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安全管理2:联合利华公司的食品安全管理体系Safety,Health & Environment in Unilever and with pecific Reference to Food Safety Our ApproachApproach 布朗 联合利华公司 安全与环境检测中心主任Structure of this presentation1. I will explain Unilevers Business organisation to you. 2. I will describe the various groups within the organisation that are involved in setting standards for Safety,Health & Environment and how they interact with each other. 3. I will explain to you how the standards are applied at Operating Company level and how they are audited. 4. I will go into a lot more detail about how one of the groups covered in 2 operates and will use some specific examples involving food safety to explain this. Most of my examples will be taken from the area of chemical contaminants (I am a chemist), but they could equally apply to other food safety areas, such as microbiology.Unilevers Structure Each of the two Divisions is divided into anumber of Categories. Unilevers Business CategoriesFoods Ice Cream Frozen Foods Tea Based Beverages Dressings Spreads & Cooking Products Savoury Food Service Beverages & Snacks Health & WellnessHome and Personal Care Laundry Hair Deodorants Household Care Oral Care Skincare Diversey LeverPrinciples of Unilevers Approach toSafety, Health And Environment Quality AssuranceThe setting of clear operating standards which are agreed at senior level.Backed up by:-Quality ControlThe implementation of procedures to check that the standards are being applied and that they are effective.Setting of standards for Safety Health and Environment (SHE) Safety Health and Environment (SHE) policies/standards are agreed at the highest level. They are owned by Unilevers Executive Committee (ExCo - top board directors) and apply across the Foods and HPC Businesses. ie. We take Safety, Health and Environmental issues VERY seriously. The standards cover:- Product Safety- Health and Safety at Work- Environment Aim of the StandardsTo PROTECTHUMAN HEALTHENVIRONMENTDevelopment of standards for Safety Health and Environment (SHE) Standards are developed by experts and are agreed by Unilevers Safety Health and Environment Action Committee (SHEACO) on behalf of ExCo. Environmental Strategy is developed by the Unilever Environmental Group (UEG) on behalf of ExCo. Providing important input into these and into other Safety and Environmental matters, is a large group of full -time experts based within the Safety & Environmental Assurance Centre (SEAC). I will deal with this group in much more detail later. Implementation of Safety, Healthand Environment StandardsThe individual Business Groups/Categories are responsible for implementation of the standardsPosition of SEAC in relation toSHEACO and UEGAll SHE Policies areunderwritten by ExCoSafety Health and Environment Action Committee (SHEACO) Representation of Unilever world-wide:- - Involves both Foods and HPC Divisions.- Involves all Business Groups.- Involves all staff groups - business and central experts (e.g. SEAC) Sets global standards; general, specific - non-negotiable. Provides guidelines. Assesses compliance through positive assurance. Corporate Audit as part of general auditing process- reports compliance into Unilever Chairmen. SHEACO Sub-CommitteesThere are 3 Sub-Committees of SHEACO:- Consumer Safety Sub-Committee. Occupational Safety Sub-Committee Environmental Protection Sub-Committee These 3 Sub-Committees draft many of the standards, guidance documents and factsheets for endorsement by the main SHEACO Committee. Unilever Environmental Group (UEG) Representation of Unilever world-wide:- - Involves both Foods and HPC Divisions.- Involves all Business Groups.- Involves all staff groups - business and central experts (eg SEAC), Owns Environmental Strategy on behalf of ExCo:- Strategy development.- Target setting.- Performance assessment. Responsible for annual environmental reporting- with external verification.Safety and Environmental AssuranceCentre (SEAC) Central resource for dealing with:-consumer safety-occupational safety-environmental protection Situated at Colworth House, UK. 250 Full Time experts in the disciplines of:- - toxicology, microbiology, chemistry, environmental sciences, engineering, life cycle analysis, medicine. Operates the mandatory safety approval system for new materials and supply chain technology. Provides pro-active and reactive support to the Unilever Business.Clearance Forecast and ApprovalClearance Forecast - An assessment made early on in the innovation process of whether Safety Approval is likely to be given and what work will be required to substantiate this. Approval- Final Approval prior to launch, based on Risk Assessments made on data obtained. Safe product designConsiders adverse effects on:-consumerwork forceenvironmentSEAC provides:Clearance Forecast,ApprovalSafe supply chain technology designConsiders adverse effects on:-consumerwork forceenvironmentSEAC provides:Clearance Forecast,ApprovalThis Contaminants case showsit can be complexApplication of Standards at Operating