Food Safety Management System – A less chaotic approach to food safety
Food safety doesn’t exist in a bubble – a butterfly flaps its wings in Texas and a Listeria outbreak hits South Africa. Okay, maybe food safety isn’t interconnected to that extreme, however, food safety doesn’t only exist in a HACCP plan and isn’t strictly the responsibility of Quality Assurance personnel. As all activities carried out in a manufacturing site impact food safety, a company-wide food safety management system is key to ensuring that all personnel are working toward the same food safety goals. Critical components of a food safety management system include planning, implementing the plan, evaluating the performance of the plan and making adjustments to the management system. Each of these elements will be discussed in further detail, however, it’s important to highlight that a management system is never complete. The final phase discussed is adjusting the plan. Those adjustments feedback into the planning phase and the process is repeated. Adjusting the management plan could also be termed “improvement.” The ultimate goal of a management system is to have all departments/personnel working toward the same goals and to continually improve the performance of one’s food safety system.
Planning phase consists of first establishing objectives of the food safety management system. These objectives should be SMART – Specific, Measurable, Attainable, Relevant and Time-bound. When establishing objectives it is important to consider food safety parameters important to the manufacturing environment. It is common for sites to identify customer complaints and internal audit performance as objectives. Are these truly the best indicators of the overall performance of the food safety management system? Do these objectives provide the focus necessary to improve an environmental monitoring or pest control program? It’s unlikely that a site has sufficient customer complaints regarding Listeria or pests to use this data to improve their system.
Once objectives are identified, the policies, procedures, and responsibilities for achieving these objectives need to be defined. This should include training responsible personnel, defining work instructions, identifying data that is required to be collected, how this data will be structured, how this data will be analyzed, how changes will be implemented and validated and how data will be used to improve the overall system.
Implementing the Plan
Implementation of the plan is fairly straight forward, the plan needs to be implemented. Included in implementation is verifying that the plan is implemented as intended.
Evaluating the Plan
Once a plan is established and time-bound objectives are in place, data is collected during the implementation phase. This data should be reviewed periodically to determine whether the site is on track to meeting their objectives or whether adjustments can be made to the plan to improve overall performance. This phase would also include validation of the efficacy of the policies and procedures to achieve desired results.
Adjusting the plan
At this point a plan has been put into action, data has been received regarding the performance of the plan and the opportunities for improving the food safety plans are identified. The next step is to use the available information to adjust/improve the original plan. Included in these adjustments would be re-evaluating objectives, training requirements and policies and procedures by which the site intends to achieve these objectives.
Objective: Reduce Listeria positives by 15% over the next 12 months.
Considerations when constructing a plan of action: Where are our current positives coming from? Potential for listeria being introduced via raw materials and ingredients. How do maintenance activities impact Listeria in the facility? Are traffic patterns sufficient? Are management traffic patterns sufficient? Have we evaluated equipment and structures for niche areas? How can we improve our sanitation practices?
After all areas which may impact Listeria are considered, a plan needs to be developed which addresses areas of concern and defines how data will be gathered and analyzed.
Next implement the plan, collect data, verify the plan is implemented as intended. Once data is collected, analyze the data. Is the site on pace to meet objectives? What actions taken seem have had a positive impact? Can these actions be furthered? What other improvements can we take? Do we need to change our objective for next year?
Once the questions are answered, improve the plan and continue with your environmental monitoring program.
Finally, it’s important to reiterate that this type of management system is not solely the responsibility of QA. In the aforementioned example, the Listeria control plan could include educating maintenance personnel on niche areas, evaluating maintenance activities on how they potentially impact environmental contamination, evaluating raw material receiving and storage practices, and challenging production management to monitor traffic patterns. Listeria control doesn’t exist solely in an environmental monitoring program and shouldn’t be just a “QA Thing.”