How to Measure Food Safety Culture for the FDA

The FDA is digging in more into company food safety plans and hazard analysis practices. In fact, a written hazard analysis is a required part of your food safety plan, which must be prepared or overseen by one or more preventive controls qualified individuals. Continuously improving your food safety plan relies on your ability to accurately measure food safety culture at your plant.

In our recent webinar, Elevating Food Safety: Tackling Hazards for a Stronger Food Safety Culture, Sam Davidson, Food Safety Director at TAG, explains how to measure food safety culture and perform hazard analysis efficiently and thoroughly enough to meet FDA requirements.

In this blog, we’ll provide a high-level overview of hazard analysis in food safety and how to identify — and document — what your biggest hazards are to meet FDA standards.

Before we dive into implementation, we need to understand what’s being asked of us. What is hazard analysis in food safety as the FDA defines it, and what constitutes sufficient preventative controls for preventing hazards?

FDA Definitions for Hazard Analysis and Preventative Controls

Regulatory agencies provide a plethora of potential hazards, some of which may not even be applicable to your manufacturing environment. This is why it’s essential to set up a Food Safety team that includes members outside of your FSQA group to help determine which processes might introduce a risk of contamination. Your Food Safety team needs to be able to dive into the details of your manufacturing processes and source materials to quantify your hazards, develop effective controls, communicate best practices to employees, and document everything for future audits.

Elements of a Strong Food Safety Team

Establishing a strong food safety culture requires leadership to make it a priority, as well as allowing teams to spend time on training. A commitment from leadership entails a statement representing corporate policy and the resources to implement these policies, including time, money, people, equipment, and training.

In order to funnel decisions down the pipeline, it’s critical for supervisors to attend meetings so they can share critical information from the meetings with employees on the factory floor. Supervisors need support from leadership to attend, as well as to spend time training employees.

Documenting when supervisors are in attendance for Food Safety team meetings and sharing meeting information with employees is an ace in the hole to demonstrate to the FDA that you are continuously improving your food safety plan and hazard analysis. In general, the more you document your good practices, the more likely you’ll have approval from regulators when it comes time for your audit.

I don't think I can say 'document' enough. Document, document, document.
Sam Davidson, Food Safety Director, The Acheson Group

Sam Davidson, Food Safety Director, The Acheson Group

What do I do with all the lists of hazards from regulatory agencies?

Now that you’ve assembled your Food Safety team, you need to figure out what to do with the numerous lists of hazards from regulatory agencies.

A good place to start is by identifying hazards that warrant control by performing a risk assessment that organizes all risks by their likelihood of occurrence and potential severity. A risk assessment table provides a good way to visualize what your biggest hazards are, share this information in an easy-to-understand, at-a-glance format, and of course, bolster your documentation for regulatory agencies.

Once you’ve analyzed where your biggest risks are, you can start plugging in this information to hazard analysis. The FDA provides a sample of a hazard analysis worksheet (below), and your risk assessment table will help you to adequately justify your decisions for whether a potential hazard is indeed a risk for your organization.

Specificity of food safety hazards is key.

One of the common mistakes manufacturers make is generalizing too much on types of hazards and their manifestation.

It is absolutely essential that both the scope or nature of the hazard — and the source or cause of the hazard — be clearly defined in order to help the food safety team determine appropriate food control measures. The food supply chain is extremely complicated, and you need to know where possible hazards may be emerging. Understand the location from where your ingredients are sourced and location-specific risks. Here are some other examples of overgeneralization on types of hazards and their manifestations:

The type of pathogen needs to identify the specific organization, where known, e.g. resistant forms (spores), toxin producers, and vegetative (non-spore formers).
We need to know how the hazard “got there,” its manifestation, e.g. presence, contamination, survival, or growth.
Chemical and physical hazards are considered in a lot less detail than microbiological.

How to engrain a new set of food safety beliefs into our company culture that translates into measurable reductions of accidents, rework, and recalls

How do we quantify food safety culture?

The next step is actually quantifying food safety culture. Our free webinar, Elevating Food Safety: Tackling Hazards for a Stronger Food Safety Culture, shares how the experts at TAG help food manufacturers quantify their food safety culture. The assessment that TAG uses, as seen below, is just one of many helpful free tools you’ll learn about during the webinar.