Tag Archives: record keeping

Glen Ramsey, Orkin
Bug Bytes

Implementing Pest Management Changes for FSMA

By Glen Ramsey
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Glen Ramsey, Orkin

Preparation is the key to success for any ongoing endeavor. In an industry where your enemies are fighting for survival at the expense of your business, you must be ready for anything. Your opponents are crafty, adaptable and more prevalent than you think.

No, I’m not describing your competitors. I’m talking about pests—a major threat to the integrity of food products and a threat to any facility’s bottom line. Whether it’s stored product pests contaminating inventory or rodents spreading pathogens as they skitter across equipment, pests are a risk that should be minimized.

With FSMA in full effect, preparation is more important than ever. FSMA mandates a proactive approach to food safety, and by extension, pest management. It’s important that the pest management program is exhaustive and integrates seamlessly into the overarching food safety plan.

Most, if not all, food processing facilities currently use an integrated pest management (IPM) program to help minimize the chance of pest problems, but FSMA puts more emphasis on being proactive to keep pests far from products at all times. Naturally, this doesn’t mean that a pest sighting in a facility is the end of the world, but it means that it should be resolved quickly, investigated and documented to help prevent such an occurrence from happening again.

Specifically, FSMA has numerous stipulations that trickle down to pest management.

  1. Hazard analysis. First, a comprehensive inspection should be done to identify the high-risk areas in your facility where pests may take residence. Entry points, potential food and water sources and harborage areas should all be noted.
  2. Preventive controls. Include regular facility maintenance reviews and a strict sanitation regimen in your food safety plan to help minimize the use of chemical pest management treatments.
  3. Monitoring. Use devices and employees to keep tabs on pest activity and conducive conditions to ensure preventive controls are working and executed across the facility.
  4. Corrective actions. Implement and enforce pest management solutions such as exclusion strategies (e.g., weather-stripping, door sweeps, vinyl strip doors), traps (e.g. pheromone traps, insect light traps, bait boxes), air curtains and repellants to help manage pest activity.
  5. Verification. Schedule regular service visits with your pest management professional to verify corrective actions are working to reduce pest problems over time. These visits should include an annual facility assessment and pest trend analysis, both of which help determine potential areas of improvement over time.
    6. Record keeping and documentation. Document every action taken to prevent pests. That includes corrective actions and their results to prove that your written IPM and food safety plan has been implemented and is effective in helping to manage pests at the facility.

With these key components accounted for, it will be easier to be prepared for pests. But, even still, the real-world implementation of these tactics might not be abundantly clear. That being the case, let’s take a look at what food processing facility managers can start doing today to help protect their facilities and demonstrate a proactive approach to food safety.

So, what’s the best way to be more proactive in preventing pests?

Well, that question has a plethora of possible answers, but four of the most important are sanitation, exclusion, staff training and monitoring.

Sanitation

Perhaps the most important of all, sanitation helps to eliminate two key attractants—food and water—that draw pests inside a facility. Any spot where food particles or moisture is collecting, pests will be looking to find.

But sanitation shouldn’t seem daunting. Here are some actions you can start doing today to step up your sanitation program:

  • Wipe down equipment regularly to break down the buildup of organic materials.
  • Wipe off countertops and sweep floors in common areas where food is present, then sanitize with an organic cleaner afterwards to eliminate any remaining odors.
  • Take out the garbage at least daily, and keep dumpsters at least 50 feet away from the building to avoid giving pests a harborage location nearby with an easy path to get indoors. Make sure to cleanse garbage bins and dumpsters regularly, or they’ll become attractive to pests, too!

Exclusion

A big part of preventing pests from getting inside a facility is simply blocking them out using exclusion.

During an inspection, a pest management provider will walk around the interior and exterior of the facility and look for any potential entry points for pests. They should recommend you seal any cracks and crevices they notice, as many pests can fit through extremely tiny gaps. For example, mice can fit through a hole the size of a dime. Gaps should be sealed with a water-resistant sealant to keep pests and moisture out.

In addition, make sure to keep windows and doors closed as much as possible or use screens to block pests. Automatic doors can help in this way, especially when paired with an air curtain to blow flying pests away from entrances. Pests can often come in through the biggest gap of all: The front door!

Staff Training

It’s always better to have a team behind you. Training employees on the basics of an IPM program and what they can do to help will take some of the weight off your shoulders.

Many pest management providers offer free staff training sessions, which can help employees understand what to look for around their work areas and what to do in the case of a pest sighting. Consider creating your own pest sighting protocol to make it clear what employees should do if and when a pest is spotted. They’ll need to record when, where, how many and what kind of pest(s) were seen at the time to give your pest management provider the best chance to create a customized solution to resolve the issue. If you can catch one of the pests in a container for future identification, that’s even better.

Monitoring

While employees can help by keeping an eye out for pests, it’s important to have ongoing monitoring techniques to measure pest activity around the facility.

Monitoring devices are a great way to do this, and your pest management professional can help you place them strategically around the hot spots in your facility. Fly lights, bait stations, pheromone traps and more can capture pests and serve a dual purpose. First, they’ll reduce pest populations around the facility, and, second, they’ll allow you and your pest management provider to see how many pests are present in certain areas.

Over time, this will give you a feel for which pest issues have been resolved and which continue to be a problem. That can determine the corrective actions taken and the long-term food safety plan, which will demonstrate a commitment to constant improvement. That’s a great thing to have on your side, especially when an auditor happens to stop by.

Documentation

I know, I know—this wasn’t one of the four “answers” listed, but it’s still incredibly important! Documentation helps ensure you get credit for being so prepared.

It’s recommended that facility managers keep a few documents on hand to keep things simple. The food safety plan, annual assessments, sighting reports, a list of service changes over time, a list of monitoring devices and proof of your pest management professional’s certification are all important documents to keep updated and ready to go. That way, you can rest easy knowing you’re prepared at a moment’s notice.

It is never too early to start preparing. Pests aren’t going to stop searching for a food source anytime soon, so don’t stop your proactive efforts to keep them at bay. Your financial department will thank you.

Steven Burton, Icicle Technologies
FST Soapbox

Could Blockchain Technology Drive FSVP Compliance?

By Steven Burton
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Steven Burton, Icicle Technologies

From farm to fork, food produced today goes through more hands than ever before. A greater number of players in the production of even a single product could increase that the risk for foodborne illness. Not only do companies need to check incoming and outgoing products from their own facilities, but they also need to consider whether products that they are importing from other countries are compliant with local regulations, and whether the products that they are exporting are compliant with the regulations of the destination country.

