17 replies to this topic

[GMO]

As Tim suggested, here's a whole new topic.

 

Now I have to admit most of my career has been working with EFSIS then BRC then BRCGS with a bit of ISO and FSSC 22000 thrown in for fun.  So my experience across standards is limited.  

 

But I have seen a bit of "tension" about what GFSI is including into standards.

 

So what's your beef?  Share away. 

 

(I have no skin in the game and have never been in the room in the discussions of what is in or out by the way.)

[TimG]

Ok! So, I don't think I have a 'beef' per se but since I've been in the game, it seems like SQF in particular is updating code just to...update code. It's the natural tendency to bloat a decently working system which ends up diluting and removing the teeth of that system. It happens in government, corporate policy, anything where a bunch of folks get together to make rules and then have to keep making rules to keep their jobs relevant.

 

I'm looking to SQF to give me the code, audits, and corrective action feedback to put out SAFE QUALITY FOOD. I'm not looking to dance verbally with an auditor because s/he feels the table in the warehouse, while clean and physically sound, should be replaced because there are small barely recognizable surface rust stains on the legs. How is this helping me protect the food supply?

 

*Grabs popcorn because I know Glen is going to have something good*

Edited by TimG, 31 January 2025 - 04:30 PM.

[Scampi]

Here's mine in a nutshell

In 2000, the Consumer Goods Forum established the Global Food Safety Initiative (GFSI) to increase the safety of the world's food supply and to harmonize food safety regulations worldwide.

https://www.scienced...362028X22095424

 

 

About us (Consumer Goods Forum)

A Thriving Global Membership

The only organisation that brings consumer goods retailers and manufacturers together globally, we are CEO-led and help the world’s retailers and consumer goods manufacturers to collaborate, alongside other key stakeholders, to secure consumer trust and drive positive change, including greater efficiency.

 

https://www.theconsu...e-are/overview/

 

And then have a gander at the board

https://www.theconsu...d-of-directors/

 

Countries should be responsible for managing food safety AND trade relations.  This is is essence, industry creating a way to police itself by being the judge AND jailor

[jfrey123]

My beef is inconsistencies in enforcement around findings.  Anyone who has done an SQF or BRC knows your score is your score at the end of the audit, and findings are required to be CAPA'd to your CB's satisfaction.

 

But PrimusGFS farm/packinghouse audits?  Nah man, short of a critical finding, you can finish the day with an 81%, submit CA's and your certificate will show a 99% when it's issued.  I've seen farm audits where they flat out say "we will take this finding under advisement", auditor leaves it open on the CA report, and it only lowers their certificate score a single point.

 

Imagine telling your SQF auditor "yeah, we know you dinged us for not storing cleaning tools appropriately, but we're not going to change this year."  Unsatisfactory CAPAs to a finding get your SQF cert suspended.  Why GFSI allows for that difference in their approved schemes is something I hate.  I'm having to meet with a supplier next week because they got their Primus cert suspended due to a pathogen related recall.  They just finished a surveillance audit with 10 findings last Friday, 2 of which are likely related to why the recall occurred, and Primus already reinstated their cert.  Supplier wants to be taken off our hold to resume sales to us, "because now we have a good cert again!"  But from those audits I'm seeing in both Dec 2023 and 2024, they straight skipped their EMP swabs.  I'm not keen on reactivating a supplier with a recent recall and a history of skipping EMP swabs, but both my procurement and the supplier are telling me "they have a valid GFSI cert, what's the problem?"

[GMO]

Interesting perspectives.  I started back on the dim and distant past with BRC v4.  God I'm old.  And BRC back in those days stood for "British Retail Consortium" before they sold off the certification side (hence it now being BRCGS).

 

So I get the concerns as a result about this being retailer led (albeit there are a lot of multinationals in that group).*  But I also don't.  I've never worked for a retailer but I've worked closely with them and the pain they face when own branded goods end up in the headlines or in recalls is as much as we do.  Often with low resource in Technical.  Ultimately the aims of retailers and the aims of manufacturers should be pretty much in line with these standards, i.e. to prevent food safety and quality issues.

