Food Companies Should Focus on GFSI Compliance While Waiting on FSMA
by Susan Moyers, PhD
The Global Food Safety Initiative was established at the beginning of this century, following a number of widely publicized foodborne illness outbreaks that adversely impacted consumer confidence in the industry. The GFSI mission is to provide “continuous improvement in food safety management systems to ensure confidence in the delivery of safe food to consumers worldwide.” GFSI works to harmonize worldwide food safety standards to increase transparency and efficiency in the supply chain and cut costs for manufacturers.
Originally created under Belgian law in May 2000, GFSI is now managed by The Consumer Goods Forum, headquartered outside Paris, France. GFSI is composed of panels of food safety experts from around the globe whose areas of expertise range across the supply chain. There are GFSI technical working groups and stakeholders, as well as conferences and other events. A product of these activities is the GFSI Guidance Document, which establishes auditable food safety practices and procedures based on current scientific knowledge for agriculture, aquaculture, and food production.
The GFSI Guidance Document forms the basis for a process known as “benchmarking,” whereby food safety auditing organizations align their respective auditing schemes and checklists with the GFSI. These auditing schemes are then weighed by GFSI against the GFSI Guidance Document. When an organization’s scheme meets GFSI criteria, the scheme is considered certified, and the organization markets its audit and consulting services to the industry as GFSI-compliant.
As of mid-2012, the auditing scheme of nine organizations have been benchmarked: the British Retail Consortium for food processing; the Safe Quality Food Institute for agriculture and food processing; CanadaGAP (Canadian Horticultural Council On-Farm Food Safety Program) for agriculture; the Food Safety System Certification 22000 for food processing; the Global Aquaculture Alliance for aquaculture; GlobalGAP for agriculture; the Global Red Meat Standard for meat processing; International Featured Standards for food processing; and PrimusGFS for agriculture.
A full evaluation and update of the GFSI Guidance Document is scheduled to occur at least every four years, and there are plans to increase the GFSI scope to include retail and catering, warehouse and distribution, food transport, food processing equipment, food brokers, food safety services, and animal feed.
Facilities that “pass” an audit by a GFSI scheme owner can represent themselves as certified in the audited scheme, and the certification is accepted by most retailers worldwide as a basis for confidence in the facility’s food safety practices. Once certified– in the absence of major safety problems–the facility retains its certification for a period of one to three years, depending on the audit scheme, and thereafter a re-audit is executed to determine the facility’s continued certification status.
Retailers who endorse GFSI schemes typically agree to accept a benchmarked certification audit in lieu of their individual private audit of a supplier. Seven retailers originally endorsed GFSI: Carrefour, Tesco, ICA, Metro, Migros, Ahold, Walmart, and Delhaize. Retail giant Walmart became the first nationwide U.S. grocer to adopt GFSI. Food suppliers who were not certified in a GFSI scheme by the end of 2009 faced losing Walmart as a customer.
In most ways, GFSI-benchmarked audit schemes mandate higher standards for safety than are required by individual governments–even governments in developed countries. At their core, GFSI-compliant schemes are based on hazard analysis and critical control points. Yet they raise the bar higher than HACCP, and, in many instances, also cover food quality programs. The essence of GFSI-benchmarked schemes is prevention; preventing safety (and often quality) problems before they can reach customers.
Most facilities transitioning to GFSI-based programs need to upgrade their product safety programs and process controls. A farm or facility that needs to become certified in a GFSI scheme must complete upfront work that can take months. It is not unusual for a facility to engage in capital improvements and construction projects in order to meet a GFSI-benchmarked standard; location of windows, doors, roofs, traffic patterns, and air flow are scrutinized closely in the certification audits. Likewise, GFSI certification also requires a degree of documentation, evidence of worker competence, and product traceability that is not present in traditional food safety audits (such as a robust supplier monitoring program, an internal audit program, and regular senior management reviews of food safety).
Because GFSI-certified facilities adhere to rigorous prevention programs, you might expect these facilities to experience fewer food recalls than facilities that are not certified. Accordingly, a review of public reports of food recalls shows how well the certified facilities support GFSI goals to ensure confidence in the delivery of safe food. Our work for this article tallied food recalls in the United States during a 12-month period, offering an early view of the impact of GFSI certification.
Retail Gaint Walmart became the first nationwide U.S. grocer to adopt GFSI. Food Suppliers who were not certified in GFSI scheme by the end of 2009 faced losing Walmart as a customer.
We extracted information from FDA recalls, market withdrawals, and safety alerts, its weekly enforcement reports for human food, and from the USDA’s food safety and inspection service list of recalls and alerts for the period between May 1, 2011 and April 30, 2012. This provided information about the following:
- Number of recalls;
- Recalling firms;
- Dates of recall;
- Reasons for recall; and
- Amount of product recalled.