The current traceability standard of “one step forward, one step back’”is less and less suited for the current global marketplace, and governments are demanding more. Handling all this information is a challenge for food producers of all sizes, around the world.

Taking Traceability Global with FSVP

Needless to say, with 600 million people contracting foodborne illnesses every year, there is a dire need for food traceability and transparency in the food supply chain. If and when something goes wrong, traceability gives oversight agencies greater visibility investigating the root causes of an outbreak to prevent further risk to the public. It also allows companies to minimize the financial impact of a recall if they are able to pinpoint exactly which lot numbers of their products are affected.

In response to the changes in the food industry, in 2011 the USFDA introduced FSMA to implement a more proactive food safety regulatory system. With FSMA came the Foreign Supplier Verification Program (FSVP), which basically extends FSMA regulations to companies supplying food to the United States. All U.S. importers are now required to monitor and manage their foreign suppliers through six steps of hazard analysis, record keeping and more. Given the complexity of the global food supply chain, this is by no means an easy undertaking and it is clear that technology is crucial to achieving this granular level of data management alone. Blockchain technology, however, might be the answer to this problem—and many other related ones.

What is Blockchain Technology?

Evolving from the digital financial world, blockchains are distributed databases that build a growing chain of ordered records, called blocks. This means that any type of information can be stored in a chronological, consistent and secure way; even if multiple users are involved, it is extremely difficult to alter a blockchain.

Since any information on the blockchain is shared with all of its users, they can view any transactions made historically and in real-time. Theoretically, this could allow authorities to pinpoint food problems within minutes, when previously it would take days, potentially saving many lives in the process.

Blockchain in Action in the Food Industry

In 2016, retail giant Walmart started using a pilot version of the technology in its stores, tracking two products using blockchain: A packaged produce item in the United States and pork in China. Walmart announced that the results were “very encouraging,” noting that using blockchain technology could dramatically increase the speed of traceability from days to minutes. In fact, Walmart is now taking it to the next level with a collaboration with one of China’s largest retailers, JD.com, and their suppliers, to bring a higher level of food safety to China.

Other major food suppliers and retailers—Dole, Driscoll’s, Golden State Foods, Kroger, McCormick and Company, McLane Company, Nestlé, Tyson Foods and Unilever—have also signalled their intention to work with IBM to create blockchain-based solutions. Blockchain technology is even being used to track the movement of tuna through the ocean and all the way to the consumer.

At the same time, implementing blockchain technology throughout the industry is a mammoth task. As of now, blockchain technology has a problem with scaling up and can only process a limited number of transactions per second, which would not be sufficient given the needs of the global supply chain. According to Coindesk, each transaction costs about $0.20, and can only store 80 bytes of data, so the bill might become quite hefty as well.

There’s also the fact that the food industry is traditionally slow to adopt new technologies. It’s not just about big players like Walmart—small, medium, and large businesses alike need to come onboard in order for this to become an industry-wide standard.

Can FSVP Unlock the Potential for Blockchain Technology?

There are several reasons why blockchain technology could be the key to tackling the complex challenge that is tracking and verifying foreign suppliers. Blockchains can help increase transparency and communication across the food supply chain, ensuring that there are no gaps and that records are widely available and up to date. When all the information about suppliers and products is easily accessible, the potential to increase the speed of recall response is very high.

Blockchain technology is also suited to FSVP’s goals, specifically. One of the main goals of FSVP and FSMA generally is to tackle the issues of food fraud, intentional adulteration and bioterrorism that are unique problems of our time, in terms of scale if nothing else. Such a modern problem requires modern solutions. Because the blockchain, forming the basis of cryptocurrencies like Bitcoin, focuses on security, it could mean that blockchains can help close the gaps that would be exploited by food companies employees, or other actors who harbor ill intent.

The reality, however, is that the level of industry-wide coordination—and voluntary transparency—that would be necessary to deliver real benefits is extremely high. The theoretical possibilities are exciting and hugely impactful; the practical reality is more complex. For blockchain to reach its full potential, it has to be universally mandated, which is highly unlikely given the current circumstances. It seems more likely that adoption in this area could be driven by industry organizations and/or government, but unfortunately, the recently proposed budget cuts for the FDA might block progress in the latter area.

Still, with major food suppliers and retailers leading the charge and taking blockchain technology for a test run, the rest of the industry is waiting with bated breath to see what happens next.

Dana Johnson Downing, TraceGains
FST Soapbox

Six Signs Your Quality Department Is Still in the Dark Ages

By Dana Johnson Downing
1 Comment
Dana Johnson Downing, TraceGains

Increasingly, we turn to technology to simplify tasks in our personal and business lives. Platforms like Facebook and Twitter allow us to connect, shop, advertise and publish with just a few clicks. LinkedIn is where people turn to prospect for new business, publish articles, discuss issues within industry groups, and look for a job. Need a ride? Apps like Uber and Lyft can usually get you where you’re going cheaper and more easily than a taxi. Devices like Google Home and Amazon Echo can listen to your voice commands to play music, manage your shopping list, adjust your lights, or tell a joke. And experiments are underway for driverless cars, which could make us the last car-owning generation.

Food safety documentation

With technology automating and solving so many tasks, how is it possible that food production is still dependent on paper-driven and manual processes?

The current way of doing things in the food and beverage industry is outdated, labor intensive, and—most importantly—error-prone. Under FSMA, companies need to be able to justify their decisions and processes, and of course, document them. It’s not only critical for brand protection—it’s a regulatory requirement. Ignorance is not bliss. Now, senior management is obligated to demonstrate their commitment to food safety and they risk criminal prosecution if their operations don’t measure up. There’s too much at risk to keep doing things the same old way. The following are some signs that your quality department is still in the Dark Ages.

1. You’re using clipboards.

In defense of clipboards, they were a wonderful invention. They are quite well suited for gathering signatures on petitions to save the whales or signing up for a PTA bake sale. But if you’re still using clipboards to log temperatures or document sanitation procedures, then your food safety records are not as current and organized as they could be. Inputting data later is not an effective use of time. Processes like these not only take away from the core competencies of your quality team, but they also make staff spend more time analyzing everything manually, which could lead to costly mistakes or inaccuracies. Tablets and PCs have replaced paper-based logs and other quality recordkeeping. Why make your staff do a task twice? By digitizing these records, you can ensure that your records are up-to-date in real time and reduce the likelihood of errors made during transcription. Trust me, your staff will thank you for rescuing them from extra data entry. Plus, the modern workforce expects digital solutions.

