A very small processor can make someone just as sick as a large processor, so even if establishing a food safety management system is not mandatory for these operations under the Food Safety Modernization Act (FSMA), they would be wise to do so to protect themselves and their customers. In fact, small processors probably pose a greater risk as they may not have the necessary skills and knowledge to properly develop such a program. Baking & Snack contributor Richard Stier, a consulting food scientist with international experience in food safety, offered his advice to readers as they work to ensure a safe food supply.

Baking & Snack: What should management’s role be in the food safety system?

Richard Stier: Management should have a hand in every part of the program. The most visible manifestation of management’s commitment is the company’s mission statement and quality policy. Almost all audit schemes expect processors to have one or both of these documents. In addition, many expect that these documents be printed on company letterhead, signed and dated by senior management, and conspicuously posted around the plant.

The processor should distribute these documents to employees and make sure the employees understand not only the policies but also their role in meeting or exceeding what is expected. In fact, years ago I visited a facility where prior to each management team meeting, the group stood and recited their quality and safety policy in unison. I was then informed that every person in the company had to do be able to recite the policy. Of course, I had to verify this and asked several people, who successfully recited the whole policy.

The policy statements are really only a minor part of what management should be doing. It is easy to create such policies. It is more difficult to make sure that what is written is followed and maintained than it is to write something. Plant management needs to make sure that the protocols to ensure that food safety, quality and sanitation are achieved, developed, documented, implemented, monitored, verified and reviewed, and that employees are trained on the procedures.

Most important, these programs must be properly maintained. Management must provide the resources, leadership, and empower the management team to act to build and maintain these protocols. If you look back at some of the major outbreaks of foodborne illness and recalls that have occurred over the last few years, you’ll often find that management commitment to maintaining what were well-developed programs had been flagged by investigators.

Oh, yes, there is one other visible manifestation. Management must sign the HACCP manual indicating that they support the program. This should be done at a minimum at least once year as part of the annual reassessment.

What should be the end result of the management review?

The end result should be an improvement plan that includes a prioritized list of programs. Each element should have someone assigned to manage the program, its timelines and the resources required to complete the work.

Note I used the term “prioritized.” The management team, led by the senior manager, should have conducted a risk assessment on all proposed programs. Those that pose the greatest risk to the business and those with the greatest potential benefits would, hopefully, be assigned the highest priority.

However, in reality, processors usually focus on a few programs that may not have a high priority, but could be called “low-hanging fruit” — that is, programs that can be accomplished quickly or relatively easily. There is nothing wrong with this attitude. If these projects can be started and completed, the resulting successes enhance confidence in the overall program.

This seems to be a great deal of work.

It certainly is. However, taking a disciplined approach such as this can pay real benefits, especially when the processor incorporates the risk assessment process into the equation. The key is prioritization based on risk. This process helps ensure that those programs that will best benefit the business are the ones that move forward. This process also has the added benefit in that it can be used as a gap analysis. Ideally, the management review will help identify those areas that need to be improved to ensure safety, quality, sanitation and other areas of the program.           

This story is sponsored by POWER Engineers, which has one of the most comprehensive teams of engineers and specialists serving the baking and snack industry. As an extension of its clients' engineering teams, the company provides program management, integrated solutions and full facility design for the baking and snack industry. Learn more at www.powereng.com/food.