Harmonizing Standards: USDA Takes Commendable Initiative. Others to Follow?
Updated: Nov 22, 2018
We, at TAG, are often asked about the alignment of GFSI standards and federal regulations. That is: If you are in compliance with GFSI standards, is your facility compliant with federal standards and regulations? And - Does regulatory compliance get you all the way to GFSI compliance?
When comparing requirements for the two (which we have done at various times, but I will come back to that), we generally think of the federal regulatory agencies as being the higher power – and they are when it comes to “have to” vs. “want to” in food safety practices. But this took an interesting turn last week when it was USDA applying to GFSI for equivalency.
At the request of the specialty crops industry, the USDA Agricultural Marketing Service (AMS) applied for the USDA Harmonized GAP Plus+ standard to be recognized as
technically equivalent to GFSI’s food safety benchmarking requirements. The purpose is to align the USDA Good Agricultural Practices Program with industry-recognized food safety audit requirements and to provide the specialty crops sector with a single government-based certification program that meets multiple market access requirements. USDA specifically called out the specialty crops sector to help it grow the marketing opportunities for its producers, increase purchasing options for buyers, and provide consumers with access to more and diverse fresh, local produce. (To comment through June 22, 2018 or view the documents of USDA’s equivalency request, visit Technical Equivalence, Consultations.)
In many ways, though, when determining the alignment or equivalency of GFSI with any federal regulations or standards, it really comes down to the skill and experience of the auditor. How well do they know, not only the scheme against which they are auditing your facility, but also the specifics of the relevant FDA or USDA rules or standards and how it all aligns? In many cases, additional – or even contradictory – customer and/or foreign country standards and requirements also need to be added to the mix, so it can be a real juggling act for both the facility and the auditor.
Thus, the more we can harmonize the various U.S., global, and customer standards and regulations, the easier it will be for the entire industry, and the more that food facilities will be able to focus on practicing food safety and quality rather than simply aligning their policies with standards. So, kudos to USDA AMS for taking the step to request equivalency with GFSI. Perhaps it also will encourage other agencies to initiate similar alignment where possible.
I find the USDA action to be interesting as well, because we are most often asked about GFSI comparisons with FDA and FSMA, but it is USDA taking the initiative to create harmonization. The fact that it is AMS making this request does not detract from the fact that it is a U.S. government body that is requesting the GFSI technical equivalency. To give credit where due, however, FDA did consider GFSI standards in the writing of many of the FSMA rules, and with the rules in place, it has become a focus of GFSI scheme holders to review the FSMA specifics and make some adaptations for alignment.
It also has become a commitment of TAG to help you figure it all out – through various newsletter articles, webinars, documents, and consultation. For example, in April, we published a blog by TAG Senior Director of Food Safety Cameron Prince on Latest GFSI Scheme Updates – and How They Compare to FSMA’s Human Food Rule Requirements. The blog was an adaptation of Prince’s presentation on one of the FSMA Friday webinars we hold on a monthly basis. A few other TAG resources on GFSI and FSMA alignment include What Does It Mean to be GFSI Certified in a FSMA Environment?, TAG GFSI FSMA Comparisons (scroll to bottom of page), and Does GFSI Certification Equate to FSMA Compliance? Additionally TAG has worked with some of the scheme holders to conduct comparisons of their specific standards with FSMA, such as SQF, FSSC 22000, and BRC.
I am a big fan of harmonization of standards. It is likely a little Utopian, but the idea of one set of preventive control standards for all makes a lot of sense to me as a means to reduce duplications and wasted resources. So any initiatives from the government, such as the one we discussed in this newsletter seeking better alignment with standards, are clearly steps in the right direction.
About The Acheson Group (TAG)
Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG's team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com