Over the past couple of years, almost half our custom food control plan jobs have come about from clients who have initially engaged the wrong consultant. The have come to us after they had sacked them, or the consultant had walked away from the job because they had realised they couldn’t do it. Food businesses have been left in impossible situations by people who simply did not know what they were doing, and did not have the skills to dig themselves out of the mess.
We write custom food control plans, but realistically can only write a half dozen or so a year. If you need a plan, we might be able to help you, but also, might not be able to. They’re generally over 150 pages long, are very detailed, and require a lot of time to complete. There are a few other consultants out there capable of writing these plans, but they’re as busy as us, so finding one who is competent is extremely challenging. We’ve all had our fingers burnt on these projects so are a little choosy of our clients too. That means, if you are looking for a consultant, there’s a high chance you could end up with a cowboy who doesn’t know what they’re doing.
We’ve compiled a few do’s and don’t below to help you in your search.
Rule 1 – Find someone with verifiable and extensive experience writing custom food control plans
If someone says they have written plans in the past, be sceptical. I’ve had a consultant outright lie to me and say they had done a custom food control plan, when in fact it had been a National Programme 1. There’s a pretty big difference!
Ask who they have written them for, or if confidentiality is an issue, what was involved in the Scope. Also ask when they were written. The most detailed and skillful plans were written before February 2019.
It is not enough that a consultant has read the guidance and thinks they can give it a go for the first time. We had to do this in 2016 when the law was introduced and it didn’t go that well. The guidance has been fundamentally flawed. If you follow it, you’re probably going to end up in trouble, and by the time you realise this, it will be too late to mitigate the damage to your business. We managed this situation on our first job because we had the time, skills and patience to figure it all out – but it meant essentially rewriting an entire plan about 3 times (once based on the guidance, once based on what the evaluator wanted, and finally based on what MPI required).
Likewise, someone who has worked in compliance for years may not have the right level of experience. A food professional could go most of their working life using or even tweaking HACCP plans, but writing one from scratch is a rarity in many careers and requires a very specific skill set. A plan that has already been approved will never undergo the level of scrutiny that a new plan will be examined with.
Rule x – Ensure that the consultant has the relevant qualification
If you need a template food control plan or national programme, someone with a background in environmental health might be fine. Experience as a council inspector should be good enough. However, if you require a custom food control plan, it probably won’t be enough.
For a custom food control plan, you really need a food specialist with a degree in food science or food technology. Even then, you want to be careful as not all food science or technology degrees are equal. One of the NZ food science degrees is extremely weak on maths and science. The Food Technology degree from Massey University remains the gold standard.
I have a degree in Food Engineering from Massey University (a couple of papers different to food technology). This is a 4 year degree, but I was lucky enough to be able to finish it in just 3 years. When I travelled to the UK in the early 2000’s I wanted to become a chartered engineer, and the Institute of Engineering and Technology graded the Massey degree as the equivalent to a UK Masters in Engineering degree. This should give you an idea of the calibre of person you will be getting if you can find a Massey food techie (the food tech degree is also considered a full engineering degree on top of everything else that it is).
Look very carefully at qualifications, but not in isolation. It should form a part of the decision making process.
Rule 4 – Make sure the consultant you are working with has public liability insurance
Everyone makes mistakes. If the consultant doesn’t have insurance, then they are exposing you to risks you simply don’t understand and cannot anticipate. Insisting on insurance will expose the cowboys very quickly.
Rule 5 – Listen to Word of Mouth Advice
Listen to the advice of others in the industry, but don’t take anything for granted. Someone who was excellent at implementing a low level plan might be useless at implementing one that has a little more complexity.
Rule 2 – Look Out for a Butchered Template Food Control Plan
A Custom Food Control Plan is more than just a butchered Template Food Control Plan. The template plans were designed for restaurants and cafes, and do have some good content, but on a whole, aren’t suitable for manufacturing. Once you start changing small parts of them, they can become unsuitable very quickly, and it is
If you read the official guidance from MPI on how to write a custom food control plan, it might seem relatively straight forward. It isn’t.
MPI has several departments – Food and Beverage who write the guidance, approvals who approve the plans, and compliance, who enforce the rules.
Rule 3 – Look Out for Someone Else’s Work
Food Control Plan’s and their predecessor Food Safety Programmes are often based on templates and these are often provided by MPI for an entire industry. They can be a complete overkill, or undercooked. Likewise, a lot of work has been copied and pasted unfortunately from one company to another.
We’ve found in the past that the MPI work is extremely hard to customise and adapt. Just reformatting the work is close to impossible. If you end up with someone else’s plan, there can be huge amounts of ongoing work described in the plan that is unnecessary.
Any good plan will have elements that have been carefully transferred from a government template, or based on a consultant’s previous work. But if you are running a dried snack food business, and find references to pet food in your plan (yes, this is a real example!) then be wary.
Rule 3 – Don’t Just Take the Cheapest Option
We can offer you more or less any price you want. We won’t, but we can. Seriously. We can use your lack of knowledge against you, tie you up in a contract that is inadequate, then charge you for extras till the cows come in.
If you just go for the cheapest option, you’ll probably end up with a HACCP plan that lacks so much detail that the evaluator will carve it, chew it up, and spit it out. Reworking this will be hard – you’ll have to redo you process flow charts, then probably rewrite your HACCP Plan. You might even end up sacking your consultant, and your new consultant will throw the previous work in the bin. We’ve seen work where trying to salvage anything has been slower than starting again.
Get clear boundaries as the what work you are doing, and what work the consultant is doing
. In NZ this typically means a food technology degree from Massey University, or Food Scie
Rule x – Have a look at MPI’s list of consultants, but be very sceptical.
MPI has a list of consultants on their website. The criteria for getting added to this list is that you asked. Or in my case, I asked 3 times and they eventually got around to it. Last time I looked at this list, it had
Rule x – Find out What Else they Can Do for You
If you are going with a big city consultant, they might just offer a commodity service where they do the bare minimum to get you over the line and can’t help with anything else. We are different, and so might other consultants, so find out what more they can do. When we write one of these plans we need to get heavily involved with your business and this usually presents some opportunities. The ultimate is to have a custom food control plan that inadvertently pays for itself. We are a very commercially minded business and are always looking for ways to add value to our work for our clients – this might be through improving production efficiencies, improving products, reducing costs, helping with market access or helping with sales and distributing opportunities. We are food manufacturers too, so have lived and breathed what you go through every day.
Rule 6 – Ignore Some of this Advice
Here is something that will always stay constant – MPI will keep changing the rules. So far, I have counted 6 different interpretations of the rules around manufacture of ready meals since 2016. So, by the time you read this, some of this advice might be out of date.
Foodaction started contracting and consulting work in 2011. We were well established by 2014 when the government passed the Food Act 2014, then Food Regulations 2015, and were already writing food safety programmes for businesses, local and far afield when MPI introduced the Food Act transition period in 2016.
We wrote our first Custom Food Control Plan, implemented a National Programme, helped a business with the template food control plan, and imported a consignment of food as a registered food importer by the end of that year, and were probably the first consultancy to perform all 4 core tasks.
It was a rough ride. On day 1, MPI hadn’t approved a single evaluator so new food businesses literally could not start operating. It was months before any guidance came out on how to write a custom food control plan, and about 18 months before the guidance became available for National Programmes. The few consultants operating, really were operating in the dark.
