Documentation . . . is it a necessary??

What is Documentation?

Material that provides official information or evidence or that serves as a record.

Documentation can be available in forms of paper, online and digital or analog media, such as audio tape or CDs.

Why is maintaining documentation and records an important part of a food-processing business?

Documentation is a general practice which, a food processor reflect important product and business information and practices.

Such documentation can be helpful to the processor in several ways.

-       Detailed records are extremely important in making management decisions regarding the production, marketing, and financial management aspects.

-       Such records help ensure consistency of processing operations and end-product quality and safety.

-       They are more reliable than human memory.

-       They are a useful tool to identify operational areas where inconsistencies occur and where further employee training may be needed.

-       Maintaining adequate documentation and records of food-processing operations is important if a trace-back investigation of product is ever needed.

-       Documentation is also crucial in terms of helping protect business in terms of potential liability or if business should ever become involved in a lawsuit.

Responsibility

-       Records are most useful when they begin by including the date and time, name of person(s) who completed the record, and the activity or production station being recorded.

-       Documentation is a responsibility of every staff member of the company.

·         Managers

·         Supervisors

·         Production Workers

·         Executives

Etc…

-       Document verification was done by authorized person (Food safety team leader)

Battling Complacency

Well documented SOPs and company policies are an essential part of every food plant operation. However, the development of policies and procedures is only the beginning of the process.

Experience can be an excellent, but often harsh teacher. Just when we feel comfortable with our programs and the conditions in the food plant, something comes along and reminds us that we don’t know as much as we thought. These events can be expensive, frustrating and upsetting. Complacency always demands a high price.

The limited resources in today’s food plants and the fast-paced environment that people have come to expect have created some interesting opportunities for events to take advantage of. In the past, there was one employee dedicated to a particular discipline such as sanitation, quality assurance, production or maintenance. Today we have one person serving multiple roles. However, it is unreasonable to expect the person wearing many hats to possess all the experience and awareness of someone dedicated to one role.

In years to come, we will continue to see reduced numbers of personnel throughout the food industry. We have examined a variety of different programs to assist us with managing the situations that our past has shown us are a concern. We embraced HACCP as our food safety program, and a well developed, implemented and managed HACCP Program is now considered vital to every food manufacturing facility.

Prerequisite programs that are developed and implemented to manage the food plant environment are vital to the success of food safety. The food industry has spent a considerable amount of money and effort improving these programs in order to maintain product quality and market brand. Many hours of development time, training sessions and follow up have been dedicated to this end.

However, I am concerned that we may have used too broad of a brush to paint a picture of our food plant and the programs used to prove we are in control. We may have missed the significance of some of the finer brush strokes. Have we become so focused on making sure our programs are structured to conform to a particular model that we have overlooked items the program was originally designed to take care of?

The Role of Documentation. 

Documentation is one area where exhaustive efforts have been made to provide a record of activities that can be examined by various groups to help determine compliance with specific program criteria. However, we may have reached a point where collecting the documentation in the correct format overrides our ability to understand what the data is actually telling us.

Documentation collection should serve as a resource to help identify deficiencies in the processes. Decisions about what should be done are based on accurate reporting. The concern is that information is being collected simply to complete a checklist, and its impact on food plant processes or food safety programs is being overlooked.

During the past several years I have witnessed an increasing number of instances where the pressure to collect information has encouraged the falsification of documentation. Pressure to have it all conform to what the expectations have established has led to “creative record keeping” issues.

Far too many times this has been detrimental to operations identifying the root cause of processing and/or food safety failures. Corrections that are made on documents during their processing to the completed form for filing only provide a misleading picture of what actually transpired when a situation occurred.

Pre-recording process documentation (such as batch sheets or production records) before the work has actually been done, because it is inconvenient to record information when the work actually occurs, also sets the stage for major problems. Incorrect lot numbers, temperatures, mix times and other critical elements that are not within acceptable ranges are becoming too common. Employee education and more time spent on the floor supervising and reinforcing the importance of procedure compliance is one possible way to curb this growing practice.

When issues with critical documentation exist in a facility, how can lot traceability be effectively conducted? The impact can have a profound impact on a firm’s ability to react quickly to a food safety event. Processing failures will require far more time to identify the correct actions needed to regain control over the processes. This alone can have a dramatic impact on your brand in the marketplace.

Along the same vein, how often do we properly use the programs we have designed to catch food safety issues before they occur? Are post-work inspections consistently conducted to verify that the work meets the expectations? Who confirms that the actions implemented to correct an issue were in fact the correct actions that needed to be taken? Are pre-startup or post-maintenance inspections confirming that the equipment or system is ready to be used for food production, or are we just doing the paperwork? All we need to do is look at the recall data to get the answers. Everyday there are examples of products that should never have reached the market if we were paying attention to the basic, though sometimes monotonous, programs.

Examples of Opportunity. 

