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Identifying Gaps in Your Food Safety Programs & Being Guilty Until Proven Innocent

Posted on November 9, 2018 by Brian Sharp

Recently we were joined by Cathy Crawford and Stephanie Faucetta from HACCP Consulting Group, for a very informative online discussion on FSMA Preventive Controls and identifying gaps in your current food safety program. Key insights shared by both Cathy and Stephanie included topics around risk assessments, meeting FSMA PC requirements, best practices, and more.

With so much information, we decided to pull out some key takeaways.

Biggest Gaps Most Often Seen In Food Safety Plans

When asked about the biggest gaps from current plans to FSMA requirements, Cathy identified five scenarios:

1. Companies that don’t have a HACCP plan

As Cathy puts it, “Quite simply, HACCP really fosters safety and quality. All that time and effort that goes into a well-designed HACCP plan usually leads to identification of concerns or improvements that weren't considered previously and leads to a stronger system and better regulatory compliance. It truly improves the process and helps you show that things are being done correctly.”

2.  Companies that have a HACCP plan but no food safety plan

A food safety plan has now become a more broad way of expanding hazard analysis and includes many of the “newer” hazards that Stephanie mentioned in our webinar such as allergen controls and sanitation controls. Systems are growing as a way to ensure compliance.

3. Lack of discipline on documentation

Cathy discussed the common saying “if you didn’t write it down, it didn’t happen” and shared that she has elevated that to, “the way you wrote it down is the way it happened,” to force people to be as diligent as possible in their data and records.

4. Hazard Analysis – limited views

Cathy identified “traditional HACCP” as looking at your process flow and the step-by-step of making a finished product and analyzing each step. A hazard analysis under FSMA does not specify those pieces, but looks beyond those steps to review R&D, support functions, and more. She also recommended that companies consider environmental issues, supply chain issues, and sanitation, which is not typically a part of the flowchart.

5. Incomplete verification

“Verification and validation are probably the most misunderstood concepts in the industry,” said Cathy. “It's not easy. I teach an entire one day course on the topic, helping people understand the differences and identify how to do it better. Very briefly, all your food safety activities have to be completed and effective. There needs to be documentation that supports both those concepts, that you did it and that it will work and that it is working. Not just today, but daily. Then retain those records of verification and validation according to the applicable retention policies.”

FSMA is really changing how companies review and analyze their food safety programs. It really forces teams to take the attention to detail to that next level, expand review of hazards beyond the obvious, and look at things in a different way.

Guilty Until Proven Innocent

I think Cathy really hit home with this statement: “The food industry, I often say, is kind of opposite of the American way. Part of the American way is that you’re innocent until proven guilty when there's an issue. In the food industry, it's the other way around. You're guilty unless you can prove you're innocent. With the new regulatory requirements, this further enhances the need for good records.”

Thank you to both Cathy and Stephanie with the HACCP Consulting Group for sharing your insights. 

If you’re looking for solutions that can help you more effectively manage FSMA compliance – look no further, learn more about how SafetyChain helps ensure your programs are executed to plan, properly documented and most importantly, give you the data intelligence you need to identify and manage issues earlier – and continually improve your operation!

Topics: Safety