By Amy Scanlin, M.S., EAS Consulting Group, LLC
When the FDA’s overhaul of food safety, the Food Safety Modernization Act (FSMA), is fully rolled out in 2016 it will be the largest change the U.S. food industry has seen. And yet with all the increased requirements for compliance there is one link that is not addressed and cannot be addressed by FDA, that of an organization’s corporate culture and employee internal commitment to getting it right.
How can the industry help further corporate culture and individuals to understand, care about and comply with their personal roles in food safety? Food safety culture is communicated not only through written protocols but through unwritten commitment to compliance and attention to detail. EAS Senior Consultants Tim Hansen, Joan Rosen and Joseph Famiglietti share their thoughts on how corporate culture affects a firm’s understanding and response to FSMA.
Food Safety Leadership from the Top Down
“There is no question in my mind that food safety leadership starts at the top,” says Tim Hansen. “There are several reasons. First, it is usually a regulatory requirement. Second, food safety concepts are not always simple so management has to implement procedures that protect food safety as the average line worker may not understand the concepts and third, a food safety problem can cause great economic harm to the producer. It is leadership’s duty to ensure that this does not happen.”
“A food company needs to have a continuous program in place to keep their employees involved with food safety,” adds Joe Famiglietti. “A problem that I’ve seen over the years is the highest ranking officer delegates quality control and training functions to certain employees and holds them responsible for ensuring these programs are successful. CEO’s need to get more involved in product safety and demonstrate their involvement to their employees. Employees need to know that food safety is critical to their jobs and that company management is playing an active role in implementing programs to ensure their products do not adversely affect the public.”
The culture of an organization plays a role, Hansen explains. “If all employees feel like they are part of the organization and the firm treats everyone fairly there is a good chance that employees will go the extra mile. Accomplishing food safety goals can be problematic when there isn’t a highly engaged work force.”
“Employees will care more about food safety when management demonstrates leadership by ‘walking the talk,’” says Joan Rosen. “Simple steps can go a long way to build trust and drive food safety commitment.” She also says that consistent communication and actions will help to convey the company’s food safety mission and vision. This can include posting reminders around the facility, or incentives for sharing examples of food safety practices and improvements with peers.
Training and Compliance – Lessons from HACCP
Hansen cites compliance lessons learned by FDA during the implementation of the 1997 Seafood HACCP rule. “Almost all the processors had findings on the FDA 483 form,” he says. Some firms clearly did not do their due diligence in conforming to the new regulations but most of problems were due to the sheer complexity of the new requirements. The processors did not really understand what FDA expected. FDA had a big learning curve in how to communicate these complexities and have largely succeeded.”
FDA is drawing on it’s experience with HACCP as it prepares to roll out new rules under FSMA. But companies will need to understand that simply conducting a hazard analysis and preparing a written HACCP plan may not be enough,” says Famiglietti. “They may need to take a closer look at their raw material suppliers and conduct more product testing and environmental monitoring to assure they are producing a safe product.”
“A lack of training is frequently the cause of errors,” says Rosen. “Training is not just a matter of sitting people down, explaining a set of instructions and then signing a paper saying ‘I attended and have been trained.’ Verifying the effectiveness of training is just as important or perhaps more important than the training itself.”
Getting it Right – Low Acid Canned Foods
Hansen, who was a Director in FDA’s Office of Seafood and the Director Seafood Inspection Program at NOAA Fisheries prior to joining EAS shares one of his many favorite examples of industry getting it right. “In the 1980’s there had been a couple of botulism outbreaks in canned salmon. These events threatened the viability of this product as consumers were justifiably wary.”
With a few notable exceptions, the industry “really rallied around the principles of food safety for Low Acid Canned Foods,” he says. “Everyone from the President of the companies to the workers on the line became very aware of the hazards associated with canning salmon and the possibility of a botulism outbreak and many important steps were taken to ensure food safety… Everyone involved in the salmon canning process understood that they needed to do more, from the line workers to the company management, to the trade association and government regulators. It is a success story for food safety since it is been over 35 years since there has been a food safety outbreak [in that industry].”
Sometimes food safety is as simple as a choice. As FDA and industry work together to further implementation and understanding of FSMA, remember that with buy-in from all levels these guidance documents will move from merely words on paper to a living document. Staying vigilant to the importance of everyone’s role will have a significant impact.