Having a documented procedure that defines your HACCP based food safety training programme is not a specific requirement of the FSANZ food standards code.
However, a training procedure is an expectation of regulators and major retailers because it adds to the control of a company’s food safety operations and decisions. From a business perspective, a procedure that describes your food safety training activities is a simple yet effective way to communicate and standardise what is expected.
It seems logical, then, to describe what should be considered in a document defining a food safety training programme. If your company does not have a training procedure, you can use these as ‘points to consider’; if your company does have one in place, you can use these as a checklist in evaluating it.
Sources for current expectations:
Unfortunately, there is no government ‘guidance to industry’ on training. First, look at the GMP / food safety regulations that apply to your company. They might include the regulations of your state or customers, depending on where your products are marketed.
You will see basic requirements in the FSANZ food standards code section 3.2.2, clause 3 stating that: ‘A food business must ensure that persons undertaking or supervising food handling operations have:
- Skills in food safety and food hygiene matters, and
- Knowledge of food safety and food hygiene matters commensurate with their work activities.
The requirements of this training will require definition in your company’s procedure. In your procedure you will need to define ‘skills’ and ‘knowledge’ such as they mean to your company (consistent with the following points)
Points to include in a training procedure:
Here are some points to consider. The information sources listed above provide additional details that you may include.
Scope of the procedure:
Define what personnel or sites are covered by the training procedure. For example, the procedure might have a corporate wide scope, or it might affect only one site or business unit.
Types of training covered by the procedure:
Your good manufacturing practices call for training personnel in the application of the tasks they perform.
Responsibilities for the training programme:
Your programme should define what organisational unit(s) is (are) responsible for training efforts including the design and delivery of the training events.
Responsibilities are frequently split among different departments. For example, in some companies the QA department is responsible for GMP / HACCP training and conduct internal auditing to ensure the training programme is working.
Skill training is often part of the individual operations area. Other companies include GMP and skills training as part of the human resources (HR) department. However keep in mind some HR groups are not sensitive enough to the special compliance issues that are part of GMP training.
Food safety is not just another ‘soft skill’ topic, a ‘nice to know’ that a generalist can teach.
Identify people to be trained:
In this part of your procedure, identify the general audiences for training. This includes operations, maintenance, lab, and technical staff; it also includes management, contract, temporary, and consulting personnel. As I work with food industry managers, I encourage them to give some GMP / food safety training to everyone. As you consider audiences for training, do not forget that senior and line management need to have some food safety ‘literacy’ as they make many food safety related decisions.
Temporary and contract personnel present a particular training challenge. Organisations like using them for flexibility and to keep head counts low. That does not excuse a company from complying with the FSANZ training requirements.
When training is conducted:
Effective training must be ongoing. Most companies’ conduct formal food safety training or reinforcement training at least annually; some do it twice a year; a few do it quarterly.
Training on specific HACCP related skills (such as conducting monitoring a CCP) and on new, revised, and unchanged procedures should be considered here as well. Be realistic as you set training intervals so you can actually accomplish what is defined.
The quality assurance (QA) team should approve various elements of your training programme. QA review and approval of GMP / food safety related training courses are particularly important. QA approval should indicate that the courses are complete and accurate, covering topics and using examples that are relevant and meaningful to the learners.
Quality personnel also should review and approve food safety training curricula for job functions or positions. Although the points listed above are consistently adopted as industry practice, the approval of SOP training varies considerably.
It is easy to say that QA should review the training outline for each course (for each procedure), but what does the typical QA representative know about teaching a cleaning procedure for a diaphragm pump?
In some situations, QA ‘approval’ is just a rubber stamp, an act that looks good but gives a false sense of assurance. An alternative is for QA to approve the ‘templates’ or standard outlines for training and place a high emphasis on the review and approval of instructor qualifications.
A training plan for a position lists the instructions that a person needs and should be developed for everyone in a in a food business including management. It is the ‘specification’ for training and includes the recommended sequence and timings for each event. Some companies have integrated training plans that cover more than food safety topics, such as worker health and safety, and so on.
