The Maggi noodles controversy is a textbook case study on how popular brands are vulnerable to the risk of a sudden erosion of customer trust. You can count on the Peter Principle — if something can go wrong, it most certainly will — to kick in at some point. The episode is instructive of what managements, when faced with such a challenge, should and should not do. That said, it is also a lesson in the design of management control systems for a regulatory agency with enforcement responsibilities such as the Food Safety and Standards Authority of India (FSSAI) and its regional counterparts.
The theoretical underpinnings of a good management control system have evolved over time. In the beginning it was thought of as nothing more than a rather simplistic model where outputs are measured against certain normative values and deviations flagged for investigation. This then leads to an investigation; a diagnosis of faults in the operations and putting in place corrective action so that output in the next cycle is brought within standard parameters.
Feedback is crucial
Over time, everything that could possibly go wrong in the process would have been identified and corrective measures put in place, so that performance would, in course of time, conform to the desired standard. In other words, ‘feedback’ is at the heart of any management control system.
The problem with this approach is that a lot of sub-standard output would have gone unnoticed and, in the process, affected customer trust in the output quality, which has been the focus of the ‘control’ system.
Think of it this way. You would much rather have two engines in an aircraft when you sit down to design one in the first place, rather than have an air crash, with the failure analysis concluding that it was too much of a risk to depend on the flawless performance of one engine all the time. Of course, you might still design a fighter aircraft with a single engine. But that is based on altogether different calculations about the output of a fighter aircraft system.
The emphasis in later years thus shifted from ‘feedback’ to a ‘feed-forward’ dimension, so that output is made to conform to the standard even as deviation is beginning to occur in the output. This is in contrast to allowing deviations to occur but take corrective action for the subsequent cycle of output.
Corrective mechanism
Of course, it is not always possible to anticipate every contingency and provide for a ‘feed-forward’ corrective mechanism within a management control system. But then, it was not as if India’s food safety enforcement faced so daunting a challenge that it would have tested its regulatory capability to the hilt. It was perfectly possible to conceive of a control system that demanded something more than what was on display in the Maggi case.
Going by news reports on the controversy, the country did had no protocol — at least none that was routinely enforced — on food safety. The exact nature of random samples that these products would be subjected to or the frequency with which safety tests would be carried out are questions for which there have been no clear answers. Neither, for that matter, is there clarity on the protocol for testing of food ingredients used in a processed food.
Indeed, had it not been for the extraordinary initiative on the part of a solitary food inspector, way down in the hierarchy and that too, in just one of the 22 States, the country would never have thought there are serious issues with food safety, not just in the case of one brand (‘Maggi’ noodles) but across an entire spectrum of packaged food products, both branded and unbranded.
By no stretch of imagination can we call a system that depended on nothing more than exceptional commitment to duty on the part of a lowly functionary in the food-safety enforcement regime, a well-structured management control system.
Clearly, the situation called for a comprehensive testing of cereals, vegetables and other food articles used in processed foods across the country.
Raw materials
Decades ago, this writer, quite early in his first job, had occasion to wander into the factory kitchen along with a colleague and chanced upon the staff stuffing mashed vegetables into what looked like square, thin pieces of tissue paper before being fried in oil.
Astonished at the fact (or so it seemed, at that time) that the employees could be fed with ‘samosas’ made of cellulosic material, we smuggled out two pieces of ‘samosas’ and gave it to the local public health laboratory for analysis.
The chief of the laboratory heard out our story and was sympathetic and understanding of our concerns. But he left us in no doubt whatsoever that we were holding the wrong end of the management control system stick, on food safety. He told us that what looked like tissue paper was actually flattened and dried pieces of dough made of highly refined wheat flour.
He added that even if those ‘samosas’ were rich in E-coli bacteria or any other harmful organisms, it doesn’t prove anything. The food stuff could have been contaminated any time in the last 24 hours after they were fried. He concluded with what seemed like sage advice not just on food safety but also insight on management system design with the words that it is far better to get the purity of raw material right (besides of course hygienic conditions in the kitchen) rather than worry about the quality of the end product.
Rigorous testing
If the raw material is safe and the kitchen staff are not germ carriers then frying ‘samosas’ in oil heated up to 120 degree Celsius pretty much takes care of everything else. Of course, we might still die of a heart attack from clogged arteries. But there is zero possibility of our dying of ‘Cholera’ or other intestinal disorder, he reassured us!
Even if the authorities aren’t able to enforce food safety standards at the farm gate, they can at least make a beginning with more rigorous testing of food ingredients at the manufacturing locations, both in the organised and unorganised sectors.
If the objective of the control system is ‘secure public health’ it lies not in setting up hospitals with state-of-the-art facilities and staffed with competent medical personnel, or even rigorous testing of food products after they are manufactured. The control could begin, for a start, with testing food ingredients at food processing units.