A couple of years ago, you may have drawn a blank when one of your customers demanded GFSI (Global Food Safety Initiative) certification if you wanted to continue as a supplier. Now, there’s a good chance you not only know what GFSI is, you may already have a GFSI certification or are earnestly pursuing it—because it’s no longer just Walmart that demands the certification. Now, retailers like Costco, A&P, Carrefour Group, Harris-Teeter, Jack in the Box, McDonald’s, Pathmark Stores, Publix Super Markets, Safeway, Subway, Stop & Shop Supermarkets, Wawa, Wegmans and Wendy’s represent a small number of the chains that ask for GFSI certification.

While Walmart was instrumental in kicking off GFSI, support for the initiative and its schema (standards held by maintaining organizations or owners, such as the Safe Quality Food Institute [SQFI], British Retail Consortium [BRC], Food Safety System Certification 22000 [FSSC 22000] and others), has taken off. (For more details on the way GFSI works, see “GFSI Update: Creating a Safe and Effective Worldwide Food System,” FE, March 2012.)

Practically speaking, GFSI removes from retailers the burden of auditing every supplier but, at the same time, offers some real pluses to processors. Katie Moore, previously a plant manager within the food and beverage industry and now global industry manager, food and beverage for GE Intelligent Platforms, implemented a GFSI scheme in multiple plants. “In many cases, big-box stores, like Walmart, Costco and Kroger, are driving the [GFSI] requirement, especially for their private label co-manufacturers, with one benefit being the ability to pass the auditing management to third-party auditors in addition to having a standardized platform by which to [evaluate a supplier’s conformance to food safety practices].” As a side benefit, food manufacturers are able to consolidate a number of internal and external audits and food safety and quality programs, she adds. “The ultimate benefit for all parties involved is to better understand and secure what’s happening in the food supply chain and [determining] how to ensure food safety in the manufacturing process.”

GFSI and FSMA: What relationship?

FE’s March 2012 article pointed out FDA isn’t necessarily adopting GFSI as its platform nor is it giving GFSI auditors the power FSMA holds. However, FDA recognizes the value of GFSI as a tool to be used in conjunction with satisfying FSMA requirements. The law firm Hogan/Lovells published a memorandum on January 9, 2013, in which its four authors state:

“Testing and Supplier Verification: Surprisingly, FDA does not propose specific requirements for either environmental/product testing or supplier verification, even though both are clearly referenced in FSMA. Citing the high costs associated with these activities, FDA instead solicits public comment on whether these requirements should nevertheless be included in a final rule. FDA includes in a detailed Appendix describing the agency’s views of how it would expect testing and supplier verification activities to be conducted—a ‘must-read’ for all food quality directors. Notably, FDA cites the GFSI framework, and GFSI-recognized certification schemes such as Safe Quality Food (SQF) 2000, as a valuable tool for supplier verification.”¹

The memorandum later explains that FDA acknowledges supplier approval and verification programs (e.g., GFSI-recognized schemes such as SQF 2000) are widely accepted in the domestic and international food safety community, thereby signaling FDA believes the GFSI framework provides a valid form of supplier verification even though these programs aren’t formally recognized by FSMA.

“SQF has worked with Dr. David Acheson at Leavitt Partners to conduct a gap analysis against the SQF code and the proposed preventative controls and cGMPs,” says LeAnn Chuboff, SQFI senior technical director. “The results identified a strong similarity between the two documents, and while there are some differences, a SQF facility is right on track with meeting the requirements of the proposed rule.” In Acheson’s words, “SQF is a great start to meeting the new FSMA requirements.

“Our analysis showed that generally the SQF Code aligned well to the proposed [FDA] Preventive Controls Rules requirements,” says Acheson. Several areas addressed by SQF have not been addressed in the proposed rule or have been addressed to a lesser extent. In these areas, SQF specific requirements exceed that of the proposed rule (recognizing some items may be covered by existing regulations or are covered by other areas of FSMA and will be addressed in forthcoming rules/regulations), according to Acheson. There are a few areas where SQF elements are less prescriptive than those found in FDA’s proposed Preventive Controls Rule. “This is not unexpected since SQF is a global program that is not intended to be US- or FDA-centric,” adds Acheson.

“FSMA, as well as other national food safety programs, require verification of the controls involved in ensuring safe food production,” says John Kukoly, BRC Americas director. “Third-party accredited food safety certification is recognized as a tool that can help ensure a manufacturer is compliant with the expectations of both customers and regulatory agencies.”

Although initially, processors may have pursued certification to satisfy a customer mandate, the benefits of building and maintaining programs that are required to satisfy the schemes are showing significant benefits to product safety, adds Kukoly. This is illustrated in several studies showing a significant decline in recalls and food safety issues post certification as well as quality in schemes that have quality and customer satisfaction components built into the requirements for certification.

Once a processor has obtained a GFSI certification, the work doesn’t stop there, says Skip Greenaway, Eagle Registrations CEO. Processors must realize that to derive the benefits of a certification (understanding a process and promoting food safety), they must be committed to continuous improvement. Unlike a simple audit or inspection, a GFSI certification is an ongoing process, and processors that fail to understand this concept can later find themselves in trouble down the road. “The key difference between an inspection and a third-party GFSI audit is with continued oversight. That’s where GFSI offers more than just benchmarking.”