Filing cabinet, food safety documentation
Still using a filing cabinet to store documentation? All images courtesy of TraceGains

2. You’re still using a physical filing cabinet to store food safety documentation.

If you’re putting your food safety plan, supplier documents and certificates of authenticity (COAs) in a filing cabinet, you have a transparency problem. Your department isn’t the only one that needs access to those critical documents. And if everyone has their own paper copy, then you are going to have problems with version control. Solve your transparency and version control problems by keeping critical documents in the cloud where the data can be extracted, analyzed and shared internally and externally across your supply chain.

Food safety documentation
Three-ring binders are no longer an appropriate place to store important information.

3. Three-ring binders are for middle school, not food safety.

If your idea of ensuring compliance involves keeping COAs in a three-ring binder, you probably still have a flip phone, too. Seriously, 1980 called and they want their Trapper Keeper back. Whether your documents are in filing cabinets or binders, you still don’t have the transparency you need to efficiently share that information with your peers and other departments. Plus, your audits are sure to drag on longer than necessary if you are doing audits with stacks of three-ring binder instead of using an online platform where you can show the auditor any documentation they need with just a few clicks of a mouse.

4. Your suppliers send critical food safety documents to you via e-mail.

Email is a great way to communicate. It’s just not the best way to gather and manage supplier documents. Admit it; we all get behind on email, and sometimes things slip through the cracks. What happens if an out-of-spec allergen declaration gets buried under the 586 emails you receive each day? I can tell you, it’s certainly not good. The alternative is allowing your suppliers to upload those documents into a platform, so they are immediately available to you and anyone else in the company that you’ve given access to the system. Leveraging a platform, you also have access to a dashboard that can quickly show you which suppliers are in compliance and which ones have issues that need to be addressed. And if you have incoming certificates of authenticity (COAs), you can sit back and rely on software to read those documents for you and spot anything that doesn’t match your specifications or purchase order details. Isn’t it time that you not only collected supplier documents, but really use that data within the documents to better manage your incoming material to ensure food safety and quality?

5. You rely on file sharing to store your food safety and quality documentation.

SharePoint and other file sharing systems may look more modern than the paper alternative, but they weren’t designed specifically for vendor management or supply chain transparency. They can file and retrieve, but it’s not automated document management. Ask yourself how long do you or fellow employees spend searching for requested documents? Perhaps you need certain documentation for your GFSI/FDA audit, but different pieces of information are stored in various locations, either in a shared drive like SharePoint or a custom vendor portal. Every minute counts when it comes to document retrieval. These systems are often a little more than an electronic filing cabinet. They can store the information electronically, but unless it’s gathering, analyzing, validating and sharing that data across all departments, you still don’t have an automated system.

Spreadsheets, food safety documentation
If you’re still using spreadsheets, consider moving data to the cloud.

6. Spreadsheets are the main source of tracking your data.

While quality managers at competing companies are investing in the latest technology, other food companies are still inputting supplier lists and data in spreadsheets. Often, managers are reluctant to move their data to the cloud, opting instead to stick with what they know by using a spreadsheet that lacks a comprehensive system to track supplier performance in real time. This is a major disadvantage when different departments need one source of the truth about supplier performance and trend data about incoming material. Not only are spreadsheets hard to share and keep up-to-date, but the majority of them also contain errors.

  • A report by Ray Panko, a professor of IT management at the University of Hawaii, found that 88% of spreadsheets contained errors.
  • Coopers & Lybrand found that 91% of spreadsheets with 150 rows or more produced results that were off by more than 5%.
  • In a sample of 22 spreadsheets, KPMG found that 91% contained serious errors.

If your executives think automated supplier, compliance and quality systems are a “nice-to-have,” chances are you are still operating in the Dark Ages. This final advice is true no matter what software your business is thinking of implementing. Whatever the aims of the system, you must choose a long-term partner. Make sure your vendor can solve these six problems and meet the needs of your business now and in the future.

Jordan Anderson, PAR Technology Corp.
FST Soapbox

How Proper Record Keeping Can Help Reduce Food Waste in the Supply Chain

By Jordan Anderson
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Jordan Anderson, PAR Technology Corp.

One stringent component of FSMA and the Final Rule on Sanitary Transportation of Human and Animal Food is record keeping. Depending on the type and size of business, the FDA can demand proof of record anywhere from under one year and upwards to two years, all while needing to address their inquiry within 24 hours. Failure to do so will be considered a “prohibited act” and violators can be tried for civil and criminal penalties.
This new rule, put in place by the FDA, will put immense pressure on the food transportation industry, not only to make food safety a priority, but also to ensure that proper food safety practices and measures are being properly implemented, by way of record keeping.

While the litany of rules and regulations pertaining to record keeping best practices is intense, let us break down the basic requirements applying to records in layman’s terms:

  • If HACCP procedures aren’t documented, it didn’t happen
  • Records must be verbatim accounts of what happened
    • The need for real-time recording is paramount
  • Corrective actions must be executed immediately if an issue occurs
    • If not, liability risk increases exponentially

Companies must determine the most efficient and plausible manner by which they will comply. Traditional storage of records in filing cabinets and input of data in spreadsheets is antiquated, and leads to errors and the potential for misplaced records. Now, more than ever, is the time for businesses along the food chain to deliver value to their organization via digital technologies and automated data gathering solutions. This will ensure constant visibility and ensure quality control throughout the process from farm to fork.

Where Does Waste Happen?

While covering a lettuce farm in central California, National Geographic discovered that numerous loads were dumped each day due to procedural mistakes , including improperly filled, labeled and sealed containers.1 Due to the mishaps, the loads were then dumped. Between April and November that year, the local Waste Authority landfilled 4–8 million pounds of fresh vegetables from those fields.

The Food and Agriculture Organization (FAO) estimates that:

  • 54% of world food waste occurs during production, handling and storage
  • 46% occurs during processing & distribution

These numbers are not only staggering, but they illustrate the seriousness of this issue.

Many of these mishaps occur when standard recording procedures are done manually, which leads to improper documentation that invalidates the integrity of shipments—to which the above figures illustrate and corroborate.

But can shippers, loaders, receivers and the like secure their procedures and eliminate wasted product by implementing stricter digital HACCP solutions?

Lost Food

While improper execution of best practices can lead to FDA imposed sanctions and profit loss, it also perpetuates the problem of food waste globally. This issue has become an epidemic and one that greatly affects the lives of many.

