Food Safety Culture at the Heart of Canada's Largest Meat Recall
Over the past month XL Foods Inc, Brooks plant in southern Alberta has been the focus of Canada's largest meat recall in history. Information about the current recall at XL is still preliminary, however, the information available suggests that a breakdown in the Food Safety Culture within the plant was a contributing factor.
Feedback from CFIA
XL Foods Inc is a private company with a number of processing plants. The Brooks plant is one of the largest in Canada and has a full time presence of Canadian Food Inspection Agency (CFIA) inspectors and veterinarians working two shifts. The plant has a hazard analysis and critical control points plan (HACCP). The CFIA investigation reports that:
However, the plan, known as hazard analysis and critical control points plan (HACCP), was not being fully implemented or regularly updated. Specific observations included:
- Lack of detailed documents outlining required steps when product was positive for E. coli or when there were a high number of positives in a 24-hour period
- Inconsistent trend analysis on positive samples and no process to include test results from client establishments
- Insufficient record keeping related to on-going monitoring and validation of processes, procedures, and equipment maintenance (e.g., 12 of 100 water nozzles clogged in the primary carcass wash area)
- Deficiencies in sampling techniques and procedures, such as inconsistent sampling and no established monitoring program.
The comments from the CFIA investigation suggest a breakdown in the food safety culture within the plant. Research and experience in food safety culture recognizes that there are three parties involved in the promotion of an effective food safety culture: management, employees/workers, and the inspection authority. In the past, the role of the inspection authority has been a policing and enforcement role. The role of management is to provide the policies and procedures and to champion the food safety culture. Front-line employees have a direct role in implementing the food safety protocols in their day-to-day work.
Changing roles and responsibilities
A successful food safety culture ensures that there is a protocol in place that is up to date and regularly reviewed and updated. While XL Foods had an HACCP plan in place, the CFIA review suggests if was not fully implemented or regularly updated. That is a primary responsibility of management.
Employees need sufficient knowledge and training in the HACCP plan to be able to effectively contribute observations and take corrective action in real time. However, there is insufficient information available to know what levels of training and empowerment were given to employees to appropriately manage their assigned aspects of the food safety system. Press conferences given by union officials have suggested that a culture of getting product out the door trumped food safety issues. This suggests that issues of food safety being brought by employees to the attention of management were compromised.
The role of inspection authorities is changing in both Canada and the U.S. Increasingly, the responsibility for food safety is shifting to management and employees. Rather than filling the traditional policing role, inspection authorities are now taking an audit role.
This changing approach by inspection agencies results in a business environment where a vibrant food safety culture is now a strategic advantage. An effective working culture will provide producers with the ability to prevent recalls, and to manage recalls in a timely manner when they do happen.
Some questions for CEO’s
If you are an Executive in a food manufacturing facility here are some questions to help you evaluate your food safety culture:
- As CEO/Executive are you a passionate leader in fostering a food safety culture?
- In making decisions, what weight is put on food safety – or is operational throughput more important?
- How up to date is your HACCP? When was the last time it was revised? How do you know?
- Right now, if you polled 10 line employees, could they explain your food safety policies and procedures? Could they explain their role in the HACCP plan?
- Are your sampling procedures and tracking systems up to standard? How do you know?
- What continuous improvement process do you have in place to monitor and improve your HACCP? What is the representation from employees?
- How up-to-date is your HACCP training? How many training hours per year are spent on food safety?
- If you had a crisis, how long would it take you to deliver relevant reports and documents to CFIA; two hours, six hours, a day...? How long should it take?
- How up-to-date is your technology for traceability and tracking? What could be improved?
- What is your average response time to resolve a corrective action request (CAR)? What is the trend in the last 18 months in both number of CAR’s received and response times?
The 6 attributes of a food safety culture
A strategic food safety culture requires the following six attributes:
- Management has to see food safety and food safety culture as a core competency. All managers must support and champion both food safety and a food safety culture.
- The ability for management to have a HACCP plan that is functional, operational and up to date is now no longer a “nice to have” but a core operational function. One of the criticisms from CFIA was XL Foods inability to provide the necessary documentation in a timely manner.
- There must be ongoing and updated training for all employees in the HACCP plan, its implementation, and responsibilities.
- Employees need a communications mechanism that empowers them to report deficiencies and initiate corrective actions – even to the point of closing the line.
- A formal and ongoing continuous improvement process needs to be in place to enhance the HACCP and promote the primacy of the food safety.
- The ability to track the corrective action response, when the inspection authorities issue a corrective action request, is critical.
Regardless of where your organization is in its effort to create a food safety culture, ultimately the key is engagement; both managers and employees need to be actively engaged on a daily basis with food safety.
In a later post, we will look at crisis management approaches and the opportunities to demonstrate leadership commitment.
For a further discussion see the CBC News piece: