Time to stop luxuriating Food Safety Management Systems?

By Guest Author on 18 October 2019

Dear food industry, can we stop luxuriating FSMS’?

I remember the first time I attended an FSMS implementation course, it was for GMPs/PRPs & HACCP implementation and fresh-faced me had never heard of HACCP or any kind of food safety management system before. I can still distinctly remember the prologue to our 3-day long training, after giving us a run-through of his colourful resume, our well experienced and obviously deserving trainer went on to say the words that unbeknownst to me would shape the next phase of my young career; " if FSMS's could be likened to cars then GMPs would be like a bicycle, HACCP would be a motorcycle, ISO22000 an SUV and FSSC22000 would be the Rolls Royce of FSMS!" I thought to myself wow, Rolls Royce! Who wouldn't want to have a Rolls Royce?! And, that my dear friends, is how I became brainwashed into chasing certification standards. Looking back at this statement I now realize how misleading such statements can be, or to be frank; how much this belief has messed up the food industry.

If we take a moment to look back at the history of HACCP, it was developed by the food scientists at Pillsbury (an American food manufacturer) in collaboration with NASA in the 1950s in response to concerns about the health and safety of astronauts who were being sent into space, NASA was concerned that if the astronauts got food-poisoning while out in space with no nearby medical practitioners, hospitals or specialist medication for galaxies, that this would jeopardize the entire manned space program and potentially destroy years of research and hard work, and so together they developed a system that would not only help to identify potential hazards but also mitigate, eliminate or control any significant hazards to ensure safe food for astronauts and ultimately the success of the manned space programme. Fast forward a few years later and Pillsbury started to see problems in their own products with one of their cereal products, Farina, having been found be contaminated with glass fragments- scary to think that this was actually an infant product (don't worry, the product was recalled). One of the microbiologists who worked on the NASA project proposed that the manufacturer adopts a GMP & HACCP system, and in 1971 after a panel discussion at the National Conference on Food Protection where GMPs & CCPs were the main discussion point HACCP was born- NB; this is a very rough overview on the history of HACCP there are many more details and stakeholders that were involved.

The point is that the forefathers of HACCP understood the importance of a simple and practical way to prevent foodborne illness, and for many, many years (about 34 to be exact) HACCP implementation was the talk of food safety town, then countries, industries and organizations started adding on and altering these standards to better market their products and increase consumer confidence which led to the birth of standards such as the BRC, Global GAP, PAS220 etc. this became such a trend that as of July 2019 the CAC had produced 223 food safety standards, 78 food safety guidelines and 53 food safety codes of practice since its inception in 1963, now considering that there are 195 countries in the world that would mean that if we were to equally divide the standards among each country, then there would be more than one standard for food safety per country . This makes me wonder are all these standards really necessary? What is the difference between this standard and the next? and, do all of these food safety standards, guidelines and codes of practice still capture the true & intended essence of food safety management systems or have we lost the fundamental reason that food safety management systems were created for in the first place?

From what I understand, the food safety compliance pyramid consists of 3 tiers, Regulation & legislation which are mandatory and have legal implications if not adhered to at the base of the pyramid- these are available free of charge on government sites examples include R146:2010 (the labelling regulation) or R638:2018 (regulations governing general hygiene requirements for food premises & transport). The second tier comprises of industry guidelines which set a precedent for specifications in their given industries - these are usually paid access material and examples would include SANS 885 (the processed meat standard) and SANS 1798 (the bottled tomato sauce standard) and they are the first level of "nice-to-haves". The top tier is made up of national or international standards which are also paid access materials, examples of these would be SANS 10049:2012 (The PRP standard), SANS 10330: 2006 (The HACCP standard) and SANS 22000: 2018 (The basis of ISO and FSSC standards).

With all these different standards relating to food safety obviously comes regulatory & certification bodies, which in turn come with consultants, training bodies and laboratories, each one with increasingly skyrocketing prices, each one helping to make the business of food safety a lucrative one. There are food safety service providers capitalizing on the competitiveness within the food industry to produce better, safer and higher quality products & services and these providers have convinced both the industry and the consumer that we need the Rolls Royce in order to be considered as compliant when the truth is that

(i)   ISO and FSSC 22000 were only established over 30 years after HACCP was introduced and

(ii) Both ISO & FSSC22000 are heavily based on HACCP principles

Now, I am all for competitiveness in the market, however, I’d much prefer it if the competition was necessary and of distinct and undeniable value it's consumer, traits which I do not really see in the current state of the food industry. Instead what I see is FSMS’ being marketed as a luxury mink coat that makes their wearer a premium member of the cool kids club. What I’ve seen in the industry is that having an FSMS has become a marketing tool that is often used to win new business, impress investors and lure the consumer into buying a premium brand all in the name of “oh darling, the manufacturer has the rolls Royce of FSMS in place”, and as a result what has become of the FSQA and QC teams working in this industry is astonishing.

FSQAand QC personnel now find themselves only being of value in the weeks leading up to an audit, we are suddenly plagued with questions on what we need in order to have a successful audit, where we need support and how management can be of assistance? Food safety team meeting outstanding actions are now the mantra of the day and non-conformances are suddenly getting the attention they deserve. The audit day comes we window dress our way to certification and once audit season is over, its back to being nothing but a liability.

How about we start placing value in food safety culture and not food safety certification! 
What if we could measure the success of an FSMS by how much
attention we pay it when no one is auditing or watching us?

I heard an interesting radio interview the other day where a young woman who owns a coffee business was seeking advice on how to enter the retail market, and she went on to lament about how the main retailers had such high barriers to entry which included preferences for certain FSMS certification over another or none at all, requirements that had led her to so much frustration that she was considering stopping the business. What got to me was that the panellists who tasted her product seemed to have really enjoyed it, with some placing orders on the spot meaning that she had a great product to offer, but what really drove the last nail in the coffin for me was when she received advice to “not even bother” with the retail market as she "stands no chance" and to rather market her products to the informal sector where she stood a better chance of success. Wow, so, does this mean that these up and coming organizations cannot win business because larger organizations that can afford to implement “better” Food safety management systems and meet all the requirements will always trump them?

To put it another way, does this mean that organizations that only pay attention to their luxury, chauffeur-driven and leased vehicle of an FSMS for audit & certificate purposes will always beat the little guy who has successfully managed to self-fund, build from the ground up and regularly service his motorcycle? And if the little guy somehow manages to get people to buy his products through the informal sector and he messes up and doesn't apply the principles of food safety as well as he could have which leads to the illnesses (or God forbid- deaths) of those who are poor enough to afford his products, then does that mean that there will be no direct consequence because after all, all he has is a bicycle.

The way I see it, food safety has become a luxury value-added service that the food industry offers to those who can afford to pay the price tag, and it is our duty as professionals in this field to bring it back to basics and provide food safety for all- not just those who can pay for it.

About the Author
Lydia Shoniwa-Sagonda is a cum laude BSc degree holder, food safety specialist, speaker, SAATCA registered auditor for FSMS, consultant and the founder of @thefoodtech_sa - a bottom-up approach that educates, challenges, empowers and ultimately influences consumers and small food businesses towards a food safety culture at home and in their business. Lydia loves anything food from preparing to testing it (yes, as in labs and test tubes and all that geeky stuff) and she has worked for the food industry her entire career from sales, customer services, technical support right up to food safety management systems development, implementation, management and continual improvement. 

She believes that food safety should never be a luxury reserved only for those who can afford to walk into premium retail stores or restaurants, and her goal is simple - food safety for every African.