Market Watch

A
n incredible number of companies are making the decision to become certied to
a Global Food Safety Initiative (GFSI) benchmarked audit, such as SQF 1000 or
2000, BRC, FSSC 22200, etc. The question is whether or not it is an informed
decision. The audit has many benets, but when members of an executive team are making
the decision to become certied to a GFSI-benchmarked audit, they often do not fully
understand the resource commitment that is required. This article outlines some of the
more resource-demanding areas of the audits.
For purposes of this article management is dened as the senior site manager (often
plant manager) and the direct reports such as department heads or managers. Senior man-
agement is the team of decision makers in the plant and will be responsible for ensuring
resources are applied to implement and maintain the GFSI Standard of choice. Senior
management also will be expected to demonstrate commitment by participating both
passively (receiving communication) and actively (actual participation in the activity) in
the various activities being referenced in the clauses.
HOW MUCH WILL IT COST TO BECOME CERTIFIED?
There are clear costs for the certication process including application and audit fees. The
most difcult costs to dene are those associated with the day-to-day program improvements.
Keeping in mind that GFSI began with retailers, there is greater focus on the manufactur-
ing sites role in the larger supply chain. Traditional inspections and audits have focused on
the sanitary condition and safe handling of the food products on site. With GFSI, a broader
view is being taken and requirements are expanded beyond the walls of the manufacturing
site. For example, under GFSI-benchmarked audits, supplier approval is quite elaborate.
It includes approval not only of ingredient suppliers, but also of service suppliers such as
A decision to
become GFSI
certied is a good
one. An informed
decision to become
GFSI certied is an
even better one.
GFSI-CERTIFICATION
COMMITMENT
THE
By Stephanie Lopez
AIB UPDATE SEPTEMBER/OCTOBER 2011 7
Market Watch
laundering and transport companies and
laboratories.
RESOURCE RICH PROGRAMS
IN GFSI-BENCHMARKED AUDITS
In addition to the traditional food safety
programs that manufacturing facilities
have maintained for years, such as sanita-
tion, pest control, personnel practices,
and HACCP, there are several program
requirements that are new to many com-
panies. Some of these are listed below with
an explanation of the demands they will
make on resources, including time, money,
and people.
These include:
Management commitment
Change management
Document control
Training
Internal auditing
Corrective action
Supplier approval
MANAGEMENT COMMITMENT
The purpose of management commitment
i s to provi de a formal means of
communicating the status of a facilitys
programs to the senior site manager. The
senior site manager must provide adequate
resources for maintaining food safety, food
quality, and legality.
Components:
Senior site manager involvement at day
of audit
Ongoing involvement in key programs,
such as HACCP and internal audits, by
the senior site manager
Detailed documentation of meeting
minutes
A person assigned as leader, practitioner,
coach, or facilitator of the GFSI stan-
dard
Resource Considerations:
Time allotments for the senior site
manager to participate in meetings
Time allocated for all staff for adequate
traininginitial and refresher
Time allocated for program assessments:
verication, validation, internal audit-
ing
Training from external experts: HACCP,
GFSI, internal auditing
The leader, practitioner or facilitator will
likely devote half of full-time equivalent
(FTE) employees time to the system
maintenance
CHANGE MANAGEMENT
The purpose of change management is to
establish a formal review process for any
changes to product, process, or facilities
to ensure that the impact on food safety,
food quality, and legality is understood and
managed prior to realization.
Components:
R&D review for hazards (HACCP)
Test runs
Shelf-life trials
New or changed product evaluation
by all departments (maintenance,
warehouse, sanitation, production,
quality, occupational safety)-PRIOR
to production
Resource Considerations:
Test runs
Shelf-life trials
New supplier/new raw material evalua-
tions
Evaluations by all departments (this
could be allergen testing, capability
studies, effectiveness of cleaning chemi-
cals, etc.)
Training for all impacted staff about the
implementation of the new or changed
products/processes
DOCUMENT CONTROL
The purpose of document control is to en-
sure that documents (policies, procedures,
forms, etc.) that affect food safety, food
quality, or legality are controlled to ensure
that only approved versions are used.
Components:
Identincation of relevant documents
(maintenance, receiving, sanitation,
quality, production, etc.)
All documents provided with tracking
information (header, footer, or simi-
lar) that contains, at a minimum, the
document identication and version
information
Identincation of person authorized to
approve/change each document
Master list of approved documents with
current version information
Change log of all revisions to all docu-
ments
Training of relevant staff on established
and modied documents
Procedure for rescinding/replacing
obsolete documents
Provision for storing all documents and
records for the dened period of time
Resource Considerations:
Possible software to facilitate creation
and tracking of documents
Time allocations for creating, changing,
rescinding documents
Time allocations for training employees
on established and revised documents
Possible contracted warehousing for
document archival
TRAINING
The purpose of the training program is
to ensure that training has been provided
and evaluated for each task or activity per-
formed related to food safety, food quality,
or legality.
