ISO 22000:2018 – 5.3 - Organizational roles, responsibilities and authorities

 

                    

Welcome back to this blog. I hope the approach used here to break down and analyze the different requirements of these management system standards will help to reinforce your understanding of the different requirements somewhat. I hope this information is of interest to you.

 

In previous entries we dealt with the requirements corresponding to Section 5.2.1-Establishing the food safety policy, and we did so in two parts, due to the importance and complexity of the requirements derived from said section, as well as the requirements derived from Section 5.2.2 – Communicating the food safety policy.

 

On this occasion we will focus on analyzing the requirements derived from the last sub-clause of those that make up Clause 5 - Leadership, and I am referring to Subclause 5.3 - Organizational roles, responsibilities and authorities.

 

As I have explained to you in a previous entry, the food safety policy is the most important element of a food safety management system, because all the processes and activities carried out by the organization within that FSMS will be to comply with the aforementioned policy. That is why in this group of requirements of this standard, derived from Section 5.2.2, all of them refer to this food safety policy, specifying how, and to whom, this element of the food safety management system should be communicated.

 

In that Section 5.2.2, the ISO 22000:2018 Standard establishes a series of requirements, all directed to top management, since if you remember, we are still analyzing Clause 5 - Leadership, and all requirements that derive from this Sub-clause 5.3 refer to the exercise of leadership by top management to assign responsibilities and authorities at all levels of the organization. Below I present to you the list of these requirements derived from Sub-clause 5.3, and I present them with the corresponding progressive numbering, as we have been presenting, individually, all requirements of this ISO 22000 Standard that have been analyzed:

 

 

 

If we apply the appropriate correction corresponding to ISO 22000 Standard, the Technical Specification TS 9002:2016 - Quality management systems — Guidelines for the application of the ISO 9001:2015 Standard, in relation to this Subclause 5.3 - Organizational roles, responsibilities and authorities, mentions that the intent of this sub-clause is for top management to assign relevant roles related to food safety management system, in order to ensure effectiveness and the achievement of intended results. Top management will need to establish specific responsibilities and authorities for those roles, and ensure that people in the organization understand and are aware of their assignments through effective communication activities.

 

It also indicates that responsibilities and authorities can be assigned to one or more people. They should be able to make decisions and effect changes in the area and/or processes to which they have been assigned. It is essential to emphasize that although authority may be delegated, overall responsibility and accountability for the food safety management system remains with top management.

 

It mentions that in some organizations there may be a limited number of people available with the necessary competence to carry out the required tasks; it might be helpful to plan so that roles, responsibilities and authorities are shared. Such plans are valuable during vacations, when managers are not on site, or in cases of accident or illness.

 

Top management, in accordance with TS 9002: 2016, should determine the manner in which relevant roles, responsibilities and authorities are communicated. This could be done through the use of relevant documented information, e.g. job descriptions, work instructions, duty statements, organizational charts, manuals, procedures.

 

The responsibilities and authorities to be assigned by top management to the relevant roles within the food safety management system are closely linked, but are not the same, and are therefore presented here as different elements of different requirements.

 

If there are several people who carry out the same role within the FSMS, the responsibilities assigned to them should be practically the same, for the performance of their roles, but in the case of the assignment of authorities, the situation changes, since the top management should decide to whom of these people will assign the necessary authorities to make decisions and give orders to others.

 

In accordance with the list of requirements presented above, the next one to be analyzed, first of this sub-clause, is the following:

 

 

Requirement No. 86: Top management shall ensure that the responsibilities for relevant roles are assigned within the organization.

 

What this requirement points out is that top management should first identify which are all relevant roles to the food safety management system.

 

As you may have noticed, this standard includes commonly used terms, but there are some of them that supposedly we all clearly understand, but in fact each person understands those in a different way.

 

That is why it is convenient for us to look for a dictionary and use it to find the definitions of these types of terms that can cause confusion if we do not understand and use them in the same way.

