CHAPTER 9.1
Food Safety Management Systems

What is a Food Safety Management System?


Basically, it’s a plan, an agreed set of controls, and a set of documents that detail what you and your team do in terms of food safety to prevent a foodborne illness from occurring.

Throughout this course, we have talked about the importance of training staff and then monitoring what they do to make sure they are following the procedures and processes you have put in place.

  • We have talked about checking a delivery to ensure it is in temperature and the products are in date.
  • We talked about signing the delivery note as proof of delivery or even as proof of rejecting the delivery.
  • We talked about using probe thermometers to test temperatures and the need to write these down to prove you cooked or stored the food at the right temperature.
  • We have talked about the time limits you are allowed for hot and cold hold, and how you monitor these products.
  • We talked about policies for reporting staff sickness.
  • We talked about a due diligence defense and the need to “prove it.”

When we talk about a Food Safety Management System, (let’s call it FSMS going forward), it’s basically the collection of forms, (similar to the ones we have just mentioned), which are needed to ensure you are controlling food safety and as importantly, that you can prove it.

Your local DOHI, (Health Inspector), has to feel confident that as a manager, you understand the controls needed to protect public health, you are implementing them into your operation, your staff has been trained, and you can prove it via documentation.

The size and complexity of your FSMS will depend on the type of operation you run and the requirements of your local authority.

In fairness, your operation will probably have an FSMS already in place and you will know how little it impacts your daily role from a paperwork perspective.

If you have never been involved in setting up or running an FSMS, at this stage you may be concerned that it is unneeded and unnecessary paperwork. Actually, it isn’t, and once established, it is simple to manage on an ongoing, daily basis.

We do not intend to drown you in paperwork in this chapter, rather run through the basics and provide many downloadable documents that you may find useful.

If any are of use, excellent; if you already have the forms in your business, then even better!

DEFINITIONS

Before we talk about an FSMS, there are a few definitions we need to explain.

Due Diligence Defense


This has been mentioned quite a few times throughout the course. If something goes wrong and you have a major foodborne illness outbreak, your FSMS can help prove, (via documentation), that you have taken every reasonable precaution to protect the consumer, (a due diligence defense).

This could save your operation thousands of dollars in fines, loss of reputation, and the risk of closure.

What does HACCP Mean?


You may have heard of the term HACCP. It means ‘Hazard Analysis Critical Control Point’.

HACCP is the set of principles, (backbone), on which every FSMS is built.

HACCP is designed to:

  • Examine threats to food safety
  • Identify what are the actual hazards to food safety.
  • Determine ways to eliminate or control the threat.
  • The best way to understand HACCP is to split it into two parts:

HA, (Hazard, Analysis)

  • is all about identifying the hazards

CCP, (Critical, Control, Points)

  • at this stage you put in control points to remove or reduce the hazard to an acceptable level.

We use the word ‘Control’ quite a lot in the food industry. It is important to understand that you can never fully eliminate a threat, so we look to control the threat and reduce it to a level that represents a low risk to food safety.

HARPC Principles


HARPC stands for “Hazard Analysis and Risk Based Preventative Controls.”

This is very similar to HACCP and is mainly used for manufacturing.

HARPC identifies hazards due to the specific foods or food ingredients in the food or due to the various processing, manufacturing, packing, and holding steps applied to the foods. Once identified, the company must evaluate each hazard to assess its probability of occurring and the severity of the injury it would bring. This step is designed to prepare the firm for identifying the steps necessary to minimize or prevent hazards from arising.

FDA Federal Food Code 2017


Federal Food Codes are the government-issued guidance provided to all US local Department of Health agencies to provide guidance for all food establishments. It does not tell you how to run your food establishment but provides the Dos and Don’ts of food safety.

