What's New Unreplied Topics Membership About Us Contact Us Privacy Policy
[Ad]

GMP Implementation

Started by , May 05 2023 03:38 PM
9 Replies

Good Morning All,

          I am new to ifsqn.com so i will give a little background on my situation. I am a Quality Assurance Supervisor in a beef and pork processing facility. I have been tasked with creating and implementing an SQF plan in our already USDA FSIS inspected plant. I have created new GMPs specific to areas (slaughter employee, processing employee, non-processing employee, maintenance employee) but i am having a hard time getting my upper management team to understand that lack of GMP compliance should be recorded for validation and verification purposes. They want this process to only be verbal as to not anger our employees, how do I make them understand that documentation of lack of GMP compliance  is very important to insure the SQF system is working.

Share this Topic
Topics you might be interested in
Implementation of HACCP in the school canteen FSSC 22000 Implementation but have non-food Products SQF Implementation Package offered by IFSQN SQF Level 2 implementation for seafood wholesaler and distributor Suggestions for the implementation of new additional requirement in FSSC 22000 V6
[Ad]
There's a great and simple diagram near the front of the SQF Code manual and the wording is as follows...

SAY WHAT YOU DO
DO WHAT YOU SAY
PROVE IT.

It is the prove it part which means DOCUMENTATION.

Verbal don't go .
1 Like1 Thank

Upper management needs to understand the importance of implementing SQF.  SQF is not just a paper trail to sell to big accounts.  Implementing SQF will greatly help with preventing food safety disasters that could close the company.  

 

I think if you really want to keep this job, you have to get upper management AND the employees to get on board with food safety, GMP, and all the procedures.  In my days on the floor, the biggest challenges were to get people onboard.  Once everyone gets it, implementing food safety principles and procedures become very easy.

1 Like1 Thank

Can I ask what you're meaning when you say you want to document the GMP non-compliance?  When you state upper management isn't wanting to anger the employees, it makes me think you're documenting via a formal warning or write-up of some kind.

 

I don't see a problem with verbal corrections being a prequel to more formal actions (of course, based on the type of violation), and those verbal corrections can be recorded separately for trending.  Once trended over a week/month/quarter (depending on how many), you can approach management to show them what type of violations are occurring most, and determine if retraining is appropriate or disciplinary actions should be considered (e.g. for purposeful non-compliance).

1 Like1 Thank

jfrey123- My upper management team does not even want to document verbal warnings, they think it will be to much work to document verbal warnings and they think only department supervisors should verbally correct their employees if they fail to follow gmps, with no documentation at all.

Does your facility have any documented policy in place regarding the reprimanding of employees? GMP or otherwise?

1 Like1 Thank

Does your facility have any documented policy in place regarding the reprimanding of employees? GMP or otherwise?

we have no policy in place and my upper management team is so fearful of angering people they do not want to implement any policy pertaining to this.

Sounds like a management strategy issue, fundamentally. It's a simple fact of life that you will have staff disputes when running a company, I can 100% guarantee that there will be a scenario in the future that will require your management team to discipline an employee. It's very important to have a documented system in place ahead of time for how to handle disciplinary action. It's a benefit to staff too, because they know what to expect if they make mistakes or cause trouble. It bleeds into HR, but these facts should be laid out in a documented employee manual.

 

Your team needs to ask itself, who is managing who? Are the staff making the rules, or is the management team? Here's a rational perspective you may be able to present: Your management team fears disciplining employees because they may get angry which may lead to a downturn in production or quality due to their disgruntlement. However, without control over your staff, I can guarantee you will run into production and quality issues sooner or later. It simply makes more sense to reign your staff in at this point. This of course says nothing of SQF compliance, which you would not achieve without policies related to employee training and corrective actions. It's an issue that needs to be confronted if you plan to become SQF certified.

1 Like

jfrey123- My upper management team does not even want to document verbal warnings, they think it will be to much work to document verbal warnings and they think only department supervisors should verbally correct their employees if they fail to follow gmps, with no documentation at all.

 

Yeah, I don't like their response to you.  Recording when these verbal warnings occur doesn't have to be super intensive.  You could keep a record of them via Excel (date/time, employee name, observed violation) and just ask other managers/supervisors to email you or tell you when they occur.  I'd take the extra step to choose "categories" to assign each one of them on the spreadsheet for trending these corrections in management review meetings later.  If they learn they've got a large number of employees deciding to skip handwashing, they should want to know about it and correct it, because eventually your onsite USDA inspector is going to catch it.

 

If it helps boost your case, you can remind them that documentation isn't just required by SQF code, but "corrections" and "corrective actions" for events like a GMP violation is a requirement of US law.

 

FSMA Final Rule for Preventive Controls for Human Food | FDA

eCFR :: 21 CFR Part 117 -- Current Good Manufacturing Practice, Hazard Analysis, and Risk–Based Preventive Controls for Human Food

Without a documentation system for the evaluation of compliance you will run into HR-compounded safety and quality problems when someone fails terribly and you have no grounds to terminate, reprimand, or deny pay raises etc. for their previous recorded negligence or refusal/failure to comply with company safety or quality policy.

 

If the owner/management can't see this, get out before it gets worse.

 

By making sure everyone knows what is expected of them and complies with safety and quality programs you are protecting the consumer and the company.


Similar Discussion Topics
Implementation of HACCP in the school canteen FSSC 22000 Implementation but have non-food Products SQF Implementation Package offered by IFSQN SQF Level 2 implementation for seafood wholesaler and distributor Suggestions for the implementation of new additional requirement in FSSC 22000 V6 HACCP implementation IFSQN BRCGS Food Safety Management System Implementation Workbook IFSQN - SQF Implementation Package SQF Storage & Distribution Implementation Package FSVP Development and Implementation Cost