Disciplining food safety violations: A key to an effective food safety plan

Handling farm workers that violate food safety rules is important in maintaining the integrity of your food safety plan. Consider these points when writing a discipline policy in your food safety plan.

How do you handle a farm worker who you see breaking a food safety rule in your operation? Most growers can answer this question without too much thought; however, they may not have a policy written in their food safety manual. When crafting a food safety manual, these things must be spelled out in a disciplinary policy as part of that manual.

When writing a food safety disciplinary policy, consideration must be given as to whether to give the farm worker a second chance or move the worker to a non-food-related activity. Both are options instead of immediate termination. There also needs to be a clear understanding regarding the circumstances under which termination of an employee will occur for food safety violations.

There is a risk when a farm worker does not comply with a food safety policy that the food they came into contact with could be contaminated. As such, the disposition of that food needs to be considered and possibly changed depending on the severity of the violation.

When operations using HACCP have a violation, they employ three steps. First, they work to correct the violation to bring the system back into compliance. Then they identify the produce that was harvested or processed during the period of noncompliance. Finally, they evaluate the noncompliant produce to determine final disposition based on the severity of the noncompliance.

The changes made regarding what will be done with the produce that was handled during the breach in policy must be outlined. This is very dependent on the type of crop being considered and the relative risk posed by the violation.

Make sure the disciplinary policy you craft is something you can actually perform. The auditor is looking for evidence of a policy written in the GAP Manual to minimize incidence of foodborne illness, visual evidence that it is taking place and documentation that it has been taking place in the past. Writing the discipline policy is the first step. Implementing the policy on your farm is the next step. Documenting that you have used it is the final step.

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