Food safety management systems frequently fail. We know this because it is contained daily in media and agency reports on recalls, alerts and food poisoning outbreaks. These events are the public expression of these failures, but behind them there is a deeper story – one of food business operators who under legislation, certification and customer standards are required to have in place systems capable of preventing these events occurring in the first place.
Based upon past experience, when undertaking many implementations with food businesses I began to realise that the large, complex, manual food safety systems we had put in place to meet the various requirements of regulators, customers and certification schemes would in time present major challenges to maintain and prevent failure. It was not that we were providing a poor service, indeed we had a glowing portfolio of project success. It was the fact that the manual, paper based platform would by its nature require dramatically increased inputs to maintain it.
I will return to this point in a moment but first let’s talk about the more obvious reasons food safety systems fail. These can be catalogued under two general headings. Those relating to design and implementation of food safety systems and those relating to their ongoing maintenance. Examples include; failure to identify hazards and CCPs correctly; inadequate provision of resources; poor management commitment and culture, poor quality data and information; poor understanding of the requirements; poor training and poor technical leadership. We are all familiar with them but for me they only represent the true nature of the issue.
‘The Second Law of Food Safety’
Food safety systems lose energy. It is a generally accepted law of nature that in a system where work is conducted, heat or energy is lost. While this law usually relates to the more lofty scientific principles of thermodynamics (the second law of thermodynamics to be exact), I have always been of the opinion that it holds true, at least in the layman’s universe, for any organised system particularly where human inputs are essential, just like a food safety management system.
Let’s phrase this another way. The natural tendency for any management system is towards disorganisation, disintegration and ultimately failure. For those of us who have ever been responsible for the maintenance of a food safety management system we know this to be true. Even a couple of days where tasks are not completed, the food safety management system begins to show early signs of losing integrity. And the more manual, complex and dependent on humans to maintain the system is, the quicker it descends into ruin. Why should this be? The reason is simply that like a cup of boiling water or a poorly insulated house, the food safety system will over time lose energy. It must be maintained and re-energised constantly. We must add more hot water and insulate where possible.
Let’s bring this back to the real world of food safety management and think about a more practical example we can all relate to. The vast majority of food safety systems are manual and paper based. To maintain order and integrity, by their very nature, they require significant and continuous human input to maintain. The internal auditing system for example is usually planned and schedule on a grid or spread sheet, which defines what is to be audited, who will conduct audit, when it will be conducted and against which checklists. A lot of input required here. But before this energy is even spent, the internal audit system requires a human to first check the plan. More input. If someone fails to check the plan or checks it late this system already starts to break down. Furthermore, the outputs of the system will yield non-conformances which in themselves need to be notified, assigned, reviewed and corrected.
Once again it depends on one or more humans to independently remember and initiate the processes described. These manual system are so open, they readily lose energy even after one missed oversight, task or late action. This is the most fundamental reason why food safety systems fail.
The Rise of the Unannounced Audit
Recently, one of the most objective events that supports this analysis is the unstoppable move to unannounced audits around the globe. It is compelling proof. The unannounced audit reduces the window of compliance to just one day. The idea is that it prevents the system’s natural tendency to break down by holding out the possibility that an audit can be conducted on any day without notice. However in reality this is not the case. The certified audit frequency remains more or less the same except the company cannot identify the exact day it will occur. In general the audit event will take place in a window of time and so the systems will remain subject the same tendencies.
Stop Feeding Manual Systems
No food business wants to make unsafe food. Aside from the moral arguments it is simply bad business. If the product you produce is not fit for purpose then you will not sustain your position in the markets. Yet everyday food businesses produce products which are not legal, safe or wholesome. These companies are resourced and committed to their obligations in terms of food safety and good business, but they would appear to be subject to the same tendency towards failures. In other words they have the same manual, paper based management systems which expose them in the market.
The solution is to stop continuously feeding the energy hungry manual system. The solution is to design and insulate the system to reduce the rate of energy loss. This means removing the manual aspects of the system, which waste human and physical resources. We humans are capable of fantastic achievements – management of the paper monster in most food companies is not one of them and nor should it be. It is not by accident that we have made massive leaps in the application of IT solutions in almost every management process (accounts, stock control, HR management, production) except food safety. The reason is because food business have yet to formally measure the financial losses arising from food safety failures. In terms of stock control, financial controls, and HR the losses are self-evident and therefore investment in IT for these systems is almost ubiquitous.
This is changing. IT solutions which automatically monitor programs and schedules; create the records for completion; sends out notifications, automatically alerts the right individuals when control is slipping, generates reports and disseminates them, compares results to specifications and stimulates corrective action, trends data. It knows when to push alerts higher up the organisational structure if critical areas are being neglected for any defined period of time. Above all, it allows your internal resources to expend energy on those areas where value is added e.g. the actual audit exercise as opposed to its management.
The loss of energy is now dramatically reduced and the tendency towards disintegration is mitigated. We are not seeking to change the laws of nature, but we simply want to understand them and in so doing design, implement and maintain better food safety system which produce fewer failures.