The 100% Solution to Worker Testing

Some plants are satisfied with minimum passable scores and consider workers who achieve them as having satisfactorily completed and absorbed training. Some consider an 80% correct score acceptable proof of comprehension—a tenuous supposition.

Why? Because there is always the chance that the 20% the worker doesn’t know could result in improper handling or packaging leading to contamination. Just one incident of food safety noncompliance places the public (and perhaps the employees) at risk, while the company awaits the federal investigation, litigation, and bad media coverage certain to follow.

Yet it’s actually an internal concern about liability issues from training, testing, and comprehension that makes some companies leery. This hesitation emanates from three levels: quality assurance (QA), legal counsel, and unions. Fears of liability associated with employee comprehension graded at less than 100% have led a few companies to decide not to track actual scores—a clear example of an inadequate determination of worker understanding. Another potential red light is the possibility of union grievances over job security should any of their members fail the tests—an additional barrier to effective testing and training. Those involved in QA may be tempted to establish a lower test score threshold to reduce the number, not to mention the time and cost, of employees who will need remedial training.

“The important piece of all of this is to come around and address what is missed, what isn’t understood, and then readdress it,” said Kim Onett, lead auditor for Silliker, an international firm that conducts audits of the food industry, including GMP and food safety systems. “There are always opportunities for improvement, [and] increased training keeps things current and relevant.”

Unfortunately, remediation has also been found to be inconsistent, whether it’s in the form of additional testing or one-on-one training. Sometimes remediation can resemble an intervention; because of time constraints, this too can fall short of correcting a problem. When that happens, the company has unwittingly increased its liability exposure because training comprehension was not conclusively established in such critical areas as worker safety and health (e.g., cross-contamination of pathogens from improper handling and packaging).

A Legal Opinion

William Marler is no stranger to the perils that result from inadequate training and testing in the food processing industry. The Seattle-based attorney has a 20-year history of filing lawsuits against food companies because of alleged food poisoning or other safety violations that resulted in injuries to either workers or the general public.

Marler said that in several cases, his successful filings have forced companies into bankruptcy or liquidation.

“I think there are reasons they don’t invest in food safety until there is a disaster,” he said. “If you’re focused on producing a product, the risks of that product tend to get pushed to the sidelines. A company that is serious about a food safety culture trains and tests its employees to see if they really understand the training being given.”

His blog contains examples of worker food mishandling resulting from inadequate comprehension of safety. One example: At a California cheese company, workers’ failure to wash their hands before handling products caused microorganism contamination that led to investigations by several agencies.

Hand washing has always been emphasized in this industry, but because it didn’t happen in this case, a potentially lethal poisoning outbreak occurred. Is this another example that shows why an 80% correct rate isn’t good enough?