 

So I'm going to split into my beef and my gravy (gravy being the good bits.  To go with the beef analogy.)

 

Beefs

 

I agree the standards are variable.  I don't have a lot of experience with FSSC 22000 but I have been in plants that would get A LOT of non cons on BRCGS but don't on FSSC 22000 and I take the points about other standards above.  There needs to be more harmonisation.

 

BRC was designed to take away retailer audits in the UK.  So not a beef on GFSI per se but a beef on one of the standards.  That's how it was sold to the manufacturers.  It didn't work.

 

It costs to comply.  I think those costs are needed but that means that it's a hard barrier to entry for new business.

 

Gravy

 

What it does do though is limit some business to business audits for suppliers to manufacturers.  

 

GFSI with having some equivalence for global standards which are accepted across scheme has probably done more for the global food trade than anything.

 

GFSI standards go far beyond legislation.  While some MDs may see this as a bad thing, I do not.  A UK EHO audit is laughable in comparison to GFSI or retailer audit.  Unfortunately legislation is lagging and prone to politicians doing what they do.  This obviously has the hand of interested parties in it but it, to the most part, bypasses partisan politics and gets to the nub of food safety and quality.

 

 

------

 

*By the way if that worries you, you should check out the history of the new CEO of the Food Standards Agency in the UK.  Civil Servant through and through.  It would be marvellous if she at least had retailer experience but does not.  Zero food manufacturing background.  I fail to see how that is an effective appointment with relevant experience.

[SQFconsultant]

I actually see GFSI as imploding and give it about 1-2 years to do so.

 

We are entering a whole new world and there is no place for a UN & WEF affiliated organization to over lord food safety for the entire world - once you review the golden threads feeding the GFSI organization you'll understand why they need to go - I don't even think there will be a replacement for them.

 

I think we will also see dramatic changes with each scheme be it SQF, BRC, IFS,Global-Gap,FSSC etc. Some of these will be eliminated and eventually we may even see 1 standard for the entire earth.

 

Back to the UN by the way, at home in the states our new restored Republic is in process of shedding needless government employees and entire needless and overgrown organizations that served (not the people) corporations instead we the people - Federal employees (and this includes those with the FDA and USDA) are about to find their jobs gone, not that they actually did anything to begin with and of course every single employee that "worked" for the IRS (which is no more) is in process of being severed.

 

And,,, just like TimG, I am looking for SQF to give me what they are supposed to give me and nothing less.  

 

Leg rust, yeah - think on this...

 

It's about 25 years ago and I'm a brand new SQF Auditor, I've been working as a 3rd party auditor for about 3 years and I've been thru my witness audits and that day I flew out from Charlotte, North Carolina to Los Angeles and then drive up the coast to Bakersfield heading to a nut and blueberry grower/processor to begin day 1 of a 3-day SQF Audit.

 

I pull off the main road and drive about 2 miles into the property (rather large plot of land) and finally get to an absolutely beautiful oasis of about 100 acres that contains the owners house, a couple of office buildings (that also look like ranch houses), an employees cantina with exercise facility and a really nice pool, shipping facility - pre-process receiving building, helicopters - about 3 on a large landing zone area and a maintenance building - and a 500,000 sq. ft two level production building.....   there is nothing wrong with the exterior areas except for some weeds growing up thru a crack in the asphalt - so I mentioned that on my tape.

 

We do the paperwork first and there is nothing, nothing, nothing wrong - 100% perfect.

 

We visit the all the out-buildings and again - absolutely perfect.

 

We do the exterior main building walk-around and I notice some weeds growing up thru a couple of cracks in the asphalt and notice the employee walk-way path into the building is soil only, not sealed. and so I make a note about that on my tape.

 

The next day we do the interior -- everything perfect - and we entered the building from the tunnel instead of from the employee entrance side.

 

We exit the building at the employee ingress/egress area and there it is! 

 

Overnight, the owners had the entire walkway re-constructed, paved it, installed directional signage, built an extension on the building  that included a washing station for shoes, sanitizer, brushes, etc and every place were there had been weeds growing up they burned them out, re-leveled, filled in and paved over... except for one.

