By Joan Martino
What do you think of when you hear the words “root cause analysis?” Many people envision a painstaking, tedious process that tries to discover the true reason a process failed. Who wants to do that?! The quick approach is to just point a finger and blame the employee. But in order to really find out the cause of a problem—and develop a method for corrective and preventive action—it is important to go beyond human error and fix the integrated procedures that contribute to the problem. Otherwise it will simply keep recurring. There are various tools and methods to determine root cause including: Failure Mode and Effects Analysis (FMEA), Pareto Analysis, Current Reality Tree and others.
One of the Simplest Tools is Using the 5-Why’s:
The quick approach is
to just point
a finger and blame the employee
- Why is the metal detector rejecting product? Because there is metal in the product.
- Why is there metal in the product? Because the equipment is worn.
- Why is worn equipment causing metal to enter the product steam? … And so on.
Examining a problem with metal detection “rejects” in finished goods can lead to the conclusion that worn equipment needs replacement or improved maintenance procedures, sanitation or quality inspections. The immediate corrective action for product rejected by metal detection is to “Hold” all of the product that may have been affected and, at some point, conduct a quality inspection. In most cases the suspect goods become scrap. What are the business costs associated with this?
When it is important to analyze a problem more thoroughly, another great tool is the Ishikawa Diagram, (a.k.a. Fishbone, Cause and Effect). Dr. Ishikawa’s work is based on the use of process improvement teams who determine appropriate problems to work on, develop solutions and establish new procedures that refine quality, productivity and cost improvement. (Summers)
The Ishikawa Diagram provides a structured way to bring employees together and look beyond the surface to really discover why a problem disrupted the flow of business. It examines different categories and these typically include: People, Process, Equipment, Materials, Management & Environment. The questions we ask are beyond why and include what, how, when, where and so on. Now when we consider metal contamination in the product, the causal elements may be more significant and they can point the way to an integrated and long-term solution to the problem.
Once a conclusion is reached, a follow up action plan to correct the issues—with target completion dates—should be implemented, along with verification and monitoring, to close the loop. Implementing preventive actions takes it all to the next level: this step looks at processes and systems where similar failures could occur, and then applies appropriate preventive measures.
The tool can be adapted for use in both service and manufacturing areas. Not every problem requires root cause analysis. But when applied correctly, measurable cost savings can be identified in many areas, including: increased performance, improved product/service quality, less scrap, increased operation efficiency and more.
A good approach is to define specific problems where product quality, safety and legality are affected, and, where obvious errors can be corrected it is best to just fix them.
About the Author
Joan Martino is CEO of Quality Supply Chain, a company that provides simplified solutions to address regulatory compliance, supply chain initiatives and audit requirements for multiple industry sectors including food manufacturers, hospitality, retail, warehousing, packaging and equipment suppliers. She has also helped many leading US and Canadian companies integrate their systems with HACCP and GFSI requirements.
By Allie Gallant
There’s a common saying: “fat is flavour”. Our favourite foods often come with a little – or a lot – of fat, oil and grease, also known as FOGs. So it’s no surprise that commercial kitchens, food manufacturers and processors deal with a substantial amount in their day-to-day operations.
FOGs are flavourful, but they’re also good at clogging things up. Whether it’s your drain, grease trap or pipes, if left to their own devices, FOGs will cling to every surface.
The costs associated with damage, equipment downtime, professional cleaning and disposal are substantial and common. Not to mention fines…regulators won’t look kindly on contamination of sewage systems, and generally, the discharge of FOGs is prohibited. So what’s the solution?
Biodegradable solutions provide the best of both worlds: clean pipes, without harmful contamination
Many have realized that periodic flushing with a cleaning solution can keep equipment running smoothly, without the need to take things apart or get elbow deep in the grease trap. But how we remove grease comes with its own share of problems.
FOGs belong to a family of molecules called hydrocarbons. Hydrocarbons don’t like to mix with water, which makes them hard to clean. Traditional degreasers overcame this problem with harsh solvents and detergents, posing risks to employees and the environment. You might eliminate FOGs, but now you have corrosive cleaners on your hands.
Biodegradable degreasers, on the other hand, are environmentally safe and can go straight down the drain. “Wastewater is not a place where you want toxic cleaning chemicals. But the reality is that FOGs clog systems,” says William (Doc) Knight, Chief Operating Officer for FFT Technologies, LLC, based in South Carolina. His company makes a plant-based petroleum cleaning agent that is non-toxic and non-hazardous. It doesn’t destroy paint or metal surfaces and it is biodegradable.
“Biodegradable solutions provide the best of both worlds,” he says. “(You get) clean pipes, without harmful contamination.”
