Tag Archives: audit

Tim Husen, Rollins Technical Services
Bug Bytes

Sanitation Solutions for Pest Problems

By Tim Husen, Ph.D.
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Tim Husen, Rollins Technical Services

It’s no surprise that food manufacturing and processing environments are naturally vulnerable to food safety threats. Food processing environments have all the things a pest needs to thrive: Food, water and shelter. And if poor sanitation is added to the mix, pests can find your food processing plant absolutely irresistible.

An unkempt facility can attract flies, ants, cockroaches and other unwanted common pests such as rodents. All of these common pests could put you or your facility at risk during your next audit.

The good news is pest-related sanitation issues are preventable through proactive and holistic preventive treatment plans. It’s important to establish proper sanitation processes and procedures so that over time, you avoid or reduce the occurrence of pest problems that could cost you major points on an audit and potentially compromise your products.

Many food processing facilities employ integrated pest management (IPM), an approach that helps prevent pest activity before it occurs and uses chemical treatments only as a last resort. The goal with these types of treatments is to give facility managers tools to use in advance of their next audit to stay ahead of pests, to teach employees good practices and to avoid problems before they happen. A good IPM program includes careful documentation of pest issues and the conducive conditions relating to them, as well as any corrective actions taken to resolve them. This documentation is incredibly important not just in solving pest problems, but also in its relevance to FSMA regulations.

When talking to pest management providers, remember that a “one-size fits all” strategy often doesn’t work, so expect your pest control company to recommend a customized plan. Different environments have different “hot spots” (areas where pests typically are present if the conditions are right) and face different pest pressures. However, there are a few key best practices that can be applied to any facility to help protect against pests.

The following guidelines will help to minimize pest activity and prepare for your facility’s next audit.

1. Educate and Enlist Your Employees in the Fight Against Pests

The first step to establishing your sanitation plan is enlisting your staff. One of the strongest building blocks in your defense against pest activity is sanitation. This key component of your IPM plan begins with the vigilance of your employees. Sanitation and pest management aren’t one-and-done tasks. They’re ongoing and you’ll get the best results when the entire staff is on board.

How can they help? Your employees are often the first to notice any potential signs of existing problems, so it’s important to educate them on hot spots where pests could live, what signs they should look for, and what to do if they see a pest issue. Once your employees understand the importance of sanitation, set a zero-tolerance policy for spills, debris and waste. If employees spot a pest, make sure they understand the protocols for documenting its presence. Consider implementing daily, weekly and monthly sanitation routines in addition to an annual deep cleaning.

Finally, enlist your employees to help keep common areas clean, from break rooms to locker rooms. Establish processes to clean up dirty dishes and drink spills, and empty full trash bins immediately. Don’t forget about cleaning the bins themselves! Also, make sure that common refrigerators aren’t filled with past-expiration lunches or snacks. If you’re finding it tough to get employees to participate, most pest management providers will offer a free education program to make employees aware of potential risks and what they can do to help. Sometimes it can help employees to hear from the experts.

2. What’s on the Inside Counts

As the saying goes, what’s on the inside really matters. This is true for the interior sanitation of your processing facility, too. There are a few particularly vulnerable hotspots to be conscious of when putting together your sanitation plan, especially the production floor, the storage areas and the receiving areas.

For obvious reasons, the production floor is one of the most important areas of focus for your sanitation program. Any hygiene issue could directly impact and expose your food products to contamination. Pests love to make their homes in big equipment that is often difficult to access for cleaning. Improper sanitation may lead to bacteria growth on the production line, which poses a major food safety threat. Create a schedule so that all equipment and machinery are sanitized regularly, and don’t forget about paying extra attention to those out-of-sight areas.

Drain flies and other pests live around drains and drain lids. Both should be scrubbed and sanitized regularly to prevent buildup of grease and other gunk that can attract pests. Organic, professional cleaning solutions are a great option to break down tough stains and grime on floors and around drains. These organic cleaners use naturally occurring enzymes and beneficial bacteria to degrade stains, grime and other organic matter build up, which helps reduce the likelihood of drain flies and other pests.

