The GFSI-Certification Commitment

An incredible number of companies are making the decision to become certified to a Global Food Safety Initiative (GFSI) benchmarked audit, such as SQF 1000 or 2000, BRC, FSSC 22200, etc. The question is whether or not it is an informed decision. The audit has many benefits, but when members of an executive team are making the decision to become certified to a GFSI-benchmarked audit, they often do not fully understand the resource commitment that is required. This article outlines some of the more resource-demanding areas of the audits.

For purposes of this article "management" is defined as the senior site manager (often plant manager) and the direct reports such as department heads or managers. Senior management is the team of decision makers in the plant and will be responsible for ensuring resources are applied to implement and maintain the GFSI Standard of choice. Senior management also will be expected to demonstrate commitment by participating both passively (receiving communication) and actively (actual participation in the activity) in the various activities being referenced in the clauses.
 

How Much Will It Cost to Become Certified?
There are clear costs for the certification process including application and audit fees. The most difficult costs to define are those associated with the day-to-day program improvements. Keeping in mind that GFSI began with retailers, there is greater focus on the manufacturing site's role in the larger supply chain. Traditional inspections and audits have focused on the sanitary condition and safe handling of the food products on site. With GFSI, a broader view is being taken and requirements are expanded beyond the walls of the manufacturing site. For example, under GFSI-benchmarked audits, supplier approval is quite elaborate. It includes approval not only of ingredient suppliers, but also of service suppliers such as laundering and transport companies and laboratories.
 

Resource Rich Programs in GFSI-Benchmarked Audits
In addition to the traditional food safety programs that manufacturing facilities have maintained for years, such as sanitation, pest control, personnel practices, and HACCP, there are several program requirements that are new to many companies. Some of these are listed below with an explanation of the demands they will make on resources, including time, money, and people.

These include:

• Management commitment
• Change management
• Document control
• Training
• Internal auditing
• Corrective action
• Supplier approval

Management Commitment
The purpose of management commitment is to provide a formal means of communicating the status of a facility's programs to the senior site manager. The senior site manager must provide adequate resources for maintaining food safety, food quality, and legality.

Components:

• Senior site manager involvement at day of audit
• Ongoing involvement in key programs, such as HACCP and internal audits, by the senior site manager
• Detailed documentation of meeting minutes
• A person assigned as leader, practitioner, coach, or facilitator of the GFSI standard

Resource Considerations:

• Time allotments for the senior site manager to participate in meetings
• Time allocated for all staff for adequate training—initial and refresher
• Time allocated for program assessments: verification, validation, internal auditing
• Training from external experts: HACCP, GFSI, internal auditing
• The leader, practitioner or facilitator will likely devote half of full-time equivalent (FTE) employee's time to the system maintenance

Change Management
The purpose of change management is to establish a formal review process for any changes to product, process, or facilities to ensure that the impact on food safety, food quality, and legality is understood and managed prior to realization.

Components:

• R&D review for hazards (HACCP)
• Test runs
• Shelf-life trials
• New or changed product evaluation by all departments (maintenance, warehouse, sanitation, production, quality, occupational safety)—PRIOR to production

Resource Considerations:

• Test runs
• Shelf-life trials
• New supplier/new raw material evaluations
• Evaluations by all departments (this could be allergen testing, capability studies, effectiveness of cleaning chemicals, etc.)
• Training for all impacted staff about the implementation of the new or changed products/processes

Document Control
The purpose of document control is to ensure that documents (policies, procedures, forms, etc.) that affect food safety, food quality, or legality are controlled to ensure that only approved versions are used.

Components:

• Identification of relevant documents (maintenance, receiving, sanitation, quality, production, etc.)
• All documents provided with tracking information (header, footer, or similar) that contains, at a minimum, the document identification and version information
• Identification of person authorized to approve/change each document
• Master list of approved documents with current version information
• Change log of all revisions to all documents
• Training of relevant staff on established and modified documents
• Procedure for rescinding/replacing obsolete documents
• Provision for storing all documents and records for the defined period of time

Resource Considerations:

• Possible software to facilitate creation and tracking of documents
• Time allocations for creating, changing, rescinding documents
• Time allocations for training employees on established and revised documents
• Possible contracted warehousing for document archival

Training
The purpose of the training program is to ensure that training has been provided and evaluated for each task or activity performed related to food safety, food quality, or legality.

Components:

• Training needs assessment to identify the training mechanism for each activity/task
• Training plan to identify required training for each job function
• Documented training (on-the-job, classroom, or otherwise)
• Documented confirmation that trainee understood the materials and is competent

Resource Considerations:

• Train-the-trainer course for in-house personnel providing training
• Time allocations to ensure that there is documented training for each task/activity
• Time allocations for the confirmation of trainee competence
• Expert trainers (on-site or public courses)—HACCP, GFSI, internal auditing
• Videos, DVDs, online courses, correspondence courses, etc.
• Interpreters or translators needed to ensure training is provided in a language understood by the employee

Internal Audits
The purpose of the internal audit program is to evaluate all the elements of the audit standard against the facility's programs to identify weaknesses or gaps and to ensure timely correction.

Components:

• Internal audit team
• Auditors independent of area/subject being audited
• Audit schedule
• Documentation of conformances and non-conformances
• Documented corrective action, preventive action, and follow-up
• Communication to senior management

Resource Considerations:

• Recognized training in audit principles for audit team leader
• Training in audit principles for audit team members
• Time allocations to evaluate the entire audit standard—includes time allocations for internal auditors and internal auditees
• Time and money needed to correct any non-conformances
• Time allocations to conduct follow-up investigations to ensure that preventive measures were effective

Corrective Actions
The purpose of corrective action is to ensure that weaknesses in programs related to food safety, food quality, and legality are addressed and that effective measures are taken to prevent recurrence.

Components:

• Identification of incidents or triggers that require corrective action (such as complaints, internal audit findings, negative trends in self-inspections, etc.)
• Investigation and root cause analysis
• Documentation of corrective action, preventive action, and follow-up for each incident

Resource Considerations:

• Time allocations for root cause analysis by person(s) knowledgeable about the incident; this is often more than one person
• Corrective action may involve destruction of product or line downtime
• Preventive action often involves a financial investment to modify a system
• Time allocations to conduct follow-up investigations to ensure that preventive measures were effective

Supplier Approval
The purpose of supplier approval is to ensure that suppliers of goods or services that impact food safety, food quality, or legality meet established criteria and are monitored for compliance.

Components:

• Ingredient supplier approval and monitoring
• Packaging supplier approval and monitoring
• Processing aide supplier approval and monitoring
• Chemical supplier approval and monitoring
• On-site supplier approval and monitoring (pest control, janitorial, HVAC, etc.)
• Off-site supplier approval and monitoring (laboratories, label review, etc.)

Resource Considerations:

• Time to manage associated documentation (letters of guarantee, certificates of analysis, approved supplier logs)
• Training for employees who will conduct supplier inspections/audits
• Time to visit and evaluate suppliers
• Time to review third-party audit reports or program submissions from suppliers (HACCP, allergen control)
• Monitoring of suppliers (testing of product to confirm validity of certificate of analysis data)
• Training of suppliers that come on-site

A facility cannot have a commitment to GFSI without a commitment to provide all necessary resources, including time, money, and people. A decision to become GFSI Certified is a good one. An informed decision to become GFSI Certified is an even better one!

The author is Director of Food Safety Education, AIB International.