You've worked hard with your team to build the ideal food safety plan, taking expert advice and regulatory considerations into account to ensure the highest possible quality. But food safety isn’t fixed; over time, research, circumstances, and standards change. Particularly during periods of regulatory uncertainty, food safety rules and best practices inevitably evolve.
If you aren't staying on top of your food safety practices, you could become complacent and risk falling out of compliance. This complacency can lead to outdated preventive controls, gaps in employee training, and ineffective monitoring procedures, among other issues. Avoiding these missteps and remaining compliant requires an understanding of the dangers of apathy and a commitment to continuous improvement through proactive food safety planning.
Your food safety plan should be a living document, continually updated and adjusted with regular analysis, validation, and management review in accordance with regulatory and certification requirements. Approaching your food safety plan with a "set it and forget it" mentality can lead to:
Recalls
Non-compliance
Danger to consumers
Legal actions
Regulatory penalties
As the regulatory landscape continues to shift, periodically revisiting your food safety plan and reviewing your processes will be essential to getting ahead of compliance breaches.
Regularly updating your food safety plan isn’t just a best practice for staying on top of the latest regulations; the FDA also requires it. According to the Food Safety Modernization Act (FSMA), food safety plans must be regularly reassessed every three years.
The FDA also requires that portions of your food safety plan be reanalyzed under certain circumstances, such as when a preventive control is found to be ineffective during an audit or following a food safety incident.
But even if your food safety plan doesn’t require special reevaluation, food safety regulations can change significantly over three years. With the unpredictability of food safety policies, waiting the required reevaluation period before reassessing your plan could leave your operation vulnerable to regulatory noncompliance regardless. Regularly evaluating your plan's relevance can help you avoid making major changes when the FDA's required assessment interval comes around.
Reviewing your food safety plan with your PCQI or a third-party expert allows you to ask important questions and identify areas that may not adhere to recent updates. These insights can help you improve your policies to keep pace with today's food safety guidelines, and records of these reviews must be retained as part of food safety systems.
Aside from your regularly scheduled food safety plan review, consider implementing additional circumstantial reviews for instances such as:
Introducing new ingredients
Formula, equipment, supplier, and process changes
Experiencing a food safety incident
The release of new food safety regulations
Shift in targeted consumers (children, infants, etc.)
But knowing when to update your food safety plan is only half the battle.
From staying ahead of the latest regulatory updates to taking initiative on your own internal audits, there are several ways to maintain the relevancy and effectiveness of your food safety plan.
Your greatest defense against stagnation is a commitment to regulatory awareness. As food safety policies evolve, you should consider how those changes impact your current practices. For example, your current traceability protocols might not align with the latest FSMA updates. In this case, you would need to review the updated guidelines carefully to determine necessary changes to your food safety plan to comply by the FDA’s deadline.
The responsibility of staying informed ultimately relies on leadership, who must then communicate potential upcoming changes to frontline employees. That said, encouraging frontline workers to stay informed on their own can reinforce a strong food safety culture and help your organization stay ahead. Keeping up with the current state of food safety regulations can help your team understand the changes to their workflows and why they matter.
Consider subscribing to food safety publications, checking FDA updates, and signing up for food safety newsletters that regularly provide updates on the latest news to stay on the cutting edge of food safety regulations.
Finding out that a preventive control is ineffective during a third-party audit — or even worse, after a food safety incident — is too late. Your preventive controls must be carefully and regularly monitored to avoid the potential consequences of obsolete practices.
Revalidation and analysis of preventive controls should be a key component of your food safety plan. At regular intervals, your team should check whether your controls are performing as expected and meeting today's standards. This regular reevaluation can help you identify potentially disqualifying factors such as:
Improper employee hygiene
Lack of accountability
Training gaps
Operational or equipment issues
Supplier changes
Process modifications
Production volume changes
New scientific information
Checking your preventive controls can help you verify their validity or make the changes necessary to maintain their effectiveness.
Your PCQI plays a key role in the creation, maintenance, and execution of your food safety plan. But if their food safety knowledge isn’t up to date, their ability to prevent complacency may be severely diminished.
For example, many PCQIs are now using predictive analytics to enhance proactive decision-making using food safety data. Implementing this modern practice into your food safety plan can help your team react before hazards occur, better anticipate potential risks, and improve your documentation process.
While your PCQI may be self-driven and seek out the latest food safety knowledge, it's your duty to help them in the same way they help you. Signing your PCQI up for relevant training, like PCQI 2.0, can help them learn new strategies, regulations, and discoveries, which they can use to keep your food safety plan fresh.
Waiting until a third-party audit to test your food safety plan's effectiveness is a recipe for non-compliance — potentially leading to delays in production or even regulatory consequences like fines, recalls, and more. Conducting regular, randomized internal food safety audits can ensure and reaffirm that your food safety strategy is working as intended. These internal audits must be risk-based, documented, and include corrective actions and follow-up verification.
These reviews provide a snapshot of how effective your current practices are — allowing you to identify inadequate controls or internal audit gaps that may have slipped through the cracks. And while your internal food safety team can perform these audits, partnering with third-party experts can provide support and a new perspective.
Understanding your food safety plan's recency can help you avoid common issues caused by outdated preventive controls. But revitalizing your food safety plan alone can seem daunting. For additional support and unbiased insight, consider working with a specialized expert from AIB International to assess and improve your current protocols.
These experts can help brainstorm solutions to outdated strategies and educate your team on the latest in food safety regulations. So don't hesitate; stay ahead, minimize stagnation, and maximize your success with outside help designed to drive food safety compliance.