Having implemented enhanced control measures over the past couple of months in our food factories it is now time for the Risk Mitigation Team to pause and think for a moment and assess the success of these measures. The Plan, Do, Check, Act approach is the logic behind any continuous improvement process. The approach to COVID-19 by all Food Business Operators was to ‘Do’ the obvious as quickly as possible : hand-washing, zoning, visitor control, cleaning etc., this was followed up by ‘checking’ to see are these controls working. Now is the time for the Risk Mitigation Team to ‘Plan’ logically using the 12 Step Process to develop a Risk Mitigation Strategy that defines company policy, outlines your Risk Assessment approach and develop and document Risk Mitigation Plans for the four pillars.
As it is unknown what will happen over the coming weeks and months, Food Businesses will in time have to demonstrate that their Risk Mitigation Strategy was well thought out (Plan), rigorously implemented (Do), Closely Monitored (Check) and Continually Improved as the Pandemic evolved (Act). To have a comprehensive document available to show that your Food Business at all times looked after the wellbeing of your staff, business and customers will give peace of mind that due diligence was exercised at all times.
In 1998 the British Retail Consortium (BRC) developed and introduced the BRC technical standard and protocol for companies supplying retailer branded products. BRC Global Standard for Food Safety. The current standard was published January 2015 with Issue 8 coming out in August 2018.
BRC Food Safety Issue 8 : Time Lines
- January 2018 – standards wording finalised
- July/ August 2018 – standard published
- January/February 2019 – Audit commences
The number of BRC certified sites is a testament to the increased international popularity of the BRC standards. Currently there are almost 26,000 certified sites in 130 countries with the USA being the area of greatest growth. Achieving BRC Certification against the relevant BRC standard is an essential component of any business’s strategy for business continuity.
Regardless of which end of the food/product supply chain a business operates, due diligence is one of the most essential elements of business continuity. Achieving BRC Certification against the relevant BRC standard not only allows companies demonstrate due diligence, it also opens business opportunities with the most powerful sector in the supply chain, the retailer. The first step to achieving certification is to learn and understand your relevant standard.
BRC Issue 7 was published in January 2015 and came into effect July 1st 2015. Issue 8 will be published in July/August 2018 comes into effect from January/February 2019.
It is anticipated that the voluntary module concept will become more popular as “Food Safety Culture” and “FSMA” are ideas that Best Practice companies are pursuing. Changes to Section 1 will require Senior Management to establish a strategic plan for creating a robust food safety culture. This will require Senior Management to be engaged with the Food Safety Management System and not simply pay lip service to it.
Site security and food defense requirements have now been amended including threat assessment to align with FSMA expectations. The new changes will require that sites complete a risk assessment of internal and external threats.
It is proposed that 2 new sections will be added in Issue 8:
Section 8 has centralized all high risk, high care and ambient high care requirements. This ensures that both FBO and Auditor can concentrate on this area of enhanced importance.
Section 9 although still voluntary, incorporates the voluntary modules however non-conformances assigned against this section will now be included in the sites audit grade.
Food Safety Culture :
There is no doubt that Food Safety Standards have improved significantly over the past twenty years in all sectors of the supply chain driven primarily by major product recalls, GFSI and retailer standards. Large multinational food manufacturers have also driven improvements through increased expectations of the upstream supply chain.
Figure 1: Elements of Food Supply Chain
As companies’ food safety management systems have matured with 10-15 years of BRC Grade A or FSSC Certification, the expectation now is that Food Businesses have a strong Food Safety Culture. If most CEOs were asked ”Do you have a strong Food Safety Culture?” they would all say “yes” believing that they do, but do they?
In challenging oneself as to whether your Food Business really has a best practice Food Safety Culture you must first establish what is culture? There are many definitions to be found but the following two are perhaps the more accurate and thought provoking respectively:
“Culture is the system of knowledge shared by a relatively large group of people.”
“Culture is communication, communication is culture”
Figure 1 above simply visualizes the elements of the supply chain. Food flows one way, money the opposite and expectation always follows the money “he who pays the piper calls the tune.”
What is the tune that your customer expects you to play? They expect you to know their fears, their concerns, their expectations and to understand their Food Safety Culture. It is then up to your entire organisation from CEO to shop floor operator to “communicate” to them in a manner that assures them that you won’t let them down.
Interested in Finding out More? Check out the Food Safety Culture One Day Training Programme at SQT Training
Preventive Controls Qualified Individual
The Food Safety Modernisation Act (FSMA) is the most significant change to US Food Safety legislation in over 70 years. The act was signed into law by President Obama in 2011. FSMA is in response to numerous food poisoning incidents that have occurred in the US over the past ten years. Figures released by the USDA estimate that each year over 48 million Americans become ill from food poisoning, resulting in 50,000 hospitalisations and over 3,000 deaths.
The FSMA concept is to move away from a reactive approach towards a preventive system.
With FSMA there are seven rules which are specific to different types of foods, elements of the supply chain and stakeholders. With this level of complexity and change, the challenge for Irish indigenous and Irish based multinational food companies is to understand how these rules will affect their current Food Safety Management Systems.
Under CFR 117 each food manufacturer in the US must have a Preventive Controls Qualified Individual (PCQI). This individual must have successfully completed training in the development and application of risk base preventive controls using a standardized curriculum recognized by the FDA. Denis Kiely is a Qualified PCQI (Cert a1e9e90b) and a Qualified Lead Instructor (Cert 31bf87e2) in Preventive Controls for Human Food. Delegates who attend this 20 hour programme will become qualified PCQIs.
IMS will be offering Public PCQI Training via SQT Training Ltd., in early 2018…..