FSSC 22000/ISO 22000 allows for the use of external experts in the development, documentation, implementation and maintenance of your food safety management system. These standards do not define the role of the external expert, you have to do this yourself in a contract. But where should you use a consultant? Where can a consultant add value?
A good place to draw from would be the FMSA requirements where the preventive controls rules place great emphasis on the use of outside expertise. A quick look at the preventive controls qualified individual role shows that FDA wants you to get help in areas that may be beyond your scientific skill level, such as designing and performing validation studies, rather than attempt to do something that is not in your area of expertise. This is a good principle to follow in all food safety management systems.
According to Patricia Wester, while FDA does provide information on resources such as those available via universities, extension offices, and other major resources, a great many of you will end up in the private sector for help, which brings to light the challenges involved in selecting a competent consultant. Someone who knows everything there is to know in one sector may not know nearly enough to advise in another. Some, sadly, probably should not be advising anyone, but there is no grading system out there to help you choose between the good, the bad, and the ugly.
Finding an expert that knows everything about anything would be nearly impossible, so avoid anyone that claims to know it all. The first step is to identify experts in your arena, then you can begin the selection process from within that pool. Beyond the trade associations though, what else can be done to quantify experience in a given product mix?
This is an area where the auditing industry can be used as an example. There are several places in this sector where groups have attempted to create general product categories that might help distinguish experts in one area versus another, such as GFSI recognized schemes. However, even those illustrate the diversity of the food industry; some have as many as 30 product groups, others as few as 18—so perhaps this is not the most valuable help after all.
Wester gives us five basic rules to keep in mind when searching for a qualified food safety consultant
There are experts that have “been there, done that.” Use the expertise gained from the learning arc of the meat industry in critical areas, such as environmental monitoring.
Beyond technical skill, a good expert/consultant must have a solid grasp of the regulatory requirements necessary for compliance. As much as you strive to do all you can in the food safety arena, it starts with achieving the minimum legal requirements for compliance. For every manufacturer, meeting the compliance requirements is priority, only then can you look for ways to expand your food safety horizon.
Make sure you choose an expert that fully understands the entire scope of regulatory compliance requirements for your products and situations.
As the industry was adjusting to the globalization of the supply chain and the impact of imported foods, industry and regulatory thought leaders understood the need to move away from physical inspections and repetitive and simple audits, and into a system of risk ranking for inspected goods and standardized audits that verified the effectiveness of an overall food safety management system as a predictor of continuous food safety success. According to Wester this is another area where outside support is needed.
Don’t underestimate the full scope of compliance requirements, outside resources may be needed in areas not currently expected.
The food industry is a cost sensitive sector. Pennies matter, and QA/QC are still considered an overhead department with pressure to reduce costs whenever possible. While some of that culture is changing, the lowest possible price is still used as the primary selection criteria far too often.
The adage that says “Pick two out of the three: good, fast, and/or cheap; you can’t get all three,” applies in food safety. If it’s fast and cheap, it’s likely not very good. If it’s good and fast, it won’t be cheap. If it’s good and cheap, it probably will not be fast.
Plan ahead and discuss implementation costs early. Identify where outside support is needed and arrange it as early as possible in the process to prevent a last-minute crisis. Avoid using the lowest price as the final selection criteria for your outside expertise.
You get what you pay for.
One of the best things I learned is no one is an expert at everything, we all need to ask for help every now and then. Often, the difference between good consultants/experts and great consultants is how well they know their own limitations, and whether they consider it a strength or weakness to ask for help when necessary.
There are no hard and fast rules in food safety. Objectives can be achieved in a wide range of methods and there are usually a variety of approaches that can be used. But all come with hard choices that have to be made along the way, and trade-offs may be necessary.
If it was easy, anyone would do it. But no one knows it all.
About the Author
Wester is president of PA Wester Consulting and is the founder of the recently created Association of Food Safety Auditing Professionals.
The original article appeared in Food Qualityand Safety: