Ten Commandments – Food Safety Management
You have seen the ten commandments in your spiritual life but what about the food safety life?
As we all know, the DoJ has stepped into the food industry and they can seek to prosecute cases where illnesses have occurred – restaurant companies, manufacturers, etc. Our consumers are demanding “cleaner” products as they eat out or purchase their food. With the science of genome sequencing, it’s possible to link illnesses from years earlier to their source, meaning a past incident can come back to haunt a company – long after the event.
Food Safety Modernization Act (FSMA) – based regulations are here. The first impression that restaurants and grocery stores would not be impacted is now becoming clear that the ripple effect of FSMA will increase the food safety demands on them as well. FDA has written the rules for some flexibility – which is causing significant confusion and it carries the risk of many in the industry getting something wrong and placing considerable and unnecessary strain on already overburdened QA professionals.
Therefore, the food safety professionals cannot manage food safety program in the same old way. There has never been a more important time to stop, take a critical and unbiased view of the food safety management systems and processes, and emulate best practices being used in the industry.
Follow these 10 simple commandments:
- Senior Leadership Team on your side
Senior leadership want to know: ROI, key issues and plans to address those, business trending, strategies employed to move the business in the right direction, and how the quality and food safety strategies support business strategies and objectives. These strategies are always focused on the customer.
Be clear with the senior leaders’ group about the investment required in food safety, and the benefits gained through the investment. As we all know, the investment is significantly less costly than the problems. Provide simple but impactful food safety training to the senior leaders. This will highlight that effective food safety training is provided for every team member in the company.
- Suppliers audited
Regularly audit all suppliers, especially prior to their first delivery of items. Must review supplier’s track record so it can be established that appropriate systems and processes exist. The audits need to be structured so that all of the elements supporting the supplier’s ability to reliably meet all the quality and food safety requirements are checked, and where deficiencies are found, formal corrective actions are established. There are a number of good auditing schemes in widespread use, accredited under the Global Food Safety Initiative (GFSI).
Best practice in this area: Obtain full copy of every audit, review the audit outcomes to establish that risks are effectively identified and managed; and ensure that corrective actions requested by the auditor are resolved in a timely manner.
- Supplier Specifications
To ensure consistency of the items you are using in your restaurant, specification is required for most items.
The specification should include the chemical, physical, and biological parameters the supplier has promised to comply with to ensure the item is safe. The specification should also contain a full ingredient list of the product, including the presence or otherwise of any allergens. This is essential to enable rapid investigation of the presence of a particular ingredient of concern that may be subject of a wider recall.
- Supplier Performance
Supplier audit is merely a point-in-time assessment, and may or may not reflect the typical week-to-week performance of a given supplier. Be sure to include conformance to specifications, the number and rate of corrective actions and timely responses to measure performance. The best industry practice is to keep your dialogue and communication with the suppliers – – fact based; transparently providing comments to the supplier on their actual performance.
- Risk Assessment and Preventative Controls
Hazard Analysis and Critical Control Point (HACCP) is used on a voluntary basis by few operators, though not currently required. The HACCP process identifies all hazards that may exist and clarifies the point at which the hazard can be managed or controlled. This process prevents the hazard: a) from entering the food, b) eliminating it in product, or c) reducing it to acceptable levels.
FSMA’s requires for the supplier to identify particular hazard, if not controlled by their process. In this case, they must advise users of their non-compliance in writing.
Restaurants must acknowledge that items such as raw meats, fresh produce, and many other items contain hazards, and take on the responsibility for controlling specific hazard. Implement HACCP (if possible) to ensure that the hazard is effectively controlled.
- Validate | Monitor | Document |
The validation step determines that the control measures put in place are scientifically sound and will control the identified hazard. Managers and team members are required to “monitor” the control measures to ensure the hazard is eliminated/controlled.
The best way to verify a restaurant’s plan is being followed is to document the evidence. One can also include a review of the execution and evidence for corrective actions being taken when control measures are out of compliance. Verification is providing proof that you are doing what you said you needed to.
- Corrective Actions
Organize workflow, take prompt and timely corrective action when something fails and always follow-up. Documentation of all the required communication of the details between the parties is very important. Train and re-train as necessary.
An arduous food safety management system ensures that everything is documented—a challenging task in today’s dynamic work environment because of pressure on new product development, constant change in the supplier world, pressure on value engineering, and staff turnover. For documentation to be truly effective, each element of data needs to be dated, and each action must be trackable. Thankfully, technology has changed, and in this cloud-based computing age and with the right software, data can be available to anyone who is authorized, from any device, at any time and from any location.
- Complaints and Social Media
While employee empowerment is a great approach to resolve complaints at the point of receipt, there must also be an entrenched process of identifying and resolving common causes. Social Media (Facebook, Twitter, Instagram, Snapchat, etc.) being used by the masses – can’t be ignored and must be effectively monitored and managed.
- Professional FTE
One must have a food safety professional on staff – company’s growth and future plans must include a FTE, if not already! Consultants can help and assist you and your team as well – but there are limitations to this.
In short: Almost 60% of all food borne illnesses in the US is caused by food consumed from a food service facility, the business must take every possible step to ensure brand protection and that all food served is safe to eat.