The 100% Solution to Worker Testing: Less-Than-Complete Employee Understanding Adds Up to Potentially Serious Food Safety Issues

Employee training has always posed challenges for food companies. Consider language, for example. English may be a second language for many employees, which raises the issue of worker comprehension. Do employees really understand the concepts and procedures being taught, particularly the importance of product safety?

No less significant is the evaluation of worker competence based on understanding of the material covered in training. Some companies do not test their employees to verify comprehension of training content. Other companies may limit test score requirements to pass or fail because of liability fears based on union contracts or other potential litigation. This reasoning continues despite the introduction of sophisticated technological tools that can effectively deliver training and accurately determine worker comprehension.

In fact, the issue of employee testing to confirm comprehension has ramifications that extend far beyond the company. The most obvious one is public health, which can be jeopardized through improper food processing, packing, and shipping by workers who were conceivably taught but may not have fully understood company procedures, health standards, and safety requirements. The other is failure to comply with tightening training standards set by the Occupational Safety and Health Administration (OSHA).

To assume that an employee successfully completed training based solely on a pass/fail standard or the achievement of an arbitrary and barely passing grade is to invite trouble. It represents an unacceptable level of risk to the public, a possible OSHA investigation that could result in fines, and the litigation that would inevitably result. This is why food manufacturers, processors, and distributors need to understand the necessity of measuring employee comprehension and why nothing less than a 100% correct score earned by each employee should be considered acceptable. After all, how else can employers possibly know how much their employees don’t really understand?

Testing to confirm training comprehension is still relatively new to the food processing industry—so new that there are few if any hard and fast requirements from the U.S. Department of Agriculture (USDA) or the U.S. Food and Drug Administration (FDA). If there is any source for guidance on testing and comprehension that might be satisfactory to regulatory agencies, it is likely to be found among regulations promulgated by OSHA. The agency requires training to be tailored to the language, vocabulary, and education level of workers, which could be an issue for plants with many employees for whom English is a second language. As with OSHA, third-party audits such as good manufacturing practices (GMP) and the Global Food Safety Initiative (GFSI) demand verification that workers fully comprehend what they’re being trained to do.

Just imagine the ramifications when testing standards and acceptable scores are left up to the individual plant. This practice may well be the root of a problem bound to surface. Worker training and testing for gauging comprehension seems to be a hodgepodge of approaches that depend on company policies, most of which are likely to produce unacceptable results. Some plants, for example, eschew formal testing by deferring to on-the-job training and verbal corrections by supervisors with no formal process for documentation of comprehension (e.g., “Go stand next to Joe and do what he does.”). A few facilities are known to be using outdated training materials, including VHS tapes probably recorded at least two decades ago.

More up to date, but equally ineffective, are lengthy PowerPoint presentations overloaded with text and presented in language that may be beyond the comprehension of workers with limited education, even those for whom English is their primary language.

Some plants are satisfied with minimum passable scores and consider workers who achieve them as having satisfactorily completed and absorbed training. Some consider an 80% correct score acceptable proof of comprehension—a tenuous supposition.

Why? Because there is always the chance that the 20% the worker doesn’t know could result in improper handling or packaging leading to contamination. Just one incident of food safety noncompliance places the public (and perhaps the employees) at risk, while the company awaits the federal investigation, litigation, and bad media coverage certain to follow.

Yet it’s actually an internal concern about liability issues from training, testing, and comprehension that makes some companies leery. This hesitation emanates from three levels: quality assurance (QA), legal counsel, and unions. Fears of liability associated with employee comprehension graded at less than 100% have led a few companies to decide not to track actual scores—a clear example of an inadequate determination of worker understanding. Another potential red light is the possibility of union grievances over job security should any of their members fail the tests—an additional barrier to effective testing and training. Those involved in QA may be tempted to establish a lower test score threshold to reduce the number, not to mention the time and cost, of employees who will need remedial training.

“The important piece of all of this is to come around and address what is missed, what isn’t understood, and then readdress it,” said Kim Onett, lead auditor for Silliker, an international firm that conducts audits of the food industry, including GMP and food safety systems. “There are always opportunities for improvement, [and] increased training keeps things current and relevant.”

Unfortunately, remediation has also been found to be inconsistent, whether it’s in the form of additional testing or one-on-one training. Sometimes remediation can resemble an intervention; because of time constraints, this too can fall short of correcting a problem. When that happens, the company has unwittingly increased its liability exposure because training comprehension was not conclusively established in such critical areas as worker safety and health (e.g., cross-contamination of pathogens from improper handling and packaging).

A Legal Option

William Marler is no stranger to the perils that result from inadequate training and testing in the food processing industry. The Seattle-based attorney has a 20-year history of filing lawsuits against food companies because of alleged food poisoning or other safety violations that resulted in injuries to either workers or the general public.

Marler said that in several cases, his successful filings have forced companies into bankruptcy or liquidation. “I think there are reasons they don’t invest in food safety until there is a disaster,” he said. “If you’re focused on producing a product, the risks of that product tend to get pushed to the sidelines. A company that is serious about a food safety culture trains and tests its employees to see if they really understand the training being given.”

