Sherwin Gardner is a Senior Vice President for Science and Technology of the Grocery Manufacturers of America, Inc.
Food industry's view of food control
Setting and implementing food standards
Industry's efforts to ensure quality
Communication between industry and consumers
Consumers have a right to expect that the foods they purchase and consume will be safe and of high quality. They have a right to voice their opinions about the food control procedures, standards and activities that governments and industry use to ascertain that the food supply has these characteristics. While consumers, governments and others play an important part in ensuring food safety and quality, in free-market societies the ultimate responsibility for investing the physical and managerial resources that are necessary for implementing appropriate controls lies with the food industry - the industry that continuously oversees the manufacture and processing of foods, from raw ingredients to finished product, day in and day out.1
1 Although in the broadest sense the food industry encompasses all those who are involved in growing, processing, manufacturing or distributing food, from the farm to retail shops and restaurants, this article focuses on manufacturers of packaged food products who have clearly identified products and a long history of outreach to consumers.
While this is true, private enterprise recognizes that its success - measured in terms of profitability - is completely dependent on consumer satisfaction. A reflection of consumers' satisfaction is their continuing purchase of the same products. Food manufacturers and marketers thus have an investment in their product identities (brand names) that they naturally wish to protect. It is in their interest, therefore, to establish and administer the controls that ensure that their products do indeed meet consumer expectations of safety and quality.
The food industry takes a broad view of the term food control, which includes a large number of factors such as:
· safety - setting standards for toxicological and microbiological hazards, and instituting procedures and practices to ensure that the standards are achieved;
· nutrition - maintaining nutrient levels in food ingredients and formulating foods with nutritional profiles that contribute to consumer interest in healthful diets;
· quality - providing sensory characteristics such as taste, aroma, palatability and appearance;
· value - providing characteristics of consumer utility and economic advantage, involving attributes such as convenience, packaging and shelf-life. Some of these factors, such as value, are exclusively in the domain of industry and consumers; while others, such as safety, are shared interests of government, industry and consumers.
At the heart of all food control activities is the establishment of safety, quality and labelling standards. These should be established on the broadest possible scale, in the recognition that food production and marketing is truly a global industry. Governments and intergovernmental organizations such as the Codex Alimentarius Commission have the principal role in establishing certain food control standards. It is the role of national governments to establish uniform safety standards so that
· all consumers receive equal levels of protection;
· all food producers, whether domestic or foreign, are equitably treated through application of the same levels of safety;
· consumers are informed about the standards of protection that are being applied.
In establishing safety standards, it is important that governments allow industry, the scientific community and the public to contribute information and ideas. Standards and guidelines should be sufficiently flexible to meet the needs of changing technology. At the same time, governments should apply those controls that will assure real and meaningful safety benefits rather than merely perceived benefits.
Any safety standards that are developed have real costs for governments, industry and consumers. Governments bear an obligation to monitor and enforce safety standards. Imposing stringent standards usually increases the government's need for resources to enforce those standards; therefore standards must be carefully set to take enforcement costs into account. Industry bears the primary responsibility for implementing safety standards and must invest the resources such as staff time, systems, training and equipment required to put the standards into practice. Ultimately, consumers will pay the costs for food safety standards both through taxes to pay for the government control authorities' activities and through food prices, which must reflect all the costs of production, including the cost of quality assurance.
Control of food safety and quality encompasses a broad number of factors, and governments must carefully select the areas in which they will set standards. In particular, quality includes attributes of food that are market concerns rather than public health matters. Governments should focus their attention and resources on the public health aspects of quality and on those market-related aspects of quality and labelling that will protect consumers against fraud and misleading claims.
