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Peanut Quality - How did the Food Inspection Fail?

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In a recent article, Food Problems Elude Private Inspectors, journalists speculated on how food safety auditors could give a “superior” rating to a production facility that a few months later would poison hundreds. Many people have noticed the increasing number of food-borne illnesses reported in the press, but no one has attempted to explain why it's happening, how it can come about. Let me show you not only how it happens but how our present food safety system encourages similar situations.

To understand the problem it is necessary to look at the “Quality Revolution.” In the 1970s when I first started working in the quality field, Military. Standard 105D (it became 105E later) was often used to determine incoming inspection levels. Mil Spec 105Dwas a common-sense, statistics-based standard, appropriate to the military sense of getting things done correctly, and it saw wide use in industry. It provided methods to categorize vendors as good, average or below average. The customer could adjust the level of incoming inspection accordingly.

Dr. W. Edwards Deming, a mathematician doing research into quality, had been ignored by US business. He took his expertise to postwar Japan where his methods revolutionized quality. After superior Japanese quality flattened American business in the market place, Americans started searching for the “Magic Wand” that would allow them to compete, Several experts cashed in on this mad search. Joseph Juran, Armand Feigenbaum and Philip Crosby emerged as the leaders of the pack.

In 1987 the methods used by Deming and the other leaders were quantified as a set of quality manufacturing standards called ISO 9000. I was one of the first to get training in ISO 9000 here in the USA. I was impressed by the first half of the presentation and during break started discussing what I had learned with my seat-mate. He was not at all impressed. He was originally from Russia, and he told me that the Soviet Union had used the same kind of system for years, and that and it generated paperwork, not quality. Twenty years later I, along with other quality professionals, agree with him.

...”I'm wondering if there might be a silent majority of Quality [magazine] readers out there on the topic of ISO 9000. The response to my July editorial, "Eliminate ISO 9000?," was the heaviest that we have received in some time...What surprised me is that the July editorial elicited no ardent rebuttals in defense of ISO 9000...” http://www.qualitymag.com/Articles/Letters_From_the_Editor/65730ee7f4c38010VgnVCM100000f932a8c0

Bean counters, looking only for immediate additional profit, found some of the concepts of ISO 9000 very attractive:

  1. Do not duplicate effort by repeating testing that's already been done. This means that incoming inspection can be eliminated, saving some labor.

  2. Develop a relationship with a single source instead of wasting resources on qualifying several sources

  3. Use “Just In Time.” Since the source is prequalified, the raw materials can arrive on the same day as needed, eliminating warehouses and jobs.

The third item is particularly interesting. If the method fails, that is, if the supposedly prequalified material is no good, there might be no choice but to use it anyway! The result can be anywhere from a minor inconvenience to a total disaster.

So what does this have to do with the peanut fiasco? First, because of the “Quality Revolution” a version of ISO was developed for the food industry. It was called HACCP and was published as an international standard in 1993 by Codex Alimentarius. In 1995 Mil Std 105E was declared obsolete and in 1996 HACCP was adopted by the USDA.

Pathogen Reduction/Hazard Analysis and Critical Control Point (HACCP) Systems rule, on July 25, 1996: Under the HACCP rule, industry is responsible for assessing potential food safety hazards and systematically preventing and controlling those hazards. FSIS [Food Safety Inspection Service] is responsible for verifying that establishments’ HACCP systems are working ..www.fsis.usda.gov/PDF/Evolution_of_RBI_022007.pdf

Notice how this ruling has shifted the focus of audits, both government and private, from testing for contamination to the paperwork documenting the “Quality Management System”. Secondly, rigorous incoming inspection has been drastically cut‒if not eliminated‒by the companies that receive raw materials. In buying peanuts from the vendor, Kellog relied only on a third-party auditor who reported on the integrity of the suppler. Twenty or thirty years earlier Kellog would have sent their own quality professional to work at the vendor's facility.

If the “Quality Revolution” worked so well for the Japanese, why isn't it working in the USA? There are several reasons. First is the Japanese sense of honor, ethics and integrity. Deceitfulness is frowned upon and results in a loss of face and disgrace to the family.. Secondly, Japan is a small country so word of deceitfulness spreads easily.. In the USA a slick salesmen who lies to get sales is likely to be praised and held up as an example to new salesmen. The US has a very mobile population, there are always new suckers moving into the community . A scoundrel can relocate to any of forty nine other states.

Another problem, according to quality expert Kaoru Ishikawa, is America's regulations of business that give tremendous importance to each company's quarterly results. He claims that the result is short-sightedness.

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I am trained as a chemist, quality engineer and I am now self employed after being blackballed for refusing to falsify data. I consider myself an individual and not a conservative or liberal. I dislike most politicos because they are generally (more...)
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