Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

FSVP: What Has Changed in the Re-proposed Rule?

By Sangita Viswanathan
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Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

In a recent FSMA Fridays webinar, Dr. David Acheson, and Melanie Neumann of The Acheson Group covered some of these changes and its impact on the food industry. Food Safety Tech presents some excerpts:

What is FSVP all about?

Dr. Acheson: The foreign supplier verification program is supply chain risk control for imported foods. Following the melamine in pet foods scandal that originated in China, the legislation was aimed at tightening preventive controls for imported foods. The rule concerns companies that import food from foreign manufacturers, and requires them to ensure that those suppliers are complaint with FDA requirements in the U.S. and thus, you are addressing risks along the supply chain.

How did the re-proposals change FVSP rules?

While there are several changes proposed, the entire substance of the FSVP rules haven’t changed as whole. Overall the changes seem to align the FSVP rule closer to the preventive controls rule in terms of wording and intent. Some of the changes include:

  • Approved Suppliers: As long as an importer can demonstrate that they have a process to approve suppliers, and that they follow it, there is no need for them to maintain a list of approved suppliers. However, this raises a question: If you don’t have a list of suppliers, do you know if your supplier is approved or not?
  • Supplier Risk: FDA now requires an evaluation of supplier risk along with product risk. Factors that should be considered include regulatory compliance, the history with the supplier (including test results and their willingness to correct problems), and any other relevant factors.
  • Audit requirements: In the original rules, FDA asked whether or not an initial audit and subsequent annual audits should be required when an importer identifies hazards that could cause serious adverse health consequences or death to humans or animals. In the supplement, FDA has basically said that yes, audits should be required under these circumstances, but has also given the flexibility in stating that if an importer can demonstrate that the risk can be managed in some other way, and that suppliers can be just as effectively verified through other means, then the importer is free to use other tools, or to decrease frequency of the audits.
  • Duplication of efforts: FDA will not require food manufacturing facilities who are subject to preventive controls (and who rely on suppliers to control significant hazards) to keep a whole additional plan in place to comply with FSVP.
  • Definition of very small importer: In the re-proposed rule, FDA has set $ 1 million in annual sales as the definition for very small importer, which aligns with the definition in the Preventive Controls rule.

Will food and beverage importers be expected to do onsite audits of foreign suppliers?

As described above, importers are supposed to do onsite audits, but only for significant hazards. Earlier FDA had provided two options. In the re-proposal, FDA seems to going with Option 1, which requires an annual audit for those supplier with significant hazards, but had added flexibility, by which the importer can determine another way of determining risk, or a less frequent audit schedule in lieu of that annual audit. But here’ the concern: While I embrace flexibility and decision making power at the industry or importer level, but there’s no objective bar set. The new requirement seems to say, ‘You have to do this, but you don’t have to do this, if you think you don’t have to do it!’ As a lawyer, looking at this in writing, it raises some flags about enforcement.

Click here for more on this exciting and evolving topic, including answers on where GFSI audits fit in, and what should U.S. importers be doing now to be ready to comply with FSVP requirements.

Shannon Cooksey, MS, PMP, Senior Director, Science Program Management at the Grocery Manufacturers Association

Food Safety Consortium Sneak Peek – Food Defense Rule

By Sangita Viswanathan
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Shannon Cooksey, MS, PMP, Senior Director, Science Program Management at the Grocery Manufacturers Association

The Food Safety Modernization Act is the first instance of codified food defense regulations. This discussion is a hard look at the proposed food defense requirements and examining what compliance may look like. 

At the upcoming Food Safety Consortium, to be held November 17-18 in Schaumburg, IL, Shannon Cooksey, MS, PMP, Senior Director, Science Program Management at the Grocery Manufacturers Association (GMA), will address the key takeaways associated with the proposed regulation.

Following this presentation, Sarah Sunday from Kraft will talk about challenges the industry will face in implementing the rule as written and how the industry currently addresses food safety.

In a chat with Food Safety Tech, Cooksey provides a sneak-peek into her presentation.

FST: How are Food Defense requirements evolving under proposed FSMA rules?

