Efforts to devise systems to control “hazards” in the food we eat have evolved in the last 22 years. HACCP categorizes hazards as chemical, physical, and biological. FDA’s “Preventive Controls for Human Foods” adds radiological, economically related, and ideologically motivated hazards. BRC’s “Global Standard for Food Safety” adds allergens, fraud, and radiological hazards. Our history of attempts to control hazards, and of broadening the horizon to include “quality” and “authenticity” reads like this:
- In 1996, USDA mandated HACCP for domesticated-animal meat, poultry, and egg products sold in interstate and foreign commerce. Since then, seafood, fruit juice, and vegetable juice (all regulated by FDA) and catfish (regulated by USDA) were required to have HACCP programs.
- In 2000, the Global Food Safety Initiative (GFSI) was developed as a voluntary structure for food safety standards. It “benchmarks” (i.e., “recognizes”) schemes originally developed in the US and several other countries. Though GFSI said its focus was on food “safety” standards, some benchmarked schemes also set standards for “quality” and “authenticity.
- In 2016, FDA mandated “Preventive Controls for Human Foods” as one of the seven pillars of the Food Safety Modernization Act for all other foods–including wild-animal meat, fish, and game.
At present, approximately 20% of food consumed in the USA comes from processing facilities regulated by USDA, while about 80% of our food comes from processing facilities regulated by FDA. Most of the food consumed in the USA is packed or processed in facilities that voluntarily abide by GFSI standards. For example, a meat packing plant might be inspected by USDA and audited by a GFSI-benchmarked entity (e.g., British Retail Consortium; Safe Quality Foods) while a bakery might be inspected by FDA and audited by a GFSI-recognized entity (e.g., Food Safety System Certification 22000; Global GAP). Either way, GFSI can bring quality and authenticity to the party. So, in what specific ways has GFSI certification strengthened protection of the public health while simultaneously encompassing food quality and food authenticity issues.
Surak and Gombas (Food Safety Magazine, 2009) believe that GFSI has been pivotal in harmonizing global food safety standards. Sanchez (Food Safety Magazine, 2011) argues for the strength of a singular (like GFSI), rather than a bifurcated (part FDA; part USDA), approach to a country’s food safety program. Moyer (Food Quality, 2012) believes the GFSI mandates standards that are higher than those of FDA or USDA for: safety, internal auditing programs, documentation, supplier monitoring programs, senior management reviews, evidence of worker competence, prevention of problems, process controls, food quality, and traceability.
A survey of 834 food suppliers in 21 countries (Crandall et al., 2017; J. Food Protection 80: 1613-1622) revealed that GFSI certification helped food processors strengthen their food safety management systems, enhance regulatory compliance, and promote a culture of food safety, which ultimately benefits their customers and consumers.
Steve Sayer (Meatingplace; Sept, Oct, Nov, 2017) wrote a series of articles on “GFSI–Is it Worth The Time, Money, and Efforts?” Highlights of his observations were: (a) GFSI increases exponentially a company’s vigilance, awareness, and focus towards all aspects of one’s food safety and quality management programs that–in turn–helps truncate the odds of product recalls and adverse food safety or quality issues rearing their ugly heads. (b) Areas upon which there was plant-dependence on federal regulations are better refined and defined in GFSI requirements; those include such things as management commitment, approved-supplier performance, monitoring, risk assessment, internal audits, traceability, security, fraud, control of non-conforming products, employee training, and complaint handling.
Of substantial importance is that USDA-HACCP and FDA-PCHF are subject to daily or periodic, respectively, governmental in-plant oversight, and that GFSI-certificated plants are subject to third-party auditing for initial and continual (annually) accreditation. There is great merit to having both systems “in play, every hour of every day,” to help assist in assuring the safety, quality, and authenticity of food products. Of the GFSI-recognized schemes, I am personally most knowledgeable about the specific contributions of British Retail Consortium’s “Requirements of the Global Standard for Food Safety.” These are things I think GFSI-BRC brings to the party:
- The greatest strength of the GFSI-BRC approach is its dependence upon development of a “company culture” directed toward a team-centric approach to improving the safety, quality, and authenticity of its products. Such culture must start at the top and trickle all the way down to the worker who loads the conveyance. The senior manager (like a football coach) preaches the sermon for team success–fully recognizing that each player must “swallow the Kool-Aid” in order to achieve the team’s goal. That is embodied and codified in BRC Requirement Group 1 (Senior Management Commitment).
- The play-book is For the players to be capable of “doing their very best” they must have precise and detailed instructions. That’s why the BRC “Global Standard for Food Safety” is comprised of 7 Requirement Groups with 256 Clause/Requirements to flesh them out.
- The metrics to quantify Continual Improvement are embodied in near-perpetual auditing protocols (BRC Requirements 2 and 3 for Internal Audits, 4 for Security Audits, and 5 for Vulnerability Assessments). Such audits provide reinforcement that Corrective Actions are verified, that site-security is maintained, and that Food Defense and Food Fraud risks are being successfully mitigated.
- Viewing the totality of food safety, quality, and authenticity issues as a “system in need of management-entity oversight” is critical. Much like ISO 22000, BRC Requirement Group 3 defines a management scheme that encompasses things like customer focus and communication, risk assessments of raw materials, root cause analysis, and internal auditing in a management system.
- With increasing interest of consumers in “real,” “genuine,” and “authentic” foods, the BRC-GSFS–in Requirement Groups 2,3,4, and 5–emphasizes consideration of Food Security, Food Defense, Food Fraud, ingredient substitution, provenance, identity preservation, food authenticity, and traceability.
Other GFSI-recognized schemes bring even more to the party. For example: Safe Quality Foods contributes greatly (at Level 3) to “quality” issues, while FSSC 22000 provides additional focus on “food safety management” principles. Certification against a GFSI-benchmarked standard is much more than a “paper tiger”–buyers demand it because it brings so much to the party.
