HACCP implementation in the United States
5.3 Implementation challenges and solutions
less than $500,000 per year. At the business and plant level, no full-time people were added. Instead, responsibilities for implementation were added to existing positions. HACCP was seen as a normal part of doing business. Money was allocated on an as-needed basis to correct facility and equipment problems that were identified during hazard analysis, HACCP, or GMP implementation. Over the last ten years Cargill has spent millions of dollars in redesigning/upgrading facilities. No formal process has been established to track spending, because quite often expenditures to improve a process result in production benefits as well as food safety benefits.
Actually, standardizing and implementing HACCP prerequisite systems like GMPs is more difficult than HACCP since GMPs cover the whole facility environment, not just specific points in the process. The time required to implement GMP systems completely can be a year or more. The main lesson here is to focus on the basics first. Do not try to do too much, too fast.
5.3.3 Challenge 3 – employee involvement
Initially, the first HACCPs were written entirely by the plant Food Safety Committee with little or no input from hourly employees. Because hourly employees were not actively involved from the start, they did not always buy into the plan as it was written and quite often they had a better or easier method for monitoring CCPs than that written in the plan. Eventually plant committees learned that writing and implementing HACCP programs worked best when HACCP teams were created at the department level with active input from all employees, especially line operators who became the people responsible for monitoring CCPs. The lesson here is for everyone to remember that ‘managers do not make safe food, line workers make safe food’. Line workers must be involved during HACCP development, especially in the area of process flow chart reviews and writing procedures for monitoring CCPs.
5.3.4 Challenge 4 – communication
Active communication within a business or plant takes a great deal of effort, and the same is true for HACCP implementation. In large plants (>1,000 employees), it was a constant struggle to keep everyone informed and to capture good ideas and spread them across the plant. Communication between plants was also, at times, difficult. Sometimes different locations within the business were working on the same problems or recreating the same solutions.
Although the business food safety team helped to spread ideas across locations, no formalized process was in place.
Eventually, more formalized communication systems were started. At the plant level, the Food Safety Committee met weekly to keep everyone on the same page. Plant newsletters and other awareness campaigns were also started.
At the business level, plant food safety coordinators established weekly conference calls to discuss progress and exchange ideas. At the corporate level, a success story newsletter was established to communicate problems, solutions, and other successes across all businesses world-wide.
5.3.5 Challenge 5 – training
Training is the link between writing a good HACCP and successful implementation. Without active training systems, HACCP will fail. The greatest difficulty was experienced by locations with the highest number of employees with the highest turnover rate. Imagine trying to train 2,000 employees, who
speak four different languages, on the basics of food safety while dealing with a 20% turnover rate. Many locations learned that initial training was, in fact, easier than training employees on an ongoing basis.
To deal with the training challenge, all locations incorporated food safety in their newly hired employee orientation training. For ongoing training, many locations created awareness tools such as setting up display cases in hallways containing food safety information or objects found in food. Informational training brochures for safe food handling at home were created. In large plants, food safety topics were added as part of monthly training meetings, conducted by department supervisors with their employees. At the corporate level, Cargill developed and conducted a monthly seminar to train managers within the company. This seminar was eventually complemented by a self-paced CD-ROM directed to production supervisors.
Businesses learned an important lesson while coping with the challenges of training. First, do not just tell employees what to do, tell them why they should do it. Describe why food safety is important to employees and their families.
Make it personal! In other words, cover what is in it for them personally; do not just tell them it is part of their job. Most employees do care about the company they work for, but they care most about how food safety affects them personally.
Second, describe why their particular job is important and how their efforts will make a difference. Make sure that each person understands that what they do makes a difference. If these training challenges can be conquered, employee buy-in will be strong.
5.3.6 Challenge 6 – corrective action
Conducting a hazard analysis and identifying CCPs can be difficult, but the hardest part of HACCP is writing corrective action procedures that are meaningful, easy to understand, and complete. It is very difficult to write a procedure that applies to all situations. A standard was established that required corrective actions to cover three questions:
1. What will you do with the product?
2. What will you do to bring the process back in control?
3. What will you do to prevent a reccurrence?
Getting line operators involved to ensure that corrective actions were understandable was also a key factor for overcoming this challenge.
5.3.7 Challenge 7 – production ownership
In the beginning, some locations still saw HACCP as another tool for Quality Assurance to use to ensure quality and wanted to make the QA Department responsible for monitoring CCPs. This, of course, is against the premise of a good HACCP system. Cargill’s standard is that CCPs are to be monitored by production people producing the food and that QA staff, along with production
managers, fill the verification role. The QA Department does not produce safe food, line workers do. Once production understood and believed this concept, the true effectiveness for HACCP to control hazards was realized.
5.3.8 Challenge 8 – documentation
One area of HACCP that usually puts a company to the task is documentation.
Even a well-run company usually finds that documentation needs generally exceed what is normally done. The challenge of documentation is a question of how it should be integrated with other documentation being generated during production. Should separate HACCP forms be created or should HACCP information be added to existing forms? Most locations chose to add HACCP documentation to existing forms to reduce the amount of extra paperwork. This option also takes advantage of existing document handling systems, which turned out to be a good choice. However, many existing documents were not structured properly for HACCP needs. Document structure was not uniform and sometimes pieces of HACCP information, such as time of entry or signature lines, were left out. Document use was also not uniform. People often forgot to sign documents, and corrective action reports were incomplete. Auditing helped to correct these issues, along with policies regarding document structure and use.