 

For example, among the terms that can cause this type of confusion, we have the following:

 

In light of this definition, the organization should identify all activities that are performed by one or more persons, for a particular operation or process that is relevant to the food safety management system. It is worth clarifying that, for this task, it is generally not convenient to include all the roles or functions that are performed in the organization, but only those that are relevant to this system. Among the roles that most organizations can identify, that are relevant to the FSMS, we could mention the following: food system team leader, food system team members, processes owners, processes operators, those who create documented information, those who update it, those who control documented information, those who generate records (documented information as evidence of conformity), those who maintain records (documented information maintained as evidence of conformity), inspectors, supervisors, verifiers, internal auditors, those who identify and document non conformities, those who initiate corrective actions, those who plan, carry out, verify and close corrective actions, among others.

 

Once we have identified what the term "role" means, in order to identify the pertinent roles of the FSMS, it is convenient to consult other definitions, such as those presented below:

 

We can understand, then, that once top management has identified all these relevant roles, it should ensure that, through the deployment of its entire chain of responsibility and authority, each of these relevant roles for the FSMS have been assigned their corresponding responsibilities, that is, that it has been indicated, for each of these roles, all the obligations that correspond to it for the fulfillment of the duty.

 

There is a situation that is worth rising so that it is well understood, as we saw it in TS 9002:2016. Even though responsibilities should be assigned for all relevant roles within the FSMS, top management cannot delegate these responsibilities, they can only share them, but this top management will always have primary responsibility and accountability for the food safety management system.

 

When assigning responsibilities for the relevant roles within the food safety management system, top management should take into account that those responsibilities should be clearly assigned to each role and should be sufficient for the person(s) to whom they are going to assign, be able to fulfill the entrusted role.

 

 

Requirement No. 87: Top management shall ensure that the responsibilities for relevant roles are communicated within the organization.

 

In accordance with this requirement, top management should ensure that, once responsibilities for relevant roles to the FSMS are assigned, they are communicated throughout the organization.

 

To achieve this, it will be important for the organization to present these assigned responsibilities as documented information, either generally in a food safety manual, on a web page, or as the organization has arranged to present and describe its food safety management system, so that all personnel have access to this information, and it can also be done in a more specific and better described way in documentation of processes, procedures or work instructions.

 

This ensures that the personnel who carry out these types of roles for the FSMS clearly know what activities they are responsible for carrying out, and that all personnel know who carries out those relevant roles of the FSMS and what their corresponding responsibilities are.

 

 

Requirement No. 88: Top management shall ensure that the responsibilities for relevant roles are understood within the organization.

 

The intent of this requirement is to ensure that all personnel have a proper understanding of what those relevant roles are, and what are those responsibilities associated with each of these roles.

 

Top management will need to establish specific responsibilities for those roles, and ensure that people in the organization understand and are aware of those assignments, in order to ensure the effectiveness of the FSMS and the achievement of the intended results.

 

That is why top management should establish mechanisms to ensure that all staff understands these responsibilities, such as informational meetings, workshops, seminars, evaluations, among others, and generate evidence of understanding of said responsibilities, at the level of understanding that it deems appropriate to estimate that they have been understood by the entire staff of the organization.

 

 

Requirement No. 89: Top management shall ensure that the authorities for relevant roles are assigned within the organization.

 

To better understand this requirement, it is convenient to also present the definition of the term “authority”.

 

 

Once top management has identified all the relevant roles for the FSMS, it should ensure that, through the deployment of its entire chain of responsibility and authority, each of these roles has been assigned its corresponding authorities, that is, that it has been pointed out, for each of these roles, all the official power to make decisions for other people or to tell them what they must do, in their delimited scope.

 

As we have seen, when an authority is assigned to a specific role, it is granted the right to give orders or make decisions, within what corresponds to said role. Contrary to what is indicated in requirement No. 116, concerning the case of responsibility, the authority is delegated.

 

When assigning authorities to the relevant roles within the food safety management system, top management should take into account that these authorities should be clearly assigned to each role and should be sufficient for the person(s) to whom they are going to assign, be able to fulfill the entrusted authority. No more, no less.