When you pass through an area, randomly look at the working documentation. Is everything being completed as expected? Is there a creative documentation language being used on the floor? Are there entries without initials or required signatures?

Now check the files. Has the documentation been “cleaned up”? Documents get dirty and folded on the production floor. Is this the type of documentation in your files or does your documentation look clean and done to specification?

How complete was the job before it was signed off? The documentation indicates repair criteria, but the physical evidence in the plant indicates workers are allowed to do as they please. Jobs are left half finished, but records indicate they were done. This could be everything from equipment set-up to maintenance repairs or sanitation tasks. If the observations indicate a conflict with a documented program, then a problem exists somewhere: insects found in an area where the current sanitation program should control them; equipment failure on systems where the PM documentation indicated every task is completed on time; poor product performance issues when the production sheets tell us everything was done according to specification.

Take a moment and assess your Glass and Brittle Plastic Program. You probably do a monthly area inspection to check the items on your list. How often do you leave the list in the office and dig further to determine if you have missed anything important?

Step out of the box you have built around yourself and go explore. Observe with a critical eye to see things that you may have overlooked before.

The next time you visit the lunch room in your facility, sit down and look around. This is the gathering place for your entire plant. How much unprotected glass is there in this one area? Would glass breakage in this area be a potential significant food safety risk?

You would likely cover all of the major sources like the overhead lights, ceramic coffee cups, and any glass containers that are brought in by employees (even though your policy prohibits this activity). Depending on where you are sitting, you may be close to a source of glass that is often overlooked. We have scoured production areas to find every possible source of glass, but we may have overlooked a critical source in our lunch rooms.

Every lunch-room vending machine contains fluorescent light bulbs to aid in the display of the products or attract you to the machines. Typically these machines are not on the plant inspection program even though they should be. Since you are never inside them, you may not be aware of the risks presented by these lights. Vendors service the machines at odd hours so you may not have seen them change the light bulbs. A chosen few plants have had their awareness of this issue raised because the vendor left the bulbs leaning against a wall in the lunch room only to have them fall onto the floor, explode and scatter fine glass particles throughout the area.

Would compliance with your existing glass policy have avoided this?

Along the same lines, I have discovered unshielded light bulbs being installed in very sensitive production areas. Certainly the program documentation that should have prevented this was impressive, as was the passion of the people stating this is not an event that could happen in their facility. A brief demonstration outside the facility in a controlled container was all it took to clear their minds of the impossible and focus, instead, on how it could have happened.

One facility used a contracted service to maintain administrative areas of the facility to keep plant personnel focused on the manufacturing areas. Unknown to maintenance personnel, the contract included bulb replacement as needed. At some point, the service contractors introduced a full box of bulbs to replace one burned out light. They left the case of bulbs leaning against a file cabinet when they left. Office personnel notified maintenance of the bulbs so they retrieved them and placed them into their inventory. Complacency with the programs could have led to a major food safety issue. What happens at your facility?

Another area that frequently drops off the radar screen is the warehouse. Food plants develop their programs to focus on inbound materials from suppliers. Are the seals intact? Is the shipment clean enough to come into the warehouse? Is there evidence of insect or rodent activity? Etc.

Sometimes this inspection is thorough, but most often it is a simple glance as the shipment passes by on the forklift. In reality, the inspection should dig deeper. What are the lot numbers? Is all the paperwork filled out? Is the vehicle inspection checklist completed? Is the bill of lading signed? Are any goods damaged?

We diligently follow a policy of First In-First Out (FIFO). Computerized inventory programs tell us we are compliant with this policy. But, how much material do you store in the warehouse that is not in your FIFO program? You might store financial records, miscellaneous maintenance parts, obsolete materials we cannot dispose of for a number of reasons, etc. Eventually we no longer notice these items and subconsciously convince ourselves they don’t exist.

Are your monthly material inspections limited to food items only, or do they encompass these sensitive areas? Many times I have investigated pest control treatment failures only to find that the efforts to locate and deal with the source of infestation fell short of what was needed. Mice were residing in the shredded financial records stored on the fifth level in the center of the warehouse. The Indian Meal Moth population was in the broken production equipment that maintenance placed in the warehouse, food products and all.

Conclusion. 

Well-documented SOPs and policies are an essential part of every plant operation. However, the development of policies and procedures is only the beginning of the program. Food plants must continually challenge their program application and do their best to make sure nothing has been overlooked. When you feel that everything has been covered, look again or have someone else look at it.

Accurately recorded events are a valuable asset. Documented history provides insight into what and where something may have gone wrong. This shortens the investigation process and allows for good judgment to occur. Inaccurate or non-factual documentation is a precursor to a food plant’s worst nightmare. A disconnect between the documentation and the actual events can stop an investigation in its tracks, sometimes causing plants to lose everything. Make sure that the employees responsible for recording the events are aware of the importance of accuracy and understand their significance in the program.

The author is Head of Food Safety Education, AIB International.

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