 

As we are walking back to the conference room, a maintenance employee runs up the owner and says they had run out of pavement filler - the owner looks at me and says, are we getting written up for that? (I had already decided to let it go) to which I said, no - as long as it's done before 5pm.  It was 3pm.

 

Sure enough, that maintenance employee did a 50 mile round trip, had the backhoe come over and at 4:58pm that area of the lot looked perfect.

 

Auditors sometimes key in on things and they get stuck in their heads, you can have a perfectly great Auditor and think you are getting a perfect score but it's that one little thing that is stuck in that guys head, and logically it just doesn't matter (like a little bit of rust on a non-impact piece of equipment) and regardless of any argument you can come up with it's going to get the gig in an otherwise perfect audit.

 

Now, I will add - every time we did an audit when we finished we'd call in to the Audit Director and provide the grade/score and brief summary - issues, etc - it was like our own internal audit corrective action session - when I called that evening the Director said, WHAT YOU GAVE THEM A PERFECT!?!   I'VE BEEN TO THAT PLACE, FOR A 3RD PARTY AUDIT TWO YEARS AGO -- THEY HAD CRACKS WITH WEEDS!!!!

 

Gee, whiz ya talk about an Auditor holding onto something!!!!

 

But getting back to the GFSI thing, If I did not think they were going away or that we would be eventually heading to a one-world food safety standard I'd be writing here about lots of things (beefs.)  They are nothing but a bunch of FQQKS that follow their masters in screwing with people's heads and exacting as much power and money as possible.

 

Yeah, Global this!

 

That should cover my feelings about them.

[TimG]

I feel Glenn is holding back and still did not disappoint. 

[Kara S.]

My issue with these 3rd party audits, and even the state/federal inspections, is that they spend more time looking at how well written your policies are rather than the production floor where the actual contamination events occur. Written documents can look great but are often poorly implemented. I rather see a 2 auditor system - 1 for policy and 1 for facility. 

 

Then these recent US recalls hit and everyone is like well how did they pass their GFSI audit?! ummm quite easily because more time was spent in a conference room rather than the production floor where the rest of management was cleaning up for the audit. GFSI has good intentions but also misses the mark sometimes.

[GMO]

 

That should cover my feelings about them.

 

You would raise some cracks in some external asphalt with weeds?  Why?  What's the food safety risk?

[GMO]

My issue with these 3rd party audits, and even the state/federal inspections, is that they spend more time looking at how well written your policies are rather than the production floor where the actual contamination events occur. Written documents can look great but are often poorly implemented. I rather see a 2 auditor system - 1 for policy and 1 for facility. 

 

Then these recent US recalls hit and everyone is like well how did they pass their GFSI audit?! ummm quite easily because more time was spent in a conference room rather than the production floor where the rest of management was cleaning up for the audit. GFSI has good intentions but also misses the mark sometimes.

 

I think that's poor auditing and standards needing to change.

 

BRCGS made a change years ago to identify which parts of the standard needed to be audited in the factory and which could be audited via documentation.  On my first audit after that change, the auditor insisted I brought the HACCP file into the factory then proceeded to do a paperwork audit on the HACCP documentation in our goods in area.  *Facepalm*

 

I had another customer auditor who would just collect document dates and would never actually read the documentation to see if it was any good.

 

Again.  *Facepalm".

 

The standards as I see them are perfectly able to be effectively audited, however, they could be made easier to focus more on reality rather than systems.  That said though I do think a lot of the problems I have with GFSI isn't the standard itself, it's the auditors and poor quality of them.  An auditing job used to be something people would go into, often freelance, late in their career to have more flexibility and get away from the 20-30 years of pain they'd gone through but also help newer Technical teams develop and understand what was needed.

 

Now, with pay for auditing in the UK at around the £40k p.a. you are not getting my experience on that salary.  As a result, the people who go into it have 2-3 years in food, often in quite junior level roles.  I was shocked to hear recently as well that one of the major CB bodies for GFSI and other standards don't treat travel time as working hours.  How on earth are you going to entice new auditors with those conditions?