Company Level There are SHE co-ordinators within the various Business Groups (many are involved with SHEACO). Operating Companies must apply the agreed standards and have control procedure to demonstrate they are doing so. Many have their own on-site quality control labs (eg microbiology, analytical laboratories) to do this. Foods Quality Assurance Group carries out regular factory audits to ensure the standards are being applied. Factories not reaching agreed standards are reported. The setting of raw material specifications is being co-ordinated across Unilever. SEAC Structure and FunctionSEACs availability to the BusinessFor normal enquiries SEAC Enquiry Service Available during UK office hours and will pass enquiries onto relevant SEAC experts. Response is normally within 1 working day. In Emergencies SEAC Support ServiceAvailable 24hrs/day, 365 days/year to tackle important time critical issues. People are on permanent stand-by, on a rota basis and with sophisticated telecommunications back-up. Specific experts are also available via a telephone cascade system. Once products are on the marketExperts in SEAC continue to monitor the external world for issues that might affect our products, such as:- New Toxicological data. New Regulatory/Legislative positions. Planned Government Surveys and the results of these (eg Foods Standards Agency Food Surveillance Surveys in the UK). Position of Key Opinion Formers (eg Scientific Committee for Food) Public Opinion and Customer feedback We are alerted by agencies (eg UK Pesticides Safety Directorate) about contaminated commodities they have detected. As an exampleSome of The UK Foods Standards Agency Foods Surveillance Surveys to be carried out in 2001-2002 Survey of milk for Aflatoxin M1 and Ochratoxin A (Nov 2001). Dioxins and PCBs in shellfish (Jan 2002). Survey of paper and board for acrylamide monomer and migration into foodstuffs (March 2002). Lead and cadmium in foodstuffs not included in the draft EC Regulation on lead and cadmium Nov 2001). Survey of individual phthalates in fatty foods (Jan 2002).All Brand Names will be published for all these surveys As another exampleIn Oct 2000, the EC Scientific Steering Committee published alist of issues they considered as having the potential to impact human health. These included:-Comparing this with a number ofissues of current relevance to the food industry, there is avery good fit:- Infectious agents Natural toxins Antibiotic resistance Chemical pollution of the environment Bioterrorism Recycling of toxic substances Endocrine disruption Allergenicity Microbiology. DON, Aflatoxins etc. Veterinary drug residues. Pesticides, dioxins, polycyclic hydrocarbons. Malicious product tampering. DIPN etc in recycled board. Platicisers. Control of allergens in products. Our Involvement We are actively involved in monitoring and dealing with current and emerging issues that might affect Unilever. This involves:- Active participation with regulators, with scientific groups, with joint industry bodies etc to contribute to the scientific understanding of the issues and to discuss how to deal with them.- Where appropriate, the carrying out of experimental work in order to obtain data to assess whether issues are likely to have potential implications for Unilevers product portfolio. - Having processes and expertise in place for dealing promptly with issues that have become time critical. - Provision of advice and support to the Business based on the above activities. Some Examples of Pro-active Advice& Support to the Business Consumer Safety News - A SHEACO Bulletin which is sent out to SHE Co-ordinators and others each month, covering topical SHE issues which might have an impact on our Business. Chemical Contaminants in Foods Database:- Provides data on all strategic surveys carried out on contaminants in food raw materials.- Classifies situations as High, Medium and Low Risk based on Raw Material type, Type of Contaminant, and Source eg Black Tea + Organochlorine pesticides + India = High Risk Black Tea + Organochlorine pesticides + Indonesia = Low Risk Allergens Website - Very comprehensive support for the business on this subject.Our Commitment and Capabilities We have a great number experts, covering many different disciplines. These experts are highly experienced and are aware of all the major present and emerging issues We have a good depth of science, well-trained staff and “state of the art” laboratories & equipment. Some of our Equipment Gas Chromatographs with FID, ECD, FPD, NPD and other detection systems. High Performance Liquid Chromatographs with UV, Fluorescence, Diode Array and Refractive Index detection. Capillary Zone Electrophoresis. 