22 replies to this topic

[Simon]

John Surak is the US Representative on the ISO Committee developing the ISO 22000:200X Standard.
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Comparison of ISO 22000:200X Food Safety Management System Requirements and The BRC/IOP Technical Standard and Protocol for Companies Manufacturing and Supplying Food Packaging Materials for Retailer Branded Products The BRC/IoP Packaging Standard

Type of standard
ISO has several types of standards. One type are auditable standards. These standards are developed in a manner that all elements are applicable (unless stated otherwise (exclusions)) and must be implemented. In addition, ISO also develops guidance standards. These standards can be used by organizations to provide an interpretation of the auditable standard.

For example ISO 9001:2000 is an auditable standards. ISO 9000:2000 and ISO 9004:2000 are guidance standards that are used to interpret ISO 9001:2000.

ISO 22000:200x will be a guidance standard describing the requirements of a food safety management system, it will also be an auditable standard and can be used for certification and registration. The scope of the standard will be food safety. Food quality issues are to be addressed using ISO 9001:2000.

It appears that the BRC/IOP standard does not completely separate the food safety issues and the quality issues. In addition, it appears that the BRC/IOP standard combines both requirements and interpretation of the requirements.

Detail of the standard
ISO 22000:200x appears to be less prescriptive than the BRC/IOP standard, in that it does not address in detail the Good Manufacturing Programs (GMPs), (Good Hygiene Programs) or prerequisite programs.

Structure of the standards
ISO 22000:200x will be compliant with ISO Guide 72. ISO Guide 72 is a standard that describes the structure of management system standards. This will ensure that the ISO standard has a parallel structure to ISO 9001:20000.

It appears that the structure of BRC/IOP is similar to ISO 9001:1994. ISO 9001:1994 will be completely withdrawn as a standard at the end of this year.

Scope
The two standards appear to have different scopes. ISO 22000:200x is intended to be used by organizations throughout the food chain, while The BRC/IOP Standard is intended to be used by food packaging organizations.

Comments
The following question was raised. Will ISO 22000:200x replace The BRC/IOP Standard? It is hard to predict the future. I would expect that as an auditable standard or a standard that can be used for registration / certification, the answer will be yes.

However, there may be a need in the UK food industry to have a standard that could provide more guidance to the food packaging companies on the interpretation of the GMP or prerequisite programs.

With regard to industrial sectors, I do not expect to see it subdivided within the food chain. I do not know if there will be the development of any guidance standards.
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Saferpak Summary

ISO 2000:200X will:

- Be International
- Be applicable to the entire food chain
- Be auditable and can be used for certification and registration
- Be structured / aligned with the 8 clauses of ISO 9000:2000
- Require the implementation of relevant industry GMP's and Standards as prerequisite measures e.g. The BRC/IoP Packaging Standard (to put the meat on the bones).

Well what does it all mean and will organisations certified to The BRC/IoP Packaging Standard be affected?

Without the aid of a crystal ball it is difficult to say, as we don't know at this stage what the exact requirements of ISO 22000:200X will be. On the face of it does make good 'systems sense' for the structure to be aligned with ISO 9001:2000. And if the standard contains requirements for monitoring and measurement of customer satisfaction on food safety issues and for establishing a process for continuous improvement - then it looks very interesting.

For food industry organisations who trade solely within the UK there may never be a requirement to become ISO 22000:200X certified on the other hand global suppliers of packaging may well start receiving requests from customers early in 2005.

ISO 22000:2000X is not going away so the question is:

Should The BRC/IoP Packaging Standard and The BRC Food Standard be reviewed and amended in line with ISO 22000:200X?

A proactive approach now would ensure minimum discomfort should certification to ISO 22000:200X become a requirement in the future?

Simon

[Charles Chew]

Hi Simon

I want to get ready for ISO 22K and I have recently put in some thoughts on some of the comments from John Surak during the review on ISO22K / BRC.IOP

It does not sound as prescriptive as feared which means each system can stand alone through integrations and yet have two auditable systems (which also means spending more money.....hmm)

Do we need another ISO standard when BRC/IOP or HACCP is already food safety based.

In my industry, having a dual system as in ISO 9001:2000 and HACCP means not only does the food looks good, smells good and tastes good (ISO 9K) but it also means that when you consume the food, you would not sick as a dog (HACCP).

I wonder what can I say about having an ISO 22K on top of what we already have....hmmm.


Charles Chew

[Simon]

Possible benefits are:

1. It will be Internationally recognised. Although most probably customers will still require their own country or industry specific standards and guidelines to provide the prerequisite programs and GMP's.

2. ISO 22000 will have a parallel structure to ISO 9001:2000 allowing for easier integration and maybe even requiring continual improvement.

