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FSSC 22000 on the attack in the GFSI Quality game

Posted by Tony-C, in Food Safety Standards 20 November 2014 · 6,466 views

fssc 22000 quality gfsi
FSSC 22000 on the attack in the GFSI Quality game Last month FSSC 22000 announced its intention to add a module for the certification of Food Quality Management Systems based on ISO 9001. Certification should be available in the New Year.

In the announcement FSSC 22000 stated:

‘The addition will give organizations the possibility to be FSSC 22000 audited and certified for Food Safety and Quality Management Systems. The ISO 9001 standard has a strong customer focus. It helps to ensure that customers get consistent, good quality products and services. It also covers product development and design.’

So what is the aim of the “quality” addition?

If we refer to the GFSI Guidance Document Sixth Edition Issue 3 Version 6.3 (October 2013), the third part of the Guidance Document (Part III: Scheme Scope and Key Elements) specifies the requirements for the recognition of food safety schemes. The objective of Part lll is to define the requirements for food safety management systems, Good Practices and the HACCP or HACCP based requirements to be in place in the scheme’s standard for each GFSI scope of recognition.

Looking through Part III in more detail we see that in section 1, Food and Feed Safety Management Requirements there is no mention of quality. In Section 2 Good Industry Sector Practice Requirements (see appendix[1]) you can find some references to air and water quality, and also that the effectiveness of the training is monitored in packaging hygiene, quality and food safety principles and practices. Like section 1, in section 3: HACCP or Hazard Based Requirements there is no mention of quality.

The main reason becomes clear if you look at the quality aspects of the other main GSFI benchmarked standards such as SQF Code, IFS Food Standard and the BRC Global Standard for Food Safety.

SQF Code Edition 7.2

‘The main feature of the SQF Code is its emphasis on the systematic application of HACCP for control of food quality hazards as well as food safety. The implementation of an SQF management system addresses a buyer’s food safety and quality requirements and provides the solution for businesses supplying local and global food markets.’

There are 3 levels of certification to the SQF code:
LEVEL 1 Food Safety Fundamentals (accredited certification)
LEVEL 2 Food Safety Plan (accredited certification, GFSI recognition)
LEVEL 3 Food Quality Plan (accredited certification, GFSI + Quality Management)
Level 3 requirements all Level 1 and Level 2 system elements plus a food quality risk analysis of the product has been undertaken and food quality plans implemented.

Looking that the requirements for food manufacturers, there are over 60 references to quality in the SQF Code Modules 2 and 11[2], most of them being in Module 2: SQF System Elements.

Additionally SQF reward suppliers who achieve level 3 certification with permission to use the SQF quality shield.

BRC Global Standard for Food Safety

The BRC Global Standard for Food Safety was the first Food Safety Standard to be benchmarked by the GFSI, and it also incorporates quality requirements. As well as food safety requirements there is a need to ‘manage product quality to meet customer’s requirements’. Section 3 Food Safety and Quality Management System: 'Sets out requirements for the management of food safety and quality, building upon the principles of ISO 9000.’

According to the BRC, the Global Standard for Food Safety was…

‘developed to specify the safety, quality and operational criteria required to be in place within a food manufacturing organisation to fulfil obligations with regards to legal compliance and protection of the consumer’.

There are over 40 references to 'quality' in Section 2 Requirements, of the BRC Global Standard for Food Safety, from Clause 1.1 Senior Management commitment and continual improvement to Clause 7.1 Training.

IFS Food Standard for auditing quality and food safety of food products Version 6 January 2012

IFS Food requires a company’s quality and food safety system to be documented, implemented, maintained, and continuously improved.

‘All processes and procedures shall be clear, concise and unambiguous and the personnel responsible shall understand the principles of the quality and food safety management system’.

Quality is referred to over 25 times in the IFS Food Standard Part 2: List of audit requirements from Clause 1.1 Corporate policy/Corporate principles to Clause 5.9 Management of incidents, product withdrawal and product recall.

The current FSSC 22000 Certification Scheme for food manufacturers is based on 3 elements:In International Standard ISO 22000:2005 Food safety management systems - Requirements for any organization in the food chain the only mention to quality are references to ISO 9001 (Bibliography [1] ISO 9001:2000, Quality management systems — Requirements)

In Technical Specification ISO/TS 22002-1:2009 Prerequisite programmes on food safety - Part 1: Food manufacturing there are a few references to quality[3], in the terms and definitions for material specification/product specification in requirements for utilities, assessment of the suppliers, vehicle checks and rework control.

In FSSC 22000 Part I Requirements for Organizations that Require Certification there is a single mention of quality:

Food Safety Management and HACCP

‘For the greater part the requirements are based on the standard ISO 22000. ISO 22000 was developed by the International Organization for Standardization (ISO) and fulfils the need of integration of the technological (i.e. Good practices, HACCP, traceability) and legal food safety requirements in the quality management system requirements of standard ISO 9001'

So clearly this move is aimed at trying to achieve parity with the major players and the integration of ISO 9001 Quality management systems Requirements fills a sizeable gap between the FSSC 22000 Certification scheme and the other major players in terms of quality requirements and will enable FSSC to provide certification of Food Quality Management Systems.

