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The relationship between quality and compliance.
10/12/21 |
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'Quality' and 'compliance' are fairly closely related to each other, but the relationship between the two isn’t always simple.
Performance indicators
All departments and functions in a business have various KPIs, which the senior management can use to assess performance. Different reporting systems will deliver performance metrics to varying levels of detail, but there always exist some very clear and visceral signs of failure or success. If the business account exceeds its overdraft, you’ve got a critical failure in the finance department. If you run out of raw materials, that’s a critical failure for the purchasing function.
For the technical/quality department, the critical measure of success is a pass/fail at 3rd party audit. There are all sorts of ways to assess the fine detail of ongoing performance, but a pass/fail at 3rd party audit is treated as a high-profile event, with congratulations or consequences for the quality manager depending on the outcome.
In much the same way as a salesperson’s take-home depends on commission, technical and quality managers understand that their job security depends on their site’s audit grades. This is all quite rational, because from the point of view of the business a pass at audit means customers will approve your site for supply, whereas a fail will exclude your business from the market and cause lasting reputational damage.
Here, the motivation forms around the success metric. People don’t design quality systems; they design compliance systems. The primary motivation is to produce evidence of compliance that can be delivered at audit, the particulars of whatever activity is being undertaken become a secondary motivation.
Clearly, with the intent of many compliance standards being to safeguard product safety, quality, legality and authenticity, this is not necessarily an immediate conflict of interest, but it is an important motivation shift.
For the technical/quality department, the critical measure of success is a pass/fail at 3rd party audit. There are all sorts of ways to assess the fine detail of ongoing performance, but a pass/fail at 3rd party audit is treated as a high-profile event, with congratulations or consequences for the quality manager depending on the outcome.
In much the same way as a salesperson’s take-home depends on commission, technical and quality managers understand that their job security depends on their site’s audit grades. This is all quite rational, because from the point of view of the business a pass at audit means customers will approve your site for supply, whereas a fail will exclude your business from the market and cause lasting reputational damage.
Here, the motivation forms around the success metric. People don’t design quality systems; they design compliance systems. The primary motivation is to produce evidence of compliance that can be delivered at audit, the particulars of whatever activity is being undertaken become a secondary motivation.
Clearly, with the intent of many compliance standards being to safeguard product safety, quality, legality and authenticity, this is not necessarily an immediate conflict of interest, but it is an important motivation shift.
Practical necessity
The argument against 3rd party accreditation for supplier assurance is that it’s not actually a forward guarantee. Just because the supplier was found to be operating in compliance with the standard on the day, doesn’t mean product made by that site on any other day will be safe. Even if a site is found to be operating to the most stringent compliance standard in the world, there can never be enough challenge and inspection to provide robust assurance. And how do you know you can trust the auditor’s findings?
That acknowledged, compliance with a GFSI-benchmarked standard verified by regular 3rd party audit is the absolute best practical option for most food businesses to base approval decisions on.
A small/medium food business simply doesn’t have the resources to subject every supplier it uses to 1st party audit, so basing approval decisions on accreditation presents a practical and viable means to selectively approve suppliers that have demonstrated quality performance. Any food business can request this type of evidence, but few can afford to audit each of their suppliers every year.
On the above point, even if every food business could afford to conduct 1st party audit on their suppliers, could any business sustain the onslaught of having every customer visit their site?
For a number of reasons, approval based on accreditation represents a licence to enter the market for food manufacturers; and for customers, accepting that licence is the only sensible alternative. So on a supply chain scale, the motivation is again oriented to compliance, with the particular quality activities undertaken to achieve compliance being secondary objectives.
That acknowledged, compliance with a GFSI-benchmarked standard verified by regular 3rd party audit is the absolute best practical option for most food businesses to base approval decisions on.
A small/medium food business simply doesn’t have the resources to subject every supplier it uses to 1st party audit, so basing approval decisions on accreditation presents a practical and viable means to selectively approve suppliers that have demonstrated quality performance. Any food business can request this type of evidence, but few can afford to audit each of their suppliers every year.
On the above point, even if every food business could afford to conduct 1st party audit on their suppliers, could any business sustain the onslaught of having every customer visit their site?
For a number of reasons, approval based on accreditation represents a licence to enter the market for food manufacturers; and for customers, accepting that licence is the only sensible alternative. So on a supply chain scale, the motivation is again oriented to compliance, with the particular quality activities undertaken to achieve compliance being secondary objectives.
Authority
Each time a new quality requirement is introduced into operations, the compliance motivation comes into play. This isn’t just a quality activity; this is an evidence-producing compliance activity. Paperwork and record-keeping
Now these records are seriously important. There are lots of occasions where fault diagnosis requires that these records be reviewed. Comprehensive traceability records are critical for a recall to be effective. But not everyone’s pleased about it when you ask them to do more paperwork on top of whatever else it was you wanted them to do, and sometimes there’s resistance.
