Management of training

Contents

• The standards
• The requirements
• BRCGS Food safety Issue 9

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 7.1.3 Documented training programme 7.1.4 Allergen training 7.1.5 Packing and labelling training 7.1.6 Training records 7.1.7 Competency review
BRCGS Packaging Issue 6	6.1.1 Initial training and supervision 6.1.3 Communication of updates 6.1.4 Ongoing competency 6.1.5 Training records 6.1.6 Documented training programme 6.2.5 Induction training
BRCGS Agents & Brokers Issue 3	5.1.1 Initial training and supervision 5.1.2 Training procedures and records 5.1.3 Competency review
BRCGS Storage & Distribution Issue 4	8.1.1 Initial training and supervision 8.1.2 Training matrix 8.1.3 Training records 8.1.5 Competency review 8.2.2 Induction training and site procedures
FSSC22000 Version 6	ISO 7.2 Competence
IFS Food Version 8	3.3.1, 3.3.2 Documented training and instruction programs 3.3.4 Training review
SQF Edition 9	2.9.1.1, 2.9.1.2 Training requirements 2.9.2.1, 2.9.2.1.viii Training program 2.9.2.2 Training languages 2.9.2.3 Training records

The requirements

Procedure

There must be a procedure in place which defines the training programme for:

• Initial (induction) training, including basic food hygiene level, to a level appropriate for the business (e.g. including high-risk principles where needed).
• Visitors, contractors and third-party engineers.
• Subject matter training, including level of training.
• Job based learning; procedural and CCP training.

The procedure must also define how the following will be managed:

• Supervision.
• Competency.
• Language.
• Records.
• Updates or changes.

When updates are made to documentation that’s used for training, there must be rules that define when training must occur, including:

• When a change doesn’t require retraining.
• How changes will be implemented and maximum timeframe from publishing to completion of retraining.
• How document changes will be communicated to those who provide the training.

Training materials including procedures will be updated when the need is identified from:

• External or internal audits.
• Competency checks.
• Complaints.
• Non conformances.
• Changes to the business, including product and process.
• Training on the role that they are to carry out, so they know what their responsibilities include.
• Company policies and procedures relevant their role, including product safety control points.
• Inspection and testing procedures relevant to their role.

Basic training

Prior to beginning work, new employees, temporary staff, and contractors are trained basic food hygiene, relative to their role and level of responsibility.

Training assessment

Role-based training

To establish what training is required, the competencies for each specific job role (which covers safety, legality, authenticity and quality) must be assessed, and:

• The job roles listed.
• What task-based (procedural) training is required for each role.
• What subject matter training is required for each role.
• What level of subject matter training is required for each role.
• Where staff perform specific tasks, procedural training must be provided on those tasks. This will involve training staff on:
  • Procedures.
  • Principles of good manufacturing practice, e.g. personal hygiene policies, glass policies and allergen policies.
  • Standard operating procedures for equipment.
  • Work instructions for operational tasks.
  • Cleaning instruction cards (CICs) for hygiene tasks.
  • And any documents or activities which ensure that the Standard is met.

Staff must be provided with training to complete their role, including procedural training for the tasks that they are responsible for.

The level of training of subject matter training must be appropriate to the individual’s role.

Taking the subject of allergens, as an example:

• Those who do not work with allergens may require just an awareness of the safety implications of allergens (allergen awareness training).
• Those who carry out allergen control tasks that are critical to the safety of the product.
• Those who are responsible for developing or managing the allergen management system will need in-depth allergen training.

Training matrix

A training matrix can be used to ensure that training is completed and kept up to date.

Training delivery

Training may be delivered internally or externally.

Where training is provided internally, there must be evidence that the trainer is competent.

Where training is delivered by external suppliers, reputable training providers must be used who specialise in the delivery of that subject.

The delivery of training must be appropriate to the learning requirements of the trainee, this includes:

• Consideration of language.
• Where needed, translators must be provided.
• The use of images to aid understanding.

Competency

The training must be verified using competency checks.

The type of competency required must be determined using risk assessment. This must include:

• The frequency for routine competency.
• What to do when there’s a change which impacts training (such as a version change of a procedure).
• Other aspects that would trigger retraining.

Where competency tests are used, any wrong answers must be reviewed with, and corrected by the trainee, to demonstrate full understanding.

Competency is split into 2 parts:

1. Initial competency following training.
2. Ongoing competency.

The initial competency checks must include:

• How the initial competency check is completed.
• Maximum time frame between the training and the initial competency check.

Ongoing competency checks must include:

• The frequency at which the learner will be assessed to ensure they continue to be competent.
• How this competency check will be completed.

Ongoing competency checks may include:

• Coaching assessment.
• Observational assessment.
• Tests or exams.
• One to one appraisals .
• The delivery of refresher training.

Refresher training and education are done at a minimum of annually or more often as needed.

Training records

Records of training must be kept and include:

• The name of the trainee to confirm their attendance.
• The date.
• How long the training took.
• The course title or procedure name, reference and version number.
• The name of the training provider (if external).
• A summary of the curriculum where internal training presentation has been used, or a copy of the presentation.
• Where verbal translation is used during training, the translator must sign the training record and the language used must be recorded.

There are instances where formal training is not necessary and other methods such as tool box talks may be used.  Where this is the case, the above rules around recording of the training must still be applied.