The list of procedures, protocols, and methods used is also part of a person’s training plan. The quality team should review and approve the training plan for each job function. Periodically, they need to be compared against the training records for each person to ensure that the prescribed training is taking place.
Many companies use a standardised approach to developing training courses and events. A model that includes analysis, design, development, implementation, and evaluation is often used to ensure course integrity and consistency.
Maintenance of training materials:
Your training programme should include a provision for periodic review and updating of training courses and events. All changes should be approved by the quality unit before being implemented. The plan also should consider the impact of new content on those who have already taken the course; alternatives to retaking the full course may be adequate.
Retention of training materials:
An official copy of instructional materials (such as course outline, worksheets, and instructor’s notes) should be retained. Your procedure should define where such materials are filed. Regulatory auditors rarely ask to see course outlines; such materials are more valuable as a record of what was actually taught. In deciding how long to keep them, a practical solution is to keep the materials of the course currently being used along with the version previous to it.
Qualification of trainers:
In your training procedure you should describe the minimum trainer qualifications, such as successful completion of basic food safety training. For example, a trainer of a course in internal auditing should have experience as an internal auditor.
Scheduling and administration of training events are time-consuming tasks essential to the success of a training programme. Different approaches used by companies include a direct approach (‘you will attend on this date and time’) or providing learners (or their supervisors) with a set of dates they can select from. The method(s) used and responsibilities should be defined in the programme.
Records of training:
Several elements figure into documenting when someone completes a training course. The minimum information is a sign-in sheet with the person’s name, signature, name and number of the course, date of the session, and the trainer’s name and signature. The participant’s signature attests to his or her attending the complete session; the instructor’s signature attests that the programme was given and that the people listed did attend.
If testing scores or pass–fail assessments are collected, it is useful to include them in the training management system. Attendance in outside training and educational events
(such as conferences and technical meetings) also should be documented because it contributes to a person’s ‘education, training, and experience.’
Copies of certificates, and programme outlines or other information are useful records to retain. Some electronic training management systems have provisions for documenting outside events.
Your procedure should define where such information is kept (preferably not as part
of the person’s confidential personnel files) and how long it should be retained (typically several years beyond the last date of the individual’s employment).
Your training procedure also should consider keeping records on temporary and contract personnel who must meet
GMP training expectations:
Training management systems often are tied into a company’s personnel and payroll database, which does not include temporary or contract people.
Your company’s use of testing or assessment is described in this part of the training procedure, including the types of assessment used (such as pen and paper, verbal feedback, computer-based, or performance-based).
A particularly important element is determining what constitutes passing and what happens when an employee does not pass a test. You do not want to create the awkward situation of a person independently performing a GMP task on which he or she has been assessed and failed. Consideration also must be given to other legal issues of testing on the job if it in any way affects a person’s salary or position.
Many companies use participant feedback forms to collect subjective information from the attendees. Your procedure may state when feedback forms are appropriate and how the data are to be collected and summarised for the trainer and management.
Reports to management:
Management at all levels should be kept informed about training activities. Summary data can include the number of people attending programmes, percentages of those who have completed particular courses, people who are significantly behind in meeting their training plans, and assessment scores.
If people are not getting trained in a timely way, management may find that production demands are impinging on time available for training.
Keep it practical:
Your training procedure needs to be complete, but do not burden it with unnecessary and impractical details. You want the procedure to define and standardise your food safety related training activities so you can enable your personnel-at all levels-to make decisions and take actions that contribute to products that are safe and of high quality.
Edward McCartney is a senior consultant with Food Safety Plus and a professional member of the Australian Institute of Food Science and Technology, certified RABQSA food safety auditor and registered SQF Consultant.
As a management consultant he has presented Food Safety and Quality Assurance seminars and training courses throughout Australia, and Papua New Guinea to food processors, producers, certification bodies and auditors.