F-STEPS: Our Food Safety Team Expectations and Program Standards incorporate key steps that every company implementing an Ingredients, Components and Materials Food Safety Management System will need to have.
We need to understand your products, process and operation in detail in order to identify and recommend the applicable standards against which your facilities will be evaluated and graded. In some cases, multiple standards apply. Before we can customize the set of standards and expectations which will become your benchmark, you should familiarize yourself with the form, complete it and return it to us (e-mail is fine, regular mail is acceptable if you prefer).
Q: That form is long and involved. Is all of that really necessary?
A: The form is created to support all possibilities, including the assumption that you have not previously undergone a comprehensive audit and your individual circumstances are such that we don't know in advance what risk category to assign your facility. Reading and completing the form with attention to detail (we know it's lengthy) allows us to apply the correct standards in advance of our first visit. In our experience, it protects your client interests, saves you time and money.
Food safety standards have commonality within the Food & Materials Industry, but also differences. Those differences are often linked to your specific products, process, services and circumstance. Your products and facilities have the potential to be regulated or controlled under the authority of a host of federal, state and local agencies, as well as having the potential to be audited by multiple certifying authorities. Experts are aware of the many different, ever-changing regulations and standards which apply to food safety and agree that identifying the correct set of standards to meet your organization's requirements can be a complex task. Some packaging material converters service food and pharma customers and are in a quandary as to whether 2 separate sets of standards apply within the same facility.
EHA Consulting Group utilizes its wealth of experience and expertise to evaluate your specific needs and match them with the latest standards and expectations which are reasonable, appropriate and industry-accepted to help you create the program that fits your risk model. Regulatory agency (FDA, USDA, etc.) requirements typically supersede industry standards; in some cases, though, they are complementary to one another, and the client is expected to understand how to address and apply the differences. When applicable, this is documented, highlighted and explained with guidance in your Client F-STEPS Expectations Document.
Q: What determines my risk level?
A: Your risk level is determined by a decision tree used by the majority of certifying bodies. If you manufacture or handle foodstuffs, ingredients or other edibles or food contact materials or packaging, you likely fall into the high risk hygiene category. The "high risk" category is not suggestive of anything extraordinary, it is just the nomenclature used by the Organizations who create and administer standards and related programs. A "high risk" designation for edibles and contact materials suggests that there is a reasonable possibility of the food (and, thus, the health and safety of the consumer) being affected by biological, physical or chemical contamination if the proper protections and safeguards (e.g., a "plan") are not in place, practiced and validated.
After EHA Consulting Group develops a base standard, we discuss the scope and implications with your Implementation Team, who then initiates the process by preparing organizational strategy and assigning resources to the key functions designed to implement, maintain and verify the Plan. The effectiveness of any Food Safety and Quality Plan is directly connected to and requires the commitment of senior management; therefore, it is vital that senior management be involved from beginning to end of the process.
Q: We are a very small organization here and most people perform more than 1 function. Is that taken into consideration when creating my custom food safety "plan"?
A: Absolutely! Many of EHAs clients are smaller processing and repacking facilities with limited resources who wear "multiple function hats." We engage a variety of cross-functional key personnel as part of the risk assessment, implementation and verification teams, using their multi-function familiarity with the process as a benefit to the Program. There are, however, some organizational (reporting structures) requirements which must be understood and followed. EHA makes you aware of these during the process and makes practical suggestions for changes which will make you compliant with the standards without disruption.
EHA will be side-by-side with you during the implementation phase. We advise how best to implement your food safety management system and have experience which can ensure you avoid costly mistakes. The key to implementation is communication, training and fool-proof methods for documentation. During the implementation phase everyone operates according to the procedures and collects records that demonstrate the all-important documentation "evidence" to prove you are doing what you say you are doing.
EHA Consulting Group can't stress enough that training is the foundation of your Plan. An effective training plan engages employees at all levels, addresses cultural and language variations, and drives home the concept that Food Safety and Quality are everybody's business: We Are All Quality Managers in one respect or another. The remainder of training explains the objectives, specifics, methods and background for each requirement or expectation, always tailored to the needs and sophistication of the audience. When advisable, we provide information on workshops, seminars and higher-level certification training to your Quality Organization.
Q: I have some challenges with training. My hourly workers are not English-speaking, we are a seasonal business and frequently bring in temporary employees to fill the gap. How can EHA help me manage training of multi-lingual, temporary and seasonal changes in my workforce?
A: EHA provides multi-lingual trainers and creates training programs designed to meet to satisfy changing workforce situations. EHA's comprehensive library of custom documents track and monitor changing employees and temporaries, allowing the training manager to see who has and has not been trained. We also get concerns from clients who are concerned about practical methods to certify knowledge and understanding which varies with cultural differences. We have procedures which will allow you to meet the training standards of the recognized "schemes" without administering formal written tests.
Create documentation that outlines your intention to operate in a safe manner. It outlines why you are in business, what your intentions are, how you are applying the management system and how your business operates.
Q: I'm concerned that my document formats are not current, comprehensive, and I know that there are certain forms and templates that are out-and-out missing. How can you help me correct this and make my facility compliant with a complete library of documents?
A: EHA maintains a comprehensive electronic library of forms, templates and documents consistent with your business type and needs. We provide you with those which are specifically designed, adapted or required for each facility and integrate those documents into your Program. Once in the Program, we confirm during the verification phase that they are being used and populated consistently and correctly.
EHA recommends a trial audit as part of a comprehensive program. EHA trained auditors collaborate with client management and key program designees to execute a 1-day audit exercise, the purpose of which is to identify steps and procedures that are in place (in theory) but may not be operating to meet targeted standards. Identification of errors or omissions in this process allows clients to make adjustments, corrections or apply additional training before a formal audit.
Arrange an initial (formal) audit with the certification body of choice (yours or our customers). On a pre-arranged date, an auditor from the certification body will review your food materials safety management system and determine whether you meet their criteria. The program that EHA designs for you will meet the criteria issued by the major certification bodies registered under the 2011 GFSI guidance document version 6.1 for benchmarking and unifying food safety standards.
Once you have successfully passed a standard audit and received a certificate of compliance, you can begin to tout your success to your customers. Maintaining your "F-STEPS" food materials safety management system is the key to your continued success and recognition. EHA will periodically connect with your dedicated liaison to discuss your Program, changes to global standards and other pertinent details to ensure that your food safety management system continues to meet standard requirements.
Q: I'm nervous about the first audit. I don't exactly know what the auditor will ask for, and my staff and I are new to this entire program. Can an EHA representative attend out first audit by a certification body in order to make sure we get recognized for all of our hard work towards making our process safe?
A: EHA attends the trial audit as well as the formal audit in order to put your staff at ease and provide the documentation and evidence that shows and proves your diligence and conformance with industry standards. In the event that there is a documentation or procedural non-conformance identified, we correct it immediately as the audit progresses and advise the auditor of the correction or mitigation. EHA experts provide continuous support until you understand and meet all standard requirements.