Food safety regulations are driving organizations to seek more methods of enhancing visibility into their quality and safety operations to increase compliance and reduce risk. As this need evolves, the tools inherent in the Food Safety Management System are crucial in helping an organization take a proactive approach to preventing food safety risks.
What lessons can you learn by looking at and analyzing your non-conformance reports and how can you use these to better your food safety management programs?
LeAnn Chuboff, Senior Technical Director, SQFI, talked about using data within the food safety management system to prioritize food safety risks within your organization.
Speaking recently on the topic of How can Food Safety Management Systems Improve Compliance and Reduce Risk, Chuboff discussed the example of SQF analyzing a year’s worth of audit reports and non-conformances. Below are some excerpts.
“We asked ourselves the following questions: What area has the greatest impact to food safety – is this impact overall, major, minor or critical? What is one of the main reasons for recalls? What is the top major or critical non-conformances? And what is the frequently missed element? And we identified allergen management as the top area.”
Chuboff listed the key requirements for an allergen management program:
- The facility needs to have an allergen management program in place;
- The program should have cleaning and validation requirements in place;
- There should be a register of list of allergens maintained;
- And the allergen management program should be thoroughly addressed in the facility’s food safety plan.
On further analysis, SQF found that 84 percent of the facilities were missing an allergen program; 13 percent of the non-conformances were due to improper storage of the food products; the next issue was that facilities have improper labeling in place – 2 percent of non-conformances were due to labeling issues. And another problem was inadequately addressing rework.
So what can a supplier do in terms of corrective actions to address these non-conformances:
- Conduct validation study for SSOPs (validate it, test it, revalidate it) – if you don’t have in-house expertise, bring them in from outside;
- Identify ingredients as allergens at receiving, in process and rework – do a complete reassessment of the labeling program;
- Establish label inspection program at receipt and in packaging – work with raw material suppliers to ascertain that the labels are clearly specified, taking into account requirements of both the country that it’s produced in and the country it’s being shipped to;
- Include allergens in the facility’s HACCP plan; and
- Have a strong internal audit program – this will help you engage your employees, identify problems, and address them successfully.
What can auditors and scheme owners do?
- Support additional research for effective allergen control;
- Training and guidance for auditors and suppliers is needed for this sensitive area; and
- Work on providing stronger GFSI guidance?
In summary, Chuboff added that companies need to gather the right data, use the data available to identify areas of opportunity and establish KPIs; conduct a root cause analysis and use the tools available and work with all members on the team to develop a solution; avoid settling on simple solutions and immediate corrections and instead plan to get to the root; establish a preventive action plan for long-term control; and finally, repeat all the above!
To listen to Leann Chuboff talk more on this topic, click here.