Knight notes that there are many benefits to using biodegradable cleaning solutions:
Non-toxic degreasers cost about the same as traditional cleaners and eliminate the need for hazardous waste disposal. “Issues with cleaning cooking surfaces, machinery, drain lines and grease pits are day-to-day problems for the food industry,” says Knight. “We’ve progressed a lot in terms of the safety and adaptability of degreasers. Safety and effectiveness can go hand in hand. And, you get cost savings.”
Greasy messes are a reality in the food industry but the technology now exists to allow businesses to escape the grease trap: regular maintenance with a biodegradable product prevents clogs before they happen, increases the safety of your site for your employees and your customers, and allows you to take another step toward building on the profitability of the business. Everybody wins.
About the Author
Allie Gallant is a regular freelance writer and blogger with Global Food Safety Resource and she is also one of our most valuable and recognizable contributors.
The primary purpose of the American Food Safety Modernization Act (FSMA) is to improve food safety standards by changing both industry’s and government’s approach to food safety from reactive to preventive. This ground breaking piece of food safety legislation is broken down into four main sections:
As part of this comprehensive change, the Food and Drug Administration (FDA) has been releasing rules to specifically address important aspects of food safety. These include the Foreign Supplier Verification Programs (FSVP) for Importers of Food for Humans and Animals,the Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption, and the FSMA Final Rule for Preventive Controls for Human Food.Other rules include:
The changes are dramatic. For example, the regulations address Preventive Controls. The details of this are outlined in the Preventive Controls Rule but, briefly, companies are now required to:
On their side, staff at the FDA is working to establish science-based standards for testing. One area they are specifically focusing on is safe production and harvesting of produce. The Produce Rule is one part of this ongoing process.
The FDA’s Food Safety Modernization Act also gives the FDA the power to hold companies accountable for these preventive controls, primarily through inspection. This represents a huge change in food safety legislation and so the FDA is changing the way its inspection resources
are allocated, utilizing a proactive, risk-based assessment process. The focus is on innovation with the goal of providing effective and efficient services.
Special attention is given to ensuring that imported foods meet the same food safety standards as domestic foods. The Foreign Supplier Verification Rule details the requirements, but beyond stating that importers are required to carry out supplier verification procedures to ensure the imported food is safe, the legislation also:
Should anything go wrong, the FSMA gives the FDA the right to issue a mandatory recall. Although historically most companies have been very cooperative when asked to implement a voluntary recall, this change is an important step in protecting the public health.
In most cases, the Act gives dates of compliance based on the size of the operation and defines very small and small businesses. Very small businesses are given the longest time to reach compliance, small businesses slightly less time and the rest have the shortest time to comply.
Finally, the legislation also recognizes the need for the FDA to partner with state, local, territorial and tribal authorities to enhance the food safety network. As well, the FDA is mandated to work with all of these authorities to provide food safety training, and it offers grants to help increase the number of labs and certified testing facilities.
Companies are strongly encourage to become “FSMA ready” now to mitigate any risks associated with non-compliance, once the rules are finalized.
By: GFSR Staff
There was a terrific turnout for Global Food Safety Resource’s (GFSR) first online video panel discussion in late August and we were delighted with our audience’s interest in “The Next Big Killer: Food Fraud—Protecting Your Brand Through Transparency.” Our panelists received so many questions that we couldn’t get to them all in the hour allocated for the discussion, so we know we broached a topic that is top-of-mind for many people in the industry. The discussion was co-sponsored by GFSR and Authenticateit, the global leader in helping companies protect their brand from counterfeiters using software that empowers brands to manage their brands and intellectual property Co-moderators were our own CEO, Tina Brillinger, and Dawn Van Dam, an innovative business leader and facilitator.
The discussion brought industry stakeholders and subject matter experts together to increase awareness of food fraud and provide strategies to mitigate the risk to your brand while improving consumer trust.
Our panelists included:
We’ve taken the liberty of summarizing the discussion for you, highlighting only the responses to questions that were asked. If you would like to view the discussion we’ve made the recording available as a new member benefit and you can download it by signing up or logging into GFSR.
Karen Mills Director, Quality Assurance (Canada) at Highliner Foods
Food fraud is pervasive and we need to make sure that what we’re getting is as pure as possible. Dairy, juices, oil – it’s a bit of a war. Fraudsters are getting very ingenious about how to make funds from the product that they’re selling and this is definitely an issue.
I definitely think this is something consumers are concerned about and it’s especially an issue with seafood. Highliner is fortunate because we have a fairly robust supplier base and a strong vendor approval process for all our suppliers, including those overseas. It’s critically important because the health risk for substitution can lead to extremely drastic results.
