Q: In a food manufacturing company, with certifications to ISO 22000:2005 Food safety management systems — Requirements for any organization in the food chain as well as ISO 14001-2004: Environmental management systems – Requirements with guidance for use, the certification to ISO 22000 allows the company to operate with exemption from the Food Act. The exemption from Food Act determines that the organization has a permit to use its physical premises to indulge in industrial activity involving consumable food products.
Now, this permit is issued with certain conditions — e.g., regular updates to the issuing authority regarding changes to to the food safety plan. We view this requirement as a legal requirement.
My question is, would we use the legal register developed as part of ISO 14000 as the tool to manage the compliance to the above legal requirements? Doubt arises because the legal requirement addresses a condition imposed by the food safety system, but at the same time, if it is not complied with we could lose our license to operate (which I could interpret as an environmental aspect…license to exist).
Could someone kindly advise what they would consider to be a logical option?
Response from Susan Briggs:
A: I am not a food safety expert, so I cannot give an opinion on whether or not using a register/process established for environmental regulations can be used for tracking food safety regulatory requirements. But from the ISO 14001 perspective, and my professional opinion, the answer is “of course!.”
The intent of management system standards — certainly all of the ones I have worked with– is to integrate the processes that are required by a standard (whether it be ISO 14001, ISO 22000, etc.) into the company’s business management process (i.e., a single process that is used to track all of the company’s legal obligations…environment, safety, finance, food safety, etc.), not to create stove piped processes (i.e., separate processes/systems for tracking depending on the nature of the regulation).
Director of Environment, Health and Safety, Textron Systems
Chair, U.S. TAG to ISO/TC 207 on Environmental Management Systems
Response from John Surak:
A: I am not sure what is meant by the term “exemption from the Food Act.” ISO 22000 requires that the organization meet all of the legal requirements of the country in which the site is located. In addition, if the organization is exporting food, they must meet all of the legal requirements of the target company. ISO 22000 was developed to be compatible with the other ISO management system standards. Therefore, it is fully permissible to develop an integrated management system as long as the management system meets the requirements of each standard and regulatory requirements. I personally support the development of an integrated management system. Sue conveyed this thought very well in her response.
Just one additional note, if the organization’s customers expect that the organization has a food safety management system that meets the requirements of Global Food Safety Initiative (GFSI), then the organization should seek registration to FSSC 22000 rather than ISO 22000. FSSC 22000 is a food safety audit scheme that utilizes ISO 22000 and ISO 22002-1.
John G. Surak, PhD
Surak and Associates
A member of Stratecon International Consultants
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