The FSMS Folder Nobody Opens
A catering company supplying 30 school canteens has a written FSMS in a folder. It was written three years ago by a consultant and has not been updated since. The company switched suppliers, added a new cold-storage room, and changed its delivery route last year. Staff say they 'know what to do' but there are no temperature logs for the new cold room, and the CCP for chilled delivery is still described as 'check on arrival' with no critical limits. A school reports that a delivery arrived at 12°C. The SFA officer asks to see how the FSMS is implemented and verified.
1. Assess the FSMS. Is having a written document enough, and what specific gaps would the officer identify?
Read the worked answer
A written FSMS that is not implemented, maintained or verified is not an effective FSMS.
Gaps the officer would identify:
- Not maintained - three years without review despite major changes (new supplier, new cold room, new route). An FSMS must be reviewed when operations change.
- Hazard analysis incomplete - the new cold-storage room and new route introduce hazards that were never analysed.
- No critical limits - 'check on arrival' is not a CCP. A CCP needs measurable critical limits (e.g. chilled food ≤ 5°C or as specified), monitoring, corrective action and verification.
- No monitoring records - no temperature logs for the new cold room means the CCP cannot be shown to be under control.
- No verification - nothing shows the system is checked for effectiveness.
- Reliance on 'staff know' - undocumented knowledge is not a system.
Conclusion: the document is a paper exercise, not a functioning FSMS. The 12°C delivery is the predictable result.
2. What must the company do to bring the FSMS into line, and how should the 12°C delivery have been handled under a proper FSMS?
Read the worked answer
Bringing the FSMS into line:
- Re-do the hazard analysis for the current operation, including the new cold room, new supplier and new route.
- Set CCPs with measurable critical limits - e.g. chilled deliveries received at or below the specified temperature (commonly ≤ 5°C unless the product's own controls justify otherwise), with a defined action if exceeded.
- Define monitoring - who checks, how often, with what device (calibrated thermometer), and where it is recorded.
- Define corrective actions - reject, segregate, or escalate.
- Keep records - temperature logs for the cold room and every delivery.
- Verify - periodic review, internal audit, record checks.
- Train staff and update the document to match reality.
Handling the 12°C delivery under a proper FSMS:
- The handler checks temperature at receipt against the critical limit.
- 12°C exceeds the limit → reject or segregate the delivery; do not put it into the cold chain.
- Record the deviation, the temperature, the product and the action taken.
- Notify the supplier and the FHO.
- Investigate why the route or vehicle failed and correct it.
Under the current paper FSMS, none of this would have been triggered - which is exactly the officer's concern.