 

 

Requirement No. 90: Top management shall ensure that the authorities for relevant roles are communicated within the organization.

 

In accordance with this requirement, top management should ensure that, once authorities are assigned for the relevant roles to the FSMS, they are communicated to the entire organization.

 

To achieve this, it will be important for the organization to present these assigned authorities as documented information, either generally in a quality manual, on a web page, or as the organization has arranged to present and describe its food safety management system, so that all personnel have access to this information, and it can also be done in a more specific and better described way in documentation of processes, procedures or work instructions.

 

With this, it is ensured that the personnel who carry out these types of roles for the FSMS know what activities they are responsible for carrying out, and that all personnel know who carries out those relevant roles of the management system and who their corresponding authorities are.

 

 

Requirement No. 91: Top management shall ensure that the authorities for relevant roles are understood within the organization.

 

The intent of this requirement is to ensure that all personnel have a proper understanding of what those relevant roles are, and what are those authorities associated with each of these roles.

 

Top management will need to establish specific authorities for those relevant roles, and ensure that people in the organization understand and are aware of those assignments, in order to ensure the effectiveness of the FSMS and the achievement of the intended results.

 

That is why top management should establish mechanisms to ensure that all staff understands these authorities, such as briefings, workshops, seminars, evaluations, among others, and generate evidence of understanding of said authorities, at the level of understanding that it deems appropriate to estimate that they have been understood by the entire staff of the organization.

 

 

Requirement No. 92: Top management shall assign the responsibility for ensuring that the FSMS conforms to the requirements of this document.

 

Top management should assign for one or more persons the responsibility that the food safety management system conforms to requirements of this ISO 22000:2018 standard, to ensure that the FSMS considers all the specific roles necessary, such as internal auditors, or for management review, among others, not only regarding the roles of the food safety team. In the event that this authority is assigned to more than one person, it will be important to define their areas of action, so that there is no interference between them.

 

 

Requirement No. 93: Top management shall assign the authority for ensuring that the FSMS conforms to the requirements of this document.

 

Top management should assign for one or more persons the authority for the food safety management system to conform to requirements of this ISO 22000:2018 standard, to ensure that the QMS considers all specific roles required, such as internal auditors, or for management review, among others, not only regarding the roles of the food safety team. In the event that this authority is assigned to more than one person, it will be important to define their areas of action, so that there is no interference between them.

 

 

Requirement No. 94: Top management shall assign the responsibility for reporting on the performance of the FSMS to top management.

 

If we remember that top management maintains the primary responsibility and accountability for the food safety management system, it is essential that it is kept informed of the performance of this system.

 

In accordance with Technical Specification TS 9002:2016, this reporting is typically carried out as part of the management review process (see ISO 22000:2018 Sub-clause 9.3); One person might be assigned responsibility for coordinating reporting, with other people taking responsibility for reporting on specific food safety management system processes.

 

In this assignment of responsibilities, top management should take into consideration, that this standard establishes, in paragraph 5.3.2.d) that the food safety team leader shall be responsible for reporting to top management on the effectiveness and suitability of the FSMS.

 

 

Requirement No. 95: Top management shall assign the authority for reporting on the performance of the FSMS to top management.

 

Considering, as mentioned in the previous requirement, that top management maintains primary responsibility and accountability for the food safety management system, it is essential that it be kept informed of the performance of this system.

 

In accordance with Technical Specification TS 9002:2016, this reporting is typically carried out as part of the management review process (see ISO 22000:2018 Sub-clause 9.3); Authority could be assigned to a person to coordinate reporting, with other persons with reporting authority on specific processes of the quality management system.

 

In this assignment of authorities, top management should take into consideration that this standard does not assign any authority on the food safety team leader, for reporting to top management on the effectiveness and suitability of the FSMS just a responsibility.

 

 

Requirement No. 96: Top management shall assign the responsibility for appointing the food safety team.

