On December 12, The FDA released a systematic review of the scientific literature on food safety culture (FSC), which identified barriers, as well as best practices, for organizations seeking to develop a stronger culture of food safety. The FDA noted that it will use this research to inform its continued efforts in support of food safety culture.
While food safety culture is defined in various ways in the literature, the review identified the most frequently cited definition of FSC as “the aggregation of the prevailing, relatively constant, learned, shared attitudes, values and beliefs contributing to the hygiene behaviors used within a particular food handling environment.” (Griffith, Livesey, and Clayton 2010).
Best practices for promoting FSC include:
Promoting FSC as a topmost goal of each member of the organization, not just a goal of a specific group within an organization.
Branding your commitment to FSC and promoting it everywhere. This includes displaying food safety messaging in break rooms, hallways, elevators, parking lots, or anywhere employees congregate so employees don’t forget it. In his book Food Safety Culture: Creating a Behavior-Based Food Safety Management System, Frank Yiannas, FDA Deputy Commissioner for Food Policy and Response wrote that, “Messaging should be simple, communicate what the desired behavior is, be placed where the desired behavior should occur, and changed often enough to prevent desensitizing.”
Building your food safety messages on the concept of “we,” and clearly defining how employees’ job objectives align with food safety.
Promoting FSC not only within your organization, but also within your entire supply chain.
Challenges and barriers to a strong and effective FSC include:
Over-reliance on Food Safety Management Systems (FSMS). Because FSMSs do not address the human impact on food safety, they do not guarantee a good FSC. A combination of a well-elaborated FSMS and a favorable food safety climate is ideal.
Prioritization of Cost-saving and Money-earning. A commitment to food safety must take precedence over other objectives and cultures that compete for priority within an organization, including the culture of saving money.
Frequent Staff Turnover. Continuous turnover can be detrimental to key determinants of FSC, such as risk awareness and accountability.
Optimistic Bias. Reviewed studies found that some organizations or employees have an “illusion of invulnerability,” which may hinder effective implementation of food safety behaviors. Without perceiving a susceptibility to food contamination, people often resist a focus on it unless they can see the value.
If you watch the evening news or read the local newspaper, the chances are pretty good that you will read or see something about a food safety concern or incident.
An estimated 1 in 6 Americans fall victim to a foodborne illness annually.
While the American food supply is among the safest in the world, the Federal government estimates that there are about 48 million cases of foodborne illness annually—the equivalent of sickening 1 in 6 Americans each year, according to Foodsafety.gov. And each year these illnesses result in an estimated 128,000 hospitalizations and 3,000 deaths. Five types of organisms—Salmonella, Toxoplasma, Listeria, norovirus, and Campylobacter—account for 88% of the deaths for which the cause is known.
We watched from the sidelines when major retailers faced public scrutiny over their practices on safeguarding consumer credit card information when their websites were hacked. Today, consumer and regulatory interest in food safety are the new focus areas for the news media, especially in light of the Blue Bell Creameries Listeria and the Peanut Corporation of America (PCA) Salmonella outbreaks. Unlike consumer credit information, serious missteps in our industry can kill people, and in the case of PCA, can put you permanently out of business.
In 2008, peanut butter paste manufactured by PCA killed nine people and sickened 714 others, some critically, across 46 states and was one of the largest food recalls in American history, according to the CDC. Although still under appeal, PCA CEO Stewart Parnell was convicted and sentenced to a 28-year prison term for his role in knowingly shipping out salmonella-contaminated peanut butter. Parnell received one of the toughest punishments in U.S. history in a foodborne illness case.
In the Blue Bell case, a total of 10 people with Listeriosis related to this outbreak were reported from four states, with three deaths reported from Kansas, according to the CDC. Blue Bell pulled their products from store shelves on April 20, 2015. On May 7, the FDA released findings from inspections at the Blue Bell production facilities in Brenham, Texas, Broken Arrow, Oklahoma and Sylacauga, Alabama. The FDA reports highlighted serious problems across multiple sites.
