Food safety: the dangers on the procurement side

Last November's updated NVWA Information Sheet 64 caused quite a stir. Hardly anything has changed in terms of content, but there is still insufficient attention to food safety on the procurement side, according to the NVWA. In this article, Paul Besseling, Food Safety Consultant highlights the problem from different angles. A solution does not appear to be easy, but it is getting closer.

In our production, food safety is well taken care of, but how is it with our suppliers?

What is the point of a supplier audit, certificate or declaration?

We have a good sampling plan, what will NVWA think of that?

These questions haunt many a quality manager in the industry. HACCP is presented in the Codex as a chain responsibility, talking about "the crucial importance of cooperation between companies, trade groups and authorities." Fine words, but in practice it is mostly "every man for himself" and "certificates for all."

Control

The many recalls on ethylene oxide have shown how huge the impact can be. But there is much more at play. European Implementing Regulation 2019/1793, which is partly based on RASFF (Rapid Alert System Food and Feed), shows that the control of some 10 contaminants from some 35 non-European countries is structurally inadequate. It is therefore not surprising that NVWA would like to see the sector strengthen its self-cleaning capacity.

Control of a dozen or so contaminants from some 35 non-European countries is structurally deficient

Despite this endeavor, NVWA, from a European/international perspective, still stands fairly alone with fact sheet 64. Perhaps this is partly due to the formal HACCP method in which hardly any attention is paid to the relationship between the links. Basic errors are also often not recognized as a result. For example, companies often present the request for a CoA (Certificate of Analysis) as a control measure - sometimes even as a CCP - while it is about verification. With control measures, a company takes responsibility for a particular hazard; verification is often no more than an additional indication that things are okay, guaranteeing it does nothing. The added value of verification to the total risk management is therefore difficult to interpret. This makes it difficult for buyers and suppliers to agree on what information is provided (communication) and how it is tested (verification).

Certification

The introduction of HACCP has given a big push to certification in the food sector. But even though there are plenty of starting points in the standards, there is very little time in the average audit to test them all. Much beyond methodical inconsistencies, most findings don't go much further. This is understandable. After all, the standards say nothing about the content of the hazard analysis, and an auditor does not simply have the knowledge at his or her fingertips to comment on the various risks of the many raw materials. Only an audit according to Risk Plaza provides an auditor with enough baggage and time to handle this.

GINO helps

At Précon, we see many companies struggling with their approach. The administrative burden of the ever-expanding hazard analysis is great and keeping it up to date is certainly no easy task. Fortunately, we recently acquired GINO, an interactive software tool for a risk-oriented verification plan.
The tool basically consists of a database of purchases and suppliers and a database of hazards. A link between the databases leads to a hazard analysis that is converted via a decision model into verification actions per supplier and per procurement product.

Database Procurement and Database Hazards

The hazards database contains about 200 hazards identified in about 40 laws for about 500 products. Probability and severity information is used to determine the risk for each combination of hazard and product. On the basis of legislation, RASFF notifications and publications by, for example, the RIVM and EFSA, we constantly keep the database up to date. The purchasing database is filled by the user and contains the purchases with the corresponding suppliers.
The user links his purchased products to the product groups in the hazards database and thus the hazard analysis is made. It is now immediately clear which procurement products represent an increased risk.

From hazard analysis to verification plan

Through a decision model - based on Information Sheet 64 or set by the user - the hazard analysis is converted into a verification plan. The decision model contains questions about the level of risk, the possible control by the buyer and the reliability of the supplier. The answers together determine whether to request a certificate or analysis result, analyze samples or do supplier audits, etc. GINO creates the verification plan per supplier, product, or hazard, in the desired combination and order. Via an export in Excel, the plan is available for other applications.

One less worry

The tool takes the worry out of keeping track of legislations through hazard analysis and provides a consistently substantiated verification plan. There will be discussion about the outcomes. After all, how far should we go? Do we look only at our direct suppliers, or do we go a step further back or put our questions on the farmer's plate? Who knows, may say. The A-brand producer will go much further for his single product than the private label producer who sources some 1,000 raw materials from a hundred or so suppliers at the customer's request. For now, it is up to each company to make up its own mind. Just make sure the homework has been done.