Food Safety Starts at Your Own Kitchen Door
One consultant's case for why the food safety conversation keeps starting in the wrong place.
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One consultant's case for why the food safety conversation keeps starting in the wrong place.
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Two auditors can walk your plant against the same scheme and hand you reports that are worth very different things.
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Lessons from 200+ facility assessments on what separates facilities that sail through from those that scramble.
Read moreIndustry leaders and regulatory experts share their insights on emerging food safety challenges, compliance strategies, and best practices.
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Book a ConsultationOne consultant's case for why the food safety conversation keeps starting in the wrong place.
Someone buys a bottled drink, sees a ring of rust around the rim, wipes it off with whatever cloth is to hand and drinks it anyway. Most of us have watched that happen. A few of us have done it.
Asked about the habit on air this week, a food safety consultant who helps companies set up management systems said we should be worried about it, then declined to walk the audience through the chemistry. There's a reaction producing what you're looking at, he said. The point isn't the chemistry. It's that a layman should be able to protect himself without it.
He spent most of the hour on that gap.
Before anything else, he said, you have to do the research and know the critical control points for your product: the places in the process where things can go wrong, and what you're doing at those exact spots. A multinational, a mid-size outfit, somebody's kitchen at home. Same question. "You may think what you're doing is right," he said. "The world is so dynamic."
The thing that unsettles people is why the permitted level of a given substance isn't the same from one country to the next. We're all human, so why one limit here and another there?
He answered it with a refrigerator. Some countries are more temperate than others, and preservation is a cold problem before it's a chemical one. Climatic temperature varies. So does handling, and so does distribution, and when a manufacturer decides what preservative goes into a product meant to last, he's making a judgment about the entire route that product is about to travel.
So environment explains some of the variation. He didn't linger there. What he wanted on record was simpler: the consumer safe, and the consumer knowing what he's taking and what it can do to him.
He has no interest in explaining any of this in auditor vocabulary. "I'm more concerned about speaking in simple terms that a layman can understand," he said, because the same rules are running in a home kitchen whether or not anyone writes them down.
Ask him about a crate of soft drinks standing in the sun and he doesn't hedge. Heat isn't good for anything. Even bottled water left out in it isn't the best. Some foods need heat to cook them, and others, because of what they're made of, should be kept well away from it, and almost nobody has been told which is which.
He got impatient when the conversation stayed on the product in the news. He'd watched a programme about it earlier that same day, and a great deal had been said. But had anyone considered the man buying akara at the roadside? Had anyone looked at what it gets handed over in — newsprint, ink, handled by who knows how many people? Or where it was fried?
Go further back and it gets worse. Food safety starts at the farm: how produce is transported, in what, at what temperature, for how long. Then it reaches the market, and we all know what our markets look like. The stalls sit beside where the tomatoes and the dirt and the rubbish get dumped. People carry food home with that still on it. He wanted to know how many of them wash it properly.
None of that is an incident, so none of it is news.
Everybody's talking now because it's in the news. What about tomorrow, when something else happens? And in the meantime, what about the man who has diarrhoea every day because the water is bad and nobody taught him how to treat it, or because the meal wasn't cooked through?
He works with companies to put food safety management systems in place, and he thinks the people inside those systems should be taking the same habits home. "We have to be safe first before we can apply," he said.
Then the host called a break, and the adverts came on.
Two auditors can walk your plant against the same scheme and hand you reports that are worth very different things.
Two auditors can walk your plant against the same scheme, write up the same findings, and hand you reports that are worth very different things to you.
That's the distinction an SCS Consulting Services representative spent a good chunk of a recent overview on, because clients ask for one and mean the other.
In a pre-assessment audit, somebody who knows the scheme goes through its requirements, decides where the site doesn't meet them, and writes it up. That's the end of the service. The person running it can't tell you what to do about any of it. A gap assessment covers much the same ground, except the report comes with recommendations: here's how you'd close this, here's the corrective action that would work. Same findings, different document, and the second one is the one you can hand to your team on Monday.
The reason for the wall is structural. SCS Global Services certifies against the GFSI schemes. SCS Consulting Services, the arm doing the talking here, gets clients ready for those certification audits. The consulting side covers FSSC 22000, BRCGS, SQF, GlobalG.A.P. and PrimusGFS on the scheme side, and on the regulatory side the FSMA programs: preventive controls for human food, preventive controls for animal food, and foreign supplier verification, which he described as one of their bigger services.
Written programs are not the thing being assessed. Implemented programs are. You can read a sanitation program in a binder and learn almost nothing about whether anyone follows it, which is why the default is to show up, walk the site, and look.
Then COVID took the walking away. They built a remote process for observing and inspecting implemented programs instead, used it through the pandemic, and he says it worked well enough that clients kept using it.
Two other services came up. Labels: they'll review a client's labels against current U.S. regulations and, where something isn't compliant, say what would make it compliant. And sanitary design, which is the one people tend to discover late. U.S. regulations have stipulations about how facilities and equipment have to be built and designed to keep conditions sanitary and keep food from being contaminated. SCS will inspect the building, the equipment, or both, read the plans, go through the documentation, and then issue a letter stating whether the design meets what the law expects. If it doesn't, the recommendations come with it.
Their team, he said, has more than 30 years of combined experience across the food supply chain, in hazard-based systems and in the GFSI schemes.
Lessons from 200+ facility assessments on what separates facilities that sail through from those that scramble.
Full article coming soon.