In a recent National Geographic article, The Food and Agriculture Organization (FAO) suggests the following:1

  • One-third of food produced for global human consumption is annually lost or wasted along the supply chain
  • Food waste equates to 2.8 trillion pounds each year, which is enough to feed 3 billion people per year

Consider this: The World Food Programme estimates that nearly 795 million people in the world do not have access to the proper amount of food needed to live a healthy, active life, which equates to roughly one in nine people on earth.

The amount of waste created along the supply chain each year is enough to feed the hungry and malnourished people of the world three-times over. While waste is inevitable, even a 50% improvement would be able to feed those most in need.
We understand the nature of business is overcoming competition while expending the least capital possible, ultimately leading to profit. However, food-related businesses along the supply chain must ask themselves whether or not they are their own competition. Are best practices being properly executed? How can they ensure this in order to mitigate waste?

Ultimately, however, it becomes a human issue. Companies must be responsible and possess the empathy to understand this. While domestically we may not feel the effects of global hunger as much as other third-world countries, these businesses must be aware of the epidemic in order to elucidate this topic while simultaneously maximizing its businesses potential.

By leveraging new food safety solutions such as mobile devices, the cloud, IoT, sensors and more, you can better protect your customers while also gaining a tangible ROI. Wherever consumers purchase and shop for food today, they are likely to find a larger selection than ever before. From the bread aisle to the cheese counter to the produce section, food options and manufacturing processes today are more diverse than ever. While variety is positive on a consumer and cultural level, it can create challenges for food safety from farm to fork.

Reference

  1.  Royte, E. (October 13, 2014). “One-Third of Food Is Lost or Wasted: What Can Be Done”. National Geographic. Retrieved from http://news.nationalgeographic.com/news/2014/10/141013-food-waste-national-security-environment-science-ngfood/.
Shawn K. Stevens, Food Industry Counsel
Food Safety Attorney

Are You Ready for an FDA Inspection?

By Shawn K. Stevens
1 Comment
Shawn K. Stevens, Food Industry Counsel

Don’t miss the Plenary Mock Food Safety Trial: Sam I Am who made Green Eggs and Ham is represented by Shawn Stevens vs. Food Safety victims represented by Bill Marler. Judged by Steve Sklare | November 30 at the 2017 Food Safety Consortium | Learn moreWith FSMA regulations coming into effect, food companies must prepare for the arrival of FDA investigators, as the agency has made it a priority to inspect U.S. food facilities, and they won’t always show up announced. Prior to an investigator’s arrival, it’s important to iron out several details in order to be adequately prepared. The following are 10 questions that every company should add to its pre-inspection checklist and make sure they are addressed before the inspection.

  1. Where will you meet? Pinpoint a place where you will host the FDA investigators. It should be a space that has enough room for them to review records, but it should not provide access to records (paper or digital) that could be viewed unsupervised.
  2. Who are the Designated Individuals? Assign a primary and secondary Designated Individual (DI) for each facility. This person serves as the liaison with the FDA investigators and should coordinate vacation time to ensure that one DI will always be available if FDA arrives. Although not required, the DI should also complete Preventive Control Qualified Individual Training.
  3. Has the written food safety plan been finalized? And, do the primary and secondary DIs know its components (i.e., GMPs, Sanitation Programs, Preventive Control Plan, Recall Plan, Environmental Monitoring Program, Foreign Supplier Verification Plan, Sanitary Transportation Plan, Food DefensePlan, and Produce Safety Plan)?
  4. Are records readily accessible? The DI should be able to immediately access any supporting records from the past three months for FDA review (FDA requires that most records are maintained for at least two years, but investigators usually ask to review the preceding three months).
  5. Have corrective actions been documented? When a deviation occurs, you must document all corrective actions. These actions should identify the deviation’s root cause and actions to prevent recurrence. If product safety is not affected, this should include a written conclusion that the deviation “does not create an immediate or direct food safety issue.”
  6. Have you conducted environmental monitoring and environmental sampling? If your company processes ready- to-eat food products that are exposed to the environment prior to packaging, FDA will require you to have an environmental monitoring program. In addition, the agency will collect 100–200 microbiological samples from your facility, so you need to know exactly what FDA will find before it arrives. By conducting your own FDA-style facility swabbing, you’ll be able to identify and immediately correct any hidden problems. It’s also important to develop your swabbing and testing plan with the help of legal counsel so that  the final testing results are confidential.
  7. Do you have a “No Photographs” policy? If not, you should. FDA Investigators will often insist on taking photographs while inspecting the processing environment. If your corporate policy prohibits visitors from taking photographs, you may in some cases be able to prevent FDA from taking pictures as well.
  8. Do you have a “Do Not Sign” policy? Sometimes, FDA Investigators will insist that a company representative sign a statement or affidavit during an inspection. You’re not legally obligated to do sign such a document. You should develop a policy stating you will neither sign nor acknowledge any written statements presented by FDA Investigators.
  9. Have you identified a suitable “on call” food industry lawyer? Add a food industry lawyer familiar with the inspection process to the company’s emergency contact list. This lawyer should be notified and remain “on call” during the inspection and serve as a resource to help answer any regulatory or investigator-related questions that arise during the process.
  10. Did you conduct a mock FDA inspection? One of the most effective ways to prepare for an FDA visit is to conduct a mock inspection. Food industry consultants and/or lawyers can visit your facility and play the role of the Investigator. Ask them to review your programs to identify possible regulatory shortfalls, and work with you to implement strategies that will strengthen your programs and reduce your regulatory exposure.

There are several more points to add to your pre-inspection checklist. To get the rest, attend the webinar, FDA Inspection Readiness Checklists, on March 28.

Bill Bremer is Principal, Food Safety Compliance at Kestrel Management LLC
FST Soapbox

FSMA Preventive Controls: Are You Prepared?

By Bill Bremer
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Bill Bremer is Principal, Food Safety Compliance at Kestrel Management LLC

Compliance to FSMA has presented a new and difficult challenge for industry, the public and the FDA since it passed on January 4, 2011. With compliance dates for the initial FSMA rule—Preventive Controls—coming in September 2016, food sites must establish plans now to meet the impending deadline.

Complying with the Preventive Controls Rule

The Preventive Controls Rule was published September 17, 2015, with the compliance date for registered companies (more than 500 employees) scheduled for September 19, 2016. The compliance date is one year later for companies with fewer than 500 employees, unless otherwise specified under FSMA.

Under the FSMA rules, registered food facilities must evaluate and implement preventive control provisions and meet the requirements and the approaching deadline. The most urgent concerns for companies subject to the Preventive Controls Rule include developing a Preventive Controls Program, identifying a Preventive Control Qualified Individual (PCQI), and implementing a Food Safety Plan.

