Water Matters
Product Certification, GFSI, HACCP and Training
The DNA of Beverage Quality
F
or decades manufacturers, retailers and By Chris Dunn
trade organizations have promoted
voluntary compliance of government food safety standards;
initial focus was on product quality.
More recently, global retailers and manufacturers have
been working to find common ground with schemes that focus
on the underlying quality of management systems involved in
the production of food. Better documentation correlation and
more consistent methods with less defects and better quality
are essential.
The double helix of DNA1, with its two strands connected
together for strength, represents a
model to join quality of product with
quality of management systems. Haz-
Quality of
ard analysis and critical control points
(HACCP2), training and inspection
product
(verification) become the links and
together form a ladder for continually Product
improving beverage quality. certification
and listing
in public
First strand: product
database
certification
Product certification started about
25 years ago. Non-profit organizations,
such as NSF International, began to Physical
set consensus standards built around
inspection
voluntary guidelines. These were de-
of bottling
signed to provide checks and balances
plant plus
inside the manufacturing process,
corrective
which could then be verified through
actions to
laboratory testing and plant audits.
rectify any
This type of standard is specific to a
non-
product and validates performance
conformances
against governmental organizations
requirements such as the US FDA,
Health Canada or European Food
Safety Authority (EFSA).
The foundation of product cer- Laboratory
tifications is transparency of what is testing of
required and the independence of source and
the certifying entity. Standards are finished
validated by food safety expertise, product
scientific method, objective observa-
tion, quantitative measurement and
physical inspection to verify compli-
ance. The foundation is built on the Review of
verification of a functioning HAACP product
plan, physical plant inspection and labels
laboratory testing of the product. Once
the benchmark is achieved, there are
re-inspections and re-testing at least Desk audit
once annually. of HACCP
Governments recognize qualified plan
third-party standards. They know that
Water Conditioning & Purification
a product obtaining certification has a work-
ing HACCP plan supported by prerequisite
programs built around good manufacturing practices (GMPs),
sanitary and standard operating procedures (SSOPs and SOPs).
They also know a physical audit has been conducted and
laboratory tests have been performed to verify product safety.
While third-party standards are not a replacement for government
oversight, they provide public affirmation of compliance. Some
regulators reference third-party standards as guidance to people
asking for help to meet government regulations.
Retailers value product certification because of the brand
protection it offers their private label
Quality of products. Because retailers often do
management not have the technical expertise in all
product categories, their risk man-
systems agement strategy can use published
standards to ensure their co-packers
are fully complying with all the regula-
SQF
tions via third-party verification.
BRC
Manufacturers appreciate prod-
IFS
FSSC22000 uct certification as support in helping
them achieve ‘best practice,’ as well
as demonstrate to their customers
HACCP
they have world-class quality that
has been validated by an independent
Physical third party.
inspection Faced with a plethora of choices,
of bottling a certification mark on the product is a
plant that key factor in consumers choosing one
indentifies brand over another. Knowing that a
industry certified product has met all applicable
non- requirements provides peace of mind
conformances for consumers.
Trade associations, such as the In-
ternational Bottled Water Association
Training (IBWA), have also helped to advance
bottled water quality by promoting
Verification their Model Code and plant inspection
of system programs, which impact the majority
implementation of the US bottled water industry. NSF
in all has been providing inspection and
processes audits of IBWA member facilities since
1984. About half of the US states use
IBWA Model Code as the basis for their
Inspections own regulations.
Desk
audit Second strand: Global Food
of systems Safety Initiative
Global sourcing and distribution
HACCP of food and beverages has increased
Desk audit the complexity and interconnection
of HACCP required to produce consistency and
plan uniformity. Retailers have in the past
set their own criteria, especially for
October 2009
their own private-label brand and have done their own inspec-
tions. While this benefited some individual retailers, it also
resulted in redundancy.
Trying to reduce the negative impact on cost and efficiency,
an organization called the Food Business Forum (www.ciesnet.
com) took action. This forum was founded in Europe by seven
global retailers (Carrefour, Tesco, Metro, Migros, Ahold, Wal-Mart
and Delhaize) and supported by major manufacturers like Kraft.3
This group sought a solution that would reduce redundancy,
while assuring members consistent, high-quality products.
The retailers chose their focus to be on the process
(management systems) rather than individual products. This
would result in a program that would be as applicable to
fresh produce as to canned soup. Better systems would cause
manufacturers to adopt better controls and thus improve
quality.
The forum harmonized minimum standards to ensure
competing programs delivered the same basic requirements.
