Global Market Access Restrictions

through Private Standards

P.C. Anil Kumar

Sr. Manager Food Safety & Hygiene
JohnsonDiversey India Pvt. Ltd.
‰ JohnsonDiversey Knowledge Centre

- What are private standards

and their evolution

- Country / Retailers Specific

Standards

- Cost of Compliance, Audits and

Certification

- Challenges – Trade Concerns

- Benefits
 JohnsonDiversey
Solutions
• Floor Care
• Machines
• Kitchen Hygiene
• Dispensing &
Dosing Systems
• General Cleaning &
Disinfection
• Cleaning Utensils
• Fabric Wash
• Food Safety
Consultancy
• Food & Beverage
Hygiene
• Food Safety
Audits
• Personal Care
• Food Safety
• Odour Control Training
• Detergents
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International Standards Other International Courses

¾ GMP / GHP / GLP ¾ Serv-Safe Program – NRAEF, USA

¾ HACCP - NBE & CODEX ¾ CIEH, UK Accredited Program –

(Level 1, 2, 3 & 4 Advanced Food
¾ SQF 1000 / SQF 2000 Safety)

¾ ISO 9001: 2000 ¾ Kitchen Hygiene

¾ ISO 22000: 2005 ¾ Mechanical Warewashing

¾ BRC Standard Food and Packaging ¾ Efficient Laundry Practices

¾ International Food Standard ¾ House Keeping Task Competency

Certificate (HTCC)
¾ Internal Auditor Course
¾ Cleaning Operators Proficiency
Certificate (COPC)

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 What are
Private Standards
• Private standards are country specific or retailer
specific requirements on product safety
• Must be complied as an access to exporting country /
buyer etc
• These standards mostly talk about HACCP, Traceability,
Product and Process management, Site oriented
specific requirements, Senior Management
Commitment etc
• They are some times very specific to the buying country
specific requirements
• Private Schemes range from those developed by
individual firms to collective industry-wide international
schemes ; estimated to be at 400 and rising
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 Ex – Private Standards
Individual firm schemes Collective national schemes
Tesco Nature's Choice Assured Food Standards
Carrefour Filière Qualité British Retail Consortium
Global Standard - Food
QS Qualitat Sicherheit
Label Rouge
Food and Drink
Federation/British Retail
Consortium Technical
Standard for the Supply of
Identity Preserved Non-
Genetically Modified Food
Ingredients and Product
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Collective international
schemes
EurepGAP (Globalgap)
International Food Standard
Global Food Safety Initiative
ISO 22000: Food safety
management systems
Safe Quality Food (SQF)
1000 and 2000
ISO 22005: Traceability in
the feed and food chain
 Goals of the
Private Standards
A common standard with a uniform evaluation system

- To provide brand protection

- Due diligence - to meet legislative requirements

- To promote business improvement and efficiency

- Creation of comparability and transparency throughout

all stages of the supply chain

- Cost reduction for both retailers and suppliers.

- Accreditation of qualified certification bodies and

auditors

•7 To assist in the response to consumer FS concerns

 Why Private Standards?
• Growing demands of buyers.
• Buyers requires more and more
transparency - suppliers RM & FG.
• Different requirements of each buyer
• Suppliers capability to supply a safe
product as per the
•Specification and
•Meets the applicable legislation

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 Evolution of
Private Standards
• Existence in some form for many years,
but major push began in late 1990s

• High profile food safety scares in the

world during mid-to late 1990s. (BSE,
Dioxin crisis, etc)

• Driven by retailer demand for improved

food risk management in light of
• Lower confidence in regulatory agencies

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 Evolution of
Private Standards
• Legal requirements on companies to
demonstrate "due diligence" in the
prevention of food safety risks;
• Growing attention to “CSR" and a drive by
companies to minimize "reputational risks
• "Globalisation" of supply chains
• Global expansion of supermarkets (food
retailing)
• Global expansion of food service
companies
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 GLOBALGAP

9 Primary food producers

9 More and more sector included (e.g.cotton)
9 Still retailer driven

Retailer
Input Authority
Grower Processor Traders Consumer
Food
services

GLOBAL GAP

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 GLOBALGAP
Principles
• Risk prevention HACCP (Hazard
Analysis and Critical Control Point)

• Good Hygiene practice

• Sustainable agriculture:
– Integrated Pest Management (IPM)
– Integrated Crop Management (ICM)

• Continuously improving farming system

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 Risk assessment/
analysis

• Documented Risk analysis ⇒

• Documented (hygiene) procedures (policy) ⇒

• Instructions (how to implement the procedure

on different level) ⇒

• Training (recorded) ⇒

• Verification of implementation (visual,

interview)
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 Retailers Driven

