Top 10 Questions When Hiring for the Food Safety Modernization Act
By Michael Kalish
Before the Food Safety Modernization Act (FSMA), a deciding factor when hiring quality assurance (QA) professionals has been work experience, but prior to 2016, few people had prepared a company for compliance with FSMA’s rules. Like third-party audit criteria, FSMA rules are best addressed by QA professionals with experience, project management and leadership skills, as well as cross-department communication. It is especially important for a QA professional to know when to outsource to a consultant and when to cultivate expertise in-house. Below are the top 10 questions that ought to be considered when interviewing a prospective employee with some Hazard Analysis and Critical Control Points (HACCP)-based experience.
1. What were the greatest successes in your development, implementation and/or maintenance of a HACCP-based food safety plan?
I like putting this question first because provides the candidate with an opportunity to define success. Is it individualistic or team-oriented? Does it consider the customer or an audit? Does the candidate question his/her success, based on customer feedback or lack thereof? Success at each stage (i.e., development, implementation and maintenance) can mean very different things, which will give you a cross-section of the candidate’s leadership skills. Success may be, for the candidate, the overcoming of tremendous obstacles posed by management, such as passing an audit with very little preparation time or resources.
2. What were the greatest challenges in your development, implementation and maintenance of the plan?
This question can go two ways: a cathartic burst of complaints and hostility or a restrained and measured response that frames observations constructively. This question is useful for evaluating the candidate’s level of maturity (and sense of humor).
3. What would you have done differently to improve the process of developing, implementing and/or maintaining a HACCP-based food safety plan?
Because FSMA rules require the implementation of continuously improving systems, it is fitting that your candidate demonstrates the ability to continuously-improve her/her methods.
4. Assuming you are hired for the job, what assistance would you ask the CEO for to effectively develop, implement and/or maintenance the HACCP-based food safety plan?
One of the most difficult things for every food company is to determine how much time and money ought to be invested in food safety. This requires a familiarity with the facility, equipment, process, quality of the available human resources and applicable exemptions, regulations and audit criteria. This questions presses the candidate to demonstrate the ability to think big picture and identify what her/she knows and does not know.
5. How comfortable are you with assisting with a food safety training?
The ability to share knowledge is a prerequisite for teamwork. It also helps distribute the load of the training program, which is a key program for continuously improving the plan and adopting changes. One of the greatest threats to food safety is the individual who positions his/her self as indispensable. One day this person will not make it to work; and, one day, this person will disappear altogether (e.g., retirement, illness, new job, family crisis, career change, etc.). Hiring individuals willing to take part in the training process reduce the risk of food safety system decomposition.
6. If you observed a fellow employee neglect his/her food safety duty and he/she explained that the risk was minimal, what would you do?
This question is not intended to make the candidate choose between work and friendship—it is intended to give the candidate an opportunity to explain how he/she would handle a sensitive, interpersonal issue with food safety relevance. In my opinion, food safety ought to be framed for the company as a form of job security. If customers suffer serious injury or illness, settlements and regulatory action could cost everyone their job. Making an intervention, from this perspective, can be in everyone’s interest. It is important for the candidate to give an answer that helps prevent (both in the short- and long-run) potentially contaminated product from reaching the customer.
7. If you saw an auditor fail to notice a potential non-conformity, what would you do?
The auditor’s job is to identify gaps in your food safety plan. If the auditor helped you notice the issue (by overlooking it), you are just as informed as if he/she had told you of it. In this circumstance, does the candidate limit the scope of his/her answer to the audit or expand it to include other impacted bodies (e.g., customer, company standards, etc.)?
8. What are the most important feedback loops every HACCP-based food safety plan ought to have?
This question challenges the candidate to demonstrate the ability to prioritize and to brainstorm. Encourage the candidate to think out loud.
9. If management asked you to prepare for an audit scheduled one month from today, what would you say and what would you not say?
Expectation management, tact and discretion are three excellent traits in QA professionals (or anyone). This question will give your candidate a chance to demonstrate these traits.
10. Can you find the Preventive Controls for Human Food rule online? If so, can you find the definition of a Qualified Individual (QI) in the regulatory text (in subpart A) or the QI’s responsibilities (in subpart C)?
It doesn’t matter what you know as much as what you can find. The FSMA rules, with their preambles, are too long for anyone to commit to memory. The ability to navigate the internet (and regulation) is far more important and useful. This skillset will pay off significantly when it is time to conduct (or re-evaluate) a hazard analysis.
Michael Kalish is managing member of Food Safety Guides, a progressive food safety and quality systems consulting firm that specializes in FSMA compliance, HACCP, third-party audit preparation and food safety and quality plan development. Michael is also Senior Technical Advisor for Food Safety at the University of California – San Diego and a Food Safety Preventive Controls Alliance Lead Instructor for Human and Animal Food.