Some adopters of HACCP saw verification as a management role but failed to describe how the role was to be performed. Others saw it as a method to evaluate a particular point in the process. Both groups put the burden on the shoulders of management and, consequently, on the quality assurance manager. Regardless, it was clear that there must be a review and evaluation of the overall system.
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Later, as a part of the natural evolution of the system, HACCP practitioners began to define verification, which arose from benchmarking other system methods. Validation was simply the name given to the process that determined whether or not a system could deliver what it was designed to deliver. Once the system was designed, a validation was performed to determine whether or not it worked correctly. If not, modifications were made. If the system functioned as planned, it was put into standard procedure. This process augmented verification activities, enabling them to determine not only that a system could deliver but also that it would continue to deliver.
Again, because validation was generally thought of as a scientific practice, management was at least one step removed from ownership of the system. Eventually, government inspection agencies found it necessary to improve the system evaluation process.
Auditing became the tool used by inspection programs, allowing the entire system to be evaluated. This meant that, in spite of regulations stating that the firm and its management were responsible for the safety of the food produced, the government was still, to some extent, taking ownership of the system.
Management’s Role in ISO 22000
In late 2005, official publication of the food safety management standard ISO 22000 provided an opportunity to take a hard look at the role of management in food safety and quality systems. ISO 22000 gives a number of advantages to the food processor wishing to improve its food safety management system. The system approach of the standard, for example, with its compatibility to ISO 9001, is a great advantage. The ISO 22000 standard is meant to simplify the myriad of different audit program requirements that buyers currently face.
ISO 22000 is designed to address Codex requirements specific to the food industry. Companies adopting the standard will now be on an even playing field with many other firms across international lines. Further, buyers can be assured that products from these firms will, with proper outside auditing, meet their food safety needs. Because the standard is written in similar terms to those of ISO 9001, the roles of verification, validation, and management review are clearly outlined. The role of management review is stated outright—even though top management may or may not have a role in verification and validation, they are still responsible, ultimately, for the function and effectiveness of the system.
When discussing the USDC Seafood Inspection Program’s use of ISO 22000, many field inspectors were concerned that those in the industry would be distressed by the requirement of management review. After all, the program was voluntary, and wasn’t this the function of audits?
An announcement regarding changes to the HACCP Quality Management Program went out to all program participants. Program leaders waited, anticipating negative reactions regarding the changes to management roles.
But the result was astounding. Not only were few comments received; none were directed at the management requirements. Discussions showed that the seafood industry strongly supported changes involving management review and commitment.
Ultimate Role of Management
Recent media announcements make it clear that all eyes are on the nation’s food supply. This is not surprising. What is unexpected is that industries are taking a leading role in accepting more responsibility for the function of their systems. Now, not only are there food safety and quality concerns to consider, but also liability issues. No one in upper management desires to be the focus of a recall, investigation, or import detention; they are showing that they desire to take a more informed role in the products produced.