The following areas are all included under the FSMA Preventive Controls Rule:

  • Hazard Analysis. Companies must identify and evaluate known and reasonably foreseeable hazards.
  • Preventive Controls. Preventive controls must be implemented to significantly minimize or prevent the occurrence of hazards.
  • Monitoring. Preventive controls must be monitored for effectiveness.
  • Corrective Actions. Procedures for addressing failures of preventive controls and prevention of affected food from entering commerce are required.
  • Verification. Facilities are required to verify that preventive controls, monitoring and corrective actions are adequate.
  • Recordkeeping. Records must be kept for two years.
  • Written Plan and Documentation. A written plan must document and describe procedures used to comply with requirements.
  • Qualified Individual. A Qualified Individual who has been adequately trained must be present at the facility to manage the preventive controls for the site and the products processed and distributed at/from the site.

Failure to implement Preventive Controls (a.k.a., Hazard Analysis and Risk-based Preventive Controls (HARPC)) for qualified sites may result in fines and possible jail sentences.

Self-Diagnostic Assessment Tool

The following self-diagnostic assessment tool can help organizations better determine their current state of planning for FSMA compliance (see Table I). To complete your own planning assessment, review your progress compared to the questions below.

Table I. Kestrel Management’s self-diagnostic tool can help a company assess its level of preparedness for FSMA compliance.
Table I. Kestrel Management’s self-diagnostic tool can help a company assess its level of preparedness for FSMA compliance.

Get Compliance-Ready

Companies must have their training, planning and development underway to comply, or face possible violations, fines, and penalties under FDA enforcement. The questions in Table I will help companies identify the areas in which they need to focus attention. Kestrel can also help answer questions, provide input on solutions, discuss how to better manage the preventive controls program—and change “No” responses into “Yes” responses that promote best practices for FSMA compliance.

John Sammon, ParTech
Retail Food Safety Forum

Break the Pencil: Goodbye Paper, Hello Technology

By John Sammon III
No Comments
John Sammon, ParTech

With the passage of FSMA, any location that handles food for public consumption must implement Hazard Analysis and Critical Control Points (HACCP) plans to reduce food safety risks across the food chain. Many businesses with multiple locations in the restaurant and retail industries are finding that traditional paper-based methods of record keeping are no longer adequate to comply with the FSMA. By abandoning paper-based systems and adopting cloud-based technology, restaurant and retail locations can embrace and enforce stronger food safety cultures and help eliminate human error.

According to the CDC, each year an estimated 48 million Americans get sick, 128,000 are hospitalized and 3,000 die from foodborne disease.

Why? The process of purchasing, transporting, preparing and serving food heavily revolves around individual human behaviors related to cooking, cleaning, handling and refrigerating food. When employees do not follow the correct processes and procedures, it can lead to accidental food safety issues.

FSMA & HACCP Plans

In an effort to shift from responding to food contamination incidents after the fact to proactively preventing them, the FDA introduced FSMA in 2011. To allow businesses time to adjust to new rules and regulations, the FSMA requirements are implemented in phases, which began in September 2015 and will continue through May 2016.

As part of a larger food safety initiative, FSMA requires any business that handles food for public consumption to implement a HACCP plan. The purpose of the plan and its procedures is to identify potential hazards in any food-related processes where a lapse in attention or failure to complete a task could turn a potential hazard into an actual one.

The three main components of an HACCP plan that are required to be documented are:

  • Hazards: Evaluate potential hazards that exist in the enterprise. For example, how, when and why Salmonella or Listeria could migrate into a finished product
  • Critical Control Points: Identify critical control points where failures could occur, such as when products are moved from preparation to the sales floor
  • Preventative Steps: Establish the preventative steps that must be followed at each critical control point to reduce hazards, for example, interval checks to make sure correct temperatures, whether hot or cold, are consistently maintained

FSMA also mandates a record of food safety compliance to ensure a company follows its HACCP plan. Every location must document all actions, including ongoing monitoring of when a problem was spotted and corrective actions taken. These records, which have traditionally been created and maintained with pen or pencil and paper logs, must be kept for a minimum of two years.

Deli worker checks cold food temperatures using a handheld probe and wireless device. Maintaining proper food temperatures and recording checks for consistency is an important part of HACCP guidelines.
Deli worker checks cold food temperatures using a handheld probe and wireless device. Maintaining proper food temperatures and recording checks for consistency is an important part of HACCP guidelines.

Compliance Challenges

With multiple locations and an ever-changing labor force, it is difficult for companies to be confident that the food they sell is safe and that every employee is acting diligently when it comes to food safety across the entire enterprise.

In a busy restaurant or retail environment with ever-changing customer demands for a variety of different products and services, a food safety culture and plan can unintentionally become compromised.

With local farmers to international food manufacturers supplying fresh, frozen and prepared foods and a variety of workers in contact with each for different reasons, it can be difficult to track food safety procedures.

Add an inefficient, manual, paper-based food safety record-keeping system that does not proactively remind employees to complete tasks or prompt corrective actions when needed, and you are opening the door to potential problems.

It’s Time to Break the Pencil

Companies must implement the highest standards of food safety processes at all levels and locations. Once a food safety culture is defined, it needs to be enforced every day. Employees should be well trained on policies, feel empowered and mandated to behave consistently.

A major part of the solution is abandoning traditional pen or pencil and paper-based record-keeping systems. By adopting technology, restaurants and retail locations can embrace and enforce stronger a food safety culture and help eliminate human error.

Electronic and intelligent checklists and digital record keeping on mobile, handheld solutions that are integrated into the Internet of Things (IoT) represent a major technological advancement over what was previously possible, and can manage and dynamically influence food safety processes. Through connectivity to the cloud, mobile, digital solutions can be deployed anywhere throughout a business, from warehouses to sales floors, to prompt the desired behaviors and provide a detailed, accurate audit trail of completion. Devices can also keep track of relevant safety alerts and recalls to improve efficiencies and initiate steps that may not be part of a typical routine.

Daily employee work schedules can be preloaded and custom electronic-based checklists and templates can be built specifically around potential hazards to manage employee tasks and processes. Any missed steps or violations are flagged for easy correction.

As tasks are completed, data is electronically gathered and transmitted directly to the cloud where it can be stored, analyzed and reported for compliance.

In addition, through the cloud and IoT, employees at various levels of an organization, from corporate headquarters to store managers, can view and access real-time data from each location. New information can be uploaded from any location and automatically distributed to a particular store, region or all locations across an enterprise. Enterprise-wide access helps ensure all locations are practicing the most up-to-date HACCP plan and procedures.

