A Certificate is not Enough

A Certificate is Not Enough

By Mary Smith

Whenever there is a consumer safety incident, the first impulse is to require a "Certificate" from the producer or manufacturer. During the uproar over Chinese goods, sparked by tainted toothpaste, adulterated dog food, leaded toys, etc., customers began demanding "No Chinese Origin" certificates. Now we are hearing of requirements for "Salmonella Free Certificates".

A Simplistic Approach to a Complicated Problem

The problem with this approach is threefold. First, a certificate, especially if it is not issued by an impartial third party, cannot always be taken at face value. Often the certificates are faxed or scanned, making alteration easy to do and difficult to detect. Secondly, what is there to guarantee that the certificate in question actually applies to the merchandise it is supposed to certify, if there is no tracking system? The third problem with solving safety issues through certificates is that it is a simplistic approach to a much more complicated question. In the case of the "No Chinese Origin" certificate, can we then assume that there are no problems in facilities in the rest of the world? For that matter, aren't there reputable facilities in China that have nothing in common with the substandard operations that cause the problems?

It was revealed that Peanut Corporation of America had actually issued a certificate stating that the peanuts that caused an enormous and costly recall, not to mention seven deaths, were free from salmonella. In reality, the batch of nuts had received a postitive salmonella reading from one laboratory, and a negative test from another. PCA's customers, who had relied on the certificate, nevertheless became embroiled in a difficult and cumbersome recall that strained resources and weakened consumers confidence.

The scenario was different for Nestle, who actually did inspect the plant. Nestle sent auditors to PCA plants in Georgia and Texas, and found "grossly unsanitary conditions" in both. The company did not do business with PCA, and consequently suffered no harm when the recall took place. Proper due diligence is the wisest course.

According to international food safety expert David Troster*, "Certificates are always open to question, scanners and copiers and unscrupulous people always ready to falsify things. The solution to this problem is to demand that all certificates be obtained from laboratories that have ISO 17025 certification, with a scope that covers the analysis. You need to extend this by including from time to time an audit of the laboratory and its certification. You must also audit your suppliers to see if they provide liquid bactericidal soap, non-perfumed, hot water and disposable towels to dry hands. Watch to see if people do clean their hands. Audit their cleaning methods. There are many factories that only clean when a vistor is coming. These are easily found and should be avoided."

The Need For Industry Standards

By David Rosenthal

At last year's Association of Food Industry Convention, I proposed as a topic for discussion at the Nut and Agricultural section meeting the need to establish protocol to address the increase in rejections due to microbial contaminants in nut products. I also stated that it was necessary to establish documented, industry wide accepted tolerance levels for microbial contaminants in raw nut commodities, and approved methods to reduce pathogens if they are above acceptable levels. At present, there are no established acceptable levels, and no industry wide standards addressing these issues. At that time the prevailing feeling at the AFI was that these were not priority issues, but recent events in the nut industry have made it urgent that ithey be addressed.

New Questions Are Surfacing

Last year at this time no one could have imagined that 700 people would have been sickened and 7 dead as the result of microbial contamination in a nut product. Nor would anyone have thought that just three months later another contaminated nut would be the cause of a massive recall involving products as diverse as energy bars and ice cream. Now questions are surfacing:

"What industry wide standards have been established for accepted microbial tolerance levels for raw imported nut products?"

"What are the accepted and effective kill steps for nuts in order to eliminate dangerous contaminants such as salmonella and e.coli?

Industry standards related to nut products have not historically addressed microbial tolerance levels as it has been widely assumed that the raw nut products would go through additional processing, such as roasting, that would involve a kill step. In recent years many of the nut categories that were traditionally consumed roasted are finding their way into consumer products in their raw form. This being the case, questions arise as to what steps have been taken to ensure that the raw material is within accepted microbial tolerance levels.

Is Testing Enough?

Does testing give us the assurance we need to omit a kill step? And here is the million dollar question "Who is responsible for the kill step when the raw product is distributed directly to consumers???" Many manufacturers have purchased raw imported nut products with the assumption that they were consumer ready from a microbial standpoint. This mindset started to change when some companies started to conduct their own testing, and now, in light of recent incidents, it has become a dangerous assumption.

There is no industry protocol to address what should be done in the event of a confirmed positive for salmonella, but the fact is that an adulterated product cannot be distributed in the USA. The following links provide some guidance:

http://rs6.net/tn.jsp?t=dyvb79cab.0.0.987yumcab.0&p=http%3A%2F%2Fwww.fda.gov%2Fopacom%2Flaws%2Ffdcact%2Ffdcact4.htm%23sec402&id=preview

www.co.sauk.wi.us/data/news/flood/ph_flood_info/Policy-10.12.pdf

Testing upon arrival is only one component of a food safety system, but it is not a substitute for the due diligence needed to ensure that the facilities at origin maintain good manufacturing practices. The testing is simply a final verification of the integrity of the process by which the product was manufactured. Therefore proactive measures to ensure responsible sourcing from good facilities overseas is the first step to ensure consistent product quality.

CCC Moves to New Offices

The CCC has moved to new offices. We are now located at 9509 Hull Street Road, Suite D1, Richmond, Virginia. 23236. Our phone and fax numbers remain the same.

-------------------------------------------------------------------------------
*David Troster is a Food Safety Consultant with thirty years experience in many areas of the food and hospitality industries. David's areas of work include:
A practical approach to developing working HACCP systems integrated into your operating system.
Training Directors and Managers in Food Safety.
Supply chain auditing, identifying the hazards and helping you eliminate them.
Factory design.
Advice on European legal requirements.
If you need more details or have a specific question then please e-mail David at troster@netone.com.tr