Food standards and auditing

Why have standards become so important?

The increased need to meet a wide range of standards by trade partners to ensure ‘equivalence’ in food control or achieve market expectations has elevated the commercial importance of food standards. The rising actual and perceived economic impact of meeting these standards has necessitated investigations into the relevant costs and benefits. Many developing countries have claimed standards are in effect trade barriers, as the countries imposing such standards often do not comply with rigorous controls internally, e.g., zero tolerance for Listeria within meat products in the USA. The meat lobby within the USA is claimed to demand such standards to prevent the import of competitor products. The increasing number of widely reported serious food poisoning outbreaks has also raised public demands for more effective food standards.

Transparency within the standard setting and compliance process is therefore crucial to international trade. Emberley has reported that there is a need for the ‘fair validation’ of food control systems to prevent non-tariff trade barriers and ensure their equivalency. This has resulted in an increasing workload for the Codex Committee on Food Import and Export Inspection and Certification (CCFICS). This committee developed and reviewed the criteria for inter-country inspections and has thus clarified the mechanisms for mutual recognition agreements (MRAs) and memorandums of understanding (MOUs) as the basis of bilateral food trade. The mutual recognition of equivalent standards and conformity assessment procedures has moulded international standards guidelines and requirements in the last five years.

Audit systems are now used by government agencies who monitor these agreements and therefore audit has been recognised as the mechanism to ensure effective food control systems have been implemented and maintained. The United States has prioritised the development of MOUs with its major trading partners particularly those with established operational hazard analysis critical control point (HACCP) systems. The route to determining equivalence is now based on desk and on-site audit techniques. Apart from this legal drive for audit, suppliers also want to meet agreed market standards and therefore face a larger number of ‘supplier’ audits from their customer base.

What are standards?

Standards are agreed sets of criteria for ensuring consistent manufacture of food products from a safety, nutritional or management system perspective. These standards may be required by law or by the market. There are a wide range of legal food standards, ranging from product specific such as meat, fish and eggs (EU directives) to cross cutting, such as the horizontal general hygiene directive. These standards are therefore established by agreement and approved by a recognised body that ensures consistent manufacture within agreed rules. Completed standards should be simply documented technical specifications aimed at the promotion of community benefits.

Why have standards?

In complex food networks clear standards are needed to ensure efficient food production within a myriad of legal requirements. The ISO/IEC Guide reported the improved suitability of the product, process or service for an intended purpose when standards are used. Furthermore, standards should prevent barriers to trade and enable technological co-operation. Standards may therefore be focused on, but not restricted to, variety control and protection of the product, consumer or environment, and also cover health and safety.

Some customers may only require a ‘certificate of conformity’ to guarantee that an agreed specification is being met. Many companies now insist on a ‘supplier appraisal’ scheme to compare performance against agreed quality and legal standards. Much of the world food trade is reliant on raw material from developing countries.

Principles outlined in the standard setting process:

Simplification

This is a continual process of converting complex processes into an easily understood model, e.g., the Institute of Food Science and Technology (IFST) Good Manufacturing Practice guidelines. This document provides guidance to food manufacturers on how to manufacture safe, quality food products consistently by adherence to the principles of GMP within a wide range of processes.

Co-operation

The standard should be reached by consensus between the relevant stakeholders, as economic and social requirements may be in conflict. The process by which standards are agreed has been used to incorporate a risk-based approach, that is understood and accepted by the population. The co-operation and involvement of the public in agreeing acceptable levels of risk within a given food standard is now an essential part of setting standards and avoiding conflict.

Implementation

The standard must be achievable and clear guidance on implementation provided. The original World Health Organisation (WHO) documents on food safety systems, i.e., HACCP, contained principles, but insufficient information was provided on how to achieve them consistently. More recent publications have provided guidance on the methods and approaches required to achieve standards.

Selection

The areas and subjects that standards may cover in the food sector are wide and must be chosen carefully. The areas of focus and the basis of the standard are selected specifically to ensure that topical issues are encompassed in any new development and the standard will remain relevant for as long as possible without revision.

Revision

This revision introduces the farm to fork principle within hygiene policy, and includes programmed self-checking and modern hazard control techniques. Food producers assume primary responsibility for food safety. The implementation of harmonised HACCP systems by non-primary food operators will also become a mandatory requirement. A third principle will be traceability of all food and food ingredients. These new requirements will result in the fourth principle, which is the compulsory registration of all food businesses. These revisions have been made to keep the existing standards relevant and capable of achieving consistent control within the food chain.

Determination of compliance

When the key process or product criterion is defined, the specifications must include a description of the recommended or compulsory methods and tests. Sample size, frequency and method should be given if necessary. Existing EU directives and annexes often give guidance on specific methods to be used to determine compliance.

Legal enforcement

This is dependent on society and the national opinion on the need for legally enforceable standards. In many cases, countries vacillate between encouraging members of the food chain to comply with relevant standards and strict enforcement of standards.

Standards and specifications:

The term ‘standard’ can be used in different ways. It can refer to a relative level, i.e. the standard of something, or to an absolute threshold, e.g. minimum performance criteria. Food standards are issued by government bodies, and companies must comply with them. They safeguard public health, safety and the environment and are therefore compulsory. United Kingdom food legislation requires food to be not injurious to health. Some US and other legislation require food to achieve specific microbial standards.

Mandatory standards

Examples of mandatory standards include the absence of Salmonella, Cholera and other pathogens in processed foods and maximum residue for chemicals, heavy metals and specific pesticides. These standards specify limits for toxicants, pathogens and additives. Additional standards cover packaging and labelling.

Voluntary standards

These standards are set by trade associations or companies and detail minimum requirements for products, but are not legally enforceable. They are intended to provide a guide for business to achieve target requirements, often in relation to market needs.

Standards are viewed as the minimum requirement, but specifications are often much more stringent. Often problems may arise when enforcement officers inspect non-compliance records, which demonstrate that the business may not be meeting current market requirements, but achieves the minimum legal requirements. Companies may hold specifications for raw materials, in process and final product specifications.

The need for audit:

Industry and governments have realised that effective food control systems require shared responsibility in aspects of their design, operation and verification. Governments are required to set the overarching limits within which these systems operate, and industry must design and operate to meet these limits. Food control standards, once set up, are not always effectively implemented, because of resistance to change, lack of commitment, limited resources and increased training requirements. Commercial advantages have not always been measured or promoted and industry fears the cost implications in achieving set standards. Audit has often been poorly addressed by government and industry. Confusion exists about the meaning of the words audit and verification, both in the US and in other countries.

The role of audit is therefore of increasing importance, and the relevant skill sets required by food ‘inspectors’ need to be defined and agreed at national and international level. Auditing food control systems using standard methods is now recognised as a challenge for the new millennium, for both industry and government, in the expanding and increasingly complex world of food protection. It is a challenge that must be met!

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