According to FSSC 22000, food businesses have to demonstrate their food safety critical activities, staff competence, and maintain records proving this competence has been verified, not presumed. This is not a simple training calendar check. The auditor will be looking for an explicit connection between position, its requirements, the training and/or experience leading to acquiring those competencies, and proving training effectiveness. The present article explains the necessary components of FSSC 22000 employees’ competency and training records, personnel competence assessment in FSSC 22000 certification process, and documents which food manufacturers in India should maintain.
Many certified organizations already carry out some kind of induction and refreshment training program. However, the certification body does not evaluate the existence of training at all. It evaluates the ability of an organization to demonstrate that it carried out, that this training was relevant and had resulted in a certain effect. This is the major difference between the current state of affairs and the requirements stated in FSSC 22000.
What FSSC 22000 Employee Competency and Training Records Actually Cover
The training and competence of the employees in accordance with FSSC 22000 does not include attendance at induction classes alone. The specification, which is based on the ISO 22000 and the further requirements of FSSC, requires three components in regard to every position that may impact the safety of the products: competence requirement, competence development or verification process, and verification documentation.
These records typically fall into the following categories:
- Job specific competency profile or skill matrix
- Identification of training need associated with the particular job
- Documentation of training (internal or external)
- Evaluation of training (after training assessment)
- Continuous training and refresher programs
When auditing the employee competency and training documentation of FSSC 22000, the auditor would usually select a few individuals from various departments and ask Human Resources (HR) or Quality Assurance (QA) to provide him/her with their entire documentation, starting with their job description to the latest refresher training.
FSSC 22000 Training Requirements Under Clause 7.2
The FSSC 22000 training requirements fall under ISO 22000 Clause 7.2 (Competence) and Clause 7.3 (Awareness), along with FSSC 22000’s extra requirements for food safety culture and food defense awareness. Together, these clauses mandate the organization to:
- Define the required competence of those individuals whose activities have an influence on food safety performance
- Provide competence by means of suitable education, training, and experience
- Develop measures in order to achieve competence, if there are deficiencies in this area, and to evaluate the success of such measures
- Maintain documented information concerning competence
- Make sure that individuals are aware of the food safety policy, their role in food safety performance, and non-conformity with food safety requirements
It is important to note that training needs of the FSSC 22000 certification program involve more than the fundamentals of hygiene and HACCP. Food defense, food fraud (VACCP), allergens, and food safety culture training must also be considered and should have their own dedicated entry on the training agenda.
Employee Competency Assessment: How FSSC 22000 Defines It
A competent evaluation of an employee according to FSSC 22000 is the assessment that a worker has the capability to carry out a food safety critical task in practice rather than only participating in a seminar on the same. The standard allows a number of assessment techniques, and most of the accredited facilities employ several of them.
One common misconception is that the certificate from the external training company is enough to prove their competency alone. Under FSSC 22000, the training given to the organisation must have been proven to result in actual changes in work habits in order to prove their competency.
Documented Information: How Long to Retain FSSC 22000 Training Records
The FSSC 22000 standard does not mention a time frame for training records retention. The standards of ISO 22000 apply to the documentation of information and the organization establishes the time frame for record retention according to its document control policy. In practice, the majority of organizations in India that hold certifications retain their employees’ competency and training records during their service period plus an additional two to three years.
- Keep records until the end of the next surveillance/recertification audit cycle at the very minimum.
- Keep records for the entire employment period and also some extra time after the employee exits.
- Keep physical and electronic versions of the record available where employees lack reading skills and/or internet access.
- Be able to retrieve the record instantly using the employee’s name, position, and training topic.
Food Safety Training Records Auditors Expect to See
The following table shows the typical records of food safety training that the FSSC 22000 auditor looks for during an audit, typically in respect of each employee, each department, and each type of training received.