Edited by GMO, 01 February 2025 - 08:43 PM.

[SQFconsultant]

You would raise some cracks in some external asphalt with weeds?  Why?  What's the food safety risk?

 

 

Not what I said, I said I had already decided to let it go, it was so less than minor in that environment.

[GMO]

Not what I said, I said I had already decided to let it go, it was so less than minor in that environment.

 

Hi SQF, no offence was intended by that.  I was meaning it wouldn't have been something I'd decide not to include it would have been something I walked past.  It had also apparently previously been noted from the comment you made.  That was all.  Seemed odd.

[Scampi]

 

The standards as I see them are perfectly able to be effectively audited, however, they could be made easier to focus more on reality rather than systems.  That said though I do think a lot of the problems I have with GFSI isn't the standard itself, it's the auditors and poor quality of them.  An auditing job used to be something people would go into, often freelance, late in their career to have more flexibility and get away from the 20-30 years of pain they'd gone through but also help newer Technical teams develop and understand what was needed.

 

Now, with pay for auditing in the UK at around the £40k p.a. you are not getting my experience on that salary.  As a result, the people who go into it have 2-3 years in food, often in quite junior level roles.  I was shocked to hear recently as well that one of the major CB bodies for GFSI and other standards don't treat travel time as working hours.  How on earth are you going to entice new auditors with those conditions?

 

 

 

Almost all auditors in Canada that are replacing the OG who are retiring are new to the country          they come with education for country of origin, but ZERO work experience here...............because, as you've stated, you cannot possibly live on the pay....................unless you're getting a kick back of some kind some where..............again to be clear.........this is my opinion based on my experience

[GMO]

Wow that never occurred to me Scampi and I've only once had a government employee try to get some free product. I've never personally had any GFSI auditor try for a kick back. But I hardly scream "I'm corruptable!" to look at! Do you genuinely think that's a thing? Don't get me wrong it is possible to live on £40k in the UK but not well unless your partner earns at least the same or more.

[SQFconsultant]

I was fortunate when I came into  the world of 3rd party auditing on the food side (+food packaging and transportation/logistics) in that I had lots of experience directly and in-directly and started off as an independent contractor at about $700 per audit (and only the audit time, getting there was not considered working time, but we did have a rather liberal expense budget), eventually I moved into a salary position at about $150 or so + benefit package.

 

With that said, in our team of about 20 Auditors I only knew of 1 Auditor that took bribes and he was drummed out quickly by Internal Affairs and personally (plus most everyone else on the team) had offers on a routine basis, we'd turn them down, document it (if we could) and report it to our company and the client - if we had enough documentation on it, it many times resulted in people saying goodbye to their positions and sometimes would result in being dropped as a supplier by the food chain.

 

Thinking back here - I can only really remember being offered $$$$ to throw an audit and one was an organic butter concern and the other was an absolutely DIRTY sausage company - make we shutter thinking about the mold dripping off the ceiling onto the lines - yikes.

 

More often the offers were for either their products or stuff like cars, gold, rolex watches, gentlemen club passes etc.

 

Couple of notables and funny too...

 

a famous chef down New Orleans way has a food processing company and line of products and cookware - his plant manager offered to fill my car trunk up with his signature cookware and a year subscription to their food delivery program.

 

a Rum company offered, you guessed it - 5 cases of Rum.

 

at a hotel where I did an inspection ( I worked for a hotel company for years as an Audiitor) the manager offered herself and her sister to me - it was unfortunate for her as I was wired and her offer was on the record - they got fired and signage got bagged for a week.

 

Hummer SUV from the owner of a potato company.

 

Well, there are others - but hey it would become boring.

 

40k would be ok if you were an intern/starter - but long term, better to start your own business or find another line of work.

[TimG]

 

at a hotel where I did an inspection ( I worked for a hotel company for years as an Audiitor) the manager offered herself and her sister to me - it was unfortunate for her as I was wired and her offer was on the record - they got fired and signage got bagged for a week.

 

Hummer SUV from the owner of a potato company.

 

 

LOLWUT!?!?

Just when I think my life is exciting, Glenn comes in here nonchalantly dropping history that could be the crux of a Netflix movie.

