Training Oversights and Their Impact on GFSI

The Global Food Safety Initiative tightened food safety standards with the North American introduction of its approved benchmarking schemes in 2007. These were developed to increase the safety of all food production and manufacturing by incorporating all of the food safety requirements within GFSI’s guidance document. GFSI’s benchmarked food safety schemes require plants to identify their internal risks to food safety and establish a process to mitigate, reduce, and, ideally, eliminate those risks.

Yet one of the most important elements of these schemes, the need for training and knowledge retention, often falls short, as a number of third-party audits can attest. Many workers who have passed classroom testing demonstrate a troubling lack of knowledge about food safety when questioned by auditors. For a plant, the results could well mean a finding for nonconformance and a failure to achieve its chosen GFSI benchmark scheme (e.g., Safe Quality Food or British Retail Consortium), rendering a delay in certification while time-consuming corrective actions are taken.

The underlying issue behind these training inconsistencies is not difficult to pinpoint. The training process lacks thoroughness for several reasons, such as ineffectual testing with marginal passing scores, inadequate proof of actual comprehension, or timely remediation follow-up when questions are missed. Based on a recent survey of auditors from eight global firms, training practices that do not adequately teach or ensure comprehension are occurring with what can objectively be called alarming regularity. Results show that 25% of audited food manufacturing or distribution facilities, not an insignificant number, are falling well short of acceptable training practices. Companies need to understand why these training issues continue to fall through the cracks and what can be done to alleviate them. One innovative solution is to integrate all training platforms.

GFSI, Training, and Risk

GFSI benchmarks broad foundational competencies in food safety concepts and programs. In Version 6, the most recent for the GFSI Guidance Document, the foundation lists as one of its objectives the development of “competencies and capacity building in food safety to create consistent and effective global food systems.” There can be no doubt that one key to competency is thorough and effective training that positively influences awareness of food safety and behavior in the workplace.

However, the focus becomes more specific when it comes to company programs, particularly food safety risks at individual plants. That has become increasingly clear during GFSI audits in which auditors question a large number of randomly selected employees to verify comprehension of food safety protocols and, equally important, application of those concepts in the plant operation. Many plants have been hit with nonconformance findings based on answers given by individual workers that, in the view of the auditor, constitute a potential food safety hazard. The result is that companies are recognizing, belatedly, the need for more specific training relating to standard operating procedures, along with food safety protocols and procedures.

Plants are also recognizing that a greater emphasis on risk management is a vital function of every aspect of food manufacturing, processing, and distribution. Reducing the risk to food safety through comprehensive and documented training is an important element for scheme certification, necessary to achieve GFSI standards. The FSMA also recognizes the training imperative by including it among preventive controls necessary to ensure food safety.

Yet, despite the importance of training, companies continue to multiply the risks caused by employees not suitably trained to deal with potential microbial, chemical, or physical hazards. Effective GMP training and verification are called into question when auditors find employees wearing improper attire, displaying a lack of awareness of sanitation protocol, and failing to understand the need to control the spread of allergens.

Survey Shock

Unfortunately, auditors find these kinds of problems all too often. In early 2011, a private firm surveyed auditors from eight global auditing firms about employee training. The auditors, who were guaranteed anonymity, were asked about such issues as verification of comprehension, whether the training was updated on a regular basis, and if the documentation was acceptable. Their answers were surprising at best and disturbing at worst.