Re: Auditing Quality Systems

From: Remi Michalowski (remi.michalowski@cpp.co.id)
Date: Thu Aug 16 2007 - 01:31:08 PDT

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    Thks for the news. Glad to see it passed through the process. Even if the result is not so good for the ISO (but ISO could have "lobbied" more aggressively). Btw, with the info, we can appreciate the retailers' "Means"-focused expectations (another big debate for food safety experts - Means or Results, what is better?).

    True that BRC has incorporated the requirements on traceability and "sensitive material handling" but wasn't IFS the first to address these matters (version 4 BRC after Version 4 IFS)? Plus, if you look at the clauses and the Fundamentals Vs. KOs, they are more "heavy" (in terms of score) in the IFS. And it is not so easy to avoid getting a KO during a IFS audit.

    However, I need to insist that, on the business point of view, UK retailers (and even other retailers, I am thinking of Wal Mart and Carrefour) trend to develop their own technical standards (true, they integrate also requirements outside the food safety, but their expectations on food safety are more demanding e.g. more precise), and, yes, you are right, M&S has always been the "lone cowboy" on that matter.

    I was only stating that BRC is "nothing but" a "prerequisite" to access the UK market, not the ultimate key that will unlock the access to buyers. Do not get me wrong, I value the standards such as IFS and BRC, but ultimately, the retailers move to their own (Filiere Qualite Carrefour, which is also a quality label), it is simply a natural evolution process based on the consumers' expectations, but also to secure their own supply chain.

    Furthermore, there is still the issue for some CBs to be recognized (access to UKAS accreditation), many because they are not British while their professionalism is not even an issue !

    To come back to the ISO 22000 (yes, I am a true believer in its power!), please, Seafood list members, do not reject it because GFSI does not trust it.
    It is a very useful tool to manage the food safety and to address "real" risks identified in your process (a processor does not wish to invest in blue plasters metal detectable, fine, as long as there is no significant risk identified). EU legislation left a potential for ISO 22000 recognition as equivalent (regulation EC No 882/2004) to "delegate" the official inspections to third parties (even if the feasibility is questionable as discussed in a EC report). It could (and I insist on the "could", it is my own analysis) become mandatory to reduce inspection budgets, and, as Clare put in her mail, it is useful for countries with a limited legal framework and competent authorities.
    You do not wish to pay for a certification process (2 stages, and rather expensive), no pbl. At least, you can purchase the standard and use it.

    Anyway, John, I am very happy to discuss with you the big issue of the standards. Your input is highly valuable and I apologize for my "short comings" that could have lead to some misunderstandings.

    Hope we can keep in touch to share more views and opinions on that matter.

    I thank you again.

    Take care.

    Rgds,

    Dipl. Ing. Rémi Michalowski
    Senior Manager QA Food Processing
    PT. Centralpertiwi Bahari - Lampung, Indonesia
    HP + 62 815 4040 484
    Yahoo Messenger ID: michalowski_rmi@yahoo.fr<mailto:michalowski_rmi@yahoo.fr>
    Skype ID: remi_michalowski

    CPB - Integrated Shrimp Farming. "From Pond to Plate"
    A CPP Company. Part of Charoen Pokphand Group

    On Aug 16, 2007, at 2:48 PM, cansalmon@aol.com<mailto:cansalmon@aol.com> wrote:

    Dear Mr Michalowski

    See the notes below the press release.

    Sincerely,

    John Clemence

    PRESS RELEASE
    Shanghai, 20th June 2007
    Global Food Safety Initiative Breakthrough
    Roger Corbett, Chairman of CIES - The Food Business Forum announced to over 1100 senior
    executives at the CIES Annual World Food Business Summit in Shanghai, PR. China, that
    retailers have reached a landmark agreement on food safety standards.
    Under the umbrella of the Global Food Safety Initiative (GFSI), 7 major retailers have come to a
    common acceptance of the four GFSI benchmarked food safety schemes:
    • BRC - British Retail Consortium Global Food Standard
    • IFS – International Food Standard
    • SQF 2000 – Safe Quality Food Scheme
    • Dutch HACCP Scheme (Option B)
    Each scheme has now aligned itself with common criteria defined by food safety experts from
    the food business, with the objective of making food manufacture as safe as possible. As a result,
    this will also drive cost efficiency in the supply chain and reduce the duplication of audits.
    The GFSI vision of ‘once certified, accepted everywhere’ has now become a reality. Carrefour,
    Tesco, Metro, Migros, Ahold, Wal-Mart and Delhaize have agreed to reduce duplication in the
    supply chain through the common acceptance of any of the four GFSI benchmarked schemes.
    The current Chairman of GFSI, Roland Vaxelaire, Director of Risk, Responsibility and Quality
    for Carrefour said “I can only encourage other retailers to follow this example and apply the
    GFSI philosophy, in order to continue to drive cost-efficiency for all players throughout the
    supply chain, whilst making food as safe as possible for our customers”.
    This breakthrough marks a step change in the orientation of GFSI. The group will now
    concentrate on the application of the schemes by examining auditor competence, along with
    upcoming issues such as food security and food safety in emerging markets.
    The CIES-led initiative was set up in 2000 to pursue continuous improvement in our food safety
    systems, cost efficiency in the supply chain, and above all safer food for consumers worldwide.
    For more information:
    Catherine François
    Senior Manager – Food Safety Programmes
    CIES - The Food Business Forum
    Tel : (33) 1 44 69 99 21
    c.francois@ciesnet.com<mailto:c.francois@ciesnet.com>
    Anne Malbrancq
    Corporate Communications
    CIES - The Food Business Forum
    Tel : (33) 1 44 69 99 20
    a.malbrancq@ciesnet.com<mailto:a.malbrancq@ciesnet.com>