Storage areas are also prone to attracting pests and the potential bacteria they harbor. These cluttered spaces can get filled with extra boxes and other debris, and are perfect locations for pests to hide. Keep these areas clean and clear of clutter so pests have fewer areas to seek shelter and reproduce.

Cockroaches especially love cardboard boxes, so take those to recycling facilities regularly. Remove any equipment that is not being used. If you have re-sealable containers, clean out all the containers before placing new products inside. All containers should be tightly sealed and kept six inches off the floor and 18 inches away from walls. You can also affix mops and other types of cleaning equipment to the wall. Keeping them off the ground will keep them dry and prevent them from sitting in standing water, which is a major hot spot for fly breeding and bacteria build up.

Don’t forget that pests are experts at squeezing under receiving doors and sneaking onto shipments. To prevent unwanted stowaways, ensure your exterior doors form a tight seal when closed and always give delivery trucks and incoming shipments a thorough inspection for pest activity. Pests love to sneak into any opening they can find, so keep building exits, loading docks and other entrances closed as much as possible. Install weather stripping and door sweeps to keep pests out by creating a tight seal around openings. Believe it or not, rats can squeeze through a hole the size of a quarter, mice through a gap the size of a dime, and crawling insect pests through spaces barely noticeable to the human eye. For other cracks and crevices, use weather-resistant sealants to close any openings and consider installing metal mesh for an extra layer of protection against rodents that can gnaw openings to get inside.

3. Don’t Forget the Great Outdoors

To keep your exterior spic and span, create and maintain a regular sanitation schedule for your building’s exterior so it doesn’t become a haven for pests.

Regular pressure washings of sidewalks and walls will knock away any debris or build-up on exterior surfaces and could help remove any bird droppings around the property that could be brought inside by foot traffic. While it seems like a no-brainer, keep dumpsters and recycling collections as far away from facilities as possible, and make sure they are cleaned and sanitized frequently. And like interior cleaning best practices, don’t neglect areas above or out of the line of sight like gutters and rooftop ledges. Sometimes, leaves, standing water and other debris can build up over time, which provides breeding areas and shelter for pests—­especially mosquitoes.

Did you know that flies are not just attracted to food processing facilities because of food smells, but also for their exterior lighting? Flies and other flying insects are attracted to light and may use it for orientation. Mercury-vapor lighting is especially attractive to flies, so consider swapping mercury-vapor lamps next to entryways with sodium-vapor lights or LEDs. And to lure flies away from your building, place your facility’s mercury-vapor lighting at least 100 feet from entrances. It is often important to remember that the best option is always to direct lighting towards a building rather than mount lighting on it.

Good outdoor pest maintenance also includes landscaping. Trim your trees often and keep plants at least 12 inches away from your building. This decreases the chance of pests using vegetation as breeding or nesting grounds and the chances they’ll get access to your facility. Standing water often becomes a breeding site and moisture source that could provide pests like flies, mosquitoes and rodents with water necessary for survival. Remove any standing water around your building to prevent this and remove any reason for those pests to stick around. Look for stagnant water in gutters, ponds, birdbaths, water fountains and any other places that water could sit for more than a week without moving.

These proactive pest management tips will be useful in protecting your building and products from food safety threats. If there are any tasks that require additional help, consider talking to your pest management provider about creating an IPM plan. They will walk through your facility with you to identify any hotspots and suggest potential corrective actions—you’ll be glad you did when it’s time for your next audit.

Zia Siddiqi, Orkin
Bug Bytes

Stored Product Pests May Be Lurking in Your Facility

By Zia Siddiqi, Ph.D.
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Zia Siddiqi, Orkin

Pests can be sneaky. Many can compromise food products without anyone realizing they’re present. This is bad news for food processing facilities where an abundance of food products can translate into high pest pressure.

Beetles and moths are two of the main offenders in this environment and are referred to as stored product pests. These creatures can cause safety and legal concerns if they find their way into products, as they are quite adept at doing. They can damage packaging and cause product contamination or alter the taste of products when they secrete chemicals from their bodies, as many do.

This is not only a concern for your business’s reputation and bottom line, but could cost you major points on your next audit. Especially under the new FSMA regulations, prevention must be the emphasis in all U.S. facilities. This represents a shift from previous regulations as the new ones require risk-based preventive controls.

