9 replies to this topic

[gcse-fhp]

It goes without saying that we all need to take stock from time to time to assess our success rate no matter the engagement. This equally applies to such industry self-assessment process as the GFSI audits. We need to constantly and properly measure our success rate with these audits and other engagements through valid and effective means. This helps us to better apply and manage our resources to the benefit of all parties.

The success rate of GFSI based on the increasing number of operations being audited against GFSI standards worldwide is well published and it is both impressive and encouraging.

Another valid self-assessment by the industry should show the percentage of operations audited against the GFSI standards that are involved in recalls and how this percentage has decreased from the early implementation of GFSI standards to the present, and on-going.

Does anyone from the industry in general, regulatory bodies, the GFSI organisation, the standard owners, etc. know how this percentage is tracking? This, of course, should be of interest to the industry as a whole (the GFSI organisation, audit standard owners, auditing companies, food business operators, regulators, customers, consumers, etc.).

Does anyone know if and to what extent the percentage of operations audited against the GFSI standards that are involved in recalls has decreased?

Edited by gcse-fhp, 18 May 2012 - 11:24 AM.

[Simon]

I can guarantee there is no data on that. But then again is a recall a bad thing? If a company has voluntarily invoked a recall or a withdrawal then that demonstrates they have a functioning FSMS (that identified a problem) and they are not prepared to sweep it under the carpet.

It's a bit like saying the number of food poisoning illness is going up, is it really, or is it just better identified and reported these days.

Regards,
Simon

[Cranberry]

Good point Simon, it is the same with complaints. My last company produced own label products for a number of major retailers. Although we produced similar volumes for each of the retailers about 75% of our complaints came from one particular retailer. Nothing to do with the product, their complaint capture was just much better than the others (both in terms of total numbers and also speed of relay to us and organisation of the system).

On a synical note, do all recally worthy situations result in a recall? Bet some get swept under carpets and fingers crossed...

Edited by Cranberry, 18 May 2012 - 03:58 PM.

[gcse-fhp]

We must agree on a common base of assessment. Hence the percentage approach rather than mere numbers. The explanation that recalls indicate that the food safety management systems (FSMS) are working begs a number of questions:

• Are these FSMS intended to ensure proper recall or are they intended to prevent recalls irrespective of being voluntary or not?
• Should industry operators, customers and consumers rest satisfied that situations leading to product withholding, withdrawal and recalls are being caught after products have been fully processed, packaged, inventoried, shipped, etc.?
• What is the actual role of the GFSI standards and audits? Are they designed to help the facilities ensure only before sale identification of issues or are they supposed to help the facilities prevent the occurrence of such issues in the first place.

I am inclined to believe what Cranberry said about all recall worthy situations not being reported for obvious reasons. It is difficult for me to say there is absolute transparency on the part of all industry operators today. At the same time, nobody wants a bad name. Nobody wants to be held liable for causing consumer illness, injury or other losses.

Catching recall situations is not enough. The GFSI assessment standards and audits are intended and designed to help operators prevent product safety failures. How well are they doing this?

Such guarantee as put forth by Simon that there is no data to demonstrate this kind of success with the GFSI system leaves one discouraged on many fronts. It means that the industry is blindly engaging in this enterprise. In that case, it is a sad commentary on how we have engaged our collective intelligence in this matter. This is also contrary to my belief that we have great minds out there. The reality and encouragement is that we can do better. We can measure whether or not we are succeeding in what we are doing in this regards in order to more properly allocate resources, direct or re-direct our actions, etc. for the benefit of all.

Blindly saying “we are doing well” without the hard facts to prove it is out of the question.

Edited by gcse-fhp, 18 May 2012 - 09:22 PM.

[gcse-fhp]

All instances are not voluntary - One example of a supposedly GFSI certified operation with more than one recall within a two-year period (2011 & 2012):

River Ranch Fresh Foods, LLC of Salinas, CA

This operator is reportedly certified under a GFSI benchmarked and fully recognized audit scheme covering both GAP and GMP scopes as well as food safety management systems (FSMS). Document PDF

Certified Suppliers

PrimusGFS is a Global Food Safety Initiative (GFSI) benchmarked and fully recognized audit scheme covering both GAP and GMP scopes as well as food safety management systems (FSMS). The PrimusGFS is owned and managed by Azzule Systems. PrimusLabs was the first Certification Body to be ISO 65 accredited and Azzule approved for this new GFSI audit.