3. Make consultants and certification bodies wads of money.

Hard to say until we've all read it.

Can anyone think of any other possible benefits?

Regards,
Simon

[Charles Chew]

Benefit 1 - HACCP is already internationalised by WHO / Codex and so is ISO 9K. No added advantages. In fact, in my country, Malaysia, BRC/IoP Certification is offered through international consultancy firms which perhaps retailers like Carrefour and Tesco are already working on it.

Benefit 2 -Already integrating HACCP with ISO 9K without any hassles. Don't need any integration!

Benefit 3 - Love this one


Charles Chew

[henrysilvag]

hi charles
My name is Henry and I would like to give you my view about this issue.
I am a consultant in Spain so you can see I love simon's third point of view.

Iso will harmonize many protocols regarding food safety.
BRC or IFS are autidable PARTICULAR standars but cover a very much wider aspects than ISO 22000.

ISO 22K will be international, what this means is that any arganization certified with ISO 22000 can say to any client anywhere that your products are safe, that your HACCP works (not only by internal audits but for a certificaton body). HACCP can only be certified by the duch standard nowdays. It is really a thrust issue. Nobody wants to thrust anyone even more in food bussiness.

I don´t know if you have a deep knowledge of BRC or IFS or EUREPGAP or EFSIS or DS or HACCP standars but their problem is that their documentation structure doesn´t aloud you to compagin it with ISO 9001 what in many cases duplicate documentations and records.

I am sure iso will simplify work and what everybody will have in a few years will be and integrated ISO 9001:2000 and ISO 22K

YOu can also still have a oparating BRC or IFS or any other inside ISO 22K within the Pre requisitives section but you wón´t have to certified with all of them.

For a example: One company which I sometimes work for: They export cookies to the whole world. They have about 15 audits from differentes standars every year. This means about 3000 Euros for each one, this mean about 50000 Euros a year plus my company fee. If ISo 22K can reduce this anual cost I am sure It will be a success.

[Charles Chew]

Hi Henry,

I am from Malaysia and is currently involved in HACCP and ISO 17025 more as an interest than anything else.....you know some thing on the side BUT my main interest will be production of medical consumables which will be off the ground soon.

See why you love Simon's third point of view. We share some common interest here. However, you cannot really compare HACCP with ISO 9K because they are both based on different principles. There are many Certification Bodies for HACCP worldwide and audit procedures are fairly similar although I would agree with you that a company exporting products to USA would prefer a HACCP Alliance Audit Standards while for EU countries, EFSIS may be another option. Dutch standard is but only one of them, however, one thing is for sure........lots of audit fees are gping out.

If ISO 22K is going to be less prescriptive, I wonder if it is desirable to pursue it when recognised current accredited schemes are already sufficient to proof what we are doing is enough. Adding more documentations to an already congested "paper environment" may be counter effective particularly to the small and medium size organizations.

Until the final draft is out, I am not sure if ISO 22K would add any thing more effective to what is already put in place in current schemes but if duplications prevail, maybe cost saving is an interesting point. An example is SA-8000 in comparison with ISO 18000 / OHSAS!

Charles Chew

[rheath]

ISO 22K will be international, what this means is that any arganization certified with ISO 22000 can say to any client anywhere that your products are safe

Henry,

By this logic, I assume that you would advocate any company that has ISO 9001 provides a quality product?

Regards

Richard

[SAM]

OK, so if we are going to look at implementing 22k does that mean we can get rid of 9k2k or BRC, or will we end up having to run all three togeher?

Nadine

[Charles Chew]

Sam,

If you go back a year, ISO 15161 was established as a implementation guideline to integrate 9K2K with HACCP. What happen to it?

Yet you probably have heard of HAXXP:9000 which is still in the market but I am not sure whether companies have a reason to go for it.

There are good reasons for wanting a new industrial standard (for whatever the purpose) but it is difficult to achieve a global embrace. Implementing global standards is not just about integrating or combining some prinicples of HACCP, BRC/IFS, ISO9K plus few new stuff and presto! you have a New Standard.

From my observations and feedback, none of the companies that I know are keen to even embrace ISO 15161 integration let alone ISO 22K. General comments were, if the current system is working well for you, why change? Well, ISO 22K has got to provide significant "benefits" to warrant any serious management review.

As the saying goes, "if it ain't broken, don't fix it" Understandably, we need to move forward.

to be fair, the final draft of ISO 22K is not out yet but I am certainly very keen to have a good look at it though.

Charles Chew

[hak]

The key disadvantage with the current state of HACCP schems are that international accreditation bodies have not come up with a harmonised
approval method.

