16 replies to this topic

[NAPS]

Hi everyone,

How do you deal with non-compliant employees? We have a few employees who continue to "forget" and undermine policies set in place by the HACCP program, but due to their relationship with senior management, have made themselves indesposable. Any thoughts?

[Rizwan Ahmed]

Dear NAPS,

its a quite typical problem and i presume most of us face such situation in the organizations. these are difficult employees you are talking about with either less understanding/lack of knowledge and lack of committment. earlier's can be achieved by appropriate training and coaching and continous assessment.

for lack of committment you need to either motivate them by bringing in competetion amongst employees by going with Monthly Hygiene Award which will definitely help you in uplifting their motivation level or otherwise take the disciplinary action.

increasing motivation level is more appropriate and important than going for disciplinary action, but in some cases we have to be strict in order to keep things going in right direction.

bring this matter in your HACCP Team Meeting discussion and emphasize that this kind of staff overall have impact on the food safety and also lowers the morale of the people who are working with great committment , and come up with the policy with the ideas of other team members when (under what circumstances) to take the disciplinary action.

regards.

RIZ

[Anne Z]

Hi NAPS,

It's not easy, but let them see what will happend if the don't follow the rules. What will happen with the people that eat it?

Here all food is forbiden at the production area. However during an audit the auditor found a peanut. Finding food is not good, finding a peanut is even worse because of the allergeen risk. Of course the peanut didn't belong to anybody. I held a hygien training and showed everybody some pictures of swollen children who where allergic to peanuts. What would happen if by mistake there is a peanut somewhere. You get a lot of iiiieek but the pictures made my point: don't eat in the production room. I haven't found a peanuts since.

They have to understand the rule otherwise you will get the situation 'we have to where hairnets because ... said so' and not 'we have to where hairnets because hairs may fall into the product'.

Good luck with it.

Anne

[GMO]

Sooooo difficult. I employed someone recently who made a big fuss in a similar situation with staff members who were cozy with the management not following food safety law! He was sacked (took the company to tribunal and won.) Still, you can imagine how difficult it's been for him to get a job and I have to admit I had my reservations but am prepared to give him a go and see how it works out.

Anyway, that's the extreme but I remember something from my behavioural safety course where how people act is greatly related to the consequences. You can just as easily apply this to food safety. So your team are already aware that the consequences of having peanuts in the factory is potentially death of a consumer but that's not worked? Why? Do they not believe it? Do they not care? Do they think "if NAPS doesn't know it doesn't matter?"

Well there are a couple of approaches I'd use for this. One is that we need to bring it home to them how common allergies are and how serious they are. Is there anyone in your workplace with a severe food allergy or has a relative who has one? It might be worth getting them to talk about it in your training.

Ultimately though, making the consequences hit them is vital so it does need to be linked to disciplinary and there has to be management commitment for that. If you can't get management commitment to discipline these people for something that serious (and I would say it's gross misconduct) then you have no chance of demonstrating due diligence. Frankly I know management commitment is a struggle everywhere but this is serious if you can't get management support for something like this. It's a bit different to the occasional lax attitude. I could see myself getting into the same situation as my new employee and would rather leave for somewhere which has a better attitude to food safety than bang my head against a brick wall until I break or get pushed for willful brick wall damage!

[Zeeshan]

Hi everyone,

How do you deal with non-compliant employees? We have a few employees who continue to "forget" and undermine policies set in place by the HACCP program, but due to their relationship with senior management, have made themselves indesposable. Any thoughts?

Some good points presented by the members.

I have to add just a few more.

Dear NAPS,

1- Have you ever forwarded any report of these non-complaint employees to your senior management? Or you have assumed that since these employees have relationship with senior management the later would not consider the reports and would not take any action?

2- If your senior managers are not showing commitment to hygiene rules and procedures, would there be a provision to report to their seniors/Top Management? (Slightly off topic: IMO, if managers and personnel are not authorized to report critical non-compliance to any authority, even by passing their seniors, Top Management is deemed not committed to ensure quality and food safety).

Regards:
M.Zeeshan

[GMO]

Good point Zeeshan. All too often we assume because we see no action that the people at the top know what's going on. I work in a factory senior team and it drives me doolally when I hear from someone "well it's been like this for ages and I told my boss, I assumed he'd told you" which of course he hadn't. When you do hear things like that though it's a great opportunity to show some senior management commitment and resolve the ongoing gripe quickly (as well as giving the middle manager a gentle poke in the ribs for not escallating the issue...)

[NAPS]

Thanks for the feedback guys,

Let me give you guys a little background on what were working on over here. Were a fresh produce wholesaler in the middle of getting our HACCP certification. For the most part, I've finished the HACCP document and have now shifted my focus towards training and preparing the facility for an audit. We do no cutting and limited repacking and reworking services.

Unfortunately the entire situation is a little more complicated than a simple employee management relationship. We are family owned and operated and my "non compliant employee" is my own grandmother! Shes very old school when it comes to food safety and I'm really struggling to convey the salient points. Because we don't do any cutting and contact with the food is limited, many people are resistant to the changes we are making. I'll give a different approach to training a try and let you guys know how it goes.

Any other suggestions? Would anyone want to run through my HACCP document to make sure I have all my points covered? This is my first foray into food safety and at times I feel like I'm in over my head.

Again, thanks for all the feedback

Kyle

[Charles.C]

Dear NAPS / Kyle,

Regarding the HACCP document I’m sure you will get plenty of feedback if you post it here! The degree of usefulness may depend on what you are planning to do with it. Is this to be submitted to the CFIA or ?

As it happens, I hv recently been studying the HACCP / ISO 22000 literature scene with respect to minimally processed vegetables for the purposes of (much delayed) responding to a post by FSSM about 1-2 months back. My own background is the fish business which was one of the pioneers in the industrial implementation of this technique and for which considerable IT generic info. is available. In striking contrast the fresh produce business seems to be distinctly “arbitrary” as far as I can see, perhaps partly unavoidable due to the enormous variations in global crop practices and subsequent processing technologies available. I am wondering if you are a member of an equivalent association to the IFPA of USA who offer model programs of the HACCP type although “HACCP-based” is perhaps a more appropriate terminology these days as far as the microbiological aspects are concerned.

Regarding the “employee” difficulty, I hv also worked in family run enterprises and, from a neutral observer's aspect, this kind of internal problem can get really tricky even without variables like age added in. My guess is that possible solutions may depend on the exact structure / situation, eg size of business, product sensitivity, specific problem, personalities involved etc. The previous comments were fine IMO but may not be so readily implementable in yr case ??

Rgds / Charles.C

[Tony-C]

my "non compliant employee" is my own grandmother!

Kyle

Hi Kyle

Have you thought of suggesting retirement?

Regards,

Tony

[GMO]

Y'ouch! Oh this is going to be difficult...

Ok, there are some things you could try, however, this is always going to be an uphill battle. I think you need to combine the training with bits of "this is where the old ways work, and this is where they don't". So, for example, I bet she will be rigorous on handwashing so there's something you may not have a battle with. However, if I think of my Mum, she would think nothing of cooking some meat, leaving it out all day, putting it in the fridge and then serving it cold the next day!

So, how do you convince her where the old ways are not the best? One way is to use examples of where these have gone wrong from the press and led to major recalls / food incidents. May not convince her though. If you can, what I'd love to do is take her into another food processing establishment (preferably one which makes a product she respects) to show her how food hygiene rules are implemented there so she doesn't think that what you're suggesting is strange! If you have a retail establishment with good hygiene standards it may be worth also taking her there (although they're few and far between around where I live, there are some who will have separate staff for serving raw and cooked from counters, colour coding, hair coverings, tongs to avoid hand contact etc.)

Ultimately though it could be difficult, not because of her age (I've had 60+ employees get "on message" before) but because of the power situation in your relationship.

It may also be worth posting your HACCP here or posting some info about how you intend to implement it so we could give you some specific help? Dammit I'm on maternity leave and bored right now so get me before the baby comes!

[NAPS]

Charles,

Do you have a link to any articles related to minimally processed fresh produce? This is something I have struggled mightily with, as almost all literature I've been able to dig up has been related to heavily processed produce or meat, which have more strict regulations. Because of this I'm having trouble establishing which regulations are "arbitrary" and which regulations I need to follow to a T.


I'm exactly sure who the IFPA is, but thus far we've been working loosely with a food safety auditor who has been largely unhelpful. We're located on the west coast and she is based out of Toronto and is terrible at responding to emails.


I've attached the bulk of my HACCP document, just the system/operational/environmental controls without any of the supporting docs/logs. Some of the formatting is off from converting it from .docx to .doc but for the most part, it is complete. There is still tweaking to do as we work through the implementation stages of the program. I have many of you to thank for it, this site has been a tremendous resource for me. Feel free to use any of the material in the development of your systems.


If any of you are able to wade through the 100+ pages and give me any feedback, positive or critical, please do. As I said earlier, this is my first attempt at any sort of program related to food safety.


And Tony, there Isn't a day that goes by that we pray she decides to retire.


Kyle

Attached Files

•  HACCP PROGRAM.doc   410KB   87 downloads

[NAPS]

I'm exactly sure who the IFPA is, but thus far we've been working loosely with a food safety auditor who has been largely unhelpful. We're located on the west coast and she is based out of Toronto and is terrible at responding to emails.

Is there no edit function?

I'm NOT exactly sure who the IFPA is...

[GMO]

Just had a quick look and if I'm critical, I don't get a totally clear idea of the product from the description. Is it ready to eat? Ready to cook? Only supplied as "dirty" veg or cleaned?

I'd also specify the likely consumer more clearly and ideally include some of the other staff in the HACCP team, even in a minimal or informal capacity.

Also I'd be more specific with your hazards, use the words "presence of..." "introduction (or contamination) with..." "growth of..." or "survival of..." as the starting of your sentence as that really hones in on what the risk is and also specify what each hazard is.

For example, your chemical hazard in storage could be "introduction of cleaning chemicals to the produce due to poor cleaning chemical storage and handling" for example.

I have to admit I'm no produce expert though and I'm sure there are people on the board who will be able to give you better advice specific to your industry but I'd think from recent incidents presence of Salmonellae and E. Coli from poor irrigation should be considered as well as presence of pesticide residue.

The vast majority of it appears to be focussing on PRPs which for your industry is probably the right way to go. I can't really see any verification / validation though?

As for converting this into something for the shop floor; there will be key PRPs that each person will need to know. I'd put this into some kind of GMP training programme (I think Simon started a topic recently on how to make these effective.) I'd also expect to have to tell people again and again what it's for and why!

[NAPS]

Majority of the product is raw produce that you would buy at the grocery store; apples, lettuce, tomatoes etc. It is supplied to retail distributors, food service establishments, restaurants, cruise ships, hotels, private functions, other wholesalers. So basically anyone who eats, prepares, sells, processes or just wants to have a good old fashion food fight. The scope of our customers is extremely vast, is identifying them all exclusively necessary?


As far as a HACCP team goes, I'm the only one working on it in any capacity right now.

The description is vague in the Hazard Analysis, but the linked documentation covers each hazard in further depth. I just used the Hazard Analysis as a tool to identify potential hazards throughout the warehouse and process steps.

[GMO]

I don't think you have to identify each consumer, however, I would put in something like "likely consumer and intended use: Produce possible to be consumed by all consumers older than weaning age after washing process. Produce may be eaten raw or cooked. Consumers may include infants, pregnant women, the eldery and other immunocompromised groups. Storage advised to be refrigerated between 3 and 5 degrees C (if that's true!) and consumed within the best before date."

