How Do You Keep Up?

I’ve said many times that one of the reasons I like working in quality is that every day is different. But sometimes that daily difference can be just plain crazy. Regulations continually change; customers update their specifications; and third-party audit expectations are rarely the same from year to year. All these new and different things can put a crimp on our ability to manage the plant.

If it were only the food industry that continually changed and improved, it could be manageable; but it’s not, it’s the world. Back in the “good ol’ days,” individual supervisors were trained and given the skills to make decisions on the fly. Then came radios, and a supervisor could reach anyone in the plant to help with a decision. Now we have smart phones; supervisors can reach anyone at anytime—and can let others make decisions for them. Sometimes this leads to under-training, but sometimes it is good. By helping us dig up information and have the latest regulation at our fingertips, that smart phone can help us make better decisions.

But just how much do we have to research and keep up with, and what definition(s) should we follow for food safety—let alone food quality? Although delayed, FSMA is bringing new regulations and definitions. Customers are continually changing their repertoires—new products, new-and-improved products, new expectations. Many are requiring third-party audits and GFSI certifications. (And who had heard of GFSI seven years ago?) Then you have customers who want the product certified to kosher, Halal, organic, fair trade, gluten-free, allergen-free, social welfare, animal welfare, indigenous people benefit, recyclable, renewable, ethical, GMO tested, and/or HACCP … to name just a “few.”

With all these certificates available, many consumers no longer make their their own food safety decisions, but prefer to rely, instead, on certifications to ensure what they see as appropriate for themselves, their families, and the global community. For example, they look for free-trade certifications to ensure all employees in the supply chain are being properly treated and paid; recyclability and sustainability certifications for a focus on environmental issues; and allergen-free labeling which gained momentum with the advent of rapid and accurate allergen testing. There are groups offering certifications for a vast array of food quality and safety aspects of your products—and consumers are finding them to be valuable.

As a quality manager, however, I want first and foremost for the food to be safe. But even this has a variety of meanings and definitions. A basic definition is that it is free of foreign materials or pathogens, but to some consumers, it also means that the product has no GMOs. In California, where we continue to experiment in “government by initiative,” there is a ballot measure to have any food product that contains any GMO be labeled as such and to define “natural” for foods. If this measure passes, it is just one more requirement with which we’ll all have to deal. Another change that is expected soon is FDA’s update of the GMP regulation that started a number of years ago. When published, this too, will require review of and modifications to our in-plant programs.

To provide just one example of drilling down into the details of one of the many programs for which we, as quality managers, are responsible, let’s look at a plant’s Food Defense Program. Food defense was part of our jobs prior to 9/11, but now it has a name. It is now a separate program that must be incorporated and properly managed.

Both FDA and USDA have issued guidelines for food defense, detailing requirements for compliance and its inspection focus. In addition, FDA and USDA issued CARVER+Shock as a tool for plants to assess their vulnerability, and FDA has the FREE-B training programs. USDA has an inspectors’ assessment questionnaire with four questions, while the FDA plant self-assessment form has 20 sections—each of which has multiple questions. Both FDA and USDA offer training tools and the above-noted materials on their websites. And with each day that goes by, we hear of new elements that we should consider.

If we’re brave enough to watch the news, we hear of intentional “people-borne” tragedies, not just in other parts of the world, but right here at home. This certainly makes us—and our customers—think about food defense and facility security. Some customers have additional elements of food defense up to and including a certification of the supply chain in concert with U.S. Customs and Border Control called C-TPAT. This is just one (more) program we all need to maintain. So how do we know what we need to manage to? Common sense goes a long way, but we also need to know which expectation we are supposed to know and manage to—USDA, FDA, C-TPAT? It sure seems crazy with this being just one part of our jobs.

In addition to regulations and customer-driven certifications, there are also the third-party audit schemes. Many industry customers expect production facilities to be certified to a GFSI-benchmarked scheme. If you haven’t already done this, it will catch up with you. The expectations for each of these schemes are continually updated. SQF moved to version 7 this year after using version 6 for only a few years. Of course, these expectation need to be updated in response to changes made at GFSI. As a manufacturer, you need to know when there are changes and what they are, so that you can update your programs as well.

To add more grief to our work days, we have to manage our internal programs—developing new products, and updating and refining our internal specifications; getting new tests into our labs; and new labels have to be created, reviewed, and approved. With all this, every day is definitely different for a quality practitioner. So how do we keep up with all these changes and new expectations? … How do you do it?

We all do our best and drive hard for the finish line (success), but sometimes it’s hard to keep up. I’d like to hear from our readers: How do you keep up? Do you rely on trade magazines, webinars, trade shows, friends, consultants, others? There’s an old adage that says: “The system—you can try to fight it, change it, beat it, knuckle under to it, or improve it. But first you have to learn it.” How do you learn it—and keep up with it? Let me know at bferree@giemedia.com.