Digital food safety solutions have many benefits for a business:

  • Overall Food Safety: Ensures critical control points are monitored and proper corrective actions are taken when necessary
  • Higher Performance: Employees are reminded to complete assigned tasks, so more tasks are completed on time with fewer misses
  • Audit Trail: Detailed, automated audit trail of who completed the action, what time it was completed and the data retrieved from the action
  • Process Improvement: A single database of comprehensive information detailing timing, missed checklists, commonly missed items and top violations to help improve overall processes
  • Cost Savings: Fewer resources are needed to complete food safety inspections, a 60% reduction in time compared to pen or pencil and paper-based systems1
  • Quality Improvement: In addition to HACCP compliance, the information gathered can be used for quality control. For example identifying where there has been over- or under-cooking in the food preparation process

Handheld, wireless and cloud-based technologies can serve as more accurate, reliable and efficient systems. Electronic systems are part of the solution for businesses to comply with new FSMA regulations and improve food safety procedures. When implemented properly, these technologies can help turn food safety in a positive direction and potentially avoid the next foodborne illness outbreak.

Reference

  1. National Grocers Innovation Center, Center for Advancing Retail Technology. Intelligent Checklist for Quality and Safety in the Supermarket. Retrieved from http://info.partech.com/whitepaper-intelligent-checklist-for-food-safety

Top 10 Tips for Creating a Sustained Food Safety Culture

By Holly Mockus
4 Comments

After much anticipation, FDA has finally published the FSMA final rules. If you’ve had time to dig into the details, you most likely noted the new initiative that requires companies to measure food safety culture. The industry is also seeing SQF, BRC and other GFSI audit schemes ramping up discussions around measuring food safety culture. However, FDA and GFSI audits aside, how do you create a culture for sustained compliance with this initiative? Follow these 10 tips to ensure your food safety culture is constant and in line with the new requirements

Photo credit: Dennis Burnett for Alchemy Systems
Set clear expectations for employees across the board. Photo credit: Dennis Burnett for Alchemy Systems

1: Create a solid foundation of programs, procedures and policies

Have a preset annual schedule for review and update of all programs, procedures and policies. Don’t let the schedule slide because there are competing priorities. A small pebble is all it takes to start ripple effect in the company, making it difficult to recover.

2: Set clear expectations, driven from the top down

Everyone should follow the rules and guidelines—from visitors to the CEO to the plant manager to the hourly employee. A “no exceptions” policy will drive a culture that is sustainable and drive a “this-is-just-how-we-do-things” mindset.

3: Use record keeping to ensure that food safety culture is well documented and data-driven

Collect the data that is measureable and non-subjective to help drive continuous improvement. If you collect it, you must do something with it. Good documentation is imperative to proving you did what you said you were going to do, especially in the event of an audit. Be stringent in training, and review all documentation before it hits the file cabinet to ensure it is accurate and appropriate.

4: Implement a robust continuous improvement process

Forward momentum through a continuous improvement process cannot be achieved unless management nurtures the program. If you are not continuously improving, you are falling behind.

5: Have a 360-degree approach to employee engagement with 24/7 awareness and communication

Top-down communication is critical to highlighting the priorities and needs of an organization and will not be effective unless an organized program is in place. Organizations that are not making the necessary pivots to communicate with the multiple generations within their workplace today will struggle to sustain change.

6: Foster an atmosphere of mutual respect

Treat people as you would like to be treated, turn the other cheek, etc. There may be lots of adages you quote, but which one best describes your facility and the relationships with management and peers on a daily basis?

7: Be sure employees have consumer awareness for the products they produce

Do your employees know who the end consumer is of the product that they are producing every day?  Does your culture include a review of consumer complaints and customer complaints with your frontline workers?  Listening in to a call center is a very powerful way to help employees understand what affects consumers and how their job is critical to avoiding a food safety or quality issue.

8: Create accountability across the board

Hold folks who do not support the culture in which you are striving to develop or maintain accountable, regardless of their position or stature.

9: Provide positive reinforcement. It’s the best motivator

Work to catch people doing things right and make a big fuss when you do. Positive reinforcement for a job well done is the most powerful motivator. It helps keep every team member on board with food safety commitments.

10: Celebrate often

We spend too much time at work not to celebrate all the good things that are accomplished. Whether it’s a cake and recognition for those that served in the armed forces on Veterans Day or a successful launch of a new product—celebrations are a great way to recognize and reinforce your employees’ hard work. Identifying and correcting mistakes should also be celebrated; they are fertile ground for making changes and provide great nutrients for continuous improvement.

Mobile technology and food safety

The Digital Revolution in Food Safety

By Manik Suri
2 Comments
Mobile technology and food safety

News concerning the safety of food seems to be everywhere these days. On a daily basis there’s a story about a salmonella outbreak or a company initiating a product recall due to possible contamination. Why is this the case?

If you visit most food businesses, whether it’s a restaurant, grocery store, manufacturer or foodservice operator, chances are you’ll see the same thing: Employees using pen and paper checklists, forms and log books to manage their food safety operations.

The recent E. coli outbreak traced to Chipotle Mexican Grill infected more than 50 people and led the company to shut down several restaurants. The outbreak was also a PR disaster for the company and damaged its reputation as a reliable provider of safe meals. Chipotle lost out on potential revenue and probably spent a good amount of money on hiring outside food safety consultants to examine its safety standards.

Since starting the business, Chipotle has remained focused on a core mission: Make great-tasting food, and more recently, food that is not modified with GMOs. While its goal has not changed, running a food company is vastly different today than in the past.

Modern Food Safety Isn’t So Modern

For one thing, there is a lot more paper to manage in today’s world. Between time and temperature controls, HACCP and HARPC requirements, and a whole host of industry certifications and brand standards, food businesses implement several safety processes. Even with advancements in technology, food safety operations are often run manually and therefore are error-prone.

In the early 1990s, food companies could handle the volume of paperwork themselves. Today, they’re swamped. Visit a food business, and you’ll see the same thing everywhere: Stacks of documents that need to be typed up and sent to food agencies. As one quality assurance manager recently stated, “We can barely keep track of them all.”

Surrounded by stacks of paper in their office, quality assurance (QA) managers explain that much of the pileup is due to more rules and regulations related to food safety. Food companies must comply with a growing number of local, state and federal laws that regulate food safety. The focus of recent laws such as FSMA is toward prevention of foodborne illness, placing even more emphasis on internal audits and recordkeeping. In addition to these laws, food companies must compete with the wealth of information available to customers about how their food safety operations work. Especially in the realm of social media, as Taco Bell has learned, one photo of an employee playing with food can lead to a PR nightmare.

