4 Mistakes You’re Making in Your Food Safety Program
Food Safety Magazine just released its annual article tallying the previous year’s food-related recalls announced by the U.S. Food and Drug Administration and the Department of Agriculture’s Food Safety and Inspection Service. 2018’s count amounted to 382 food product recalls, including some products that were recalled more than once.
From undeclared allergens to bacterial contamination and more, last year saw a seemingly continuous stream of supply chain hazards that resulted in foodborne illness outbreaks, voluntary company recalls and the FDA’s first-ever mandatory food recall.
What do these numbers reveal about the efficacy of the industry’s food safety programs? And what risk-prone mistakes might your company be making right now?
As the evolution of food safety continues to transform regulatory standards across the FDA, USDA, GFSI and other governing bodies, the task of maintaining compliance and mitigating brand-damaging food safety risks is becoming more complex than ever. Last year’s food recall numbers are proof that implementing a proactive food safety program is a real challenge for today’s manufacturing companies. From sanitation to documentation, there is a magnitude of opportunity for missteps to occur.
By arming yourself with comprehensive information, however, you can approach your food safety program from a more confident perspective. Check out four of the most common mistakes below, and leverage these insights to take smart action that helps reduce risk and meet all of your compliance obligations.
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Mistake #1: Documentation Mismanagement and Lack of Control
“The Global Food Safety Initiative (GFSI) is a global initiative for the continuous improvement of food safety management systems. From a functional standpoint, you might be surprised to learn that one of the most challenging elements of keeping up with GFSI compliance for many food producers is sufficient document control. In fact, data compiled by SQF shows that document control-related issues are one of the most common sources of a non-conformance during GFSI-benchmarked audits.” (Food Safety Tech)
The truth is lags and missteps in your documentation process will erode your food safety standards and negatively affect the outcomes. If you’re not leveraging a solution that supports strong documentation management and control, you’re putting the entire food safety program at risk. Consider these integral components of proper food safety documentation:
A successful food safety program necessitates a continuously thorough recordkeeping effort, which includes logical data archiving, comprehensive audit trail history and active reporting. If you’re working tirelessly to keep archives organized and up to date, you’re not utilizing the right kind of system.
Whether you’re managing a food safety program across one facility or many, there’s a lot of information to be stored, communicated, retrieved and reported on. This means there are multiple people inputting and accessing critical data related to your food safety and compliance efforts, so it’s paramount to enforce document controls that keep the information secure and standardized.
Undocumented actions and data points can cause major food safety complications down the road. Without complete visibility into the documentation efforts and oversights occurring at the plant level, you don’t have the support you need to safeguard your brand in the event of a recall and protect against food safety liabilities.
Given these realities, it’s essential to utilize a solution that eradicates the potential for documentation chaos, with capabilities for:
Streamlining documentation efforts
Fostering transparency and visibility across the plant
Easilying control document administration and accessibility
Unifying documentation between departments
Facilitating the audit process and complying with regulatory requirements
Eliminating redundancies and inefficiencies
Mistake #2: Insufficient Testing and Test-Scheduling Procedures
Positive testing results will inevitably occur, regardless of the prevention systems you have in place. That’s why it’s necessary to have a documented process for corrective actions, and that includes randomized testing. Unfortunately, a majority of food safety programs don’t have the tools to automatically generate schedules that support good coverage and optimal testing scenarios.
Within your program, you must be able to select appropriate sampling points and test them on a regular basis. To accomplish this, it’s essential to construct schedules using your business rules and best practices, focusing on components like:
Only a food safety solution with the means to enable testing schedule randomization can ensure the kind of strong testing point coverage to meet stringent regulatory standards. You need to be able to add test points from multiple zones or areas of the plant in a randomized fashion. The answer is a food safety solution that allows you to build a schedule “scenario” based on your business rules so that it can be used over and over again. Saved scenarios make the process of building recurring schedules much more efficient and effective.
Mistake #3: Manual, Error-Prone Labeling Methods
Under the Food Allergen Labeling and Consumer Protection Act (FALCPA), all foods regulated by the FDA are required to have certain food allergy labels. This accounts for about 80% of food manufactured for sale in the U.S. The labels must clearly state the food source names of all the ingredients that are or derive from the eight most common food allergens so that allergic consumers can actively avoid them. As a manufacturer, if you fail to properly state common allergens in your product, you risk criminal and civil penalties, product recalls and reputational damage.
“A single, standardized labeling solution, implemented and supported across an organization brings labeling under one platform. And when it’s tightly integrated with existing enterprise systems, you not only improve label accuracy, but you have a central “go-to” source to monitor, manage and control all the labeling — on the product itself, the carton, the pallet — from manufacturing to transport to the grocer’s shelves. Best of all, when regulations do change (as they always do!), you’ve simplified the process and narrowed it down to one solution where you can update and apply appropriate label changes.” (Manufacturing.net)
Mistake #4: Inadequate Employee Training
Your company’s manufacturing process relies on human effort, which always comes with a risk of error. Ensuring that your people are effectively trained can significantly reduce the possibility of human involvement becoming a massive liability for your brand.
“Food safety training protocols can only be implemented after an effective HACCP plan has been developed and instituted. Appropriate training, obviously, varies considerably from business to business, and adopting a one-size-fits-all program is a common mistake. You, and more importantly, your employees know your business the best, and the more that knowledge is deployed, the better your training and food safety record will perform. The single most important piece of a food safety training program is establishing company-wide buy-in. If top management views such a program as a mere regulatory obligation, employees will quickly get the message that paying lip service to training is adequate, and standards on the production floor will quickly slip.” (Food Safety Magazine)
Education and training must be a priority. It’s important to designate a team or individual to overseeing the training initiative and maintaining the company’s commitment to ongoing improvement. In every area of your production process, you should be confident that each employee is being comprehensively trained on:
Control point testing
With a proper training program in place, communication of food safety issues becomes a natural occurrence with more successful results. To support your training efforts, begin by developing written procedures that can be used as a reference for workers. As the food safety landscape transforms, regulations change and industry technology advances, it will be vital to adapt your strategies appropriately. Therefore, training should be ongoing and updated to reflect new information, requirements and approaches.
In the end, your goal is to avoid becoming the next news headline as a result of mistakes made in your food safety program. It is absolutely critical to ensure that your program is supported by a solution that gives you the insight and control to rectify these mistakes before they become major public health concerns or catalysts for reputational scars.
For more information on what you can do to reduce risk and protect your brand, download this free checklist now.
About David Hatch
Dave Hatch has spent over 30 years solving data management, information security and analytics challenges across multiple industries, including food/beverage, healthcare, publishing, manufacturing and financial services. As Chief Strategy Officer at Corvium, Dave focuses on the emerging digital transformation occurring in the food industry, and its impact on the advancement of food safety programs across the food supply chain.
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