Cooksey: GMA led industry in developing comments on the proposed Food Defense rule earlier this year, specifically focusing two things: one, food defense is different from preventive controls and two, food defense cannot be prescriptive—it needs to be tied to a facility-specific risk evaluation. While FDA has not yet re-proposed new food defense language as part of the supplementals released on September 29 of this year, we have good reason to believe that FDA has shifted some of its positions in light of our comments. We also believe another opportunity to submit comments on a food defense supplemental proposal, similar to what was done with Preventive Controls, would be a valuable use of time for both the industry and the Agency as they move towards issuance of a final food defense rule in May of 2016.

FST: What are some things that companies need to keep in mind to be prepared to comply with these requirements?

Cooksey: While this is the first time food defense is being proposed as a regulation, there are already some existing training materials available to industry to begin developing food defense plans. Since the requirement to have someone specially trained in food defense will likely be part of the final rule, GMA recommends that companies start early and take advantage of the available materials already available. GMA and the GMA Science and Education Foundation are planning to release additional materials and courses in 2015.

FST: Who should attend this discussion, and how would they benefit from it?

Cooksey: Security specialists at the facility and corporate level regulatory affairs staff who oversee food defense and/or FSMA within their companies should attend. Also, food quality assurance and food safety managers will need to know how the food defense plan will work in combination with food safety plans.

Click here for more information on the Food Safety Consortium, and learn from over 75 of the Food Industry’s top food safety SMEs.

Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

Interview: “Look at your Food Safety Testing Needs, and Carefully Assess your Lab”

By Sangita Viswanathan
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Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

Food Safety Tech (FST): What’s so important about IS0 17025 accreditation?

Shaw: The ISO 17025 standard is a gold standard for lab quality. The standard is system based, and not prescriptive, so there can be a lot of differences in how it’s implemented. ISO requires you to have a procedure to do something, it doesn’t tell you what that procedure is. For instance, the standard requires you to have a procedure for customer complaints, however the lab can either have a very basic system of recording and investigating these complaints, or it could process that complaint and get to the root cause, and correct the nonconformance, so that the problem wouldn’t be repeated. Similarly when it comes to personnel requirements, the standard can be interpreted as having competent people on staff, or having elaborate six-week long training programs and documenting this.

FST: How does laboratory design impact microbiology operations?

Shaw: Lab design is very important from both an operation and quality point of view. It’s important to keep in mind that you are dealing with potentially dangerous pathogens and contaminants, and after you have prepped and enriched the sample, and it’s positive for a pathogen, you have a huge number of microorganisms in that sample. You have to make sure that this is not moved back into the lab. Thus lab design has to ensure single directional flow of sample from one side of the lab to the other side, with both sample and personnel moving along the clean to dirty direction. Once samples come in, are prepped, enriched, incubated, and then tested, positive samples then are a threat to the lab, and the environment, in case there’s a spill or a bad technique in place.

From an efficiency point of view, LEAN is a big concept now. So lab design, if done well, can help realize efficiencies in consumables, personnel, minimizing foot traffic etc. If everything is set up correctly – in terms of reagents, equipment, testing kits etc – then you can reduce time and effort spent in gathering samples, and moving around the lab. At Eurofins, we take this very seriously. We have a team that’s dedicated to lab design process and engineering around our workflow, and believe investing resources in the necessary software system LIMS to drive up efficiencies.

FST: How should high risk samples be treated? Should customers notify the lab of hot samples?

Shaw: There are two schools of thought about this. The first one is we want to treat all samples the same, so that we don’t bias the technician. We barcode all samples in the same way, test them in the same way.

On the other hand, we don’t want to open the lab to unnecessary risk, and contaminate the lab. So we handle high-risk samples differently, by taking extra precautions. Sometimes, a customer can bring in a sample and say it has Salmonella, and needs to be tested. We will still run the sample through the same procedure, but will separate it from the other batches. We also have to take care to schedule testing of these positive samples carefully such as moving it towards the end of a shift or break.

FST: With changing rules for food safety testing, what’s changing with regards to documentation?

Shaw: It’s important, as always, to record anything that can affect the result of a test. Also clear time stamps must be documentation. When things happened, who did the preparation of the sample, who analyzed the sample? Consumption of media, test kits, chemicals and agents, or anything that was used in the analys, all must be clearly recorded. In some labs, all of the documentation is still in paper, and hence is a very manual process, while other labs are highly digitized and have the ability to track a lot of this information electronically.