Governments have three additional responsibilities related to the establishment of food controls. First, they should conduct research into testing and evaluation methods for determining the safety of food ingredients and processes. Governments need to have a good research base because food controls should only be imposed on a sound scientific basis. Second, governments need to audit industry performance to ensure that companies are complying with standards and that standards are being uniformly applied. This involves training inspection personnel so that they have a good understanding of the technologies and processes involved, as well as conducting inspections in an even-handed and fair manner. Third, governments must communicate with industry and consumers about food controls. It is important that all affected industry members know their obligations so that they can comply. It is also important that consumers know what steps are being taken on their behalf to prevent misconceptions. Further, consumers make a contribution to food safety in handling food after purchase and need to be informed about proper procedures. Consumers and industry must have an opportunity to raise questions and comment about the appropriateness of food control standards. In those areas in which governments exercise premarket approval,2 this should be done in a timely manner in order to facilitate the application of new technology.
2 In the United States and a number of other developed countries, food ingredients that are regulated as food additives, e.g. preservatives, emulsifiers and colours, require government approval before they may be used in foods. The manufacturers of such food additives must submit scientific data that demonstrate that these;: substances are safe. The standards of safety are established by laws and regulations and include considerations of various types of toxicity, ranging from carcinogenicity and reproductive effects to effects on digestion. According to Title 21, Part 170 of the United States Code of Federal Regulations, a substance may be termed safe when there is "a reasonable certainty in the minds of competent scientists that the substance is not harmful under the intended conditions of use". Once a food additive is determined to be safe, it may be used in any food application for which it is approved.
Because of their necessarily intimate involvement with the science, technology, logistics and management disciplines required to make the food supply system work, food manufacturers must be involved in the standard-setting process at both the national and international levels. They are obliged to lend their knowledge of the food supply system to this process to help guarantee its efficiency and effectiveness and to ensure that it results in a supply of safe products. This involvement is beneficial to consumers and governments as well as to industry, and this exchange of information should be facilitated by governments.
To provide safe products, food industry management requires an organized way of defining and controlling the relationships of critical factors in the complete food supply system, including product conception, manufacturing and distribution and customer satisfaction. Quality assurance encompasses the development, organization and implementation of a variety of activities directed at maintaining and/or improving the safety and quality of products. It begins when the product is conceived and continues in the selection and purchasing of raw materials and in processing, packaging, distribution and marketing.
It is axiomatic that safety and quality must be designed into a product; they cannot be achieved by end-product testing. Therefore, quality assurance begins with the design and development of food products. This is not only a laboratory or conference-room process; it also involves consumer participation in evaluating new products. Before making a commitment to produce and market an important new product, a manufacturer introduces it to small groups of consumers to obtain their reactions to a wide range of matters, for example, usage and packaging as well as sensory satisfaction. Even after deciding to proceed with the marketing of a product, a manufacturer will often introduce it in a limited, regional market to obtain more widespread consumer reactions.
Quality assurance programmes are designed today with particular emphasis on the use of hazard analysis and critical control point (HACCP) techniques, an approach that the food industry developed and has voluntarily adopted on a broad scale for the past 20 years. This approach consists of several elements:
· conducting a hazard analysis to identify hazards and the needed controls;
· identifying the critical control points;
· establishing critical limits for each control point;
· establishing monitoring procedures;
· establishing corrective action procedures;
· establishing verification procedures to ensure that corrective steps have been taken;
· establishing appropriate documentation procedures to ensure that the control system is defined and that records will be maintained to permit auditing and verification that the system is properly applied.
Training is an essential element of HACCP and of all the operating activities involved in producing safe, high-quality food. All those employed in food production must be thoroughly trained in their responsibilities to achieve this result. Indeed, manufacturers are providing extensive employee training, as no HACCP programme could function without it.
Similarly, supplier and distributor controls are essential to the production and marketing of safe, high-quality foods. Manufacturers must ascertain that the suppliers of their ingredients comply with strict specifications. This is done by contractual arrangements, with verification by a strong system of testing and, in many instances, on-site inspections of suppliers.
The objective of all quality assurance systems used by food manufacturers and processors is to produce safe products that meet manufacturer's specifications, including the requirements established by governments. The corollary is to prevent unsafe or poor-quality products from reaching the marketplace. In the event that a system failure occurs, procedures should be in place for removing products from the market as expeditiously as possible so that the health of consumers and the reputation of the brands affected are protected to the greatest possible extent.