9 Mass Spectrometers, including high resolution double focusing, triple quadrupole, ion trap, bench top etc. Access to HR-NMR (400-700MHz) and LC-NMR. Access to FT-IR/FT-Raman Spectrometers, Atomic Absorption and ICP Spectrometers, Transmission Electron Microscopes, Confocal Microscopes, Scanning Electron Microscopes and X-Ray Micro-Analysis. This represents an investment of several millionOur Measurement CapabilitiesI am a Chemist with a specific interest in the trace analysis of chemical contaminants. But what does trace mean? 25 years ago, the major contaminants of concern forthe food industry were pesticides, and our limit of determination was measured in terms of parts per billion. This is 1 part of a contaminant in 109 parts of product. We used to say that detection of a contaminant at this level was like trying to find one person in the population of China! We now need to have a detection capability for some classes of contaminants (eg dioxins) measured in terms of parts per quadrillion, which is 1 part of contaminant in 1015 of product. So what is this like?Its Like:- Trying to find one person in a population 200,000x that of the earth. Detecting and accurately measuring one drop of an impurity in a volume of 2 million (5000 gallon) petrol tankers. The thickness of a piece of paper compared with the distance between the earth and the sun. So its quite easy really!So what sorts of things do we usethis capability on? Parts per billion levels of detection are required for most of the chemical contaminants of interest to the foods industry. Dioxins are the most obvious class of compounds where we need parts per quadrillion levels of detection because :- - Of their toxicity- There 17 different dioxins and furans which have significant “dioxin-like” toxicity, all of which need to be analysed for. Food taints (off-flavours) is an area requiring almost this level of sensitivity. Until the taint has been identified and quantified, it is not clear whether it represents a quality issue, or a safety issue, or both. An Example of a Food Taint Problem3rd Party Supplier WarehouseStored in paper sacks on wooden pallets.Unilever Manufacturer of a beer clarification product.Supplied to a German Brewery - used to clarify beer.1 million bottles of beer so badly tainted that it is undrinkable!Action Taken etcPrior to SEAC becoming involved Samples of beer and of clarification product sent to four universities and contract analytical laboratories - none of them was able to identify what was causing the problem. After SEAC became involved The smell of the taint implicated either a trichloro-phenol or anisole as the likely cause. Trichlorophenols are used as wood preservatives and the wooden pallets were thought a possible source, but none could be found. Tribromophenols are also listed as wood preservatives, so we looked for these compounds in the clarification product with our equipped tuned to maximum sensitivity for these compounds. 2,4,6-Tribromophenol was found in the clarification product and later in the wood from the pallets. 2,4,6-Tribromoanisole was then found in the beer. Production of Taint From Wood Preservative2,4,6 -Tribromophenol- Wood Preservativetransferred from pallets to clarification product.2,4,6 -TribromoanisoleTaint Threshold = 4pptFound in beer = 10ppt!Another example where the humannose is invaluable Therefore, wood smoke smell = possiblemicrobiological spoilageOur Capabilities In The Area ofPhysical ContaminantsIn the unlikely event of being faced with a physical contaminant issue:- FT-IR allows us to quickly identify organic contaminants such as plastics. Various microscopy techniques allow us to easily identify objects such as plant debris (leaf or ear of corn etc). X-Ray Microanalysis allows us to identify types of stainless steel, types of glass etc just like the forensic science service. This information would enable us to quickly identify the source of the physical contaminant and eliminate it. Some of the issues are very complex!Example 1 - Di-isopropylnapthalene(DIPN) in recycled boardThis is DIPN, which is used as a solvent in carbonless copy paperFacts DIPN finds its way into recycled board because it is difficult to eliminate carbonless paper from the paper recycling process. It has been shown that DIPN can migrate from primary recycled board into food products. If recycled board is stored or used in conjunction with virgin board (eg as secondary/tertiary packaging), DIPN can migrate from the recycled board to the virgin board. There is some evidence that DIPN can even pass through plastic barrier material. Attempts to eliminate DIPN from recycled board, either by trying to sort waste paper/board, or by trying to extract the DIPN out as part of the recycling process have been shown to be not feasible. There is no evidence to suggest that the DIPN levels found in foodstuffs constitute a health hazard. Switching to virgin board would increase both the ecological problems and the costs. It may well not have much effect on DIPN levels because of the migration potential. Similar arguments apply to use of barrier materials. Example 2-DioxinsFacts Dioxins are highly toxic materials that are ubiquitous in the environment, generally at ppq/ppt levels. They are therefore present, at low levels, in the food chain and they tend to concentrate in fatty substances (eg milk) beca

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