ISO 22000: Market Decides: Top Or Flop?
Wouldn't it be nice to have one global food safety standard? ISO 22000 could be the one. But what are its chances of making it in the real world?
ISO 22000 originated in Denmark. The Danish Standards Association recognized that there is an ISO standard for quality management, ISO 9001:2000, but that there is no equivalent for food safety.
As a result, many countries have developed national, voluntary standards—such as HACCP in the Netherlands—each with their own interpretation and related documents, for example for auditing bodies. Unquestionably, this situation has led, and is still leading, to confusion. Furthermore, it makes it very hard for quality managers to assess the food safety performance of their suppliers. Another obstacle in the present-day situation is that there is no food safety standard for every actor in the food supply chain. ISO 22000 has the ambition and—according to ISO—the reach to do this.
Cor Groenveld, global product manager Food at Lloyd’s Register, describes ISO 22000 as a pyramid. “The base of the pyramid is made up of Good Practices. These are prerequisites for the safe production of foodstuffs. On top of that, there is the HACCP-program which enables manufacturers to control food safety hazards. The top layer includes management system elements, which should demonstrate that the standard holder has incorporated food safety in his management structure [policy, objectives, dedicated managers, improvement programs, etc.]”. Two thirds of the pyramid—the top two layers—are based on existing standards: the HACCP-part is based on the Codex Alimentarius version and the management system on the ISO 9001:2000 standard.
As ISO 22000’s top layers—management system and HACCP—are relatively common in the European food and drinks industry, Groenveld expects a relatively smooth transition. “Companies that carry ISO 9001:2000 and HACCP, already cover 80 to 90 % of ISO22000. As the management system of ISO 22000 is based on ISO 9001:2000, the two standards can easily be integrated. All in all, the overlap and synergy with an existing standard should facilitate the penetration of the new ISO standard.”
Communication Naturally, a smooth transition would be nice for potential users of the standard. However, the standard should also offer them benefits compared with the pre-ISO 22000 situation. According to Jacob Faergemand, project leader of the ISO 22000 working group, there are several advantages. “To mention a few: companies will be able to exert a more efficient and dynamic control of food safety hazards, documentation will improve and there will be less post-process verification. Because of the coupling between the HACCP program and the prerequisite programs, the latter will be managed more systematically.” Paul Mathot, technology and food safety manager of NZO (the Dutch Dairy Association), representative of CIAA (Confederation of Food and Drink Industries in the EU) in the ISO 22000 working group, says “The unique element of this standard is that it introduces a common management system for all industries in the food chain, which secures the food safety at the end of the chain. For instance, it requires communication on food safety hazards across the supply chain, so that the hazards are actually controlled on the right spot in the chain. History has taught us that many food crises originate way up in the supply chain, for example, in the production of raw materials for feed. For feed suppliers, a certain process such as a drying method may not entail a hazard for the feed quality as such. However, if that process ultimately leads to dioxins in pork, this would be a serious food safety hazard. Therefore it is important that there is a system that allows for systematic communication so that all actors understand the risks of their production activities for the chain as a whole.” Market decides Apart from these intrinsic benefits, the biggest benefit of ISO 22000 would be that it makes the food safety standard landscape less complex. At the moment, food manufacturers—especially private label suppliers—have to maintain several standards simultaneously. This is a costly affair, and a uniform standard would bring down auditing and certification costs. However, in the real world these benefits do not necessarily lead to large-scale acceptance of the standard throughout the supply chain. The acceptance of potential users will not be the deciding factor whether ISO 22000 will make it or not. Basically, the market—or the customer if you will—is going to decide. Because of their position at the top of the food chain, supermarket retailers will play a decisive role. When asked, several supermarket retailers declined to comment on ISO 22000. They are following the issue “with interest”. It appears that most retailers “hide” behind GFSI, the Global Food Safety Initiative, which in itself aims to harmonize retail food safety standards. One of the main concerns of GFSI at the moment is that ISO 22000 does not