An especially important activity of industry is communication with the consumers of its products. Important and widely used methods of integrated communication are advertising, marketing and product promotions, in which mass media and specialized media are used to secure consumers' attention and to advise them about the availability of products and their uses and advantages.
Another important means of communication is product labelling, i.e. information that appears on the product package or that accompanies it at the point of purchase. Labelling enables consumers to make informed decisions and is intended for careful reading and understanding. It identifies the manufacturer and provides instructions for safe and effective use of the product, as well as providing information about contents, ingredients, health and safety features, preparation and storage.
Labelling and advertising that provide information about the health benefits of food products are important and effective means of communicating with consumers about diet. A study by the United States Federal Trade Commission (Ippolito and Mathios, 1989) concluded that health information in cereal labelling and advertising achieved two important effects; it added significant amounts of information to the market and changed people's eating habits; and it reached population groups that were not well covered by government and general information sources.
Although advertising and labelling are perceived as one-way communication with consumers, in fact they provide the basis for eliciting informed consumer responses to manufacturers about products. Consumers frequently take the initiative to communicate with manufacturers and to ask questions about products as a result of information they have seen in advertising or labelling or because of their experience in using the item. Manufacturers also directly solicit consumers' reactions in advertising. In the United States, for example, many manufacturers encourage communication by providing toll-free telephone numbers on product labels and in advertising so that customers can call the company free of charge.
Indeed, consumer communication with manufacturers is so frequent and important that most manufacturers have consumer affairs departments headed by a company officer to provide appropriate attention to this function. This approach is used mainly in developed countries, particularly the United States, Canada, the United Kingdom and some other European Community countries. It has two purposes: first, to provide an active outreach programme to seek out consumers and provide information to them about the company and its products; second, and most important, to obtain information and ideas from consumers.
It is not uncommon for a single company in the United States to be contacted by consumers literally hundreds of thousands of times each year through telephone or mail communications. These contacts are carefully analysed and evaluated, for they are an important source of information about consumer concerns and interests and provide useful insights about products. As a result of this communication with consumers, manufacturers will modify products, provide new information or otherwise respond to consumer interests.
Manufacturers conduct other outreach programmes for consumers in addition to those specifically intended to test new product acceptability and those intended to inform consumers about product usage. Many initiatives are undertaken voluntarily each year by individual companies and by industry associations to provide the public with useful information about food safety and nutrition. These initiatives are a valuable public service; they carry effective messages to consumers, educators, health workers and others, and thus support and complement the efforts of national governments to fulfil their public education responsibilities. Dissémination of brochures and other promotional literature, media campaigns and interaction with local government officials and schools are among the techniques used to educate consumers about food safety and nutrition. Often these activities are undertaken in association with governments, professional groups and consumer organizations. In addition, informing consumers about proper food handling should be a high priority for both government and industry.
A number of food control issues are currently being debated at the national and international levels, regarding for example pathogenic microorganisms, allergens, genetically modified foods, contaminants (including pesticides), irradiation and nutrition labelling. These are important and complicated matters that require attention. The control issues are at various stages of resolution and considerable effort will be required to resolve them in a scientific, practical and uniform manner. Industry recognizes that consumers play an active, important role in the food control process through their participation in the standard-setting process and discussions on scientific and technical issues. International bodies such as the Codex Alimentarius Commission can contribute to understanding the issues and to achieving rational standards. The food industry has an essential role in the resolution of these food control issues because of its vested interest in the safety and marketing of foods. Further, because of its extensive scientific and technical resources and experience with these issues, the food industry can make important contributions towards their understanding and resolution. Lastly, for the same reasons, the food industry's communications capabilities can benefit public understanding of the complex nature of the many issues that arise.
Clearly, food control involves many difficult issues. Some of these are highly technical, while others are partly technological and partly political. The mutual goal should be to resolve these questions in a way that takes into account the needs of governments, consumers and industry. For governments, there is the need for enforceable standards that are convincing to both consumers and industry. For consumers, food control systems must provide meaningful protection against real and important hazards. Finally, industry needs standards that permit flexibility and efficiency in producing and marketing foods that will serve their customers - the world's consumers.
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