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Ensure an Effective Food Safety Program

By Daphne Nuys-Hall, Technical Director, Meat & Poultry Ontario

After you have written and implemented your food safety program how do you ensure that you’re ready for third party certification? How do you make sure you are ready after receiving notification of a regulatory or supplier audit? Gap assessments are an effective tool to for reviewing your company’s food safety program and examine it for any gaps or deficiencies BEFORE a regulatory or certification audit.

What is a gap assessment? Put simply, a gap assessment is a process where you analyze the effectiveness of both your written program and implementation to ensure that your food safety program meets customer and/or regulatory requirements. A gap assessment also helps you to focus on the potential problem before they turn into bigger problems if they are done right. For example, checking compliance against Ontario Meat Regulation 31/05, the Safe Food for Canadian regulation (SFCR), SQF or BRC compliance and customer requirements such as for COSTCO, Loblaws, etc. There are many benefits to having a gap assessment including – • Address nonconformances before your certification or regulatory audit • Assuring that all operations meet regulatory requirements • Keep your site audit-ready • Providing customers with consistent, satisfying product • Cultivating quick, professional responses to problems • Save time and potential revenue loss

Gap assessments can be done internally, but there are many organizations that offer the analysis as a 3rd-party service.

What To Expect The first component of a gap assessment is to thoroughly review the written programs against either the food safety or quality management standard the company has implemented or against the regulations that would apply to the business, e.g. Ontario Meat Regulation 31/05 or SFCR. The programs would be evaluated to ensure that they are accurate, complete, and current.

The second component would be to perform an on-site review. The review may include: • watching the employees in the performance of their functions to ensure that they are doing it according to the written procedures • the on-site review indicates conformity with the written program • ensuring the current conditions are adequate and they control the hazards

The on-site review may include interviewing the employees to ensure that they understand the program and their role.

The final component would be a review the records completed as evidence that the written program and its procedures are being followed and the monitoring functions are being performed. The person performing the gap assessment will randomly select records to be reviewed, checking for completeness and accuracy, ensuring that the latest revision of the record is being used (if applicable).

If a gap is identified in your program, the next step is to enact measures to close these gaps. This could mean having review sessions with employees about food product safety, adding product inspection equipment to check for specific hazards that you’ve identified, or even redesigning elements of your food safety program.

Gap assessment can be performed using internal resources as well. These are often referred to as “internal audits”. They are easy to do, cost effective as you are using existing staff, and they can be done over a period of time rather then all in one or two days.

There is no hard, fast rule for performing an internal gap assessment however much like using an external 3rd party, the gap assessment follows the same three components – review the written program, on-site review and records review. Conducting an internal audit is much simpler if you prepare a checklist that contains the same items that the inspector or auditor is looking for.

The more comprehensive your assessment is, the better. Thoroughness in this process helps you better prepare for audits by allowing to spot and resolve potential issues ahead of time.

While meeting regulatory requirements or food safety program standards can be tough, the benefits your business could reap are well worth the extra time and effort.

Contact Daphne at technical@meatpoultryon.ca to find out more about how MPO can help you with your Gap Assessment today.

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