Typical weakness mentioned in an audit is where there are records of attendance but no measure of how effective the training was. FSSC 22000 has requirements for evidence of success, which can be achieved by conducting a post-training examination, supervisor assessment after several weeks, or reduction of non-conformities.
FSSC 22000 Personnel Competence for Different Roles
Personnel requirements for competence in FSSC 22000 depend on the degree of impact of their work on food safety. An operator of a critical control point and an administrative worker require training, but in different measures.
In India, food processors may have poor documentation for contractor and visitor induction programs, since they do not consider themselves to be in the domain of personnel competency. However, in FSSC 22000 audits, anyone influencing product safety falls in the personnel competence domain.
How to Build an FSSC 22000 Employee Competency and Training Records System
A functional system for the maintenance of FSSC 22000 employees’ competency and training records need not involve complicated computer software. Most accredited manufacturing organizations do this using a well-formatted spreadsheet or simple document control system as long as there is consistency in the process. A good method includes:
- Link each job role to the critical food safety-related activities it does
- Determine the minimum competency required for each role (education, training, or experience)
- Create a training needs matrix based on each role and subject matter
- Provide training and document who attended, what was covered, and who trained them
- Test the competence of individuals using an appropriate methodology
- Review the impact and effectiveness of the training at set intervals
- Train periodically and immediately following any non-conformities related to that rol
It would be much easier for you to have all the information on record when required by an auditor if you keep this system centralized and not dispersed between HR records and shop floor logs.
FSSC 22000 Employee Competency and Training Records vs Generic HR Training Logs
Most food companies have their training records based on their HR training. However, such records alone are inadequate in fulfilling FSSC 22000 criteria since they are time-based instead of being competency-based. Below is a table showing the practical difference.
In cases where food companies are opting for FSSC 22000 certification for the first time, there is usually a case where an extension of the current Human Resources log is more appropriate than developing another system because competency and effectiveness factors are considered.
Common Non-Conformities in FSSC 22000 Employee Competency and Training Records
Certain gaps recur across FSSC 22000 audits regardless of industry or site size. Being aware of these ahead of an audit helps close them before they turn into findings.
- No connection between the job and its associated competencies
- Training documentation where attendance is recorded but not its effectiveness
- Lack of food defense or food fraud awareness training
- No training documentation for contractors or visitors at all
- Non-conformity did not initiate refresher training
- No updating of training matrix due to process/equipment changes
Key Takeaways
- Records for employee competencies and training within FSSC 22000 should show role, competencies required, training provided and evidence that it was effective.
- Clauses 7.2 and 7.3 of ISO 22000 outline the basic elements of FSSC 22000 requirements related to competence and awareness.
- Employee competency testing may be done via exams, demonstrating skills or observations, as long as it is recorded and repeatable.
- Food safety training records that do not include evidence of effectiveness are common audit findings.
- Competence requirements within FSSC 22000 apply to contractors and visitors as well as employees.
FAQs
What training records are required for FSSC 22000 certification?
You require a training needs matrix, training attendance, training program details, assessment results, and training effectiveness evaluation for all the food safety critical roles.
How does FSSC 22000 assess employee competency and training effectiveness?
By testing employees through various methods including tests, demonstration, or observation by supervisors, followed by an evaluation of whether the training made a difference to on-the-job performance.
How do you demonstrate employee competency under FSSC 22000 certification?
Through documenting the competency profile of every individual in their roles, together with training and assessment records.
What are the FSSC 22000 employee training record requirements for food manufacturers?
Manufacturers are required to document training needs, training itself, assessment, and effectiveness of training for each critical food safety competence.
How often should food safety training records be updated?
At least yearly and following any change in process, equipment, position, or any food safety related nonconformity.
Who needs an FSSC 22000 personnel competence assessment?
Anyone that their position impacts food safety such as production employees, quality assurance workers, warehousing and maintenance personnel, and management.
Does FSSC 22000 require a documented training matrix?
Yes, a training matrix is common practice and regularly requested in audits.