Transferring the Role of Plant Management from Government to Management

The U.S. Department of Commerce’s (USDC) National Oceanic and Atmospheric Administration (NOAA) provides a key service to the seafood industry in the form of the voluntary Seafood Inspection Program, which offers a variety of professional inspection services that assure compliance with all applicable food regulations. In addition, product quality evaluation, grading, and certification services on a product-lot basis are also provided. Benefits include the ability to apply the U.S. Grade A, Processed Under Federal Inspection (PUFI), and lot inspection marks.

One service offered is the National Marine Fisheries Service’s Hazard Analysis and Critical Control Point Quality Management Program (HACCP-QMP). This full-focus program emphasizes product safety, plant and food hygiene, economic integrity, and product quality. Firms participating in this program operate its approved quality system and are audited at a defined frequency by Seafood Inspection Program personnel. Audits are based on the firm’s adherence to the approved plan. Firms that do not follow the plan well but take responsibility for corrections and improvement are typically audited more frequently.

If a firm can maintain its system, it can be audited as seldom as once every three months. In return, compliant firms may place inspection marks on any products that meet the program’s requirements. Because the only other alternative is having an inspector present during all processing of identified products, this means notable savings on inspection costs.

Relationship of Plant Management With Government

The traditional model of food safety and quality control has typically relied upon companies presenting their products to regulators to evaluate their conformance. The standards ranged from simple to complex, but the pressure was as much on the regulators as it was on the companies producing the products.

Inevitably, this model placed the government into the role of inspector, in many ways taking ownership of product safety and quality away from the producer. If a government inspector passed the product, it was considered fine. One downside of this model is that it led companies to focus on satisfying inspectors rather than on accepting responsibility for the safety and acceptability of their products.

From the beginning of the use of systems to evaluate food safety and quality, management clearly had a pronounced role. The first quality systems used a general plan of quality assurance that became management’s eyes and ears. But, in such systems, production remained the lead driver, and quality reports were often ignored as long as production and profits were high.

As quality management standards matured, however, management was specifically brought into the system. As the ISO 9001 Quality Management System Standard states, “top management shall provide evidence of its commitment to the development and implementation of the quality management system.” This commitment required a change from mere intention to actual demonstration. In addition, management review needed documentation and records.

This was a bold statement in the early days of quality management standards and systems. Until this change, many quality assurance managers had felt pressure from top management for a quality product only if it did not hinder production.

Management’s Role in HACCP

In the early 1970s, the food safety system of HACCP was introduced. This system outlined a strong method of identifying food safety hazards and subsequently monitoring and documenting their control. It was used sporadically until 1997, when it became required in the U.S. seafood industry. Until this time, it was industry driven and, with the exception of low-acid canned foods, was not fully in place in many food systems, let alone used as a regulatory tool.

Once HACCP principles took root, they were eventually outlined in Codex Alimentarius and generally standardized throughout the world, with some minor modifications from location to location. These principles outline, in general terms, a procedure of verification performed to evaluate the overall effectiveness of the system. In many cases, however, verification was not defined, and when it was, it tended to be narrow in scope.