ACLASS’s Greenaway Speaks on Food Safety Modernization Act
On June 6, 2011, Keith Greenaway, Vice President
ACLASS, gave a brief talk at the FDA Food Safety
Modernization Act Public Meeting: Focus on Inspections and
Compliance. His prepared remarks follow and you can view the accompanying slides.
The ANSI-ASQ National Accreditation Board is a non-profit,
non-governmental organization that provides accreditation services
to public- and private-sector organizations in the areas of
management systems, laboratories, inspection, reference material
producers, proficiency test providers, product certification, and
personnel certification. We are jointly owned by the American
National Standards Institute and the American Society for
Quality.
We operate predominately in the realm of ISO international
standards, which are developed, based on consensus, and then
adopted globally, and subsequently adopted as American National
Standards. Two organizations provide oversight and a recognition
infrastructure for accreditation bodies operating inside this
global infrastructure. The International Laboratory Accreditation
Cooperation (ILAC) was established to oversee laboratory and
inspection body accreditation and the International Accreditation
Forum (IAF) was established to oversee management systems and
product and personnel certification. Recognized accreditation
bodies then accredit conformity assessment bodies (that is,
inspection agencies, laboratories, certification bodies, and
product certifiers) to specific international standards who then
audit and/or test for competence.
This generic third-party conformity assessment [slide 4] model
illustrates the conformity assessment activities that are offered
competently and credibly by ILAC and IAF member bodies. We
developed the model in conjunction with the National Institute of
Justice and the National Institute of Standards and Technology to
support a new private-public sector partnership for accredited
third-party conformity assessment activities with oversight.
The FDA must embrace a model based on international consensus
standards that has already proven to work across international
borders and within multiple industries through the existing
recognition infrastructure of ILAC and IAF. In today's political
environment, uncertainty remains whether funding will even be
available for the mandated inspectors under the Food Safety
Modernization Act. Given this uncertainty, it is imperative that
the FDA work together with the private sector under the existing
international infrastructure and rely on accredited private sector
conformity assessment bodies to work in coordination with
appropriate government inspectors to help fulfill the mission of
the FDA under the Food Safety Modernization Act. The food industry
is already operating under a realm of uncertainty as they prepare
for both private sector food safety certification programs and
government inspections. This is unnecessary duplication, which
increases costs to the consumer and wastes taxpayer
money.
The infrastructure that's used globally and by many U.S.
regulators will support the FDA's role in protecting our nation's
food supply under the Food Safety Modernization Act, and it will do
so without adding unnecessary duplication for private industry and
without wasting taxpayer dollars.
To have a truly effective food safety system in the United
States, we must have a level of oversight that works in partnership
and supports the role of the FDA to provide confidence in the
entire lifecycle of the product. The best way to achieve this type
of system is through accredited third-party conformity assessment
services with oversight, through which an independent party
verifies and provides written assurance of conformance to
internationally recognized standards.