Integrate pest management
Does your company have an integrated pest management plan? Image courtesy of Orkin

The best way to prevent stored product pests and adhere to FSMA regulations is by implementing an integrated pest management (IPM) program. IPM programs focus on proactively preventing pests by inspection, monitoring and eliminating conditions that attract or harbor them using tactics like exclusion and sanitation, using chemicals only as a last resort. Under FSMA, you need to identify potential roadblocks and actively work to remove them. Showing constant improvement over time is an absolute must.

These programs also call for comprehensive documentation to monitor pest issues and ensure improvements are made over time. Auditors love to see documentation, as it shows that you are consciously working to strengthen your pest management efforts with continual improvement. If your facility doesn’t have an IPM program, it’s time to make a change sooner rather than later.

To successfully prevent stored product pests, you need to understand what they are and why they are attracted to your facility.

Types of Stored Product Pests

There are many different species of stored product pests, but they can be classified by four main categories based on their biology and habits:

  1. Scavengers: Eat just about anything, even if other pests have been there first. Pests in this category include the red flour beetle and sawtoothed grain beetle.
  2. External feeders: Feed on the exterior of cereal (grain) and kernel products and work their way inside. Pests in this category include Indian meal moths and cigarette beetles.
  3. Internal feeders: Lay eggs in the grain and feed on kernels from inside. Pests in this category include granary weevils, lesser grain borers and Angoumois grain moths.
  4. Secondary feeders: Eat from the outside in and consume moldy and damp food products. Pests in this category include spider beetles and fungus beetles.

How do you know if you have stored product pests? An infestation becomes apparent when the pests can be observed crawling or flying around. At this point, it’s important to identify the specific species that is plaguing your facility, as this will dictate the appropriate treatment method.  A trained professional can help correctly identify the species and recommend the best course of action to resolve the problem. Stored product pests reproduce quickly, so it’s critical to address any infestations before they have time to multiply and contaminate additional product.

The most common stored product pests are:

  • Sawtoothed Grain Beetle. Can burrow directly through boxes and packaging, so even sealed foods are at risk. They prefer processed food products like bran, chocolate, oatmeal, sugar and macaroni.
  • Indian Meal Moths. One of the most common pests for food processing facilities, the larva feeds on a large variety of different products. Some distinctive signs of an infestation are silk webbing and frass near the surface of the product.
  • Cigarette and Drugstore Beetles. Also able to chew through packaging, these beetles prefer pet food, spices, tobacco and any packaged food.
  • Granary and Rice Weevils. Prefer whole grains or seed products like popcorn, birdseed and nuts. They are recognizable by a snout protruding from their head and their reddish-brown bodies. Grains infested by weevils will be hollow and have small holes.
  • Spider Beetles. Similar to small spiders in appearance, they prefer grains, seeds, dried fruits and meats. They often accompany a rodent infestation because they prefer grain products that are old and moist.

Prevention Tactics

To help prevent stored product pests, incorporate the following tactics as part of your IPM program:

  • Closely inspect incoming shipments and packages. Look for the signs of stored product pests, like webbing, larvae and live adult insects. Check for signs of damage, especially for holes that can be caused by boring pests. To monitor for pests entering in this way, a quality assurance sample should be placed in a closed, labeled plastic container for later observations to see if any activity is noticed. This will give you a better idea if pests are present and what types may be being introduced via the incoming shipment.
  • Use of pheromone traps. These are the best tool to monitor the pest activity. These traps can also be placed in transportation vehicles to see if the trucks have a resident stored product pest population.
  • Use temperature as a repellant. Most stored product pests cannot live in extreme temperatures. If storage rooms can be maintained at 60°F or lower, stored product pests won’t be able to establish themselves inside.
  • Practice the first-in, first-out (FIFO) approach for products. Deteriorating products are an invitation to stored product pests, so make sure that older products go first and remove any with damages. It is also best to store products off the floor and more than 18 inches from walls, as it makes it easier to clean the surrounding area.
  • Create a sanitation schedule. Keeping a facility free of food debris will go a long way in eliminating attractants for pests. Clean up product spills immediately, and vacuum and wipe down everything on a regular basis. Don’t forget the cracks and crevices!