 

The food safety team is of great importance for the “Hazard analysis and critical control points” (HACCP) to be carried out, for the integration of the food safety plan, as well as to achieve control of critical points, and therefore, so that the food management system achieves an appropriate performance and the expected results. This should be a multidisciplinary team, with people with a high technical level in various fields of knowledge related to food safety, the food chain, processes and products, the organization and it could include people from outside the organization, in case it is required to complete the competencies of this team.

 

That is why top management should be very careful in selecting the person, or persons, to whom they will assign the responsibility for choosing the members of this food safety team.

 

 

Requirement No. 97: Top management shall assign the authority for appointing the food safety team.

 

As we have seen in relation with the previous requirement, the food safety team is of great importance for the “Hazard analysis and critical control points” (HACCP) to be carried out, for the integration of the food safety plan, as well as to achieve control of critical points, and therefore, so that the food management system achieves an appropriate performance and achieves the expected results. This should be a multidisciplinary team, with people with a high technical level in various fields of knowledge related to food safety, the food chain, processes and products, the organization, and it could include people from outside the organization, in case it is required to complete the competencies of this team.

 

That is why top management should be very careful in selecting the person, or persons, to whom they will assign the authority for choosing the members of this food safety team.

 

 

Requirement No. 98: Top management shall assign the responsibility for appointing the food safety team leader.

 

Just as the importance of assigning the responsibility for appointing food safety team members was previously mentioned, it is also important that top management carefully assign the responsibility for appointing the leader of that food safety team. For this, it would be important to consider a person who has a sufficient knowledge and experience in relation to hazard analysis and critical control points, safety food programs, the products involved in that food safety management system, as well as from the organization itself, and in this case it is important that it be someone who is part of the organization's staff.

 

Requirement No. 99: Top management shall assign the authority for appointing the food safety team leader.

 

Just as the importance of assigning the authority for appointing food safety team members was previously mentioned, it is also important that top management carefully assign the authority for appointing the leader of that food safety team. For this, it would be important to consider a person who has a sufficient knowledge and experience in relation to hazard analysis and critical control points, safety food programs, the products involved in that food safety management system, as well as from the organization itself, and in this case it is important that it be someone who is part of the organization's staff.

 

Requirement No. 100: Top management shall assign the responsibility for designating persons with defined responsibility and authority to initiate action(s).

 

The ISO 22000: 2018 standard identifies four types of actions that can be carried out by the organization:

 

-    Actions taken by the organization to address risks and opportunities (see 6.1);

 

-  Actions to reduce the consequences of an emergency situation (see 8.4.2 b);

 

-      Corrections (see 8.9.2 and 10.1.1 a);

 

-      Corrective actions (see 8.9.3 and 10.1.1 b).

 

The food safety management system should have the ability to respond quickly to any emergency situation as to any nonconformity, and that is why top management should assign the responsibility for designating all persons with defined responsibility and authority who, after an identification of an emergency situation as well as of a failure in the FSMS and documentation of the corresponding nonconformity, may initiate the necessary actions to reduce the consequences of that emergency situation, or in its case correct or eliminate the cause of that failure, as well as to prevent its recurrence.

 

It is recommended that the same person(s) be assigned the responsibility and the authority to initiate one or some types of actions.

 

Requirement No. 101: Top management shall assign the authority for designating persons with defined responsibility and authority to initiate action(s).

 

These two last requirements are closely linked, since although they are different, because one refers to assigning responsibility and the other to assigning authority, in order to designate the people with defined responsibility and authority to initiate action(s).

 

As we saw with the previous requirement, the ISO 22000: 2018 standard identifies four types of actions that can be carried out by the organization:

 

-   Actions taken by the organization to address risks and opportunities (see 6.1);

 

-   Actions to reduce the consequences of an emergency situation (see 8.4.2 b);

 

-       Corrections (see 8.9.2 and 10.1.1 a);

 

     Corrective actions (see 8.9.3 and 10.1.1 b).

 

In the same way that we have mentioned it in relation to other requirements of this section, the assignment of responsibility and authority to designate the persons with responsibility and authority to initiate action(s), may be to one or more persons.

