Top 10 Considerations for Building a Robust Food Safety Management System

Vel Pillay, Manager Food Safety Programs – LRQA Americas

Old Habits Die Hard There is still a belief amongst some managers in the food industry that an organization only needs a robust HACCP program to control food-borne hazards and manage risks, and that the HACCP program owner is the Quality Assurance (QA) department.

Casting our minds back 10 years ago, food safety professionals (who were commonly referred to as ‘HACCP coordinators’) remember the days when the HACCP program was a QA department initiative with support, but no commitment, from division managers, and when communication of management of change was on a need-to-know basis. Instances where procurement made deals with new suppliers and where engineering worked with production to acquire and install new equipment without involving the QA department were not uncommon.

I recall a situation where increased capacity was required because of a promotion launched by marketing. The production and engineering divisions installed an additional cooking kettle to the current Clean-In-Place (CIP) system. The flow rate during cleaning was not taken into account, and validation of the system was not performed as a result of excluding QA from the team. The result was inadequate cleaning which eventually led to a large amount of product being destroyed and having to explain to the consumer why products were not available during the promotion.

Analysis of the information obtained following years of assessing both large and small organizations that have implemented food safety management have confirmed that no matter how robust the HACCP system is, it is doomed to fail if there is no management support and commitment. A stand-alone HACCP program is a food safety system, not a food safety management system (FSMS).

This article looks at the 10 key steps to building your system, giving equal consideration to both your management systems and your operational requirements. It also outlines some of the areas where mistakes are common and defines ways to avoid these mistakes.

For implementation of a system to be successful, we first need to understand what a management system is.

What Is a Management System? The International Organization for Standardization (ISO) defines a system as “a set of interrelated or interactive elements” and a management system as “a system to establish policy and objectives and to achieve these objectives.” A management system is also referred to as a process based system where process is defined as “a set of interrelated or interacting activities which transform inputs into outputs.” Using these definitions collectively, we can look at a management system as “establishing policies and objectives to manage processes.” Why Manage Processes? In the 1950’s, Dr. Deming introduced the concept that processes are interconnected, and that one should look at processes in an organization as a whole, not in isolation. What he meant by that is that all work, in all parts of the organization – whether in manufacturing, new product development, logistics, procurement or finance – is accomplished by a series of interconnected steps which can be defined in a holistic fashion as one process. This is where FSSC 22000 comes into the picture.

FSSC 22000 takes a systematic approach to managing the various processes involved in any kind of food safety management system. It takes the view that making any kind of product involves a set of interrelated activities, including: identifying requirements, product realization, measurement, analysis and improvement, management responsibility, and resource management. Consideration for these interrelated activities is critical to ensuring the rigor of the system at preventing a catastrophic failure.

Deming also introduced the Plan-Do-Check-Act (PDCA) cycle and recommended that the business process should be placed in a continuous feedback loop so that managers can identify and change the parts of the process that need improvement. According to Dr. Deming, sources of variations are the causes of deviation from customer requirements and should be controlled.

Bill Smith, the Father of Six Sigma, elaborated more on sources of variations when he introduced Six Sigma at Motorola. Six Sigma has been a successful concept because it fosters commitment by management to bring about effective changes, and it requires the use of tools to improve the system.

How Do These Concepts or Initiatives Relate to Food Safety Management Systems? A Food Safety Management System (FSMS) can be construed as having a similar makeup. That is, a management initiative that demands commitment and process control using a HACCP program which is basically a tool or concept to be proactive in controlling food-borne hazards. Both form an integral part of the food safety management system.

In order for the deployment of the FSMS to be successful, management systems and management commitment must become a way of doing things throughout the whole organization. This may require a transformation in the way an organization perceives its environment and its role in that environment. Once management systems become the way in which people work within an organization, it will become the core to any initiative launched by that organization. Where this happens, the same management system could then be used to launch a quality system, an environmental system or a safety system.

In addition to management commitment, process control within the FSMS is critical to ensuring that food safety hazards that may be reasonably expected to occur are identified, evaluated and controlled in such a manner that the product does not directly or indirectly harm the consumer. In this way, the importance of process control cannot be over-emphasized.