Keep in mind that being proactive is an important part of this entire process. If you see something, say something. Resolving pest issues as quickly as possible will be beneficial in the long run, as infestations are naturally more difficult to remove and could cost your facility dearly during an audit. A pest management professional will be able to point out the hot spots around a facility and can help to ensure that proactive prevention tactics are in place before anything gets out of hand. If any products are compromised, discard them immediately.

Pest Management: A Team Effort

The stakes are high in the food processing environment, which means pest control must be a priority. The most successful pest control programs are a team effort. Form a strong partnership with your pest management provider and work closely with them throughout the year to proactively prevent pest problems. Reach out to them early and often if you suspect any issues.

It’s also important that your entire staff is aware of pest management initiatives and tactics, which is why many pest management providers offer free staff training courses upon request. Take advantage of the resources available through your provider.

Working with a pest management provider to create a customized, IPM plan will help prevent pests and in turn protect the quality of your products and your business.

Bryan Armentrout, Food Leadership Group
FST Soapbox

Tips on Handling an FDA Audit

By Bryan Armentrout
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Bryan Armentrout, Food Leadership Group

Here’s a typical scenario.

You are the QA Manager for a dairy manufacturing facility in the Midwest. It’s been a long week and you decide to come in a little earlier than normal to catch up on paperwork. You find out when you arrive that product is on hold because the filling line is down. Maintenance is all over the machines, and orders are piling up; the paperwork will have to wait. You head out to the line to see what you can do to help.

This only happens when the plant manager is on vacation, you think to yourself.

As you walk out to the floor, your ears perk up as you hear your name paged over the intercom. The receptionist needs you in the front office—immediately.

What now?

You can’t think of anyone who is scheduled to visit today. You heart sinks a little. You don’t like surprises and this could be a bad one.

You come around the corner to the lobby to see exactly who you were hoping you wouldn’t see: An FDA investigator.

“My name is Investigator Brown,” he says as he flashes a badge. “We’ve had an allegation of an illness from your product. I am here to look into it.”

You smile politely and nod. He does not smile. You motion for him to follow you to a conference room.

Your day just got a whole lot longer.

How will this go?

The answer to that question is, in many ways, up to you.

FDA investigators are people and they take their job as seriously as you do. They are there because they need answers. Their boss expects answers. If people are getting sick, they need to find out quickly and take action. If this is truly the case, you need to know as well. So does your boss. No one wants people to get sick.

The absolute wrong thing to do in this situation is to not have a plan. You need to know how to handle a regulatory inspection. You need a plan to prevent a misunderstanding or create a situation where something minor gets blown out of proportion.

This is not the time to play it by ear. You need training and you need a plan.

An important point to remember is that your product may not have caused the illness. People often assume the last food they ate is the one that made them sick. In reality, incubation times may take significantly longer for symptoms to manifest. Samples of the product in question are rarely available to test. Dosage, health of the person, and other factors also come into play. You need to work with facts and not supposition—as does the FDA.

Tips for an FDA Inspection

  1. You are guilty until proven innocent
  2. You are not alone
  3. You are the company spokesperson
  4. Take lots of notes
  5. Seek first to understand, then to be understood
  6. Answer the question being asked
  7. Know what is in scope and what is out of scope
  8. Don’t sign or initial anything

1. You are guilty until proven innocent

In general, you can assume that FDA thinks you are at fault; that is why they are there. You will have a hole to dig yourself out of before you can convince them otherwise. Don’t let that rattle you, they are only doing their job, and your job is to show them all the great food safety programs you have in place to prevent what they are concerned about. Keep this in mind as you go through the visit. If you are doing a good job, you should see their demeanor soften as they gain confidence in what you do.

2. You are not alone

Don’t be a hero, you need a team to help you in this situation. You need the people in the plant and you need people at corporate ready to back you up. You most likely also need access to outside counsel that specializes in food regulations. Your role in the room is to facilitate and work with FDA to get them what they need. You and FDA are on the same side of the table in this respect. Both of you are working to find out if the illness is real.