RVA has gone onits own with its version of HACCP certfication , most
larger registrars have jumped on this one and are issuing certificates
with RVA accreditation.

ISO 2200 will probably allow IAF and its members to come to terms with a
single HACCP scheme. ISO 15161 is leading us towards this path already,
however, there is an urgent need for accreditation agencies to provide a
roadmap to the future harmonised HACCP approval method for CB's.

[Charles Chew]

Dear Hak,

You are so right. ISO 15161 has been around for too long but it was meant to fulfill and guide integration for ISO 9K towards FSM. Now that we will soon be having ISO 22K, it should take its own course.

We are also heading towards RvA with our associate, a major CB even to the extend of ISO 22K which accreditation is being worked out right now priot to the DIS becoming standard soon.

As for HACCP, a harmonised approval method is exactly the problem I am facing with inexperienced food auditors. (See my latest posting on the HACCP Section - Should Auditor Play God?). This cannot come at a better time.

Look forward to your further contributions.

Regards
CharlesChew

[masculinie]

Correct me if I'm wrong....

HACCP is a process which has to be founded upon some Good Manufacturing Practices not really standardized currently.... and is itself at the Inspection and Testing level - and is part of and not a management system to stand alone....

ISO 15161 has both the specifc Good Manufacturing Practices and the management system requirements.... - unfortunately the 'added requirements' on GMP are too much for many of food-related companies.... -hence making it hard to take off the ground....

Hopefully the ultimate ISO 22000 satisfies the purpose of better defined
yet feasible GMP generic enough for the Food Industry worldwide.... while uplifting itself to the management system level for both food quality and safety....

As it is at present.... HACCP can still be arbitary subjected to Auditor's demand of GMP for food safety.... while ISO 9001 is running separately for food quality....

[Charles Chew]

Hi,

Welcome to the forum. My personal viewpoint on this subject. HACCP is currently the ONLY Food Safety Program recognized by WHO supported by CODEX. And, it is a system that concerns STRICTLY Food Safety Issues AND it is NOT part of any other systems esp. ISO 9K2K.

HACCP is also not a loose "canon system" so to speak but the Auditors may be with regards to interpetations as each ind. have different opinion. The same goes to ISO 9K2K when it comes to auditors' report and intepretations.

Whereas, ISO 9K2K is ONLY a QMS that deals with quality issues. ISO 15161 was established for integration purposes so that ISO 9K2K could incorporate its deficiency in safety issues from HACCP. You are right. It was not positively received .

Then comes along DIS 22K which is really almost the same as HACCP + ISO 15161 in a way. Remains to be seen how far reaching the impact will be in terms of support. What do you think of the impact?

Charles CHew

[masculinie]

I see that ISO 22K is purely for HACCP with reinforcement of additiional requirements for verification, validation and justification requirements with a management-sytem-like outlook.... without monitoring of objectives - it is for food safety without food quality....

It is neat in falling back to all Codex Codes of Practices for good practices in respect of specific industries....

Depending on the literacy and proficiency level of the food industry.... also the consumer awareness of their food safety rights....
ISO 22K may travel far with comparison to HACCP....yet could be very slow.... - but eventually it should grow without being aborted....

Just a matter of opinion.... my crystal ball works sometime - but it doesn't other times.... without consistency :)

Masculinie

[Simon]

ISO 22K may travel far with comparison to HACCP....yet could be very slow.... - but eventually it should grow without being aborted.  Just a matter of opinion.... my crystal ball works sometime - but it doesn't other times.... without consistency :)

<{POST_SNAPBACK}>

If ISO 22000 isn't a success believe me it won't be caused by lack of interest from Consultants. I'm seeing a tremendous amount of interest in what is an Unpublished Standard. I get several emails every day asking for information, the ISO 22000 page on the web site has by far the most downloads and the ISO 22000 discussions on these forums are quite well represented too. Can anyone smell money?

Believe in your Crystal ball Masculinie...I think it speaks the truth.

Regards,
Simon

[masculinie]

The free market mechanism will be.... leaving it to the consultants and trainers to stir up the market interests.... and consumer pressure shall be on the toes for food-seller competitiveness and interest sustainablity....

Judging on the literacy and proficiency if not (the lack of) management level of the food industry in general.... - there is a mountain of gold say 10 years ahead awaiting the able and professional consultants and trainers....

However.... bringing the food industry in general.... at its current level.... in particularly those SME's.... to willing FS Control to FS Assurance to FS Management to FS Management-System level - could post a big challenge to interested trainers and consultants....

Working on a CCP Plan and a SSM Programme is fine once they are worked out.... working on justification, verification and validation does require helps from the external experts in many cases....

But then the fat margin and the big sales volume of the food industry.... shall be able to absorb the reasonable professional fees of the external experts....

