12. Training and competency
Basic training
How to ensure that all staff are sufficiently trained before working unsupervised
The standards
This article is written to meet the following sections of the standards:
| BRCGS Food Safety Issue 9 | 7.1.1 Initial training and supervision 3.4.2, 3.4.4 Auditor training and documented inspections 4.1.4, 4.2.4 Food defence and security training |
| BRCGS Packaging Issue 6 | 6.1.1 Initial training and supervision 4.4.2 Site security and product defence training 3.5.3 Competency of internal auditors |
| BRCGS Agents & Brokers Issue 3 | 5.1.1 Initial training and supervision |
| Storage & Distribution Issue 4 | 8.1.1 Initial training and supervision 4.2.3, 5.2.3 XS Site and vehicle security procedures training 3.2.2 Auditor competency training |
| FSSC22000 Version 6 | ISO7.3 Food safety awareness training 2.5.6.f Allergen awareness training |
| IFS Food Version 8 | 3.3.2 Documented training and instruction programs |
| SQF Edition 9 | 2.9.2.1.iii, iv, vii Training program (Mandatory) 11.2.4.1.ix Pest prevention awareness training |
| Additional customer requirements | M&S |
The requirements
All product handlers must be provided with a basic level of training. The purpose of this training is to ensure that they understand the minimum requirements when working with products, so that they don’t cause contamination problems by mistake.
Induction training
All staff must be appropriately trained prior to starting work.
Initial training should include:
- Awareness training; allergens, pests, product defence, right product-right pack.
- General company rules, including site security and access procedures, clean as you go and general cleaning principles.
Where nuts and sesame must not be brought onto site by staff, this requirement must be clearly documented in the site’s allergen policy, stated in the site rules, and must be explained during the induction.
Basic food hygiene training
All staff must complete Level 2 Food Safety training (or equivalent*) within 12 weeks of starting work. Learners must have successfully completed an assessment to prove that they have understood what they’ve been taught.
The training must include:
- A basic introduction to hazard and risk management, and awareness of relevant product safety control points.
- A qualification that is equivalent to ‘basic food hygiene’ or Level 2 Food Safety.
If mandatory training is not required by regulation, food safety training is implemented annually to develop the food safety culture.
* Training does not need to be accredited. This is covered in more detail within the accreditation section of this article.
Product defence awareness
All staff must be trained in product defence awareness and security procedures. This must include:
- That staff are encouraged to challenge strangers and visitors not wearing ID, or refer them to security.
- An awareness of the implication of poor product security.
- Protection measures for product defence.
- Evidence of tampering.
- Reporting of product defence threats.
Pest awareness
All staff must be trained in pest awareness, so that they know how to:
- Identify signs of pests.
- Report signs of pests.
- Follow procedures which prevent pest ingress (such as closing of doors).
BRCGS Food Safety Issue 9
4.1.4 Although the content of this clause isn’t new (it’s been moved from 4.2.3 and 4.3.2) because the information has been brought together under a new clause reference, there will be increased focus on the requirements.
Additional clarification has also been added which states the minimum training requirements for security.
Allergen awareness
All staff on site must have documented allergen training that includes:
- Explanation of what anaphylaxis is.
- Common and legally required food allergens.
- What all staff must do to control allergen contamination, such as handwashing and not touching materials unless they’re authorised to do so.
- An overview of the controls used within the business to prevent contamination with allergenic materials.
- If free-from products are handled on site, an overview of these specific controls.
Product defence awareness
Product defense awareness training must be completed annually.
Accreditation
Is an accredited qualification a requirement of the standard?
To be clear from the outset – accredited, certified, endorsed or approved training is not a requirement of any of the GFSI Standards, or customer requirements. However, the training must be at least, equivalent to.
To understand this, you need to understand the different terms, and the positives and negatives of each type of training:
- Accredited training
- Certified training.
- Approved or endorsed training.
What is accredited training?
Accredited training means that both the training provider and the qualification they provide, are governed by an official body. In the UK, the governing body that manages training providers and qualifications is ofqual.
A ‘qualification’ has to be an accredited training course, if you follow the exact meaning of the term ‘qualification’ under the ofqual recognition standards. This means as far as ofqual are concerned, you can’t have an ‘unaccredited qualification’.
