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Training Oversights and Their Impact on GFSI
Numerous audit failures highlight need for greater communication with employees
by Laura Dunn Nelson
The Global Food Safety Initiative tightened food safety standards with the North American introduction of its approved benchmarking schemes in 2007. These were developed to increase the safety of all food production and manufacturing by incorporating all of the food safety requirements within GFSI’s guidance document. GFSI’s benchmarked food safety schemes require plants to identify their internal risks to food safety and establish a process to mitigate, reduce, and, ideally, eliminate those risks.
Yet one of the most important elements of these schemes, the need for training and knowledge retention, often falls short, as a number of third-party audits can attest. Many workers who have passed classroom testing demonstrate a troubling lack of knowledge about food safety when questioned by auditors. For a plant, the results could well mean a finding for nonconformance and a failure to achieve its chosen GFSI benchmark scheme (e.g., Safe Quality Food or British Retail Consortium), rendering a delay in certification while time-consuming corrective actions are taken.
The underlying issue behind these training inconsistencies is not difficult to pinpoint. The training process lacks thoroughness for several reasons, such as ineffectual testing with marginal passing scores, inadequate proof of actual comprehension, or timely remediation follow-up when questions are missed. Based on a recent survey of auditors from eight global firms, training practices that do not adequately teach or ensure comprehension are occurring with what can objectively be called alarming regularity. Results show that 25% of audited food manufacturing or distribution facilities, not an insignificant number, are falling well short of acceptable training practices. Companies need to understand why these training issues continue to fall through the cracks and what can be done to alleviate them. One innovative solution is to integrate all training platforms.
GFSI, Training, and Risk
GFSI benchmarks broad foundational competencies in food safety concepts and programs. In Version 6, the most recent for the GFSI Guidance Document, the foundation lists as one of its objectives the development of “competencies and capacity building in food safety to create consistent and effective global food systems.” There can be no doubt that one key to competency is thorough and effective training that positively influences awareness of food safety and behavior in the workplace.
However, the focus becomes more specific when it comes to company programs, particularly food safety risks at individual plants. That has become increasingly clear during GFSI audits in which auditors question a large number of randomly selected employees to verify comprehension of food safety protocols and, equally important, application of those concepts in the plant operation. Many plants have been hit with nonconformance findings based on answers given by individual workers that, in the view of the auditor, constitute a potential food safety hazard. The result is that companies are recognizing, belatedly, the need for more specific training relating to standard operating procedures, along with food safety protocols and procedures.
Plants are also recognizing that a greater emphasis on risk management is a vital function of every aspect of food manufacturing, processing, and distribution. Reducing the risk to food safety through comprehensive and documented training is an important element for scheme certification, necessary to achieve GFSI standards. The FSMA also recognizes the training imperative by including it among preventive controls necessary to ensure food safety.
Yet, despite the importance of training, companies continue to multiply the risks caused by employees not suitably trained to deal with potential microbial, chemical, or physical hazards. Effective GMP training and verification are called into question when auditors find employees wearing improper attire, displaying a lack of awareness of sanitation protocol, and failing to understand the need to control the spread of allergens.
Unfortunately, auditors find these kinds of problems all too often. In early 2011, a private firm surveyed auditors from eight global auditing firms about employee training. The auditors, who were guaranteed anonymity, were asked about such issues as verification of comprehension, whether the training was updated on a regular basis, and if the documentation was acceptable. Their answers were surprising at best and disturbing at worst.
Failure to train new employees and failure in testing and training verification were among the most common nonconformance issues mentioned. Also falling short, according to auditor responses, was plants’ ability to satisfactorily document proof of training compliance verification. Among the list of documentation deficiencies were difficulty accessing documents and records, failure to validate food safety performance on a daily basis, incomplete training documents, and insufficient proof of successful remediation.
