Friday, May 15, 2009



Recently the Association of Food Industries held its annual convention in Naples Florida, and of course, issues regarding food safety were the running theme throughout the meetings. Speakers included legal and insurance experts who are keeping a close eye on impending legislation that will call for significant changes to the rules under which food is imported into the United States. All of the food bills under consideration include two major components that are lacking in the current importation process. First, the ability to track lots back to their origin production facilities and lot runs. Currently this is cumbersome and ineffective. Second, there must be verification that good manufacturing procedures are being followed by overseas suppliers. At this time, verification of any kind is difficult and many facilities have never been audited.
Who is responsible? During the meeting the question was asked: Are food suppliers throughout the distribution channel responsible for ensuring the integrity of the processing plants that the raw material comes from? The answer was a definitive YES! What was not clearly determined was how it could be done effectively and affordably.

Currently the Nut and Agricultural section of the AFI and Federal Government lack the human resources and funds to ensure that every facility overseas meets good manufacturing standards. Therefore, in an effort to ensure that there is integrity to the product being supplied to the roasting and manufacturing community it was decided to put together a working group to address the possibility of having mandatory certificates of analysis with every shipment of imported nut and agricultural commodities that currently fall under AFI guidelines.

A Certificate of Analysis Is Not Enough

A Certificate of Analysis is the final validation step of good manufacturing processes, but it is not a substitute for ensuring, through third party audits, that these processes are implemented. There is a saying among food safety experts regarding the accuracy of testing: "The absence of evidence is not evidence of absence". While there are no absolute guarantees, maintaining and verifying the integrity of each step of the process reduces the risk significantly
Some companies have begun to fund efforts to inspect facilities overseas on their own. This is very costly, time consuming and only benefits the company funding the effort. To date, there have been no feasible solutions offered to address the impending necessity to inspect overseas processing facilities that would be effective, meet the demands of legislators, and benefit the entire industry at a minimal cost.


It is a known fact that a large seagoing vessel cannot be turned around instantaneously; it must be turned in degrees. This holds true to turning our industry around as well. Change won't take place overnight but it does not mean that we should not begin to focus our efforts in the right direction. At present, we would not be able to effectively comply with the imminent legislation that would require third party inspections of ALL overseas food processing facilities. It is a big job but we have to start somewhere and figure out the most cost effective and efficient way to do it. The CCC has put together a group of industry experts in the fields of auditing, production, food science, food safety compliance procedures, along with legislative experts, to establish an organization that could effectively develop control systems to protect companies and provide the information needed to source from good manufactures overseas.


Currently the CCC has a database of over 200 active users of imported nut and agricultural commodities. Using our combined financial resources we can effectively begin the auditing process of overseas facilities, establish programs for track and trace procedures, and begin turning this industry around on the right course toward the future. The CCC as a Subscriber Based Organization? The CCC has the resources, infrastructure and willingness to make positive changes for the industry. Most importantly, we have time to dedicate 100% of our effort to address ways that our industry can adapt to unprecedented legislation that will change the way we do business. Our industry will have no choice but to change and as it stands now we are ill prepared for these changes. The current trade organizations do not have the time or resources to dedicate the amount of effort needed to effectively initiate programs that will be required to help us "adapt to the future" A subscriber based organization exclusive to roasters and manufacturers who use nut and agricultural products would represent an industry segment with the same common interests regarding issues pertaining to responsible sourcing and the auditing of overseas production facilities. We are not looking to replace the existing trade organizations, as they play a very important role, but this particular issue requires a special interest group.
Since CCC management is not involved in commodity trading, our approach is unbiased and focused solely on responsible sourcing initiatives to benefit its a subscriber base. The combined forces of a roaster/manufacturer exclusive organization would have a profound influence on the importing/commodity trading community to shift focus to responsible sourcing practices. The fact is that adapting to these unprecedented changes will require so much time and dedication that a special interest group with the sole purpose of protecting roasters and manufacturers must be developed. The CCC can help pave the way to make this happen.

We invite your comments, suggestions and questions regarding the development of such a program. Please contact David Rosenthal or Mary Smith at 804-745-2848 / . Also feel free to leave comments on our blog. We'd like to get a dialogue going.