Keep Data When Changing or Adding Safety Systems

We all recognize the importance of maintaining safety and quality throughout the food chain. Unfortunately, many of us do not fully understand that the key to such maintenance is meticulous documentation and recording of procedures and processes in the production, processing, distribution, and retailing of food products. Keeping track of pertinent data helps companies minimize recalls, better manage risk, and more quickly respond to problems.

The Importance of Data

The quality and safety of a food product are influenced by a host of critical events and control points. Often, this valuable data is not captured, or nonessential information is documented instead. Furthermore, the ability to link these critical pieces of data is often lacking. Though it is obvious what the consequences are if we fail to record required information, material that is necessary for regulatory and customer requirements, the negative effects of over-documentation include information overload that is difficult to manage, loss of focus, and reduced ability to correlate data are less apparent.

Let’s start with basic definitions for the types of important data. A document is a written form that provides information and can be updated or changed over time. This includes working instructions, standard operating procedures, policies, and so on. A record is a special document that provides evidence and cannot be revised over time—for example, chart recorder disks or temperature logs. In the data collection process, the two terms are not interchangeable and should be treated differently.

Abiding by the Rules

The food industry is governed by specific rules for ensuring quality and safety. When accessing critical material, food producers and suppliers should ask the all-important question, “Are we meeting the requirements?” These requirements are determined by many factors:

• Are you regulated by a government agency like the United States Department of Agriculture or the United States Food and Drug Administration? What are the requirements? Is there a hazard analysis and critical control point (HACCP) system mandate?
• Does the customer have an internal requirement? Does it require your location to be audited by a standard such as Safe Quality Foods (SQF), International Organization for Standardization 22000, or Primus Labs?
• Does your corporate location have standards that you are required to follow? Too often, management teams try to comply with standards without fully knowing the requirements. Companies with no understanding of the rules find themselves in a similar situation to someone trying to play baseball without knowing how. There are three basic types of requirements to be aware of:
• Regulatory requirements typically look at the safety of the customer, as well as legal integrity. In the simplest terms, they prevent companies from making or selling products that cause injury or harm and prohibit companies from lying to their customers. Product safety and corporate honesty seem to be simple concepts, but businesses sometimes lose sight of these ideals.
• Customer requirements try to go above and beyond the regulations, emphasizing quality or defining the specifics that the customer wants in a product. These parameters cover everything from color, shape, smell, and size to shelf life and packaging. The food may be safe and even tasty, but if it is not appealing in other ways, it could damage a company’s reputation and reduce customer loyalty.
• Locations that are managed by a corporate entity may have their own internal requirements. Even if the customer does not have high expectations, the company may need to protect the brand. This is especially true for large companies that supply retailers throughout the country or worldwide.

What are the consequences of not complying with specified requirements? There are many possibilities, including reduced consumer confidence, recalls, lawsuits, or bankruptcy. Keeping these requirements in mind will not only ensure customer satisfaction and loyalty but will also minimize incidents such as customer complaints and returns. However, the temptation is to not ask the questions regarding requirements to avoid looking ignorant. But in the case of food safety, it’s better to ask for permission beforehand than to ask for forgiveness later.

Drowning in Paperwork

A documented, effective, and continuously improving food safety system should be every company’s goal. One issue that can prevent a company from reaching this goal is excessive volume. Too much paperwork or too much data can cause the management team to lose focus. Many times, although the content may be necessary, the amount of paperwork is not. This can also include unnecessary procedures. One solution to this problem is to collect all of the procedures and records and, as you use them, separate them into critical, important, and unnecessary piles:

• Critical data is required by regulatory or customer concerns, or needs to be analyzed and acted upon.
• Important data, such as new products or upcoming requirements, is not critical now but can affect the business in the future. Within six months to a year, start boxing these procedures and destroying them as necessary. Make sure that you know the retention requirements for the government or the audit standard before shredding.
• Unnecessary data has no use now or in the future. These documents should either be boxed and stored or slated for eventual destruction.

Since people tend to be effective when a situation appears to be manageable and not when they are inundated by the system, we’ll cover the record retention policy later.

Keep Systems Simple

Too often, we focus too much on the wording and not enough on the intent. It’s not that words are unimportant. In fact, they are very important. To be effective, written documentation must clearly communicate its intent. Excessive wordiness can make the document more difficult for the reader to understand. In order to ensure that documents are concise and to the point, use this simple rule: Do as I say, say as I do. Sometimes, it helps for managers to step back and ask themselves, “Is it really working? Is this the intent?” Remember, for a system to be effective, a company must document the system around the activities and not unnecessarily change the activities to meet a requirement.