Senior Management Commitment

Within a food business, food safety must be seen as a cross-functional responsibility, including activities that draw on many departments using different skills and levels of management expertise in the organisation. Effective food safety management extends beyond technical departments and must involve commitment form production operations, engineering, distribution management, procurement of raw materials, customer feed back and human resource activity such as training. The starting point for an effective food safety plan is the commitment of senior management to the development of an all-encompassing policy as a means to guide the activities that collectively assure food safety. The Global Standard for Food Safety places a high priority on clear evidence of senior management commitment.

The anatomy of private food law

The auditor will audit against the IFS food standard which is divided into two levels plus recommendation on higher level. The chapter ‘Senior Management Responsibility’ deals with the responsibility of the management, the management commitment, the management review and the customer focus. In the chapter ‘Quality Management System’ requirements concerning the HACCP system, the HACCP team and the HACCP analysis are defined. It also contains rules for a quality manual to be applied and the obligation to keep reports and documents. The chapter ‘Resource Management’ addresses personnel issues (hygiene, medical screening) and staff facilities. The chapter ‘Product Process’ is the most extensive one. It considers topics about e.g. specifications for products, factory environment, pest control, maintenance, traceability; GMOs and allergens. The last chapter, ‘Measurements, Analyses and Improvements’, deals with e.g. internal audit, all kind of controls during production steps, product analysis and corrective actions. The requirements for auditors and the certification bodies are strictly regulated. All certification bodies shall have an accreditation against EN 45011 on IFS food.121 Only authorised auditors who have passed a written and oral examination can audit against the standard. The auditor shall have professional knowledge of the IFS food. The auditors can only audit against their competence in a certain sector (at least 2 years professional experience in the specific sector or at least 10 audits in this sector). Finally, auditors who comply with these requirements shall only work for one IFS certification body accredited for auditing against the IFS food.122

3.21 SQF

Safe Quality Food (SQF; now based in Arlington, USA) is an Australian initiative. Taking over this system seems to have been the American answer to the mainly European initiatives described above.

Besides food safety, SQF focuses on product quality and stimulation of improvement strategies. The main goal of SQF is to control the whole chain. However, SQF believes that one standard does not work for all companies in the chain and that most other standards only work for big companies. Most procedures associated with the standards are considered too elaborate and laborious for small companies. So SQF developed two different norms, the SQF 1000 and the SQF 2000. The SQF 2000 Code was developed in consultation with food industry and quality professionals. HACCP guidelines, as developed by the Codex Alimentarius Commission, form the basis of the Code. Unlike other well-recognised quality systems like BRC, HACCP

121 _{Again an example of interconnected private schemes as discussed above.}

122 _{The question if such requirement is compatible with competition law (Article 81 EC Treaty) is outside} the scope of this chapter.

123 _{The information for this section has been taken from the SQF 2000 Code 6}th _{edition issued August} 2008 (and update July 2010) and the SQF 2000 Certification Trade Mark rules for use 7th _{edition amended} November 2005. See also http://www.sqfi.com.

and ISO 9000,124 _{SQF combines a management quality system, like ISO 9000 and} a food safety system (HACCP) with requirements for tracking and tracing. Besides the Critical Control Points (CCP) for food safety, Critical Quality Points are also identified, which makes SQF an integrated system.

The SQF codes (in particular the 1000 and 2000 Code) provide the food sector (primary producers, food manufacturers, retailers, agents and exporters) a food safety and quality management certification program that is tailored to its requirements and enables suppliers to meet regulatory, food safety and commercial quality criteria in a cost effective manner. In 1994 the Code was developed and pilot programs implemented to ensure its applicability to the food sector. It was circulated in draft form for comment to experts in quality management, food safety, and food regulation, food processing, agriculture production systems, food retailing, food distribution and HACCP.

The Food Marketing Institute (FMI) acquired the rights to the SQF Program in August 2003 and has established the SQF Institute (SQFI) Division to manage the program. The SQF 2000 Code is recognised by the Global Food Safety Initiative125 as a standard that meets its benchmark requirements.

The SQF 2000 Code can be used by all sectors of the food industry. The Code is a HACCP based quality management system that encapsulates NACMCF126 _and CODEX HACCP Principles and Guidelines, proven methods used by the food industry to reduce the incidence of unsafe food reaching the marketplace (Textbox 3.7). It is designed to support industry or company branded product and to offer benefits to suppliers at all links in the food supply chain.

The SQF 2000 Code enables a supplier to demonstrate that they can supply food that is safe and that meets the quality specified by a customer. Certified SQF 2000 suppliers receiving raw materials from suppliers who have implemented the SQF 1000 Code can ensure that, through these complimentary systems, product is traceable from the producer to the consumer.127

The SQF 2000 Code also provides a mechanism for the food sectors of developing countries seeking to effectively enter the global food market to implement a management system that addresses their needs and the needs of their customers.

124 _{On quality management in general. See here after section 3.22 for ISO 22000 on food.} 125 _{Discussed in section 3.23.}

126 _{National Advisory Committee on Microbiological Criteria for Foods.}

127 _{Here we find an example where a private scheme goes beyond compliance. Unlike EU food law,} traceability is not mandatory in US food law.

The anatomy of private food law

Textbox 3.7. SQF 2000 on HACCP (edition 6 August 2008, amended July 2010).