What can the GFSI certification process do for a processor? Chuboff asked SQF stakeholders to provide some feedback on their experiences. Here is a partial list, indicating SQF implementation leads to:

• More robust and detailed facility programs

• Processes in place to monitor product checks during production 

• Higher level of compliance to programs like GAP (generally accepted practices), GMPs and SOPs 

• More detailed quality checks

• Clearly defined product specifications

• Increased plant and manufacturing division profits

• Reduction in customer complaints

• Improved traceability

• Reduced recalls and withdrawals.

What’s new with GFSI and scheme owners?

Auditor competence and consistency continues to be a hot topic and an area of focus for both GFSI and individual standard owners, says Kukoly. While the GFSI sets the framework for this, some standard owners such as BRC have set additional requirements for monitoring and managing auditor consistency and registration of auditors per product category. The introduction of BRC issue 6 introduced best practice requirements for auditing against the standard and expectations which have been reinforced through exams, witnessed audits and calibration webinars.

GFSI has seen fit to improve its auditor competencies, according to Greenaway. The GFSI Auditor Competence Working Group met for the first time in September 2010 to determine the role, tasks and expectations of auditors; define competencies (skills, knowledge and attributes) for each task; and recommend options by which these competencies can be assessed and verified. With more work to do, GFSI recently reopened the group (phase 2), which will involve:

• Complete mapping of competencies against the key elements in GFSI Guidance Document Sixth Edition

• Reviewing generic auditing competencies

• Integrating competencies with task analysis

• Developing methods for acquisition and assessment of competencies

• Reviewing options for publication and management of competencies.

In August 2013, the GFSI board of directors announced the formation of its newest working group. The GFSI Retail/Wholesale Technical Working Group will review the roles of retailers and wholesalers in the food supply chain, according to Jessica Wigram, GFSI senior manager. The group will draft key requirements for inclusion in the GFSI Guidance Document, so existing food safety management schemes that cover this scope can be benchmarked against them. The ultimate objective is to ensure confidence in product sourcing and the systems that are put in place to supply safe food to consumers. The group held its first meeting in July and will report on its progress to the GFSI board. A global stakeholder consultation on the benchmarking criteria developed by the working group is planned for the end of this year.

In 2012, GFSI reissued its Guidance Document Sixth Edition under version 6.2 to include key elements related to the production of animal feed. As a result, the holders of existing feed safety management schemes can come to GFSI for recognition through its benchmarking process. If the scheme’s requirements are considered to be equivalent to those specified within the GFSI Guidance Document Sixth Edition version 6.2, the scheme will achieve formal recognition by GFSI.

Besides animal feed, packaging is another GFSI area where scheme owners are busy at work, says Cornelie Glerum, FSSC 22000 general secretary. The Foundation for Food Safety Certification has extended the certification scope of FSSC 22000 with its Packaging Material Manufacturing document, according to the recent publication of the PAS 223—Prerequisite programs and design requirements for food safety in the manufacture and provision of food packaging. The PAS 223 was developed by a steering group consisting of leading global packaging and food manufacturing companies.

SQF published edition 7 of the SQF code on July 1, 2012. Designed to be a modular code, Edition 7 replaced SQF 1000 and SQF 2000 codes. Its goal is to provide a certificate solution for all the industry scopes including all pre-farm gate and post-farm gate operations, according to Chuboff. Edition 7.1, released in July 2013, expanded the scope to include codes for both the feed and pet food industries. Feed and pet food documents have been submitted to GFSI for benchmarking.

The GFSI board is composed of companies from all over the world; it includes representatives of two Chinese companies: China Resources Vanguard and COFCO. These businesses, as well as numerous other Chinese companies and organizations, are also represented on the GFSI Technical Working Groups. The Certification and Accreditation Administration of the People’s Republic of China (CNCA) is a member of the GFSI Advisory Council, a body of experts providing perspectives on the implementation of GFSI’s strategic objectives. GFSI collaborates with China on its benchmarking process and signed a Memorandum of Understanding (MoU) with CNCA on collaboration on food safety, and signed a second MoU with the China Certification & Accreditation Institute (CCAI) so GFSI can proceed with the benchmarking of the Chinese Food Safety HACCP scheme.

Reference:

¹ “FDA Proposes Extensive New Food Safety Regulations Under FSMA,” Hogan/Lovells (Kushner, Levitt, Fawell, Hermida); January 9, 2013.

For more information:

Skip Greenaway, Eagle Registrations, 800-795-3641, skip.greenaway@eagleregistrations.com

Cornelie Gerum, FSSC 22000, 31 183-64 50 28, info@fssc22000.com

John Kukoly, BRC Americas, 905-892-9469,
john.kukoly@brcglobalstnadards.com

LeAnn Chuboff, SQFI, 202-262-6697, lchuboff@sqfi.com

Katie Moore, GE Intelligent Platforms, 800-433-2682, katie.moore@ge.com

Jessica Wigram, GFSI,

 j.wigram@theconsumergoodsforum.com