The Nuts and Bolts of Proper Documentation for a Food Safety Plan

Operators must create a master list of all the procedures and work instructions that need to be created. The FSMS needs to include protocols for the Hazard Analysis and Critical Control Point (HACCP) plan, the supporting prerequisite programs, food defense, and more. For a partial list of what a processor might need to develop, see the List of Procedures to be Developed box. There will also be programs in which different levels of procedures will exist. The primary example is cleaning and sanitation program. This program would include general procedures that describe the expectations of the program, define the master cleaning schedule, and establish a means to both validate that cleaning procedures are effective and verify that the work was done properly. The cleaning program would also include specific work instructions that defined how each piece of equipment and each area/part (floors, walls, drains, overheads, etc.) of the plant would be cleaned.

The next step is to create a plan for developing and documenting each of the procedures defined above. The schedule highlighted in Table 1 could serve as a model. When this plan is created, priorities and scheduling should be developed based on risk. When developing the implementation plan, the team should assign responsibility to specific persons within the company to develop and document each element on the master list. If a person has been doing a task, he or she would be the logical choice to be assigned the task of developing the procedures for that area. A word of warning: It is a bad idea to hire someone from the outside to create a company’s HACCP plan or write the supporting procedures. For a program to be successful, it is imperative the company have a sense of ownership of those procedures. If a third party writes them, there is no ownership, which is a precursor to failure. Consultants should be advisors or facilitators, not creators.

Which brings us to the last step: developing and documenting the individual procedures. This can be a real challenge for companies since there are many who are not comfortable when it comes to writing or sitting in front of a computer. There are ways around this. One is give the person assigned with creating the protocols a voice recorder to talk through the protocols. The procedures on the recorder can then be typed up and edited by someone within the company.

Getting things on paper is only part of the whole equation. Remember the mantra from the start of this piece: develop, document, implement, and maintain. There is always an issue with creating procedures. Are they well-written and will they be easily understood by those responsible for conducting the work? One means for ensuring this is to run draft procedures by non-technical types. If they can grasp what is wanted, there is a very good chance the procedures will be acceptable and easily understood by those who will do the work.

Don’t forget, procedures, work instructions, and recordkeeping forms are constantly evolving. They will be upgraded, updated, modified to meet changing demands, and developed anew as operations expand and seek to do things better. This is one reason why appointing a document control officer was the first step in this procedure. Their task or tasks won’t go away.

Stier, industry editor for Food Quality & Safety magazine, is a consulting food scientist with international experience in HACCP, plant sanitation, quality systems, process optimization, GMP compliance, and food microbiology. Reach him at [email protected].