The Food Code provides guidance on the following (along with other topics)

  • Cooking (cooking, reheating, hot-holding)
  • Cleaning (cleaning techniques, schedules, deep clean and clean as you go)
  • Chilling (chilling hot food, chilled storage, defrosting, freezing guidance)
  • Cross Contamination (personal hygiene, pests, cloths, allergies, physical & chemical hazards)

Local DOH jurisdictions adopt the FDA Federal Food Code and then, in turn, create their own state or city Food Code (Utah Food Code, Chicago Food Code, etc.)

HARPC/HACCP plans are always required when a food establishment produces a Modified Atmosphere Package, (MAP), or if the local DOH jurisdiction requires one.

CHAPTER 9.2
Developing a Food Safety Management System

  • There are two steps to developing an FSMS.

STEP 1 – ESTABLISH PREREQUISITES

A prerequisite is a basic process that you need to have in place before you can set up your FSMS. (For example: having a mains supply of fresh, clean water).

You will probably have most prerequisites, already in your business:

Prerequisite Description
Suppliers Food products must be purchased from reputable and audited suppliers
Delivery & Storage Deliveries checked and suitable storage facilities available
Cleaning & Sanitizing A cleaning schedule needs to be in place including deep clean, daily clean, and clean-as-you-go practices
Personal Hygiene Adequate handwashing, toilet, and changing facilities need to be in place
Pest Control Maintain an integrated pest management program, (IPM), using a sub-contractor
Plant, Equipment & Maintenance Machinery and equipment must be fit for purpose, in good working order with instructions and a maintenance schedule
Premises & Structure Premises fit for purpose
Waste Management Effective trash containers must be present, easily accessible, and waste management contracts in place
Activity Zones Separate areas should be assigned for unpacking deliveries, preparation, cooking, service/holding, and cleaning to prevent cross-contamination
Training & Supervision All staff should be trained to an appropriate level with effective supervision & management
Potable Water Potable water (mains supplied safe, fresh drinking water)

As you can see, it is a comprehensive list, of which you will probably have most in place already. It is important to understand that they ALL must be in place or the FSMS will not work.

STEP 2 – DEVELOP THE SYSTEM

  • Create a Process Flow
  • Identify Control Points (CP)
  • Identify Critical Control Points (CCP)
  • Set Critical Limits for each CCP
  • Establish Monitoring Procedures for each CCP
  • Corrective Actions
  • Verification
  • Establish your Documentation
  • Review your System
  • Train your Staff

Process Flow Chart


Remember how we have talked about the journey of food through your operation? A Process Flow Chart just matches these points we have already discussed.

To help you, we are going to look at a hot dog that you will serve hot to a customer.

Process Flow Chart – Raw Food to be Cooked before Service


The temperature recorded at delivery to ensure it is within temp range of 35°F – 41°F

The temperature of the fridge was checked and recorded 3 times a day.

Dates visually checked before taking to prep

Ensure time in the Temperature Danger Zone is kept to a minimum

Cook to 165°F for 15 seconds

Approved Reputable Supplier: Control Point
Chilled Delivery Control Point
Storage in Refrigerator: Control Point
Shelf Life: Control Point
Prep Time: Control Point
Cook/Kill Stage: Critical Control Point
Serve

Step 1 – Create a Process Flow


As you can see from the above flowchart, you need to think of the process the food product will go through and the steps you will take to keep the food safe. The whole process is about using a well-known reputable supplier and then controlling both the time and temperature to prevent bacterial multiplication.

Step 2 – Identify Control Points (CPs)


In the above chart, you will see that the food, (hotdog) will go through 6 steps, (processes) before it is served to the customer. At each step, (process) you need to determine if a hazard could happen. If so, what control measure would you put in place? As you can see from the chart, they are simple and easily monitorable steps to protect food safety.

A term used in FSMS is to separate the acceptable from the unacceptable.

Step 3 – Identify Critical Control Points (CCPs)


The next step is to decide at which point you place a Critical Control Point.

Ideally, there should only be ONE CCP in any process. This is usually the last point before the food goes out to a consumer. It is the last point where you can control food safety.

