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“Often, you can’t see the forest for the trees. So sometimes it’s good to have a different set of eyes,” Rootwurks Consulting expert instructor and CEO of Peak Advisors, Jeff Chilton, said.
Chilton spoke to Rootwurks just after the release of SQF 10 at the beginning of March, about what he sees on the frontlines of food safety and how Rootwurks Consulting can help.
Chilton worked directly in the food industry for 15 years, including as a director of quality assurance and as a plant manager. In 1997, when the US Department of Agriculture mandated the implementation of HACCP regulations for meat and poultry, he started a consulting business to help companies understand and implement these regulations. With more than four decades of experience in food safety and consulting, Chilton has bridged the gap from in-person, shoe leather monitoring of facilities to today’s food safety measures, bolstered by digital tools and AI.
Here are some of his main takeaways.
What to Look for in a Facility
As food safety consultants, Jeff Chilton and his colleagues assist in four key areas:
- Audit preparation: Helping companies with internal auditing to comply with the Global Food Safety Initiative and standards such as SQF, BRCGS and FSSC 22000..
- Regulatory compliance: Helping companies meet standards, including FDA, USDA and OSHA guidelines to assess their food safety and workplace safety plans.
- Training: Guiding companies and their teams through industry-standard training courses, including in-depth certification courses.
- Food safety culture: assessments and training at every level, from senior management to the frontline, to help everyone understand the importance of food safety culture
When asked what he looks for in a facility, Chilton described it as a “very comprehensive review” that takes a holistic view of the physical surroundings and the company’s operations. They’ll examine operations against SQF requirements and any others the company seeks to adhere to, as well as regulatory compliance with USDA and FDA guidelines. He also wants to see if the company is still “stuck in the 20th century,” or if they’ve shifted paper-based systems to digital platforms to provide real-time data visibility and expedited operations.
But it’s never a one-size-fits-all proposition.
“In all cases, we first do an initial walkthrough and get an assessment of the layout of the facility, what type of products they make, the processes they use, and how they make those products. And then during a more detailed assessment, we're looking at if they have all the written procedures they need and if those written procedures have been implemented effectively.”
They also take a comprehensive look at the company's recordkeeping procedures over 60 to 90 days to ensure documentation is implemented consistently. Finally, they observe the plant floor and the operating conditions.
How do you assess food safety culture?
There is one key, initial check that Chilton always performs, that he says never fails to give him a clear idea of the challenges ahead: the restrooms.
“One of my simplest checks is to go into the actual restrooms inside the plants, and I’ll look at the sanitary conditions of the restrooms, and that alone gives me a pretty good idea of the culture of the company and if they're going to have similar sanitary conditions in their plant or not.”
In general, Chilton said he looks for signs that the company is upholding the guidelines in its safety culture protocol - even when no one is watching.
“When you go through a plant, and you’re watching the employees from a distance, are they doing things right? If some product falls off a processing line onto the floor, how do they manage a situation like that?”
And through his assessments of hundreds of facilities across the world, he has found that the disconnect between management and the frontline is a constant problem.
“There's always a common disconnect between the perception that senior leadership and middle management have about how the food safety culture is doing, but when you take time to actually ask the employees that are always down there [on the floor], there’s always a gap between perceptions of food safety culture at different levels of the organization.”
He said this is why surveying the workforce is so important, and why communication is key.
“One of the best ways to get an idea of the food safety culture is to just talk to the people, interview various people throughout the organization, frontline employees, supervisors, and upper-level managers, and then look at the consistency of the responses that you get.”
How to get a “Seek and Destroy” mindset
A facility’s Environmental Monitoring Program (EMP) is the frontline in its food safety program and key to finding and mitigating food safety threats. But Chilton found that mistakes abound there as well.
“A lot of companies will do environmental monitoring just to check the box to say they’ve met this audit requirement or this regulatory demand.”
Instead, Chilton said he likes to see “a seek and destroy mentality”, which is a more robust sampling of higher risk sites within the facility. And if you find it [contaminants], you take care of it. It’s not a problem if contaminants are there - it's a problem if they’re there and you don't find them.”
Regardless, his work involves helping companies develop the right testing regimen as well as protocols for corrective actions when and where needed.
This sort of approach also applies to sanitation programs, which Chilton said entail strong verification measures.
How to get started
When a company makes the decision to get serious about food safety, Chilton said the difference has to begin at the top.
“It’s great for a company to have strong leadership at the top, and that’s part of the food safety culture that trickles down throughout different levels of the organization. The company has to own the safety of the systems and the product they are making."
Chilton said that they have to put strong processes in place, build strong HACCP and food safety management teams, and ensure these teams are multi-disciplinary including people from multiple departments and levels at the company. It also requires the understanding that food safety isn’t a painful hassle or economic burden - it’s good for business and your consumers.
“If you have better food safety culture and food safety plans, you’re going to be more likely to avoid very costly incidents. It’s an avoidance cost and an insurance policy to keep you from having to incur those catastrophic costs that can ultimately shut a company down.”
Rootwurks Consulting: Strategic, Hands-on Guidance to Master Food Safety
Rootwurks Consulting provides on-site training, strategic consulting, and custom documentation to all types of food companies. When you’re ready to build the sort of robust food safety culture that is necessary to meet regulatory requirements, avoid recalls, and uphold quality and consistency, reach out to our experts here:
