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Global Food SaFety InItIatIve ImproveS orGanIzatIonal Culture, eFFICIenCy In Food InduStry

rhonda WellIkCEO of CERT ID

Originally Published in Food Quality Magazine, April/May 2012

ComplImentary WhItepaper by

June 2012 | Whitepaper

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Global Food Safety Initiative: Rhonda Wellik | FSP-MJ-2012

exeCutIve WhItepaper SerIeS

Since its inception in 2000, the Global Food Safety Initiative has emerged as a high-impact presence in the food industry, touching multiple segments of the industry and creating a dynamic web of continuous improvement. Is GFSI creating a safer food supply from the perspective of quality assur-ance managers, certification bodies, auditors, and industry consultants? Does it reduce the number of audits a food manufacturer must undergo? How does a manufacturer pre-pare for an audit? Does certification to a GFSI-benchmarked standard create new marketing opportunities? Is the indus-try fully embracing GFSI? How is it evolving? These ques-tions are answered by those who interact daily with GFSI principles and practices.

The GFSI benchmarks existing food safety standards against guidelines established by retailers, food manufacturers, consumers, and food safety experts. Within GFSI, bench-marking is a “procedure by which a food safety-related scheme is compared to the GFSI Guidance Document.” Food manufacturers obtaining certification against any benchmarked standard, such as British Retail Consortium or Safe Quality Food, would be considered to have met GFSI requirements.

As a nexus of stakeholders, GFSI promotes continuous im-provement in the operations of groups involved in the food safety certification process—the primary producers and manufacturers, the standard owners, certification bodies, and audi-tors. Each has specific GFSI guidelines that govern operation and interaction with the others. These guidelines are regularly revised by GFSI to reflect improvements in best practices, upgrading and updating each participant’s operation.

How quickly is the industry embracing GFSI? Since Wal-Mart’s announcement in 2008 that it would require its brand label suppliers to become certified to a GFSI standard, progress has been significant. The British Retail Consortium, owner of the BRC Global Standard for Food Safety, reports that its number of certified sites is more than 15,000 globally.

BRC is only one of the GFSI-benchmarked standards.

“Wal-Mart’s backing was huge for GFSI,” recalled Monica J. Elchlepp, president of Capjem Consulting in Prairie Du Sac, Wis. In 2004, she added GFSI consulting to her company’s portfolio because the “overall concept was unique in the marketplace and fit in with our goals.” Since 2008, she has witnessed more retailers making the same demand of their sup-pliers as Wal-Mart.

“Food manufacturers are coming to us because their buyer is requiring them to meet this standard, and more times than not it’s a huge retailer they can’t afford to lose,” Elchlepp said. She also noted that while there is still resistance within companies that see “the initial financial and staffing requirements as a burden, the gain can be explosive. We have had clients drive their revenue beyond what they could imagine. Their GFSI certification opened doors and paid for itself several times over almost instantly.”

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Auditor Terry Martin of Process Management Consulting in Nashville, remembers 2008 as a time when some manufacturers “didn’t know which way to turn because their system had been operating for 10 years with little change and they had not kept pace. Suddenly they faced the real prospect of losing a lot of business. But by putting their resources into preparation for GFSI—taking one bite at a time and with added training and sometimes a pre-assessment audit—they were able to obtain certification.”

“Once Certified, Accepted Everywhere”

Meeting a GFSI-benchmarked standard requires commitment and investment from food manufacturers to embrace GFSI principles; however, obtaining and maintaining certifica-tion creates measureable, positive change. “I’m excited because GFSI food safety schemes provide for a much improved and closely monitored food supply, and this increased level of responsibility means a safer food supply for our country,” Elchlepp said.

Meanwhile, Robert W. Thrash, owner of Process Management Consulting, has noticed more sophisticated thinking about safety and quality. “I see a more ethical approach, and a genuine attempt to do the right thing,” he said. “Manufacturers want to implement improved systems rather than do damage control.”

Citing the reduction in audits that facilities face, Elchlepp emphasized, “The GFSI concept of ‘once certified, accepted everywhere’ has allowed clients to focus on one standard instead of a wide variety of inconsistent second-party audits. It’s all about utilizing best operating practices to achieve goals that increase quality and profitability.”

As Process Management Consulting’s vice president of audit operations, Maggie R. Smith noted that, “starting about three years ago, GFSI food safety audits have become the majority of audits that I perform.” She finds that the reduction in audits is a major benefit to clients achieving GFSI-benchmarked certification. “GFSI generally reduces the number of audits a facility has. I audited a client who was required to have 17 different audits a year. Now, with GFSI in place, they go through only two different types of audits per year.”

Another upside for the manufacturer is described by Martin: “There is real potential for reduction in customer complaints, reworks, and waste product,” he explained. “Once a facility is able to fine-tune their processes, there may be an opportunity to become more efficient. To make it all click at the outset requires genuine management commitment along with staff working together, but once defined and worked out, it’s a guided path that drives improvement and efficiency.”