Some reports indicated that the facility making the recall differed from the facility where the recalled product was manufactured.
For each recall, we queried the public databases of GFSI scheme owners to determine whether the recalling facility or manufacturing facility was certified on the date(s) of the recall and, if so, the scope and date range of the certification.
Of the nine GFSI-benchmarked audit schemes, we found six in use for certification in the United States during the period studied. The schemes are British Retail Consortium, London; Safe Quality Food Institute, Arlington, Va.; Food Safety System Certification 22000, Gorinchem, The Netherlands; PrimusGFS, Santa Maria, Calif.; International Featured Standards, Berlin; and Global Aquaculture Alliance, St. Louis, Mo.
Some of the facilities issuing recalls were also certified by alternate schemes not benchmarked by GFSI, such as the California Leafy Green Products Handler Marketing Agreement, which sets safety standards for agricultural practices used in the production of leafy greens.
We located 342 recalls logged by the USDA and FDA between May 1, 2011 and April 30, 2012, with 265 recalls from the FDA and 77 recalls from the USDA. These included finished product recalls as well as those at the ingredient level in which more than one finished product and/or manufacturer was affected by the same safety event(s).
The most common reason for recall, which included 118—or 35%—of all recalls, was mislabeling or non-labeling of allergenic ingredients. This number increased to 37% (127) if recalls for undeclared sulfites were included. Allergen recalls were followed in frequency by recalls for Listeria monocytogenes (64 or 19%), Salmonella (48 or 14%), and foreign material (21 or 6%). Recalls caused by foreign material were mostly due to metal or plastic found in the product (Table 1).
Facilities certified in one of the GFSI benchmarked-audit schemes were associated with 73 recalls, or 21.3% of the total. In 12 other recalls, (3.5%), the recalling facility or retailer was not GFSI certified, but the supplier of the recalled product was. In all, GFSI-benchmarked facilities were involved in about one-quarter of recalls, either as the recalling firm or the manufacturing firm. In four of the recalls, both the recalling facility and the manufacturer of recalled goods were certified in one of the GFSI-benchmarked schemes. There were 18 recalls in which the notice and/or enforcement report listed a non-U.S. facility as the site where the recalled goods were produced. None of the affected foreign sites was found to be GFSI certified.
Of the 127 recalls related to labeling of allergens and/or sulfites, 35 (27.5%) were associated with GFSI-certified facilities. When all pathogens reported were combined, there were 143 food recalls (41.8%) associated with the presence of specific pathogens; of that number, 37 pathogen-related recalls (26.2%) were associated with GFSI-certified facilities.
SQF was the dominant GFSI certification scheme among U.S. suppliers during the period evaluated. The SQF supplier database listed approximately 2,500 certified sites in the U.S.; the BRC database listed approximately 1,200 certified sites in the U.S.; the FSSC database listed approximately 300 sites in the U.S.; and the IFS listed 73 sites in North America (Canada included). We were unable to determine the number of certified site for PrimusGFS because that certification scheme’s public database lists sites by crop, which means that one site may have more than one certified crop and more than one entry in the database.
The number of certified sites associated with food recalls that had SQF as their scheme was higher than the number for sites using other schemes, because many more U.S. sites use the SQF certification than other schemes. However, the proportion of certified sites involved in recalls was relatively constant among the GFSI certification schemes where data was available. Approximately 2% of the estimated certified base was associated with recalls for SQF, BRC, and FSSC.
In this evaluation, about a quarter of the pathogen- and allergen-related food recalls in the United States during the period studied were associated with a facility that was certified in one or more of the GFSI-benchmarked schemes. At present, it is difficult to evaluate with certainty and precision just how the GFSI has impacted the number or extent of food recalls. Public data sources provide limited visibility of relevant data, and a true comparison would have to be done on a company-by-company basis, with evaluation of number and type of pre- and post-GFSI certification periods within each individual organization. The data presented here offer an early look, providing a baseline for future analysis of trends. If GFSI prevalence increases and the rigor of certification audits is sustained, we expect to see a decreasing trend: more GFSI certifications and fewer recalls overall in the facilities that adhere to GFSI-benchmarked schemes.
Susan Moyers, PhD, is a consultant and trainer in food quality and safety. Her experience spans more than 20 years in industry and academia. Dr. Moyers provides training, consulting and troubleshooting services to facilities large and small, including processing plants, supermarkets, restaurant chains, dietary supplement manufacturers, and health care institutions. She can be reached at firstname.lastname@example.org.