Under the banner of Global Food Safety Initiative (GFSI4), four
schemes now exist and are deemed interchangeable: 1) British
Retail Consortium (BRC5); 2) Safe Quality Food (SQF6); 3)
International Food Standard (IFS7) and 4) Food Safety System
Certification 22000 (FSSC220008).
Each of the schemes covers all food and beverage categories,
versus a specific product. They also promote systemization and
documentation that guides a manufacturer in any food category
to implement and manage a food quality and safety program
focused on processes, measurement and documentation. These
systems support complex product formulas and manufacturing
processes, as well as upstream and downstream supply chains
that often span the globe.
Similar to product certification, management systems are
built on a HACCP foundation. With the intensity of processes
and documentation, these programs start with a management
commitment to provide the resources, as well as sign-off on
system documentation. There is often linkage to corporate IT
systems to collect and manage data.
These are complex programs that require in-house experts
to implement and create the documentation. After everything
has been systemized and documented according to the program
guidelines, an approved auditor (certified by the GFSI program
itself) does a desk audit of all documents and systems.
After verifying the systems and documents are in place,
a verification of the system implementation takes place. This
includes the physical plant inspection, as well as document
review and usage.
Any non-conformances are noted and must be corrected
before certification is granted. Annual follow-up visits are
required to verify ongoing compliance.
What are the differences?
There are many points of difference on how each strand
approaches quality. Some are defined by their nature—GFSI
programs are generic, meaning the same manual and checklist
apply to all categories of food.
There are references to industry practices, but no product-
specific requirements outlined. Product certification is tailored
specifically to the product itself, thus it is naturally more
proscriptive and clear.
In lighting for a plant, as an example, GFSI would say there
shall be adequate lighting tied to all types of activity performed.
Product certification would be much more specific stating that
there shall be 50-foot candles of light in product areas and 20-foot
candles elsewhere.
The differences are driven by the nature of the programs—
Water Conditioning & Purification
one tied to a specific product, the other tied to the systems generic
to any food plant.
Common bonds
The underlying principle that both approaches share is
HACCP.
Both systems place a heavy reliance on training. As part
of product certification, a bottler is required to have provided
HACCP, GMP, Food Security and Employee Hygiene Training
to all production workers.
Both approaches rely on inspections to verify implementation
and efficacy of the programs. Product certification will devote
more of the inspection to GMPs. The system audit will view the
GMPs in the context of reviewing documentation.
Combined effect
When you use HACCP and training as connectors of the two
strands and implement both programs, you form the spiraling
double helix of beverage quality DNA. While symbolic, it is also
a practical image of a ladder, which implies the best quality is
achieved by continuously climbing upward.
As with real DNA, remove one of the strands or even
one of the connectors and one is incapable of achieving best
practice. Large operations often need both. The more complex
an operation, or the more varied the products become, systems
take on increasing importance.
Early proponents of GFSI once thought that GFSI was going
to be the end-all solution. It is now of paramount importance
to have product-specific programs, such as those found in
NSF’s bottled water certification program to complement GFSI,
HACCP and training initiatives. The best approach, therefore,
is to infuse the manufacturing process with the strongest DNA
possible so that it can replicate itself in the form of zero-defect
product quality.
References and footnotes
1. National Human Genome Research Institute: http://www.genome.
gov/25520880.
2. Hazard Analysis and Critical Control Points (HACCP) is a systematic
preventive approach to food safety and pharmaceutical safety that ad-
dresses physical, chemical, and biological hazards as a means of preven-
tion rather than finished product inspection. http://en.wikipedia.org/
wiki/HACCP.
3. The Food Business Forum started in 1953 and now has over 400 mem-
bers in 51 countries. www.ciesnet.com.
4. The Global Food Safety Initiative (GFSI) coordinated by CIES – The
Food Business Forum, was launched in May 2000
5. BRC first introduced in 1998; now in Fifth Edition, published January
4, 2008.
6. SQF launched August 2003 by SQFI; now in Sixth Edition, published
in August 2008.
7. IFS started in 2003; now in Fifth Edition, published August 5, 2007.
8. FSSC22000 was approved by GFSI in June 2009 and will replace Dutch
HACCP.
About the author
S Christopher Dunn is General Manager of the Beverage Quality Pro-
gram for NSF International, a public health and safety organization,
based in Ann Arbor, Michigan. His program offers testing, auditing
and certification of beverages including bottled water, natural mineral
waters, flavored and functional beverages and packaged ice. Dunn is
a 30-year veteran of the beverage industry. For over a decade, he has
been involved with bottled water (IBWA) and packaged ice (IPIA) trade
associations and is certified CWS-I by WQA. Dunn can be reached at
cdunn@nsf.org.
October 2009