Because of our vendor approval process and our auditing standards we can keep on top of this – we’ve done some validation with external lab testing and we’ve been able to prove that what consumers stated were different species, were actually correct for the labelling and product description(s). We get some questions on the topic every year – people are paying attention and people are asking: how are we making sure that our species are what we say they are, that our labelling is correct? Our regulatory bodies and our auditing bodies are also doing everything they can to make sure that everything is what we as industry procure it to be.
Our brand is everything in this business and food fraud might be a killer in health ways, but it’s also a killer in other business-related ways as well.
Transparency for us means integrity and confidence in our products. It’s about the origin of the products and the material we use, but we also talk about transparency when it comes to consumers’ understanding of our business. We want consumers to have confidence in our products and in our integrity.
Many of us in the industry are looking for supplier approval and validation to make sure that integrity is built in to the process from the beginning. It isn’t always easy to have proven suppliers but a lot of us in the industry are networking and talking about how to make that happen on a more consistent basis. At High Liner we work with procurement and purchasing departments. We also verify incoming materials on a set sampling plan to ensure we are receiving the best standard of goods as possible.
Yves Rey, Corporate Quality General Manager at Groupe Danone
Food fraud is a growing challenge for big companies. It can occur anywhere and, economically, it’s a risk, just like a food safety hazard. I’ve been told food fraud accounts for 10% of goods being sold, although that number might be low. It’s a criminal activity and according to experts from Interpol, food fraud costs could amount to $20-$25 billion annually. We can mitigate it only through sharing information.
Like in China with the melamine issue, food fraud can kill your local communities, and even your country’s, economy. We should work hand in hand, public and private, to solve this issue. Only by working together and sharing information can we be stronger. Food fraud is a big killer and we need to find a way to mitigate it and ask how can we bring together public, private and academic interests, to figure out what can be done.
We should also develop a common methodology for identifying food fraud and share best practices, knowledge, information, and expertise.
We also need transparency in the way we deal with our suppliers. Every company must be fair, and commit to a fair selling price. If you put too much pressure on your supplier, you’re going to get issues and I do believe that a fair selling price is one of the best ways to mitigate food fraud.
When we detect fraud many companies don’t know what to do with the information. It’s going to be really important to share this learning through an organization able to manage it. There is no official formal organization to gather this information and provide relief to companies around the world.
Over the past year GFSI has succeeded in bringing together private and public interests with a business driven mindset in order to mitigate food safety hazards. I believe we should set up a controlled plan to ensure that our products are free of any contamination. We’re at the beginning of a very exciting process and there is still a long way to go. If we want to hit the target of selling products free of any adulteration, it’s only by setting up a platform for information sharing, and expertise sharing, that we can make it work, let’s work together now!
Food safety and food fraud must start at the top. Set up a meeting with your chairman and CEO in order to raise awareness of food fraud and get a commitment from your top management to fight this problem.
John Spink, Director & Assistant Professor, Food Fraud Initiative, Michigan State University
We’ve been seeing that there’s such a critical need for support on this issue, there is such a vulnerability for companies, and one thing that’s good for all of us is that there are processes in place to start to create a system. There are also some strategies available to solve the problem. We need to be very proactive on this and I think it’s very helpful that academia has been involved to define the scope.
It’s important to understand what’s going on in the entire supply chain. Once we start to discuss different types of products or programs or resources that are available, a company needs to look at the transparency of its own decision making process. How do companies make their own resource allocation decisions? That very question shifted our work from food science to criminology to business. There’s a question of how do we know when we’ve done enough and a big piece of that transparency issue is about internal processes.
There are a lot of different reasons why we need data and a lot of things we can do with it. One of the objectives is to get a look at what type of fraud occurs. The data sets are helpful to look at this during the first pass of a vulnerability assessment. We might not need a lot of information to know that we need to test for horsemeat, for example. The key is that people don’t need to jump in 10 feet deep – take a quick look at it and then decide how deep to go.
If a company hasn’t done anything yet about food fraud, I recommend they open up an internet browser window and search for “GFSI” and “vulnerability and food fraud.” GFSI is a very organized way to start. There are resources there that are free, open and online. You can take a quick look at what they offer and then look at how food fraud fits into everything else in the enterprise risk management area.
Mitchell Weinberg, CEO, INSCATECH
In the United States there is a lot of talk about potential class action suits lawsuits for food fraud and we’re about to see some of those come through in the next six months to a year. That will definitely encourage businesses to do something about food fraud.
Some cases of food fraud have resulted in fatalities –for a good six months after the peanut case, for example, people wouldn’t touch peanuts or peanut products
The problem with food fraud is that there really is no common link – it’s important to be able to identify where your vulnerabilities are all along your supply chain and at every point in your supply chain. I think you have to be looking everywhere. We’ve done investigations in every corner of the world, for large multinational companies and very small importers and producers. What we’re finding is that although 10% is the official estimate of how much food fraud there is, what we’re seeing is food fraud in approximately 75% of the investigations we do. There’s always something new that comes up and much of the time, when our client finds out where it’s coming from, they go into panic mode: they didn’t expect it and they don’t know what to do about it.
