This interview accompanies Manufacturing News for December, 2013.
Laura Dunn Nelson has more than 25 years of experience implementing food safety and quality control programs for processing, packaging, foodservice and retail operations. She has worked with global retailers and manufacturers in the implementation of their GFSI certification programs. Prior to joining Alchemy, Laura managed Silliker’s South Region food testing laboratories, implemented ISO 17025 requirements, conducted GMP, distribution, and HACCP audits and trained new food safety auditors. Her “hands-on” experience in testing food products for the presence of pathogens, toxins, and spoilage organisms, providing food safety training and consulting has assisted food companies in the successful implementation of good manufacturing practices (GMP), quality assurance and HACCP programs. She is a graduate of University of Texas with a Bachelor of Science in Microbiology.
FE: The study uses four examples of effecting behavioral change—three in food safety and one in workplace safety.
LDN: There is strong a correlation between challenges with food safety and workplace safety.
FE: Have you visited plants where improvements in both food safety and workplace safety need to be made?
LDN: Interestingly, we had a customer share that they use the percentage of “training complete” as a leading indicator/predictor for other issues. There is a strong correlation between training and safety issues—if they’re struggling with GMPs, productivity issues and customer complaints, there’s a direct correlation that they haven’t effectively trained their staff. In other words, if you see a plant that struggles in executing their training program, other key operational concerns will be present including food safety and workplace safety noncompliances.
FE: If so, what types of plants?
LDN: I haven’t discovered a type of plant that struggles more than others. Larger plants with more employees may have more challenges with execution of their training program, despite the availability of corporate resources to develop and deliver training. Smaller plants with fewer employees might struggle due to having fewer resources for creating new training or having the personnel to manage and deliver the training.
FE: At what point can workplace safety improvements affect food safety for the better?
LDN: Progressive companies recognize the value of creating a cohesive training program—workplace safety, food safety and HR training—that leverages all training resources and insures appropriate awareness for employees.
We understand there’s only a finite amount of time for training. Instead of training on these topics separately by departmental staff in silos, what if departments were to work together on these topics throughout the year? Taught hand-in-hand, you would have a far superior program.
Historically, companies have provided workplace safety training, documented employee behaviors and provided awareness campaigns to reinforce key topics like Lock-Out Tag Out in order to reduce direct liability for a company such as a workman’s compensation claim, an OSHA violation, etc. Consider linking workplace safety with food safety. Most companies clearly understand the liability from workplace safety accidents, but it can be more difficult to connect the negative consequences with a food safety noncompliance. A company might not ever know someone ate their product and became sick—unless the illness leads to a reported food poisoning incident. Approaching food safety training in a similar fashion to workplace safety training will allow companies to reinforce those “must have” food safety protocols and procedures as an operational tool to prevent a food recall.
FE: Can you cite any examples?
LDN: For example, a company that approaches workplace safety like food safety not as a “one and done” annual training event, but as ongoing weekly training and awareness, tend to be more successful implementing an overall safety culture. There’s a smart trend with progressive companies implementing “Shift Talks.” They choose a weekly topic that is directly affecting the plant. For example, if there has been an upward trend in foreign material complaints, they will access their training toolbox of the two- to ten-minute supervisor script reviewing the issue and how to resolve it. The same principles apply with workplace safety. Companies need to evolve from the “check the box compliance” to developing engaging training—both classroom and on the job—and confirm the effectiveness of training through ongoing coaching and validation of employee behaviors.
FE: The study’s one example points to potential SQF certification as an incentive to improve food safety. Since attention to detail is so important in keeping food safe, what do you see as some common, key improvements in the process (including employee handling) that processors need to make? Where are processors unaware that improvements need to be made?
LDN: GFSI certifications like SQF enable companies to achieve a greater level of safe, quality food production and operational excellence. Data from the study indicates that companies using a Corrective Observation model can effectively assess their plant’s processes and align employees with productivity and safety objectives through a process of targeted training, corrective observations and corrective actions. Some companies rely on a passing audit score as a validation of their training program. Tracking and trending key process indicators like GMP noncompliances, % downtime, customer complaints, rework, etc. and developing targeted training as preventive controls for those KPI’s appropriately links training and operational results. Together with the KPI data review and validating employee behaviors, companies can begin to achieve operational excellence through sustained superior employee performance.
FE: Many processors do some kind of training, but it may not be effective. Are many processors practicing the feedback techniques outlined in the study?
LDN: There is a growing paradigm shift where companies recognize that food safety cannot be consistently achieved from a one-day-per-year training dump session. Today, companies, supported by their executive management, understand it is critical to integrate effective training that is reinforced throughout the year with employee coaching to ensure a top-down and bottom-up food safety culture is prevalent throughout the organization.
FE: It seems like common sense that most people prefer feedback on how they do their jobs. Is the lack of it the issue at plants, or is it more so in defining the methods to measure employees’ effectiveness in actions they perform in doing their jobs?
LDN: Leading companies are focusing on employee behavioral change by augmenting effective training and awareness with systematic observations by their frontline supervisors. Defining the methods, as we have with the Corrective Observation model, reminds companies that giving employee feedback and documenting behaviors is an important step for continuous improvement.
For example, a common question is “What courses are needed to become GFSI certified?” A more appropriate question is “What are the processes and procedures necessary to consistently execute my food safety plan?” “What are the operational issues that affect the production of safe, quality food?” “How am I measuring those issues?” “What training can we provide to reduce or eliminate those issues?” You must observe processes, and if there’s a noncompliance, you need to engage your employees to find out the root cause. It could be a simple operational or system challenge keeping them from following a process they’ve been trained on, but you won’t know until you observe and engage your employees.
FE: GFSI certification under BRC, SQF, FSSC 22000, etc. is becoming a necessity as retailers are demanding it more of all processors. What hurdles do processors need to overcome in getting their employees on board with these certifications? Is documentation perhaps the major hurdle as some processors may not be very good at it?
LDN: There are multiple hurdles to get employees educated, aligned and supportive of their GFSI certification pursuit. Employees need to truly understand the journey toward certification and that the operational or system changes are not the “flavor of the month.” In many cases, the changes will involve formalizing the processes and documenting their execution—the same processes that have been in place for years. Sharing the “why” around the changes will help employees embrace the newly revised programs.
It’s important to make sure employees understand the benefits when they achieve certification. One primary goal is to maintain their customers if GFSI certification is a requirement, and allow a company to achieve new customers and grow by marketing their global certification. Effectively implemented, the new processes and procedures will help prevent operational problems, resulting in less fire-fighting, less downtime, reduced errors, and a positive work environment.
Ultimately, to get your employees on board you need to show them the benefits of having a more efficient operation—perhaps it will allow the company to grow and prosper providing advancement and opportunities for employees. Maybe it will reduce unscheduled Saturday shifts and provide more dependable work schedules. Honest communication of the certification benefits to both the company and their employees will help establish the support and commitment necessary to achieve and maintain certification.
Recordkeeping is a challenge for most companies. Many companies are still operating very lean with limited resources, and yet they have taken on many additional tasks and responsibilities to meet growing regulatory and customer requirements. That’s why people are seeking new technologies like Alchemy offers to overcome that challenge. Technology can provide the support by automating the recordkeeping processes, reducing errors and increasing efficiencies.
FE: FSMA is a risk-based approach to HACCP and food safety. How is FSMA affecting processors from an educational and training point of view?
LDN: FDA data indicates ineffective training is a direct contributor to food recalls, noting that 32 percent of recalls from 1999-2003 were due to ineffective training; 24 percent of recalls from 2008-2009 were due to training deficiencies. Auditor surveys echo that companies are struggling with training employees. We conducted a Global Food Safety Training Survey in January 2013, which noted that the biggest training deficiencies identified during an audit were lack of employee understanding and incomplete training records.
FE: What changes in thinking are required to comply with FSMA from an education/training point of view?
LDN: First of all, many companies are taking a “wait and see” approach with FSMA—particularly the small to medium companies—because many of the proposed rules lack definitive requirements.
Second, the FDA’s data indicates training is a contributor to food recalls. For many companies, training is a necessary task to successfully pass an audit and not necessarily linked to preventing food recalls. The concept of preventive controls is new, and it will take time for companies to adopt an effective, risk-based approach to their food safety program.
From an education perspective, a company needs to determine its own training needs based on its specific operation. There is a tendency to do standard, historical training (GMPs, allergen training, HACCP training) and not include targeted training to address operational risks. Companies should consider leveraging effective training as one of many preventive controls. Each company is diverse—different processes, varying ingredients, unique equipment, singular facilities, changing employee demographics—resulting in unique risks and challenges that must be met with training that reflects those specific risks and challenges.