Is your testing plan always up to date? Here are 5 tips
A good testing plan forms the foundation of safe food production. Yet in practice, many companies struggle to maintain, interpret and update their plans, potentially creating risks. Legislation changes rapidly, the NVWA is taking a more targeted approach to inspections, and many food producers simply lack the time or expertise to keep their plans up to date.
“The biggest pitfall? Thinking that a testing plan is a document you create once and then leave alone,” says Max van Leeuwen, Director of Eurofins Food Safety Solutions. “But your operations are constantly changing: your production volume grows, your recipe changes or your product range expands. Your plan needs to evolve with these changes. Otherwise, you may no longer be fully controlling all relevant hazards.”
Why does your testing plan need to be kept up to date?
An outdated testing plan can create risks at several levels.
1. You may not be addressing all hazards
Both microbiological and chemical risks can change. New product groups, increased production volumes or new processes may require different analyses or testing frequencies. Producers and retailers may also overlook legislation concerning authenticity.
“Your testing plan is the key way to assess the safety of your products,” says Nienke Hartman, QA Consultant at Eurofins Bureau de Wit. “You often cannot smell, taste or see a harmful bacterium. If you do not analyse your products according to a risk-based plan, you do not know how safe your products really are.”
2. You may not comply with legislation
The requirements for safe food production are constantly changing. Criteria are becoming stricter, interpretations by the NVWA evolve, and new guidelines are introduced for certain product groups. As a result, a testing plan can become outdated without a company realising it.
“Many companies assume their plan is still correct because little has changed in their production. But the rules change too. You will not notice that if you are not actively monitoring developments,” Hartman explains. Keeping track of these changes requires time and expertise, which smaller production companies do not always have available.
Legislation also requires your testing plan to be based on current risks. This means that monitoring and analyses must adapt to changes in processes, products or production volumes, in line with the HACCP approach to assessing the likelihood and severity of hazards.
3. Stricter NVWA inspections
“The NVWA is carrying out more inspections, particularly in relation to imports and fresh products,” says Van Leeuwen. “The NVWA is also looking more closely at the substantiation of your testing plan. If the plan does not reflect current insights or changes in product categories, this may lead to comments, additional requirements or follow-up inspections.”
Why is it difficult to keep your testing plan up to date in practice?
“Legislation changes faster than many food producers can keep up with, especially when there is no dedicated QA professional monitoring the NVWA’s interpretations,” Hartman explains. “Product changes, such as adjustments to recipes, production volumes or shelf life, are also not always incorporated into the testing plan immediately.
“In addition, determining the right testing frequencies and providing a sound rationale remains challenging. When should you test weekly, and why? When is a lower frequency sufficient? How does risk-based testing work? How large or homogeneous should a sample be? Organising product groups according to categories and determining the relevant parameters also requires considerable knowledge. Many organisations also experience uncertainty around NVWA inspections, precisely because this documentation takes time that is often not available.”
5 tips for keeping your testing plan up to date
So how can you ensure that your testing plan remains current?
1. Start with your product range
Create a complete overview of:
- The products you manufacture
- Your production volumes
- The categories they fall into
“Good categorisation makes a huge difference,” says Hartman. “By grouping products according to the classifications used in legislation, you avoid having to analyse every individual product. For example, one category such as ‘fresh poultry meat’ can cover several variants.”
2. Check that you are using the latest legislation
“Do not just look at what the regulations say, but also at how the NVWA interprets them. For microbiological criteria in particular, the NVWA’s available manuals provide important guidance. Linking products to the correct legislation also requires considerable research: for each product group, you need to determine which requirements and risks apply,” Hartman explains.
3. Analyse only what is necessary
Many companies test too much, either because they follow outdated routines or because they assume that more testing automatically means greater safety.
“But that creates unnecessary costs. You should test what is necessary, at the right frequency—not everything that can be tested,” says Van Leeuwen. “That is only possible when you have assessed the risks properly.”
4. Use all available data
“At Eurofins Food Safety Solutions and Eurofins Bureau de Wit, we use data from hundreds of thousands of analyses each year, EFSA data, RASFF trends, alerts from authorities and scientific publications to assess likelihood on an ongoing basis.
“Without this data, risk assessment is often based on gut feeling, which is unreliable. Always support your testing plan with current data; it makes your risk assessment much more robust,” Van Leeuwen explains.
5. Review your plan regularly
“Many companies do not realise how frequently legislation is amended,” Hartman explains. “We continuously monitor these developments because that is the only way to keep a testing plan genuinely up to date.
“It may also be necessary to update your plan in the meantime, for example when something changes in your production or products. This could include a revised recipe, increased output, extended shelf life or a product that suddenly falls into a different category. Warnings or alerts relating to your product group may also be a reason to update your plan immediately.”
Peace of mind and confidence
“Our consultants currently help many clients create and maintain their testing plans,” says Van Leeuwen. “Whenever something changes in production or legislation, we update the testing plan accordingly. This may involve implementing new regulations, adjusting testing frequencies or updating product categories based on new information.
“In short, we work alongside our clients, identify changes and translate them directly into the testing plan. We also handle sampling and the interpretation of analytical results against legislation and regulatory requirements, so the entire process—from sampling to substantiation—is managed in one place.
“For companies, this provides clarity, peace of mind and confidence that their plan genuinely reflects day-to-day operations. This is particularly valuable for smaller production companies that do not have the budget for a dedicated QA employee.”
Support when deviations occur
“In addition to sampling, our experts can provide clear guidance on what to do when a deviation occurs. This includes practical steps to take in the event of exceedances and advice on identifying possible causes. This way, you know what actions are needed and are not left on your own when something goes wrong,” says Van Leeuwen.
Want to know more?
Would you like to know which approach is best for your company, or are you unsure whether your current testing plan is still fully up to date? Our experts are happy to help you.
Feel free to contact us for advice or an introductory consultation at 036 536 74 20 or infobdw@ftbnl.eurofins.com. We are happy to help.