 

 

Requirement No. 102: Top management shall assign the responsibility for designating persons with defined responsibility and authority to document action(s).

 

This requirement is closely related to No. 100, previously seen, assigning the responsibility for designating persons with defined responsibility and authority to document action(s). It is recommended that the person to whom this responsibility is assigned is the same person to whom the responsibility mentioned in relation to requirement No. 100 above has been assigned.

 

The persons designated in order to accomplish this requirement, with defined responsibility and authority to document action(s) could be the same designated in relation with that Requirement No. 100, or they could be different.

 

Requirement No. 103: Top management shall assign the authority for designating persons with defined responsibility and authority to document action(s).

 

This requirement is closely related to No. 101, previously seen, assigning the authority for designating persons with defined responsibility and authority to document action(s). It is recommended that the person to whom this authority is assigned is the same person to whom the authority mentioned in relation to requirement No. 101 above has been assigned.

 

In the same way we mention it, the persons designated in order to accomplish this requirement, with defined responsibility and authority to document action(s), could be the same designated in relation with that Requirement No. 101, or they could be different.

 

 

Requirement No. 104: The food safety team leader shall be responsible for ensuring the FSMS is established.

 

In this one and the following requirements, this section of ISO 22000: 2018 standard assign directly these responsibilities to the food safety team leader. In other management standards, these responsibilities are assigned to top management.

 

If you remember, in the Sub-clause 4.4, there is the next requirement: The organization shall establish a food safety management system, including the processes needed and their interactions, in accordance with the requirements of this standard. Thus, according to this requirement, is the food safety team leader who will be responsible for ensuring the FSMS is established.

 

So, it is convenient for us to remember that the definition of this term is:

 

In this way, based on the meaning of this term and the original wording of both requirements, we can understand, therefore, that the organization should somehow bring into existence a food safety management system, in an orderly or determined manner, including the necessary processes and their interactions, in accordance with all requirements of this standard and the food safety team leader will be responsible for ensuring that this FSMS is existing.

 

Requirement No. 105: The food safety team leader shall be responsible for ensuring the FSMS is implemented.

 

In a similar way to what we saw with the previous requirement, but considering the term "implement", which if we remember we can define it as follows:

 

If we analyze this requirement considering this definition, we see that in order for an organization to accomplish this requirement, it should, once it has established its food safety management system, apply the appropriate measures and methods to put the entire management system into operation. For this, it will be necessary that all the processes that are part of this system are operating and are managed appropriately, and the food safety team leader will be responsible for ensuring that this FSMS is operating properly.

 

Requirement No. 106: The food safety team leader shall be responsible for ensuring the FSMS is maintained.

 

Again, in a similar way to what we saw with the two previous requirements, but considering the term "maintain", which if we remember we can define it as follows:

 

If we analyze this requirement considering this definition, we see that in order for an organization to accomplish this requirement, it should, once it has established and implemented its food safety management system, the organization shall keep in an existing state, as of efficiency or validity, a food safety management system, preserving it from failure or decline, including the processes necessary and their interactions, in accordance with the requirements of this standard and the food safety team leader will be responsible for ensuring that this FSMS is properly maintained.

 

Requirement No. 107: The food safety team leader shall be responsible for ensuring the FSMS is updated.

 

Again, in a similar way to what we saw with the three previous requirements, but considering the term "update", which if we remember we can define it as follows:

 

If we analyze this requirement considering this definition, we see that in order for an organization to accomplish this requirement, it should, once it has established, implemented and maintained its food safety management system, the organization shall ensure the application of the most recent information, by immediate and/or planned activity, of a food safety management system, including the necessary processes and their interactions, in accordance with the requirements of this document and the food safety team leader will be responsible for ensuring that this FSMS is properly updated.

 

 

Requirement No. 108: The food safety team leader shall be responsible for managing the work of the food safety team.

