This higher level of effort puts different challenges in front of both small and large enterprises, requiring them to allocate more time, knowledge and people to their food safety program. “Small companies may have a hard time getting people trained properly, creating bigger budgets around food safety, and understanding how to comply with each element of the law,” Scharlach says.
Larger companies face different issues. “The challenge for us has been to manage a very complex portfolio and still make our food safety plan as simple as possible,” says Perry. “The main difference has been the level of validation, verification, and transparency that we have with our agency partners. As the FDA comes in and reviews our food safety plans, we know that our record keeping must prove that we did what we said we would do.”
Despite all difficulties and misconceptions, there’s no escaping this adaptation to FSMA requirements, no matter how large or small the business. “It’s a matter of sitting down, doing it correctly, rewriting everything properly, and retraining everybody,” Scharlach says. “That takes time, effort, energy, and culture change.”
The key to this culture change is a top-down approach to food safety culture, where companies’ executives are directly involved in the implementation of the food safety plan. One example is TreeHouse’s steering committee, where, Perry explains, the C-suite and the presidents of the divisions meet monthly to review food safety objectives and challenges, and make sure they have visibility and alignment.
By contrast, when all responsibilities are left entirely to employees, the level of food safety culture is often poor. “If the project is dumped on the already overburdened food safety lead or QI-practitioner, then the workforce will resist change resulting in an ineffective plan,” says Jocelyn Lee, consultant at Superior Food Safety. “When food safety culture is embedded from the top down, the preparation of a food safety plan is likely to be smooth, comprehensive, effective, and implementable.”
Tolu is freelance writer who specializes in covering the food industry. Reach him at [email protected].
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