Both cases shine a spotlight on what can happen if you don’t have an effective food safety management system (FSMS). So what makes up a good FSMS, and is it enough to keep you out of trouble? An effective FSMS is built on three elements: Good Manufacturing Practices (GMPs), Hazard Analysis Critical Control Points (HACCP) and a management system. Food safety issues are avoidable, and good processes and a strong culture within an organization make them more unlikely to occur.
Does your leadership recognize the importance of your FSMS? An effective FSMS should be established before a product incident or recall occurs.
Implementing a FSMS does not happen in a few months; it may take up to two years to establish one. No doubt, foundational activities need to be in place for factory operations. In addition to focusing on foundational elements such as making sure equipment is cleaned properly and procedures for allergens are implemented, the leadership team needs to make it clear that it is never acceptable under any circumstances to take shortcuts that could jeopardize food safety. This policy needs to be indoctrinated throughout the organization and thus does not happen overnight.
Underlying an effective FSMS are strong HACCP and GMPs, but food safety should always be the top priority for management and its employees, not share price, earnings or profit margin. Although financial performance is important, food safety must take precedence in the organization, and leadership at all levels needs to send that message loud and clear to all employees. In today’s environment, HACCP is pretty much mandatory from a regulatory standpoint and is an essential part of a FSMS. But the missing piece in many organizations is the support from the top—this is where culture becomes embedded in the organization.
The FSMS culture is the collective behavior from the organization around shared values and beliefs. The organization will follow the actions of leaders, not necessarily what they say—we all know actions speak louder than words. A good food safety culture is one where best practices are openly discussed, defined and rewarded. Food safety culture has become a buzz word and there needs to be a focus on making it come to life through a structured FSMS.
At this year’s Food Safety Consortium conference, Tim Ahn will discuss advancing food safety training and harmonization (November 19). LEARN MOREFood safety training is important not only for first line supervisors and operators, but also for senior managers and leadership, because they define the objectives and policies of the FSMS. What does it mean to conduct an effective management review? What does it mean to do an internal audit? What’s a good corrective action process? Training often misses the mark, because organizations fail to embed it correctly.
For FSMS to thrive, management must commit to the FSMS being a required way of doing things throughout the entire organization. A FSMS is most effective when it benchmarked against a proven standard and verified by an independent third party. Certification against a proven standard will reduce risk within your business.
Select your independent third-party verifier carefully. Do they have the resources and time, and do they know what they are doing? Do they add value to your organization? This is important since once you get certified, your journey starts and it doesn’t end. The value comes in two areas: Identifying risks and developing the appropriate control measures, and ensuring that the process drive continuous improvement in your organization. FSMS is focused on how continuous improvement applies to the management of risk and business operations.
The most effective way to establish an FSMS is to have leadership that recognizes its importance. The worst way is to have a recall or an incident, which draws attention to the fact that there is a problem and something needs to happen. In the case of Blue Bell, they probably understood the importance of food safety and thought they were taking the right actions. However, their management system led them to problems. FSMS must be independently verified against world-class standards to ensure effective performance.
A thorough auditor won’t look the other way and will find the problems. Call it as you see it–don’t be too soft when getting an assessment.
Companies can develop blind spots where they cannot see their own bad practices, and they become institutionalized over time. Fortunately, experienced independent third-party assessors can shine a spotlight on those bad practices. That is the true value in bringing in outsiders to look at your operations and culture to uncover those blind spots.
At PCA, their poor culture and actions to the problem sealed their fate. In some ways, this criminal case presented a wake-up call to boardrooms across America and highlights how badly leadership mismanaged matters. This case came to light in the context of the public complaining to the regulators that they were not doing enough following several highly visible food poisoning cases. A FSMS would have prevented these problems because the structure would not allow such bad decisions to be made and would have been verified by an independent third party that would test and check everything. A reputable third-party verifier would not miss poor GMP/ HACCP processes.