Product Development & Design

It's interesting that the statement from FSSC also mentions product development and design. There is no mention of product design and development in International Standard ISO 22000:2005, Technical Specification ISO/TS 22002-1:2009 or FSSC 22000 Part I Requirements for Organizations that Require Certification.

In fact if you again refer to the GFSI Guidance Document Version 6.3 the only mention of development is in Scope of Recognition M, Clause Number FSM M1 Food safety management for packaging materials general requirements.

‘The management system shall:

g) validate packaging design and development to ensure food safe and legal manufacture.’

The FSSC 22000 Certification scheme for food packaging manufacturers does actually include packaging design and development because the prerequisites are prescribed in PAS 223:2011 - Prerequisite programmes on food safety for design and manufacture of food packaging[4]

‘Section 19 Food Packaging design and development

19.1 General requirements
19.2 Communication and change control - obtain necessary information to design food packaging suitable for use is required
19.3 Design - Confirmation of suitability of materials for intended use is required
19.4 Specifications
19.5 Process validation’

If we go back to the SQF Code product development is covered in Module 2, Section 2.3 Specification and Product Development, 2.3.1 Product Development and Realization. SQF requires the methods and responsibility for product development to be documented and implemented, validation by facility trials, food safety plans validated and verified for each new product and records of all product design/development.

IFS Food Version 6 covers product development in Section 4.3. Product development/Product modification/Modification of production processes and has similar requirements to the SQF Code.

BRC Global Standard for Food Safety covers product development in Section 5 Product Control 5.1 Product design/development and has similar requirements but also requires guidelines on any restrictions to new products to be developed to avoid introducing new hazards such as allergens.

So with the FSSC 22000 Certification Scheme the addition of ISO 9001 to provide certification of Food Quality Management Systems also has the benefit of adding product design and development requirements that were previously lacking in comparison to the other major GFSI benchmarked schemes. ISO 9001 section 7.3 Design and development has requirements for management of the design and development process:

‘7.3.1 Design and development planning - The organization shall plan and control the design and development of product.
7.3.2 Design and development inputs
7.3.3 Design and development outputs
7.3.4 Design and development review
7.3.5 Design and development verification
7.3.6 Design and development validation
7.3.7 Control of design and development changes’

So this is progress although ISO 9001 is not food specific it makes perfect sense to have Food Safety & Quality Management System certification available and there hasn’t been any need to reinvent the wheel to do it.

One final thought

Whilst FSSC are playing catch up amongst the players it appears that BRC are leading the way as mentioned in one of my previous blogs Emphasis on Integrity in BRC Version 7 Draft they plan to tackle the issue of food fraud in issue 7 which is due for release next year, whilst earlier this year GFSI[5] announced that they are to include new requirements specific to food fraud in the next full revision of the GFSI Guidance Document 7th Edition but that won’t be released until early 2016. In the meantime there may be a publicly available specification published by SSAFE[6] to fill the gap until 2016. Watch this space…

Appendices

[1] GFSI Guidance Document Sixth Edition Issue 3 Version 6.3 (October 2013)
(Part III: Scheme Scope and Key Elements)
Section 2
GOOD INDUSTRY SECTOR PRACTICE REQUIREMENTS
Clause Number GAP AI 1 Agricultural input requirements - agricultural and veterinary inputs are of adequate quality for the intended use
Clause Number GAP AI 2 Water for primary livestock production - assess its microbial and chemical quality and its suitability for the intended use
Clause Number GAP AII 1 Aquaculture input requirements - agricultural and veterinary inputs are of adequate quality for the intended use
GAP AII 2 Water for aquaculture production - water used for aquaculture production activities and to assess its microbial and chemical quality and its suitability for the intended use
GAP AII 7 Water supply - Where water is supplied and used that is not of potable quality it will be clearly marked.
GAP BI 1 Agricultural input requirements - agricultural inputs are of adequate quality for the intended use
GAP BI 2 Water for primary production - identify the sources of water used on the farm and to assess their microbial and chemical quality and suitability for intended use
GAP BI 3 Water for irrigation and harvesting - water used for agricultural purposes be of suitable quality for its intended use.
GAP BII 1 Agricultural input requirements - agricultural inputs are of adequate quality for the intended use
GAP BII 2 Water for primary production - identify the sources of water used on the farm and to assess its microbial and chemical quality and its suitability for the intended use
GAP BII 3 Water for irrigation and harvesting - water used for agricultural purposes be of suitable quality for its intended use.
GMP C 13 Water quality and utility management (including Ice) - the quality of water (including steam and ice) that comes into contact with food, be regularly monitored and shall present no risk to product safety.
GMP D 11 Water quality and utility management (including Ice) - the quality of water (including steam and ice) that comes into contact with food, be regularly monitored and shall present no risk to product safety.
GMP EL 12 Water quality and utility management (including Ice) - the quality of water (including steam and ice) that comes into contact with food, be regularly monitored and shall present no risk to product safety.
GDP J 10 Air, water quality and utility management (including ice) - the quality of air, compressed air and water in any form that comes into direct contact with food or food packaging shall present no risk to product safety.
GMP M 11 Air and water quality management - the quality of air, compressed air and water (including steam) that comes into contact with packaging material shall present no risk to product safety.
GMP M 16 Training - the effectiveness of the training is monitored in packaging hygiene, quality and food safety principles and practices, commensurate with their activity.

