Food First Blog | Tip of the Week: Frontline or Bottom Line: What

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Tip of the Week: Frontline or Bottom Line: What Risk Do Under-Trained Employees Present?
Tip of the Week: Frontline or Bottom Line: What Risk Do Under-Trained Employees Present?

Your best planned food safety systems are only as good as the people behind them. It’s not uncommon for food companies to invest the majority of their training budgets into their middle to upper level supervisors and managers. These valued team members often have a proven dedication to the company and are planning a career in the food industry. It would be careless not to invest in advancing their skillsets.

But, we’ve found that frontline personnel, a quantifiably larger and continually fluctuating group, are often skipped over when the annual training budget is allocated. At AIB International, we understand how profound the impact of line workers actions can be. On top of direct product handling, they’re also responsible for following the very procedures your management team has put together to ensure consumers can enjoy eating safe, delicious food.

So, what are the implications when your frontline employees don’t understand why a policy is important, or how to carry it out effectively? What risk does an undertrained frontline team truly present?

Take a moment to consider how you might respond to this accusation from the FDA:

You did not take a reasonable measure and precaution related to personnel practices”

What if your customers had access to that same report before you had a chance to respond? What defense could you offer to lessen the damage done to your reputation? More importantly, what response could your company offer when training failures lead to a public health risk?

We’ve partnered with FDAzilla*, the industry’s leading platform for GMP inspection analytics, to better understand the implications that poorly implemented personnel practices can have. From their platform, we were able to quickly identify all companies who have been cited with CFR 117.10 citations and then download the associated Warning Letters and 483s for those inspections. The information was sobering as we fully realized how many facilities – from family-owned operations to national brands – violate these foundational elements of the Good Manufacturing Practices regulation. Read the FDA statements below – lifted straight from publicly-accessible Form 483s and warning letters – and ask if the same could observation could be made at your facility.

Handwashing Matters

"Three employees changed their gloves without washing their hands when they changed the type of meat during manufacturing for various ready-to-eat sandwiches. Furthermore, the same employees touched non-food contact surfaces, left the room and returned to manufacture ready-to-eat sandwiches without washing their hands."
“Multiple maintenance employees entering the production area from the maintenance office entered without washing and sanitizing hands and proceeded into the area to maintain food contact conveyor equipment carrying exposed in-process food.”
“Our investigator observed employees touching shelled pecans with bare hands that were not washed after touching non-food contact surfaces such as doors and stools.”
“A male employee was observed wiping his head using paper towel. The employee washed his hands with water only and then proceeded to pack rice into bags. The employee did not use soap and sanitizer when washing his hands.”
“A male employee was observed wiping his head using paper towel. The employee washed his hands with water only and then proceeded to pack rice into bags. The employee did not use soap and sanitizer when washing his hands.”

Where’s Your Utensil?

“An employee was observed using his bare hand to transfer bulk salvaged cream cheese from the pail to the cook kettle”
“Employees were observed reaching into dry ingredient pails to retrieve scoops to add dry ingredients into their respective cook kettles. After adding a dried milk powder from a dried ingredient cart, the employee was observed placing the scoop into the cart in such a way where the handle of the scoop was touching the ingredient.”

The Surface Matters

“An employee was using a cloth towel soaked in detergent solution to wipe the non-food contact surfaces of the machine and then the food contact surfaces”

That Doesn’t Belong

“Broken pieces of glass of various sizes were observed on floors and in cracks of floors in the processing/bottling, bottle rinser, labeling, case packer, case palletizing, and warehouse areas. The past 3 years of FDA inspections noted the same observation of broken pieces of glass lying on the floors.”

What You Wear Matters

“An employee was observed to be making ready-to-eat egg and cheese croissant sandwiches to be packaged for sale, when the top of the croissant fell onto the employee’s shirt, with no apron being worn, the employee placed the top of the croissant back onto the sandwich and packaged it for sale.”

That Doesn't Belong Here

“You failed to store clothing or other personal belongings in areas other than where food is exposed or where equipment or utensils are washed, as required by 21 CFR 110.10(b)(7). Specifically, we observed several employees store their personal items such as beverages, keys, and purses on the bottom shelf of all the prep tables during the manufacture of ready-to-eat sausage sandwiches. Employees were observed to drink from personal beverages during manufacturing.”
“We observed an employee lean against a stainless steel prep table for the meat slicer while using their cell phone in the processing room during the manufacture of ready-to-eat sandwiches.”

Keep it Covered

“An employee was observed cracking eggs with no beard cover on. Employees were observed manufacturing ready-to-eat sandwiches, while not adequately wearing hair nets and beard covers to cover all exposed hair.”
“One employee was observed not wearing a hair net properly, exposing hair on the side and front of her head while repacking baking powder into packages. This is a repeat observation from the (2012) and (2013) inspections.”

Don't Eat in Here

“A group of people touring the facility was observed eating food in the processing area. An employee removed tortilla chips directly from the line and allowed the group to eat the tortilla chips while in the room. The group was also observed eating from packaged finished product provided to them within the same room.”
“We observed several used bottles of water and empty containers of food in the repacking area, directly adjacent to the product conveying line.”

Keep Doors Closed

“We observed the docking bay door at the end of the warehouse closest to the product refurbishing area, open from 11:00am to 11:28am and 11:32am to 11:45am, which allowed three and four different birds to fly into the food warehouse facility”

The everyday actions of your frontline team can have major food safety and regulatory implications, placing consumers at risk and ultimately hurting your bottom line. Are your employees making seemingly small mistakes that the FDA will hold you accountable for? 

AIB International offers an affordable, online solution to equip your frontline workers. This formative training program includes 15 lessons that support all of your food safety programs – from GMPs and allergen control to pest management and cleaning practices. Written by food safety professionals for frontline workers, Food Safety Essentials reduces the time spent scheduling and budgeting training with an automated system that instantly records and updates your training records. Don’t get caught off guard when the FDA investigator arrives! Use Food Safety Essentials to help your frontline protect your bottom line.

*FDAzilla provides actionable information on FDA-regulated companies to help food companies monitor key players along their supply chains. Learn more about FDAzilla at:

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