[Global Supply] Importing Food Safety

As imports account for an ever-growing portion of America’s food, it becomes increasingly difficult to assure that the consumer is receiving safe food, and to assure the consumer that a food is safe. In this two-part article, we look at the supply chain from import through the plant to the distributor. In a Sept-Oct article, Importing Food Safety, From China to china, we discussed the need for collaboration throughout the chain, limitations of current regulatory traceback, and lack of global standardization, con-cluding that the industry has tended to self-police and the private sector often sets up its own systems and requirements.

Private Sector Standards. U.S. Foodservice is one example of a major distributor whose supplier requirements exceed regulatory standards. The company requires suppliers be certified GlobalGAP or Global Food Safety Initiative (GFSI), said Senior Vice President of Food Safety and Quality Assurance Jorge Hernandez, "So that we know the facilities are being evaluated by standards that are accurate, that are correct, and that are audited by knowledgeable people."

Such audits and tests are essential not only for proving that the food is safe, but to ensure quality and economic integrity of the products, he added. A supplier must meet all expectations prior to approval, then be monitored throughout the partnership to ensure the product is the same as that which was originally approved. Failure to meet the expectations will keep a supplier from being picked up for distribution and can remove it after a partnership has been established, he said.

One concern of the company is the lower cost of goods from suppliers or distributors with lower safety standards. "We have to compete against them in the market," he said, "and food safety has a price."

Because of that, Hernandez would like to see tighter federal regulations. "With a more level playing field in the marketplace, the winner is the consumer," he said.

One of the difficulties with regulation is that food safety is more complex today. Past regulation set standard parameters for application across the industry, rarely taking into consideration the uniqueness of a facility, its processes or product.

"Now the thinking is more complex," with an understanding that the unique aspects of each facility may require different standards for safety, Hernandez explained. This makes it more complex for those setting the standards and those inspecting for compliance. "As an inspector, you have to be able to calibrate the differ-ences and why something is safe or not."

Internal Inspections. The complexity is not only applicable to regulatory or third-party inspectors, but to a plant’s internal inspections and audits and those it requires of its own suppliers. It is critical to have a good internal inspection system to ensure both your plant and your incom-ing supplies are meeting your own and your customers’ specifications, said IQS Senior Consultant Laura Weisensell.

Thus, she said, a question that should be asked during every incoming goods and in-process inspection is, "Have we done everything we can at the plant to protect the ingredient before it goes into a product?

"A good quality system is one that everyone has bought into, everyone is willing to work with," Weisensell said. "It is one that is documented and trained to and understood."

It should also be comprehensive across the entire chain and track as much detail per ingredient as possible. Too often, she said, plants operate on "tribal knowledge"; basing processes on the knowledge and experience of long-term employees, with-out putting it into writing and without considering ‘What happens if …’

The Cost of Non-conformance. While the economy continues to limit resources for many businesses, the implementation of a good quality system can save a plant money by detecting and reducing non-conformance. "Non-conformance, corrective action and cus-tomer complaints take up a lot of time," Weisensell said. You want to have a good quality system in place so you don’t have non-conformance, and corrective action in place to keep problems from reoccurring, both within the plant and through suppliers—domestic or global.

"I know it is very expensive to audit our global suppliers, but you do need to make sure they have a quality system that meets your demands," Weisensell said. "I’ve seen it before where you’re getting goods in and no one realizes that [the suppliers] are working out of the back of a garage with no environmental controls."

There will be cases where supply is so limited that you have little option for an ingredient, Weisensell affirmed. In that case, you can still work with the supplier, but you need to partner to put a viable system in place. "If they didn’t have a quality sys-tem, I wouldn’t be buying from them, or I would work with them to get one," she said. "Live at their plant to ensure processes are being followed, or provide recourse to help build their quality system."

It costs money to implement systems, but the results are less expensive than the alternatives. "It’s all about utilizing tools such as Six Sigma, FMEA, Control Plans, Inspection Plans and Advanced Planning that will make your plant productive, and ensure that the end product meets food safety standards." Weisensell said.

The Cost of Safety. The challenge for the industry is that all of this costs money, said David Acheson, Managing Director, Food and Import Safety at Leavitt Partners and former FDA Associate Commissioner for Foods. It is money which will ultimately be passed on to the consumer, and money which may be hard to come by for the small farmer or processor. It is a very important thing that FDA must address, Acheson said, but added, "It’s a hard fact that no one should be able to say, ‘I’m too small to worry about food safety.’"

The Mexican jalapeno farm which caused the salsa contamination—and wreaked havoc on the tomato industry was small; peanut-producer PCA was small. "If a firm can’t afford to do adequate food safety, they shouldn’t be in business," he said. "It doesn’t have to be super expensive; it has to be thorough."

"How much does one pay for food safety?" Acheson asked. "How close to the wind can one sail in the hopes that you don’t have a problem?"

The author is Managing Editor of QA magazine. She can be reached at llupo@giemedia.com.