Recall/Withdrawal Instances:

Previous (2011)

1. FOR IMMEDIATE RELEASE - October 13, 2011 - River Ranch Fresh Foods, LLC of Salinas, CA is initiating a voluntary recall of 2,154 cases of various bagged salad products due to the potential of being contaminated with Listeria monocytogenes following a routine random test conducted by the Ohio Department of Agriculture.

The bagged salad products subject to the recall include products produced on September 27, 2011 with Best By dates of October 14, 2011.

2. RECALLS AND FIELD CORRECTIONS: FOODS - CLASS I

PRODUCT
1) River Ranch Romaine Garden Salad; 10 oz plastic bags, 6 x 10 oz bags per case. Recall # F-0613-2012;
2) River Ranch Shredded lettuce; 8 oz plastic bags, 12 x 10 oz bags per case. Recall # F-0614-2012;
3) Hy-Vee Garden Salad 1 lb plastic bags, 18 x 10 oz bags per case. Recall # F-0615-2012;
4) River Ranch Coleslaw 10 oz. plastic bags, 16 x 10 oz bags per case. Recall # F-0616-2012
CODE
Best If Used By date of 4 NOV 2011
RECALLING FIRM/MANUFACTURER
River Ranch Fresh Foods LLC, Salinas, CA, by letter on October 18, 2011. FDA initiated recall is complete.
REASON
FDA Environmental samples found two sub samples positive for Listeria monocytogenes.
DISTRIBUTION
IN, IA and Canada

Recent (2012)

US-FDA

FOR IMMEDIATE RELEASE - May 18, 2012 - River Ranch Fresh Foods, LLC of Salinas, CA is initiating a voluntary recall of retail and foodservice bagged salads, because they have the potential of being contaminated with Listeria monocytogenes following routine random retail salad finished product tests conducted in the marketplace by the Food & Drug Administration.
The recalled retail and foodservice salad bags have either “Best By” code dates between 12MAY2012 – 22MAY2012 or Julian dates between 116 – 125. The code date is typically located in the upper right hand corner of the bags.

Canadian CFIA
OTTAWA, May 18, 2012 - The Canadian Food Inspection Agency (CFIA) and Sobeys Inc. are warning the public not to consume Compliments brand salads and prepared foods described below because they may be contaminated with Listeria monocytogenes.
The Compliments salads, product of USA, affected by this alert have best before dates of 12MA12 to
12MA22, inclusive.

Are there other examples of operations like this worldwide?

[gcse-fhp]

Here is another example for you to examine:

Gills Onions' Commitment to Food Safety and Quality is Proven with Audit Results: http://www.gillsonions.com/node/203

Oxnard, CA - January 27, 2011 – Gills Onions, the market leader in fresh-cut onions, was awarded the SQF 2000 Level 2 accreditation for HACCP Based Food Safety Plans last month. Unique to other third party audit programs common in the fresh produce industry, SQF 2000 is a three tier certification system that recognizes companies who implement food safety programs beyond the fundamental industry standards.
“. . . We take pride in our ability to deliver consistently excellent products, and the SQF 2000 certification results are just one more way for us to relay that message.”

Recent (2012) recall Notice: http://www.fda.gov/S...s/ucm304732.htm

FOR IMMEDIATE RELEASE - May 19, 2012 - May 19, 2012-Gills Onions, LLC of Oxnard, CA is initiating a voluntary recall, 2,360 pounds, of diced red onions with lot code 51RDA1A2119 and use-by-dates May 14, 15 and 17, 2012 because it may be contaminated by Listeria monocytogenes. The product is beyond its use-by-date, no illnesses have been reported in connection with this recall, and no other Gills Onions product is affected by this recall.

This “voluntary” recall was initiated as a result of a routine and random test directed by the Canadian Food Inspection Agency.

This incidence appears to indicate that it takes more than SQF 2000 (GFSI benchmarked standard) certification results to relay the message of a company's consistent and excellent product safety performance.

Edited by gcse-fhp, 20 May 2012 - 08:24 PM.

[Simon]

I don't get the point you are trying to make posting individual examples of companies.

