Controlling food safety by quality management system/standard

4.2.1 Contents of a standard

In this section the contents of a food safety standard is discussed in more detail. The British Retail Consortium (BRC) standard, developed by the big British supermarket chains and used by many thousands of food businesses will be used as a reference.

The BRC global standards for Food Safety contain several different chapters and sections. Some of those are seen as fundamental in the preparation of safe food, while others are given less importance. The following ten requirements are indicated as being fundamental:

1. Management commitment and continuous improvement clause 2. Food safety plan – hazard analysis and critical control points 3.5. Internal audits

3.8. Corrective action and preventative action 3.9. Traceability

4.3.1. Layout, product flow and segregation 4.9. Housekeeping and hygiene clause

5.2. Handling requirements for specific materials – materials containing allergens and identity preserved materials

6.1. Control of operations 7.1. Training

149 EU, 2010. Commission communication – EU best practice guidelines for voluntary certification schemes for agricultural products and foodstuffs. Official Journal of the European Union C 341, 16/12/2010: 5-11. See Appendix 1.

Other standards are structured differently but have similar or the same primary fundamental requirements. A good example is the International Featured Standard (IFS) for food developed by the German and French retailers. Both systems have been developed with the objective to be able to guarantee uniform and safe food products. BRC and IFS can be applied to different steps in the food production chain. Manufacturers, packaging or other types of businesses handling food can make use of these standards. In practice many companies will be certified against both standards to prevent trade restrictions. In both standards requirements are laid down in accordance to the European rules on production and packaging of foodstuffs. Securing food safety by implementation of HACCP ensures compliance with the requirements of the General Food Law. Furthermore the standards include rules that provide the specific requirements of the users on safety, quality and continuity.

4.2.2 Supervision

As mentioned before the practice of certification against good standards can be very interesting for national authorities. When good quality management systems have been implemented, authorities can reduce their supervision activities significantly.

The condition for any reduction of supervision would be that authorities can trust the system to function in practice as is laid down in the standards. All organisations developing standards, apply a system of independent inspections (audits) to ensure the correct implementation of the standard by the food business operator. The audits are executed by certification bodies (Figure 4.3).

Certification bodies (CBs) receive their accreditation from Accreditation Bodies (ABs) when compliant with their requirements. Certification bodies exchange their experiences on the certification scheme with, for example, a Technical Committee or Board of Experts and the executive board of the standard.

The operational procedures of accreditation bodies in the EU are supervised by international Accreditation Bodies through peer assessment. ABs are accepted into Multilateral Agreements in Europe (EA-MLA) and outside of Europe (IAF-MLA and ILAC-MRA).¹⁵⁰ Regulation 765/2008 lays down the requirements on accreditation and market surveillance relating to the marketing of products¹⁵¹. In Article 4 of this Regulation the general principles for accreditation are laid down. Some examples are:

150 http://www.european-accreditation.org/content/mla/what.htm.

151 EU, 2008. Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008 setting out the requirements for accreditation and market surveillance relating to the marketing of products and repealing Regulation (EEC) No 339/93. Official Journal of the European Union L 218, 13/8/2008: 30-47.

Inventory of private food law

1. Each Member State shall appoint a single national accreditation body.

2. Where a Member State considers that it is not economically meaningful or sustainable to have a national accreditation body or to provide certain accreditation services, it shall, as far as possible, have recourse to the national accreditation body of another Member State.

3. A Member State shall inform the Commission and the other Member States where, in accordance with paragraph 2, recourse is given to the national accreditation body of another Member State.

6. The responsibilities and tasks of the national accreditation body shall be clearly distinguished from those of other national authorities.

7. The national accreditation body shall operate on a not-for profit basis.

8. The national accreditation body shall not offer or provide any activities or services that conformity assessment bodies provide, nor shall it provide consultancy services, own shares in or otherwise have a financial or managerial interest in a conformity assessment body.

Certification system’s administrator/owner

Certification scheme

Certification bodies Board of experts

Auditor 2

Auditor 1 Auditor 3

Producer/importer wholesaler’s

Primary producer Retailer

Flow of products Transport

and storage Transport

and storage

Figure 4.3. A schematic overview of the certification process.

An accreditation body shall act as an independent organisation. In deploying an auditing team it gives much attention to the independence of the auditors.

Certification bodies that carry out audits and issue process/product certificates, are accredited against the standard ISO/IEC Guide 65 (1996) or ISO/IEC 17021.

Certification bodies which carry out audits to certify food management systems are accredited against ISO/IEC 17021. Certification bodies, that inspect companies on e.g. hygiene guides, are accredited against ISO/IEC 17020. The scope of inspections is more limited compared to audits. During inspections, the emphasis lays more on meeting fixed requirements, while in an audit more attention is paid to how risks are identified and managed. The laboratories, which analyse food and raw materials, are accredited by the AB against ISO/IEC 17025.

With regard to the auditors, with the authority to perform work for a certification body, strict requirements are laid down in the norms mentioned above:

• General: auditors shall have competence in performing technical reviews and have clearly defined instructions, in which tasks and responsibilities are laid down.

• Certification bodies should establish minimum criteria for the qualification of the Auditors.

• Auditors must be contractually obliged to follow established rules and report any kind of previous or on-going cooperation with an auditee.

• Certification bodies must keep track of information on the right qualifications, training and experience of auditors on the different specialisms that are applicable. This information should also indicate the date from which this information is valid.

• Auditors shall not perform other audits than the audits for which they, on the basis of their training and experience, have authority.

The certification protocol ISO/TS 22003, laying down requirements on among others the auditor and duration of the audit, is available since February 2007.

4.2.3 Audit frequency

The major international systems have set different rules regarding auditing frequencies. BRC and IFS know an annual frequency while Dutch HACCP almost always keeps a bi-annual audit frequency. In other systems an audit is performed two or three times per year at the start. If a company has correctly implemented and controlled the system, the frequency may drop to a single audit per year.

When non-conformities are found, additional audits are performed.

The results of an audit are reviewed by an expert panel at the certification body, before the certificate is issued. The auditor, on performing the audit, does therefore not determine the end result.

Inventory of private food law

4.2.4 The scope of a certificate

The scope (the scale of the activities concerning the control of food safety in the company that is being certified) can generally be divided into 3 parts:

• Pre-requisite programmes of Good Manufacturing Practices (GMP). These programs describe basic requirements for hygiene, establishment and such.

It may also include requirements that are specific to the organisation that developed the standard.

• HACCP, in which the requirements are set for the risk analysis, as required by the General Food Law. Usually the model published by the Codex Alimentarius is applied.

• System management, where the requirements are laid down on a coherent quality system of the entire organisation, allowing better management of operational processes.

The standards that are used globally, benchmarked by the Global Food Safety Initiative, are based on these 3 elements. Less extensive systems mainly use the pre-requisite programmes combined with a risk analysis performed for the sector which is based on HACCP.

4.2.5 Sanctions policy of certification bodies

For certification systems that do not meet the requirements generally the following measures apply:

• Non-conformities are discussed with the auditee.

• A date is agreed upon which corrective measures shall have been introduced.

• Possibly a re-audit needs to be performed to establish the effectiveness of taken measures.

• If this proves to be insufficient, the causes will be discussed again.

• Disciplinary measures may be applied.

If non-conformity is not resolved within the agreed upon period, suspension of a certificate is usually the first disciplinarian measure, which is followed by revocation of the certificate. Depending on the severity of the non-conformity CBs may also decide on immediate revocation of the certificate.

Where non-conformity in the management system is related to only a specific part of the organisation, CBs can also consider a limitation of the scope of certification as an alternative to suspension. For example, an auditee may no longer be allowed to produce, but is allowed to sell. CBs can also choose to only give a warning to the food business operator before suspension is considered.