Alignment of the Pasteurized Milk Ordinance (PMO) with the Preventive Controls for Human Food rule (PCHF) under the Food Safety Modernization Act (FSMA) sounds like a giant bowl of alphabet soup once you get all the letters into the mix. The upshot of all these acronyms coming together is an awesome opportunity for dairy food safety professionals to roll up their sleeves and turn their programs from plain old soup to the cream of the crop.
The Time Is Now
With a fall 2018 enactment deadline, now is the time for dairy operations to conduct a gap analysis versus the FSMA PCHF requirements. There are three big-ticket items that give clues regarding the best place to start:
- The new rule requires a written hazard analysis that is robust, fully documented, and kept up to date. Remember that the hazards list must include not only biological, chemical, and physical hazards, but things like radiological hazards, natural toxins, pesticides, drug residues, decomposition, parasites, allergens, and unapproved food and color additives. Naturally occurring or unintentionally introduced hazards must be considered as well – to mention intentionally introduced hazards.
- Each identified hazard must be addressed by detailed, fully documented food safety preventive controls. The list of FSMA required preventive controls includes sanitation procedures, environmental monitoring for pathogen controls, hygiene training, a food allergen control program, a recall plan, current Good Manufacturing Practices (cGMPs) and supplier verification activities.
- Science-based testing programs and sampling plans must be fully implemented and work as designed. Having an action plan ready for any unfavorable results, tracking and trending the resulting data, and mapping positives and presumptive with good documentation of any follow up actions are must-haves for compliant programs.
Tell Me How
So how is all of this supposed to get done? By engaging managers, supervisors, and – most importantly – frontline dairy workers and transforming them into change agents. As workforce demographics change and technology advances, the importance of informal learning experiences cannot be underestimated. Adults are embracing opportunities to learn from their peers through direct interaction or through social media now more than ever before.
Training programs should combine formal or classroom type training with more opportunities for informal training through supervisor or peer interaction, with on-the-job training included as well. Overlay all of that with passive, always-on reinforcement materials such as posters and digital signage content to make a lasting impact. These tools will cement the concepts into the long-term memory of the learner.
1-on-1 coaching is another powerful way to help create a strong food safety culture. Coaching is not yelling or telling others what to do. It has more to do with providing constructive feedback and positively reinforcing the correct procedures and behaviors. As Benjamin Franklin said, “Tell me and I forget. Teach me and I remember. Involve me and I learn.” Coaching that involves the individual can turn the dairy worker into an engaged continuous learner who can help drive positive change.
These technologies address the latest FSMA requirements, support workers’ long-term knowledge retention, and facilitate worker-supervisor interaction.
By empowering your frontline workers with the knowledge and confidence that comes from well-designed, well-delivered training, reinforcement, and coaching, PMO/FSMA alignment will go smoothly, and both your dairy operation and its food safety system will ultimately rise to the top.