The survey findings do not surprise Gary Smith, vice president of certification and supply chain solutions for Steritech Group Inc., a major provider of brand protection services. “The number one issue with training is the ability to demonstrate the activities to the auditor,” Smith said. “Then we’re finding that if something goes wrong, employees don’t know what corrective action to take.”
Smith said the GFSI Guidance Document has “raised the bar,” and companies seeking scheme certification should realize that employee job performance is a reflection of their training and comprehension. “Why are employees struggling to demonstrate their knowledge? Because they’re not properly trained,” Smith said.
Umbrellas vs. Silos
What has been made painfully clear is that food safety training at many plants is not unified. Companies tend to allow individual departments, such as quality assurance or human resources, to develop their own programs to achieve training objectives. Such disparate approaches within one plant, separate “silos,” are likely to lead to conflicting results and limited training success, drawing the eventual skepticism of experienced auditors. Documentation is one object of scrutiny: Information about classes attended, testing, and follow-ups will vary from department to department—and the paper trail may be difficult if not impossible to navigate. Inconsistencies within one company, especially when it comes to documentation of comprehension after training, place that company at risk for findings of nonconformance and a delay in achieving scheme certification.
Progressive companies now recognize the need to place their initial training, comprehension, remediation, and refresher training under one unifying umbrella rather than separate silos, which can vary in procedures from department to department. Here, technology can provide the required support with a thorough, easily accessible, and fully documented platform.
A comprehensive technological approach can integrate all employee learning plans in such diverse areas as food safety, workplace safety, and standard operating procedures. It is also an asset in addressing every other facet required for scheme certification, GFSI standards, and company-specific training objectives. Through technology, learning plans can be developed and modified, training presentations and attendance can be easily tracked, and test results for every class are easily maintained. In fact, all are accessible whenever anyone, including an auditor, requests them.
One company that can attest to the success of an integrated technological approach is O-AT-KA Milk Products Cooperative, a Batavia, N.Y., global dairy processor. The company, which had already been certified for SQF Level 2, wanted to be certified for Level 3 but recognized it needed to make substantial changes in its training program. To meet annual training requirements for food safety topics and SOPs, O-AT-KA knew it had to emphasize job-specific content and upgrade its validation of employee comprehension, all of which had to be properly documented.
At first the company feared it would have to add personnel because of the paperwork it assumed would be required for the higher level of SQF certification. Fortunately, the automated technology platform the company implemented enabled more efficient usage of staff time, increased the number of training topics that could be covered, and basically eliminated the need for paperwork, with all records stored and documented electronically. The result: O-AT-KA was granted Level 3 SQF 2000 certification in 2011, achieving one of the schemes that meet GFSI standards. The company also confirmed that it had reduced the paperwork necessary for its training records by nearly 100%.
Ensuring Effective Training and Minimizing Risk
The roles of training, comprehension, and remediation are critical, and their importance is not limited to GFSI standards. There is little doubt that the FDA plans to strictly enforce the provisions of the FSMA on executing preventive controls in the food industry, particularly when it comes to training. Haphazard documentation, marginal passing grades, and delayed remediation follow-up will be viewed as unacceptable. This is especially true when such actions do little to decrease the risk of contamination because of unwitting oversights and an unwarranted assumption that passing grades equate to understanding serious food safety concepts on the plant floor.
It is up to management to establish a culture of food safety within every plant employee. One of the best ways to start is by implementing a training process that goes beyond concept instruction by enabling employee understanding of safety procedures and their importance to workplace and public safety. By using technology to integrate and document every element from teaching to testing, from remediation to refresher courses, a company can influence safety-conscious behavior. When a plant is able to meet GFSI standards and comply with FDA and FSMA requirements due to its training process, it is protecting the brand, the bottom line, and—most important—the customers who consume the food it produces.
Laura Dunn Nelson is director of industry relations for Alchemy Systems, an Austin, Texas-based company that creates and globally markets highly interactive training products that use technology and media to educate individuals and groups. You can reach her at email@example.com. Visit Alchemy’s website at www.alchemysystems.com.