We are beginning a new year, which often means it’s time for New Year’s Resolutions. For individuals, this often entails things like exercise regularly, lose 10 pounds, or get something fixed around the house. For food, beverage, and ingredient processors, the new year may involve implementation of new programs based on the previous year’s performance. Allow me to present 10 points (or resolutions) that might be considered as part of continually improving your food quality, safety, and sanitation programs.
1. A Commitment from Management
Management commitment is an essential element for ensuring the production of high quality, safe, and wholesome foods. Personally, I always felt it should have been included as one of the preliminary steps to Hazard Analysis and Critical Control Points (HACCP) as highlighted in the Codex HACCP document and those mandating the adoption of HACCP for seafood and juice. Management responsibility was also a key element of the ISO 22000:2005 standard and remains so in the updated 22000:2018 standard. All food, beverage, and ingredient processors should seriously consider incorporating the communication element into their food safety management system. Far too many operations do not establish formal, documented protocols for communication.
The importance of management taking an active and all-encompassing role in a food safety program may be demonstrated by looking at what happened to the top guy at Peanut Corp. of America. He is now behind bars for what may be the remainder of his life.
It is very obvious when management has a positive attitude toward food safety. That attitude echoes through the company as employees at all levels buy off on food safety. These operations are a pleasure to work with and the term “food safety culture” is simply part of everyday life, whether they call it that or not.
2. Welcome Third-Party Audits
Most operators are not overly thrilled about third-party audits. Many years ago, the National Food Processors Association safety audit was supposed to be the be-all and end-all for audits—an audit that would satisfy everyone. Today, the Global Food Safety Initiative (GFSI) audits are supposed to fill that role, yet many buyers do their own audits, so operators might end up having 10 or more audits over the course of a year.
Audits may be distasteful to some, but they should be treated as a learning tool and a means of improving operations. When I perform audits and am asked the question, “What do I need to pass?” my sense is that the company is not quite clear on the concept. Audits are supposed to be a check on how an operation is performing, that is, “Do you do what you say and say what you do?” Ideally, the auditor needs to look at what the company is doing and have the knowledge and experience to determine whether that is effective. Hopefully, your auditor is not simply filling out a checklist but digging down and looking at whether programs are both comprehensive and effective. Auditors are not supposed to consult, but there is nothing wrong with picking their brains when on site. The auditor may have observed things elsewhere that can benefit you.
3. Appoint a Document Control Officer
With the emphasis on documentation in the GFSI audit schemes, ISO 22000, and the Preventive Controls for Human Food regulation in the U.S., documentation is an absolute must to pass audits and ensure regulatory compliance. Documentation must include procedures, work instructions, and development of forms for record maintenance. The company must develop the protocols, properly document them utilizing a standard format, implement the protocols including proper use of any recordkeeping forms, and maintain programs—that is, make sure the system is working.