Continual improvement is a key ingredient of any strong and reputable food business. Around the world, the best-performing organisations know that to create and nurture a culture of excellence, they need to get the basics right – and build positive attitudes on top of that foundation.
Those basic requirements, or core competencies, provide a solid platform from which to build a safe, legal and high-quality food manufacturing, processing or packaging business. They include basic elements such as regularly monitoring, continually improving traceability, GMP, foreign body controls and complaint handling, to more complex elements such as risk assessment, effective internal audits amongst others." The latest edition of the BRGCS Global Standard Food Safety, to be published on 1 August 2022, evolves the foundational best practices for food safety culture requirements accordingly.
With the release of Issue 9 of its Global Standard, BRCGS is calling for more to be done to reduce non-conformities (NCs) against food standards across the industry.
To help inform the updated Standard, BRCGS conducted an industry-wide consultation to understand stakeholders’ requirements, plus a review of emerging issues in the food industry. This highlighted several concerns regarding supply chains and associated risks to businesses. Commonly cited concerns touched on issues such as hygiene standards, allergen controls and contamination, traceability, food fraud, and labelling and claims.
As a result, Food Safety Issue 9 leans heavily towards encouraging the development of a strong product safety culture. Within this, the foundation for success is recognition of the critical core competencies that must be in place, and receiving continual focus and improvement, before an organisation turns its attention to the attitudes and behaviours that constitute its overarching culture.
First published in 1998, the Global Standard Food Safety has set the benchmark for over 20 years. Developed with input from the industry, it provides a framework to manage product safety, integrity, legality and quality, and sets out the operational controls for these criteria in the food and food ingredient manufacturing, processing and packing industry.
“Food Safety Issue 9 is all about the evolution of food safety best practice and continual improvement. We believe there’s more to be done across the industry to reduce the most common non-conformities. Some of the areas that see the common re-occurrence of NCs in food safety audits are the those related to core competencies and this currently stands at around 30% of all NCs. Our projections suggest there would be a significant reduction in the number of NCs if the fundamentals – the core competencies – were optimised by sites. That’s why we’ve strengthened some of those fundamentals in the new Standard.”
- Richa Bedi-Navik, Senior Global Standards Manager, BRCGS
The vital importance of core competencies
Core competencies form an inherent part of an organisation’s day-to-day activities as it strives to deliver safe food products to consumers. They cover everything from internal audits, root cause analysis, validation, verification and risk assessments to incident management, complaint handling, corrective/predictive action, hygiene procedures and traceability.
Worryingly, there are plenty of food businesses around the world that aren’t ‘getting the basics right’ when it comes to their everyday working practices.
In 2021, ‘premises and equipment hygiene’ was the most common global non-conformity issue. Along with ‘risk assessment for safe storage of ingredients’ and ‘food safety culture plan’, it also featured prominently among the top 8 of all NCs registered against expectations set out in Food Safety Issue 8, which was published in August 2018.
How many of the top non-conformities would still occur if the fundamentals of product safety were enhanced, and properly assessed and enforced within organisations?
It’s not just a cultural problem. If organisations do not ensure appropriate fundamental food safety practises are in place(building blocks of a robust food safety management system), they can inadvertently put customers and consumers at risk – while also running the risk of detrimental impacts on their brand reputation and business…
Take the failure of food retailer Pret a Manger to label allergen information on the baguette packaging at its Heathrow Airport outlet as an example. This resulted in the death of 15-year-old Natasha Ednan-Laperouse in 2016 and the subsequent adoption in October 2021 of strict legal requirements for Pre-Packed for Direct Sale (PPDS) food labelling, known as Natasha’s Law.
However, several additional allergy-related fatalities occurred in the intervening years – including that of a second Pret a Manger customer, Celia Marsh, who died from an allergic reaction in December 2017.
In the US alone, it’s estimated that 32 million people have food allergies. In the UK, it’s estimated that 1 in 4 people are living with allergies. Around the world, millions of people each year have allergic reactions to the products they eat. The common sense takeaway from this is that taking a lax approach to food product labelling when more and more people are reporting severe allergies is a recipe for potential trouble – and leaves companies of all sizes open to criticism.
Fundamental requirements for reducing risk and improving audit grades
Let’s consider how a food business could use the publication of Food Safety Issue 9 to enhance core competencies that lead to continual improvement.
A comprehensive internal audit system is fundamental to a company’s safety and quality control as it provides confirmation that systems and procedures are operating effectively and identifies areas that require improvement.
Audits may constitute review of those systems, for example to establish whether the company’s traceability policies and procedures meet the requirements of the Global Standard. In other words, has the company identified the correct things to do? Are there audits of procedures and practice to confirm whether personnel are understanding and carrying out procedures correctly against the documented system? Are these procedures are appropriate? For example, establishing whether staff are correctly adhering to the company requirement of hourly metal detection checks.
Best practice is for the company to introduce a programme of regular audits, say where an aspect is audited each month. Frequency should always be based on risk and it is likely that a more frequent need for internal audit is identified for practices in key areas such as hygiene, good manufacturing practices (GMP) and foreign-body risks. Particularly those of glass and controls identified as critical control points (CCP) within any hazard and risk assessment analysis. These may have a requirement for daily, weekly or monthly audits depending on your industry, while other areas identified as lower risk could be audited say twice a year.
Audits may also constitute part of an investigation process and therefore be unplanned. For example, confirming that the procedure for the cleaning of a specific piece of equipment is carried out correctly when routine microbiological testing of food products reveals an out-of-specification result.
The auditing needs to be conducted by a trained team, whether this is internal or support is sought externally by experienced consultants. The output of audits should include a list of any non-conformities raised in sufficient detail so that appropriate corrective actions can be taken. Best practice is to use a root cause analysis system.
With internal audits in place and summary reports provided for the senior management team’s review including an analysis of recurring non conformities or root cause the senior management team would have good awareness of the status of compliance with the requirements of the Standard, as well as any particular areas that may require more attention – along with areas where excellence is demonstrated.
Good practice would be to publicise the results to all employees via a communication plan. This plan would help support a good, transparent food safety culture, within which all employees are kept updated about how the site is performing. Importantly, each person would also be aware of their own personal impact on food safety and quality.
In any food business, a combination of robust processes and plans plus the ability to keep a sharp focus on the continuous improvement of core competencies will keep a facility running smoothly and enable the organisation to ensure safe behaviours – without compromising growth and development.
How does your organisation compare? Do you have the foundations in place to mitigate risk and facilitate success? To discover how we can help, contact the BRCGS Team today.