Friday, May 25, 2018


Certification bodies responsible for auditing food business operators
Tuesday, 02 May, 2017, 08 : 00 AM [IST]
Manish Veeramani
Food safety is the most basic concern, especially in a developing economy like ours. Hence, it is of utmost importance that food safety systems are implemented across all levels from farm to fork.

And the responsibility for this lies across with all the stakeholders involved in this food chain. These stakeholders include not only the regulatory body [i e the Food Safety and Standards Authority of India (FSSAI)], but also the others, viz the food business operators (FBOs), the certification bodies and the accreditation bodies.

These stakeholders have the following roles to play in this loop of the food chain:

FBOs obviously have the first liability towards compliance with food safety. They have to follow all the protocols laid down by the regulatory body, and comply with all the requirements as per the implemented food safety management system.

Certification bodies are responsible for auditing the FBOs and verifying whether they are compliant towards the implemented system.

Accreditation bodies are the apex bodies that control the certification bodies and ensure that all the activities performed by them are in line with the requirements laid down as per the accreditation norms.

Food safety management systems
Food safety management systems (FSMS) are basically programmes designed to be implemented by the FBOs with the sole intention of food safety compliance.

The benefit for FBOs is, thereby, assurance of food safety to the end user, which leads to increased trust, leading to increased business.

The various food safety management systems, based on their levels of complexity, are illustrated in Figure 1.

The basic foundation for all these systems is Hazard Analysis and Critical Control Point (HACCP).

This focuses on understanding the process-related hazards involved in the manufacturing of the product.

These hazards are classified as biological (microorganisms), chemical (toxins and adulterants), physical (hair and stones) and allergens.

The standard requires FBOs to identify hazards relevant to their products and processes and accordingly put in systems to control the same.

This controlling system is the second part in HACCP [Critical Control Points (CCPs)]. This standard focuses on a more technical aspect towards food safety compliance.

ISO 22000:2005 is a standard which combines the requirements of two programmes, viz ISO 9001 and HACCP.

The intention behind having requirements of ISO 9001 incorporated is to have the greater involvement of the top management.

This aids in enhanced management commitment leading to quicker decision-making and adequate resource allocation.

This standard is applicable to both the food processing industries as well as industries which manufacture packaging materials for food industries.

FSSC 22000 is a standard which is more rigourous in terms of implementation. It goes one step further in combining the ISO 22000:2005 with another technical specification.

This technical standard lays down requirements for pre-requisite programmes which are on the lines of good manufacturing practice (GMP) requirements.

However, the requirements under this technical specification are different for food and packaging.

The technical specifications for different sectors are as under:


Food manufacturing


ISO/TS 22002-1:2009

Food packaging

ISO/TS 22002-4:2013


ISO/TS 22002-2:2013


BSI PAS 221:2013

Storage and distribution

NEN NTA 8059:2016

The British Retail Consortium (BRC) certification is considered one of the most stringent and has requirements which are defined in the BRC Version 7 for food and BRC IOP Version 5 for food packaging materials.

Whereas all other standards have a certification validity of three years, BRC follows an annual cycle where every year the organisation needs to undergo a certification cycle.

The standards are designed in such a manner that it strikes a balance between technical requirements for food safety and management commitment.

There are requirements which focus on the good manufacturing practices to be followed, the personnel hygiene practices, medical fitness of working personnel, reviews to be conducted by the management to understand the current standing of business, actions to be implemented to go to the next level, etc.

All these standards are very dynamic in nature and keep getting updated almost every five years.

The intent behind these updates are to meet the newer trends and challenges in food safety as well as to meet the customer requirements of quality, taste and safe food.

It is a common misunderstanding that the implementation of standards means too much of documentation and record-keeping.

However, this is not the case and it is extremely important to realise this. The standards do state at many places about the need to have documented procedures and records since it expects food safety to be imbibed in the system and not personnel-oriented.

The FBOs need to understand and keep in mind that these certifications aren’t product certifications but system certifications.

Hence it is expected to be system-oriented by having appropriate documents, procedures and recording systems in place.

Certification bodies
The certification bodies are responsible for evaluating the compliance of a FBO towards the respective food safety management system.

The certification bodies are represented by their auditors, who are qualified and possess the domain knowledge of the sector they audit (viz food safety).

These auditors are responsible for evaluating the performance of any food safety management system by onsite assessment of the site operations and records.

Basis the evidences and actual situations available and verified onsite, these auditors recommend a specific organisation for certification against the specific management system.

Also the intention of these auditors in not purely to do a nitpicking job and identify only mistakes, but to support the organisation to realise its weaknesses and also its strengths.

Organisations today look up to auditors as not merely someone who comes and audits against the standards, but as someone who can add genuine value to their business.

And thus the relationship between an FBO and a certification body gets established on the basis of trust and value added to their overall operations.

Benefit to FBOs
So this gets us to a very interesting question on what is the benefit for organisations by implementing these systems.

The first, and obviously biggest, impact is that it shows to all stakeholders and customers dealing with the FBO their commitment to food safety.

Everyone would prefer to have any relationship with a food safety certified organisaton called ABC Pvt Ltd than just a company called ABC Pvt Ltd.

This means there is a greater visibility among different sections not only in India, but also on an international scale.

The first thing any international party dealing with an Indian company asks for is the certificate. Without a valid certificate, they do not even initiate a discussion. Such is the level of compliance expected.

Thereby, when an FBO implements these systems, it ensures greater opportunity for business in the international markets as well.

This results in better returns for the FBO in terms of revenue generation. And this business is not restricted to any specific country, as these standards come under the purview of the Global Food Safety Initiative (GFSI), thereby meaning that they have a global acceptance.

Another advantage for the FBOs is that it helps them identify any potential serious issues concerning food safety well in advance, thereby reducing the possibility of any such occurrence.

FBOs can take steps to mitigate these situations and do an in-depth analysis, often referred to as root cause analysis, which leads them to ensuring such situations are avoided in real time.

For instance, the standard talks about recall and traceability as a very important activity. Preparing for this and having a defined action plan helps any FBO to have a robust system in place in case of a product safety issue, which may lead to a recall of the products.

The FBOs can take a timely action, thereby avoiding any serious consequences arising from the consumption of such affected products.

The implementation of food safety management systems also results in the increased involvement of the top management and decision-makers, which enhances their commitment to food safety.

This makes the staff down the line also be seriously committed to food safety practices, as it is driven down to them from top.

This results in innovative ideas and actions by the staff on a more proactive approach, leading to better, quicker and safer outputs.

As a conclusion, effective implementation of food safety management systems is the primary prerogative of the FBO, but is the responsibility of all stakeholders as well in regards to the activities they are involved in.

Irrespective of the efforts and costs involved in this activity, the bottom line is that once the customer is ensured of a safe product, the business automatically rolls in.

Increased customer satisfaction brings to the FBO increased business, leading to higher revenue generation.

If one looks at it from a short-term perspective, definitely there will be no returns, but if taken as a full-time commitment, the returns will be there to see earlier than expected.

And the biggest benefit is that all FBOs operating at a domestic level stand a chance to compete in the international markets, which gives a completely different dimension to the brand value.

(The author is lead auditor and technical reviewer, food, Bureau Veritas India Pvt Ltd. He  can be contacted at
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