Critical Thinking in Food Safety: What It Is and How To Use It

At the end of a food safety audit, when we—as auditors—show the quality team the list of nonconformances that were found, the immediate reaction we often get is “we didn't know that” or “we overlooked that.” In a way, that's understandable. After all, how can we know what we don't know? On the other hand, however, lack of awareness can put the quality and safety of your products at risk.

Fortunately, there is a way to bridge the gap between the known and the unknown: it’s called critical thinking, an approach to food safety that allows you to understand the risk of any potential nonconformances associated with your production process.

In this article, we'll explain what critical thinking is, how to apply it in your food facility and will also provide some practical examples of how to connect it back to the SQF Code requirements.

Critical thinking is best explained by looking at its four mai aspects.

In this section we’ll look at each of the four steps of the critical thinking process and provide practical examples of how to apply it to an internal audit to get ready for the renewal of an SQF certification.

A frequent limit that we see in internal audits is that they only take note of surface issues and don’t dive deeply enough. Observation in critical thinking, however, focuses on details and actively considers how and why things are done in a certain way, trying to uncover unknown risks for your food safety management system. Active observation is something that everyone in your facility—including line workers—should practice at all times, not only during internal audits.

Practical example. Employee observed not following the SOP (Standard Operating Procedure) for metal detection.

This is where the data-driven element of critical thinking stands out the most. While with active observation you have identified a potential nonconformance, with the analysis step you start digging deeper by breaking down the issue into smaller elements. Your goal here is to assess what level of risk is associated to the nonconformance by separating facts from feelings and opinions.

Practical example. The two main questions you want to answer regarding your initial observation are whether metal detection is a CCP (Critical Control Point) and whether the lack of compliance with SOP for metal detection was a one-off event or part of a systemic breakdown.

The SQF Code offers simple but effective guidance for this type analysis, called RIO, which stands for records, interviews and observation. By following the RIO method, you will:

• Review records, such as calibration and maintenance records, the food safety plan, the process flow, customer complaints, etc.
• Interview people on the floor and ask them about their tasks and the training they received.
• Observe how SOPs for metal detection are executed across different shifts and at different points of the production line.

You can break down the issue into smaller elements by asking the following questions:

• Have there been any complaints from customers about foreign objects in food?
• Are SOPs up to date?
• Was the metal detection process validated?
• Are rejects dealt with correctly?
• Did internal audits identify similar issues before?
• Have employees been trained?
• Is the metal detector operating at the right frequency?

Application is the ability to draw informed conclusions based on the results of the analysis and to connect these conclusions to the requirements of your certification scheme. During this step you’re basically answering the “Why” and “Where” that nonconformance does not meet the requirements of your scheme of reference.

Practical example. Depending on the gravity, the metal detection SOP nonconformance could be in breach of one or more requirements of your food safety scheme. The example below shows how this connection between findings and requirements would work within the SQF Code:

• There were customers complaints but were not managed correctly à section 2.1.3 - Complaint Management.
• SOPs in the food safety plan are not up to dateà section 2.4.3 - Food Safety Plan.
• The foreign material detection process was not validated à section 2.5.1 - Validation and Effectiveness.
• Rejects are not dealt with correctly à section 2.5.3 - Corrective and Preventative Action.
• Previous internal audits were not thorough enough à section 2.5.4 - Internal Audits and Inspections.
• Employee training is insufficient à section 2.9 – Training.
• The metal detector is not operating at the optimized frequency for that product à section 11.2.3 – Calibration.

The final step of the critical thinking process is to communicate your findings to everyone in the company, from senior management, to supervisors, to employees. The reason why we consider this a standalone step is that it’s of crucial importance and requires its own set of skills. To be effective in your communication, you’ll have to be clear and concise. Everyone should come away with a clear idea of what hazards were identified, and what requirements exactly these hazards are in breach of.

Practical example. Let’s imagine two opposite results of the investigation: in one case the lack of compliance with metal detection SOP turned out to be an isolated event, which leads to a Minor NC (nonconformance); in the other case, several issues were found, leading to a Major NC.

Here’s how you would communicate that concisely and clearly:

Employee was observed not following the Metal Detection SOP – Minor NC.

Metal Detection CCP was observed ineffective – Employee not trained, wands did not detect, reject mechanisms not functioning and 5 metal complaints in past month – Major/Critical NC.

To get to know what you don't know, you have to continually challenge your processes, removing opinions and feelings and basing your conclusions on data. Critical thinking allows you to do just that. With its structured approach, it gives you the ability to logically analyze and understand the links between your operations and the requirements of your food safety certification, helping you produce safer and better-quality food products.

By Geoff Farrell - Technical scheme lead SCFS, SCFS certification direct SG&A

As a Global Senior Technical Manager, Food Supply Chain at NSF, Geoff Farrell leads the Safe Quality Food (SQF) program, a food safety standard recognized by the Global Food Safety Initiative (GFSI). In his role, he ensures that all SQF requirements are met by clients, ensuring the safety of food products across the supply chain.