    -----Original Message-----
    From: Remi Michalowski <remi.michalowski@cpp.co.id<mailto:remi.michalowski@cpp.co.id>>
    To: cansalmon@aol.com<mailto:cansalmon@aol.com> <cansalmon@aol.com<mailto:cansalmon@aol.com>>
    Cc: seafood@ucdavis.edu<mailto:seafood@ucdavis.edu> <seafood@ucdavis.edu<mailto:seafood@ucdavis.edu>>
    Sent: Tue, 14 Aug 2007 11:52 pm
    Subject: Re: Auditing Quality Systems

    Agree the BRC and the IFS are rather similar even if the evaluation scales are different. I was talking on certain "degrees" of expectations. If I remember correctly, your original statement was "Please note that IFS is a bit "better" than BRC as it integrates legal requirements such as traceability, GMO and allergens." My critique was that in fact the BRC does incorporate those requirements also.

    Abt the ISO, I never stated that the retailers will better accept the ISO. I said that there are issues from the retailers' point of view, such as on the requirements: Means Vs. Results. Means are always preferred by retailers. If I am not wrong, ISO is still reviewed by GFSI, isn't it? Yes you are wrong, CIES may have reviewed the ISO standard but it does not accept ISO. Note press release at start of page.

    At last, abt the CBs, I insist: UK retailers do not trust all the CBs. I agree 100 percent. There is no doubt that they have favorites; some due to familiarity, some due to proximity and probably some due to personal contacts. After all, a CB is not a non-profit organization, they have a business to run. They follow what customers expect. Furthermore, auditors are only men and they have different ways to interpret the standards and even to appreciate a non-conformity.
    As a result, some CBs are more trusted than others and if you are not certified by one of the "approved" CBs, they can request you to be recertified by another CB, part of their "positive list". You have put your finger on the biggest problem in the quality auditing business; trustworthiness of the CBs and the auditors themselves. There is ample room for improvement by the standards owners in monitoring the CBs. They also should investigate why some CBs are not accepted and either work with them to gain acceptance or drop them as recognized auditors.

    However, if you look at the trends, more and more, the retailers have their own expectations (M&S does not even look at the BRC).
    Once again I respectfully disagree, M&S has always operated separate from the BRC and their continued independent stance is hardly proof that other retailers are dissatisfied with the standard. Are you familiar with any long time BRC members that are no longer recognizing that standard? Further as the press release notes it looks like the really big boys are declaring the 4 GFSI benchmarked standards as equal, which in the long run should simplify the situation for the processors.

    We cannot expect for the "best" or the most demanding standard. Nobody can be satisfied 100% by a standard. Look at the ISO, GFSI was a bit disappointed by the results. Some WG members were expecting more from the ISO such as a clear Decision Tree.

    No system is perfect, no standard is perfect. You will always find higher expectations from certain buyers. But, to summarize, ISO is very interesting for developing countries, and for the others too, as it offers a systematic approach to analyze your process and fulfill legal requirements. Then, you can move on with the BRC or the IFS, and, maybe, you can satisfy M&S one day.

    Rgds,

    Dipl. Ing. Rémi Michalowski
    Senior Manager QA Food Processing
    PT. Centralpertiwi Bahari - Lampung, Indonesia
    HP + 62 815 4040 484
    Yahoo Messenger ID: michalowski_rmi@yahoo.fr<mailto:michalowski_rmi@yahoo.fr>
    Skype ID: remi_michalowski

    CPB - Integrated Shrimp Farming. "From Pond to Plate"
    A CPP Company. Part of Charoen Pokphand Group

    On Aug 15, 2007, at 12:59 PM, cansalmon@aol.com<mailto:cansalmon@aol.com> wrote:

    Dear Mr. Michalowski,

    I was interested to read your comments concerning the relative merits of the BRC, ISO 22000 and the IFS. I find it hard to believe that British retailers trust ISO over the BRC. Remember BRC stands for British Retail Consortium and the standard has been developed and updated by British Retailers. In fact I am aware of several British Retailers who approve plants having only a BRC certificate, but do not accept only an ISO certification.

