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This information can be used to develop food safety and quality programs that meet the requirements of modern Regulatory, Customer and Industry Standards:
When considering the development, documentation, and implementation of Business Continuity and Crisis Management within food safety and quality management systems, the following information should be considered to ensure effective outcomes:
Business Continuity and Crisis Management plans are developed, documented, and implemented to ensure a food business has a structured and tested system to deal with known threats to the supply of safe and quality finished products. Business continuity plans may be strongly linked to systemic elements including those for food recall and withdrawal.
Contemporary food businesses are required to have in place business systems that facilitate the production of safe and quality foodstuffs; these systems must also ensure where possible that the production and supply of foodstuffs to customers are not disrupted by manageable incidents or emergencies.
Business Continuity and Crisis Management includes the development of plans to reduce the risk of a crisis occurring and deal with any crises that do arise and the implementation of these plans to minimize the impact of crises and assist the organization to recover from them. Crises may occur as a result of external factors such as the development of a new product by a competitor or changes in legislation, or internal factors such as a product failure or faulty decision making, and often involve the need to make quick decisions based on uncertain or incomplete information.
Within the context of food industry compliance standards, the terms Business Continuity and Crisis Management are often exchanged for other terms including Emergency Preparedness and Incident Management.
It is important to consider that the Business Continuity and Crisis Management system may have strong links to the established Product Recall and Product Withdrawal systems within a food business. This may become apparent in both pre-activation and post-activation of the Business Continuity and Crisis Management protocols.
The following examples are provided as indicators of prospective related interactions:
Business Continuity and Crisis Management review activities should be scheduled, conducted, and recorded on an ongoing basis. Such activities are not dissimilar to a Mock Recall, in which a hypothetical scenario is devised, and the Business Continuity and Crisis Management system is activated within the food business. The Business Continuity and Crisis Management procedures are followed, and records are maintained to show a diary of events and timeframes. Mock Business Continuity and Crisis Management are commonly scheduled to be conducted at least annually.
Elements of a Business Continuity and Crisis Management system usually consist of documented policies and procedures for:
Contact listings for Business Continuity and Crisis Management should be inclusive of the following where applicable:
Business Continuity and Crisis Management systems are commonly developed, documented, and implemented into food businesses to define the procedures and responsibilities for handling contingencies such as Disruption to Key Services, Destruction of Premises or Equipment, or Malicious Contamination of Sabotage.
Disruption of key services may include instances in which the following are impaired within a food business:
Destruction to Premises or Equipment may occur due to:
In an age where instances of terrorism and sabotage are commonplace, it is important to ensure that deliberate malicious contamination or sabotage of products or processes is prevented.
Consideration of such prevention may take into account the following:
As with any food safety and quality system element, Business Continuity and Crisis Management require a structured approach to defining the risk associated with outcomes of food business incidents. A factual approach to decision-making defines a business’ ability to use accurate information and data as a foundation for decision-making.
The benefits of a factual approach to decision making include:
Risk Management principles can be applied throughout all sectors of all food industries and throughout all business systems, including food safety, food quality, workplace health and safety, finance, and operational management.
Risks are an unavoidable component of any business operation. Risk-taking is essential to progression and success, and failure is often a key part of learning. Although some risks are inevitable, this does not mean that attempting to recognize and manage risk will harm opportunities for creativity. It is important to keep in mind that risks are generally known by management, but are often poorly communicated. Usually, communicating risks down the chain of command is easy, but communicating risks up the chain of command is difficult. The risk management process is ongoing, and requires constant analysis, as agenda elements need to be decided, implemented, and managed.
Risk management processes are best managed by multidisciplinary teams. When risk management teams use proactive risk management, the continuous assessment creates data and information that can then be used for decision-making in all phases of the scope of the risk management activity. The team must ensure that risks are identified, managed, and resolved in a manner that is facilitative of continuous improvement for the business involved.
Contemporary risk management processes are inclusive of the following 5 elements:
Risk identification is the first step in the proactive risk management process. Risks must be identified before they can be managed. Risk identification provides the risk management team with opportunities, stimuli, and information that allow them to surface major risks before they have an impact upon the business. This risk identification step involves adequate and appropriate communication between team members and stakeholders to be successful. It is a powerful way to expose assumptions and differing viewpoints between all parties involved in the risk management process.
Risk analysis is the conversion of risk data into risk decision-making information. Thorough risk analysis ensures that the risk management team is managing appropriate risks. During this step the risk management can use a system that identifies the following:
Risk action planning is the third step in the risk management process – It turns risk information into decisions and actions. Planning involves developing actions to address individual risks, prioritizing risk actions, and creating an integrated risk management plan, which may contain the following:
Risk tracking is the fourth step in the risk management process. This step is where the risk management team monitors the status of risks and the actions it has taken to observe and control them. Risk tracking is essential to effective risk action plan implementation. This means defining the risk measures and triggering events needed to ensure that the planned risk actions are working. Tracking is the observation function of the risk action plan. Risk reviews are a recommended item to include in each program review.
Risk control is the final step in the proactive risk management process before proceeding back onto the risk analysis step. After the risk management team has chosen the risk measures and the triggering events, there is nothing defined about the risk management process; it simply becomes a component of the business management process. Risk control is intended to manage the risk action plans, correct for variations from the risk action plans, respond to triggering events, and improve the general risk management process.
Where a Business Continuity and Crisis Management incident has occurred as an outcome of a customer complaint, it is important to ensure that the appropriate actions are taken for the complaint, as well as for other requirements.
The complaint should be investigated immediately by a suitably qualified person from your business, or by an approved external specialist.
The investigation should answer the following questions:
All products that may have been implicated by the problem should be immediately risk assessed and investigated.
Record in your customer complaint file:
Where Customer Complaints involve allegations such as foreign objects, samples of such objects may be provided by the complainant. During the investigative process, it is in the best interests of the food business involved to:
After giving the matter proper consideration, if key team members have reason to believe that a foodborne illness incident has occurred, the following contacts should be facilitated within an appropriate timeframe:
Once the investigation has gathered as much information as possible from all relevant sources:
It is important to consider at this step that if your food business supplies foodstuffs manufactured to a customer’s specifications, you may be required to contact the customer before notifying the nominated regulatory body, particularly where “private label” branded products are involved. This is an important consideration as legal accountability for the regulatory compliance of any foodstuff often remains the liability of the “brand owner”, rather than the manufacturer.
A local health authority notification contact list should contain the following information:
Outcomes of this notification process generally include details for:
The following details should be recorded as an element of notifications:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Business Continuity and Crisis Management Development requirements in relation to their items.
Document: A document provides guidance and/or direction for performing work, making decisions, or rendering judgments that affect the safety or quality of the products or services that customers receive.
Documented policies, procedures, work instructions, and schedules form the basis of any food safety and quality management system. The following documentation formats may be considered to ensure ongoing compliance with specified requirements for Business Continuity and Crisis Management:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Business Continuity and Crisis Management Documentation requirements in relation to their items.
You may wish to visit the Business Continuity and Crisis Management Templates section of haccp.com for examples of Business Continuity and Crisis Management documentation, record and resource formats commonly applied within food safety and quality systems.
Implementation: Implementation is the application of documented food safety and quality system elements into the actual business operation.
The implementation of Business Continuity and Crisis Management within any food business requires genuine commitment from senior management, staff, and visitors to ensure the nominated goals of implementation are achievable on an ongoing basis. It is a step that requires significant planning and consideration of general and specific food business circumstances to ensure the outcomes of Business Continuity and Crisis Management do not negatively impact the safety and quality of the food items dispatched from the business.
Implementation of Business Continuity and Crisis Management must include a clear definition of responsibilities and authorities for all levels of participation by senior management, staff, and visitors to the site.
When implementing Business Continuity and Crisis Management within a food safety and quality system, you may wish to consider the following requirements before completion:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Business Continuity and Crisis Management Implementation requirements in relation to their items.
Monitoring: Monitoring is the act of reviewing and confirming measurable parameters of a defined process or product status.
Monitoring requirements within food industry sectors are generally identified against limits of acceptability defined within HACCP plans, implementation procedures, and work instructions. Monitoring usually includes some element of record-keeping, which may be maintained manually or through digital systems. It is important to consider that advancements in technology have spawned many systems and processes which are self-monitored and or self-adjusted when variances are identified. Regardless of the system used; the goal of any monitoring activity is to provide sufficient evidence that any limit of acceptability has been met.