I'd also put in a section about potential misuse by the consumer including, failure to wash produce, failure to refrigerate, consumption after best before date etc...

I think it is important to put the specific hazards in at the hazard analysis stage because otherwise you may misidentify the controls you need. For example, you will need a different control mechanism for chemical contamination due to pesticides vs. chemical contamination due to cleaning chemicals for example. Also I'd put in some kind of likelihood / severity matrix to decide which are significant.

I'm sure I'm preaching to the converted here but it's really difficult to do HACCP alone and unless you were a sole trader, I really wouldn't recommend it. Even if your colleagues know nothing about HACCP, they could help you decide which hazards are significant (or not) because they will definitely know how often some of them occur. For example, you may decide finding stones in root vegetables is a hazard. You could then ask the team who process the vegetables how often this happens and what size of stones they find.

Edited by GMO, 01 May 2010 - 03:22 AM.

[Charles.C]

Dear NAPS,

Thks for posting yr haccp plan.

You neglected to answer my query as to who the receiver of yr document will be ? The introductory sections (“Scope” in usual parlance) do not state for what certification is involved. I presume there is a specific objective. One immediate relevance is that there may be regulatory CCPs involved in the HACCP plan.

From a quick look, The document you posted seems to be a combination of a (modified) IFSQN forum packaging HACCP plan layout (a la Simon) plus (I'm guessing) a layout / set of prerequisite procedures very heavily borrowed from the Canadian (Ontario) Advantage manual (ie., all the “O” procedures, and why not ?, it’s an impressive (free) product IMO and presumably oriented to yr specific situation). I noticed some cross-references within the PRP linked to “standards”, I presume these are also Canadian standards of some kind.

I deduce these items are all RTE (ready-to-eat) which means they are high risk from a HACCP point of view despite no process cooking step being involved but, equally, no cooking prior to consumption. Not easy to analyse further since you don’t mention what products are involved.(scope?)

I appreciate yr posted plan is a work in progress. The basic layout is usable IMO however the crunch often comes with respect to the validation of the assumptions stated in yr hazard plan. For example, some people for this product would set the material receiving aspect as a CCP although this is definitely optional depending on yr PRP structure. Various opinions do not set the storage temperature as a CCP as far as I know (some also set the temp. of the whole operation as a CCP!). AFAIK, there are no regulatory CCPs involved for USA and Canada for this product category so it comes back to yr validation again.

Obviously cannot comment on the “Procedures” aspect since not posted here however the auditable correlation / documentation between these and what is actually happening on the factory floor is often the most critical (practical) part IMEX.

I suspect you are, technically, essentially a team of 1. I sympathise, my first plan was done on an identical basis.

The repeated use of the word "generic" in yr HACCP plan / hazard analysis would IMO be unacceptable to many (most?) official bodies but perhaps you are aware of yr intended recipient's specific requirements. The fact is that there is no mention of any specific microbiological hazards anywhere in the analysis, I doubt that this is acceptable to most HACCP auditors.

IFPA is the International Fresh Cut Produce Asociation although now renamed I think.

http://www.unitedfresh.org/

It consists of many growers / consultant bodies and is regarded as a premier source of information on fresh produce. I believe there is a Canadian adjoint or something similar. This group in combination with the (I think) USDA/USFDA hv published (freely downloadable) guidelines for the whole farm-fork chain for certain specific vegetables. However the main core of their research is available to members only.

Regarding industry references I suggest you initially head to this forum thread/post which contains the start of my ongoing literature investigation. You will shortly see some recent fundamental links, eg #29. Please revert if any queries on the links (I expect that yr specific process(es) will match some but not all of the sub-steps discussed)

http://www.ifsqn.com...dpost__p__34610

Rgds / Charles.C

[NAPS]

Thanks GMO and Charles,

Exactly what I needed to hear. I will continue to adjust the program and work towards further identifying the generic hazards in the plan.