There are tens of thousands of businesses that are certified to one of the GFSI standards and I can guarantee the vast (silent) majority of companies who do work to GFSI standards improve their performance, they may not be perfect, but at least they are regularly audited to a standard and have a food safety management system in place. Perfection doesn’t happen overnight, things can and do go wrong.

By the way do you have a better alternative?

Regards,
Simon

[gcse-fhp]

Hi Simon,

Thanks for your post and I am glad you asked. There are alternative approaches that could be adopted to resolve the issue that I am highlighting. In fact most of my posts provide tidbits about alternative approaches and practical action steps that may be taken. There are also posts by many others on currents approaches and their failure to meet the food safety needs of consumers. These posts are not hard to find. If you need specific links to my posts please let me know.

My lament (which ought to be the lament of the entire industry today) is that our target and focus are wrong. Until the target and focus are set right, we will continue to miss the mark. We should not be looking at the companies’ certification audit reports. We should be looking at how the products are actually doing in terms of being safe and satisfying to the consumers. Looking at polished programs, records from forced record-keeping, and fallacious practices because the auditors are present will never tell us what is actually happening. These may give us some satisfaction that we have done a lot. The reality is showing contrary to this sense of satisfaction.

Even where we may think, as you stated, that many companies working to GFSI standards improve their performance, the examples I have given show contrary to this presumption. The point really is this: No one seems to be doing a proper and factual tracking to support this “improved performance" claim.

Hence this post that calls us to properly and honestly take stock of our progress instead of making unsubstantiated claims about it. Irrespective of all the claims about our progress that we can make, a quick peek at the number, frequency and ubiquity of recall incidents will not allow us to rest satisfied.

This is in fact an urgent matter. One person becoming ill or dying because of one occurrence of a food-borne illness is already too much since I would not want to be that person. The argument that “people die all the time from all sorts of things” is also not acceptable where something can be done to avoid such deaths as are caused by failed food safety programs and controls. This is the point of the GFSI schemes - to ensure fail safe food safety programs. Is it not?


Regards,
gcse-fhp

Edited by gcse-fhp, 21 May 2012 - 11:28 PM.

[AnkushK]

Hello Folks,

This was an interesting conversation, where both Simon and GCSE-FHP have put their input on effectiveness (positive or negative) of GFSI standards. As a matter of fact, one could get the best out of both.

Yes, GSFI standards are now accepted world-wide and they are written with a great objective of bringing the entire food industry on a common platform because life on all the corners of this planet is equally important. So, we should not raise any question about the integrity of these standards. Yes, they can be improved over time and things can be added, as we encounter new problems in the industry. Now for a company being GFSI certified, if it really doesn't avoid recalls, it still helps mitigate the food safety risks. My question is that, is there any data or survey done by someone in the industry, which tells us, has any company avoided recall like situation with effective implementation of GFSI standards? Is there anyone out there, who would say, we would have been in trouble if we didn't have these food safety programs in place? I am sure there will be incidences like this, which people have encountered. So, I strongly support effective implementation of these standards.

However, most of the external audits are done annually and rest of the time, it is the company's management and staff who take care of their food safety systems. So, there may lack of proper implementation of these standards during the peak season of production, harvest or for what ever reason. And that's when these systems fail because top management sometimes really force them to take short cuts. So, it is still wise to see the data, which GFSI approved companies had recalls often. If the recall is being repeated by the same company over the course of say three years, then they really got some problem in the effective implementation. If it was once in three years, then it is the same thing which Simon said " things can and do go wrong " once or twice.

[gcse-fhp]

Hi AnkushK,

Thanks for joining the discussion. We must not rest satisfied precisely " things can and do go wrong ". The frequency and pervasiveness of this problem calls for a -examination of what we are doing. We need to particularly look at and eliminate the counter-productive aspects of what we are currently doing. I personally think a major (no, a seismic) change in approach is required.

This is why the seeming complacency in spite of what we are seeing is troubling. Does it not matter as long as I am not directly affected? Sadly we are all affected even when we do not all feel the wind at the same time. Hey! Now there is a line for my twitter post today.

By the way, I like your "Simon Says".

Regards,
gcse-fhp

Edited by gcse-fhp, 22 May 2012 - 12:22 PM.