FST: What are some practical challenges that food safety testing lab typically encounter?

Shaw: Labs typically face challenges with result validation, typos in documenting test results, and customer requests around retest situations. When it comes to reporting, it’s important to have a number of eyes looking at your data, to make sure that it makes complete sense. For instance, if you are testing a product for coliform bacteria, and specifically for E.coli, then the latter number cannot be higher than the total coliform number. If there is, it means there’s an issue with the analysis.

Typos with lab results, sample number etc. are other issues that every lab suffers on a day to day basis. Fundamentally, humans make errors, but as technology evolves, and systems learn to interface better with each other, such errors can be minimized.

Another challenge relates to situations when we have released the CoA and then the customer calls us to modify the lot numbers. This is a gray area, and potentially could become problematic. In such situations, when the customer requires something to changed, it’s prudent to have some kind of documentation about this, clearly specifying that it was a customer-initiated request. Of course, such situations also have an ethical component to it, so they need to be handled carefully.

Accommodating requests for retesting samples can also be a challenge. For instance, you test a sample on Day 1, and are also to test again on Day 3, you could get different results. Getting similar results with microorganisms, even when the samples are homogenized etc., is challenging and not realistic if you consider that the microorganism could increase or decrease in those few days.

Overall, Shaw encourages food companies to take a careful look at their food safety testing needs and the lab’s abilities. “Don’t just accept an ISO certificate. Ask to look at the labs, their processes etc. Good labs will encourage that, while the not so robust ones, may not accept that request, even though they have an ISO certificate, and that, in my mind, should raise a red flag,” explains Shaw.

Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

FSMA and GFSI: Alignment and Gaps

By Sangita Viswanathan
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Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

A recent FSMA Fridays webinar, presented by SafetyChain and The Acheson Group, focused on the interesting topic of FSMA and GFSI: Alignment and Gaps. The discussion covered questions such as did FDA reinvent the wheel with FSMA, given GFSI? If you are GFSI certified, will you comply with all FSMA rules? What do you need to do in addition? Will FDA accept GFSI certification in lieu of an inspection?

David Acheson, M.D., and Jennifer McEntire, Ph.D., of The Acheson Group gave their perspective on where the rules and guidance shaping food safety programs in the industry are similar, and how they differ. We present below some excerpts.

Did FDA reinvent the wheel with FSMA, with GFSI already there?

Dr. Acheson: At a very fundamental level, GFSI is global and FSMA is more U.S.-centric, focused on protecting the American consumer. If you look back a few years, to the time when FSMA rules were being put together, there wasn’t clear understanding about the impact of GFSI and what it could accomplish. GFSI has evolved substantially since then, both in terms of the various standards, and in terms of the execution (preparing companies for audits and doing the actual audits). While there is a lot of alignment between FSMA proposed rules and the various GFSI guidance documents, I don’t think FDA reinvented the wheel with FSMA, which is more detailed, more prescriptive and U.S.-centric.

Which proposed rules are most similar to the GFSI guidance document, and which are different?

McEntire: If we consider the seven proposed rules under GFSI so far, and compare it with the different ‘scopes’ under GFSI, you can see within one scope several elements of FSMA rule:

Produce rule: In some areas what FDA is looking for is more prescriptive, more stringent than what GFSI has in their books, and in other areas, GFSI standard is more detailed. We need to remember that these are still ‘proposed’ rules, so it is hard to predict where FDA will land eventually.

Preventive controls: There is fairly strong alignment between this rule and GFSI. There is some minor differences, but the approach is quite similar.

Food defense: With this rule, you can see of the greater differences. Under FSMA, there’s a whole new rule, compared to just a few lines under GFSI for food defense. So FDA is more specific in what they are looking for and will expect food companies to do more work, over the GFSI scheme.

Sanitary transportation: FDA said they wanted to align with industry practices, and GFSI Logistics guidance for this rule. So broadly the requirements are consistent.

Foreign Supplier Verification Program: This is an interesting one, because there’s no GFSI call out for international versus domestic supplier. FDA is taking a more specific approach in what needs to be done to evaluate and verify foreign suppliers. In our mind, GFSI is taking a more appropriate approach, which FDA will need to consider, to include all suppliers, global or domestic.