A Day in the Life of a QA Manager

Complying with food safety laws often falls on a company’s QA manager who supervises food safety. She walks through the facility several times a day with clipboard in hand, reviewing a list of safety and quality measures.

The QA manager will then manually key this data into a spreadsheet, create reports, and file the results with industry partners and government regulators. These seemingly routine and time-consuming compliance tasks matter. Failing to comply with the appropriate laws can lead to costly penalties, permitting delays, loss of business from industry partners (such as retailers with strict requirements), and even legal action.

The legal requirements are often complex, overlapping, and they change every couple of years. The laws are designed, of course, to ensure that food preparation and delivery is safe, thereby protecting consumers. But an expanding body of regulations and fear of litigation have increased the time, cost and stress that play into compliance.

Mobile technology and food safety
Mobile tools can help companies improve food safety processes.

Improve Food Safety with Technology

So how can companies improve their food safety operations? By using food safety technology, particularly mobile software tools, to improve their processes. Since food safety operations are still manual, they tend to be hard to standardize and difficult to track—especially at larger companies where employees are working in multiple shifts across dozens of locations. Mobile food safety software offers several major benefits:

  • No More Pen and Paper. Replacing paper-and-pencil clipboards with digital tools saves time and money. Digital audits and task-lists can be logged and tracked, ensuring that staff are performing tasks in real-time. Digital entries are more accountable; managers can confirm when and where tasks where conducted and completed (including requiring photos to be taken). And digital clipboards can be loaded with reference materials like images and training videos, which helps staff learn best practices and prepare for real inspections by government agencies.
  • Quality and Safety Checklists. Instead of letting employees complete tasks ad hoc and make notes on clipboards and log books, companies can use quality and safety checklists to ensure that key tasks are standardized across the organization. For example, data can be collected to show that a company is always forgetting to label produce with an expiration date. Digital food safety and quality checklists that are loaded on smartphones or tablets makes it easier to ensure that all employees are following brand standards and best practices.
  • Automated Reports. Instead of sifting through binders filled with audit logs, food safety software captures and stores data in a structured format, making it easy to search and analyze. Why waste hours at the end of every week or month sifting through binders full of paper, when software lets you generate insights with the click of a button?
  • Real-Time, Centralized Management. Food companies often have multiple locations in which employees are conducting food safety operations in their own way. For companies that have multiple locations, mobile software being used by employees at each location can help corporate managers track performance by location, provide critical alerts, and give employees real-time feedback to help standardize food safety operations.

Here’s an example of a QA manager running a food safety audit using mobile software. During a random spot check, the manager shows up on the line with a smartphone in hand. As she walks around, she pulls up a food safety application and answers a series of pre-set multiple choices questions that cover key criteria, dictates comments into the device using the built-in voice recognition, and takes high-resolution color photos of several problematic issues. If a QA manager is unsure about food safety requirements, she can use her mobile device to quickly pull up a reference document (or even the official code citation) from state, FDA, USDA or other agencies.

After running a digital audit with food safety software, the QA manager can immediately print or e-mail a report that shows all of the items out of compliance, creating actionable intelligence for her team. The QA manager can then share this with line workers during their weekly team meeting, which help to train staff on best practices in food safety.

The data the QA manager collected through her mobile device is immediately stored in the cloud. From there it can be easily accessed by a colleague (i.e., her manager at corporate headquarters) at any time. Over time, the data from each of these spot checks is stored in a central database that a manager can analyze, looking for trends in performance, issues that keep arising, or locations that may need extra training and attention. Mobile software makes it easier to generate insights that can drive major improvements in an organization’s safety and performance.

By using software to help manage food safety audits, logs and line checks, businesses can save time and money on compliance, train staff on best practices, and most importantly, keep customers safe and satisfied.

Today, food safety technology, especially mobile software, should be a critical part of any modern food company’s operations. Mobile audit and task-management software allows QA managers to streamline and standardize quality and safety operations across large teams and multiple locations, helping save valuable time and money. Whether you’re a mobile food vendor or a large-scale food processor, modern software tools can help food businesses of all sizes effectively manage time-consuming tasks around food safety and compliance, from digitizing audit logs for analysis to created automated filings for supply chain partners.

Hand

Why Management Reviews and the SQF System Go Hand-in-Hand

By Clare Winkel
1 Comment
Hand

SQF certification is an ongoing process; once you have attained it, you have effectively committed to a continuous improvement program for your business. Conducting regular, thorough and transparent management reviews will play a key role in ensuring that you continue to achieve your SQF goals.

The first and most important thing to understand about management reviews is that they don’t have to be a cost to your organization. In fact, when conducted correctly, these reviews should become the cornerstone of your continuous improvement program, assisting you in measuring company performance against documented objectives.

Once you’ve committed to a management review, it’s important to be aware of the fact that these reviews take significant preparation. The senior management team will be responsible for reviewing the SQF system, preparing for and documenting the review procedure in its entirety. As outlined in clause 2.1.2.4 of the SQF system, there are four key elements against which company performance must be reviewed:

  • The SQF policy manual
  • Internal and external audit findings
  • Corrective actions (investigation and resolution)
  • Customer complaints (investigation and resolution)
SQF Management Review Procedure
Click to enlarge this document on how to conduct a Management Review Procedure

The management team is required to make adequate resources available for food safety and quality objectives and to support the development, implementation and maintenance and ongoing improvement of the SQF system (clause 2.1.2.3). This team must also establish processes to improve the effectiveness of the SQF system in order to demonstrate continuous improvement (clause 2.1.2.9).

Keeping Good Records

One cannot overstate the importance of thorough and effective documentation of the review, so remember the mantra: If you don’t write it down, it didn’t happen.

Every aspect of your review must be clearly and thoroughly documented. These records are important documents in the SQF audit process and also as benchmarks against which company performance and subsequent reviews can be measured.

Management Review Process

The management review process comprises four key stages:

  • Identifying objectives
  • Collecting and analyzing data
  • Management review meeting
  • Disseminating results

1. Identifying Objectives

Identifying objectives should be your first step. You cannot start collating data before you know what you’ll be measuring it against. Objectives are essentially short statements that outline what you want your company to achieve in specific business areas. They should encompass a whole-of-company approach in that they should contribute to overarching company goals rather than delivering a one-sided or fragmented approach to continuous improvement. It is important to note that objectives are neither mission statements nor warm and fuzzy statements.