In the example of the hot dog, the CCP would be cooking it to 165°F for 15 seconds. After that, you can do nothing else that will protect food safety before it goes to the consumer.

However, if you were then going to hot hold the hot dog for service over dinner, the heat of the hot holding equipment would then be the critical control point.

Step 4 – Set Critical Limits for CP and CCPs


A Critical Limit is a standard that must be achieved to maintain food safety.

They must be 100% strictly observed and enforced.

In the example of the hot dog, the Critical Limit will still be cooking it to 165°F for 15 seconds.

All staff must be trained to understand that cooking the hotdog to 145°F for 30 seconds is unacceptable. If this happens you do not protect the Critical Control Point and food safety is at risk.

Step 5 – Establish Monitoring Procedures for each CP & CCP


This is an important part of the process. You need to make sure that the controls you have put in place are working correctly and the only way to ensure this is happening is by regular monitoring and recording the results. Also, a Due Diligence defense relies on your ability to prove that monitoring has taken place. Written/documented evidence is the best option.

Typically, it will be the recording of delivery temperatures, fridge/freezer temps, cooking, and hot holding temps.

In the example of the hot dog, you need to be able to PROVE that it was cooked at 165°F for 15 seconds.

As the manager (PIC), you will not be expected to monitor every process that happens in your kitchen. It is your role to train your staff to carry out these monitoring roles and assign tasks to individuals. It is also important that the staff understand why they need to do it accurately and properly. Remember, they play an important role in food safety

Questions you need to ask, and answer, are:

  • Who will monitor and what?
  • What needs to be recorded, and where will it be recorded?
  • How will it be monitored?
  • How often will the monitoring take place?

Step 6 – Corrective Actions


If the hot dog only achieves a temperature of 145°F, the Corrective Action would be to carry on cooking to 165°F.

If the food delivery was at 70°F then the Corrective Action would be to refuse delivery.

Decide what corrective actions are to be taken when limits are exceeded to restore control.

To a DOHI, documented corrective action is evidence of the system working.

If a Corrective Action happens repeatedly then you need to look at the system and re-train staff who are making repeated mistakes.

Key Point: If the hotdog has only reached a temp of 145°F, it is perfectly acceptable to carry on cooking until the temperature hits 165°F. The food does not need to be destroyed, it merely needs to be cooked for longer to ensure it hits the limit you have set for the Critical Control Point.

Step 7 -Verification


Often you will be too close to the daily workings of the operation to look at the system objectively. A suggestion is once you have set up the system, ask a consultant/expert to come in and look at the system. You can also ask your local DOHI. Remember they are there to help and will appreciate you asking for their guidance.

Step 8 – Establish your Documentation


Once you have decided what needs monitoring, the CP, CCPs, and Critical Limits you will then require the documents to record everything. This can sometimes be a daunting task; however, help is at hand. We have provided a full set of documents that are available to download, free of charge.

Key Point

Only use the documents you need! Too many and the system will start to get confusing and become a hindrance as opposed to a help. Again, if unsure, ask your DOHI.

Step 9 – Review your System


On at least a yearly basis you need to review your system to make sure it is working properly.

In real life, you will be looking at the system on an ongoing basis. You may have problems with Corrective Actions. You may have changed how you prep or cook food, for example, the chilled hotdog has changed to a frozen variety.

The reason for a yearly review is that you take the time to stand back from the business and look at what is REALLY happening in your business. You can then determine what if anything needs changing. Remember the system is to protect food safety, not drown you in paperwork!

Step 10 – Train your Staff


As we have already mentioned, you will not be conducting all the checking and monitoring. Your staff needs to understand why it has to be done, the dangers if it does not adhere to and the benefits of a properly working system. They have to feel they are part of the process.

Your role as a manager will be to then oversee and make occasional checks to ensure everything is working properly.

And that is basically how an FSMS works. It is in the main, common sense and implemented properly, it will help to significantly reduce the risks of a foodborne illness outbreak.

In your download section, we have provided many different forms. We hope they will be of use in your operation.

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