Strong Prerequisite Programs Half the Battle in FSMA Compliance
Having a strong prerequisite program is a key part of maintaining compliance with FSMA and food safety management systems standards. In a recent discussion with Food Safety Tech, Debby Newslow, president of DL Newslow & Associates gave a preview of some of the expertise that she will be sharing during her session at next week’s Food Safety Consortium, “Food Safety/HACCP Prerequisite Programs” (session takes place Thursday, November 19).
Food Safety Tech: What are some of the challenges that companies face in establishing prerequisite programs for HACCP?
Debby Newslow: Understanding the significance of the prerequisite program—a lot of times, employees are [going through the motions] of things like wearing hairnets or not wearing jewelry—but [they need to] understand why it’s important. There’s a weakness in the education of employees. We need to redefine the word “training”, because training should mean education, too and understanding the importance of it. Companies take it for granted—they have defined procedures that they may or may not follow. And the other challenge is commitment and an understanding from management as to why it’s important.
On Wednesday, November 18, Debby Newslow will participate in the Ask the Experts session, “Food Safety Training Challenges”. LEARN MOREFST: What are best practices that companies can implement in this area?
Newslow: They need a program established, along with commitment to and support from a food safety team that has a responsibility to the team to evaluate the effectiveness. They also need support from top management. Every group and department needs to understand their requirements and why they’re important. They need to have the tools and the knowledge to understand what’s needed. Through the food safety team or internal audit team they can have the independence to monitor and look at its effectiveness. A lot of companies hold strong that the auditors need to find everything that’s wrong, and that’s an old school way of thinking.
Educate everyone and encourage them to take ownership for compliance, and use the internal programs and teams to evaluate the effectiveness.
On Thursday, November 19, Debby Newslow will present, Food Safety Management Systems—Understanding the Three Legged Stool” LEARN MOREFST: What do you hope attendees gain from your session on food safety & HACCP PRPs at the Food Safety Consortium?
Newslow: My session is going to be focused on prerequisite programs and how they fit with FSMA and the preventive controls (they really go side-by-side)
- I want folks not to be so nervous about FSMA. If they have a strong program now for food safety and HACCP, and have the prerequisite programs identified and managed, they’ll be 95% there for FSMA [compliance]. Companies really need to focus on their internal programs and have a food safety program that is compliant with FSMA, and expand and confirm the effectiveness of these internal programs. Take pest control, for example. Some companies will hire the outside company and will monitor and know the effectiveness on a regular basis. Other companies will hire an outside firm and let them do whatever they want, and not have a clue what’s going on. Then there are smaller companies that have someone come in, spray, and send them a bill, and they won’t even know what the [outside] company is using as an insecticide. So you have different levels, and that’s why we have to understand each program and what is required for effectiveness and compliance.
- The role of the prerequisite program and preventive controls is that if you look at recalls in today’s world, 90% of recalls are caused from ineffective or nonexistent prerequisite programs [Newslow estimate]. Very seldom do we see a recall because a CCP fails. We get so hung up on other things and forget why do we take off our jewelry, for example. The odds of something going wrong are thin but when you look at it from the big picture, it can happen and it does happen. I’ll have some significant recent examples in my session.