However.... one shall be looking 10 years ahead....

The initial years can be TOUGH.... and require a few big buyers in the market to insist on ISO 22K to expedite the market needs....

In general.... I'm pretty optimistic about the batch life of ISO 22K....

Personally I cannot sing too loud to invite the already keen competition.... :)

Good vision and judgement of yours Simon.... - lets pray that we are right.... only time will tell.... :)

Masculinie

[Simon]

I'd say it will be more like 3-5 years rather than 10 before we reach critical mass. I think maybe the biggest opportunity will be in the developing markets such as Asia, I say this based solely on the interest and communications I've had personally from this region.

Regards,
Simon

[Charles Chew]

Working on a CCP Plan and a SSM Programme is fine once they are worked out.... working on justification, verification and validation does require helps from the external experts in many cases....

An excellent point from record keeping and system maintenance angle.

It just confirms the current average levels of understanding of basic Haccp in my country / region, that I do not envisage ISO 22K to be significantly embraced inside the 3 years of standard implementation but rather sporadic interests specifically amongst those that had been driven to both certifications and integrated. But the major problem lies in the fact that the market needs to recognize and ACCEPT that an ISO 22K indeed comprises of HACCP and to some degree QMS (as it is not required to integrate the entire QMS) .................which may represent a potential problem here.

Also, there is this issue of "cannibalising" effects on ISO 9K2K if ISO 22K is fully integrated with QMS.

It would be true though that consultants and trainers will be driving hard on ISO 22K as it would represent a new source of potential income. Personally, if ISO 22K is not well accepted within the 3 years to create a global impact, I am afraid it may have the fate of ISO 15161..............lets hope not.

Much to consider before the market is trully tested.

Charles Chew

[Lion Maru]

"It would be true though that consultants and trainers will be driving hard on ISO 22K as it would represent a new source of potential income. Personally, if ISO 22K is not well accepted within the 3 years to create a global impact, I am afraid it may have the fate of ISO 15161..............lets hope not."

Do you think there will be any added weight to the document now it has been officially adopted as a European work item? e.g. when published it will be EN ISO 22000 - which as I understand it means it HAS to be implemented by the National Standards Bodies in the various EU states - as opposed to ISO 15161 which was only an ISO and therefore no obligation for inidvidual countries to adopt it?

[Simon]

Do you think there will be any added weight to the document now it has been officially adopted as a European work item?  e.g.  when published it will be EN ISO 22000 - which as I understand it means it HAS to be implemented by the National Standards Bodies in the various EU states - as opposed to ISO 15161 which was only an ISO and therefore no obligation for inidvidual countries to adopt it?

<{POST_SNAPBACK}>

It may help, but at the end of the day it will be the food industry that will make or break it. It will only take one or two of the large Retailers to shout and I'm sure we'll all jump. Nobody will do ISO 22000 just for the fun of it.

Regards,
Simon

[masculinie]

If I recall it rightly.... ISO 15161 does disqualify itself as an audit standard for certification purpose.... - a standard that is counting on the conscience of the food-supplier in a commercial world.... will inevitably be extinct....

Large retailers and EN ISO 22000 shall both be contributory the the worldwide acceptance and growth of the ISO 22000....

As to the years to be taken.... I recall ISO 9000 was not gaining great popularity in the States and Japan until year 1992 - some 6 years down from the year it was born....

10 years for growing into ISO 22000 state of a mature market - is just a conservative guestimate.....

.... and being humble Sirs.....:)

Masculinie

[Charles Chew]

I do hope you will be right that ISO 22000 will get it rightful recognition sooner than expected. But base on the current average level of understanding on food safety in Asia where i come from, I am not too sure that such as a recognition will be forthwith within the next 6 years.

Maturity of comprehension on fundamentals of food safety issues are essential to capturing interests in ISO 22000 notwithstanding the fact that the requirements to comply are likely going to be country or trade specific rather than on a global requirement basis between govt. to govt.

Personally, I do feel that the commercial scenario on "standards" has become somewhat of a "paper chase". Is it worth the while to go for certifications that are probably already reflected in other current standards?

Charles Chew

[masculinie]

From the experience of the ISO 9001.... exporting countries will receive the impact a few years down - not very much to do with any current local or regional standards.... - it is the power of ISO Standard somehow....

From international buyers.... to eventually local buyers - the ISO 22000 shall grow over time....

If Asia is growing in food export.... or public puchasers are drawn into stipulating the requirements for huge puchases.... - to protect the consumer interests..... the Standard is destined to grow in demand....

If certification cannot live up to its reputation in the commercial world.... vendor audit will just take over - but the same Standard will still be adopted.... for its International sense....

Masculinie :D