All the buzz about the Food Safety Modernization Act (FSMA) has led to some familiar approaches to meeting these new standards. In fact, FSMA implementation checklists have been created by dozens of consultants to help provide a clear path to compliance.
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It’s common knowledge that a qualified individual must be trained, knowledgeable, and accountable for the “new” food safety plan. Hazard Analysis and Critical Control Point (HACCP) documents need to be dusted off and re-assessed to include radiological hazards, environmental pathogens, pesticides, drug residues, and natural toxins, to name a few. Consideration must also include hazards that occur naturally, those that may be introduced into our operations unintentionally, as well as those introduced intentionally.
Once critical hazards are in sight, preventive controls need to be identified and implemented—strategies that assure risks will be mitigated. All this seems to provide a clear path to FSMA success…or does it?
If FSMA was the only regulation to contend with, this check-the-box approach might easily guide everyone. However, the reality is that food industry operations are more complex and demanding than ever. The Washington Examiner reported that the pace of agencies issuing new rules and regulations has hit a record high—21,000 new regulations have been introduced during the eight years of President Obama’s administration alone. Yet food companies’ business challenges go far beyond regulations. Equipment has become more complex, customer expectations more exacting, ingredient sourcing is now multifarious, and frontline workers are more diverse. The list goes on.
Don’t turn exclusively to consultants to develop a strategy. Take the path less traveled by harnessing the power of your best asset—your employees.
FSMA’s emphasis on preventive controls provides the perfect opportunity to dive deeper into true prevention by educating employees. Employee education helps workers identify risks introduced from critical areas like microbial niches, pooled water, and cross contamination. Their comprehension translates into keen awareness of emerging hazards at all levels of operations. Engaged, educated employees will begin to look for crimped equipment, rusted seams, drippy hoses, improperly stored sanitation equipment, effective handwashing, and so on. Having trained eyes focused on the critical risk areas within facilitates is a proactive approach to managing food safety concerns.
Sound too good to be true? Consider your own personal goals. What if you shared those goals with everyone around you and asked them to hold you accountable? Odds are you’d have a much better chance at success. Obtaining collective help from your frontline workers in identifying incremental challenges creates accountability from within and sustains food safety culture.
If this seems like a radical idea, understand that your employees want to help. During my auditing days, it was very common to have frontline workers pull me to the side and say, “Let me show you something.” They wanted me to document issues they had identified because they knew it had the potential to be a serious problem. Employees on the frontline have the advantage of experiencing trends and seeing differences from day to day, putting them in the unique position of being able to identify things that “don’t look right” before problems have a chance to turn into a serious food safety incident—or FSMA non-compliance.
It is important to train employees on how hazards are created and why hazards must be identified to achieve employee awareness. Expand employees’ knowledge of how allergens are inadvertently introduced into product, why damaged equipment is difficult to clean to prevent microbial growth, etc. In turn, your teams will be hyper-focused on reducing the root causes to food safety issues instead of firefighting while trying to meet FSMA standards.