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3 The Complexities of Food Safety and Some Strategic Approaches Being Taken
Pages 43-64

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From page 43...
... Shifting gears a bit, rather than revolving around the complexities of the global nature of the food supply chain, the second presentation of this session, Russell Flowers's Technological Improvements in Outbreak   Ms. Janet Beauvais is the Director General of the Health Canada's Food Directorate.
From page 44...
... He pointed to plant facility lay-out as an area where improvements could be made. Returning to the global theme, the third presentation of the session, Julie Caswell's Roles and Responsibilities of Industry and Government in Managing Relationships with Global Food Suppliers, revolved around the reality that risk management for food safety is a complex endeavor not just because of the inherent risks associated with food production but also because of the diverse nature of our international food supply chains.
From page 45...
... While the specific implications of globalization for food safety are uncertain and continually evolving, Bracket emphasized that one thing is certain: globalization of the food supply means that all countries must share responsibility for food safety throughout the entire food supply chain, from producers to consumers. Ensuring that our food products are safe requires every component of the global food supply system be functioning the way it is intended to function.
From page 46...
... Not having confidence in the global food supply means that not only are consumers not trusting food manufacturers or food in general, but they also have less confidence in regulatory and other government agencies and are less likely to react to government advice. Brackett then went on to discuss the nature of the risks being faced -- both what those risks are and why they exist.
From page 47...
... o  need more collaboration between industry and regulatory We agencies so that appropriate risk management decisions can be made down the line rather than companies being afraid to reveal too much information because of the likelihood of fac ing a punitive action or having information shared with their competitors. o  Industry needs to manage the supply chain in a way that they have not done in the past.
From page 48...
... broader focus: The regulatory agencies C need to have the resources and authorities they need in order to do their job. Brackett defined "supply chain management" as "due diligence to assure that products received from suppliers meet required regulatory, legal and contractual standards of safety." He listed several reasons why supply chain management is important: • Legal considerations o Companies must comply with regulations and laws.
From page 49...
... GMA has issued a document, the GMA Food Supply Chain Handbook, published in five different languages (English, Spanish, Mandarin, French, and Russian) , that includes a checklist of things that buyers should expect of their suppliers in an effort to "raise the [safety]
From page 50...
... There are several technologies available for this purpose: •  Traditional technologies for killing pathogens include the use of heat, pH/acidity, sanitizers/biocides and irradiation. •  Newer technologies available for killing pathogens include the use of pulsed electric fields, pulsed light, high power ultrason ics, cold plasma, ohmic heating, UV light, microwave, high pressure, and new biocides acceptable for direct food contact.
From page 51...
... In order to accomplish this, the ideal food plant layout has a separate raw processing area (where all the cutting, sorting, etc., are conducted) , a kill step between this area and the next, and then a separate packaging area (see Figure 3-1)
From page 52...
... In actuality, this is not a common layout; most existing facilities have a lot of back-and-forth movement of product and situations where cooked product that has already gone through the kill step is subject to recontamination. Flowers mentioned that, as Huffman alluded in his presentation on Listeria in RTE meat products, there are ways to manage this problem, but it requires diligence and a redesign of the plant and the process flows.
From page 53...
... • Must be able to provide verification for initial product runs after a contamination event.
From page 54...
... (Flowers noted that while this may seem a biased remark, given his affiliation with Silliker, in fact companies invalidate testing data.) In his final remarks, Flowers emphasized that while new technologies for killing pathogens are being developed and validated, these technologies will not prevent contamination.
From page 55...
... • Second, in most countries around the world, there has been an ongoing shift in the food safety regulatory approach, from a "com mand and control" approach to a more "performance" approach that puts the responsibility for food safety production more directly and strongly on the food business operators themselves and which has led to a rapid development of private standards. • Third, when examining food safety, we are dealing with a very complex and demanding policy space that involves both public and private sector incentives and controls.
From page 56...
... Between these two ends are a range of private/public mixes, including self-regulation, such as the use of industry voluntary codes of practice and farm assurance schemes; informa Options for Public/Private Actions NO INTERVENTION { No government regulation Private controls LEVEL OF GOVERNMENT INTERVENTION SELF-REGULATION { Voluntary private Codes of Practice Farm assurance schemes Retailers' roprietary quality assurance schemes INFORMATION AND EDUCATION { Government assembles and publishes evidence Provides information/advice to consumers "Naming and Shaming" { Government/private partnership in regulation CO-REGULATION Statutory or government-backed Codes of Practice or Action Plans { Government rewards desirable behavior by private or INCENTIVE- voluntary sector BASED Creating market incentives for food safety investments STRUCTURES Liability rules { Prohibition of certain actions, products, and/or processes DIRECT Prescription: process standards (HACCP) , labeling REGULATION Sanctions and penalties Figure 3-2  A spectrum of generic approaches to private versus public involvement in global food safety risk management, as described by Caswell.
From page 57...
... In short, Caswell said, the distinction between public and private regulations is less discrete than often assumed, with most markets having a mix of co-existing public and private safety regulations and considerable interrelationships and dependencies between the two. Knowing which box and specific regulatory approach is being used and whether it is the right approach in any given food safety situation enables us to ask whether we might achieve better results with respect to both food safety effectiveness and economic efficiency if our regulatory approach were different (i.e., if a different mix of public and private roles and responsibilities might be more effective)
From page 58...
... and Integrate Keten Beheersing, and at the international level, the International Food Standards, Safe Quality Food (SQF) 1000/2000/3000 and GLOBALGAP (formerly EUREPGAP)
From page 59...
... Also as shown in Figure 3-3, food safety programs in the United Kingdom and Canada employ a range of public-private mixes but are more   Fearne, A., M Garcia, J
From page 60...
... While the public health risk associated with any situation is always going to be the guiding principle, other considerations would include market risk, governmental capacity to be effective in that area, the scope and comprehensiveness of private standards and trade impacts. Ned Groth commented on how the workshop lacked perspective from an exporting developing country (i.e., exporter to the United States)
From page 61...
... Making the effort to integrate and coordinate public and private parties -- and across countries -- requires a means of capturing the "dynamic ability of private standards to evolve quickly." A good intermediate step might be the development of meta-standards, or industry-wide standards. The individual private parties set the standards; those standards give those companies market power.
From page 62...
... Getting back to some of the specifics of Caswell's talk, another audience member asked to what extent food safety management is really shifting from a "command and control" to a performance or process risk-based system. Or, is the shift from an approach where government issues "command and control" standards to one where the proliferation of private standards has led to a private "command and control" standards?
From page 63...
... The questioner commented that the meat industry has been living with this "dogma" for years and years -- that it is appropriate to conduct a complete clean-up on a nightly basis. But is this an area of food safety regulation that needs to be re-addressed?


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