Did your facility say what it was going to do, did it do what it said, and can you prove it?
By A.C. Fahrenholz, W.J. Pacheco and C.R. Stark As we approach the mid-point of 2022 it’s a good time to remind everyone to review their documents to ensure that your employees are doing what is written in the Animal Food Safety Plan, SOP’s and company policies. It’s easy to get caught up in the day-to-day activities and then days turn into weeks and weeks into years. A perfect example of this may be your Animal Food Safety Plan, most plans were developed and implemented in 2018 or 2019, which means the 3-year reanalysis of the plan should be taking place. During the reanalysis closely read the plan to ensure that you can do what you say. The same is true for SOPs and policies that may have been written by a previous manager. The Feedstuffs article “Do what you say, then document it” published in 2017 has some excellent points to consider as each mill reviews their documents. Many folks in the feed industry are familiar with the phrase, “If it isn’t written down, it didn’t happen.” Another favorite of ours is, “Say what you’re going to do, do what you say, and prove it.” Now, paperwork is nobody’s favorite thing, and certainly an excessive amount of time spent on documenting the trivial can be both inefficient and counter-productive. As students anywhere will tell you, busy work typically ends up leading to frustration and a general dislike for the task at hand. That having been said, this isn’t a reason to avoid documentation, but rather should be viewed as an incentive to make it worthwhile. The first step in the process is to determine what’s really important to have written down. There are four interrelated categories here: because the government says you have to, because the customer expects you to, because the boss has told you to, and because you decide to. Though often the source of some frustration, the first three are in some ways the easiest because at least you don’t have a decision to make. The fourth is a little trickier; if you’re adding something to the workload, you have to be willing to take full ownership of it. Often the biggest issue with adoption of documentation policies is working against the rationale of “we’ve never had to do this before.” This is the somewhat less pervasive cousin of “we’ve always done it this way.” As we all know, neither of these are particularly good reasons to avoid change. However, it is fair to concede that, without a well-developed rationale, it’s often going to be difficult to encourage buy-in from those outside the decision-making loop, but who are ultimately responsible for completing the tasks. So be prepared to teach others about the reasoning behind new documentation policies. As we said before, sometimes the fact of the matter is that the reason is “because we have to,” but this really isn’t going to be a satisfying answer for facility personnel. Instead, you want to be able to describe why this is important, how it is beneficial, and what kinds of problems it will help to prevent. With all of this said, at the end of the day these policies only work when they are adhered to by everyone, all the time. So, make your expectations clear. There is also a decision-making process when it comes to determining how something will be documented. Classically, the answer has been reams of paper, three ring binders, and file drawers. And for some things, this probably remains the best and most efficient answer. For example, in some cases a facility may decide that regulatory documentation is best handled by hardcopy, written in ink, and stored in a secure location. But depending on your facility, and to a large extent your workforce, there is certainly an opportunity to take advantage of technology to streamline processes. Even better, technology can make it much easier to access and share items, since things don’t have to be tied to a single person or a single physical location. Some solutions are very specific and designed for a particular purpose, such as dedicated preventive maintenance software that relies on electronic work orders, real-time inventory, and barcoding on equipment. Others are much more basic (and therefore in some ways more flexible), such as cloud-based interactive documents used to prioritize to-do’s, create checklists, or keep track of production. Regardless of how it’s done, whether it be pen and paper, whiteboard, or technical software, the goal is the same: to document what is supposed to be done, what has been done, what is still needed, and what results have been found. So, what should be written down? Again, the first answer is the easiest: whatever you must; and the first things that come into mind here are regulatory requirements. Some examples include: employee training programs and records; accident reports; environmental monitoring records associated with NESHAP, waste water, and SPCC; medicated feed documentation such as production records, assay results, and discrepancy policies and investigations; and the FSMA food safety plan, including at the very least employee training, hazard analysis, and program review documents. If your facility is involved in any third-party or customer-initiated programs, there will likely be required documentation for these as well. Keep in mind however that you need to “do what you say”, so excess information or information that is not compatible with the actual operation should be avoided. For example, if policies state that you are collecting and keeping certain records, you should be doing so. And if they are regulatory records (e.g., FSMA, Food Safety Plan), you should be prepared to show them during an inspection.
As for non-required documents (from a regulatory perspective anyway), good examples include production, quality assurance, and preventive maintenance plans. The foundations of these plans are often the standard operating procedures (SOPs), which describe how any process is to be completed. The ultimate goal of any SOP is to be easy enough to understand, but also sufficiently detailed, to allow any person to complete a task. Think step-by-step instructions. Alongside the SOPs, there should often be records which allow us to verify that a process was completed, was completed correctly, and that the results are as expected. Finally, there should be sufficiently documented human resource programs, including job descriptions, leave and sick policies, and progressive discipline. Having well written expectations and well documented activities in this area not only protects both the employee and the employer, but also helps prevent small problems from becoming bigger issues. It seems fair to say that we would all rather focus our time and efforts on making feed, working with our customers, and keeping our facilities up and running. It is, after all, what many of us are best at, and generally describes what we like best about our profession. As previously mentioned, almost nobody really likes pushing papers, and being on the floor vs. being in the office really isn’t much of a comparison. However, accountability is a very real part of the feed industry today, and that is something that everyone should want to be out in front of, rather than playing catch up. So try to think about documentation as a tool, and figure out how to make it work for your facility. Then, take the time to teach your folks not only how to do it, but also the why behind it, and work towards buy-in as well as compliance. And at the end of the day, if it happened, is it written down? Did your facility say what it was going to do, did it do what it said, and can you prove it?
