Food safety hazards, the human element

 November 2014

 

When we look at the definitions and methodology of the HACCP System, we will, eventually understand that there are three basic types of hazards: biological, chemical and physical.

When implementing a HACCP System, prerequisite programs (GMPs) must already be in place and will be used by the HACCP System to “prevent, eliminate or reduce hazards to an acceptable level”. I’m borrowing this definition from the HACCP System and applying it to prerequisite programs.

Anyone responsible for the development and implementation of a HACCP System will identify specific hazards from the three available types (biological, chemical and physical) and will perform a risk analysis based on the severity and likelihood of the hazards to determine how significant they are. This process will be fundamental when identifying critical control points or preventive controls (FSMA).

What we are missing is a type of hazard that, by nature, may always be considered “Significant”, and this hazard is the “human element”.

For example, by looking at current statistics of recalls, the number one reason for recalls is allergen control. Whenever we have allergens in our facility/process, they show up in our HACCP Program as chemical hazards.

However, by using a “root cause analysis”, the main reason why allergens are cause number one for recalls is the “human element”. Why?

People is responsible for identifying the allergenic agents in food, include them in the HACCP program, handle them inside the facility, develop labels that include the allergens used and review those labels frequently and, cleaning all food contact surfaces to prevent cross-contamination. The only way this is effectively accomplished is by having “qualified individuals”, as defined by FSMA. This is training.

Here is where the effectiveness of the “training program” comes into play. People must be trained to:

1) Obtain the knowledge required to develop and implement a food safety system.

2) Start using the knowledge and converting it to skills. This is experience.

3) Have the right attitude towards the job, responsibilities and activities to be performed. This is inherent to each person, as well as the ability to be tolerant to other opinions. This is where the human element plays a big role as a food safety hazard.

Training requirements are in the HACCP regulations as well as in the Good Manufacturing Practices” regulation. Employees must be trained.

The challenge: measure the effectiveness of the training including the attitude of personnel towards the food safety program.