Tuesday 2 February 2010

INSPECTION TO PROCESS MANAGEMENT – THE EVOLUTION OF FOOD SAFETY MANAGEMENT


As we have all seen over the course of the past few years, the impact of food safety scares go well beyond the immediate costs of the incident itself.  The direct costs of such incidents can be relatively modest, but the impact on brand reputational risk can potentially put organizations out of business.  Global food organizations recognize this concern and are consequently bringing a clear focus to this concern at Board level.    

Historically, food safety has been ensured through inspection.  This approach has served the industry well to a degree for many years, however the fundamental problem with that approach is that it’s limited to what is seen on the day, and thus clearly has inherent limitations.  Indeed, many of the high profile food safety scares of the past few years had inspection regimes in place and they were being followed. However, because either the underlying weaknesses did not by chance result in physically observable problems on the day of the audit, or because these symptoms were not seen by the inspectors, remedial action was not taken and it was only a matter of time before a serious food safety event ensued.

A process audit approach is fundamentally different from an inspection based regime, whereby it actually determines the adequacy of the management processes to produce quality, safe product, through a detailed investigation of policies, procedures, competencies, resources applied, internal audit and verification processes and corrective and preventative action programs. It investigates the whole management process and supporting organizational structure to identify inherent weaknesses in the system, which can then be used to predict where problems might occur.  Clearly, the resources to be applied to a process audit approach are significantly higher than those applied in traditional inspection regimes, costing several thousand dollars more per audit, but these costs are outweighed by the tens or even hundreds of millions of dollars avoided from a major food safety scare.

A few years ago, the GFSI recognised the inherent inadequacies of the inspection approach and basically put in place four approved schemes that started to address the process safety approach, and recently a fifth has been added, FSSC 22000. The 2010 CIES conference will consider the latest state of play in the adoption of these schemes by the industry and key challenges moving forwards.  LRQA has put its weight behind FSSC 22000 because it’s fundamentally based on a Plan, Do, Check, Act management process cycle, together with a detailed consideration as to the adequacy of GMPs via an assessment of the facility against the requirements of PAS220.

Looking into the future, forward-thinking food organizations have already started to think more broadly about risks to brand reputation beyond just food safety, to include such aspects as the environment, ethical sourcing and other wide-ranging social responsibility issues.  It is likely that future process audit approaches to be applied within the food sector will incorporate these issues to provide a holistic tool for organizations to assess their overall brand reputational risk.  It must also be recognized that in these days of global sourcing, such tools cannot be restricted to an assessment of processes at manufacturing facilities, but must be applied across increasing complex networks of global supply chains.  The reputation of a large multi-national brand is equally at risk from a small farmer in Asia as it is from a defective process in one of its own facilities in its home country.  An effective process audit must have the capacity to address all of these concerns.

In closing, a robust assurance process is an absolute necessity not an option for global brands. The question such an organization must ask is are they going to use such processes to systematically identify risks and put in place necessary control measures, or be blind to such concerns and hope for the best. Your stakeholders are listening……

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