There are other elements of GFSI that FDA has not issued rules such as traceability, but overall there’s general alignment between the two sets of food safety requirements.

When you look at some key differences, again, GFSI is global. FSMA more US focused. GFSI is more guidance documents and broad scope, while FSMA is actual rules.

When it comes to rule-specific differences, if you consider Preventive Controls, the proposed rule looks at it pretty comprehensively, not just at critical points. So while it’s aligned with HACCP principles, it builds on it, and goes beyond HACCP.

Also, there are some terminology differences: FDA calls the point person a ‘qualified individual.’ Each scheme has their own term for this person. Some standards require a team to evaluate – not just one individual.

Will FDA accept a certificate from one of the GFSI schemes instead of an inspection?

Dr. Acheson: This is a million dollar question and often asked. I feel if it is a full course inspection (based on a compliant, an RFR etc.), then no. FDA will want to do the inspection in order to do their regulatory job, as they are supposed to. Remember, there’s a lot of alignment between GFSI and FSMA, though it’s not a 100 percent. So will they accept a certificate in lieu of an inspection? Right now, no. but there will be a point, where FDA will take a certificate as recognition that a company is certified to a GFSI standard – and factor this in to a certain level, for instance, to determine who will get inspected this week versus next month. As the schemes evolve, and as GFSI becomes more aligned with FDA, keeping in mind that GFSI is intended to be more global than U.S. focused, if a company is certified against a GFSI standard, I think it’s likely that FDA will take it seriously.

McEntire: If a company is certified to a GFSI scheme, and is willing to share information of that certification process with FDA, it will go a long way in establishing credibility of the food safety and quality program. Of course, you need to keep in mind that the certificate is limited to that audit, which at best, is a snap shot of the company’s food safety management program a given time. Also, note that GFSI audits are currently announced, versus FDA inspections which are unannounced, where an inspector show s up at your door.

Broadly, if you are certified to a GFSI standard, you are in a good place to comply with FSMA rules, and in better shape than other companies who are not certified. But you need to read the rules, understand the rules, and see what additional things you need to do to be compliant.

Hear more about FSMA and GFSI – Alignment and Gaps, and what you need to do by clicking here.Next FSMA Fridays, on October 31, will cover Foreign Supplier Verification, Produce, Human and Animal Rules – 2nd Review Cycle – Part 2.

Gary Nowacki, CEO, TraceGains, Inc.

How Can You Improve Your Supplier Qualification and Management?

By Food Safety Tech Staff
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Gary Nowacki, CEO, TraceGains, Inc.

Proposed rules under Food Safety Modernization Act are putting new demands on food and beverage companies for prevention-based risk controls. FSMA specifically addresses issues related to this for both foreign and domestic suppliers. This is going to mean either allocating more people and more time or coming up with modern ways to address these increasing and emerging demands.

Gary Nowacki, CEO at TraceGains, Inc. will address the topic of Supplier Qualification and Management at Food Safety Tech’s Food Safety Consortium to be held next month in Chicago. He will speak about how companies are struggling with managing up-stream supplier and ingredient risk and how they can both save time and be more in control of these challenges by using powerful tools and techniques.

Nowacki says that often companies have partial information on necessary documents: “Previously, companies might have felt ok about having at least certain data on their suppliers. That’s not enough under FSMA and the increasing demands of GFSI schemes, audits, and auditors.” By automating tasks that free up valuable human resources to focus on more complex issues, says Nowacki.

Giving an example, he says think about automatically sending out notices to suppliers who are non-compliant on certain information or documents so that a valuable resource doesn’t have to waste time calling or emailing the suppliers.

The role of desk audits

Another way to strengthen supplier relationships is by doing desk audits, the topic that Chris Petrlik-Siegel, Supplier Quality Manager at TIC Gums, will address at the Food Safety Consortium.

In a desk audit, the auditor checks to see if a supplier’s system as documented meets the requirements of the GFSI code under which they are certified. It also confirms if the concerned person has validated and verified the Food Safety Plans and Food Quality Plans. The Desk Audit can be conducted as an off-site or on-site activity and issues found during the Desk Audit will be documented as non-conformities. Depending on the number and type of non-conformities documented, the audit will move to the next phase – the Facility Audit – or not move forward until and critical and major non-conformities identified are properly corrected and corrective action is verified.

