Food Safety Culture

A successful food safety culture is the product of individual and group values, attitudes, competencies and patterns of behaviour that determine the commitment to, and the style and proficiency of the food safety management system. Senior management should plan for the development and continuing improvement of a food safety culture.

Senior management should be implementing a “It is how we do things here” food safety culture. This can be achieved by:

• Leadership – starting from the top
• Demonstrating visible commitment
• Effective communication of company philosophy and policy
• Ensuring there is accountability from the top of the organization to the bottom
• Developing employee confidence and mutual trust
• Developing reward schemes including ‘Employee of the Month’ award
• Ensuring all employees are accountable, engaged and understand the value of integrity and proactivity
• Developing an action plan for the development and continuing improvement of food safety culture

To ensure success Senior Management should be directly responsible for food safety by ensuring adequate; organization and support, equipment and facilities, training and education of all employees, reviewing and auditing performance, and driving continuous improvement.

All employees should be empowered and individually responsible for the quality of their work, resulting in a continual improvement culture and working environment for all. Employees should be encouraged and required to notify management about actual or potential food safety issues and are empowered to act to resolve food safety issues within their scope of work.

The philosophy of Food Safety should be promoted throughout the organization and in particular the Food Safety Policy.

Communication processes for promoting food safety include:

• Team briefings
• Staff reviews
• Daily Management meetings
• Feedback mechanisms
• Newsletters
• Notice boards

Senior management should monitor and measure through reports and trend analysis the degree of development of the food safety culture by analyzing information including KPIs from:

• Hygiene & Housekeeping Audits
• Internal Audits
• External Audits
• Non-conforming products
• Environmental monitoring
• Review of implementation plan and numbers trained
• Employee reviews
• Staff surveys on values and culture
• Customer Complaints
• Staff Turnover
• Staff Exit Interviews

All employees should undergo individual food safety culture development which can include:

• Food Safety Policy
• Food Safety Objectives
• Food Safety Management System Overview
• Job Descriptions
• Job Training
• Employee Briefing
• Individual Objectives
• CCP Controls – Training Procedures & Record Completion
• PRP Controls – Training Procedures & Record Completion
• Employee Review

A training matrix can be used for Food Safety Culture Planning:

Records of all training should be maintained, including those of induction, on-the-job, refresher and external training. Training schedules and records should be managed by Department Managers and where applicable include the following records:

• Training register
• Operator training review
• Training matrix
• Department training matrix
• Individual Training records including:
  • Description of training
  • Skills description
  • Name of trainee
  • Confirmation of training
  • Date and duration of training
  • Trainer details
  • Verification that the trainer has assessed the trainee and found them to be competent
• Identifying the competencies needed for specific roles
• Reviewing and auditing the implementation and effectiveness of the training and the competency of the trainer with a view to taking action to improve the training.

All food operations should have a proactive system for the prevention of contamination of products by pests that ensures there are effective controls and processes in place to minimise pest activity and ensure any pest infestation does not present a risk of contamination to products, raw materials or packaging.

Most organizations use Pest Control Association registered pest control contractor to implement a Pest Management programme and maintain the site free from pest contamination unless the organization employs a Pest Management Specialist.

A typical Pest Management contract agreement defines:

• Company and contractor key contact personnel
• Description of contracted services and how they will be completed
• Term of the contract
• Equipment and material storage specifications
• A complete inventory of pesticides (must be approved by the regulatory authority for use in a food facility) detailing the safe use and application of baits and other materials such as insecticide sprays or fumigants
• Emergency call out procedures
• Records to be maintained
• Requirement to notify facility of any changes in service or materials used
• Service personnel including evidence of competency by exam from a recognized organization

The contracted Pest Management service should provide:

• Site visits and inspections (including the periphery and internal and external buildings) based on a documented risk assessment including service records describing current levels of pest activity and recommendations for taking corrective actions.
• The provision of a plan/diagram of the site showing the location of all pest control monitoring and prevention measures
• Flying insect controls including fly killing units
• Emergency 24-hour call-out service
• Quarterly biologist inspection reports, visit and trend reports with recommendations
• A current copy of the certificate of insurance that specifies the liability coverage
• Spill control materials and procedures
• Material safety data sheet information to ensure proper usage of pesticide chemicals.

