It should be noted that the processor
needs to verify that all documented
communication methods are effective.
Processors may also develop a
register that lists all persons and/or
departments within the company that
are part of “internal communication”
that would list contact information,
highlight the means of communication,
specifically citing documented procedures, and describe situations that must
be communicated.
External communication is a little
easier to understand. The rules are the
same when it comes to food safety:
clear and concise communication. A
register is also an extremely useful tool
and great first step when highlighting
external communication. Listing all the
organizations a company deals with
can be a challenge: regulators, customers, suppliers, distributors, contractors,
personnel agencies, service providers,
trade associations and others. The same
guidelines for establishing a register and
procedures apply. It is also imperative
that the company clearly define which
group or persons should be responsible
for different external communications
and how they should be done.
With both external and internal
communication, a regular program for
verification and updating these programs must be implemented. Some may
review and update their registers monthly and others quarterly. Make sure that
all registers are dated and that the dates
are changed whenever there is a review
and update. Auditors will downgrade a
company if lists have not been updated.
In addition, auditors will ask employees
if they understand and utilize the food
safety information that was presented in
communication programs.
Management Review. The management review is another problem area.
All companies have management meetings, but the management review is
more than that. The function of management review is a high-level review to
determine whether the FSMS is effective and efficient.
How a management review is con-
ducted varies with the size of the com-
pany. Small companies are now being
required to implement management
review in response to the requirements
of GFSI-recognized audit schemes. In
small companies, one person typically
wears many hats. In a large company,
the workload will be divided. One hint
to better understand the management
system and to create the foundation for
the management review is to define who
is responsible for managing each of the
areas that comprise the FSMS. The job
descriptions for each of these individu-
als must define their responsibilities
within the FSMS. In addition, it is a
good idea to create a single document
that lists all the food safety areas and
have each responsible person sign that
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