It is clear why the U.S. Food and Drug Administration (FDA) is taking a microscopic focus on training in the food production industry. The number of recalls of contaminated products with subsequent investigations pinpointing causes such as employee mishandling or unsafe work practices are reasons enough for companies to take a much closer look at their training efforts even without federal scrutiny. The issue here cannot be more serious: public and workplace safety can and has been jeopardized because a worker either failed to apply food safety training on the job or was never correctly taught it in the first place. Companies rely on their employees—both seasoned workers and new hires—to follow their food safety plans every hour of the day, but challenges of juggling customer demands and managing operational constraints often derail execution. The impact of such mistakes on the company brand can be substantial.
One particularly costly example of improper training in food safety protocols occurred in 2010 when an outbreak of salmonella sickened hundreds in four states and led to the recall of 380 million eggs traced to one Midwestern company. A national news media probe found evidence of numerous safety lapses, many of which were attributable to substandard training. This and other food mishandling incidents that jeopardized consumer health and safety were instrumental in the passage of the Food Safety Modernization Act (FSMA)—a law that has been in effect for two years and continues to be defined by FDA, particularly on the subject of training.
Training and FDA Proposed Rules
There is a reason why David Acheson, M.D., former chief medical officer of FDA’s Center for Food Safety and Applied Nutrition, has described FSMA as “the most sweeping overhaul of the food safety system since 1938.” It literally requires companies to be more proactive to meet strict requirements for food safety that will only intensify as FDA continues the law’s implementation. The agency is considering five proposed rules that are understood to be the framework of a comprehensive change in today’s food safety protocols. Earlier this year, the agency published two of the five proposed rules and scheduled hearings for public comments on “preventive controls for human food and produce safety standards.” The rationale behind both can be understood in the statistics the agency presents. For example, nearly 32 percent of food recalls related to Current Good Manufacturing Practices (cGMPs) from 1999–2003 were the result of ineffective employee training. FDA repeated its assessment of recalls issued in 2008-2009. The agency found a continuing pattern with 24 percent of the recalls during this period attributed to deficiencies in employee training.
Clearly traditional food safety training approaches and sporadic or inconsistent documentation that fails to prove worker comprehension to FDA’s satisfaction have to be changed. Companies are turning to sophisticated, new technology to assure learning comprehension and mitigate the risk to the public by alleviating improper and insufficient training. Yet there is one more element that should not be overlooked if employees are to fully understand the concepts: they need to become involved with the training. In other words, to be successful, the training should be interactive.
The Principles of Interactive Training
A food safety culture is best accomplished when the workforce is engaged. It is here that new training technology becomes fundamental by incorporating three learning styles: auditory, kinesthetic and visual. Studies indicate that trainees learn and retain information better when there is significant visual metaphor to attract and hold their attention span. At the same time, training that is interactive increases retention (always important) and team building. Employees who feel they are team members are likely to be more conscious of on-the-job food safety demonstrated by their co-workers as well as themselves.
To assure a learning environment, consider these five best practices:
• Consistently deliver up-to-date information. With today’s technology, training should never be outdated. Training providers can offer subscription-based training with frequently updated content that will meet industry standards and government regulations.
• Develop interactive and engaging content. New technology is available to engage the employees as they learn. For example, training can be delivered using the most basic gadget of all—the simple remote control. This unintimidating device supports employee interaction with the instruction and testing enabling the instructor to focus on immediate remediation when answers are incorrect. It is a style that drives engagement and offers long-term retention, especially important considering the demands of evolving FSMA compliance.
• Provide training content in multiple languages. Food industry employees are diverse and many are non–English speakers. Make sure training is provided in different languages to deliver a consistent message and assure English and non-English speaking employees are able to follow the company’s food safety plan.
• Implement company content, tests and evaluations. Today’s learning platforms enable companies to easily create training on company-specific policies and procedures through a common platform across a dispersed user base. Companies should not accept “canned” training programs that fail to address a company’s specific critical controls or standard operating procedures. FSMA training requirements are evolving, but it’s clear that companies will need to effectively train their employees on the importance of their role in maintaining their food safety plan.
• Automatically document and report on results. Most advanced training systems now help employers develop learning plans, manage training events, store training records, provide automatic documentation of the results and instantly download training reports in electronic or printed formats. This helps avert potential employee legal issues and, just as important, improves results from third-party audits with defensible training records stored in a central location.
Experiences from the field
O-AT-KA Milk Products Cooperative, Inc., Batavia, NY, is a global provider of high-quality milk products. When seeking SQF Level 3 2000 Certification, the company discovered that its training program and documentation for its 300 employees were insufficient. To address this gap, O-AT-KA explored the new technology and adopted the remote-controlled interactive technology platform for employee learning and records documentation. Employees were energized by the new system (they actually enjoyed food safety training) and the cooperative was more than pleased with the results. With its training electronically documented and learning comprehension verified, O-AT-KA received a “fully compliant” rating and achieved certification in 2011.
Ralcorp, a St. Louis-based producer of Post Cereals, provides another example of the role of interactive technology in achieving a food safety culture. The company had been using a manual system and was concerned about inconsistencies in message, content and human intervention. Two Ralcorp divisions switched to an interactive technology. The company found that the technology improved understanding of the key concepts of food safety training and provided consistency in delivery and presentation, which was missing with its previous training methods.
What these advanced training platforms achieve goes beyond training and documentation. Perhaps their greatest return on investment is an intangible—the establishment of a culture of safety. By adopting new training technology, companies are able to develop company specific training effectively. They can reduce time-consuming manual tracking and efficiently increase training of employees by capitalizing on equipment down- time and change-overs to continually reinforce food safety. These training tools help companies comply with the new expanding and evolving FSMA standards while emphasizing the importance of food safety in their day-to-day operations. Employees who recognize and clearly understand their critical role in food safety translate into invaluable brand protection for food manufacturers and processors.
Laura Dunn Nelson is director of industry relations for Alchemy Systems, LP, an Austin, TX-based company that creates and globally markets highly interactive training products that use technology and media to educate individuals and groups. She can be reached at 254.965.8563 or laura.nelson@alchemysystems.com. For more information, visit www.alchemysystems.com.