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Why You Need to Record Non-Conformance Data & How to Improve Your Systems
Mike Koeris

By: Mike Koeris on July 26th, 2017

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Why You Need to Record Non-Conformance Data & How to Improve Your Systems

Food Safety Testing  |  FSMA  |  Food Safety

Managing non-conformances is a complex effort, made even more challenging and complex with new food safety requirements. Executing corrective actions well and in a timely manner though is critical to both being compliant with regulations as well as continuously improving your operations to reduce brand risk. As FSMA continues to roll out and necessitate a proactive focus on contamination prevention, one of your top concerns must be to implement preventive controls that meet government provisions. You can’t expect to accomplish this objective without arming your team with the right tools for the job; tools that give them the right data at the right time!

The FDA’s final rules for preventive controls in both human and animal foods requires facilities to monitor for hazards and employ preventive controls to mitigate pathogens. What steps is your plant taking to conduct proactive monitoring? Are you harvesting non-conformance data properly to log data and use it for continuous improvement? Are you using it to consistently evaluate your processes and revise those that are causing noncompliance and food safety problems?

How your company manages its non-conformances can either support or hinder the effectiveness of a continuous improvement process and the ability to comply with food safety mandates. This article explain why recording non-conformance data is so important and offers impactful guidance on enhancing your systems.

Is Your EMP Ready for FSMA?

The True Value of Non-Conformance Data

You have an obligation to your customers, the government and, ultimately, your brand to ensure the safety of your products. This isn’t just about protecting yourself from an FDA audit; it’s also about protecting the legitimacy and trustworthiness of your brand. When you have recalls, noncompliance issues and other food safety concerns compromising your brand, you put the very existence of your entire business at risk.

Therefore, whenever a failure to meet the requirements of your food safety obligations occurs within your process, it is essential to collect that information and take advantage of it to the fullest. The ability to automatically record, access and evaluate non-conformance data empowers your team to make informed decisions, take required actions and be truly proactive rather than reactive.

How can you ensure that you’re meeting food safety compliance needs if you have no visibility into the effectiveness of your plans? How can you take steps to improve your approach if you’re not harnessing the data that reveals your weaknesses? The answer: You can’t.

How Data Fuels Preventive Controls and Corrective Actions

Your strategies and methods for food safety and compliance are not sufficient if they’re not proactive. Period. And this proactive mentality relies on having a strong environmental monitoring program (EMP) in place. But for any EMP to be truly effective, it must facilitate a high level of data tracking, visibility and communication.

For any multi-department, multi-system operation to enable the kind of powerful communication and robust visibility that’s required to address preventive controls and corrective actions appropriately, automated tracking of non-conformance data is vital. This is the only way to:

  • Visualize your preventive control points
  • Quickly identify locations and patterns that require attention
  • Keep the team apprised of important alerts and information regarding non-conformances
  • Respond efficiently to food safety hazards
  • Manage recalls properly
  • Supply the necessary documentation in the event of an audit

Data tracking should never be an afterthought in your food safety strategies. In fact, it needs to be a top driver of your efforts. The preventive control and corrective action tactics needed to meet food safety compliance requirements and elevate your brand depend on it. So be sure to consider whether your existing solutions are enabling this kind of data tracking and visibility.

Are they enough to keep your preventive controls program  in check and meet tough food safety regulations? Or are they obstructing your ability to comply with FSMA and safeguard your reputation?

3 Major Keys to Process Improvement

Continuous process improvement is fundamental to adopting the proactive approach required by the FDA for better food safety assurance. By leveraging your non-conformance data, you have a much stronger position from which to improve your processes and protect your brand. Your corporate strategy should unite everyone in your operation toward a common goal, and it should integrate these three keys to success:


1. Data Collection

Non-conformance data can be compiled through a number of sources, including sample test results, audits and informal observations. You must institute a data management solution that streamlines the collection process across all channels. Unless your team is armed with the requisite tools to contribute effectively to food safety processes, you’ll continue risking detrimental outcomes like steep noncompliance penalties and eroded trust in your brand. Ensure that you employ an intuitive, automated data management and decision support solution that supports (rather than impedes) your overall food safety and brand goals.

2. Data Analysis

As non-conformances are identified and recorded, you must be able to go beyond data collection to data analysis. This is the critical juncture at which you assess the information to discern root causes and underlying issues in your process that can be addressed and improved upon. Whether it’s a problem with equipment, sanitation efforts, human error or something else, you’ve got to rely on the data to inform your decisions and actions.

To fully harness non-conformance data, you need to make assessment and reporting a routine practice, approaching your information with insightful questions that lead to valuable process improvements. This is a crucial step in rectifying problem areas and minimizing the risks and costs associated with ineffective methods.

3. Communication and Iteration

The fact is no one’s processes aren’t perfect. No organization runs a flawless operation. Therefore, non-conformances will always occur. It’s how you deal with them and make use of the data to improve your process that makes the difference between a strong brand protection program and a weak one. With the benefit of data collection and analysis, you can effectively communicate with your team and execute process iterations that advance your objectives and promote a proactive food safety culture.

In order for any preventive controls program or food safety compliance plan to be effective, communication is paramount. Every member of your team, from upper management to the production line, needs to have clear visibility into and direct communication of the non-conformances that are jeopardizing the product at any stage of the process. Make sure you’re relying on an automated solution that can quickly relay this information, send critical alerts and notify the right people at the right time. This will strengthen every individual’s capacity to embrace process changes that generate improvement.  

Non-conformance data recording and management is just one important aspect of food safety compliance. Are there other areas in which your company may not be fully equipped to meet FSMA regulations? Take this free quiz to find out now


Is Your EMP Ready for FSMA?