Lessons Learned from Assessments From my experience, a common cause of failure in deployment and implementation is underestimating the importance of having both a functioning management system and a robust HACCP program in place. Failure is also due to the food safety systems not being established, operated and updated within the framework of a structured management system.

My experience has shown that organizations that had a management system as a way of working had an advantage in the deployment and implementation phase of the FSMS. This was because the culture of a holistic approach and working as a team, not in silos, had already been instilled.

“Once management systems become the way in which people work within an organization, it will become the core to any initiative launched by that organization.”

How Do We Build a Robust System? There is no magic bullet nor is there one right way. One of the approaches that works well is to start by assembling a multi-disciplinary team under the leadership of a strong manager, then providing in-depth training for all the members of the team in both management systems implementation, planning and realization of safe products. In addition, all levels of management, from the top down, should be made fully aware of their responsibilities, expectations for participation in the program, and how and what to communicate internally and externally. Then, organizations should identify the controls needed to proactively manage food borne hazards using a step-by-step, simple and logical approach:

1. Establish, implement and maintain measures to create a hygienic environment to control the likelihood of introducing food safety hazards to the product through the work environment, product-to-product contamination, or through process-to-process contamination. 2. Gather the information necessary to conduct a hazard analysis. All materials and ingredients entering the premises and all process steps should be considered. 3. Conduct the hazard analysis to determine which hazards need to be controlled. To do this, first identify the hazards that are reasonably expected to occur (this includes all potential food borne hazards), then determine the acceptable level for each hazard identified, taking into account regulatory, customer and organizational requirements. In addition, the intended use of the product by the consumer and customer should be considered because acceptable levels could be different depending upon intended use. For example, if milk is being processed for consumption, the acceptable level would be different than milk used for further processing such as evaporated or condensed. 4. Assess the hazard to determine whether it is significant and needs to be eliminated or reduced to an acceptable level, taking into account possible severity of adverse health effects and likelihood of occurrence based on historical data. 5. If the hazard is significant, put into place control measures or a combination of control measures to eliminate or reduce the hazard to an acceptable level. Then, review the effectiveness of the control measures and categorize whether it should be managed through Prerequisite programs, Operational Prerequisites or Critical Control Points (also known in ISO 22000 as the HACCP Plan). 6. Establish the Operational Prerequisite Program (OPRP) and Critical Control Points (CCP), determine the critical limits, establish a system for monitoring and correction, and determine corrective actions to be taken when critical limits are exceeded or when there is a loss of control of operational PRPs. It is important that control measures are capable of being effective and meeting their intended purpose. This is done through validation. 7. Confirm that specified requirements have been fulfilled by verifying that control measures are implemented, that hazards are updated when there is a change or when newly recognized hazards are identified, and that the system is effective. Using verification tools such as internal audits are important. 8. Ensure the result of verification activities are individually evaluated, compiled, analyzed, trended and acted upon. These should include inputs to management review meetings in order for management to make decisions and take appropriate actions on improvement of the effectiveness of the food safety system, resource needs, re-evaluation of the policy and objectives, and assurance of the food safety system as part of the continual improvement process. 9. Ensure that documents required by the Food Safety Management System are controlled and that records are established and maintained according to the requirements of the standard. 10. The framework should also take into consideration the role and commitment of the management team in ensuring that food safety is supported by the business objectives of the organization and that policy and measurable objectives are established, and reviewed for suitability.

Conclusion Again, there isn’t one right way to build a robust food safety management system, but I believe that equal consideration should be given to both operational requirements and management framework to support the success and effectiveness of the system.

Remember, a stand-alone HACCP program is a food safety system, not a food safety management system. To ensure food safety, organizations should take a systematic approach to managing the various processes involved in any kind of food safety management system and throughout their organization. To do this, it should be understood that an important part of ensuring food safety means taking the view that making any kind of product involves a set of interrelated activities and that management of these interrelated activities is critical to ensuring the rigor of the system.