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From: Food Quality & Safety magazine, February/March 2009

Food Safety is all in the Details

The first step in setting up a safety system is to keep meticulous data

by Frank Guray

We all recognize the importance of maintaining safety and quality throughout the food chain. Unfortunately, many of us do not fully understand that the key to such maintenance is meticulous documentation and recording of procedures and processes in the production, processing, distribution, and retailing of food products. Keeping track of pertinent data helps companies minimize recalls, better manage risk, and more quickly respond to problems.

The Importance of Data

The quality and safety of a food product are influenced by a host of critical events and control points. Often, this valuable data is not captured, or nonessential information is documented instead. Furthermore, the ability to link these critical pieces of data is often lacking. Though it is obvious what the consequences are if we fail to record required information, material that is necessary for regulatory and customer requirements, the negative effects of over-documentation include information overload that is difficult to manage, loss of focus, and reduced ability to correlate data are less apparent.

Let’s start with basic definitions for the types of important data. A document is a written form that provides information and can be updated or changed over time. This includes working instructions, standard operating procedures, policies, and so on. A record is a special document that provides evidence and cannot be revised over time—for example, chart recorder disks or temperature logs. In the data collection process, the two terms are not interchangeable and should be treated differently.

Abiding by the Rules

The food industry is governed by specific rules for ensuring quality and safety. When accessing critical material, food producers and suppliers should ask the all-important question, “Are we meeting the requirements?” These requirements are determined by many factors:

  • Are you regulated by a government agency like the United States Department of Agriculture or the United States Food and Drug Administration? What are the requirements? Is there a hazard analysis and critical control point (HACCP) system mandate?
  • Does the customer have an internal requirement? Does it require your location to be audited by a standard such as Safe Quality Foods (SQF), International Organization for Standardization 22000, or Primus Labs?
  • Does your corporate location have standards that you are required to follow? Too often, management teams try to comply with standards without fully knowing the requirements. Companies with no understanding of the rules find themselves in a similar situation to someone trying to play baseball without knowing how. There are three basic types of requirements to be aware of:
  • Regulatory requirements typically look at the safety of the customer, as well as legal integrity. In the simplest terms, they prevent companies from making or selling products that cause injury or harm and prohibit companies from lying to their customers. Product safety and corporate honesty seem to be simple concepts, but businesses sometimes lose sight of these ideals.
  • Customer requirements try to go above and beyond the regulations, emphasizing quality or defining the specifics that the customer wants in a product. These parameters cover everything from color, shape, smell, and size to shelf life and packaging. The food may be safe and even tasty, but if it is not appealing in other ways, it could damage a company’s reputation and reduce customer loyalty.
  • Locations that are managed by a corporate entity may have their own internal requirements. Even if the customer does not have high expectations, the company may need to protect the brand. This is especially true for large companies that supply retailers throughout the country or worldwide.

What are the consequences of not complying with specified requirements? There are many possibilities, including reduced consumer confidence, recalls, lawsuits, or bankruptcy. Keeping these requirements in mind will not only ensure customer satisfaction and loyalty but will also minimize incidents such as customer complaints and returns. However, the temptation is to not ask the questions regarding requirements to avoid looking ignorant. But in the case of food safety, it’s better to ask for permission beforehand than to ask for forgiveness later.

Drowning in Paperwork

A documented, effective, and continuously improving food safety system should be every company’s goal. One issue that can prevent a company from reaching this goal is excessive volume. Too much paperwork or too much data can cause the management team to lose focus. Many times, although the content may be necessary, the amount of paperwork is not. This can also include unnecessary procedures. One solution to this problem is to collect all of the procedures and records and, as you use them, separate them into critical, important, and unnecessary piles:

  • Critical data is required by regulatory or customer concerns, or needs to be analyzed and acted upon.
  • Important data, such as new products or upcoming requirements, is not critical now but can affect the business in the future. Within six months to a year, start boxing these procedures and destroying them as necessary. Make sure that you know the retention requirements for the government or the audit standard before shredding.
  • Unnecessary data has no use now or in the future. These documents should either be boxed and stored or slated for eventual destruction.

Since people tend to be effective when a situation appears to be manageable and not when they are inundated by the system, we’ll cover the record retention policy later.

Keep Systems Simple

Too often, we focus too much on the wording and not enough on the intent. It’s not that words are unimportant. In fact, they are very important. To be effective, written documentation must clearly communicate its intent. Excessive wordiness can make the document more difficult for the reader to understand. In order to ensure that documents are concise and to the point, use this simple rule: Do as I say, say as I do. Sometimes, it helps for managers to step back and ask themselves, “Is it really working? Is this the intent?” Remember, for a system to be effective, a company must document the system around the activities and not unnecessarily change the activities to meet a requirement.

Here’s a simple exercise. Take a common procedure such as good manufacturing practices or a critical control point (CCP) instruction in the HACCP program. Give it to a supervisor who is not involved in the authoring process. Does this person understand it or even know what it is? How much worse will it get if you give it to a line worker? Can the line worker explain what to do, as well as why it is important? Learn the lessons from this exercise, as it will make life easier for all.

Is it possible to oversimplify? Of course it is. Here’s an example: Which instructions would you prefer to have?

  1. Cut the wires.
  2. Cut the red wire, then the blue wire, to disable the explosive device.

The choice is clear, especially when safety is the issue.

Continuous Improvement

Now that your quality management system is cleaned up and under control, it’s safe to assume that your work is done, right? Wrong. Keep in mind the goal of a documented, effective, and continuously improving food safety system. Anything worth doing is worth measuring and perfecting. As your system continues to mature and improve, you should ask yourself the following questions: How do we measure and demonstrate performance of the system? Are we getting better? Are we focused on the critical issues? Though some do not understand the purpose of increasing performance, there are many benefits that come with a mature system:

  1. Better quality control processes minimize losses such as products rejected because of CCP failures as well as those returned due to customer complaints.
  2. Increased control allows companies to better manage their processes and make a higher quality product with fewer resources.
  3. Effective systems, such as preventive maintenance, reduce expenditures for equipment and facility repairs, saving the company money.
  4. As systems become more predict- able, companies can effectively decrease monitoring costs, because failures are less likely and control is more assured.

Although this is only a partial list, it illustrates some of the many benefits of a mature system.

Another important element is the record retention policy. If your system is working, just write down what you do. Yes, it’s that simple. Still not sure? Ask an expert or an attorney to guide you. When I suggest expert guidance, I do not mean that you should have a consultant create the system, thinking you will save a lot of time because you won’t have to put any effort into it. When the expert is gone, your company still has to understand, use, and maintain the system.

At first glance, the task of putting an effective food quality management system into place looks daunting. Simply looking at all of those binders and stacks of paperwork can make teams shudder, close their eyes, and hope it all goes away. Unfortunately, it won’t—unless you take the appropriate steps.

First, know your rules. Do the research on the appropriate regulations and codes, and understand what the customer and corporate requirements are. Next, it’s important to make the system manageable. Continue to maintain the documents and records that are vital to meeting regulatory requirements and keeping the customers and corporation happy.

When you are changing or adding systems, keep your focus on the intent, with the final goal being a safe product. By making sure that the message is clear for all, including the auditor, inspector, and even the line personnel, you will help create a more effective system. Finally, measure the system’s performance and find ways to improve it. Continue to strive to make the system better in order to keep the team focused on the task at hand. Keeping these issues in mind will help your company reach the important goals of producing not only safe, quality food, but food that will keep the customer satisfied and your company profitable.

Guray is SQF lead auditor at TÜV SÜD America Inc. Contact him at fguray@tuvam.com or (978) 573-2500.

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