required to verify ongoing compliance.

What are the differences?
There are many points of difference on how each strand approaches quality. Some are defined by their nature — GFSI programs are generic, meaning the same manual and checklist apply to all categories of food.

There are references to ‘industry practices,’ but no product-specific requirements outlined. Product certification is tailored specifically to the product itself, thus it is naturally more proscriptive and clear.

In lighting for a plant, as an example, GFSI would say there shall be ‘adequate lighting’ tied to all types of activity performed. Product certification would be much more specific stating that there shall be 50 foot-candles of light in product areas and 20 foot-candles elsewhere.

The differences are driven by the nature of the programs – one tied to a specific product, the other tied to the systems generic to any food plant.

Common bonds
The underlying principle that both approaches share is HACCP.

Both systems place a heavy reliance on training. As part of product certification, a bottler is required to have provided HACCP, GMP, Food Security and Employee Hygiene training to all production workers.

Both approaches rely on inspections to verify implementation and efficacy of the programs. Product certification will devote more of the inspection to GMPs. The system audit will view the GMPs in the context of reviewing documentation.

Combined effect
When you use HACCP and training as connectors of the two strands and implement both programs, you form the spiraling double helix of beverage quality DNA. While symbolic, it is also a practical image of a ladder, which implies the best quality is achieved by continuously climbing upward.

As with real DNA, remove one of the strands or even one of the connectors and one is incapable of achieving best practice. Large operations often need both. The more complex an operation, or the more varied the products become, systems take on increasing importance.

Early proponents of GFSI once thought that GFSI was going to be the end-all solution. It is now of paramount importance to have product-specific programs, such as those found in NSF’s bottled water certification program to complement GFSI, HACCP and training initiatives. The best approach, therefore, is to infuse the manufacturing process with the strongest DNA possible so that it can replicate itself in the form of zero defect product quality.

References and Footnotes

  1. National Human Genome Research Institute: http://www.genome.gov/25520880
  2. Hazard Analysis and Critical Control Points (HACCP) is a systematic preventive approach to food safety and pharmaceutical safety that addresses physical, chemical, and biological hazards as a means of prevention rather than finished product inspection. http://en.wikipedia.org/wiki/HACCP
  3. The Food Business Forum started in 1953 and now has over 400 members in 51 countries. www.ciesnet.com
  4. The Global Food Safety Initiative (GFSI) coordinated by CIES – The Food Business Forum, was launched in May 2000
  5. BRC first introduced in 1998; now in Fifth Edition, published January 4, 2008.
  6. SQF launched August 2003 by SQFI; now in Sixth Edition, published in August 2008
  7. IFS started in 2003; now in Fifth Edition, published August 5, 2007
  8. FSSC22000 was approved by GFSI in June 2009 and will replace Dutch HACCP.Pull Quotes—The double helix of DNA, with its two strands connected together for strength, represents a model to join quality of product with quality of management systems.As people who were early proponents that GFSI was going to be the end-all solution are discovering, it is of paramount importance to have product-specific programs such as those found in NSF’s bottled water certification.
  9. Trade associations, like IBWA, have also helped to advance bottled water quality by promoting their Model Code and plant inspection programs which impact the majority of the US bottled water industry. About half of the individual US states use the IBWA Model Code as the basis for their own regulations.

About the Author
Christopher Dunn is General Manager of the Beverage Quality Program for NSF International, a public health and safety organization, based in Ann Arbor, Michigan. His program offers testing, auditing and certification of beverages including bottled water, natural mineral waters, flavored and functional beverages and packaged ice. Dunn is a 30-year veteran of the beverage industry. For over a decade, he has been involved with bottled water (IBWA) and packaged ice (IPIA) trade associations and is certified CWS-I by WQA. Dunn can be reached at cdunn@nsf.org.

 

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