[Scampi]

Wow that never occurred to me Scampi and I've only once had a government employee try to get some free product. I've never personally had any GFSI auditor try for a kick back. But I hardly scream "I'm corruptable!" to look at! Do you genuinely think that's a thing? Don't get me wrong it is possible to live on £40k in the UK but not well unless your partner earns at least the same or more.

 

Well, a new Canadian say under 30, cannot possibly have enough work experience (as per the GFSI requirements) to have more than 1-2 categories under their belt but somehow can audit against almost all of them??   Really?????? you've worked more than 1 month in ALL OF THE CATEGOREIS   um nope====not possible

[Kara S.]

My issue with these 3rd party audits, and even the state/federal inspections, is that they spend more time looking at how well written your policies are rather than the production floor where the actual contamination events occur. Written documents can look great but are often poorly implemented. I rather see a 2 auditor system - 1 for policy and 1 for facility. 

 

Then these recent US recalls hit and everyone is like well how did they pass their GFSI audit?! ummm quite easily because more time was spent in a conference room rather than the production floor where the rest of management was cleaning up for the audit. GFSI has good intentions but also misses the mark sometimes.

 

 

I think that's poor auditing and standards needing to change.

 

BRCGS made a change years ago to identify which parts of the standard needed to be audited in the factory and which could be audited via documentation.  On my first audit after that change, the auditor insisted I brought the HACCP file into the factory then proceeded to do a paperwork audit on the HACCP documentation in our goods in area.  *Facepalm*

 

I had another customer auditor who would just collect document dates and would never actually read the documentation to see if it was any good.

 

Again.  *Facepalm".

 

The standards as I see them are perfectly able to be effectively audited, however, they could be made easier to focus more on reality rather than systems.  That said though I do think a lot of the problems I have with GFSI isn't the standard itself, it's the auditors and poor quality of them.  An auditing job used to be something people would go into, often freelance, late in their career to have more flexibility and get away from the 20-30 years of pain they'd gone through but also help newer Technical teams develop and understand what was needed.

 

Now, with pay for auditing in the UK at around the £40k p.a. you are not getting my experience on that salary.  As a result, the people who go into it have 2-3 years in food, often in quite junior level roles.  I was shocked to hear recently as well that one of the major CB bodies for GFSI and other standards don't treat travel time as working hours.  How on earth are you going to entice new auditors with those conditions?

 

I completely agree. How can you expect someone to have degrees for these roles and then pay them pennies? These shouldn't be viewed as entry level positions. This topic really irks me because we all know the problems, we're sitting here agreeing with each other on the short comings but we still have that red tape preventing real change. 

 

The intent of the standards and even the FSMA regulations is there. It's not working because the bulk of our food supply is all owned by several large organizations with investors and other stakeholders looking to make money. They look at numbers on a spreadsheet and what the assets are worth. They aren't seeing that "potential recall risk" first hand, that isnt taught in business school. Even though these standards and regulations say the owner in charge needs to "sign the HACCP/Food safety plan" and there needs to be a management commitment - it really missed the mark because it should be the CEO and true owners of the company, not a plant management. The only fix to food safety culture, is forcing it into the c-suite and holding them accountable for denying plant upgrades which lead to illnesses. There is a big difference between "sanitation failures" and not providing adequate downtime for cleaning and not providing a cleanable environment. 

 

I can ramble on forever... all my webinars try to integrate food safety and quality into the business, speak the same language, try new approaches to these issues. All we can do is keep spreading knowledge!

 

I do see the positive changes we've made as a food design/construction company by simply teaching them the actual food safety regs. The engineers love the FSPCA classes and it connects all the hygienic design/ sanitation/ food safety dots for them. I truly think the more folks outside FS&Q that take that type of course, the better. It has really given them the fuel to stand their ground on design decisions. Just on Friday, I had 2 electrical engineers wanting to know more about why we pick non-standard electrical fixtures in process areas so they can better communicate that to contractors and teach them about food safety concerns    proud food safety moment! Not related to why we all have minor issues with GFSI but food safety is connected to everything lol