 

In order to comply with this requirement, the food safety team leader must have the responsibility of directing the work of that food safety team, so that activities such as the following are carried out appropriately:

 

- Approval of prerequisite programs,

- Collection, maintenance and updating of preliminary documented information for hazard analysis,

- the establishment, maintenance and updating of flow charts as documented information for the products or categories of products within the FSMS,

- On-site confirmation of flow charts,

- Description of the processes and the process environment,

- carry out the hazard analysis,

- Validation that the selected control measures, or their combinations, are capable of achieving the expected control of significant safety hazards,

- Analysis of the results of verification activities, and

- Evaluate the FSMS at planned intervals for possible updating.

 

Requirement No. 109: The food safety team leader shall be responsible for organizing the work of the food safety team.

 

In order to comply with this requirement, the food safety team leader should have the responsibility of organizing the work of that food safety team, so that activities such as the following are carried out appropriately. Through this responsibility, the food safety team leader should be in charge of structuring the essential relationships among the food safety team members, tasks, and other activities. This should be done in a way that the organization's resources are integrated and are coordinated to accomplish the objectives efficiently and effectively.  

 

Requirement No. 110: The food safety team leader shall be responsible for ensuring relevant training for the food safety team (see 7.2).

 

In order to comply with this requirement, the food safety team leader should have the responsibility of ensuring that the food safety team has a combination of multi-disciplinary knowledge and experience in developing and implementing the FSMS (including, but not limited to, the organization’s products, processes, equipment and food safety hazards within the scope of the FSMS), and where applicable, take actions to acquire the necessary competence, and evaluate the effectiveness of the actions taken.

 

Applicable actions can include, for example, the provision of training to, or the mentoring of currently employed persons. 

 

 

Requirement No. 111: The food safety team leader shall be responsible for ensuring relevant competencies for the food safety team (see 7.2).

 

In order to comply with this requirement, the food safety team leader should have the responsibility of ensuring that the food safety team members have a combination of multi-disciplinary knowledge and experience in developing and implementing the FSMS (including, but not limited to, the organization’s products, processes, equipment and food safety hazards within the scope of the FSMS). This food safety team leader should:

 

- determine the necessary competence of the food safety team members, including external providers, doing work under its control that affects its food safety performance and effectiveness of the FSMS;

- ensure that these food safety team members are competent on the basis of appropriate education, training and/or experience;

- ensure that the food safety team members have a combination of multi-disciplinary knowledge and experience in developing and implementing the FSMS (including, but not limited to, the organization’s products, processes, equipment and food safety hazards within the scope of the FSMS); and

. retain appropriate documented information as evidence of competence.

 

 

Requirement No. 112: The food safety team leader shall be responsible for reporting to top management on the effectiveness of the FSMS.

 

In order to comply with this requirement, the food safety team leader should have the responsibility for keeping informed of the performance of the FSMS, as well as the comparison of the results achieved against the food safety objectives established by the organization, and for reporting to top management on the effectiveness of the FSMS.

  

Requirement No. 113: The food safety team leader shall be responsible for reporting to top management on the suitability of the FSMS.

 

In order to comply with this requirement, the food safety team leader should have the responsibility for keeping informed of the performance of the FSMS, as well as the comparison of the results achieved against the food safety objectives established by the organization, and for reporting to top management, in addition to the effectiveness of the FSMS, as we saw it in the previous requirement, the quality of being right or appropriate this system for its particular purpose.

 

 

Requirement No. 114: All persons shall have the responsibility to report problem(s) with regards to the FSMS to identified person(s).

 

To meet this requirement, the organization´s top management should make all staff aware of the responsibility assigned to them by the standard for reporting problems with respect to the FSMS to the identified persons who have been assigned responsibility for documenting nonconformities, as well as those to document and initiate action(s).

  

In the next entry we will begin the analysis of requirements derived from Clause 6 - Planning, So for this we will be starting with requirements derived from Sub-clause 6.1 - Actions to address risks and opportunities, of this ISO 22000:2018 Standard.

 

Your doubts or comments that you want to upload to this blog about the analysis presented will be always welcome.

 

 

Author:

 

Ernesto Palomares Hilton