Implementing food safety and hygiene

Responsibility for safety from ‘farm to fork’ is obviously shared between farmers, manufacturers and processors, distributors, consumers and various government authorities. The perspective of the manufacturer is in ensuring that known food safety risks are managed and controlled, while the areas of new and emerging food safety risk have traditionally been the government’s domain. However, in recent years, the retailer has joined the manufacturer in taking responsibility for food safety in the factory and both have become more involved in assessing and managing potential new issues.

In terms of a systematic approach to food safety, the HACCP concept was first presented to the World in 1971. In the following 30 or so years, the principles of HACCP have been promulgated as the ‘final solution’ for food safety management and have been included in the legislative arrangements of almost every international, national and regional organisation.

In spite of this progress in communicating the HACCP concept more widely and incorporating its principles into legislation, significant food safety problems are still encountered. In the last ten years the UK Dairy Industry alone has witnessed two outbreaks of E.coli O157 in territorial cheese; an outbreak of Salmonella in cheddar cheese; Listeria monocytogenes in blue cheese and an outbreak of Salmonella in flavoured milk. Similar examples are seen in other countries and it is therefore obvious that the issue of food safety at the manufacturing level has not been completely resolved.

A model for food safety management

In most countries since the early 1990s, there has been a substantial development in Food Safety Law, reflecting harmonisation within and between major trading blocks and the increasing expectations of consumers. As a result of the requirements of this developing legislation and the legal defences available, a framework of elements has been established that are widely agreed to constitute a systematic approach to food safety management at the manufacturing level:

1. Food safety policy: communicated to all company employees
2. Organisation: defining and communicating individual responsibilities for food safety
3. Staff training and written instructions: including training plans and records and defining competencies
4. Good Manufacturing Practices (GMPs): setting out basic factory standards for buildings, equipment, personnel, cleaning, pest control, foreign body control and how these are to be enforced
5. HACCP plans and controls: comprising process flow charts and schedules setting out monitoring, control and corrective action strategies for both food safety and quality issues
6. Specifications: documented to define key characteristics in raw materials, processes, work in progress, rework and finished products
7. Supplier Quality Assurance: ensuring all raw materials are adequately specified and obtained from audited suppliers
8. Laboratory accreditation: ensuring that key laboratory tests are performed to approved methodology by competent analysts in capable laboratories
9. Complaint management and product recall: ensuring that all product feedback is reviewed and acted upon
10. Audit: internally and by second and third parties to ensure arrangements are still in place and operating as they should

One of the key issues in this model is the link between GMPs and HACCP and, in particular, the need for a good set of GMP standards to be in place before HACCP is implemented. This is one of a number of reasons why the practical application of HACCP in manufacturing is still flawed. Where an attempt is made to implement HACCP in an operation with limited GMPs, it is often found that what should be a routine GMP standard suddenly becomes a critical control point. This creates an unnecessarily complex HACCP plan – and over-complex systems are often not effective.

Over-complexity in HACCP has a number of outcomes: it results in a lower level of understanding of the issues; the HACCP plan tends not to be challenged because of the time necessary to interrogate the detail and it tends not to be adapted in line with changes to product and/or process for the same reason. Ultimately, the HACCP plan too often ends up in a file on the shelf.

Even this basic ten point approach can therefore often have difficulties. In addition there are a number of non technical issues that put further pressure on the manufacturing system and its safety.

Challenges to food safety strategy

Whilst food safety management in manufacture is important for a host of reasons, it is important to understand the underlying purpose of the manufacturing operation. It can be presented in many different ways but, in essence, it is to generate a target financial return on investment. To achieve this return, manufacturers compete with each other across a number of key performance areas, the five most important of which are quality, speed, dependability, flexibility and cost.

Food safety is obviously an aspect of quality, but the other competitive factors all impact directly on food safety management.The objective of ‘speed’ relates to faster throughputs and shorter delivery lead times. Compressing the time frame of manufacturing obviously creates more opportunity for problems while providing less opportunity for problem identification and, more importantly, for problem resolution.

Dependability is concerned with reliability towards customers and is a very important competitive performance measure in terms of the reliability, in both time and quantity, of deliveries to customers. Supermarkets demand deliveries on time, in spite of congested road systems and often a major priority within plants is to load the lorries and despatch them on time. This can become an overriding objective at plant level at the expense of food safety.

Flexibility, again, is an important competitive weapon for the manufacturer and relates to the ability to offer frequent product changes, volume and delivery adjustments.

Competing on the basis of flexibility means that the plant will be operating to constantly evolving objectives and conditions and if this change process is not 100 per cent managed breakdowns in quality will occur – some of which will have food safety repercussions.

The last of the five key manufacturing performance areas is cost, which probably represents the greatest threat to plant food safety standards. Depending on the degree of competitiveness of the market, a large proportion of plants will have pressure on margins. How can companies respond to short term margin pressure? Experience shows they do this through cutting back on training, research and enforcement activity, while reducing indirect staff costs including those related to quality and safety assurance.

The impact of these cost and time pressures can also be seen in pressures on plant utilisation leading to reduced time available for maintenance and cleaning; two of the key areas of GMP that were established earlier as an essential base for an effective HACCP programme. On-going cost pressure can also result in the CATNIP syndrome, i.e. using the Cheapest Available Technology Not Involving Prosecution!

