School catering: repeated corrective actions and an empty management review
A contract caterer supplies 38 schools with chilled meals. The FSMS has been certified for three years. The latest internal audit found: CCP records for cooking (75 °C) missing for 4 of 60 production days; the corrective action log shows “retrain staff” repeated three times for the same deviation; the management review minutes from last month include sales, budget and customer complaints, but no review of food safety objectives, audit results or verification results. The food safety team leader is also the operations manager and signs off corrective actions. Two schools reported a stomach upset last term, but no samples were taken. The certification body is due in six weeks. The site wants to “close” the audit findings quickly.
1. Assess whether “retrain staff” is an acceptable corrective action for the missing CCP cooking records.
Read the worked answer
“Retrain staff” is not acceptable as the sole corrective action when the same deviation has recurred three times. Repetition points to a systemic cause: shift handover, record design, supervision, workload or accountability. Training may be part of the response, but it does not address why records were missing on 4 of 60 days.
The company must first contain the problem: identify the affected production days and batches, establish whether 75 °C was actually achieved using other evidence (thermometer logs, equipment data, supervisor checks), and assess product disposition. It should then perform root cause analysis and change the system - for example, automatic temperature data logging, a simplified record with supervisor verification, shift-handover checks, and a competence check rather than attendance at training.
Effectiveness must be verified after implementation. The fact that the food safety team leader is also operations manager and signs off corrective actions creates a conflict of interest and weakens independent verification.
2. What should top management review, and why does the current management review fall short?
Read the worked answer
The current review covers sales, budget and complaints but omits the inputs needed to judge whether the FSMS is effective. Management review should consider the status of previous actions, changes in internal and external issues, food safety objectives and performance, audit results, verification results, CCP deviations and nonconformities, customer complaints, supplier performance, emergency situations, withdrawal or recall experience, resource adequacy, and risks and opportunities.
The review should lead to decisions and actions, not just financial discussion. Top management must demonstrate commitment to the FSMS. The missing cooking records and repeated corrective actions are exactly the kind of performance data that should reach management review. Without them, the review cannot assess whether the system is suitable, adequate and effective.
The certification body will look for evidence that management review has covered food safety performance and led to action.
3. Advise the site on whether it is ready for the certification audit in six weeks.
Read the worked answer
The site is not ready if the findings are closed administratively. Writing “retrained” without root cause analysis, product assessment and verified effectiveness will not satisfy an auditor. The repeated nature of the deviation shows the corrective action process itself is weak.
Six weeks is enough if the site prioritises: complete the product assessment for the affected days; implement and verify corrective actions; update the hazard analysis if needed; conduct follow-up internal audit; hold a management review with the required inputs; resolve the conflict of interest in sign-off; and check PRPs, traceability and emergency arrangements. The stomach-upset reports should be reviewed even without samples, because the site needs to show how complaints are evaluated for food safety significance.
The goal is not to “close” findings quickly but to show that the FSMS detects problems and drives effective change.