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How Do You Write a Food Loss and Waste Policy and Objectives That Pass an FSSC 22000 Audit?

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FOOD LOSS AND WASTE · FSSC 22000 CLAUSE 2.5.16 A

FSSC 22000 clause 2.5.16 a asks a certified site for four things: a documented food loss and waste policy, a defensible base year, one or more objectives measured against an intensity metric rather than an absolute tonnage, and a prevention plan behind each one. What an auditor actually opens is the objectives register, where the base year, the metric, the target, the owner and the review date have to hold up against dates, names and numbers, not intentions.

Key facts

  • Governing clause FSSC 22000 additional requirement 2.5.16 a
  • Required elements policy, base year, objectives, prevention plan
  • Metric type expected intensity, per tonne of production or value
  • Why not an absolute tonnage falls automatically if production falls
  • Document an auditor opens the objectives register
  • Register fields base year, metric, target, owner, review date
  • Plan required alongside targets a named prevention plan, not just a number
  • Course that builds this Reducing Food Loss and Waste, R1195

Turn the baseline into a funded, audit ready programme

Reducing Food Loss and Waste for Sustainable Manufacturing teaches you to cost the losses, write the policy and objectives, and route surplus to donation or animal feed safely.

Enrol in Reducing Food Loss and Waste, R1195
See the full food loss and waste pathway
Self paced online with lifetime access. About eight hours in total, including a hands on programme workshop.

What clause 2.5.16 a is actually asking for

FSSC 22000 additional requirement 2.5.16 a asks a certified site for a documented policy, a base year that progress will be measured against, one or more objectives with a target, and a prevention plan describing how the site intends to meet them. Each of those four elements is tested separately by an auditor. A policy without a base year has nothing to be measured against. A base year without a documented method behind it cannot be defended if it is questioned. An objective without a plan is an intention, not a programme, and the standard does not treat intentions as evidence.

Choosing a base year that survives being questioned

A base year is only as strong as the measurement work behind it. Choosing a base year is choosing the period for which the site can still produce the underlying data: which quantification method was used for each stream, whether the mass balance closed within a stated tolerance, and how any donated or diverted surplus was classified. A base year chosen for convenience, or one for which those working papers no longer exist, will not hold up the moment an auditor asks where the number actually came from. This is also the reason the measurement work covered in a companion guide has to happen before the policy work, not alongside it as an afterthought.

Why the metric has to be intensity, not a raw tonnage

An objective written as an absolute tonnage, reduce food loss and waste by a fixed number of tonnes, can be met without anyone changing anything, simply by producing and selling less. That is not a reduction in performance, and an auditor reviewing the target against a year of falling production volume will see straight through it. The metric the standards expect is an intensity figure, food loss and waste per tonne of production or per unit of value, so the number only moves when the rate of loss genuinely changes, independent of how much the site made that year.

Build the number an auditor cannot pick apart

Measuring Food Loss and Waste teaches QA and technical managers the scope, quantification method and mass balance discipline behind a defensible clause 2.5.16 baseline.

Enrol in Measuring Food Loss and Waste, R995
See the full food loss and waste pathway
Self paced online with lifetime access. About seven hours in total, including a hands on baseline workshop.

The objectives register: the document an auditor actually opens

Field What it records What an auditor checks
Base year The reference period the target is measured against That supporting measurement records for that period still exist
Metric The intensity measure used, for example kilograms per tonne of production That it cannot be met by producing less
Target The stated reduction, with a date Whether it is realistic against the prevention plan behind it
Owner The named role accountable for the objective Whether that person can explain the number unprompted
Review How often progress is checked and by whom Whether reviews actually happened, and what changed as a result

An objectives register is where a policy’s claims stop being words and start being dates, names and numbers. It is also where most sites either pass this part of the audit comfortably or discover that a policy was written once, filed, and never operated.

The prevention plan and taking it through management review

Every objective needs a prevention plan underneath it: the actions that will move the number, who owns each action, and how progress will be monitored between reviews. That plan then belongs in management review like any other system input, with progress against target reported, root causes for any shortfall discussed, and resources reallocated where the plan is not working. A policy and a register that never reach management review are a compliance document, not a management system, and an auditor experienced enough to ask for the last review’s minutes will find that gap quickly.

Turn this into a certificate your auditor can check

Food Loss and Waste Essentials teaches operators, packers and supervisors to sort what comes off a line into the right pile and say why, using one real production day from gate to pallet.

Enrol in Food Loss and Waste Essentials, R599
See the full food loss and waste pathway
Self paced online with lifetime access. About five hours in total. QR verified Certificate of Achievement.

Frequently asked questions

What does FSSC 22000 clause 2.5.16 a require in a food loss and waste policy?

Clause 2.5.16 a asks for a documented policy, a defensible base year against which progress is measured, one or more objectives with a target, and a prevention plan that sets out how the site intends to meet those objectives. A statement of intent without a base year, a metric and a named plan behind it does not meet the clause on its own.

What makes a base year defensible to an auditor?

A defensible base year is a period for which the site can produce the underlying measurement data, not just the final total, using a quantification method it can explain and a mass balance that closed within a stated tolerance. A base year chosen because it happens to look bad, or one for which the supporting records no longer exist, will not survive an auditor asking to see where the number came from.

Why can’t a food loss and waste target be met by simply selling less?

A target expressed as an absolute tonnage falls automatically when production volume falls, which rewards a bad year rather than a genuine improvement. The standards expect an intensity based metric, food loss and waste per tonne of production or per unit of value, so that a real reduction in the rate of loss is what moves the number, not a change in how much the site made.

What is an objectives register, and why does it matter?

An objectives register is the working document, not the policy statement, that records the base year, the metric, the target, the owner and the review frequency for each objective. It is what an auditor actually asks to see, because it is where a policy’s claims are tested against dates, names and numbers rather than intentions.

Does the policy need a prevention plan as well as a target?

Yes. Clause 2.5.16 a asks for a prevention plan behind the objectives, setting out the actions, owners and monitoring that will move the number, not just the number itself. An objective with a target and no named plan behind it reads as an intention rather than a programme, and that gap is one auditors are trained to probe.

Which course teaches how to write this policy and objectives register?

Reducing Food Loss and Waste for Sustainable Manufacturing. It teaches learners to write a food loss and waste policy and an objectives register that satisfy clause 2.5.16 a, with a defensible base year and an intensity metric, then build the prevention and monitoring plans underneath each objective and take the whole package through management review.

About the author. Mthokozisi Nkosi is a food scientist, a registered Lead Auditor with Exemplar Global and IRCA, an HPCSA registered Environmental Health Practitioner, and one of four SAATCA registered R638:2018 Lead Implementers. He holds an MSc in International Public Health, an MSc in Data Science, an MBA and a BSc in Agriculture (Food Science and Technology), and is completing a PhD in Public Health. He founded ASC Food Safety Consultants, a SAATCA registered training centre (TC No. 065) and FoodBev SETA accredited provider, and built the food loss and waste course series from the same production lines he audits for a living. Connect on LinkedIn.

ASC Food Safety Training · Leading with Science. Ensuring Food Safety. · Fully online, serving all of South Africa and beyond · info@ascfoodsafety.com · WhatsApp +27 61 483 0381 · SAATCA registered training centre (TC No. 065) · FoodBev SETA accredited provider No. 587/00337/1900 · B-BBEE Level 1 · Registered Lead Auditor (Exemplar Global and IRCA) · Consulting and document toolkits at ascfoodsafety.com

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