In today’s environment, there are so many things the food safety leader has to think about that it seems you never know where your next issue will come from. It could be having to bring in a lot of new temp workers on short notice, understaffing a supposedly non-essential “low” priority area (e.g., the cleaning crew), or simply having to run lines short. Or, it could even be, as occurred recently in Mississippi, the loss of numerous workers in seven food processing facilities due to an ICE raid. It’s not difficult to notice that all of these are worker related and, as we all know, workers are a critical part of maintaining food safety. So when the workers are disrupted, so is the food safety. While plenty of other unexpected, unconventional issues can crop up (such as an emerging pathogen you’ve never before dealt with – but that’s a whole different article!), your workers are the essential difference between a safe, quality, on-time product and a recall. And when you run short, the difference, and the risk, becomes that much greater; and food safety becomes all about managing that risk. While you, as a food safety and/or quality assurance manager, may (or may not!) have some say in the hiring of plant-floor workers, you likely are not the first link of that chain or the one who verifies their background, and may not even have a say in how many workers you can employ. But you are the one who is responsible for those workers once they are on the floor. So what can you do to manage risk that could originate with your workforce? The obvious, and accurate, answer is training and education. But what is that training and education; what processes and practices should take priority; and what else should you be doing? Training temps or large numbers of new employees at short notice can be a challenge. So if you have not done so, plan on how you may accomplish this should the unexpected happen. TAG’s extensive experience in and with food facilities has shown there to be three key areas of risk: operational, regulatory, and reputational. Operational. As the most applicable area of risk to your workforce, operational risk could involve areas such as allergen cross contact, raw/finished product cross contamination, intentional adulteration/food defense, health and hygiene, food segment and facility-specific practices, and general food safety culture. Ongoing training, education, and on-the-floor observation should regularly occur in all these areas. Regulatory. While workers do need to understand applicable aspects of the regulations that apply to their jobs, it is your job (or that of your training manager if you have one) to put those into terms and practices that they can understand and apply. Some of the most applicable regulations are FSMA’s Preventive Controls, GMPs, and Produce Safety, USDA’s animal handling, and specified HACCP programs. Remember to keep a log of training. Reputational. The controls related to operational and regulatory risk then factor into your reputational risk, along with your management of any crisis that should occur. In this case, being prepared means assessing the particular aspects of your facility and worker situation; addressing gaps in worker practices, procedures, and training; and deploying best practices to mitigate risks and protect your brand. While all of the above are applicable to all food facilities, managing potential risk is particularly critical when you do have worker shortages or atypical numbers of temporary workers – which can occur for any number of reasons.You may not know where your next food safety risk will come from, but you can take steps to keep your workers performing effectively (however many you may have) and your facility operating efficiently, so you can focus in on and mitigate any issues that do arise. Assessing and continuously improving your food safety system is key to mitigating risks and protecting your brand. TAG’s experienced team of experts can help. Give us a call today. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com
