12 replies to this topic

[Charles Chew]

Dear all,

Perhaps the title of the topic should be "Can zero tolerance concept be applied to food safety instead?"

Maintaining an effective Food Safety System in a dynamic environment has never been easy. Despite the emergence of new food safety standards with additional stringent requirements (i.e. PAS220, ISO22002-1-2009... etc) the world continues to be saddled with increased food contaminations i.e. recent re-emergence of melamine in China.

There are often conflicts between private interest and regulatory objectives through public governance and the gap is not getting smaller and thats where adulterated products continue to be in the market place.

To support worldwide reduction in food poisonings, should zero tolerance concept be integrated into a food safety system and where this is not achievable, should the concept of zero tolerance be viewed as an operating target instead.

The zero tolerance concept would likely to have direct/indirect link with your sampling plan structure, national MRLs for pesticides, migration, etc, including performance objectives (as raised by Jean recently) which are likely to be influenced by the tolerance of your Performance Criteria, ............etc i.e. including other performance parameters within the structure of your FSO.

Views and comments are appreciated.

Regards
Charles Chew

Edited by Charles Chew, 11 February 2010 - 07:49 AM.

[Abdul Qudoos]

You're absolutely right my friend, I agree...

Maintaining an effective Food Safety System is difficult in a dynamic environment and targeting zero tolerance concept to food safety impossible, changes and incidents happens anytime as we see in food safety news.

But we need to keep some objectives with target.

[Jean]

Hi Charles,

Is Zero tolerance in Food safety achievable?? I think my answer would be No in the fist place.

Pathogens are inherent in any foods. If we consider meat products, to ensure that it is safe for consumption, is by having effective sanitary / process control procedures in place and it has to be cooked thoroughly to safe time-temperatures ratio.
Sometimes guest orders for steaks which are blue / rare cooked, some ethnic foods like Sushi, sashimi, raw oysters etc, in such cases the pathogens reduction step is not met.

Emergence of new hazards need to studied more to have effective controls in reducing the risks. Emergence of new standards cannot guarentee zero tolerance, IMHO.

[Simon]

I think I would be helpful if we could define zero tolerance and in what context. Is zero tolerance the same as zero defects or is zero defects a result of zero tolerance. Everything has a tolerance, there is no such thing as perfection.

Zero Defects is Step 7 of "Philip Crosby's 14 Step Quality Improvement Process. For me it is not possible but it is a worthy goal. If you have all of the resources in the world at your disposal errors still happen.

Take NASA or a large airline even they do not achieve zero defects, planes fall out of the sky sometimes. Ongoing Toyota recall. These industries have highly mature and highly regulated supply chain with long standing quality management standards. They use concepts like six sigma.

Source: http://www.isixsigma...nt/c010101a.asp
The objective of Six Sigma Quality is to reduce process output variation so that on a long term basis, which is the customer's aggregate experience with our process over time, this will result in no more than 3.4 defect Parts Per Million (PPM) opportunities (or 3.4 Defects Per Million Opportunities – DPMO).

The holy grail (six sigma) even allows for 3.4 defects per million. That’s not even close to zero defects or zero tolerance.

People make mistakes. People who believe in that do not even comprehend that it’s the system that has failed. Systems thinking and mistake proofing and getting anywhere near to zero defects come only as a result of applied knowledge and experienced coupled with motivation and resources.

The vast majority of businesses do not have these prerequisites at their disposal. If we are being realistic continual improvement is the very best we can hope for.

Regards,
Simon

[Chac]

I doubt that zero tolerance is sensefull or at least practicable.
e.g microorganism: To reduce all microorganism from the product it is necessary to heat the product to a high temperature for a long time. In this case all nutrition values, like vitamins, will be destroyed, too. Also the flavour and the colur can be reduced or be influenced in a bad way (e.g. cooked flavour of heated milk). Therefore it's sensefull to fix tolerances in a way that health risks are not expectable.

I think the problem is not that there no zero tolerances but that the tolerances are not kept within some producers. The problem will still remains with a zero tolerance.

[Simon]

Any more comments on this interesting topic. By the way I think I have gone off beam with zero defects, I think. If I have let me know.

Regards,
Simon

[Charles Chew]

Countries have their own regulatory / statutory requirements (e.g. GMO-free status, MRLs, allergen declaration, etc); customers at times demand specific sampling plan tolerances to be achieved as part of business contracts; zero tolerance on religious requirements such Kosher / Halal key to breaking new markets..........zero tolerance is pretty much a way of life, well almost!

Of course we have the other side of the coin where zero tolerance can never ever be achieved such as becoming a "perfect food auditor" but we all know that is not possible. However, I would expect the "not-so-perfect" auditor to remain as professional as possible striving to be "perfect" - again that is only purely a personal target.

Recent accident involving the crash of two trains in Europe is clearly a case of zero tolerance practice that had wrong. Imagine, if zero tolerances under the HACCP Plan (critical limits) is out of control.