“Desk audits are a great way to check how ready you are to be audited. These take a lot less time than an on-site audit, and really help in preparing for the actual audit. Desk audits are more to establish or strengthen the partnership with the supplier rather than to work on an audit for the purpose of complying with regulations,” says Petrlik-Siegel.

She explains that many times, a food company visits a supplier to do an audit, and realizes that it’s a waste of time due to lack of preparedness of the supplier. “Now due to new rules being proposed under FSMA, as an end product supplier, we are responsible for the ingredients in the products, and all the products we are importing from foreign suppliers. So we rely on in-depth audits to ensure that our suppliers have robust systems and procedures in place, in addition to what we follow in-house,” describes Petrlik-Siegel.

So with 70 suppliers, each on an average supplying about 10 ingredients, the Quality Manager stresses on the importance of desk audits preparing you for the final site audits, and also for better compliance with FSMA rules. It’s often overwhelming to do a thorough audit in a matter of one or two days, so it helps to look at documentation and identify any gaps ahead of time, Petrlik-Siegel adds.

Listen to Nowacki and Petrlik-Siegel speak about Supplier Qualification and Management at the Food Safety Consortium. Click here for more information and to register.

William L Michels, President, ISM Services

Managing Suppliers: Race to Win, Rather Than to the Bottom!

By Sangita Viswanathan
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William L Michels, President, ISM Services

Continued consolidation of the food supply base will lead to more powerful and assertive customers in some markets. These customers are placing increasing demand on the entire supply chain for reduced cost and higher levels of value delivery.

While many companies focus on price reduction as a solution, they soon realize that there is only so much supplier margin and they soon become in effective in trying to meet the increasing demands of the customer and company management. They also realize that there is a significant cost and time involved in changing and developing new suppliers.

The solution to increasing demand for value is to get business alignment across the entire supply chain, which requires value-based relationships. In an upcoming webinar presented by TraceGains, William L Michels, will speak about how a company can build such a process that delivers cost and value improvement year on year, and how you can better understand SRM (click here to register).

Michels is President of ISM Services, a specialty training & consulting company that focuses on procurement and supply chain management. In a chat with Food Safety Tech, Michels provided a sneak-peek into his presentation.

FST: Supplier Relationship Management is critical and challenging. What aspects of this will you be addressing in this webinar? Why are these important to food manufacturers today?

Michels: The food industry has been consolidating for some time, and now it is essential that food companies align with the suppliers that can meet their overall business goals for cost, quality, safety and value delivery. The drive for continued consolidation will ultimately impact supply chains leaving integrated, exclusive and competing supply chains. Only the leanest, most efficient, and aligned supply chains will provide maximum competitive advantage to the end customer.

In the past many companies have focused on price, but as buyers gain transparency on supply chain cost, yields and efficiency, they need to manage the supply chain and optimize value delivery. SRM is the process by which companies can integrate the supply chain and extract real value.

FST: In the webinar you will be speaking about how to identify which suppliers are good candidates for SRM. Can you give us an idea about that?

SRM is a resource-intensive investment with a big pay back, therefore, we need to align with the most strategic suppliers to assure that we can get the maximum value and competitive advantage. The webinar will provide a template for choosing the correct suppliers.

FST: What are some common SRM errors/ omissions that you notice? And how would your webinar help address these?

Companies fail to look beyond the immediate first tier supplier in the supply chain and fail to recognize all aspects of the relationship that will lead to competitive advantage for both firms. Through the SRM process, companies can improve speed to market, total cost of ownership, quality, availability, and risk management. The webinar will detail how every supplier in the supply chain can incrementally add value.

FST: How is SRM evolving and what does this mean to the food industry?

If food companies continue to focus on price, rather that cost and value, the food industry will not progress far. Driving already slim margins lower will not provide the necessary capital to invest, innovate, create new processes and add incremental value. By recognizing the need for transparency and linkages of business objectives across the supply base, there is an opportunity for true transformation. This is an evolutionary process.

Michels will talk more on this topic in the webinar. Click here for details and to register.

Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

How Effective is Your Cleaning and Sanitation Program?

By Sangita Viswanathan
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Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

Cleaning and sanitation programs are indispensable in a food manufacturing plant, as they assure the safety and quality of food being produced. These programs are also key in protecting the integrity of your brand. Because of these programs’ importance, 3M Food Safety sent out a survey this summer toFood Safety Tech readers to learn more about how their manufacturing plants are checked for cleaning and sanitation effectiveness.

Here is what we heard back from 155 respondents:

  • Only 5.8 percent do not perform any type of cleaning and sanitation validation program in their facilities.
  • Of the 94.2 percent that do have a cleaning and sanitation validation program in place, 92 percent use more than one method to verify cleaning and sanitation effectiveness.
  • The methods of choice in order of higher preference were: visual check (86.8 percent), microbial testing (80.5 percent), ATP swabs (70.1 percent) and protein swabs (25.7 percent).
  • The most used combination of tests was visual checks along with ATP swabs (70 percent).

Analyzing the survey results, Camila Gadotti, Professional Service Account Representative for 3M Food Safety Department was surprised there were still a proportion of respondents (though small) who didn’t have a cleaning and sanitation program in place. “This is such an important part of food safety and quality, and yet we still have some people who don’t have a program in place. Also majority of people still rely on visual check, which is not a good system for a sanitation program.”

Since respondents could check more than one choice for which method they used, a lot of people did visual check in conjunction with other microbial or ATP swab testing. Of these methods, Gadotti pointed out that microbial testing, given that it could take 24 to 48 hours to get results, would be a slow process. “In this time frame, the product could have been sold in the market. So while the test results could still be used for corrective steps to improve sanitation, it’s not the ideal choice for testing.”

Instead, ATP swabs would be a faster and more sensitive alternative, she adds. “ATP swabs work on the science that every live cell contains ATP. This is not just microbial cells, but also product residue, which will generate light based on the chemistry of the product. And results are back in 10 seconds. So you can walk around, collect swabs, put them in the illuminator, and you will very quickly get a number, which is the Relative Light Unit. If the RLU level is considered safe, the facility is clean.” With new and stricter regulations on the food industry horizon, companies are increasingly moving to adopt ATP swab for their sanitation programs, says Gadotti.

Besides which method to choose, another important step in creating a cleaning and sanitation validation plan is the number of sampling sites to be tested. Readers were asked how many locations they test for and there was a wide spread of answers:

  • 65.3 percent test between 5 to 20 different locations in their plants for cleaning and sanitation effectiveness;
  • 14.6 percent of the respondents test between 20 to 30 locations;
  • 6.2 percent of the respondents test between 30 to 40 locations;
  • 3.5 percent of the respondents test between 40 to 50 locations; and
  • 10.4 percent of the respondents test more than 50 locations.

The respondents of this survey work in facilities that range from fresh cut fruits and vegetables to dairy, confectionery, meat and poultry plants. Each of these facilities chose validation methods that were deemed appropriate to support their cleaning and sanitation plans in their manufacturing plants. Although some methods are more common than others, choosing the right method for each processing plant will depend on factors like the type of food being produced, turn-around time, product label claims and, of course, cost.

Another observation from the survey was that people still see verification of sanitation program as an expense. Instead companies need to view this as an investment for the company and its food safety program, Gadotti says.

“Verifying the effectiveness of your cleaning and sanitation program does not need to be a lengthy and troublesome task. Adopting a couple different methods of verification, such as visual checks, microbial testing and/or ATP swabs, tested for in a couple dozen strategic locations throughout your plant should suffice to verify that your plant has been properly cleaned and sanitized. Remember, verifying cleaning and sanitation may help you prevent many issues like reduced shelf-life in your products and unnecessary product recalls,” she sums up.

Gary Smith, Eurofins’ Food Safety Systems

Why Food Safety Training Fails, and What Can be Done?

By Sangita Viswanathan
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Gary Smith, Eurofins’ Food Safety Systems

The food industry has multiple levels of people involved, ranging from leadership and supervisors, all the way to line and front-end workers. Training, thus, has to not just give directions, but also provide better understanding of why we do what we are supposed to, says Gary Smith at Eurofins.

Smith, who leads the strategic development and oversight of Eurofins’ Food Safety Systems division, including auditing, certification, and training programs, says that “training for supervisors and leadership usually works well. But training workers is fraught with challenges. General training is focused more on giving directions, but not so much on providing understanding. People often skirt this rationale with the line workers, or it’s lost in translation, or missed out due to time constraints, turnover, vacation days etc. That’s where training fails.”

