Food Safety Magazine, October/November 2008

Supply Chain Verification

All food system companies employ some level of quality assurance and supply chain verification—from HACCP plans to a bill of lading. Fewer companies, however, go beyond the one-step forward, one-step back record keeping required under the 2002 Bioterrorism Act to require source identification, quality assurance, food safety, food defense and related requirements from retail to the farm. Having standards is a step forward, ensuring that those standards are consistently met is what supply chain verification really means. At its core, supply chain verification can be thought of as management by objectives brought to bear on a company’s supply chain. The objectives are relatively straightforward:

• All ingredients or products are as in-
tended, with no accidental, inten-
tional or economic adulteration.

• Ingredient or product handling, transportation and processing maintain product quality and safety.

• Every product or input can be rapidly traced back to its source.

These may sound like “food system for dummies” requirements, but it is how the objectives are translated into sensible and verifiable measures of system performance that they form a more robust approach to crisis prevention and preparedness. The extent that a food firm can drive these objectives and, importantly, the performance measures, all the way through their supply chain will dictate how prepared it is to prevent, and if necessary respond to, accidental or intentional food contamination.

Avoiding Adulteration

Wheat gluten, sunflower oil and infant formula economic adulteration events illustrate how quality standards can apparently be met while still exposing consumers to potential risk. The wheat gluten contamination is a particularly challenging example as the product still met the protein content quality standard because the method generally used is an indirect measure of protein content. The Kjeldahl method specified for apparent protein content measures total nitrogen, so the melamine contaminant enabled the product to meet that stan-

dard to the economic gain of the supplier. In some cases, this type of contamination can be anticipated by prior events, but having a quality assurance test protocol that verifies the absence of anything that isn’t supposed to be there isn’t realistic. Until a “Star Trek Tri-corder” is available, having the user of the product verify that their supplier is operating in a manner that will yield the desired product is the only reasonable approach. This includes objective measures of food quality and safety, but it is not limited to those.

Third-party in-spections/audits are invaluable, but not infallible. If a retailer requires the supplier to undergo unannounced third-party audits, they may very well catch any issues before they cause a problem. If that supplier, however, receives input material that is adulterated, then the audit might not find it until the product has quality or safety issues in the marketplace. One frequent concern with audits is their proliferation rather than their absence, with firms having to undergo multiple audits to meet customer demands. There are efforts un-derway to come up with coordinated approaches to supplier auditing to help reduce the burden of audits while increasing their utility. Examples include the Global Food Safety Initiative (GFSI) and GMA-SAFE. Participation in these programs will need to increase, however, to meet consumer expectations on the safety of the food supply while also managing the cost of audits given that GMA-SAFE includes 2,103 plants (five inspected in 2007) and GFSI membership is at 415 companies, with only three in China and over 150 of them retailers.

For something like the wheat gluten contamination, periodically conducting more detailed product analyses could also be part of the program. This is especially true if there is information indicating that there have been problems with that supplier or that type of product in

the past, as was the case with the contaminated wheat gluten. It may also be appropriate to conduct more detailed product analyses if supply situations require sourcing a product outside of a company’s normal supply chain.

Preventing System Failure

The Castlebury, Cadbury and Peter
Pan foodborne illness events are exam-
ples of product processing failures lead-
ing to consumer illness. These represent
a different type of
challenge in that a
supply chain verifi-
cation program,
even with third-party
inspections and re-
lated food safety per-
formance
requirements, may
well not uncover the
issues until the prod-
uct is already in con-
sumers’ hands. From
what has been made
public of the three

events, the challenge here was accepting results from quality assurance as being still quality product, when in fact there was enough unusual data to suggest that a more detailed investigation for potential food safety problems was warranted. When a system is at that point—it has already failed and the consequences are just waiting to roll in. If neither the company nor their supplier emphasizes the importance of food safety and the need to invest in it, efforts are unlikely to yield acceptable results.

In some cases, part of the problem is the cost and reputation penalty of dealing with what may appear to be minor processing or related problems. To borrow from Rudy Guliani’s approach to crime reduction in New York City, if you focus on and fix the small problems that occur regularly (broken windows), you can reduce the possibility of bigger problems in the future (felony crimes). An active supply chain verification program is similar—by identifying and resolving the small quality or other issues that occur randomly, the overall supply chain is increasingly strengthened to avoid food