Cheers
Charles Chew

[Aegean]

Hi all;

This is quite famous subject isnt it ..
Zero target would always be helpfull but not easy to achievable . I can suggest that having specific zero targets for some specific materials/cases can be achieved . For instance ; I guess that it is not possible to achieve zero TVC in most of the ready to eat food products(like meat) , therefore putting zero target doesnt mean a sense .

It is almost the same with some physical or chemical( like pesticides) hazards in most of the agricultural products. If you follow zero limit ; means you will not be able to trade your product in the markets ; that would even cause big chrisis in tradeworld.

Sorry to be so pessimisstic ; but to me ;

keep zero as a target but if its logic :))


Bilge as Agean ..

[Charles.C]

Dear All,

I hope this is not too .

I deduce from previous posts that most people here believe that a zero level of pathogens in RTE foods is not attainable. And yet I frequently see posts here where cooking is claimed to "eliminate" the pathogenic content. I wonder what percentage is actually removed ?

So what (maximum) low level of, say Salmonella, do you think should be attainable for a (classified) RTE food ?? I'm sure that Cadburys would like to know.

The current reality of course is that in most places (bar USA) zero presence is typically interpreted as non-detection in 5 samples. And we all know how meaningless that is for protection purposes.

(BTW, It's interesting to note that the organisation in USA which did a lot of the original research into the "Salmonella Problem" actually proposed that positive detection in their 30/60 etc sampling scheme should be allowed since this generated a more effective long-term sampling plan. Was ruled as (politically?) unacceptable logic for regulatory purposes.)

Rgds / Charles.C

[Charles Chew]

Before further divergence of the topic occurs, IMO the interpretation of "zero tolerance" would basically involve set criteria where the degree of acceptability and non-acceptability would determine the degree of tolerance e.g. a specific food process performance criterion versus process performance objective indicated a process failure (may be due lack of technical capability) - can we therefore accept accept this failure to meet the process performance range?

As such, IMO, zero tolerance is not about zero defects or zero targets! Its about the degree of tolerance allowable if permitted. e.g. if say Taiwan has an MRL for "Streptomycin" in Milk of say 0.2ppm this would become a regulatory requirement. Therefore, this is a zero tolerance requirement. Exceeding 0.2ppm would render violation and unacceptability.

I would reckon the situation is the same as that of a "2-Class versus a 3-Class Sampling Plan" where C = 0 for 2-Class Sampling Plan.

Again views are appreciated.

Cheers
Charles Chew

[Charles.C]

Dear Charles Chew,

The re-statement was a timely idea. Nonetheless, it still seems difficult to me to lump BCP hazards into a generalised response.

As such, IMO, zero tolerance is not about zero defects or zero targets! Its about the degree of tolerance allowable if permitted. e.g. if say Taiwan has an MRL for "Streptomycin" in Milk of say 0.2ppm this would become a regulatory requirement. Therefore, this is a zero tolerance requirement. Exceeding 0.2ppm would render violation and unacceptability.

No problem regarding your concepts assuming a limit consensus is feasible. The recent melamine scare suggests such is not always so easy ([cold-blooded] risk analysis vs the [human reactive] precautionary principle perhaps).


I suppose you could have a Salmonella requirement like < 0.008cfu/g (undetected in 5x25g sample) but doesn't seem quite so impressive as zero tolerance. Legally acceptable?, somehow I doubt it.

As half intimated in my previous post, I do fear that analytically, chemical limits are a magnitude easier to implement than microbiological.

Perhaps the phrase "operating target" was initially a little ambiguous. Relating it to yr 2class/3class extrapolation does hv some precedent in the microbiological business, eg L.monocytogenes. Risk analysis allowed the original zero tolerance to be softened (in some locations anyway). However that case is a very rare exception in the ZT genre.


Rgds / Charles.C

Added – the above L.mono comment was related to Ready-To-Eat foods of course. As another response to the thread title consider -

(a) Many HACCP plans for raw finished products assume Salmonella is typically present in the raw material / final product but evaluate as a hazard of non-significant risk due to the ultimate consumer cooking.
(b) Many legally sold retail raw products are known to exhibit substantial frequencies of Salmonella content, eg eggs, chicken.

But how many finished raw product specifications include a statement like - “Salmonella may be present in 25g” ?

[Eya]

Hi all,

For me the word "zero tolerance" is just saying that all limit/standard set is met religiously with "zero deviation". This may vary from country to country depending on their local regulation. Some country are stricker some country are not. Lets say for instance microbial count or pesticide content in US and europe it will be much lesser compare with what is being implemented in asia like china and india. The same as allergen content may be its a requirement for other country but from where i came from the goverment still at the far side of the world.

[Charles Chew]

Dear Charles C.

Nonetheless, it still seems difficult to me to lump BCP hazards into a generalised response.

I agree. Determining specific tolerance criterion should be assessed after taking into consideration the defined BCP hazards within the implicative conformity and compliant requirements which will certainly differ amongst various processors even of the same industry.

Having said that, every process has a specific performance objective (PO) and monitoring the effectiveness of the PO within the overall FSO would certainly co-relate to the stringency of the performance tolerance be it FSMS or QMS etc.

Comments appreciated.


Rgds
Charles Chew