Restaurants should be prepared.
If you’re reading this article, then it’s probably safe to assume that food safety plays a critical role in your business. Maybe you’ve had complaints or a compliance audit found an area or two are falling short of state safety regulations.
Perhaps one of your competitors just experienced a disaster, such as a power outage or contaminated water, and you want to know how you can better handle these types of food service related disasters since they are likely to happen at your establishment some point down the road.
Well, I have two words for you—be prepared.
Preparation within your establishment ensures food safety, quality, and compliance. And crafting corrective action plans is a surefire way to be prepared for any food safety or quality problem that comes your way.
Follow the HACCP Plan
Being in the food service industry, you’re probably very familiar with Hazard Analysis Critical Control Point, or what most of us shorten and refer to as HACCP.
Five preliminary steps and seven principles form a good HACCP plan.
Those five steps are:
1. Assemble a HACCP team
2. Describe products and their distribution methods
3. Compile a complete list of ingredients and raw materials
4. Construct a process flow diagram
5. Meet the sanitation regulations for standard operating procedures.
After you’ve met the five preliminary steps, you then can apply HACCP’s seven principles:
1. Administer a hazard analysis
2. Find critical control points
3. Form critical limits
4. Establish monitoring procedures
5. Create corrective actions
6. Set up record keeping procedures
7. Institute verification processes.
The fifth principle is the focus of this article. Corrective actions are actions taken when a critical limit is met, such as discarding uncooked chicken breasts that have been left out of the walk-in freezer for too long or reheating a stew that fell below 135°F for a few seconds. While corrective measures such as these may seem obvious to some of you, it’s important to note that corrective measures are necessary for every food item you sell, every work procedure you perform, and every possible disaster that could hit you.
Important Components of a Corrective Action Plan
Before I go into the steps you should take to create and execute a corrective action plan, let’s go over some things every plan should include.
First, a good corrective action plan clearly states the problem that’s been investigated and identified, and second, it should list the specific steps that need to be taken to rectify the problematic situation.
For example, let’s say you caught one of your restaurant employees handling fresh vegetables with his bare hands that he didn’t wash beforehand. Your corrective action plan would then list the problem of employees not following proper procedures for preparing fresh fruits and vegetables, i.e. not washing their hands or wearing disposable gloves. Your basic corrective action steps would then be to stop and talk to the worker who’s not following proper protocol and make him discard the food he touched.
Each step should list who’s responsible for the task’s completion, what resources are needed for completion, a way to measure progress and completion, and a completion due date.
Other things to keep in mind with your corrective action plans are to make sure they’re clear, accurate, flexible, and intended to automate your organizational processes.
Steps to Follow
According to the FDA’s Code of Federal Regulations Title 21 Part 820 Subpart J—Corrective and Preventive Action, the corrective procedure you follow has to include seven different requirements, so I think it’s a good idea to use a form of each of these requirements as the steps you should follow when crafting and executing your plans.
1. Analyze Data
In this case, the information you analyze should involve your work processes, operations, audit reports, customers, and other reliable sources that detect existing or potential causes of nonconforming products. Gather plenty of internal data sources, i.e. internal audits and training records, as well as external data sources, i.e. customer complaints and servicing repairs. Be sure all data you gather is correctly captured, categorized, and maintained, and that it’s accurately and entirely received in a timely manner.
2. Investigate the Cause
Your next step is conducting a thorough investigation to determine the root of the cause of nonconformities relating to the product or process. Typical steps inside this step include identify and characterize the problem; define the degree of impact; investigate data, processes, operations, and other information sources; and then determine the root of the cause. Some common root causes I’ve seen relate to training, management, supplier quality, and documentation. The 5 Whys [KB3] is a great technique to use that helps lead you to the root cause of your problem.
3. Identify the Necessary Action(s) to Take
Once you know the cause of the problem, you can formulate the measures you need to take to correct it and hopefully prevent it from reoccurring. The degree of your corrective action has to match the magnitude of the problem. Identify any and all possible solutions, develop your action plan, and don’t forget to consider the risk posed by the problem. The FDA is likely review your actions, so be prepped and ready to discuss the appropriateness of any corrective action taken. Possible questions they might ask you are why the action was necessary to take and if it includes any subsequent actions be taken.
4. Validate Effectiveness
Did your corrective action plan work? Did it cause any potential nonconformance? These questions, as well as reviewing data after action was taken to discover if similar problems existed after the fact, are good ways to validate the effectiveness of your plan. Compliance software is also a great resource to use during this step if you have it because it provides needed visibility and the ability to track your action plan throughout its progression.
5. Implement and Record Changes
If it’s not documented, did it really happen? I ask myself that question a lot, which is probably why I take so many pictures. But in this case, it’s not only important to implement procedure changes, you have to be sure to correctly document them to further prove to an FDA investigator that action was taken and to clearly show the results. Also, review and approve documentation before you mark this step complete.
6. Share Related Information to Those Involved
If the information related to the problem and changes made aren’t expressed to those involved, it’s highly likely the problem is just going to occur again. Prevent further food safety and quality noncompliance by clearly sharing all details with every responsible party.
7. Submit for Management Review
Last but certainly not least, submit all relevant information to your upper management. Like with most things, you need their awareness and buy-in so that appropriate funds and other resources are distributed. The problem and corrective action plan impact management so don’t leave them out of the loop.
Know Your Responsibility
Like I mentioned earlier, each task within a step should be assigned to a certain person who’s responsible for completing it. So make sure if your name is listed that you know what you’re responsible for doing.
Other responsibilities include informing, training, and understanding corrective action plans. Managers are in charge of informing and training all employees, and every employee is responsible for understanding what corrective actions are and what correction action plans your establishment will follow when it falls short of industry food safety and quality standards.
Not every complaint or nonconformance triggers a corrective action plan. But when they do, you want to be prepared to rally your team to appropriate action and success.
In the food service industry, your goal is to provide safe, quality foods to consumers, and crafting corrective action plans helps ensure you’ll continue to do so.
The opinions of contributors are their own. Publication of their writing does not imply endorsement by FSR magazine or Journalistic Inc.