Training Oversights and Their Impact on GFSI

Failure to train new employees and failure in testing and training verification were among the most common nonconformance issues mentioned. Also falling short, according to auditor responses, was plants’ ability to satisfactorily document proof of training compliance verification. Among the list of documentation deficiencies were difficulty accessing documents and records, failure to validate food safety performance on a daily basis, incomplete training documents, and insufficient proof of successful remediation.

The survey findings do not surprise Gary Smith, vice president of certification and supply chain solutions for Steritech Group Inc., a major provider of brand protection services. “The number one issue with training is the ability to demonstrate the activities to the auditor,” Smith said. “Then we’re finding that if something goes wrong, employees don’t know what corrective action to take.”

Smith said the GFSI Guidance Document has “raised the bar,” and companies seeking scheme certification should realize that employee job performance is a reflection of their training and comprehension. “Why are employees struggling to demonstrate their knowledge? Because they’re not properly trained,” Smith said.

Umbrellas vs. Silos

What has been made painfully clear is that food safety training at many plants is not unified. Companies tend to allow individual departments, such as quality assurance or human resources, to develop their own programs to achieve training objectives. Such disparate approaches within one plant, separate “silos,” are likely to lead to conflicting results and limited training success, drawing the eventual skepticism of experienced auditors. Documentation is one object of scrutiny: Information about classes attended, testing, and follow-ups will vary from department to department—and the paper trail may be difficult if not impossible to navigate. Inconsistencies within one company, especially when it comes to documentation of comprehension after training, place that company at risk for findings of nonconformance and a delay in achieving scheme certification.

Progressive companies now recognize the need to place their initial training, comprehension, remediation, and refresher training under one unifying umbrella rather than separate silos, which can vary in procedures from department to department. Here, technology can provide the required support with a thorough, easily accessible, and fully documented platform.

A comprehensive technological approach can integrate all employee learning plans in such diverse areas as food safety, workplace safety, and standard operating procedures. It is also an asset in addressing every other facet required for scheme certification, GFSI standards, and company-specific training objectives. Through technology, learning plans can be developed and modified, training presentations and attendance can be easily tracked, and test results for every class are easily maintained. In fact, all are accessible whenever anyone, including an auditor, requests them.

One company that can attest to the success of an integrated technological approach is O-AT-KA Milk Products Cooperative, a Batavia, N.Y., global dairy processor. The company, which had already been certified for SQF Level 2, wanted to be certified for Level 3 but recognized it needed to make substantial changes in its training program. To meet annual training requirements for food safety topics and SOPs, O-AT-KA knew it had to emphasize job-specific content and upgrade its validation of employee comprehension, all of which had to be properly documented.

At first the company feared it would have to add personnel because of the paperwork it assumed would be required for the higher level of SQF certification. Fortunately, the automated technology platform the company implemented enabled more efficient usage of staff time, increased the number of training topics that could be covered, and basically eliminated the need for paperwork, with all records stored and documented electronically. The result: O-AT-KA was granted Level 3 SQF 2000 certification in 2011, achieving one of the schemes that meet GFSI standards. The company also confirmed that it had reduced the paperwork necessary for its training records by nearly 100%.

Ensuring Effective Training and Minimizing Risk

The roles of training, comprehension, and remediation are critical, and their importance is not limited to GFSI standards. There is little doubt that the FDA plans to strictly enforce the provisions of the FSMA on executing preventive controls in the food industry, particularly when it comes to training. Haphazard documentation, marginal passing grades, and delayed remediation follow-up will be viewed as unacceptable. This is especially true when such actions do little to decrease the risk of contamination because of unwitting oversights and an unwarranted assumption that passing grades equate to understanding serious food safety concepts on the plant floor.