Traditional Business Continuity and Crisis Management monitoring requirements include manual recording and the application of corrective actions when the results of monitoring are found to be outside acceptable limits. Corrective Actions should also generally be strongly linked to the monitoring process where applied to ensure full traceability of the applied actions.
Common monitoring activities and record formats may apply to Business Continuity and Crisis Management:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Business Continuity and Crisis Management Monitoring requirements in relation to their items.
You may wish to visit the Business Continuity and Crisis Management Templates section of haccp.com for examples of Business Continuity and Crisis Management documentation, record and resource formats commonly applied within food safety and quality systems.
Corrective Action: Corrective action is mandatory action to be taken when a deviation to the Quality System occurs, particularly in relation to a Critical Control Point.
Preventative Action: At any step in the process where a hazard has been identified, preventative action must be put into place to prevent re-occurrence.
Corrective Action and Preventative Action are implemented to ensure that any identified non-conformance issues are documented, investigated, and rectified within appropriate time frames. Corrective action is any action applied to regain control over a product, process, policy, or procedure that has been identified as being non-conforming or outside nominated limits of acceptability. Preventative action is any action applied to prevent any identified non-conformance from reoccurring.
The outcomes of corrective and preventative actions should result in regained process control after effective application. Specified corrective actions are commonly linked to the HACCP Plans and the food business certification process.
Below are Corrective Action and Preventative Action examples which may be associated with Business Continuity and Crisis Management related non-conformance:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Business Continuity and Crisis Management Corrective Action requirements in relation to their items.
You may wish to visit the Corrective Action and Preventative Action section of haccp.com for examples of best practice applications for this food safety and quality system element.
Verification: The act of reviewing, inspecting, testing, checking, auditing, or otherwise establishing and documenting whether items, processes, services, or documents conform to specified requirements.
Verification is the detailed review of all food safety and quality system elements to confirm that they are effectively developed, documented, implemented, monitored, and reviewed. All food safety and quality system elements, including documented policies, procedures, training, HACCP plans, and their operational applications must be verified on an ongoing scheduled basis. The verification process commonly includes a defined schedule for which verification activities are required, how often they are conducted, who is responsible, and detailed documented procedures for each nominated verification activity.
The general goal of an established verification process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact the effectiveness of the food safety and quality system.
The following examples of verification activities may apply to Business Continuity and Crisis Management:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Business Continuity and Crisis Management Verification requirements in relation to their items.
You may wish to visit the Verification Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.
Validation: The process of gathering evidence to provide a scientific basis for the documented act of demonstrating that a procedure, process, and activity will consistently lead to the expected results. It often includes the qualification of systems and equipment.
Validation is the provision of evidence to support the limits of control or acceptability for food safety or quality parameters nominated within systemic elements. Limits of control or acceptability are commonly included within documented food safety and quality systems elements such as procedures, HACCP plans, and specifications.
Common sources of validation include regulatory and legislative standards, finished product specifications and customer requirements, industry codes of practice and guidelines, verified and validated research, historical product, and process control outcomes, and analytical testing.
The general goal of an established validation process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact the effectiveness of the food safety and quality system.
Validation activities are commonly defined within the verification schedules and procedures of established food safety and quality management systems.
The following examples may apply to validation of the limits of control or acceptability for Business Continuity and Crisis Management:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Business Continuity and Crisis Management Validation requirements in relation to their items.
You may wish to visit the Validation Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.
Skills and Knowledge: Skills and knowledge are attributes of human interactions commonly linked to competency within any specified job-related task.
Training and competency requirements for Business Continuity and Crisis Management must be ongoing, including regularly scheduled reviews to ensure the effectiveness of training and competency outcomes.
Team members who have defined responsibilities regarding Business Continuity and Crisis Management should have a knowledge including:
Team members who have defined responsibilities regarding Business Continuity and Crisis Management should have skills including:
Team members who have defined responsibilities regarding Business Continuity and Crisis Management should have access to resources including:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Business Continuity and Crisis Management Training, Competency, and Resources requirements in relation to their items.
You may wish to visit the Training, Competency, and Resources section of haccp.com for examples of best practice applications for this food safety and quality system element.
haccp.com was created to support food businesses and food industry professionals in achieving and maintaining the stringent requirements of food industry compliance.