We can all agree that consumers should never have to worry whether their food is safe. Where agreement doesn’t exist, however, is in the how. How do we best monitor for chemical, biological and physical contaminants, how do we report and to whom, and how much regulation is too much? Even as industry continues to debate the how, prevailing sentiment is that the onus for ingredient and finished product safety is on manufacturers large and small, not on the myriad regulatory bodies that now have jurisdictional oversight. After all, no regulator has sufficient resources to do anything more than perfunctory testing, and many agencies would readily admit they are drowning in data that, despite the intrinsic value, they are unable to effectively access and use. The answer must — and is — coming from those best positioned to be stewards of food safety: the producers and manufacturers themselves. But this isn’t a case of the “fox guarding the henhouse” because there is no predator here. Each producer or manufacturer is accountable up and down an increasingly more transparent food supply chain. The consequences of a mistake range from crippling stock deflation for a mega brand to the complete shuttering of a smaller company affected by a recall on a national or international stage. Now the burden of proof has shifted to industry, each link in the supply chain has a proportional responsibility to supply safe product. Suddenly it doesn’t matter whether the Food Safety Modernization Act (FSMA) goes too far or whether the General Food Law Regulation in the EU goes even further. If the industry has a vested interest in delivering safe food — because the alternative is business-ending — they’ll make investments that exceed what’s required by regulation. So what does all this have to do with harmonization, which is the subject of this article? Let’s start by looking at what harmonization means. Harmonization in Food Safety Many eyes are on the Trans-Pacific Partnership (TPP), and the food industry is no exception. On its website, the U.S. Dept. of Agriculture (USDA) states that, “The TPP is an opportunity to advance U.S. economic interests in this critical region and to respond to the Asia-only regional trade agreements being negotiated by our competitors. A high-standard TPP agreement that addresses tariff and non-tariff barriers, including phytosanitary measures, will support expansion of U.S. agricultural exports and promote job growth.” Advocates for the dairy and poultry industries, among others, agree. Easing restrictions to global trade is important to future growth. But whether TPP is the catalyst for this growth (as of this writing, the U.S. Congress is still debating the law) isn’t subject for debate here. We accept that the opening of trade between nations and among the thousands of food safety businesses within is inevitable. But this is where the real challenge begins. Critics of the law believe that an already loose net will get looser. For years, domestic seafood producers have complained of contaminated imports, including shrimp from TPP-participant Vietnam. How, these critics wonder, will opening trade help this long-standing problem? And this is just one example among many. Simply put, there is no regulatory harmony between these 11 potential trade partners — and the many other nations not part of TPP — so it’s right to wonder how standards will be monitored and met. The same worries exist as the U.S. and EU hammer out terms of the Transatlantic Trade and Investment Partnership (TTIP), “an ambitious, comprehensive, and high-standard trade and investment agreement.” Protests in the streets of Europe earlier this year don’t portend well for TTIP, but that doesn’t change the fact that strong political will exists to remove real and perceived shackles that prevent a free-flowing global food supply chain. Before this happens, however, proponents will need to win over those who question whether harmonization does indeed benefit consumers. In an article in Huffington Post, authors Elizabeth Kucinich and Debbie Barker from the Center for Food Safety wrote skeptically that “harmonization is code for low standards for food safety.” Without taking sides, however, we can at least concede that cross-jurisdictional harmonization will require negotiation and tradeoff. So proponents and opponents must accept something less than a perfect outcome. But everything we’ve explored so far looks at harmonization from the country or regulator point of view. What if, instead, harmonization capitalized on industry’s willingness to accept the burden of proof and make harmonization about following data-driven business rules instead of adherence to a hodgepodge of standards? In this case, could the outcome — safer food — actually be better? Perhaps. Achieving Data Harmony First You are only as strong as your weakest link. And if food safety is a chain, not a confederacy of monoliths, then weak links will stand out as the liabilities they are. A misstep by a single supplier can affect a brand’s market cap significantly. And that single supplier is one recall away from bankruptcy. So for any reputable food supplier, manufacturer or distributor, data-driven insights — as deep and detailed as possible — are actually prudent business insurance. Is harmony just about agreeing to minimum standards? Maybe. But lost in the discussion of what standards should be is how to measure them, track them inside and outside of an enterprise, and how to respond as quickly as possible if a breach of any kind occurs. This is where the regulation — even if harmonized — doesn’t help. What can help, however, is a management system that over-achieves and is actually voluntary: ISO 22000. And don’t let voluntary imply less rigor — adherents to ISO 22000 haven’t taken the easy way out — they’ve committed to hold themselves and their partners to a higher standard. While there’s no single formula for compelling rigor across the global food supply chain, there’s clear evidence that ISO 22000 can make a significant impact industrywide. And this will require rigor on the part of labs that serve the industry with increasingly more specific and data-intensive testing. But with advanced technologies for data collection, analysis and reporting, the benefits of ISO 22000 are well within reach of most, if not all, companies. The goal here is data harmonization first, a first step toward establishing true harmony — and enhanced consumer protection — across the highly interconnected supply chain. Conclusion Once you harmonize the data, you’re one step closer to protecting your flanks up and down your supply chain. Or, if you’re a single link in that chain, you have a way to validate that your ISO 22000-driven processes and management systems enable you to immediately plug into a lucrative global supply chain. Over the next decades, the world will get progressively “flatter,” and that brings both opportunity and risk. But whether harmonization is possible across disparate regulatory jurisdictions is moot — what’s most exciting for our industry is seeing how it steps up voluntarily, arming itself with better approaches to collecting and using data that let us fulfill our promise to consumers that they’ll never have to worry whether their food is safe.
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