Two safety birds, one stone
by Lucy Sutton
When President Barack Obama signed the Food Safety Modernization Act (FSMA) into US law in January, the Global Food Safety Initiative (GFSI) was identified as one way to ensure compliance with its provisions. Retailers such as Wal-Mart and Target require that all suppliers be certified by a GFSI-recognized standard, and companies may have a hard time participating in the global marketplace without such certification.
As part of Baking & Snack's exclusive Q&A series, Tom Clark offered advice on how to become certified with GFSI-recognized programs. Formerly regulatory and formulations manager at Shearer's Foods, Inc., Brewster, OH, Mr. Clark is now a consultant at his own company, Food Management Systems. Specializing in quality system design and regulatory compliance, particularly under the British Retail Consortium (BRC) plan, Mr. Clark is available to answer further questions through www.foodmanagementsystems.net.
Baking & Snack: What impact will FSMA have on GFSI and the certification programs it recognizes?
Tom Clark: FSMA, signed into law by President Obama on Jan. 4, enables the Food and Drug Administration (FDA) to better protect public health by strengthening the food safety system. It enables FDA to focus more on preventing food safety problems rather than relying primarily on reacting to problems after they occur. The law also provides FDA with new enforcement authority designed to achieve higher rates of compliance with prevention- and risk-based food safety standards and to better respond to and contain problems when they do occur. The law also gives FDA important new tools to hold imported foods to the same standards as domestic foods and directs FDA to build an integrated national food safety system in partnership with state and local authorities.
The good news is that FSMA and GFSI actually have the same main intent, which is to make the food supply safer for the consumer. Both FSMA and GFSI are more focused on preventing food safety issues rather than managing the problem after the fact. The biggest difference may lie in the fact that GFSI is designed for companies that voluntarily wish to go to a higher, more rigorous level of food safety, while FSMA is a law that FDA felt was needed to give the government more ability to mandate and legally enforce a higher base level of food safety compliance for all companies.
In my opinion, companies that voluntarily see the need to improve any aspect of their business will always do so more quickly, at a higher level of execution and in an overall more profitable manner than a company that insists on dragging its feet and whose focus is only to achieve the minimum execution level to satisfy a customer’s expectation or regulatory law. For this reason, I believe companies that pursue GFSI will not only exceed the requirements of FSMA but will put themselves in a much better position to protect their customers as well as their own business from the adverse ramifications that always accompany a food safety-related issue.
Are all GFSI-approved schemes interchangeable in audit format and acceptance?
It appears to me that at this time most customers are more interested in a supplying company becoming GFSI-certified rather than the specific standard that was used or even the certifying body that conducted the audit. I think that this is a great testimony to the uniform approach and control systems that have been put in place by the GFSI organization.
Would companies benefit from having more than one company audit them?
The GFSI organization goes to great lengths to ensure that the various certification bodies audit the standards in a very consistent manner. Auditors who perform a GFSI-type audit are a very select group. They are required to be affiliated with an accredited certification body and must meet certain international standards determined by internationally recognized accreditation bodies like the American National Standards Institute (ANSI).
The auditors are only able to audit food industry sectors for which they have specialized training and personal experience. As a result of these requirements, most auditors certified to conduct GFSI standards-type audits are only able to do two or three food industry sectors.
An additional requirement is that the auditors themselves must be audited by another certified auditor during what is often called the “audit of the auditor.” During this audit, a nonparticipating certified auditor observes the entire audit process and then prepares a written evaluation for the purpose of certifying the auditor. The audit of the auditor is a very important part of the process that GFSI uses to ensure uniformity in approach and evaluation methods used by the various auditors.
How often do companies have to be audited with these schemes? What kinds of records do they have to keep?
The re-audit frequency varies depending on a variety of factors such as the type of certification being sought as well as the previous audit ratings, but in general, it occurs on an annual basis. For example, the BRC standard requires an annual audit provided that your previous audit score was either an A or a B rating. If your rating on the previous audit was only a C, you would need to be re-audited in six months. Depending on the nature of the nonconformities discovered during the audit, an additional on-site inspection may be required to ensure that all the nonconformities have been adequately corrected. Again, it is best to look at an overview of the audit recertification schedule when selecting the GFSI standard that you wish to pursue.
Record-keeping is critical. Everything a company does must be documented in a way that is easy to follow and filed in a manner that makes it readily accessible. Remember the age-old audit saying, “If it isn’t written down, it didn’t happen”? Record-keeping and document control are part of every audit and many companies will struggle with this area unless they have a very well-thought-out plan.
In addition, many companies simply don’t do a good job of creating simple and user-friendly forms. My experience has been that most companies try to make a form serve too many purposes and make the input areas too small for the legible input of data. As a result, forms are often incomplete, illegible or not executed at all.
This story is sponsored by POWER Engineers, which has one of the most comprehensive teams of engineers and specialists serving the baking and snack industry. As an extension of its clients' engineering teams, the company provides program management, integrated solutions and full facility design for the baking and snack industry. Learn more at www.powereng.com/food.
For more insights from Mr. Clark, check out the November 2011 issue of Baking & Snack.