Facing a Tougher Future

Food processors rely heavily on the Canadian Food Inspection Agency (CFIA) and third-party audits to tell them if their operations and products are in compliance. The reality is that the CFIA and third-party audits can’t cover everything. Here is a short food safety checklist for CEOs and COOs:

• HACCP plans for all fully cooked and minimally processed foods are audited at least yearly by qualified personnel. HACCP plans for other products should be audited as well – the frequency should reflect risk and food safety issues being experienced.

• HACCP Plan Critical Control Points are incorporated into production documents.

• The company shares audit reports from the CFIA and third-party auditors with management and customers.

• There is a documented and validated hold-release program in place to ensure that, at a minimum, all fully cooked and minimally processed foods are safe.

• Experienced quality assurance (QA) personnel are present and engaged during sanitation.

• Production does not begin until sanitation is completed and QA has signed off.

• Senior QA, operations and sanitation personnel meet regularly to address food safety and sanitation issues, and minutes are circulated to management.

• There is less than 20 per cent turnover annually in the sanitation and QA departments.

• Training for food safety and sanitation is ongoing and documented for sanitation, production and QA personnel.

• The company has documented and validated backup plans to address sanitation and food safety issues in the plant. “Plan A” is normal operating procedures, “Plan B” is implemented to address most deficiencies, and “Plan C” is a crisis response plan.

• There is a documented customer complaint program defining the roles of company personnel, and procedures to follow for responding to complaints. Reports are circulated to all management personnel. Management takes prompt and meaningful action to address the complaints.

• There is a documented recall plan and crisis management plan that is validated annually by all stakeholders.

• The company has at least $10 million in liability insurance and possibly other insurance to cover the cost of a recall and business interruption.
If your company is deficient in any one of these items, I strongly recommend that you address the matter in the near future. Not doing so could be very costly.