The Most Important Food Safety Document

As a consultant, I am often asked “what is the most important document I need to have?” Some will say “they are all important”, some will say “HACCP, is the most important”. I could argue that the Food Safety Plan (FSP) is now your most important document for any Food Safety Modernization Act (FSMA) certification. The FSP or in some cases “The Human Rule” encompasses everything about the HACCP, and it also includes preventive controls approach to controlling hazards.

Let’s take a look at some of the things that the FSP not only takes into consideration but differ in comparison to a HACCP plan:

• FSP takes into consideration the opportunity for economically motivated adulteration. Better defined as your Food Defense Plan and your Food Fraud Plan.
• Records must be maintained for process controls in HACCP plans, but with FSPs, records should be kept for all preventive controls.
• HACCP plans do not require monitoring, but FSPs do. Specifically, monitoring must be done after any hazard requiring a preventive control has been identified.
• As in HACCP, you will need to create an FSP team. I always advise my clients to have different team members for different plans. By doing do, you are keeping your team members knowledgeable to your certification standards. I would also rotate your teams (using a mixture of hourly -80% and salary – 20% employees), so that your team are not only in a constant training mode, but you provide all team members with the opportunity to be leaders.
• Your Environmental Monitoring Program, along with your Environmental Risk Assessment, must also be included in your FSP.
• Under your FSP, a recall plan must be prepared for each product for which a hazard requiring a preventive control has been identified.

The identification and verification of your hazards and how you monitor them are the keys to a robust food safety plan. The plans success always must be a “Substance over form” Your food safety plan is not about checking a box and moving on. Your food safety plan is a living, breathing document, that is always changing and always expanding.

It is important for senior leadership and team members understand how their behavior and activities contribute to the safety of food and how they can decrease the risk of foodborne illness. Your FSP is a written plan that shows what your business does to ensure that the food it sells, or the direct contact packaging is safe for people. The FSP is an important tool to help businesses handle, process or sell potentially hazardous foods. The FSP and HACCP can be said to be interrelated. In the FSMA world one cannot exist without the other. As you can see from the above bullet points, and roadmap your FSP needs to not only include to a large detail everything in HACCP, but have the flexibility and understanding to far outreach the HACCP plan design. So why can’t your FSP be your most important document?

About the Author:

William McCann
Senior SQF Practitioner for Paige Packaging, Elmwood Park NJ.

“I was offered a chance to come in, shake things up, create something." – William McCann 2016

William has spent 15 years in the field of Quality and Safe Quality Food. He is certified in HACCP and SQF for Packaging. He is an accomplished Lean Six Sigma Black Belt, having been certified at Kent State University in 2008. William holds an under graduate degree in Business from Fairleigh Dickinson University. Currently William leads Paige Packaging efforts in maintaining the high standards in SQF – Quality, supporting the team and leading the efforts in becoming the first corrugated facility in the New York Metro area in achieving the highest standard in SQF edition 8.0.