A nominated manager or responsible employee should have overall responsibility for Pest Management on site so that Pest Management is manged within site control rather than relying on contractors. Before agreeing to a contract the Pest Management Contractor should be subject to Supplier Approval to ensure that the contractor is qualified and the pest management programmes will comply with applicable legislation. Copies of the Contract, Service Agreement, Pest Control Reports and Pest Management Contractor training records and qualifications should be held in Pest Control File on site. At the start of the contract a detailed survey of the entire facility should be completed by a qualified Field Biologist and the results documented and used to determine placement of Pest Control devices.

Exterior Bait Stations

Exterior rodent bait stations should be set up to deter rodents from entering the facility. Based on the detailed facility survey, exterior bait stations should be placed along the foundation walls on the exterior of the facility and along the site boundaries. Exterior bait stations containing rodenticides should be tamper resistant, anchored in place, locked, and labelled.

Interior Monitoring

Based on the detailed Field Biologist survey, interior monitoring devices should be placed in strategic sensitive areas specific to the rodent species, and other areas of possible pest activity. Interior rodent monitoring devices identify and capture rodents that gain access to the facility. Interior monitoring devices should be placed in areas where pest ingress is first likely to be identified and secured in position.

Elimination of Pest Habitat

The Field Biologist should identify any possible pest habitat around the site in the quarterly inspections. The nominated manager or responsible employee should take actions to remove or eliminate favourable conditions for pests including eliminating any rodent burrows, rodent runs and areas that provide harbourage or may attract rodents or other pests to the site or outside grounds.

Pest Management Reporting

Records of all Monitoring devices should be maintained, including services performed, to ensure that devices are properly placed and inspected to allow trend analysis of activity. Pest Management Contractor reports include:

• Signs of pest activity
• Proofing requirements
• Actions required by site
• Type of Pest
• Pesticide or material applied
• Pesticide registration number
• Rate of application or percent of concentration
• Specific location of application
• Method of application
• Amount of pesticide used at the application site
• Next action/follow up date
• Date and time
• Review and investigation of any missing baits
• Signature of pest controller

Temporary placement of any pest monitoring devices for short-term monitoring should be documented in pest management action reports. All personnel should be trained to identify potential issues caused by pests at induction. A pest reporting procedure should be in place such that any incident or sign of pest activity is immediately reported to the nominated manager or responsible employee and any potential product affected quarantined. The nominated manager or responsible employee maintains a log of pest sightings and the action taken by the pest controller. The Pest Control Contractor should provide reports for all visits and advise on any trends and corrective actions.

Site Standards

Pests pose a major threat to the safety of food. Pest infestations can occur where there are breeding sites and a supply of food. Good hygiene practices should be employed to avoid creating an environment conducive to pests. Sanitation, inspection of incoming materials and monitoring can minimise the likelihood of infestation. Buildings should be kept in good repair and condition to prevent pest access and to eliminate potential breeding sites. Holes, drains and other places where pests are likely to gain access should be protected or sealed. Screens for windows, doors and vents should be used to reduce the risk of pest entry. The availability of food and water encourages pest harbourage and infestation. Potential food sources should be protected and stored above the ground and away from walls. Areas both inside and outside food premises should be kept clean. Waste should be stored in covered, pest-proof containers whenever possible. Pest infestations should be dealt with immediately and without adversely affecting food safety or suitability. Treatment with chemical, physical or biological agents should be carried out without posing a threat to the safety of food. Pesticides should not be used in food areas.

Pointers

As well as carrying bacteria, rodents can gnaw their way into materials and can cause substantial damage to buildings.

It is important to prevent access to pests, all access doors should be adequately proofed and/or screened.

Adequate measures in place to prevent birds from entering buildings or roosting.

Establishments and surrounding areas should be regularly examined by a competent person for evidence of infestation.

Food Complaint Levels

I have been involved in many projects to improve product quality and reduce food complaint levels. One of the best tools for indicating where action for improvement needs to be applied is by analyzing your complaint data appropriately.

Whilst you can identify faults in your factory your customers are your 100% inspection service so respect their feedback. Whilst all of your customers will not complain when they find a problem so you will not capture all of your product faults you will however identify trends.