facilitate on-site inspections. GFSI director Hugo Byrnes: “We have to see whether there is a solution for this issue, as paper inspections are not sufficient for our members.” Tailor-made standards According to Groenveld, the Dutch ISO branch has proposed the development of technical specifications that cover specific Good Manufacturing Practices. “This in turn would meet the demands of retailers.” However, Paul Devos, senior quality consultant at Amelior, thinks that, despite possible amendments, retailers will remain hesitant to demand or accept ISO 22000 from their suppliers. “Their own standards, for example BRC Global or IFS, are more tailor-made to their operations. Furthermore, in the case of British retailers, the due diligence aspect is better covered by BRC.” Devos continues: “As for now, the base layer of the ISO 22000 pyramid—the GMP or prerequisite programs—is too vague. Given the broad scope of ISO 22000, ranging from feed to packaging supplier, that is no wonder. Therefore, retail associations, such as GFSI, have requested more specific instructions for their suppliers. Admittedly, the current standard has been amended to include more specific instructions on a micro level, for example, regarding cleaning, working attire, etc.” Added cost So much for retailers, but what about the industry? Paul Mathot, voicing the opinion of the industry via CIAA, is positive. “It is the first food safety standard with a global reach for each and every actor in the food supply chain.” That is all very nice, but individual manufacturers seem to be more hesitant. Roy Kirby, manager in Unilever’s safety and environmental assurance centre, says: “At the moment, I do not see any benefits for our company, as our food safety program is doing its job. If we were to switch to ISO 22000, this would mean that we would have to rewrite our program. As there is already a huge overlap between what we do and ISO 22000, this would lead to unnecessary costs. Therefore, the element of substantial equivalence should be introduced which allows for a certification without the rewriting process.” As for Unilever’s suppliers, Kirby does not see a role for ISO 22000. “We demand HACCP from our suppliers. We do not see any benefit in replacing this requirement with ISO 22000, which would bring added cost to our suppliers.” Udo Spiegel’s reaction - director of R&D and QA at Dr. Oetker – is equally reserved. “So far we only have a draft of the standard, and we have not yet decided to evaluate whether the new standard might be of advantage to us. We will wait until a final document is available. Certainly the cost of the certificate, the dealings with the certifier and the administration of the standard is not very favorable.” Goat code If a multinational of the likes of Dr. Oetker objects against the paperwork, what would small- to medium-sized businesses (SMEs) think about a possible ‘administration overload’? Bob Salmon of UEAPME (the European Association of Craft, Small and Mediumsized Enterprises), the self-acclaimed European SME umbrella organisation: “ISO 22000 will be beyond the means of most of our suppliers. Roughly 90 % of Europe’s food businesses have less than ten employees. This means that CEOs are also involved on an operational level. Furthermore, there are no designated managers, as each employee performs several tasks. Furthermore, these small companies do not have the time or the money to deal with complicated paperwork, which takes up too much time.” According to Mathot, ISO 22000 offers the possibility to develop a sector-specific code —say, for goat farmers—based on a ‘collective’ risk analysis. “This code would only contain specific guidelines that are relevant for that particular sector. It would also avoid the need to keep an extensive administration.” Marketing machine All in all, ISO 22000 has the potential to make it to a global standard. As David Rose, technical director of EFSIS and closely involved in the genesis of ISO 22000, explains: “ISO has a global presence. Something that cannot be said of the other standards. This means that an ISO standard can be audited anywhere in the world. Other standards do not have such an extensive ‘reach’.” Rose continues: “Overall, the manufacturing industry and regulatory bodies, for instance, in the US and Asia, seem to be in favour of ISO 22000.” Devos adds: “ISO 22000 will need a breakthrough, for example a major supermarket retailer that imposes this standard on its suppliers. Other actors—I am afraid - are not powerful enough. Furthermore, do not underestimate the ISO marketing machine.” For now, there is only a minute chance that a powerful retailer will make ISO 22000 ‘the standard’. On the other hand, one should not expect miracles. In the food safety standards arena, which is highly political, one cannot expect a warm reception for a threatening newcomer. ISO 22000 needs at least five years to prove itself. Until that time, good luck. More Information www.iso.org
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