    Likewise I am puzzled by your comment that the IFS is better than the BRC because it has requirements for traceability, GMO and allergens. I don't know who has provided information that the BRC standard does not address those requirements. Traceability is one of the 10 Fundamental Clause requirements of the standard (Section 2.13) as are Allergens and GMO products (Section 4.2). Failure to have systems to meet any of those requirements results in no certificate being issued.

    Finally, I don't understand the notation concerning Certification Bodies. Any third party standard scheme requires an auditing body to determine compliance. ISO 22000 is no exception and many of the CBs conducting audits for ISO 22000 also audit for BRC or IFS certifications as well.

    It is fine to debate the relative merits of participating in Quality System audit programs and what benefit one receives from them, but be careful of statements that misrepresent the various standards.

    Sincerely,

    John Clemence
    President
    Clemence Technical Services

    -----Original Message-----
    From: Remi Michalowski <remi.michalowski@cpp.co.id<mailto:remi.michalowski@cpp.co.id>>
    To: Chingling Tanco <crt@mida-group.com<mailto:crt@mida-group.com>>
    Cc: seafood@ucdavis.edu<mailto:seafood@ucdavis.edu>
    Sent: Tue, 14 Aug 2007 4:16 pm
    Subject: Re: Auditing Quality Systems

    ISO 22000 is a management system, international standard to support your FSMS. It pushes companies to provide results e.g. the main issue for retailers is that the company can select and implement the control measures they want, once they manage the risks identified and that the system meets the targets established.

    Private standards such BRC and IFS, all is means e.g. investments. BUT, more and more nowadays, this "prerequisite" to be able to sold to retailers becomes less "trusted" by the retailers: they have a list of "approved" CB and some have their own requirements much more demanding !!

    In conclusion, ISO 22000 very good for developing countries and to meet legal requirements but demanding on results and also on money (audit, competence). BRC very demanding on means and facilities but less trusted by the UK retailers.

    Please note that IFS is a bit "better" than BRC as it integrates legal requirements such as traceability, GMO and allergens. but the standard is still a private one and only valuable if you process retailers' branded products.

    Rgds,

    Dipl. Ing. Rémi Michalowski
    Senior Manager QA Food Processing
    PT. Centralpertiwi Bahari - Lampung, Indonesia
    HP + 62 815 4040 484
    Yahoo Messenger ID: michalowski_rmi@yahoo.fr<mailto:michalowski_rmi@yahoo.fr>
    Skype ID: remi_michalowski

    CPB - Integrated Shrimp Farming. "From Pond to Plate"
    A CPP Company. Part of Charoen Pokphand Group

    On Aug 11, 2007, at 10:30 PM, Chingling Tanco wrote:

    I agree it's getting crazy - in Europe for example - the UK wants the BRC
    (British Retail Consortium) standard while France and Germany want the IFS
    International Food Standard system and they are almost the same but called
    different names. Suggestion for those plants going for BRC certification -
    ask for IFS certification to be done at the same time as this shouldn't cost
    you much more.

    Chingling Tanco
    Mida Trade
    Manila, Philippines

    From: Vanessa Broadnax <vanessa@baldorfood.com<mailto:vanessa@baldorfood.com>>
    Date: Thu, 9 Aug 2007 20:12:01 -0400
    To: <criticalcontrolpoints@yahoo.com<mailto:criticalcontrolpoints@yahoo.com>>, <seafood@ucdavis.edu<mailto:seafood@ucdavis.edu>>
    Conversation: Auditing Quality Systems
    Subject: Re: Auditing Quality Systems

    Sometimes more is good. We need to keep food safety in the forefront. We can
    not afford not to look at different points of view. Different views keeps us
    on our toes. We must manage our time and efforts wisely.

    ----- Original Message -----
    From: owner-seafood@ucdavis.edu<mailto:owner-seafood@ucdavis.edu> <owner-seafood@ucdavis.edu<mailto:owner-seafood@ucdavis.edu>>
    To: seafood@ucdavis.edu<mailto:seafood@ucdavis.edu> <seafood@ucdavis.edu<mailto:seafood@ucdavis.edu>>
    Sent: Thu Aug 09 19:57:07 2007
    Subject: Auditing Quality Systems

    I seem to spend a lot of time being accredited to one quality system or
    another and then meeting with Processors who complain that there are so many
    systems that they have to become documenters for each system with differing
    needs.

    Any comments on relative merits of the differing systems ?
    (without especially trashing systems by name)

    My two cents, for what it is worth, is that ISO 22000 will probably replace
    everything else eventually. ( it has HACCP components so is on-topic)

    Other views anyone?

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