[2] SQF Code Module 11: Food Safety Fundamentals – Good Manufacturing Practices for Processing of Food Products, Reference to Quality:
Clause 11.2.9 Maintenance Schedule
Clause 11.2.10 Calibration
Clause 11.6.5 Alternative Storage and Handling of Goods

[3] Technical Specification ISO/TS 22002-1:2009 Prerequisite programmes on food safety - Part 1: Food manufacturing references to quality:
3 Terms and definitions
‘3.7 material specification product specification
Food safety detailed documented description or enumeration of parameters, including permissible variations and tolerances, which are required to achieve a defined level of acceptability or quality’
6 Utilities - air, water, energy
6.1 General requirements - Utilities’ quality shall be monitored
6.2 Water supply
6.4 Air quality and ventilation
9.2 Selection and management of suppliers
‘assessment of the supplier’s ability to meet quality and food safety expectations’
9.3 Incoming material requirements (raw/ingredients/packaging)
‘Delivery vehicles shall be checked prior to, and during, unloading to verify that the quality and safety of the material has been maintained during transit’
14 Rework
14.1 General requirements
‘Rework shall be stored, handled and used in such a way that product safety, quality, traceability and regulatory compliance are maintained.’

[4] PAS 223:2011 - Prerequisite programmes on food safety for design and manufacture of food packaging or ISO/TS 22002-4:2013 Prerequisite programme on food safety - Part 4: Food packaging manufacturing. Based on history PAS 223 is likely to be withdrawn.

[5] GFSI POSITION ON MITIGATING THE PUBLIC HEALTH RISK OF FOOD FRAUD July 2014

APPENDIX: PROPOSED KEY ELEMENTS FOR FOOD FRAUD MITIGATION
The below key elements were prepared by the Guidance Document Technical Working Group based on the recommendations of the Food Fraud Think Tank. Consultation will continue during the development of Version 7 of the Guidance Document.

‘Food fraud vulnerability
The standard shall require that the organisation have a documented assessment’ requirements food fraud vulnerability assessment in place to identify potential vulnerability and prioritise food fraud vulnerability control measures.
‘Food fraud vulnerability control plan’ requirements
The standard shall require that the organisation have a documented plan in place that specifies the control measures the organisation has implemented to minimize the public health risks from the identified food fraud vulnerabilities.
This plan shall cover the relevant GFSI scope and s hall be supported by the organisation’s Food Safety Management System.

In order to ensure transparency, the GFSI Board believes that the mitigation of food fraud is an integral part of a company's food safety management system, and has therefore decided to include new requirements specific to food fraud mitigation in the next full revision of the GFSI Guidance Document 7th Edition which will be released in early 2016.

[6] GFSI POSITION ON MITIGATING THE PUBLIC HEALTH RISK OF FOOD FRAUD July 2014
The GFSI Board will support SSAFE’s initiative which aims to develop and publish practical guidelines for companies on ‘how’ to assess and control food fraud vulnerabilities within their organizations and supply chains. SSAFE is working to have these guidelines available before the release of Version 7 of the Guidance Document, so that companies and scheme owners can prepare their organisations before the new requirements are effective.

SSAFE (Safe Supply of Affordable Food Everywhere) is a non‐profit organisation addressing pre‐competitive issues for the food industry through public private partnerships




Thanks Tony...I learned a lot from your blog post. Very well researched and must have taken a lot of time to put together.  You have provided a great 'heads-up' on the current quality elements of the major GFSI standards as well as valubale insight on future trends.

 

Thanks,

Simon

The idea of having to do only one audit/certification was one of the ideas behind the GFSI from the start.  It would be tempting for people to use the FSSC 22000 if it would get rid of the ISO 9001 need.  I am in the process of considering which of the GFSI schemes to go with, and we are already have an ISO 9001 certificate.  So on its face, this would look good for us.

 

But after stepping back, this scheme would present problems for us:

  • Our customers are used to seeing our ISO 9001 certificate, so not getting it and trying to tell them that the "new and improved" FSSC 22000 is just as good is not the scenario that you want to follow
  • We manufacture some non-food grade products, and the FSSC 22000 would probably not cover them, so we'd have to get the ISO 9001 anyway.  The FSSC 22000 audit would only inspect our food grade areas, not our overall operation.

 

Right now, we get rated by AIB on top of ISO 9001.  I think that it would be easier to substitute a GFSI food standard for AIB when talking about our food grade products and tell the customers that it is an upgrade rather than try to educate our industrial customers that somehow ISO 9001 is contained in the FSSC 22000.

 

Interesting post, as Simon said (no pun intended), lots of work and analysis.  Thanks.

 

Martha