The first step is to collate all of your complaint data. Your data should then be categorized by product type, complaint type and size. Analyzing complaints by numbers alone will not give you a real picture of your performance. What you need to know is the proportion of complaints you are getting for each product. By far the most practical way of doing this is by using the sales volumes to calculate the proportion of complaints you get for each product. Some people use weight or volume such as complaints per ton or 1000 Liters. My preference is to use complaints per million units.

So, you analyze your complaint data product type, complaint type and size per million units. From this data, you can easily spot the worst performing product lines.

You should then analyze the results for the worst performing products:

Are they all the same size?

Are they produced on the same filling machine/production line?

Is it the same type of complaint?

The answers to these questions will generate your corrective action plans. If products with the highest complaint levels are all the same size it could be a particular problem with that size of packaging. If it is all the same type of complaint then why are some product lines worse than others? If product from one particular production line is generating the highest number of complaints per million units then there must be a reason for this, it needs investigating.

You should compare product performance and if there are significant differences you should ask the question why? At this point complaint trends are useful. For example, when I worked with fresh pasteurized milk sour complaints were higher in larger sized containers. The reason for this was not related to the quality of the product but the fact they took longer to consume and spent more time in and out of the fridge. Such products would be targeted for improvement projects as opposed to corrective action to remedy a problem area.

A few words of caution though, your analysis needs to take into consideration the comparative value of the products and the market. People are more likely to complain about higher value products. Also, some retail customers are much better at reporting complaints from customers to the extent that I used to get 10 times the complaint levels from one particular retailer compared to another for exactly the same product.

My last tip the more data you analyze the better. In the past I have analyzed 3 year’s worth of data. Why? It gives a year on year performance so you can see if things have been improving or deteriorating and also it shows any effects of seasonality. For example, it is not reasonable to compare summer levels of “off” complaints on a fresh product with winter levels. This is why in the Northern Hemisphere I would compare August complaint performance with the complaint levels for August in the previous year.

The complaint analyzer that I have developed based on over 30 years’ experience in the food industry is included in our Food Safety Management System Implementation Packages.

A Food Safety Management System should be planned, established, documented and implemented in order to ensure compliance with company, customer, regulatory and statutory requirements. Senior management need to confirm the scope of the Food Safety Management System including product categories, processes and activities conducted on by the organization.

Senior management need to be committed to the food safety management system and establishing and implementing, then fully communicating and supporting company policies, procedures and objectives. Senior management plan, establish, document and implement the food safety management system by:

• Establishing and implementing a Food Safety Policy.
• Communicating and Maintaining the Food Safety Policy.
• Establishing and implementing Food Safety Objectives.
• Communicating and Maintaining the Food Safety Objectives
• Leading and supporting a food safety culture within the site
• Conducting regular pro-active management reviews and communicating outputs.
• Communicating commitment to satisfying customer requirements including food safety, quality and service
• Supporting and planning the development and operation of the Food Safety Management systems.
• Ensuring the food safety management system is maintained when changes are planned and implemented.
• Establishing documentation required for the effective development, implementation and updating of the food safety management system and communicating pertinent information throughout the organization.
• Providing the human and financial resources, and training, to manage the Policies and Objectives effectively.
• Providing the infrastructure and work environment to manage the Policies and Objectives effectively.
• Promoting an ethic of continuous improvement throughout the company.
• Ensuring the strict observation of all food safety system procedures, the use of correct materials and equipment, recording and reporting of both standard and non-standard events and compliance with the company rules.
• Providing the resources to audit the Food Safety Management system effectively.
• Providing the resources necessary for the food safety team to effectively implement a Food Safety HACCP plan.
• Carrying out regular Management Reviews.
• Implementing and maintaining Corrective Action, Preventative Action and Continuous Improvement Plans.
• Communicating effectively throughout the food chain from primary suppliers to end consumers including any relevant food safety information.
• Providing the resource to ensure the company is kept up to date with all industry codes of practice, legislative, scientific and technical information appropriate to the products in the countries of raw material supply, production and product sales.

Due diligence

An effective Food Safety Management System demonstrates due diligence of the company in the effective development and implementation of safe food operations. The Food Safety Management System documents are supported by the completion of specified records for the monitoring of planned activities, maintenance and verification of control measures and by taking effective actions when non-conformity is encountered.