Many changes can be expected when the Modernized GMP requirements take effect, including training documentation. As published in the revised document, the most common cause for failure of food safety programs was not related to program development, but employee training.
Training is often thought of as a formal learning method using correspondence courses, videos/DVDs, webinars, off-site workshops, etc. But, in reality, the bulk of the training required in food processing facilities is most effective through on the job training. This may be anything from cleaning and sanitizing a piece of equipment to lubricating a bearing, receiving incoming ingredients, or inspecting a sifter or strainer. Thousands of tasks which are critical to maintaining the GMPs/Prerequisite Programs require one-on-one on the job training to prepare employees.
While documentation and SOPs are required, working with employees and teaching them the process of performing the task most often requires this type of interaction. It also requires a method of measuring the competence of the employee in understanding the documentation as well as the task at hand. The new regulations will require some form of documentation to verify that the employee understood the task and was competent in performing it. These training records will require that a supervisor or manager sign off that the training was completed and that competence was achieved.
In addition, supervisors and managers need to receive the proper training to become trainers themselves. The most common failure I have noted in many years of working in food facilities is that the how and why behind tasks is not communicated. Trainers often work with an employee on how the specific task is accomplished, but fail to stress the importance of why it needs to be done this particular way. Teaching an employee how to clean a piece of equipment and to understand the SSOP procedures is only part of the training. They must understand the reasoning behind the procedures, the consequences of not meeting specification, and the risk to the product.
I once watched employees at a receiving dock completing an incoming-materials inspection. When they finished, I checked their inspection checklist and, although it was fairly complete, I quickly saw that the employees did not have a clue as to what they were looking for and why. I shared with them some issues I had noted over the years with the same types of ingredients and pointed out issues around the trailer that could cause a potential problem. Later that day I was called to the receiving dock because I was told the receivers had questions. They had found an issue, as I had suspected. While not major, they decided to reject the product. On a following visit these same two receivers were very proud of the log book which indicated they had protected the facility from possible issues because of their diligence. They better understood the risk, the why and also the how.
While we need to prepare for changes ahead and documentation required, don’t forget about the employees on whom we rely to perform the thousands of tasks which make up our product safety programs. They need to understand their responsibilities and why they are important.
The author is Vice President of Food Safety Education, AIB International.
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