Editor’s Note: The Caribbean, Central America, and Oceania comprise some of the world’s top tourist destinations. But behind the beautiful beaches, ancient ruins, and unique landscapes, each region is hard at work improving their food safety initiatives to be on par with the rest of the globe. The first part of this special report focuses on the Caribbean. The second and third parts will focus on Central American and Oceania, respectively.
The Caribbean welcomed an estimated 28.7 million tourists in 2015, according to the Caribbean Tourism Organization. Given the scope, scale, and diversity of the Caribbean, its people and cuisines, and the significant tourism component of its economy, it’s no surprise there are many challenges to achieving and maintaining a high level of food safety, many of which are unique to the region.
The Food Safety Modernization Act (FSMA) is among the most prominent food safety issues currently impacting Caribbean exporters, according to André Gordon, PhD, CFS, managing director of Technological Solutions Limited (TSL), a Kingston, Jamaica based company that provides food product development, auditing, laboratory, training, and other food safety consulting services throughout the world.
“Compliance with the FSMA requirements that have come into force or are approaching their implementation dates is a concern for food manufacturers on the Caribbean islands,” Dr. Gordon says. “Specifically, the Preventive Controls for Human Foods Rule (21 CFR part 117), the Produce Safety Rule, traceability requirements, compliance with the Foreign Supplier Verification Program requirements, and conformance with the allergen management and labeling requirement are all in the fore front. So is understanding the implications of the full implementation of the FSMA, particularly the Hazard Analysis and Risk-based Preventive Controls regulations.”
Ongoing inspection of Caribbean food and ingredient exporters by the FDA is another issue, Dr. Gordon notes. “The FDA conducted 18 inspections in Jamaica in July and August 2016 alone, with all of the firms visited generally being acceptable, and just minor findings being raised in a few instances,” he mentions. “Moreover, meeting the food safety and quality systems requirements of buyers from the European Union (EU) and Canada, including for proof of compliance with allergen, labeling, residue, and other limits, is a constant challenge.”
Dr. Gordon says the ability to access the kind of technical and analytical support required to comply with importing country and buyer requirements can be both financially tough, as well as challenging for some Caribbean stakeholders, as the persons with the knowledge to assist, though growing, are few.
“The increasing insistence of buyers of Caribbean export products in the U.K., EU, and North America that firms must have at least a certified, compliant Hazard Analysis and Critical Control Points (HACCP) system in place or have HACCP certification from a recognized entity compound some companies’ challenges,” Dr. Gordon relates. “This is because it both costs and takes time to get the system implemented, during which time the firms’ access to the market may be curtailed. And many importers of our products are insisting on Global Food Safety Initiative (GFSI) certification in order to continue to do business with Caribbean exporters.”
Caribbean food purveyors also need to comply with requirements of major buyers from the hospitality and food service sector for a compliant and/or certified food safety system, Dr. Gordon adds. “There are increasingly mandatory requirements from transnational quick serve restaurant (or QSR, the common industry abbreviation) customers that supplier firms must be able to pass food safety audits to their proprietary standards,” he says. “Some of these include the need for GFSI certification.”
Caribbean food regulations, where they exist, need to be based on food safety system principles, rather than on quality criteria, Dr. Gordon emphasizes.
“In those countries where food safety-based or food industry regulations are lacking, the relevant ministries are in the process of promulgating the requisite legislation to address this gap,” he points out.
Dr. Gordon says some other issues that are of importance to various stakeholders in the Caribbean food industry include 1.) strengthening the capacity of the public sector apparatus to be able to administer food safety-based regulatory systems, including the training of staff, upgrading of inspection systems, and the significant upgrading of analytical support capabilities; 2.) modification of existing or newly implemented legislation and/or regulations to ensure congruence/equivalence with the major trading partners of Caribbean countries, especially the EU, the U.S., and Canada; 3.) strengthening the surveillance and monitoring of the domestic food handling system, inclusive of agricultural production, food service, hospitality, manufacturing for domestic consumption, and manufacturing for export; and 4.) improving technical support capacity to help exporters in meeting importing country technical and analytical requirements.
In the plus column, Dr. Gordon points out, several of the countries of the Caribbean have been very involved in exports to developed country markets for many decades and, as such, have already developed systems to ensure the safety of their food supply. “This covers both food for domestic consumption, as well as for exports,” he says. “Also, because much of the region is dependent on tourism in which visitors, mainly from developed country markets visit and stay in-country, this has provided additional incentives for each country to ensure that the food being offered for sale and/or service to visitors is safe.”
Another important contributor to Caribbean food safety practices, particularly in the manufacturing sector, Dr. Gordon relates, has been the presence in the region for decades of manufacturers such as Nestlé, Unilever, Pepsi, Guinness, Coca Cola, other international brands, and regional brands whose standards set the bar for manufacturing and significantly influenced practices in other companies.
Dr. Gordon is quick to point out that the nature of Caribbean cuisine is such that most foods are very well cooked, and where traditional methods are used research has shown these foods to be safe. This is highlighted in several case studies in Food Safety and Quality Systems in Developing Countries, Vol II: Case Studies of Effective Implementation, published by Academic Press (Elsevier), in December 2016, of which Dr. Gordon is an author and the editor.
“The food safety initiatives that have been undertaken in the Caribbean and those which are currently underway have many strengths,” Dr. Gordon boasts. He mentions the following list of what he considers strengths.
1. In many Caribbean countries, regulatory oversight of the food industry for safety is well established through the Ministries of Agriculture, Health, and Trade/Commerce.
2. There are many, detailed and equivalent (in fact, many are more stringent) regulations in place in the region in various territories to govern the production and handling of foods, with Jamaica and the Dominican Republic being the leaders in this area.
3. A regional organization dedicated to food safety, the Caribbean Agricultural Health and Food Safety Agency, has been established.
4. The Caribbean Public Health Agency has had a focused program on food safety monitoring and reporting in place for years that assists with planning and management.
5. The ministries of agriculture have long established proper procedures and programs for the use of fertilizers, pesticides, and other chemicals in agriculture.
6. Analytical support for the food industry is strong in the Dominican Republic, Jamaica, Trinidad and Tobago, St. Kitts and Nevis, Dominica, and Grenada, and is improving in other territories such as Guyana, St. Vincent and the Grenadines, St. Lucia, Antigua, Haiti, and Suriname.
7. The region has several university level and private programs that have significantly improved the knowledge and competence of the food production and handling value chain in food safety.
8. Universities and colleges have been producing graduates at the degree and diploma level trained in areas within the field, and colleges that target the hospitality sector also have specific programs on food safety as a part of their curriculum.
9. Since 1996 there has been a presence in the Caribbean of a Better Process Control School based at the University of the West Indies (UWI) at Mona, a collaboration initially between the Bureau of Standards Jamaica, UWI, the University of Maryland, the FDA and Dr. Gordon. This school was the first of its type outside of the continental U.S. and has made low-acid canned food (LACF), acidified food, and aseptic processing training available in the region since then.
10. There is a presence in the Caribbean region of process authorities that can help firms establish credible, safe thermal processes. The primary source in the region since about 2000 has been TSL, which has done many processes for exporters from Jamaica, Trinidad and Tobago, and Barbados that have been filed with the FDA Center for Food Safety and Applied Nutrition’s LACF division, according to FDA guidelines.
11. Because of their export and trade, particularly with the U.K., the EU, Canada, and the U.S. for decades, many private Caribbean companies already had good quality systems in place since the 1980s. Some of these systems were upgraded to include food safety systems in the mid-late 1990s to early 2000s, with TSL and internationally funded programs (through USAID, the EU, and Canada) being the drivers. “As a result, many companies throughout the region have been aware of and have been implementing Good Manufacturing Practices and HACCP since the early to mid-2000s,” Dr. Gordon relates.
12. In Jamaica and the Organisation of Eastern Caribbean States (OECS) in particular, there has been a push to implement food safety systems since 1999-2000 in response to market access imperatives (into the EU for seafood and the U.S. for ackees (see Food Safety and Quality Systems in Developing Countries, Vol I: Market Challenges and Implementation Strategies).
13. The major breakthrough of working closely with the FDA to get Jamaican ackees back into the U.S. market in 2000 led to a transformation of Jamaican, and then regional regulations, to become food safety-based (rather than quality systems based only).
14. Microbiological and chemical testing of food for domestic consumption and export has been routine in Jamaica for decades and is increasing in the Dominican Republic, the OECS, Trinidad and Tobago, Barbados, and others.
15. The roles of the bureaus of standards on the various islands and in the Caribbean Community, the EU-funded Caribbean Export Development Agency, the National Institute of Standards and Technology, and other regional and international development partners in supporting the drive towards a region-wide food safety trust should not be under estimated.
16. The roles of the bureaus of standards on the various islands and throughout the Caribbean Community, the EU-funded Caribbean Export Development Agency, and the Caribbean Development Bank (CDB)-funded programs on food safety have augmented those previously done by the National Institute of Standards and Technology, and other regional and international development partners. “Collectively these have supported the drive towards a region-wide food safety imperative that should not be under estimated,” Dr. Gordon emphasizes.
Caribbean Food Defense
“In the area of food defense, many of the requirements are already met by Caribbean firms as a part of their own security and brand protection systems,” Dr. Gordon says. “For example, for most major manufacturers/suppliers, numerous features are a part of their food security/defense systems.”
According to Dr. Gordon, these features include physical security through the fencing/physical protection of the property on which the food handling/production is being done; the presence of security guards to protect the property and manage personnel and transportation flows into and out of the property; control of the safety of incoming and outgoing goods, physical security of the actual production/handling facility itself including electronic access controls along with a security guard; and the widespread use of security cameras to augment any human security in place.
“These measures typically cover production and storage areas; the protection of water supply systems; and management of chemicals, raw material inputs, and finished products,” Dr. Gordon points out. “There is use, in some firms, of foreign material detection and control systems, such as magnets, sieves, and metal detectors. And many exporting firms have put documentation and systems in place to manage the security of the exports and analyze products for compliance with residue limits, microbial limits, and other requirements.”
These export security practices are routine in countries like Jamaica and the Dominican Republic, and are increasing in others, he mentions.
“Many larger firms routinely implement and manage a supplier quality assurance program to approve and manage suppliers,” Dr. Gordon adds.