His blog contains examples of worker food mishandling resulting from inadequate comprehension of safety. One example: At a California cheese company, workers’ failure to wash their hands before handling products caused microorganism contamination that led to investigations by several agencies.

Hand washing has always been emphasized in this industry, but because it didn’t happen in this case, a potentially lethal poisoning outbreak occurred. Is this another example that shows why an 80% correct rate isn’t good enough?

Marler agreed that permitting scores to fall short of 100% accuracy is unacceptable. “A company (with low standards) does not have a good food safety culture,” he said, “and those are the ones that wind up being sued.”

Response from Technology

The task of assessing actual worker comprehension and following up with remediation if necessary does not have to be hit and miss. It should not be surprising that technology, which permeates nearly every aspect of our lives, has been developed to provide training officers, employers, and supervisors with real-time data capable of evaluating worker learning and understanding.

Technology’s value in food industry training and testing became quite clear in the last decade in a report from the Texas Workforce Commission. The report contained analysis of training, evaluation, and remediation through the use of hand-held remote controls and interactive training technology applied to thousands of workers, many of whom had minimal English comprehension. The result: a 21% decrease in reportable food safety incidents, a14% decrease in worker injuries, a 24% increase in worker productivity, and a 13% increase in operating margins. The commission, noting the results, called the project “a solid success.”

Since that time, the technology, along with associated training and comprehension analysis, has become even more sophisticated. The power of technology has not gone unnoticed throughout the industry. One survey showed that approximately 20% of all food processing and distribution companies have implemented this form of training and testing.

One of its advantages, and perhaps the biggest reason for industry acceptance of this technology, is that workers do not have to be computer literate to use it. During the training, each employee receives what is, in essence, an easy-to-operate remote control device used to respond to each question. The technology is interactive and designed to keep workers engrossed in the subject matter as they learn. For non-English-speaking employees, the technology can provide multilingual information, if needed, on all critical points involved in food handling and processing.

The electronic training platform has been designed to validate worker comprehension in a practical way and to allow for immediate remediation. It accepts no scores below 100%. When employee answers are incorrect or missing, the system launches into remediation, again using remote control, until comprehension has been assured through additional testing. There is no pass/fail; there is no 80% score acceptance. Those standards just aren’t good enough.

Proof of the positive impact this approach has on comprehension, safety, and business operations comes from the companies that have used it. They now advocate insistence on 100% correct responses.

Randy Huffman, PhD, chief food safety officer for Maple Leaf Foods, Toronto, Ont., knows the value of technology-based training and comprehension. The company underwent a major product recall in 2008 after an outbreak of listeriosis—illness caused by bacterial infection—was linked to products from one of its plants.

Dr. Huffman said Maple Leaf ’s subsequent decision to implement interactive electronic training and its ability to assess actual worker comprehension supports the company’s emphasis on a strong culture of food safety.

“The key for me is how the company uses that information to make those employees better at what they do,” Dr. Huffman said. “We can engage every employee and provide them with training that they need, including food safety, because (the platform) gives us the visibility of workers who do not comprehend the material and need individual support.”

Brent Winterton, quality assurance and human resources vice president of Chudleigh’s farm and bakery in Milton, Ont., reported similar results when his baking products company switched to an interactive electronic training platform. “We now use it as a corrective action tool when a food safety element is observed and address it within 24 hours,” he said. “The ability to monitor responses is invaluable to assess comprehension or review principles for greater clarity.”

Technology ROI

Positive indicators show the return on investment (ROI) provided by technology-based training, testing, and remediation, as a number of companies are more than willing to verify. Among the indicators are:

  • Decline in recalls;
  • Decline in plant accidents and downtime;
  • Increase in employee retention;
  • Reduction in workers compensation costs;
  • Increase in productivity; and
  • Improved performance in third-party audits.

Unfortunately, some plant managers, such as those in the QA and human resources departments, may not realize the positive impact technology can have on their operations. Occasionally, internal data indicating food safety compliance may not be shared within all departments, even though this data is relevant to any department when it comes to effectively evaluating the success of a company’s training program. In this case, the data behind these leading indicators can be accessed and shared through the technology—providing useful and actionable information.

Another example of ROI is the reduction in costs associated with data entry, document storage, and retrieval. Records no longer need to be transcribed into a central database, because the training and testing data are automatically organized and archived. Companies have reported significant drops in labor and paper costs after implementing electronic record keeping.

The biggest ROI from technology, however, is its importance in creating a culture of food and plant safety—a point Marler said he frequently emphasizes. “Every company that has an outbreak wishes they would have invested the money in food safety,” he said.

Perhaps the biggest benefit of technology-based training and comprehension is its ability to quickly process and provide information that a company can act upon immediately. No one likes to admit that a current training system is inadequate. However, health and safety incidents involving workers who were thought to be properly trained are a reminder that training officers and other managers must reassess not only their training techniques and materials but also their evaluation of worker understanding.

That is especially true with testing for employee comprehension. A company whose impact extends far beyond its walls cannot afford to place itself and the public at risk. That means companies cannot accept less than perfect test scores simply to avoid the expense of remedial training. Without a thorough testing and evaluation mechanism that flags all incorrect answers, shortcomings in training will not be readily apparent—an open door to noncompliance in food safety and quality, as well as potentially serious mistakes.







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