There are therefore many instances where key manufacturing objectives challenge the ability of the plant to deliver food safety standards. ‘People’ issues are also a key consideration.

‘People’ issues in food safety strategy

One of the key factors in ensuring practical food safety strategy at plant level is the training and supervision of personnel. This has been seen again and again in the field of quality management to ensure that people know what the quality and performance standards are; know their performance against those standards and know the means for correcting their performance if they are not meeting those standards.

These points should be covered in the plant’s GMP standards and its HACCP plan. The importance of training in these two key concepts is therefore paramount.

While training can be seen as a key people issue required as part of a systematic food safety strategy, there are a number of other people issues that must be understood. For example, the attitude of strong personalities with regard to food safety at a senior level in the organisation can have either a beneficial or adverse effect on the plant’s food safety climate. Inevitably, junior employees will be influenced by that person’s example.

Another important issue is that food safety procedures can soon fall into disuse in the absence of a system to ensure they are followed. Procedures often lapse due to management neglect or because operators are encouraged to work to other production targets instead; for example, delivery service as mentioned earlier.

The other important people issue in plant food safety strategy, is that of human error.

Within any operating system, however automated, there are people operating, monitoring, maintaining and reacting. These people are continuously interacting with equipment and each other, providing a constant opportunity for mistakes to occur.

Human error can be looked at from three perspectives: ‘slips and lapses’ from low level skill based behaviour; mistakes, i.e. the wrong decision made in good faith and violations, i.e. deliberate deviations from safety rules. Understanding the psychology of human error and implementing measures to address their root causes is a key part of a food safety programme.

Making ‘the food strategy’ work

So what needs to be in place to make the ten point plan work in practice?

The first consideration is ‘what is the ‘bedrock’ for food safety success at plant level?’ and then ‘what additional defences are necessary to protect the food safety objectives from attacks and buffeting from external threats, arising from a modern highly competitive business environment?’

The first fundamental of good safety management, just as with any other type of management, is good people. Good people means: people with the right educational background; given the appropriate training; made aware of the key issues and objectives and supervised by similarly qualified managers. It sounds simple but there are so many instances of food safety breakdowns at plant level where one of the major reasons for the problem is the inadequacy of the human resource.

Inadequacy can mean simply having too few people for the tasks involved; or employing too many agency staff as opposed to direct company employees; or having adequate numbers of people but who are inadequately trained or insufficiently experienced to make appropriate judgements on the many differing situations with which they will be faced; or having sufficient numbers of trained and experienced people but without the awareness and culture of good food safety management.

The other fundamental of good plant food safety management, combining with people excellence to form the ‘bedrock’ of food safety success, is a high level of food safety and hygiene standards and processes. This goes back to GMP standards and HACCP but it is worth taking time to review what is key about these from a plant perspective.

In addition to being robust and practical, a further requisite for achieving consistently high standards of GMP is solid commitment from the most senior directors in the company. It is they who control the resources allocated to the plant and if they do not have real commitment to the achievement of high standards of GMP – and physically demonstrate it – then no amount of effort from the Quality or Technical Manager will overcome it.

Finally, with regard to GMP, standards will not be maintained if they are not enforced. This includes the daily walk-through by the plant manager, to audits of their own departments by individual managers, to independent audits by independent Technical Management. The latter must be carried out by trained, experienced Technicians who know the company’s standards in detail and cannot be delegated to third party auditors who can only judge standards from a general perspective.

A champion for change management

Having dealt with the ‘bedrock’ of plant food safety success, we can complete this review with a consideration of two further defences against a highly challenging, competitive and commercially driven environment.

The cost, time and human resource pressures on food manufacture have been mentioned however, while companies try to meet all their objectives, i.e. provide the right quality and safety delivered at the right time at the right price, there will always be times when something goes wrong and all three cannot be achieved. In a highly competitive environment, the loudest voices will require that cost and service are achieved as a priority and it is therefore paramount that a very senior Manager or Director will argue the quality and safety case with senior Commercial and Financial Directors.

I have termed this person the Food Safety Champion and such a role requires integrity (to ensure customer and consumer interests are represented), courage (to argue the case with very senior Commercial colleagues), rigour (to understand all the facts in sufficient detail) and high standards (to ensure that factory standards move forward rather than standing still).

In addition to identifying a Food Safety Champion in the company, a further defence for the manufacturer is a robust change management process. In reality, when factories are making the same amount of the same product during a period of time, there are rarely any serious problems. Sufficient equipment is available, people know their jobs and time and procedures exist for cleaning and other tasks. Most problems occur when something changes and there are many types of change that can impact on a factory: new products and/or processes being introduced; recipe changes; volume changes; promotional activity; packaging alteration; distribution channel change and new raw materials are just a few.

If there is no formal change management process, there is a major risk that resources will not be available for the full evaluation and incorporation of the change, or to ensure that key cleaning and maintenance activities are maintained.

Change management is a key business process for all companies but, in the context of food safety, it is a particularly critical one that must be managed in a systematic way.

The people decide

There is no single correct approach to good food safety management at plant level. The only certainties are that it requires the right people with the right knowledge and integrity; the ability to cope with change and the strength of character to stand firm against the various diverse demands of a competitive commercial environment. Systems and procedures are important, but the human issues are the deciding factor.