Accredited qualifications are provided by awarding bodies – these are governed by ofqual and ofqual set the structure for the training. For example, in our industry we use the ‘Levels’ -so it’s ofqual that specify what Level 4 training must be.
The awarding bodies don’t necessarily provide the training themselves though. So, they approve training providers to do this. The awarding body then have to make sure that the training providers all are working to the same standard, the standard set by the awarding body to meet the conditions of recognition for ofqual.
So, if you go for a HACCP Level 4 qualification for example – it will be provided by an awarding body that’s governed by ofqual. If you look at your certificate, you’ll see it will have the ofqual logo on it and also the logo of the accreditation body that provided the qualification. And it will also have the trainer provider details on it too.
What are the benefits of accredited training?
When you go for accredited qualifications you know what you’re getting, because there’s a set standard that all awarding bodies have to work to. They must make sure that the training providers are all working to that standard too.
The qualification will be benchmarked to the required level as well. So, no matter where you get a level 4 HACCP qualification from, they will all provide you with the same level of training.
This is why, historically – accredited training has always been the way to go. And it’s this culture within our industry, that’s led most people to believe that it’s actually a requirement – when it’s not. You don’t even need to use external training at all.
However, before jumping ship and going for the in-house training option, there are few things you need to bear in mind. Yes – it’s totally acceptable to run in-house courses yourself, but you do have to be competent as a teacher to do it. This means you have to have at least, train the trainer training and you have to have undertaken an accredited qualification in the subject you’re going to teach. And, the qualification you hold, must be higher than the level you’re going to teach. Plus, you will have to prove to an auditor what you taught during the course – so you’ll need to document control all of your training materials to do this.
What are the negatives of accredited training?
To explain this properly, we’ll tell you a story…
In 2017, when we were launching our first set of level 2 food safety courses, we made the decision to become an awarding body. We did this because we knew that there was an expectation in our industry, that to have a good quality training course – it had to be accredited.
The journey to becoming an awarding body was new to us, so we went into the process with total dedication. We were confident that our experience, knowledge and qualifications, together with our expertise in compliance and the ability to work with regulations would be of benefit. Then, during the process of becoming recognised by ofqual, we made a huge discovery….
In order for a qualification to be recognised by ofqual, it had to be comparable to other qualifications already available. That makes sense – right? Well that depends…
What this means is, it has to be comparable to the structure and curriculum content that is already available. So, we were trying to become an awarding body because we wanted to get our product specific level 2 courses accredited. However, there were not any comparable product specific level 2 courses out there at that time. Which meant, that we had to try and compare our courses to the available level 2 food safety for manufacturing curriculum – and they just didn’t align.
We purposefully wanted to bring level 2 training into the 21st Century, but we couldn’t if we were ofqual recognised, because we would have to continue to provide a qualification that’s comparable to what’s already out there (that was designed probably in the 1970’s).
This meant that the ofqual framework just didn’t work for us. We didn’t want to be constrained by practices that we felt were out-of-date and required us to change our training to fit a mould that badly needed updating in our opinion. The framework was also structured around a large organisation employing many staff.
Which is why, in the end – we decided not to progress with our application to become recognised by ofqual.
Our conclusion of accredited training
This means there’s a place for accredited qualifications as long as you remember that the aim is to provide the best quality course, that achieves the desired learning need.
And this is why there are negatives to this type of training. We’re sure that you’ve experienced some of these negatives yourselves:
- The curriculums tend to be out-of-date for today’s industry and standards.
- You have to learn specific elements in order to pass the exam, and then you never use them again (because the focus is on achieving the curriculum not gaining competency and skill in the subject).
- The qualifications can’t be adapted. A training provider can add on specifics for your site, product and process – but you’ll still end up with a generic qualification.
What is certified training?
Training which has been certified means that it’s been assessed and approved by someone. The ‘someone’ however, can be anyone.
The most popular certification for training is using CPD and to become certified you have to pay them a fee and then submit your training for assessment. Once approved, you can then use their logo to show that course has been approved by them.
What the benefits of certified training?
If you belong to a scheme like the Institute of Food Science + Technology, you have to complete a certain amount of training each year, for your personal development. CPD certified training allows you to assign your CPD hours to your personal development.