What would happen if we don’t spend this time address the ‘why’ behind training? People then get busy, and then miss out on steps and processes, and that causes problems, Smith replies. “It’s also critical to aim to strike a balance, for instance with line workers training – you have to ensure they understand the importance of what you are training them on, but at the same time, you cannot go too deep into the training, that would be either unnecessary or redundant.”

So what kind of training will continue to be the focus for the industry? The usual ones will continue to be important, according to Smith: Regulatory requirements for seafood, specific HACCP requirements for meat, HACCP training for employees directly responsible for food safety and quality, standards training; training for audits… For line workers, training also needs to cover specifics of their jobs, employee hygiene practices (for instance, why it’s important to wear gloves, hairnets etc.), and how to handle customer complaints.

Proposed rules under the Food Safety Modernization Act are having a positive impact on training needs, says Smith. “Everyone is now waiting for the final set of rules to be announced and implemented. A lot of good things are coming out of it, such focus on risk management and process control, understanding which products are high risk and low risk. FSMA has brought back HACCP for those industries that haven’t really had strict regulatory requirements for food safety – such as seafood, fresh produce, juice etc., or ready-to-eat products that may have escaped regulatory scrutiny in the past, such as fresh produce, and bakery products. Now the industry as a whole needs to focus on FSMA implementation, by companies helping its employees understand where the food safety risks are, how to manage them, document them, and mitigate them.

How can training help companies towards certification? When training leaders that are going to be implementing the food safety standards within their facility, it’s important to be comprehensive about understanding the specific standard. There is also the opportunity to focus on common non-conformances and say ‘this is where others have struggled and this is what you can do to avoid those non-conformances.’ Training can provide lessons, solutions and ideas to address common problems to addresses non-conformances before an audit. It can help drive continuous improvement, and help secure management commitment.

What are some of the common training themes that have resonated with Smith? He says that mostly employees bring up the issue of getting management to understand the need to focus on food safety training and procedures. “People who have attended my classes are usually struggling with getting management commitment. They are often told they need to be certified to a particular standard by end of the year, and so figure it out, but there’s no skin in the game from management. I help these trainees walk through the various steps that they can take to secure that commitment, how to talking their language in terms of more efficient production, and higher dollar savings etc.,” Smith describes.

Some challenges that he has observed in his years of training? Smith says that often times the trainers are great auditors, but poor trainers. “They will quote standards, and regulations. They are too black and white, and objective. However, training can have successful outcomes only when it’s practical and linked to real situations and ideas.”

Holly Mockus, Product Manager, Alchemy Systems

Real Training Needs – Time and Resources

By Holly Mockus
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Holly Mockus, Product Manager, Alchemy Systems

With the announcement on September 19, 2014 of the released re-proposals to the main FSMA-related rules – Preventive Controls for both Human and Animal Food, the Produce Safety Rule, and the Foreign Supplier Verification Program – it is time to take another look at the real need within the food industry related to training and education.

The word ‘train’ in some form or format appears over 100 times in the Produce Safety rule and the Preventive Controls for Human Food documents. One Hundred Times! This is clear indication that it’s time to take another look at the training programs in place today.

When asked, managers and supervisors responsible for training today typically respond that their biggest challenges or needs are having the time and resources available to conduct meaningful training for the workforce. Gone are the days where a ‘good’ training program consisted of shoehorning a training session into a segment of line downtime and hoping for enough time to cover all the learning objectives. As regulatory and customer emphasis on employee empowerment and engagement continues to escalate – food industry training programs must grow and evolve.

Here are some basic areas that need the proper time and resource dedication for maximum impact:

  • An analysis to determine gaps in the current training program should be very robust. Don’t skimp on the resources needed to do an effective job here. The use of this data is the first steps on the training journey and becomes the cornerstone as you build employee expertise.
  • The development of content should not be under resourced at any step in the process. Content is critical in providing the ‘How’ and the ‘Why’ (Who, Where, and When too). Worry less about fitting the material into a specific time slot and more about the quality and applicability for the specific workforce audience.
  • Partnering with a Subject Matter Expert or a content provider is an investment that will pay dividends as employees soak in the knowledge and ask for more.
  • Delivering the content in an environment that is conducive to group training where there are now distractions, all questions and answers can be heard by the participants in another resource that is critical to the success of a robust and effective program. Learning labs for more one-on-one self-directed learners are another means of providing knowledge to the workforce without having to incur line downtime. An investment that will pay for itself in a relatively short period of time.
  • Coaching employees for success in one of the best gifts that a supervisor or manager can provide. Constructively correcting incorrect behaviors and positively reinforcing good behaviors may take good people skills and a little extra time. Making it a habit costs very little and will provide a clear concise roadmap throughout the training process.

