The implementation of new FSMA rules requires leaders in the food processing industry to be more prepared than ever. Preventing problems before they begin defines every new set of compliance measures. Within those rules, proactive attention to food safety is a top priority.

Last year, Food Safety outlined five Pieces of the Food Safety Puzzle. Those pieces are Culture, Commitment, Organizational Structure, Processes/Procedures, and Implementation.

We’re revisiting those five puzzle pieces with an eye to current developments in food processing markets and more recently finalized FDA rules.

Food Safety Culture

Culture can be positive or negative. Either way,  it’s defined by what employees believe and what they think they should do. The measure of the best cultures is whether employees do the “right thing” when nobody is watching. This applies to the entire organization, and it can be felt at every level. You’ll shape your organization’s culture of safety with what you measure and what you reward. Culture is foundational and must begin with managerial commitment.  Culture will naturally emerge when management implements initiatives of belief and action around food safety. Culture must also be communicated, and that communication must align with the action that is taken to establish authentic measures and rewards.

Managerial Commitment

Absence of managerial commitment will result in one of three unsatisfactory scenarios:

  • Inactivity – nothing happens
  • Lip Service – people talk about change but nobody acts on it
  • Misalignment – rewards and measures don’t match the desired outcomes

For commitment to be strong, those at the top must believe in change and communicate their beliefs in ways that will inspire others. In other words, how you communicate is just as important as what you say. Goals and performance metrics must also be consistent with the company message so that everyone is rewarded, rather than penalized, for achieving the right outcomes. Make commitment visible in three ways:

Leaders and managers can make their commitment visible in three ways:

  • Align goals with appropriate performance metrics
  • Adjust communication to match new strategies
  • Allocate the necessary people, money, and departmental cooperation

Organizational Structure

Your organization’s structure determines how work gets done. Everyone should understand their part and where it fits into the whole. Transparency about the overall process makes handing off responsibilities more smooth and effective. It’s also important to clearly define the roles, responsibilities, and language necessary to company and industry operations.

Make clear distinctions between who is accountable for an outcome and who is actually responsible for doing the work, if those roles are different. As processes change under FSMA, decision-makers have an ideal opportunity to talk to all employees and learn new workflows, so they can make the most informed decisions possible. If a department has any responsibility for an outcome, that responsibility should be defined as it fits into department operations as well as into the outcome as a whole.

Processes and Procedures

The “glue” that holds an organizational structure together consists of communication, education, training, and metrics. Establish processes (what you’ll do) and procedures (how you’ll do it) around each of these areas. Here are some questions to get you started.


Essentially, how is information communicated? In meetings? Over email? Via communication software? How often does it happen? Who communicates with whom? What do they talk about?


What’s most important for employees to learn–especially under new guidelines and compliance measures? What provisions will the company make for continuing education?


While education happens through classes or courses, training covers job-specific tasks within your organization. Who is responsible for training? When and how will it happen?


What outcomes of your safety procedures are most important to measure? How will you measure them, and what will you do with the data? How will you communicate metrics data to employees? What tools will you use at each stage?


Implementation is the final piece of the puzzle. It’s the ongoing process of identifying, planning, and executing new work within the context of your organization’s strategy. To implement change, you must have committed management, solid communication, education, and training, and authentic, useful metrics. Implementation requires ongoing planning, process change, and skills development.


Leadership must identify the current reality state or the organization, the goal state, and the gap between the two. Then plan solutions that can bridge that gap, with the understanding that processes will require significant change.

Process Change

Process change begins with a process map. Map what is happening, then map what needs to happen, and begin to reconcile the two. Leadership must first thoroughly understand current states of operation in order to accurately project the necessary steps in changed processes. Test and vet these process maps with those who are doing the work on the floor.

Skills Development

Skills development to implement new processes will require time and commitment from employees. They need to understand why the change is being made and what’s better about the new processes. The effects of change are felt most strongly in operations and production departments. The typical “fast, cheap, and on-time” mandate may tempt employees to take shortcuts, so they’ll need to be well-equipped with the tools to do their jobs thoroughly while still hitting the necessary metrics. Those tools are both physical and psychological. Both equipment and communication must align with and encourage the requirements of the ideal process map.

Much of the change you’ll address will be non-negotiable under new FSMA rules. HACCP is gradually being replaced by the more robust and prevention-focused HARPC. Implementing change will be necessary for compliance. Whether your change is efficient and effective will depend on the strength of your organization’s culture, commitment, structures, and processes.

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