Hello,
I have a question regarding this FS Culture subject. First a little background to help you understand the issue. We have been given a minor NC on point 2.1.1.1 that states as follows:
"Although incipient efforts to establish food safety culture evaluations and improvement, the plan to implement has not been documented."
However, both the code and the guidance are kind of ambiguous when addressing the subject.
Our policy statement includes our commitment to establish and maintain a food safety culture, we have made conscious evaluation using various maturity models and tools (such as the questionnaires provided by Australia/NZ) with all employees and senior management; we have shown how we measure monthly improvement, discuss it and constantly update the objectives; we have submitted all our personal to general exams about food safety and their responsibilities to create individual improvement plans and discuss monthly on a one on one basis with all employees; and have shown our plan to develop and implement a reward program to engage employees on the improvement of the food safety culture.
Is this not enough evidence of a "plan to implement"? We have this only as part of our monthly meetings agendas but do not have a separate Food Safety Culture Program as most of the requirements are covered on our Management and Internal Policies Program and on our Capacitation Program. Does this mean that the Program we need to solve this NC is a Safety Culture Improvement Program?
Also, the next section of the code that addresses food safety culture (2.1.1.2) have mostly been long implemented as part of the system. My doubt here is about point (i) of the section. When it mentions "food safety objectives and performance measures" should I understand this as the measure of the performance of the food safety objectives or that "performance measures" are regarding personnel evaluations? I have the doubt because on most of the literature (Eg. Yiannas 2010 book, Debby Newslow book and most of Jaspersen articles and publications) they mention that employee performance evaluations should be, at least on great part, based on measurement of the accomplishment of the objectives that relates to their food safety responsibilities or about the food safety aspects related to their tasks or job descriptions.
I am really kind of stuck on everything related to the NC. The root cause may be the same NC (program not documented) but I don't know if this is something the certification body accepts. I also don't have previous experience on submitting "to do plan" as the CAPA to the certification body. I am sure that establishing a reward program and changing the performance evaluation won't be an easy task to implement in such a short time as this will have to go up to the board to get budget approval and HR will have to be involved.
Will appreciate any help you can provide.