You have been managing your business for many years, you have reliable staff who know what they are doing, surely with all this expertise you do not need a documented food safety management system to be implemented. Think again.
Retailers have been putting pressure on businesses to have a documented food safety management system in place, with never ending expensive audits and findings that urgently need to be resolved, endless procedures, records, checklists, standard operating procedures and matrices that need to be completed and updated. Rest assured, they are not attempting to make you a puppet on their string, they are protecting the consumers, themselves and your business.
The Consumer Protection Act was promulgated in 2008, making South African citizens one of the most protected groups in the world. Due to the implications of this act, this documented system is now a retailer requirement as proof that the products being sold to consumers at retail stores, contain no hazards which may harm the consumer. Should the supplier be found to be a repeat offender, they can be sued up to R1 million or 10% of their turnover. How could one prevent this? By having documented proof that all aspects of your manufacturing, from receiving and storage of the raw material, to the manufacturing of the product, to the distribution of the product are adhering to food safety requirements. Another important point to remember is that, before the Act came into being, the consumer (who was harmed from eating your product) had to somehow prove that the manufacturer was negligent in the manufacture of the product, which was virtually impossible. Now the onus is on the manufacturer to prove that they were not negligent when manufacturing the product. One would be able to prove this with your documented food safety system.
There are many different types of food safety management systems that can be implemented, depending on what your customer is requiring. All of these systems are based on national and/or international guidelines and standards. Your customer could require that you implement one of the following systems (by no means a complete list) - SANS 10049, GFSI (basic and Intermediate), SANS 10330 (South African HACCP System), FSSC 22000 (international HACCP System), BRC (British HACCP System), Local GAP, Global GAP (Agricultural systems) or NRCS Standards for fishing. The above are not legal requirements (except NRCS for fishing companies) but are retailer/customer requirements.
Regulation 962 of the Foodstuff, Cosmetics and Disinfectants Act is a legal requirement for any food manufacturing/ packing/ storage/ distribution facility. This regulation states that all premises that handle food that is intended for public consumption, need to be inspected by Environmental Health Practitioners from the local municipality who will issue a certificate of acceptability for the premises, should the requirements be adhered to. If you are operating without this certificate, you are operating illegally.
What is generally included in a documented food safety management system? Let’s delve deeper into a basic system to see what it is about.
Personal Hygiene – documented proof that staff are dressed as required in the facility, illnesses are recorded, use of gloves and plasters are recorded, PPE is properly cleaned, staff and visitors understand the hygiene rules of the facility
Preventative Maintenance – regular planned preventative maintenance and proof that it is being done, proof that maintenance areas are cleared before production in the area restarts.
Cleaning and Sanitation – planned cleaning and proof that cleaning is done as planned, staff trained in proper cleaning procedures, documented verification of cleaning procedures, foodgrade cleaning chemicals
Traceability and recall – documented proof that you have traceability of all products within your facility - incoming raw materials, work in progress and final product. You would need a recall team and annual proof that your recall system works properly (backwards and forwards traceability)
Process control – documented proof that all hazards that could possibly be introduced are controlled.
Allergen management – proof that allergens in the facility are controlled to avoid cross contamination. This refers to raw materials, work in progress and finished products. The facility needs to demonstrate how allergens are being managed.
Training- there needs to be documented proof that all the staff working at the facility have at least gone through basic food safety training. Documented assessments need to be conducted on delegates as proof that they have understood what has been trained.
Corrective and preventative action – this is central to the system. All corrective action for non-conformances, customer complaints, out of spec microbiological analysis results need to be documented. Preventative action for the identified problem also needs to be documented down.
Process flow and hazard analysis – step by step process of the manufacture of your product. Hazards need to be identified at each step and control shown. Raw materials also need to be risked and necessary controls applied. This will eventually, as one moves into more involved food safety systems, become the HACCP study of the product.
As systems become more advanced, you could be required to implement policies, food defence plans, communication plans, internal and supplier auditing plans, sample retention plans and HACCP systems.
A basic system consists of documented processes for your pre requisite programmes or your good manufacturing practices. This is being done to ensure that the food safety hazards in the facility are controlled. One would need to run this system for a while, before venturing into implementing HACCP (Hazard Analysis and Critical Control Point). The HACCP plan will analyse your hazards and those that are risked as significant would be taken through the study to find a CCP (critical control point). If one does not have a good, well entrenched GMP/PRP system, your HACCP system will not be successful, as there would be many hazards risked as significant that would need CCP’s.
The key to the successful implementation is to ensure that management are committed to the process. Management need to understand that implementing any food safety system takes time and staff need to be adequately trained, but the majority of companies, once they have successfully implemented a system, see the true value – more involved staff, increased of staff morale and the recording of processes so that manufacturing/facility problems can be adequately dealt with.