The difference between ISO and BRC standards is that the BRC standard has a focus on quality, food safety and legality. SQF has separate audit programs for food safety and food quality. The FSSC 22000 targets food safety and legal compliance.
So what about our own FDA or USDA? With regard to the USDA for meat and poultry, everything is required to be inspected. Moyers says that the FDA does get involved, but it depends on the product. “Under FSMA (Food Safety Modernization Act), there is a regulation called ‘intentional adulteration’, so under that umbrella, companies who comply with FDA standards have to look at some types of food fraud, as FDA looks at food fraud that impacts safety – i.e. intentional adulteration such as poison, terrorist event, etc.
“So they’re not looking at FDA for food fraud for quality; they’re looking at fraud in terms of safety through food quality,” Moyers says. However, some foods have standards of identity to be used in food commerce, such as milk chocolate, cheddar cheese, all dairy products. The FDA has enforcement power that if a product calls itself cheddar cheese and it isn’t, and doesn’t meet the food’s standard of identity, then the FDA will be concerned.
Moyers goes on to say that, over the years, one of the FDA’s biggest concern has been seafood, due to mislabeling. Unethical suppliers will take a cheaper cut and call it a more expensive cut of fish, for example. Globally, there is now DNA typing for all of the 35,000 plus species.
The most controversial issue for standards of identity is olive oil with so many substitutions with oils out there. “An olive oil group from California is trying to get the FDA to get a standard of identity for the safety of their products. There have been scandals with oils coming out of Italy. There have been petitions sent to the FDA but nothing has been done yet,” explains Moyers.
FDA has jurisdiction and enforces food safety as part of the FSMA, as far as quality goes, it’s only certain products that have standards of identity for quality, she adds.
So what can we do? Many larger manufacturers have their own safety protocols in place. And use the GFSI as a baseline. They may also have an audit team to perform a separate customer audit.
A Certificates of Analysis is a document that comes from the manufacturer designed to attest to the quality and/or safety of a product or ingredient. But there is no uniform document for COAs—some lis specific things like taste, texture and color while many talk about microbiological contaminations. With regard to COAs, I always think about what Ronald Reagan once said: ‘trust, but verify.’”
One provision in the FSVP states that if a foreign supplier doesn't control a certain hazard, they have to have a supplier-approval program (for E. coli, etc.) and have an annual audit. “Only foods with hazards you can’t control, i.e., produce and ingredients you’re not cooking so you can’t control the microorganism. You’re not controlling what’s going on, you’re relying on your supplier for that food safety,” Moyers explains. This puts the impetus on importers to verify their suppliers overseas meet U.S. standards.
Manufacturers should also consider independent testing on ingredients. Some have internal labs and some will send out testing to independent certified laboratories. “I believe it’s a good idea to do periodic checks,” Moyers says. Some countries have been less compliant and the companies have to be vigilant to verify food safety and fraud.
Moyers offers some tips for manufacturers who are unsure of regulations or new companies: Consider the GFSI certification. Maybe do an independent audit of supplier before engaging. Some companies do periodic testing against specifications and safety parameters using accredited labs. Testing and education are important, Moyers adds. “When we do an audit, you say what is. When consulting, you can give advice… Is there a weakness in the program that we will advise against.”
Smaller companies may not be aware of these qualifications, so education, even EAS webinars, FDA documentation, etc. A company should be familiar with Foreign Supplier Verification Programs, standards of identity.
For more information visit easconsultinggroup.com, fda.gov and usda.gov FE