Action Plan for Food Safety and Responsible Sourcing

At the recent PTNPA convention, we gave a presentation entitled "An Ounce of Prevention or a Metric Ton of Cure". (CLICK to view) We would like to propose a solution. We have been working for the past two years on the development of a program that addresses the issues that make the nut and agricultural industry vulnerable, and offers a turnkey system to protect us from the kind of situation that has resulted from the recent peanut recall.

FDA Globalization Act of 2009

Although there has been heavy focus on domestic oversight, the fact is that we know even less about where and to what standards our imported food products are processed. Ignorance is no longer an excuse that will be tolerated. Legislators have come down very hard on the people they feel were responsible for ensuring public safety. Congressmen John Dingell, Bart Stupak and Frank Pallone Jr. have incorporated higher standards of accountability in their most recent draft of the Food and Drug Administration Globalization Act of 2009. This act can be viewed in full at the following link:
http://rs6.net/tn.jsp?t=v7awjxcab.0.0.987yumcab.0&p=http%3A%2F%2Fptnpa.org%2Fnews_pdf%2FDingell-Bill-HR.pdf&id=preview

Now is the time for industry self evaluation. Would our current system stand up to government and consumer scrutiny? It doesn't matter if individual companies have this ability. We need to set standards for the entire industry. We are only as strong as our weakest link.

The CCC Solution

The CCC system presents a preventative approach to responsible sourcing and food safety and addresses many aspects of the FDA Globalization Act.

Step One: Identification - The CCC system first identifies those suppliers who subscribe to good manufacturing practices. Companies that need help in establishing GMPs can utlilize our consulting services to assist them in bringing their facilities up to the necessary standards.

Step Two: Inspection - Through a third party audit by independent unbiased inspectors using industry experts who have a background not only in Quality Control and production, but also a working knowledge of the industries being inspected.

Step Three: Certification - Once the identification and inspection process is completed, these facilities will be certified under the guidelines of the CCC.

Step Four: Tracking - The CCC has developed a user friendly, comprehensive tracking system software called CONCERNTRAK©. During the inspection process our auditor interviews two key production personnel. These individuals are fingerprinted via a biometric identification procedure. To ensure a higher level of security, only these prescreened personnel can enter data into the system. CONCERNTRAK© enables the end user to trace lots back to the production line and produces verifiable documentation, making this process quick and easy. Each carton is labeled with the tracking number and sealed to ensure a tamper resistant box that can be cross referenced with all documentation.

Step Five: Promotion - Our logos for Cashew Concern Certification and Commodity Concern Certification enable manufacturers to convey the message to consumers that they have done their due diligence to responsibly source the food products under their brand name.

Step Six: Protection - The integrity of our industry is protected when we take steps to adopt programs such as that of the CCC, to ensure the safety of our food production through a system of self regulation. If an incident should occur, at least we have a system in place to present to the authorities. Having no viable system to ensure traceability and responsible food sourcing will highlight our deficiencies, and would present an embarrassment to the industry.

The "Ounce of Prevention"

We can no longer assume that it will be "business as usual". With the current climate in Washngton we can be sure that sooner rather than later our industry will be called upon to explain the procedures and systems we have put in place to ensure responsible sourcing. We have two choices. We can start now to develop these systems using countless hours of time and energy or, we can adopt a turnkey system, such as that offered by the CCC where two years of research and development have already been done. This is our "ounce of prevention". It will certainly be more tolerable than a potential metric ton of cure.

Identification*Inspection*Certification* Tracking*Promotion*Protection

Building a Solid Foundation to Establish a Healthy Future for the Imported Food Industry