Aiming for a Food Safety Management System (FSMS)?
Why would one aim for a Food Safety Certification? The basic South African legal requirement for food production is that a food facility must comply with R962/2012. If it complies with this, and a Health inspector passes the facility and awards a Certificate of Acceptability, then food may be manufactured in the facility. This is needed for all organisations, from the smallest mobile coffee operator, to the largest pre-packaged food manufacturer.
A Food Safety Management System is a tool to manage food safety, quality and legal requirements. While R962 covers the essential legal requirements for a facility, a FSMS assists in managing quality and safety. For many manufacturers the greatest reason to apply for a Food Safety Certification is because of customer demand, particularly from retailers.
All full Food Safety Certifications will require a Food Safety Management System to be implemented. This is essentially a documented Quality Management system that describes everything that is being done on the premises and allows production to conform with all aspects of Food Safety and legality. This includes such elements as “GMP/PRP” Good Manufacturing Practice and Pre-requisite programmes, which all facilities will have, such as cleaning, pest control programmes, allergen management, facility and process layout, training needs, etc. In addition a FSMS will include an analysis of the specific needs and risks associated with your own production process, and how to manage this (HACCP – Hazard Analysis and Critical Control Points). Some more widely known certifications in South Africa are FSA (Food Safety Assessment), FSSC 22000 (ISO Food Safety System) and BRC (British Retail Consortium). FSA has recently become a stepping stone towards an FSSC22000 certification, while both FSSC22000 and BRC are internationally recognised GFSI-based Food Safety Certifications.
It typically takes a client between 6 months to a year to put a full food safety management system in place and be ready for an audit, depending on how available the quality manager/ Food technologist is and how much support they have. We would not recommend a client attempt to put a system in place in under 6 months. To be audit- ready it is necessary to have at least 3 months of documentation history, therefore, they have been manufacturing with most production documents in place for a period of 3 months. Likewise, these timelines also apply to clients going for the GMP basic and foundational level FSA audits. In addition, even once a system has been fully implemented, it will require considerable time and human resources to manage it as with most certifications every document in the system needs to be revised annually, all maintenance and calibration managed, monthly microbiological testing performed and process and HACCP documentation updated whenever a change is made to the production process, and this doesn’t even cover the continuous improvement of the system required by the certification body to show due diligence in food safety.
If a potential client requires a certification before they are prepared to purchase the product, it would make sense to try to find other clients who can buy the product in the period that the organisation is manufacturing but not yet certificated, as it may be between 6 months and a year before certification, or even longer.
Because the Food Safety System is a living system, it is also not possible to audit before manufacture, as the audit needs to demonstrate that all the processes and procedures are being followed (including cleaning, pest control, and the appropriate manufacturing methods). The alternative, which some manufacturers have done, is to negotiate with their retailer to accept their product, while giving evidence that they are working towards a Food Safety Management System and certification. Depending on customer requirements, a manufacturer may manufacture for some time with only the Certificate of Acceptability, before choosing to implement a Management System and be certified. In the interim, to booste small business, some retailers have listed products of small manufacturers on the condition that they undergo and pass a GMP basic or foundational level audit.
In summary, gaining a food safety certification is resource intensive both during the initial implementation, and in its upkeep. Applying for a certification may also be a longer term process than manufacturers originally envision, therefore this should be carefully considered as part of the business case.
Article by: Gillian de Villiers