A good assessor can help a company understand what is really important and what is not so important when it comes to findings (i.e., context). We don’t waste a client’s time with insignificant issues and that is where the experience and judgment of the auditor becomes critical. Last year I met with a client and said, “you need to be checking for Salmonella in your environment—how do you know it is not there?” I pushed them into checking because I understood the changing regulatory environment. I came back a year later, and they had confirmed that regulators were interested in their Salmonella monitoring program during a recent inspection. As an auditor, you have to be confident enough to provide advice and context to the client in a way that is understood and accepted, and that helps to build trust.
With FSMA, the government can now take specific actions against companies. If I am plant manager or CEO, how do I know for sure that I am in compliance with the requirements? How do I know that I don’t have any of these potential issues? The only way to know for sure is to have the FSMS assessed. Just like a bank or publicly traded company hires financial auditors to assure everything is done correctly, companies need to audit their FSMS to ensure compliance. Get a process audit and ensure they drill down deep into the organization—that is where we find issues and gaps. A thorough auditor will find your problems instead of looking the other way. It is important to call it the way you see it and not be too “soft” when getting an assessment.
If I am the CEO, I want to know where those problems exist. Independent third party assurance is the best way to find out how compliant you are with regulations. No CEO wants to deal with the inevitable lawsuits and lost business impacts. At least with an effective FSMS, you can show a level of due diligence when the regulators show up at your doorstep and the culture is such that you want to address any problems.
We have entered an important time for the food industry with FSMA implementation and other food safety regulatory requirements in the United States. These new rules place an emphasis on management accountability, risk assessment and control of supply chains. The bar for due diligence has been raised and it up to all us to show that we have done everything possible, and the best way is with an effective FSMS.
Food safety training has traditionally focused on foundational topics such as Hazard Analysis Critical Control Points (HACCP) and Good Manufacturing Practices (GMPs). While these topics are essential in defining and implementing Food Safety Prerequisite Programs, they define the What and How, but not the Why of Food Safety. In order to address the Why of Food Safety, training programs need to address food safety culture, and the role of a food safety management system in establishing that culture.
A session during the 2015 Food Safety Consortium Conference will discuss advancing food safety and harmonization through educating employees. | November 17-20, Schaumburg, IL| REGISTER NOWCreating a food safety culture needs to start at the top. It must be known that food safety is a top priority to upper management. In order for training programs to support a food safety culture, they need to be delivered in a format that enables employees to contribute to the organization’s business strategy and food safety objectives while simultaneously reinforcing employee skills, attitudes and behaviors. Studies have shown that during training, one should consider manufacturing as a whole—not bits and pieces—and that the correct and most effective approach to training should look at collective knowledge requirements rather than any single requirement. A good starting point is to understand how a well-planned management system can help bring focus on a holistic approach that transforms the culture. A company’s ability to adopt a culture of food safety is dependent on its ability to take a holistic approach to manage food safety risk and incorporate all components of a food safety culture.
The second area of focus is having an effective FSMS in place. The International Organization for Standardization (ISO) defines a system as “a set of interrelated or interactive elements” and a management system as “a system to establish policy and objectives and to achieve these objectives.” In order for the FSMS to thrive, management must commit to the FSMS being a required way of doing things throughout the whole organization. A food management system is most effective when it benchmarked against a proven standard and independently verified. Having an effective FSMS in place provides a vote of confidence in your organization—a statement that your organization takes safety and quality seriously and has made the right moves to help protect your brand reputation and consumers by addressing the complexity of risks, up and down your supply chain, and assuring food safety and sustainability.
By following these pragmatic guidelines your organization can raise the level of food safety around the world by creating more effective food safety solutions not only for today, but also tomorrow.
So your company has decided to pursue certification against a GFSI benchmarked standard. How do you go about choosing the right standard for you, and how can you prepare for your first audit? This article offers some advice.