However, this unfortunately is the only benefit we can identify. And we’ll explain why….
What are the negatives of certified training?
Here’s another story, direct from our own experience again…
In 2016 we applied to CPD and paid the fee (which wasn’t cheap) to become certified. We sent them access to our course content and filled in the required forms – which asked for a brief description about the training and the learning outcomes. The course was assessed and passed so we were then able to put the logo on our website and other materials.
The course that we submitted was our Food Fraud & Vulnerability Assessment course, which was new to industry with no-one else providing this. The subject matter was unknown to CPD and we had to supply the answers to the questions for it to be approved. It took just 6 working days – we were happy at the time for the approval, but it has made us question what the value is in becoming certified. They didn’t know anything about the subject and therefore, couldn’t have been able to tell if we were teaching something correctly or not. We also realised afterwards, that there doesn’t seem to be any particular standard, that you have to achieve. So, it’s unclear what you’re being assessed against.
Which is why, at renewal, a year later- we didn’t see the value in handing over the amount of money that was expected again, just to have a logo on our website – so we didn’t! We always provide details about how long our training takes in our eLearning specifications though – so that learners can see what their equivalent CPD hours would be if they use these.
Our conclusion about certified training
We do think that there’s a place for certified training, but you just need to be acutely aware of – is that when you see a certified logo, it doesn’t mean that they’re saying the course is of good quality. Its our experience, that it’s just checking that the fundamental aspects of training are there and the CPD hours are valid.
Approved or endorsed training
There are many examples of ‘approved’ training. You’ll probably have seen some of these:
- EHO approved
- Approved by RoSPA
- Institute of Hospitality endorsed
The benefits of approved and endorsed training
This type of approval or endorsement can be beneficial, if the body that’s approving it specialises in that specific subject matter. They’ll have the experience and knowledge to be able assess whether the course is providing a good level of training.
The negatives of approved and endorsed training
Although approvals can be good, you’d need to think carefully about what they mean and how they’ve been applied. For example, EHO approved – just means that someone who used to be, or is an EHO has looked at the course and approved it. It’s not an official approval against a set standard and, you don’t know how long ago it was done.
Approved by RoSPA is good, as RoSPA are subject matter experts. But you’ll find their logo being advertised where food safety courses are displayed, which is very misleading as RoSPA are not food safety experts. They specialise in health and safety, so you have to consider who has approved the course, and whether that adds value to the type of course you’re looking at.
The Institute of Hospitality endorsement can also add value, if the course you’re considering is kitchen and hospitality related – which for our industry doesn’t mean anything unfortunately.
‘Equivalent’ training
When you see expressions such as ‘equivalent to’, or ‘meets the requirements of’ – this means that you don’t have to use accredited training, but you do have to ensure that the curriculum is to the same standard. To comply with this, you must ensure that you have a training specification for the course that you’ve chosen, and that specification must either state that the course is equivalent to the required accredited course, or you must be able to prove that the curriculum compares.
Are Techni-K courses accredited?
There isn’t a method available to accredit our training, which will add value. But we value the needs of our customers and understand the importance of accreditation – so we have our own endorsement programme.
We use subject matter experts to review our training for us. This ensures that we remain at the forefront of improvement and can provide our customers with the best available course content that has been fully inspected and approved.
In true Techni-K style, we’re being completely transparent about the process and the feedback that is provided to us by the independent experts. To find out more about the process and who we have selected, take a look at our Techni-K Endorsement Programme page – where you’ll see an example of a very well respected expert, who has endorsed our product defence training. Professor Chris Elliott
Basic food hygiene or Level 2 Food Safety?
All staff who handle product, need to have completed a basic food safety course. This type of course was once called basic food hygiene training, which was then superseded by Level 2 Food Safety.
Today, we think our Food Safety & GMP training courses for operatives are the new standard in this type of training. To find out more here.
Surely within BRCGS V8 obtaining a qualification in “basic food hygiene” for food handlers is optional, as with “the following training options may be considered:” as opposed to “form of an induction and should include: A qualification that’s equivalent to ‘basic food hygiene’ or Level 2 Food Safety.” which indicates something entirely different to BRCGS.