Training is a journey, not a destination. Teaching ‘how’ starts the journey – ‘why’ builds the culture. Spending time and resources for training should be a no-brainer for the food industry today. Stop looking at training as time spent losing operational effectiveness and start looking at training as the best investment you can make in your people, products and brands!

Hear the author speak more on Food Safety training at the Food Safety Consortium, November 17-18, 2014, Schaumburg, IL. Click here for more details and to register.

 

John Kukoly of BRC Global Standards

Where BRC is Going, and How Can You Get There?

By Sangita Viswanathan
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John Kukoly of BRC Global Standards

Food Safety Tech (FST): We’re very excited to have you participate in the SafetyChain/ FoodSafetyTech’s GFSI Leadership Webcast Series with the October 24 BRC – The Road Ahead webcast. We know that you’ll first be addressing what is new with BRC today. What are some of the things you’ll be talking about in terms of current changes?

Kukoly: We are just on the cusp of releasing Issue 7 for BRC. This is scheduled to be released in January 2015. With this, there will be some changes made to how food companies and facilities can obtain the BRC standard. We have a really unique system, termed BRC Participate, that we propose to unveil during this time, which I will talk about more during the webinar.

FST: We know that audits will be a topic of many questions. Is BRC planning changes to the way it does audits? What are some of audit-related topics you’ll be addressing in the webinar?

Kukoly: One of the changes I will be talking about is the auditor-competency program. Other topics will include expansion of our unannounced audit program. BRC is currently the leader in this area, and Wal-Mart has specifically asked us about this. We have done such audits in over 600 sites already, and are currently the go-to people for unannounced audits now. We are also forming BRC Global Markets, which will help small and less developed companies to get ready for certification.

FST: You will also be talking about the direction of BRC in 2015 and beyond? Is there a “theme” or specific set of business drivers that are driving future changes to BRC?

Kukoly: In my opinion, the two most critical areas of focus for the food industry right now are risk management and supplier management. These are the two main key elements being covered in all new regulations under development, and if a food facility has these covered, then they are in a good place. These are the two specific drivers that are shaping future changes to the BRC standard.

FST: While we all know that while change is important, it’s not always easy to get already-burdened food safety organizations to embrace change. What are some of the things we’ll learn in the webinar about why embracing change is critical to the ongoing success of BRC certification?

Kukoly: I don’t think ‘why’ should be the right question. We should focus on ‘HOW’ to go about this. And I think we need to talk about food safety culture and change management. These are the areas that are key to success and embracing change.

FST: We know that you’ll be providing advice on how companies can start today to prepare for tomorrow’s BRC. Can you tell us some of the topics you’ll be addressing in this part of the webinar?

Kukoly: One of the topics I will be addressing is training, not necessarily for BRC, but for obtaining the right skill sets such as risk assessment or HACCP. These are necessary for any food manufacturing organization to prepare for tomorrow’s BRC, and to have robust systems and processes in place.

FST: It has been said that GFSI certification is a very good start to preparing for FSMA compliance. What are some of the key points you’ll be addressing when it comes to FSMA compliance and alignment with BRC?

Kukoly: If you look at FSMA expectations, they are very well aligned with requirements of BRC standards, whether it be supplier management and verification requirements, or risk assessment etc. Beyond that, it is about strength of traceability procedures, knowledge of FSMA within the facility and its qualified individual. The focus is primarily on robust supplier management programs and implementation. If all these are in place, then you are in a very good starting place for FSMA compliance.

Listen to John Kukoly talk more on these topics and take your questions live in the BRC – The Road Ahead webinar on Friday, October 24, 2014 at 10:00 PT/ 1:00 ET. Click here to register.