Developing, documenting, implementing, and maintaining the necessary documentation to properly maintain a food safety management system (FSMS) is an integral part of doing business for food processors, ingredient manufacturers, and packaging suppliers large and small. Yes, even the very small operator who might not be mandated to have such programs will, most likely, be asked to show it has a food safety system in place for its customers. The bottom line is fairly simple: Without a FSMS, a business will suffer and may even vanish. The expectation is each and every operation shall have a fully documented system that includes procedures, work instructions, and the necessary recordkeeping forms for all elements of the food safety plan.
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Creating procedures and implementing them is not easy nor is something that can be accomplished overnight. As an example, a company may have what it considers to be a well-documented FSMS, but updating that system to meet the requirements of one of the Global Food Safety Initiative management schemes or the ISO 22000 food safety standard could take 12-18 months (see Table 1). For a small company or startup that is developing everything from scratch, this is probably an unrealistic timeline. Why? The equation for building your program was highlighted above: development, documentation, implementation, and maintenance. Implementation includes the training element, which must be properly documented. This takes time, commitment, and lots of work. So, what can be done to help meet these challenges?
Meeting Challenges Head On
First and foremost, management must be committed to the project, which includes providing the necessary resources and support to get the work done. Management must also be patient since the work is not going to be completed overnight. The following steps will help overcome documentation challenges.
- Appoint a document control officer.
- Develop a standard format for procedures and work instructions.
- Create a master list of the programs that need to be documented.
- Develop a plan for developing these programs.
- Assign responsibility for developing protocols.
- Create the procedures.
Hiring or appointing a document control officer should be a task for top management and one that the food safety or quality manager needs to emphasize the importance of. Be cognizant of the fact that this would be a permanent appointment, not a temporary position. Document management will remain an ongoing task throughout the development process. The document control officer’s role is not to write the procedures but to manage the process of developing the necessary documents. He or she could be the quality manager, but that need not be the case. The document control officer could be someone from IT, but above all, must be someone who is organized and has computer skills. The document control officer should be responsible for:
- Ensuring all procedures and work instructions are created using the standard format;
- Ensuring documents are created by approved persons;
- Determining all new documents are reviewed and edited as needed;
- Tracking changes to existing documents;
- Tracking non-controlled documents;
- Maintaining a master log of all documents and records;
- Ensuring all new protocols and revisions have been properly reviewed and approved;
- Controlling distribution of new and/or revised documents and maintaining a record of distribution; and
- Collecting and destroying old documents and forms.
This is an ongoing task and not one that should be eliminated once the program is up and running.
Food processors need to create a standard form to be used for all procedures and work instructions. Table 2 is an example of what might be adopted. The standard should also include either a header or footer to indicate the procedure number, the date it was adopted, who created the document, and whether it is an original document or has been revised. One element many processors fail to do when developing procedures is include corrective actions. If product safety is potentially compromised, the corrective action needs to address how that product will be handled. For example, calibration is an essential program for ensuring that monitoring devices are working properly. If an instrument such as a temperature monitoring device is found to be out-of-calibration, there is a chance product safety was compromised. The calibration procedure must address that concern.