It's All About Top Management Committment, Food Safety, Legality, Food Quality And Continous Improvement(s).
Change can be the culprit, but it can also be the godsend.
In this case, the change is attaining and maintaining the Global Food Safety Initative (GFSI) certification.
It all begins or ends with senior management commitment.
Without such commitment, companies are just spinning their wheels, wasting time and money. The British Retail Consortium (BRC) states it like this:
BRC 1.1 - Senior Management Commitment and Continual Improvement – Fundamental #1 “The site’s senior management shall demonstrate they are fully committed to the implementation of the requirements of the Global Standard for Food Safety (GFSI) and to processes which facilitate continual improvement of food safety and quality management.”
GFSI defines senior commitment as providing both the financial and human resources needed to implement GFSI standards all the way to final shipment of excellent conditioned products. Examples of such commitments would be providing the means of sending selected employees to GFSI seminars while improving the plants infrastructure.
One reader responded to a previous Meatingplace blog on this topic by saying some companies half-heartily attain GFSI certification through smoke and mirrors and aren’t fully committed. I believe such far-and-in-between companies will ultimately lose their certification status.
Within the BRC standard there are 12 Fundamental requirements, starting with management commitment and continuous improvement.
Failure to comply with the intent of any one of the 12 Fundamental standards leads to a spontaneous non-certification during the initial audit or withdraw of certification at subsequent audits. Corrective actions would then be followed by another full audit to establish demonstrable evidence of compliance.
Section 2.1.2.9 of the Safe Quality Foods (SQF) code states: “The senior management shall establish processes to improve the effectiveness of the SQF System to demonstrate continuous improvement.”
Though the SQF wording is different than BRC, the intent and consequences are identical. This is how critical genuine senior management commitment really is.
Another response from my blog was a prudent one from Michele Pfannenstiel. Michele’s experience involving the initial implementation of GFSI was that it takes time, preparation and planning and that carefully planned preparatory steps should be taken that leads to eventual GFSI certification. This advice is spot on.
When this time, preparation and planning by senior management does not occur, there are always consequences and I have witnessed those as a consultant at selected FDA and USDA inspected plants.
Some FDA plants presently have their hands full with the pending Food Safety Modernization Act and its remarkable Hazard Analysis and Risk-Based Preventive Controls requirements. And all the while, they must maintain their pre-existing HACCP and ancillary programs while dealing with daily production chores. And because of customer demands and set deadlines involving GFSI certification, some are concurrently scrambling to blend GFSI into their operations.
That is exactly what can happen when management procrastinates, whether it’s customer or regulatory driven.
Who is at fault here?
Senior management is, and the experienced folks at GFSI who develop and govern the rules and amendments are well aware of it. That’s exactly why the benchmarks were designed the way there are.
Sometimes a series of expensive tsunamis needlessly occur, caused by poor management planning. Qualified FDA consultants continue to make a killing at selected FDA plants because of poor management leadership. Though the work is demanding for everyone involved, it’s lucrative for consultants and expensive for the plants.
Upright consultants can get a plant rolling and approved while ensuring assigned company personnel are trained and become self-reliant as the process evolves so they can become confident and fully capable of navigating their own GFSI ship - internally.
Beware, however, of selected consulting companies that set annual contracts for continued business after initial goals are achieved. I question the need for ongoing monthly teleconferences, for which the consultant is likely taking automatic monthly payments. The many standards put into action during the implementation stages should more than suffice.
GFSI isn’t rocket science and one doesn't have to be Phi Beta Kappa to see that selected consulting companies deliberately sway management to a) thinking, b) believing, and then c) reacting as though it is.
Next time we’ll cover selected food safety and quality management standards that many companies have a penchant to trip over. And when we do, keep in mind the phrase mentioned in part 1 of this series - "It's all about top management committment, food safety, legality, food quality and continous improvement."