Components:
Training needs assessment to identify
the training mechanism for each activ-
ity/task
GFSI audits have many benets, but when making the
decision to become certied, executive teams need to fully
understand the resource commitment that is required.
8 SEPTEMBER/OCTOBER 2011 AIB UPDATE
Market Watch
Training plan to identify required train-
ing for each job function
Documented training (on-the-job,
classroom, or otherwise)
Documented connrmation that trainee
understood the materials and is compe-
tent
Resource Considerations:
Train-the-trainer course for in-house
personnel providing training
Time allocations to ensure that there
is documented training for each task/
activity
Time allocations for the connrmation
of trainee competence
Expert trainers (on-site or public
courses)HACCP, GFSI, internal
auditing
Videos, DVDs, online courses, cor-
respondence courses, etc.
Interpreters or translators needed to
ensure training is provided in a language
understood by the employee
INTERNAL AUDITS
The purpose of the internal audit program
is to evaluate all the elements of the audit
standard against the facilitys programs to
identify weaknesses or gaps and to ensure
timely correction.
Components:
Internal audit team
Auditors independent of area/subject
being audited
Audit schedule
Documentation of conformances and
non-conformances
Documented corrective action, preven-
tive action, and follow-up
Communication to senior management
Resource Considerations:
Recognized training in audit principles
for audit team leader
Training in audit principles for audit
team members
Time allocations to evaluate the entire
audit standardincludes time alloca-
tions for internal auditors and internal
auditees
Time and money needed to correct any
non-conformances
Time allocations to conduct follow-up
investigations to ensure that preventive
measures were effective
CORRECTIVE ACTIONS
The purpose of corrective action is to en-
sure that weaknesses in programs related
to food safety, food quality, and legality
are addressed and that effective measures
are taken to prevent recurrence.
Components:
Identincation of incidents or triggers
that require corrective action (such as
complaints, internal audit ndings,
negative trends in self-inspections,
etc.)
Investigation and root cause analysis
Documentation of corrective action,
preventive action, and follow-up for
each incident
Resource Considerations:
Time allocations for root cause analysis
by person(s) knowledgeable about the
incident; this is often more than one
person
Corrective action may involve destruc-
tion of product or line downtime
Preventive action often involves a
financial investment to modify a
system
Time allocations to conduct follow-up
investigations to ensure that preventive
measures were effective
SUPPLIER APPROVAL
The purpose of supplier approval is to
ensure that suppliers of goods or services
that impact food safety, food quality, or
legality meet established criteria and are
monitored for compliance.
Components:
Ingredient supplier approval and moni-
toring
Packaging supplier approval and moni-
toring
Processing aide supplier approval and
monitoring
Chemical supplier approval and moni-
toring
On-site supplier approval and monitor-
ing (pest control, janitorial, HVAC,
etc.)
Off-site supplier approval and monitor-
ing (laboratories, label review, etc.)
Resource Considerations:
Time to manage associated documenta-
tion (letters of guarantee, certicates of
analysis, approved supplier logs)
Training for employees who will con-
duct supplier inspections/audits
Time to visit and evaluate suppliers
Time to review third-party audit reports
or program submissions from suppliers
(HACCP, allergen control)
Monitoring of suppliers (testing of
product to conrm validity of certicate
of analysis data)
Training of suppliers that come on-site
A facility cannot have a commitment to
GFSI without a commitment to provide
all necessary resources, including time,
money, and people. A decision to become
GFSI Certied is a good one. An informed
decision to become GFSI Certied is an
even better one! AIB
The author is Director of Food Safety Education,
AIB International.
THERE ARE CLEAR COSTS FOR THE CERTIFICATION PROCESS
INCLUDING APPLICATION AND AUDIT FEES. THE MOST
DIFFICULT COSTS TO DEFINE ARE THOSE ASSOCIATED WITH
THE DAY-TO-DAY PROGRAM IMPROVEMENTS.
A FACILITY CANNOT HAVE
A COMMITMENT TO GFSI
WITHOUT A COMMITMENT
TO PROVIDE ALL
NECESSARY RESOURCES,
INCLUDING TIME, MONEY,
AND PEOPLE. A DECISION
TO BECOME GFSI CERTIFIED
IS A GOOD ONE. AN
INFORMED DECISION TO
BECOME GFSI CERTIFIED IS
AN EVEN BETTER ONE!
AIB UPDATE SEPTEMBER/OCTOBER 2011 9