So you say the magic words: “It’s a BRC* requirement”.
*Or any other compliance scheme, really.
And that’s it – the new process is adopted without further resistance and operations go on.
It can be the same for GMP non-conformities on the factory floor. If you see someone doing something wrong, it’s always going to be tempting to say something like “If the auditor came and saw you doing that….” Because there’s a higher authority to refer to. Why stand there and appeal to someone about how likely or unlikely they are to contaminate a product if they don’t wear their beard snood, when you can just refer to the auditor like some kind of quality boogeyman?
Unfortunately, the reverse works just as well. “That’s not actually a BRC requirement” becomes a powerful counter argument to any request when the only reason to comply is ‘compliance’. There can certainly appear to be less reason to comply when there's no auditor on site.
Now these records are seriously important. There are lots of occasions where fault diagnosis requires that these records be reviewed. Comprehensive traceability records are critical for a recall to be effective. But not everyone’s pleased about it when you ask them to do more paperwork on top of whatever else it was you wanted them to do, and sometimes there’s resistance.
So you say the magic words: “It’s a BRC* requirement”.
*Or any other compliance scheme, really.
And that’s it – the new process is adopted without further resistance and operations go on.
It can be the same for GMP non-conformities on the factory floor. If you see someone doing something wrong, it’s always going to be tempting to say something like “If the auditor came and saw you doing that….” Because there’s a higher authority to refer to. Why stand there and appeal to someone about how likely or unlikely they are to contaminate a product if they don’t wear their beard snood, when you can just refer to the auditor like some kind of quality boogeyman?
Unfortunately, the reverse works just as well. “That’s not actually a BRC requirement” becomes a powerful counter argument to any request when the only reason to comply is ‘compliance’. There can certainly appear to be less reason to comply when there's no auditor on site.
Sales and marketing
The food industry is ripe with consultancy firms ready to capitalise on their technical and quality expertise. Systematically, this is a good thing because it provides skills elasticity across the supply chain – not all food businesses need to employ full time permanent experts in every field in order to gain access to those skills when needed. The interesting thing is how these services are marketed.
Across the board, the product on sale is ‘audit readiness’ and ‘compliance’. Business-to-business service providers know their customers, and while no-one has anything against quality services, if you want to convert a customer you call your product a ‘compliance solution’.
Across the board, the product on sale is ‘audit readiness’ and ‘compliance’. Business-to-business service providers know their customers, and while no-one has anything against quality services, if you want to convert a customer you call your product a ‘compliance solution’.
In summary
Compliance schemes all have different requirements. GSFI-benchmarked schemes are widely regarded as sufficient for approval – so if a business can demonstrate compliance verified by regular 3rd party audit, that business can sell to almost any customer.
At the individual level, site level, and supply chain level, this results in compliance being elevated to the primary motivation, displacing or shaping the particulars of quality activities.
There is no overt reason to think that achieving compliance should ever detract from quality ideals. The very point of many compliance schemes is to enforce a structure for effective quality systems. On the other hand, it’s easy to see how compliance schemes can also act as a limiting factor – do the minimum required to achieve compliance, and no more.
Contrary to the point about compliance standards imposing a limiting factor on quality processes, the opposite is also true. Where food manufacturers engage with compliance schemes such as the BRCGS Food Standard, it is routinely the case that the quality processes adopted by those sites are more stringent and consider a wider range of risk factors and safeguards than sites that do not operate to those standards. GSFI benchmarked standards are regularly updated by working groups of industry experts so that important considerations that might otherwise be overlooked are included.
Regardless of any criticisms that could be levied against compliance and certification, the benefits of compliance across the supply chain are enormous – providing a viable way for food manufacturers to practice diligence in approving their suppliers.
At the individual level, site level, and supply chain level, this results in compliance being elevated to the primary motivation, displacing or shaping the particulars of quality activities.
There is no overt reason to think that achieving compliance should ever detract from quality ideals. The very point of many compliance schemes is to enforce a structure for effective quality systems. On the other hand, it’s easy to see how compliance schemes can also act as a limiting factor – do the minimum required to achieve compliance, and no more.
Contrary to the point about compliance standards imposing a limiting factor on quality processes, the opposite is also true. Where food manufacturers engage with compliance schemes such as the BRCGS Food Standard, it is routinely the case that the quality processes adopted by those sites are more stringent and consider a wider range of risk factors and safeguards than sites that do not operate to those standards. GSFI benchmarked standards are regularly updated by working groups of industry experts so that important considerations that might otherwise be overlooked are included.
Regardless of any criticisms that could be levied against compliance and certification, the benefits of compliance across the supply chain are enormous – providing a viable way for food manufacturers to practice diligence in approving their suppliers.
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Author: Duncan Lacey - Director of Innovation, Food Portal
Duncan Lacey | LinkedIn |
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