One of the most important questions to ask before researching and deciding upon a standard for GFSI certification is, “Do any of my company’s current or prospective customers require GFSI certification to a particular standard?
Some customers do require their suppliers to achieve certification to a particular GFSI benchmarked standard and it is worth investigating customer requirements upfront before investing time and resources in the development of a standard specific food safety management system, which is not recognized by a particular customer.
While GFSI benchmarked standards are similar to each other in the core criteria of a supplier’s food safety management system, there are subtle differences with respect to the level of prescriptiveness and certification cycles required by each standard. While GFSI’s motto is “One Certified, Accepted Everywhere,” the reality is that retailers and manufacturers have unique requirements for their suppliers to support organizational initiatives and it is in the best interest of suppliers to understand such requirements for increased market access of their company’s food products.
Identify your company’s preparation profile
Once customer requirements for GFSI certification are evaluated, the next step is to assess management objectives for GFSI certification as commitment and resource requirements maybe different depending on which standard is adopted for certification.
At their most basic level, all GFSI benchmarked standards require the development and implementation of a food safety management system (FSMS) for certification. However, some schemes extend the scope of certification beyond food safety requirements and offer certification of both a food safety and quality management system (FSQMS) such as BRC Global Standard for Food Safety or SQF Code Level 3.
Distinguishing between implementation of these two types of management systems is critical for determining management commitment, resource requirements, implementation of timelines, and maintenance (certification) of the system.
Attributes to consider and evaluate against the different GFSI benchmarked standards when deciding which GFSI standard to implement may include consideration of the following:
Type of operation
Number of locations
Physical size of the facility
Number of employees
High or low-risk product
Number of HACCPs
Product category(ies) to be included in scope of certification
Ability of management and staff to submit to required unannounced audit during certification cycles.
Developing, implementing, and maintaining a food safety management system is a financial commitment on the part of the company seeking certification with immediate and long term benefits as previously discussed. As such, budgeting for the initial development and implementation as well as continued maintenance of the system is necessary. Consideration should be given to the need for initial training of key management and staff to the selected standard, consultancy, allocation of management and staff time, and initial audit costs. Maintenance of the system should consider continued training needs as new editions of the standards are issued, annual review, revision, and verification of the system, and annual recertification costs.
How to prepare for the audit
In preparation of the audit, it’s helpful to prepare an Internal Preparing Checklist, covering the following aspects:
GFSI Standard: Have you determined which GFSI standard best fits your company culture and acquired the current version of the standard?
Commitment: Is senior management fully committed to implementation and maintenance of the selected standard’s requirements?
Food Safety Management Team: Do you have a qualified HACCP team leader, inter-departmental HACCP team, and designated individual(s) to lead the development and implementation of the food safety management system?
Training: Are the company’s designated HACCP and food safety management leads trained in the requirements of the current version of the standard?
Readiness: Does the company have a well developed, implemented, and documented HACCP system with core prerequisite programs included allergen management, internal audit, GMPs, process and product segregation, SSOPs, specification approval, supplier approval, recall plan, traceability and training?
Timeline: Has senior management set a target date for certification?
Consultancy: Do company resources lend itself to successful development of a documented food safety management system, which meets all requirements of the standard, or is there a need for a standard specific consultancy?
Internal Audit (Gap Assessment): Has the food safety management team conducted an internal audit of its system against the requirements of the standard? Are “Gaps” or a reason of non-conformance to standard requirements identified with a correction action plan?
Third Party Assessment: Is there a need for a third-party (certification body) to conduct a pre-assessment audit of the company’s system against standard requirements? Third party pre-assessments provide objective and competent evaluation of the system by a trained auditor in preparation for the planned certification audit.
The above article has been adapted from a white paper published by CERT-ID, which has over 15 years’ experience in providing certification services globally. For more information, visit www.cert-id.com.
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