GFSI’s safety and quality management programs
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(The views and opinions expressed in this blog are strictly those of the author.)
Michael Fischer, an experienced FSIS inspector commented on fellow Meatingplace.com blogger Shawn Stevens’ blog concerning plant recalls, by stating that proper record-keeping may have avoided / limited plant recalls of the past.
Inspector Fischer is spot on.
Conformance to the Global Food Safety Initiative (GFSI) thrives on crystal clear recordkeeping. This is one of many examples of how establishment’s can enhance and improve their food safety and quality management systems by layering in GFSI into existing FSIS programs.
Under BRC it reads: “… all procedures and work instructions shall be clearly legible, unambiguous, in appropriate languages and sufficiently detailed to enable their correct application by appropriate staff. This shall include the use of photographs, diagrams or other pictorial instructions where written communication alone is not sufficient (e.g. there are issues of literacy or foreign language).”
When developing GFSI themed food safety and quality management systems is constantly reflected back upon as both pre-existing and new food safety and quality management programs are being revised/developed by the GFSI team including vital record-keeping forms.
A GFSI themed recordkeeping register is developed that lists:
BRC prudently adds: “… records shall be legible, maintained in good condition and retrievable. Any alterations to records shall be authorized and justification for alteration shall be recorded. Where records are in electronic form these shall be suitably backed up to prevent loss.”
BRC code goes on to state, “… records shall be retained for a defined period with consideration given to:
This shall take into account, where it’s specified on the label, the possibilities that shelf life may be extended by the consumer (e.g. by freezing). As a minimum, records shall be retained for the shelf life of the product plus 12 months.”
Clear, logical, proactive and laser accurate.
GFSI programs do include many pre-existing FSIS / FDA programs with only some fine-tuning needed. I’ve seen meat/poultry plants that knowingly or unknowingly tuned their FSIS programs towards GFSI requirements simply because it was the logical thing to do.
Example: Take the Oct. 20, 1999 final rule involving FSIS’ Sanitation Performance Standards (SPS) whose categories are listed below:
416.1 – General rules states that … “establishments must be operated and maintained in a manner sufficient to prevent the creation of insanitary conditions and to ensure that product is not adulterated.”
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416.2 - Establishment grounds and facilities
416.3 – Equipment and utensils
416.4 – Sanitary operations
416.5 – Employee hygiene
416.6 – Tagging insanitary equipment, utensils, rooms, or compartments
All of these SPS’s are included within GFSI schemes. But what establishments weren’t always doing was what Inspector Fischer was alluding to; insufficient recordkeeping and I’ll add in written programs as their guiding foundation.
I recall back in 2001 when consulting with a beef harvesting/further processing plant we developed individual written programs and specific recordkeeping forms for each SPS with pictures and maps. This was pre-GFSI and the reasons we did it were two-fold. The first one being that we had written a technical proposal for entry into the National School Lunch Program (NSLP). Second, from getting pounded needlessly following GMP food safety audits. We applied the NSLP’s plan, do, check and act format and afterwards we’d breeze through audits while concurrently becoming more efficient regarding food safety and quality control.
One can also add into the mix selected establishments that have in place Export Verification Programs, HACCP, SSOP’s, Food Security Programs, GMP’s, Product Recall Programs, Grading Programs, selected/mandatory microbiological testing programs, among others which all comes into play under the GFSI umbrella exactly as the right sized Lego toy does when snapped into place.
Selected establishments regardless of their size that I’ve visited didn’t really know about SPS’.
Yes, they received NR’s that would reflect them, but some never took the time to properly address and utilize SPS’ to their full advantage/potential.
With few exceptions, naysayers of FSIS should appreciate the myriad regulations that the agency has published over the years.
11/11/2016 Meatingplace.com (Revised 3/31/2022)