Food Safety Magazine - June/July 2013

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PRODUCE Figure 2: Auditing organizations: These audit organizations, and others, are using or plan to use the Harmonized Standards for GAPs audits. Audit organizations listed are for identification purposes only. The United Fresh Produce Association and the Produce GAPs Harmonization Initiative do not endorse or warrant the services of any particular entity. Who Is Auditing? All major audit organizations identified by the TWG as performing GAPs audits in the U.S. were approached early in the harmonization initiative to become involved and provide their audit checklists. Almost all agreed and have been strong supporters of the Harmonized Standards. According to Ken Petersen, head of U.S. Department of Agriculture (USDA)’s Agricultural Marketing Service, Fruit and Vegetable Program audit section, “USDA played an active role in helping the industry develop sound harmonized GAPs and GHPs [Good Hygiene Practices] produce standards. We were also among the first to perform audits using the Harmonized Standards, which helps ensure that American produce food safety criteria are met. Many retailers specifically request harmonized GAPs audits, so we work with fruit, vegetable and specialty crop suppliers of all sizes to verify their on-farm practices meet or exceed the standards, and we’ve seen many growers successfully migrate to the harmonized audit.” A more targeted audit organization is Equicert, which primarily serves small “horsepowered” farms. “After 2 years’ experience, I’m still amazed by the strength and flexibility of the Harmonized Standards,” said Michael Hari, president of Equicert. “Where other standards may be a poor fit for a certain size farm or a certain geographic area of the country, we are continuing to find the Harmonized Standards flexible enough for a wide range of applications and strong enough to address the avoidable risks that all produce farming has in common. Equicert’s experience with the Harmonized Standards has included broad buyer acceptance. We recommend buyers and growers upgrade to the Harmonized Standards in preference to the old standards.” (Figure 2). GFSI and the Harmonized Standards. GFSI was created in 2000 as a harmonization initiative. Like the produce industry in the U.S., European retailers were being criticized by their processed food suppliers for creating an audit burden: multiple, redundant and often conflicting audit requirements. In order to accept audits from organizations they didn’t know, the retailers created GFSI to establish a set of guidelines for audits and audit organizations, and to serve as an independent “benchmarking” authority. The retailers’ view: If an audit organization is managed to these guidelines, we can accept their food safety certifications with confidence. The strength of GFSI is its guidelines for how audit organizations manage their audit process, particularly in how auditors (“certification bodies”) are overseen. GFSI also established guidelines for food safety standards for processed foods, developed by several multinational processed food companies using generally the same approach as used to develop the Harmonized Standards. GFSI, and participating audit organizations, continued to grow over the next decade and eventually took hold in the U.S. About the same time, GFSI decided to establish guidelines for food safety standards for “Farming of Plants.” Aware of this, the TWG evaluated the Harmonized Standards against the GFSI guidelines and concluded that, although the words were different, the two were consistent in their expectations, perhaps requiring a few “GFSI riders” to the Harmonized Standards. Ironically, this is where the two harmonization initiatives came into conflict. U.S. retailers, trying to reduce the audit burden on their suppliers, endorsed GFSI, some requiring all of their suppliers to become certified to a GFSI-benchmarked standard. This created a dilemma for a number of produce companies that had already been audited to the Harmonized Standards, only to be told those standards weren’t going to be accepted because they had not been certified by a GFSIbenchmarked organization to a GFSI-benchmarked standard. Meanwhile, GFSI benchmarking evaluates both the audit standard and the audit process, so the Harmonized Standards, being just an audit standard, cannot be benchmarked without an associated audit process. The solution was to pair the Harmonized Standards with an already-benchmarked audit process. Three of the audit organizations that had been benchmarked to the GFSI Guidance Document 5 were asked about adopting the Harmonized Standards, and two responded. GlobalG.A.P. already had a process in place that seemed to align with the GFSI guidelines: Recognizing regional and language differences around the world, the GlobalG.A.P. process allows for National Interpretation Guidelines (NIGs) to translate their established standards into the language and special conditions of the country. A GlobalG.A.P. U.S. National TWG was formed, also coordinated by United Fresh, to develop the U.S. Fruit and Vegetable NIG. It didn’t take long to see that the GlobalG.A.P. Integrated Farm Assurance standards, which cover much more than food safety, far exceeded the scope of the Harmonized Standards. However, recognizing that the U.S. produce-buying market is more focused on food safety and less on standards for worker welfare and environmental stewardship than elsewhere in the world, GlobalG.A.P. created a shorter “Produce Safety Standard,” including all, but only, the GlobalG.A.P. food safety requirements. The GlobalG.A.P. U.S. National TWG compared the Harmonized Standards against this standard and demonstrated they are very close in their requirements, requiring only a few “GlobalG.A.P. riders” to be equivalent and consistent with the GFSI guidance. In early 2012, GlobalG.A.P. accepted the U.S. 62 F o o d S a f e t y M a g a z i n e
PRODUCE Fruit and Vegetable NIG as official, allowing U.S. produce operations to be certified to the Produce Safety Standards using the verbatim Harmonized Standards plus the GlobalG.A.P. riders. As of this writing, the GlobalG.A.P. Produce Safety Standards are being re-benchmarked to the new GFSI Guidance Document 6, but retailers requiring certification to a GFSI-benchmarked standard are accepting the GlobalG.A.P. Produce Safety Standards certificates. The Safe Quality Food (SQF) Institute took a different approach to adopting the Harmonized Standards. In 2012, SQF reorganized its food safety standards, combining its SQF 2000 standards for processed foods and its SQF 1000 standards for produce growing and handling into a new set of standards aligned with the new GFSI Guidance Document 6. SQF implemented a “Module 2,” covering an operation’s food safety management system and required for all operations undergoing SQF certification. The institute also modified its SQF 1000 requirements into a “Module 7,” covering fresh produce growing and harvesting. SQF submitted these and other modules to GFSI and completed re-benchmarking in late 2012. At this writing, with the bulk of the re-benchmarking process complete, SQF plans to submit the Harmonized Standards, verbatim except for the portions already covered in its mandatory Module 2, to GFSI for benchmarking as an alternative “Module 7H.” Thus, for operations whose buyers require them to be certified to a GFSI-benchmarked standard, they have two options with the Harmonized Standards, and operations can choose whichever best fits their culture. The fly in this ointment, however, is that the GFSI guidelines don’t appear to allow for government auditors to be certification bodies, as the GFSI guidelines require private sector oversight by an accreditation body like ANSI. At this writing, USDA and several state departments of agriculture are exploring ways around this obstacle. If successful, then operations torn between buyers requiring GFSI and governmentperformed audits can do both with one audit using the Harmonized Standards. Calibration Committee and Standards Interpretation. A key aspect of the harmonization process was to use the words from established food safety standards to write the Requirements and Procedures of the Harmonized Standards without change. While some editing was done to remove redundancies, the TWG was largely successful in keeping to this process. Additional words and columns (i.e., Verification and Corrective Actions) were included to clarify what was being required and minimize opportunities for “audit creep.” For example, the TWG carefully stated when policies, procedures and records were required to be written, allowing for verbal policies and procedures to suffice when not critical for safe practices, par- Find it before someone else does. Accurate lab results are the most important item on the menu. That’s why API, a leader in proficiency testing for labs, has developed a proficiency testing program that meets the unique needs of the food industry. Developed with food industry leaders, our A2LA-accredited proficiency testing program was developed to meet the needs of laboratories seeking to achieve or maintain ISO/IEC 17025 accreditation. Don’t wait for today’s special to be tomorrow’s news. foodpt.com • foodtest@api-pt.com U.S. & Canada 800.333.0958 International 1.231.941.5887 NOW A2LA ACCREDITED TO ISO/IEC 17043 J u n e • J u l y 2 0 1 3 63
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June/July 2013 Vol. 19, No. 3 FEATU
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Editor’s Letter Taking Care of Yo
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News Bites FSIS Updates Directive o
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Steve Taylor, Ph.D., Receives Food
Page 12 and 13: MICROBIAL TESTING By Tom Weschler C
Page 14 and 15: MICROBIAL TESTING 200 0 418.2 461.6
Page 16 and 17: Process control By Richard F. Stier
Page 18 and 19: Process control MANAGEMENT COMMITME
Page 20 and 21: Process control list. This allows t
Page 22 and 23: Testing By Joseph L. Baumert, Ph.D.
Page 24 and 25: Testing are not well suited to rout
Page 26 and 27: genetically modified foods By Mauri
Page 28 and 29: SANITATION By Ewen C. D. Todd, Ph.D
Page 30 and 31: SANITATION ceilings; the main reaso
Page 32 and 33: SANITATION floors and knife racks)
Page 34 and 35: SANITATION remained unchanged at 0.
Page 36 and 37: Creating a Culture By Geoff Schaadt
Page 38 and 39: The Atlas ® System. Fully automate
Page 40: Changing Culture Anyone who gives c
Page 44 and 45: ally kill a change effort even if i
Page 46 and 47: MEAT By Emily Meredith and Christop
Page 48 and 49: MeAT Safety.” Although the articl
Page 50: MEAT for food. The legislation, ent
Page 53 and 54: as little as 22 hrs.
Page 55 and 56: REGULATIONS FSMA gives FDA broad ne
Page 57 and 58: REGULATIONS uled and held a series
Page 59 and 60: HACCP Management. Redefined. The ne
Page 61: PRODUCE the Harmonized Standards fi
Page 65 and 66: Get concentrated processing informa
Page 67 and 68: JOIN US! 127th AOAC Annual Meeting
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Page 71 and 72: Choose Confidence Choose Confidence
Page 73 and 74: One Destination. Global Connections
Page 75 and 76: Advertisers Index Advanced Instrume
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