As a general rule of thumb, objectives should be:

  • Measurable. They should outline specific quantities and quotas for what you are trying to achieve.
  • Business-specific. Objectives should be relevant to the future of your business and to the individual business improvement process. Don’t worry about what your competitors are doing.
  • Relevant. Make sure the objectives will have a significant and lasting impact on your business once they are achieved. This might mean choosing complex objectives versus taking the easy way out.
  • Linked to a key performance indicator. Every objective should contribute to the company’s KPIs and be part of its broader strategic goals..
  • Clearly defined. Be clear about what you are trying to achieve and how you plan to achieve it.
  • Documented. Write your objectives down! The review process, future audits and your ongoing improvement efforts will be measured against them, so it is important to accurately capture the details.
  • Communicated across the breadth of the organization. Don’t make the mistake of keeping them in a filing cabinet somewhere. Put them in the lunchroom, put them in induction packs, hand them out during annual updates—share them with your team so that everybody understands the goals.

2. Collecting and Analyzing Data

Data collection is one of the most time consuming components of the management review process, so have a clear game plan ready before starting. Ask the following questions:

a.    What information must be extracted from company records?

Determining the sort of data you need depends largely on your management review objectives. Your data should deliver insights on company performance and provide an evidence base for changes you make to your business processes. As a food company, your SQF systems should monitor and collect data on a wide range of business activities, including:

  • Preventative maintenance result reports
  • Equipment breakdown reports
  • Goods inwards records
  • Verification results (i.e., swab results, lab results)
  • Cleaning records
  • Corrective action reports
  • Near miss incident records
  • Pest control records
  • Swab and microbiological results from cleaning processes
  • Microbiological results from water supply and product testing, or raw material testing
  • Insurance and credit claims
  • Chemical product results
  • Mock recall tests
  • Product traceability tests

Think about the data sources that respond directly to the objectives you developed for your review. You should be leveraging the systems you already have to collate information, with a view to feeding the information back into work practices to create a loop of continuous improvement.

b.    What format is the data in and how can you make it accessible?

Like most food companies, your company is likely to be home to a mix of paper-based and electronic data. Different data types throw up different challenges when it comes to data acquisition. Paper forms are easy for staff to use and easy for management to collect, but they require double handling in order to translate relevant data into a format that can be analyzed with any degree of depth. Electronic data collection is more useful when it comes to number crunching, but you need access to specific expertise when it comes to data extraction if you want your data to work effectively for you. Newer, more sophisticated data management systems will help automate data collection activities and will also ensure that your database systems can communicate with each other to share relevant information.

Data access is another issue to think about early in the process. Who is responsible for all the different data sets that must be accessed for the review? Is he or she the right person to manage that data? Will he or she be available at the time you need to access the data before the review?

c.     Who will analyze the data, and do you have the requisite skills in-house?

Another important element of the pre-planning process is the question of who will analyze the data once it has been extracted from your systems. Does your staff have the skills and time required to conduct effective statistical analysis? Do you have suitable software systems to support the analysis process? If so, you’ll need to allocate each data analysis task to a staff member, making roles, responsibilities and timelines for the analysis process clear. In addition, ensure that all managers have access to (and an understanding of) the previously identified management review objectives so they can target their analysis appropriately.

If you don’t have the requisite data management skills in-house, you need to think through potential solutions during the pre-planning stage, whether it involves providing training for staff or bringing in outside expertise.

Prior to the data analysis process, you should also be looking at your raw data and reviewing data outliers (that is, data that lies above or below the mode)—these can sometimes provide interesting insights about your processes and procedures. It’s important to have an experienced quality assurance team on board before you start assessing your outliers; your QA team should already understand the variables within your processes and procedures, and will therefore be able to identify whether the outliers are one-off data spikes or trends requiring further investigation.

3. Management Review Meeting

a. Meeting preparation

Meticulous preparation is key to a successful management review meeting. Ensuring all meeting attendees are on board with the agenda and meeting outcomes is a good way to get started. First, develop a written agenda and timeline for the review. Think about the timing of your meeting in conjunction with your unannounced SQF audit. Set the date of the meeting with enough time to ensure close off of the corrective actions issued as a result of the meeting. Yes, if you’re doing it properly, you should have corrective actions issued.

Next, you’ll need to get all participating staff members up to speed with the review process. Pull together the requirements of the review, the relevant SQF clauses, customer requirements and company objectives, and put them into a document that can be circulated well in advance of the meeting. Identify the individual managers who will be involved with the review—that is, the managers whose business areas will make a contribution to, or be impacted by, the review process itself. Ask participating managers to prepare the data that is relevant to their key performance areas and to the management review objectives you’ve identified, as this will be distributed at the meeting.

b. At the meeting

Good record keeping is particularly important during the management review meeting itself. Poor documentation can undermine the review and its subsequent outcomes, not to mention the SQF auditing process. As such, it’s important to capture the details of the discussion that occurs at the meeting—you need more than just a few scribbled notes. Nominate a scribe whose sole responsibility is to take notes at the meeting. Ensure they capture (at a minimum) the following:

  • Meeting date and time
  • Meeting attendees and no-shows
  • Discussion of each agenda topic
    • Key items
    • Outcomes
    • Conclusions
    • Action points
    • Objectives. Were they met? If not, why not? Do they need to be modified for next year? If so, why, and to what?
  • Action points, role responsibilities and verification of actions being undertaken
  • Conclusions

The scribe should also be responsible for compiling all supporting documentation from the meeting for audit purposes and for review prior to future management review meetings.

4. Disseminating Results

Once the review process is completed, any processes and procedures identified as requiring modification must be updated. This is also the time to follow up on action items—your meeting documentation should clearly show who is responsible for each item and their respective tasks. Engage with the staff members responsible for each item at regular intervals to chart their progress, and follow up again at subsequent management meetings to ensure that all actions have been completed.

Communicating review outcomes is very important. Charting a specific course requires an understanding of, and commitment to, that course by everyone involved in the navigation process—and you need your team to understand where you’re going so that they can help you get there. This means communicating all the outcomes, both good and bad, to all relevant personnel, and taking the time to thank and congratulate staff who were instrumental in achieving positive results.

The last step of the review process is to share your success—don’t let your hard work go unnoticed! Communicate the value of the review both to your team and your superiors, and demonstrate the link between the review itself and the achievement of individual, team and company KPIs.

Conclusion

A completed management review will deliver significant benefit to your company in the form of documented, measurable and communicated objectives that are reviewed on an annual basis. Additional benefits include:

  • Increased business value
  • Enhanced safety (for staff) and quality of product (for clients)
  • A more targeted approach to business strategy
  • Reduced financial risk and increased profitability