British Retail Consortium (BRC) Global

Standard for Food Safety

International Food Standard (IFS)

 Requirements

BRC
1. Senior Management
Commitment and Continual
Improvement
2. Food Safety Plan - HACCP
3. Food Safety and Quality
Management System
4. Site Standards
5. Product Control
IFS
1. Senior Management
Responsibility
2. Quality Management System
3. Resource Management
4. Production Process
5. Measurements, Analysis,
Improvements

6. Process Control

7. Personnel
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 BRC – FUNDAMENTAL
New

–10 nos
• Senior Management Commitment and Continual
Improvement. (1.0)

• The Food safety Plan – HACCP Plan ( 2.0)

• Internal Audit (3.5)

• Corrective and Preventive Action (3.8)

• Traceability (3.9)

• Layout, Product Flow and Segregation (4.3.1)

• Housekeeping and Hygiene (4.9)

• Handling Reqt. For Specific Materials (5.2)

• Control of Operations (6.1)

• Training (7.1)
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 IFS - KO Requirements
– 10 nos
• Senior Management Responsibility (1.2.4)

• Establish a monitoring system for each CCP (2.1.3.8)

• Personnel Hygiene (3.2.1.2)

• Specifications –RM, Ingredients, Packaging materials (4.2.2)

• Specifications – Finished goods (4.2.3)

• Risks of foreign body contamination (4.9.1)

• Traceability (4.16.1)

• Internal Audits (5.1.1)

• Product withdrawal and recall (5.9.2)

• Corrective Actions (5.11.2)

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 Grading For BRC

Grade Fundamental Critical Major Minor Evaluation Frequency

A 10 or Less 12 Months

B 1 10 or Less 12 Months

B 0 11 to 20 12 Months

C 2 20 or Less 6 Months

C Less than 2 Up to 30 6 Months

Certification Not
D 1 or More 1 or More 3 or More 21 or More Granted

Certification Not
D Less than 2 31 or More Granted

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 IFS - Certificate

Non Conformity Status Action of the auditee Certificate

Total score is ≥ Approved on Send action plan Foundation

75% and < 95% Foundation IFS within 2 weeks of Level
Food level after receiving the
receipt of the preliminary report.
action plan.

Non Conformity Status Action of the auditee Certificate

Total score is ≥ Approved on Send action plan Higher Level

95%. higher IFS Food within 2 weeks of
level after receiving the
receipt of the preliminary report.
action plan.

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 Concerns

Concerns on the content of Private Concerns related to compliance

standards with Private standards
•Multiplication of private standard schemes •Cost of third party certification, particularly
both within and between markets for small and medium-sized enterprises and
farmers in developing countries

•"Blurring" of official SPS measures with •Requirements of some private schemes to

private standards use only specified certification bodies

Relationship of private standards with the •Lack of equivalence between schemes

international standard-setting bodies leading to repetition of certification audits
referenced under the SPS Agreement

•Scientific justification for certain PPM •Lack of recognition of certificates issued

requirements and/or lack of recognized certification bodies
in developing countries

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 Cost of Compliance, Audit
and Certification
• Investment - Buildings and Equipments, Storage,
Hygiene, Temperature controlled facilities, etc.

• At Farm Levels especially small scale growers costs

may be prohibitive for them to enter the chain; like
chemical storage, toilets, changing facilities, etc
upgrading of packing and washing facilities.

• Understanding - requirements of the Standards

• Trained food professionals

• Different Standards by Different Buyers

• Cost of certification - Accredited CB

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 Challenges ???

Among the most difficult requirements or challenges cited by

exporters were:

• Record keeping by processors / producers

• Chemical use verification

• Management of different standards systems and their

compliance

• Certification, in particular for attesting to good manufacturing

practices

• Transforming the mindset of producers, particularly small and

medium producers

27 • Meeting diverse country regulations

 Benefits

•Access to the global value chain, essential for

commercial exports – Trade Creator

•To develop longer term trading relationships;

•Improved efficiency in operations: reduced costs;

better use of chemicals, organization of tasks

•Increased information on proper use and storage of

chemicals decreased negative effects

•Improved worker safety - Proper attire for chemicals,

storage facilities, etc.

•Voluntary self-regulation should reduce food safety

risks for consumers.
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 Thank you

JohnsonDiversey India Private Limited

Contact : PC. Anil Kumar

Mobile : +91 9920110176

Email : pc.anil@johnsondiversey.com

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