Julia Stewart:
Hello, this is Julia Stewart, PMA PR Director, here with PMA Chief Science Officer Dr. Bob Whitaker. Welcome back to PMA’s audio blog, “Ask Dr. Bob.” Today we’re continuing our series on risk assessment and risk management.

Bob, in several previous posts you have alluded to the value of recordkeeping, as well as training. What exactly do our listeners need to know about both these areas as they relate to risk assessment and risk management plans?

Bob Whitaker:
Well Julia, companies need to have a plan to store and catalog their food safety data, because this data can be vital to the success or failure of the company’s food safety program. Remember, in the event of a food safety incident involving your products, your food safety data will be your best means of demonstrating to regulators your adherence to your written food safety program, and it should be accessible and clear. Should the food safety event move to a legal setting, your data can be subpoenaed so you want it to be complete, accurate, and evaluated properly.

So what are some of the things to keep in mind as you consider data storage? First, make sure your data is collected and stored properly and securely. Put checks and balances in place to be sure the integrity of the data is maintained. Only your food safety professionals should be authorized to collect, verify and store food safety data. It’s wise to have written policies in place describing how to handle the data, who should read and verify if the data are complete and properly reviewed, and where the data are to be stored.

It is worth considering both short-term and long-term storage options for food safety data. Most food safety standards call for keeping data at least 2-3 years. You may also want to consider storing data in multiple locations to avoid losing data should a disaster compromise your facility.

Another of the key tools you have in implementing your risk-based food safety program is training. Training is an important aspect of any food safety program and an activity that will permeate any company that is truly integrating food safety into its culture. I have always found that employees generally want to do the right thing — they just need to be trained properly. Employees learn best when the training is made personal. Don’t just train them to do something, also explain why the task is important and why how it is done is important. If you are training on the importance of hand washing, explain why it is important: Talk about the bacteria that could be on your hands, and how these can make people sick. Talk about how those most likely to get sick, the old and the young, and relate that to the employee’s favorite grandparent or younger sister. It will have more impact and serve as a constant reminder to them.

Another important piece of training is to then empower employees to do their jobs once they are trained. Setting goals and communicating responsibilities related to food safety – and then following up to ensure the goals and responsibilities are being met – helps with empowerment. Remember, your company is only as food safe as your weakest link. You want that minimum wage employee working on the third shift, when you’re home in bed, to be as well trained as possible.

Julia:
Thank you, Bob. Training is such an important part of so many processes. PMA offers great food safety and other training resources and platforms to help our members and you can find more information on these at pma.com.

To our listeners, thank for joining us! When we come back next time, we’ll have the last post in our series on risk assessment and risk management, on the importance of continuous improvement.

Until then, goodbye for now.

Julia Stewart:
Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob.” PMA’s Chief Science Officer Dr. Bob Whitaker is with me today to continue discussing the importance of measuring your food safety program. We’ve been talking about verification as part of a series of posts about risk assessment and risk management.

Bob, in your previous post you discussed some of the tools we can use to verify food safety programs, but are there others?

Bob Whitaker:
Yeah, Julia. Another tool we can use to measure adherence to our food safety programs, and assess our risk management strategies, are food safety audits. As I’ve previously discussed, sometimes the food safety discussion in our industry is over-shadowed or somehow equated with discussions on what audits are best and how many we have to do. Remember, audits are only a tool; a snap shot in time.

Realistically, audits are like taking an exam when you know when the test will be scheduled, have all the questions already in hand, and you know what the answers need to be. But leaving aside the on-going discussions on food safety audits, in the context of verifying our food safety programs, food safety audits are a mechanism to demonstrate to yourself, your senior management, and your customers that you are following your food safety program – and that you can verify it through your audit that day. At their best, food safety audits are excellent training opportunities for employees, a chance to have an independent set of eyes critique your program, and a time when you can step back from all the other responsibilities and critically look at your food safety program and how it is being implemented. So an audit can be an important learning experience.

Just as we discussed in the last post about needing a plan of action for responding to microbial testing results, it is important to have a plan of action for audits. It is critical that once audits are performed, you assemble your food safety team and work together to develop corrective actions to address deficiencies uncovered during the audit. This is an important step in completing the audit; demonstrating to your team, senior management, customers, and possibly regulators that you have acted responsibly to address any food safety issues that might arise and were detected in your audits.

Remember an audit is not complete until the corrective actions have been developed and implemented. Preparing corrective actions is also an excellent training opportunity for your team. And be sure to document in writing all your corrective actions.

Julia:
Thank you, Bob. With all the talk about audit proliferation and audit fatigue, this helps put the usefulness and role of audits into perspective. Thanks very much to our listeners, please join us again next time!

Julia Stewart:
Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob.” PMA’s Chief Science Officer Dr. Bob Whitaker is with me today to continue discussing the steps of risk assessment and risk management.

Bob, in your previous post you mentioned the importance of being able to measure your risk management program. Can you give us some more details about this?

Bob Whitaker:
Sure Julia, it is important that you make your risk management program measurable to the extent possible. Simply put, you can’t manage what you can’t measure. For example, if you identify irrigation water sourced from a well on a farm as a risk factor should it become contaminated, then define your risk management practice in measurable terms. That means, for example, that you can have a check list that calls for weekly physical inspection of the well head, and monthly microbial testing for generic E. coli. These are measurable activities, they generate data, and that data can be used to verify you are following your risk assessment and management plan. More importantly, these data may also help you identify improvements you could make in your risk management program to help improve your food safety performance.

However, remember you cannot test your way to safety. You need to be realistic about the uses and value for testing in your operations and how it helps you manage risks. Understand that testing is only a tool. Without the proper risk management practices in place, testing is meaningless. We are faced with the need to test water, soil amendments, process environments, equipment surfaces, and even seeds. You need to look at these in relationship to your risk assessment, and determine whether testing these factors will help you manage the risk better, or if the tests will help verify the effectiveness of a process.

And, just as important as having a way to measure, is also to have a plan for responding to the results. Know what a positive test result means and how you will handle it before you get that positive result. Decision trees are great tools in situations like that. Also know who will interpret the data, and who will make the decision to ship or destroy products, to harvest or to walk by a field. These decisions can be painful because they can have bottom-line impact, so be prepared for that beforehand.

Julia:
Thank you, Bob. As always you have tough but constructive information for us. We’ll look forward to hearing more about the role of verification in risk assessment and management in the next post.

To our listeners, thanks very much for joining us today!

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