What is GFSI?
The Global Food Safety Initiative (GFSI) is a global initiative for the continuous improvement of food safety management systems. The initiative’s goal is to ensure confidence in the delivery of safe food to consumers around the world.
The initiative was launched in 2000 following a number of food safety crises that severely diminished consumers’ confidence in the global food supply chain. The key activity within the scope of GFSI was the definition of food safety requirements for food safety schemes through a benchmarking process. This global set of standards has helped to accelerate the recognition and implementation of several existing food safety schemes. It has also driven growing confidence in third-party certifications along the entire food supply chain.
A Surprising Issue for GFSI Compliance
From a functional standpoint, one of the most challenging elements of keeping up with GFSI compliance for food producers is sufficient document control. Some of the data compiled by SQF shows that document control related issues are one of the most common sources of a nonconformances during GFSI-benchmarked audits.
So what exactly are some of the most common sources of these document control nonconformances? Here are a few to look out for:
1. Lack of document control altogether
Lack of correct usage of document control in the context of GFSI compliance is a common error. This is an issue that often occurs as a result of document sprawl. Specifically as it pertains to duplicate documents and supporting documents. For example, an organization might create internal reference material designed to be cheat sheets or summaries of larger policies. These could include simple charts that list key equipment set-up parameters or charts summarizing abbreviated information from product specification sheets. Many organizations fail to realize that because of the nature of the information in these files, these reference documents must also be included in their document control program to ensure that the information in them is current and universally applied.
2. Document version control
From outdated forms being filled in to outdated employee procedures being referenced, lack of proper document version control and enforcement is the most common GFSI compliance-related nonconformance. These issues can arise from operational errors (employees don’t know where to find or how to ensure up-to-date documentation is being used) to technical errors (the document control system is unable to properly manage document versioning, or in the case of home-grown document control software systems, they may be unable to do so altogether). To avoid these errors, it’s necessary to establish where controlled versions of documents are located and ensure that they are kept up to date. It’s also important remove obsolete versions of these documents—this is a basic principle of document control but it’s often an area where errors compound over time. Reinforcing training so employees are made aware of document control best practices and policies is critical to keeping your compliance activities current.
3. Revision errors
One of the most common activities and most common sources of error within any document control program is publishing revisions to documents. These errors include:
- Updating the contents of a document but forgetting to update information such as the version number
- Improper tracking of revision history
- Adding new documents to the database rather than revising or updating existing documents
4. Inclusion of documents from external sources
If your food safety management system includes or makes use of external documents, these must be controlled in the same manner that you control internal documents.
Some examples of external documents that may need to be included in your document control program include:
- Sample labels provided by your chemical and pest management suppliers
- Raw material specifications provided by your suppliers
- Customer expectations manuals provided by your customers
5. Improper identification of approval personnel
A best practice of document control is for the person knowledgeable about the content of a document to be assigned the responsibility of approving updates to it.
In many organizations this is interpreted to mean that all approval responsibilities are assigned to a single person across the organization. This could be the food safety coordinator or the document control administrator, despite the fact that it is not reasonable for a single person to be knowledgeable about all the procedures across the organization.
A better approach to approval responsibilities is to identify individuals that can be responsible for authorizing changes based on function or discipline. By spreading the responsibilities across more people, your document control program is more likely to be current and accurate.
When it comes to many aspects of business it’s often the basic principles that get overlooked once processes and systems are up and running. GFSI compliance is no different. Setting up a process for document control is the first step in achieving compliance. This first step shouldn’t be thought of as a point in time, but rather the beginning of an ongoing process that you should be constantly revisiting, thereby helping to not only maintain compliance but to improve overall business processes as well.