Elchlepp noted that one of Capjem’s SQF clients increased operational efficiency by more than 90% as a result of the certification process. One large multinational manufacturer re-ported significant cost reductions to GFSI from the elimination of redundant audits. Another reported 90% fewer recalls.

Not Just Another Checklist Audit

Along with a growing enthusiasm for GFSI, each expert I polled openly shared some of the potential challenges for any food manufacturer wanting to achieve a GFSI certification. Martin cautioned that a facility cannot assume its GFSI audit is just another checklist audit. “They will quickly discover it’s not necessarily plug and play.” GFSI has created a new para-digm that transcends the pass/fail mentality of most supplier audits.

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Elchlepp advised that GFSI requires “a complete change of culture throughout the organiza-tion in order to really adapt to the standards and principles of GFSI. Implementation has to be from top management throughout the organization. Everyone needs to buy into the concept and live it day in and day out.” She described it as a “completely different mindset of rules, so it’s very important your facility goes into an audit prepared.”

# The audit expectation GAP and preassessment audits are based on the clause requirements in the standard. An auditor can do either. If a site elects to make sure they are as thoroughly prepared as they can be, hav-ing a consultant do a GAP first is the way to go.

Thrash added that he sees “a definite need for consulting during the process of preparing for a GFSI audit,” emphasizing that auditors played this role in the past. “Under GFSI, auditors are not allowed to provide consulting, so the process requires the involvement of consultants in this field.” Martin counseled that, while clauses of GFSI standards may seem similar to other food safety audits in the past, “from the GFSI standpoint, the auditor goes deeper in determining whether conformance to a food safety requirement has been achieved, asking the food manufacturer if there is documentation to support production GMPs. On top of that, non-conformances must be corrected and documented within specified timeframes. This is a strong incentive for the food manufacturer to be active and constantly improving. GFSI has teeth that other audits don’t. It’s a system that is improving food safety, with pre-ventive and corrective actions.” The requirement that non-conformances must be corrected and implemented before certification is a key difference between the supplier checklist audit and the GFSI audit.

Audit Preparation

Meeting the requirements of a GFSI audit can seem daunting at first. But by taking the “say what you do, do what you say, and prove it” approach, meeting the requirements of the food safety standard might be better understood:

� Say what you do: For each requirement in the standard, you need a written procedure or policy detailing how you address that specific requirement;

� Do what you say: Since you now have a written procedure, you need the tools to document it. These could be production forms, records, or logs; and

� Prove it: The auditor will want to see completed documents that demonstrate that you are operating your food safety system according to your written procedures. The GFSI standard demands a tight system and the involvement of the entire team. Along with the quality assurance manager, the plant manager, the vice president, and staff all the way down the line must be actively engaged to ensure that an audit is as successful as it can be.

Providing further tips on audit preparation, a quality assurance manager who successfully achieved SQF certification offered several pieces of advice:

“First, the QAM must take the necessary time to thoroughly understand every requirement in the standard and effectively apply the requirements to their unique operation. If you’re

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undergoing a first-time GFSI audit, don’t rush the implementation. Take the necessary time to get thoroughly prepared. You must understand the standard as a whole, and the clause by clause application to your operation.”

Second, understand that the audit expectation GAP and pre-assessment audits are based on the clause requirements in the standard. An auditor can do either. If a site elects to make sure that they are as thoroughly prepared as they can be, having a consultant do a GAP first is the way to go. A GAP audit is intended to uncover problem areas. If a consultant does the GAP, he or she can make recommendations on how to fix the problems. An auditor doing a pre-assessment can only report what is wrong, not make recommendations.

Third, if your facility is undergoing renewal, make sure that your documentation is accurate and up to date.”

Successful certification clients demonstrate the following:

� Senior management fully committed to implementing requirements of the standard;

� A well-documented food safety plan and HACCP;

� Well-documented sanitation and GMP procedures;

� An internal audit system that identifies non-conformances and provides corrective procedures and preventive action for resolution of non-conformances;

� Clear and well-documented procedures for monitoring the performance of suppliers;

� Traceability through documentation of every ingredient, final product, and service;

� Well-documented evidence of layout, process flow, and segregation;

� An incident management system;

� Well-documented handling requirements for specific materials, i.e., materials containing allergens and identity-preserved materials; and

� Well-documented training procedures, with records, for employees.

The BRC recently released a list of common non-conformances cited during U.S. audits: improper equipment maintenance; lack of a chemical control procedure for non-food chemi-cals; lack of sealed exterior doors to prevent pest ingress; lack of proper handling of glass and similar materials; ceilings and walls that do not meet requirements; correct version of controlled document that is not properly controlled; failure to control and manage potential risk from chemical, physical, or taint contamination; lack of a process flow diagram—Codex Alimentarius Step 4; lack of suitable and sufficient hand washing facilities.

Requirements, Accountability, and Reporting

A key feature of the GFSI approach is that an effective and comprehensive system of require-ments, accountability, and reporting has been implemented. All participants, including standard owners, certifying bodies, auditors, consultants, trainers, and accreditation bodies such as the American National Standards Institute, operate under GFSI guidelines. Not only must food manufacturers meet GFSI requirements, but the certification body (CB) must also meet guidelines set by GFSI.

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Recently added to GFSI benchmarking is the monitoring of the CB’s ability to operate ac-cording to GFSI requirements. The BRC evaluates all licensed CBs through key performance indicators. A star rating from one to five is granted according to overall performance in these five key areas:

� Compliance to protocols (how audits are undertaken and reported);

� Auditor registration and compliance relating to training, experience, and competence requirements;

� Quality of written audit reports based on a sample of audit reports;

� Speed of audit data upload to the BRC directory by the CBs; and

� CB communication with the BRC.

Companies entering the BRC certification process can find a complete directory of licensed certification bodies with their KPI rating noted on the BRC’s website, www.brcdirectory.com. The BRC promotes competency, professionalism, and consistency among its CBs with this rating scheme. The SQF Institute also provides a listing of licensed and accredited CBs on its website, www.sqfi.com. CBs listed here meet all SQF license requirements, including the re-quirement to employ SQF-registered auditors and/or contract auditors to conduct the audits.

Companies entering the BRC certification process can find a directory of licensed certifica-tion bodies with KPI ratings noted on the BRC’s website. The BRC promotes competency, professionalism, and consistency among its CBs with this rating scheme. The SQF Institute also provides a list of licensed and accredited CBs.

After a facility chooses a certification body, the CB begins the administrative and technical activities that result in the granting of a certificate. It’s important to note that while BRC and SQF food safety standards dominate the market in the U.S., other GFSI-benchmarked standards are also selected by food manufacturers, and each has its own history, features, and emphasis. Some retailers specify to their suppliers which certification to obtain. If there’s no specified choice, companies generally select the food safety standard that best fits with their position in the supply chain, their corporate culture, and their existing QA systems and staffing.

Once the food safety standard is determined, the CB assists the client in completing the application for certification. The completed application is used to determine the following:

� Products and processes (scope) of the certification;

� Appropriate food category as listed in the standard;

� Duration of the on-site audit;

� Audit date(s); and

� Appropriate registered auditor in your specified food category.

An essential component of the service provided to each client by its CB is the calculation of the amount of time an auditor spends onsite. For a client to receive the maximum ben-efit from the certification process, the duration of the audit must be optimized to fit each unique set of circumstances.

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Prior to January 2011, each CB performed the calculation based on its own internal set of guidelines. Recently, the BRC introduced a standardized methodology to ensure that each client has the auditor onsite for an appropriate amount of time.

Under the new BRC guidelines, the three basic indicators used to determine audit duration are the number of employees per main shift, the size of the facility, and the number of HACCP studies. In addition, there is a list of “correction factors” that can increase or decrease audit length. Some of these are the complexity of the manufacturing process, the labor-intensity of the manufacturing process, and the number of product lines.

When the application and audit process are finalized, the CB will require the client to com-plete a certification agreement. The agreement provides information detailing the certifica-tion process and all requirements for certification. The certification process is time sensitive, and its success depends partly on the food manufacturer, and partly upon the performance of the CB and the auditor. While no one can guarantee a painless process, working with a five star-rated certification body with proven expertise will create a smoother, more valuable experience for the facility.

The Future

How is GFSI evolving? The sixth edition of the GFSI Guidance Document (January 2011) offers a preview. This new edition provides for the “expansion of the document to cover primary production and processing in a more robust way, taking a scope specific approach to cover eventually all parts of the food supply chain. It has also been recognized that food safety requirements differ between the various parts of the food supply chain, and an exhaustive exercise was undertaken with sector-specific experts to define the food safety management system, Good Practice (GAP, GMP) and HACCP requirement in a number of industry scopes.”

GFSI plans to broaden its benchmarking to include all areas within the food chain. New guidance documents are in place for feed, packaging, and animal handling. More areas will follow: storage and distribution, equipment manufacturing, catering, retail, and brokers. As food manufacturers expand their certification beyond processing, greater confidence in the entire food chain is emerging.

What is the outcome when the food industry is invested in working together to meet the GFSI-benchmarked standards? I see the process as a living, breathing system of continu-ous improvement and constant positive change among all stakeholders. We are creating opportunities for building a network of cooperative stakeholder interaction.

We are inventing approaches and developing solutions that improve food safety and quality. Those food industry veterans who have embraced GFSI principles are seeing the benefits. Manufacturers are taking ownership of their food safety systems. It’s a relatively new con-cept, but its roots are growing larger and stronger, and it is moving the food industry toward providing safer food around the world.

Rhonda Wellik is CEO of CERT ID, an ANSI-accredited certification body. Contact her at [email protected].

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