Does the ISO/HACCP/HARPC Always Make Sense?
Over 1/5 of the food production in the United States is grown by small family farms. These operations are often only family members as workers or a couple helpers at most. You can find the same thing happening now in the craft food movement. Can you assure safe and quality food at this level of production with the same tools used on an operation with 20, 200 or 2,000 management and field staff?
Although a process based on analysis, documentation and monitoring may seem pretty simple to understand, at an implementation level, the concepts often do not translate well. The goal of any quality control system can be lost in the effort to maintain the system. Why build a bridge that will carry an elephant to a place it does not need to go? Give me a plank to just get me there.
A neighbor of mine does quality control for the aerospace industry. They work with small engineering and machining companies building highly critical parts of which very few are needed. While doing audits of ISO certified firms, it was discovered that all the compliance costs had gone into the documentation to comply and there was no understanding of how to apply it to the process of building parts. They have since switched to process audits that look to see, no matter how simply documented, if the controls are implemented in the process.
The space industry faced the same issues small farms and craft foods face in doing critical tasks whether rocket parts or safe food. A GFSI farm audit is going to have 300 questions whether you have 2 employees or 2000 employees. Do you really need to have an SOP template so Ma can tell Pa to wash his hands before heading out to the packing shed?
Rather than the scale determining when FSMA implementation should take place, it should determine how it is implemented. This would also mean having a scaled approach to GFSI or Food Safety audits in the checklists. I have yet to meet an operator that understood the HACCP Plan or Risk Assessment left with them by a previous consultant. Since 95% of the risk issues are common in either food production or food processing, it would be better to assist small operators with understanding and implementation rather than dump materials on them for 300 control points as a further barrier to implementation.
The industry ASC is part of is on a constant steeplechase to help clients meet the increasing audit standards often at the cost of well-implemented practices. Perhaps it is time to stop and look at the models we are building for documented compliance and develop a model focused on effective implementation at any scale.
C. Lawrence