Tips for Establishing Employee Guidelines for Food Processors

One of the most overlooked assets for many food processors is their workforce. There is a great deal of focus on food safety and quality, food safety culture, and prerequisite programs, but when it gets down to brass tacks, the line workers and their performance are what ensures that the plant operates as it should.

The role of production, sanitation, quality, and warehousing supervisors is to manage the operation and ensure that the company’s quality, safety, and sanitation programs are developed, documented, implemented, and—most importantly—properly maintained. It’s up to individual workers to conduct their jobs properly to ensure that programs are maintained. The key to maintaining the food quality and safety system is, as mentioned, developing and documenting programs, and then making sure that workers are properly educated so that they understand not only what is expected of them, but the rationale behind these expectations.

The Preventive Controls for Human Food rule found in title 21 of FDA’s CFR parts 117.10 and 117.37 emphasizes the need for programs such as disease control, handwashing, proper garments, and basic cleanliness, and is focused on people and equipment. CFR 117.37 addresses sanitary facilities and controls. How and why these are essential should be addressed as part of employee education. The goal is to minimize the potential for cross-contamination and cross-contact on the processing floor, in the warehouse, and on receiving docks to ensure that the foods produced are safe and wholesome.

The word “education” is used in this instance because it implies that a company’s programs focus not only on how to complete something and what is expected, but also why the programs are in place.

Education or training should occur within three levels:

• Orientation for new employees (this two-part program encompasses employee guidelines and job training);
• Refresher sessions for all employees (this should occur annually); and
• Emergency sessions in response to problems.

These programs must be developed, documented, and implemented by qualified individuals, preferably a Preventive Controls Qualified Individual (PCQI), in facilities regulated by FDA. Training may, however, be conducted by people under the supervision of a PCQI.

Orientation

All new employees must not only learn how to perform the job for which they were hired, but must also be educated on what is expected from a food hygiene, safety, and sanitation perspective. There are four areas that an orientation should address above and beyond learning how to conduct the task for which employees were hired. These are:

1. Issues related to prevention of contamination or adulteration.
2. Rules pertaining to clothing and garments;
3. Employee hygiene and disease control; and
4. Eating, drinking, and smoking.

How the orientation is conducted varies among companies. Some operations may present the information in a Powerpoint presentation led by a staff member, others may show a video, and some may simply give the new employee a document to review. An interactive program with visuals is the best option. When employees see, hear, and do, there is a greater chance that the message will register with the audience. It’s a good idea to provide each new employee with a document, such as an employee handbook that describes all expectations. They should sign the document acknowledging that they have both received and understood the company’s rules. Some operations even include language in their documents such as, “I understand the rules for employees of this plant and promise to abide by them as long as I am employed by the company. I also understand that failure to follow these rules may be grounds for dismissal.”

Employee Guidelines

Let’s look at what might be included in a food processor’s employee guidelines. Here are some points that a processor might establish to minimize the potential for product contamination or adulteration: