Agriculture Reference
In-Depth Information
SOPs detail the regularly recurring work processes that are to be conducted or
followed within an organization. They document the way activities are to be
performed to facilitate consistent conformance to technical and quality system
requirements and to support data quality.
SOPs are initially developed using current local, state, or federal regulations and
requirements outlined in the audit standard, and the SOPs often codify policies and
procedures already practiced, but not formally documented previously. The SOP
should be written so that the target audience fi nds it understandable and usable without
requiring constant supervision. Copies of the SOPs should be available (both in hard
copy and electronic format) and readily accessible for reference in the work areas of
individuals performing the activity. SOPs can also be made available in foreign lan-
guages, if appropriate, to help prevent deviations from the SOP. Even the most well-
written SOPs can fail, if they are not followed properly, and management needs to
review and encourage the use of SOPs. The SOPs should outline how and what will
be documented in a record (documentation is covered later in this chapter). For many
operations, the initial implementation of a food safety plan and its associated SOPs
may constitute a cultural change, but adapting to these changes is necessary to suc-
cessfully meet audit requirements.
Food safety plans do not need to be complex, and often simpler plans, if written
correctly, work better. It is important to evaluate each policy directive and to make
sure that each is obtainable and useful. As auditors observe an operation, they note
any policy or procedure in the plan that is not being followed as “out of compliance”
in the fi nal audit report. If the maximum number of “out of compliance” issues allowed
in an audit standard is exceeded, the auditee fails to meet the requirements of the audit
standard. Care must be taken to avoid putting anything in the plan that is unobtainable
or frivolous that could jeopardize meeting the requirements of the audit standard. An
example of an unobtainable or frivolous policy in a food safety plan would be having
an SOP requiring restroom facilities to be cleaned every hour. Suppose for the sake
of this example that the usage of that restroom facility is such that cleaning it once
daily suffi ces in maintaining a clean and hygienic facility. If the facilities are cleaned
once daily and recorded in written documentation, this situation would not be in
compliance with the auditee's policy, even if the facilities are clean throughout the
day. Compliance, in this case, requires that the restroom facilities must be cleaned
every hour, even if they have not been used. Such a policy would be considered
unobtainable or frivolous. The policy should be revised to something like “restroom
facilities will be checked every hour for cleanliness, and cleaned if found to be dirty
and, at a minimum, cleaned once per day.” In this case, the restroom facilities need
only to be checked every hour, and cleaned only if dirty, at a minimum of once daily.
The written documentation of the daily cleanings, as mentioned above, would suffi ce
to ensure compliance with the auditee' s policy.
Training
It is important to understand the training requirements of the audit standard and the
auditee's food safety plan in order to successfully implement a food safety program.
Once a food safety plan has been developed, management should arrange to train all
those who are covered by the plan so that they understand and abide by it. Training
