HOW WILL THE SAFE FOOD HANDLING DIAGNOSTIC BE DONE?
The Safe Food Handling Diagnostic is not an inspection and not a one-day checklist exercise.
Its purpose is to understand how food is actually being handled, how risks are being controlled and whether the operation is ready to meet its applicable FSSAI requirements.
The Diagnostic therefore looks at the operation through all three layers:
LAYER 1 — SECOND NATURE: WHAT CAN / USUALLY GO WRONG?
How people actually handle food during their everyday work.
LAYER 2 — RISK VERIFICATION SYSTEM For GHP, GMP and HACCP.
How risks are classified, and how GHP, GMP and HACCP related controls are created and verified.
LAYER 3 — FSSAI READINESS
Whether applicable regulatory requirements, systems, records and evidence are in place.
HOW DO WE FIND OUT?
We do not depend upon any one method.
What people say, what records show and what actually happens on the floor can sometimes be different.
The Diagnostic therefore uses several ways of understanding the operation.
OBSERVATION: We spend time where food is actually received, unloaded, stored, moved, picked, packed, dispatched or transported. We watch normal work without unnecessarily interrupting it.
QUESTIONS: We ask simple questions while people work. Not to test their knowledge, but to understand why something is being done in a particular way and what they would do if the normal situation changes.
DISCUSSIONS: We separately talk with people at the three levels -Food Handlers, Supervisors and Management. Each sees a different part of the same operation.
PROCESS TRACING: We may follow selected food items through their actual journey; from Receiving to Storage to Picking to Dispatch, or whichever occasions apply. This helps us see problems that may not be visible when each activity is looked at separately.
RECORDS: We look at the records that are relevant: receiving, temperatures, cleaning, pest control, stock/traceability, rejection/returns, calibration, training and other applicable records.
The purpose is not simply to see whether a register exists, but whether the record tells us something useful about what is actually happening.
MEASUREMENTS: Wherever necessary, we verify things that should not depend only upon visual judgement - temperature, time, storage conditions or other measurable parameters relevant to the operation.
PHYSICAL VERIFICATION: We look at the actual condition of storage areas, racks, pallets, cold rooms, equipment, vehicles, segregation arrangements, cleaning facilities, pest protection and other infrastructure affecting Food Safety.
PHOTOGRAPHS/ Videos: Photographs may be taken, with the client's permission, to record a situation that needs discussion, correction or comparison later.
They are evidence for understanding and improvement - not photographs for finding fault or embarrassing anyone.
WHO WILL DO IT?
The Diagnostic can be carried out by a Safe Food Handling Facilitator working with the people who actually run the operation or Trained Diagnostic Team of INTERNS. We have found Interns doing better job then Facilitators.
Routine observation, questions, process tracing, photographs and collection of information can be done by trained field facilitators or interns under supervision.
Interpretation of Risk Classification, GHP, GMP, HACCP and FSSAI requirements should be reviewed by appropriately experienced members of the program team, with specialist technical input wherever necessary at HQ Level.
In simple terms:
FIELD TEAM OBSERVES & RECORDS → PROGRAMME TEAM INTERPRETS → TECHNICAL EXPERT VALIDATES WHERE NEEDED
The client team is not merely being “audited”. Food Handlers, Supervisors and Management participate in helping us understand their own operation.
HOW MUCH TIME WILL IT TAKE?
We should not promise the same number of days for every operation.
A small depot handling mostly packaged dry foods is very different from a large Distribution/Fulfilment Centre handling dry, fresh, chilled and frozen foods across several shifts.
As a working approach, the Diagnostic may normally extend over 2 -4 weeks, with visits spread across different days, shifts and important operating occasions.
This does not mean that the Diagnostic Team remains at the facility continuously for 2 - 4 weeks.
It means we allow enough calendar time to see the operation as it actually happens - receiving days, busy periods, quiet periods, different shifts, dispatch, returns, cleaning, periodic activities and exceptions wherever relevant.
The exact number and duration of visits can therefore be decided after the initial Operation Profile is prepared.
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WHAT WILL COME OUT OF IT?
At the end, the Diagnostic should tell the client three simple things:
SECOND NATURE
Which everyday Food Handling behaviors are already working - and which need to change so that all operations run like Second Nature for everyone and not through Instructions.
RISK VERIFICATION SYSTEM for GHP / GMP / HACCP
Whether important risks are correctly classified and whether the required GHP / GMP / HACCP controls are being created and verified at the right level and frequency.
FSSAI READINESS
What is already in place, what needs strengthening and what is still missing for applicable FSSAI readiness.
We first understand what is actually happening. Then we decide what, if anything, needs to change.
I think this also gives us an important discipline for the eventual Diagnostic: every finding should have a source - Observed / Asked / Discussed / Record Checked / Measured / Physically Verified / Photographed.
That will make the Diagnostic much more credible without turning it into a scoring exercise.