There are definitely higher risk foods – typically items that are expensive are popular targets where large margins can be made. But the ingredients that go into our food are also at risk – flavourings, chemicals, those are ingredients that nobody really talks about but they are really a problem as well.
Companies need to contractually require their suppliers to address food fraud and provide transparency. That is critical to protecting your company so I strongly encourage food companies to look at their contracts to ensure that your suppliers are being responsible to you.
Technology wise – this panel is being co-sponsored by Authenticateit and I was extremely impressed with what they’re doing. They offer a smart phone app where you can scan the bar code on a food product and get all the information about that product – its country of origin, what’s in the product, etc. It forces producers to gather that information so they can enter it into the Authenticateit database.
The best thing companies can do to ensure their brand authenticity is to take a deep breath, get key people in the room and start having a conversation about your vulnerabilities. You need to talk to the people responsible within the company – the risk managers, the security professionals, the legal professionals, they all share responsibility for food fraud. Then assess where your vulnerabilities- are: who are your suppliers, where are they, what kind of relationships do you have with those suppliers? Then go ahead and start doing a vulnerability assessment, identify the risks, start to do some investigations
Sara Zborovski, Partner, Norton Rose Fulbright
As we as an industry become even more global, and as we share suppliers and the global distribution chain, the issue of food fraud is likely to become more prevalent.
This is absolutely not just about false advertising. We have noncompliance in labelling happening all the time but when we’re talking about food fraud we’re talking about an action that is done with intent and for economic gain, for example, in swapping out an ingredient for an inferior quality item.
The regulator has limited resources and how much of that can be spent policing something that is largely an invisible issue?
I think it’s important that there is a lot of honesty in the supply chain and that companies have agreements in place to ensure such honesty and that there are adequate remedies in the event something goes wrong.
There is no legislation that actually protects against food fraud. There are a bunch of Acts and Regulations that tell consumers what needs to be in place in terms of labelling, etc. And there is legislation that says we can’t poison food, etc. but the onus is on the food supplier to ensure that what is being represented is actually being supplied. The strongest protection is to rely on a rock solid contract that pushes potential liability to others in your distribution chain and can be enforced in a meaningful way. It’s also important to continually police your supply chain and make changes as needed.
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By Susie Hoeller | August 27, 2015
The Food Safety Modernization Act (FSMA), requiring the food industry to use third party auditors and certification bodies, under certain circumstances, is designed to greatly improve food safety outcomes for imported foods. FSMA directs the U.S. Food and Drug Administration (FDA) to establish an accreditation program for these third-party auditors or certification bodies who will then be authorized to:
In July of 2015, the FDA issued a Draft Guidance regarding Model Accreditation Standards for both third-party auditors (“auditors”) and certification bodies. Here are some of the highlights of the Draft Guidance which are important for companies to consider now before final regulations are issued:
I. Authority. Auditors or certification bodies must demonstrate that they are capable of exerting adequate contractual or governmental authority to:
An entity seeking accreditation must demonstrate that it has the resources necessary to fully implement its program.II. Capacity. An entity seeking accreditation must demonstrate that it has the resources necessary to fully implement its program, including:
III. Conflicts of Interest. A written program to protect against conflicts of interest between the auditor or certifier and entities certified or seeking certification must be in place.
IV. Quality Assurance. An auditor/certification body must show that it can meet the quality assurance requirements.
V. Records. An auditor/certification body must demonstrate that it has implemented written procedures to establish, control, and retain records to meet its contractual and legal obligations and to assess its program and performance.
VI. Regulatory Audit Reports. An accredited auditor/certification body must prepare and submit a report to both the FDA and to its accreditation body within 45 days of completing an audit. The report must be submitted electronically, in English, and it must include:
VII. Publicly accessible information and directory of certified clients. An accredited third-party auditor/certification body must maintain on its website a current list of the eligible entities to which it has issued food or facility certifications. The website must identify the duration and scope of the certification and other information.
It is expected that final regulations for this subject will issue in October 2015 and at that point interested companies will have a definitive roadmap to follow to become accredited.
About the Author
Susie Hoeller is an international business attorney. She counsels companies, including food companies on regulatory compliance and negotiates contracts and intellectual property licenses. Ms. Hoeller was raised in Montreal, Quebec. She is a graduate of Vanderbilt Law School and holds law licenses in five states. Currently, she is a member of a Food Policy Advisory Council in Pasco County, Florida. For more information: see, www.hoellerlaw.com.
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