The Changing Quality Management System
Import notification, traceability and the imminent requirement of country of origin labels are changes that are molding the quality management system of the future, say Lawrence and Mary Ann Platt, a husband and wife team who run RQA Inc. and CNS/FOODSAFE, two Darien, Ill., firms that help keep a variety of manufacturers and retail operations on the quality-and-safety straight and narrow.
The Bioterrorism Act, the Platts say, is perhaps the newest in a long line of adjustments for the food industry that all add up to identity preservation.
“Companies want assurances that everything from the seeds in the ground all the way through the final product has been audited, certified, checked, and that there are documents that say this has been done, says Lawrence Platt, president of RQA. “So, identity preservation is going to be a very large activity in the next few years.”
When contacted by Food Quality, the Platts had their hands full with 10 recalls. On a daily basis, they see a variety of things that were somewhat afterthoughts five to 10 years ago, but are now areas of contention that can potentially obliterate identity and brand preservation.
Aside from the regulatory influence, testing methodology and rapid microbiology methods are much better these days, and this has created a greater public awareness of emerging pathogens, allergens, labeling and cross contamination.
That awareness, Mary Ann Platt says, has increased the tendency for litigation when damage is done.
“After the Jack in the Box incident, it brought what could happen to the forefront,” she says. “It created a different level of consumer awareness. Then, you saw lawyers identifying this as an opportunity area and then you started to see some awards in court.”
The Seattle, Wash., law firm, Marler Clark, aggressively pursues foodborne illness and food-related lawsuits. At the time of this report, the Web site, www.marlerclark.com, had a number of news items ranging from “Men suing Chi-Chi’s for Hepatitis Soup” to “How Safe is Cafeteria Food?”
The Web site also sponsored numerous links, one of which was Outbreak Inc., a Seattle consulting company based on “a radical notion that the same lawyers who sue on behalf of victims of foodborne illness are best suited to help responsible companies” with food safety challenges.
The threat of litigation isn’t the only thing shaping the quality management system of the future, and over the last five years, there has also been a reemphasis on protocols to ensure recalls are implemented correctly.
Insurance companies that sell recall insurance are contracting companies like RQA to conduct pre-policy assessment for contaminated product or recall coverage. Essentially, the insurance companies require a due diligence from food companies to ensure a recall plan is in place and that it functions correctly in the event of an incident.
“A lot of times, a company has a recall plan, but it can’t execute it, so it has us go in prior to the policy and verify that. And if there are gaps, we assist those companies to make the plans work. Then, we verify the execution by doing a mock recall,” Lawrence Platt adds.
“There’s much more of an effort going toward preventive activities and crisis planning versus actually just having a problem with a product and getting it back,” he says, adding that Europe has mandated that companies selling products in the European market must have a recall plan.
The Next Chapter
So what will the next 10 years bring for food quality and safety?
Presently, there was some degree of regulatory cross-pollination going on between the food and pharmaceutical industries. The food industry has found that certain portions of protocols, like 21 CFR Part 11, which deals with electronic record and documents, can be applied in food plants. The interest on the part of the pharmaceutical industry has been piqued and it is now asking, “What’s HACCP?”
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