The most recent versions of the GFSI have intensified the importance of training in determining risk assessment, for seemingly obvious reasons. Poor training—or lack of training—places the plant and the company at risk for everything from non-conformance findings to product recalls and potential issues with public health.
Customers are also driving the growing emphasis on food safety training by demanding that processors and manufacturers achieve certification in schemes that meet GFSI standards, usually within certain time limits. That poses a particular problem for plants that have consistently allowed individual departments to set their own training standards. In these plants, particularly multisite facilities, there is little uniformity, and documentation is often sporadic, insufficient, and, in a few cases, non-existent.
The decades-old training procedure in which plants relied on instructors, general question-and-answer exams, and employee signatures as proof that effective training has been conducted, with little or no documented evidence of comprehension, is not considered satisfactory in light of this renewed emphasis. It is much harder to achieve certification in any of the acceptable schemes, including the British Retail Consortium, Safe Quality Food, or Food Safety System Certification 22000.
To meet the standards imposed by GFSI Versions 6 and 6.1, plants need a thorough documentation process that verifies training and comprehension in a unified and standardized manner, even for companies with multiple sites. A sophisticated automated and interactive technology offers the most workable and unifying solution to accomplish this goal.
It should be understood at the outset that GFSI does not dictate policy for food safety standards. As explained on the organization’s website, the GFSI Guidance Document is “a template against which food safety management schemes can be benchmarked and recognised as science-based, contemporary, and rigorous.” The approved schemes set precise certification standards that align with those of GFSI.
GFSI schemes and benchmarks are drivers for increased and enhanced protocols. One notable consequence of these more intensive standards is the fact that auditors are questioning more individual employees to assess whether they fully understand and apply the concepts they have been taught on the job. Unfortunately, there have been a number of non-conformance findings because of insufficient or erroneous responses to those questions.
The persistence of work issues involving temporary employees, along with troubling rates of fundamental good manufacturing practice non-compliances, should be viewed for what they are — symptoms of training-related issues and broad indicators that a plant has a less-than-acceptable food safety culture. It’s an intolerable situation that has to be rectified, starting with a thorough analysis of the training program.
“It’s especially challenging for temporary workers or seasonal workers, but their training is critical to a company’s success,” said George Gansner, director of global marketing and business development, International Featured Standards, North America.
At the same time, multisite food processing and manufacturing companies are recognizing that training requires a corporation-wide view. That is, independent plants that have long trained according to their own procedures will have to be standardized so that training practices and protocols are optimized at every facility.
Just as important is buy-in from senior management, which Gansner said has to be “in tune with how their food safety systems are managed.” Gansner said IFS, which has a scheme benchmarked by GFSI, integrates management practices because “integration provides a safe quality food product throughout the business.”
When the process is not fully integrated and is left to each plant’s discretion, issues are bound to flare up, and training lapses may be among the fundamental causes. A multisite company that experiences such headache-inducing and budget-busting issues as recalls, customer complaints, downtime, and market withdrawals will most certainly launch an internal analysis, which is likely to uncover some form of disconnect between training and plant floor performance.
The persistence of work issues involving temporary employees, along with troubling rates of fundamental good manufacturing practice non-compliances, should be viewed for what they are—symptoms of training-related issues and broad indicators that a plant has a less-than-acceptable food safety culture. It’s an intolerable situation that has to be rectified, starting with a thorough analysis of the training program.
Root cause analysis of plant-wide operations is not just an option. It’s a requirement set by such GFSI benchmarked schemes as SQF and BRC. RCA is a top-to-bottom examination of every causal element behind a potentially dangerous outcome such as food contamination. Every aspect of every operation has to be examined, and that includes training.
The analysis can look at different training parameters in each department and determine whether they are inconsistent with the plant or with different sites within the company. A signed document showing that training has been conducted is insufficient in and of itself, unless there is further proof of learning and comprehension. A successful food safety culture in general, and scheme certification and compliance in particular, demand irrefutable proof of training consistency, comprehension, and application. The increased scrutiny of documentation and the rest of the training process has triggered many quality assurance and human resource directors to seek tools to meet these growing demands. That is where technology comes into play.
Today’s highly sophisticated platforms have been designed to help food processing and manufacturing plants meet the new standards demanded by GFSI. One of the most important offerings in these platforms is unification of documentation that verifies a consistent methodology in training at every site of a company and, equally important, within each plant.
Plants cannot afford to accept outdated training programs in departments like quality assurance and human resources. Instead, current and optimized training and comprehension can be brought under the umbrella of a technological platform that is thorough, standardizes the training, and is easily accessible to management, trainers, and auditors. These systems can integrate training in previously disparate areas such as standard operating procedures, food safety, and workplace safety. Even individual employee lesson plans can be coordinated among plant departments or multisite facilities. These lesson plans are easily created and tracked with reporting tools for managers to monitor training progress, ensuring a smooth audit outcome.
One of the best examples of the value of a unified, standardized, and consistent training protocol at multisite food manufacturing facilities can be found at ConAgra Mills, which operates 23 food manufacturing locations in the United States and Puerto Rico. ConAgra Mills is BRC certified.
“All of our training is uniform across the plants, and we use business processes to train approximately 800 people,” said Brandon Headlee, ConAgra Mills’ director of quality. “We want to keep our product safe by ensuring employees are properly trained and educated in business process and food safety systems.”
Headlee said technology has played an important role in training and auditor verification. The company has used a technological platform for more than three years and has been pleased with results. Headlee said the platform “makes it simpler and easier to audit against and verify that training has been done.”
Headlee also acknowledged that auditors have commented on the quickness of the system and ease of access for documentation. Most of all, their personal interviews of employees have verified that workers understand what has been taught and what they are expected to do.
“Everybody gets the same training and it’s validated because auditors get the same answer and the right answer,” Headlee said. “There are no blank stares.”
As ConAgra’s experience demonstrates, today’s automated technology is an excellent tool for development of best practices in food safety training and comprehension. It affords independent plants the opportunity to share training programs that were limited to their sister plant operations and synergize them.
Everything from protocols to uniform standard operating procedures to documentation can be analyzed and mined for best practices. The next step is to standardize them throughout the corporation. There are commonalities to be found at the various plants, and they can be leveraged to help facilitate those scheme certifications essential for meeting GFSI and the demands of customers who insist on GFSI standards for their suppliers.
Training is fundamental to establishing a food safety culture, without which efforts to meet compliance with GFSI standards are likely to be inadequate. That is why it is important for every quality control and human resource manager to recognize the imperative of reviewing the effectiveness of their current training program and seek changes and tools to optimize their training practices throughout the organization.
Unifying training to meet these upgraded standards is an urgent goal, and meeting this goal is best accomplished using today’s comprehensive technology, which removes inconsistencies and alleviates deficiencies in safety and training—especially lack of comprehension. GFSI’s approved schemes require such proof. A food safety culture demands it.
Laura Dunn Nelson is director of industry relations for Alchemy Systems, LP, an Austin, Texas-based company that creates and globally markets highly interactive training products that use technology and media to educate individuals and groups. Reach her by phone at (254) 965-8563 or e-mail at firstname.lastname@example.org. Visit the company’s website at www.alchemysystems.com.