If you are not sure of an answer, say so! Call corporate QA and your legal counsel and discuss it. Find out what the answer is from someone who does know. If you still don’t have an answer, it’s better to admit it than to make something up. Tell them when they can expect an answer, even if it may be after the audit concludes. Never make stuff up.

3. You are the company spokesperson

The company should have only one voice (most likely, you) responding during the inspection. This avoids confusion and keeps you in control over the message being delivered. Other agencies, such as OSHA, have the right under the law to interview employees during an investigation. It is not that clear cut with FDA. Make sure you explain to FDA that you are the designated spokesperson for this inspection and that all questions need to be routed through you. The personnel in the facility need to understand this as well and defer to you if FDA questions them. If the question is out of the ordinary, it may need to be in writing. When on the floor, never leave the investigator alone, accompany them at all times (don’t go crazy, they can use the bathroom by themselves).

4. Take lots of notes

Have someone who can tag along with you to take written notes of the visit. Train them on what you expect. Time stamp the notes and use a stream of consciousness approach. Write down everything, more notes are preferred. You may need them in the future. Never take the notes yourself, you are going to be too busy to do that. Mark the notes confidential and do not give a copy to FDA. Also, make sure that you have a clear and explicit ‘no photography’ policy in place. Train your people and enforce it. FDA may want to take pictures and they will tell you that they have the right to do so. That is open to debate and the issue has yet to be resolved in court. In the meantime, your policy is clear, so insist that they do not take pictures. This is your plant and your proprietary process; even with the best care, your competitors might find out more than they should about what you do.

5. Seek First to Understand, then to be Understood

This rule applies everywhere in life, and especially during an FDA inspection. Gather all the information you can. Are they going to take samples? If so, you need to prepare for that. Ask for the purpose of the visit and any supporting information you can get. Seek to first meet the needs to the investigator and to understand the exact context of the inquiry. The better you understand the purpose, the easier the day will be. Just like the investigator, you have a boss. You have limits to what you can and cannot do. Make sure the FDA understands that you are the representative, but the answer may need to come from other sources. Company policies are not written by you and cannot be altered. You are both on the same side of the table and rules need to be followed. They will understand and respect that.

Best Practices for ISO 17025 Accreditation: Preparing for a Food Laboratory Audit (Part I)

By Joy Dell’Aringa
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An increasing number of food testing laboratories are seeking accreditation to the ISO/IEC 17025:2005 standard. This growth is chiefly due to regulatory implications, customer requirements, and trade organization recommendations and is seen across laboratory segments: third-party contract laboratories, private in-house laboratories, and government laboratories. ISO 17025 is the most common standard in the food testing industry and sets the guideline for “Laboratories Performing Microbiological and Chemical Analysis of Food and Pharmaceuticals”. Accreditation is known generally as a third-party attestation related to a laboratory, which conveys formal demonstration of competency that implies a reliable and consistent level of quality across an operation for a well-defined parameter of tests, often referred to as the “Field of Testing”. There are several qualified organizations that accredit laboratories to the standard; these organizations are referred to as Accrediting Bodies and are responsible for assessing facilities for conformity to a given ISO standard.

Audit Preparation Guidance

Initial Accreditation: Considerations & Preparation

When a laboratory initially entertains applying for accreditation, several factors should be considered. The cost and time commitment required to become initially conformant, and the on-going resources required to maintain conformity should be thoroughly examined in an overall benefit analysis prior to applying for accreditation. Management should be fully aware of the investment and perpetual commitment of becoming an accredited facility. Accrediting Bodies (ABs) provide resources and literature that can help guide laboratories through the initial audit-preparation phase. However, creating the systematic application of these guidelines that balances the quality and operational objectives of the organization are unique from laboratory to laboratory. Simply put: There is no cookie-cutter approach to accreditation.

Consultant Considerations

Q Laboratories in Cincinnati, OH first embarked on the path to ISO 17025 accreditation in 2009. James Agin, director of regulatory compliance at Q Laboratories and member of the A2LA Laboratory Accreditation Council took the lead on preparing for the initial assessment eight years ago. Q Laboratories was initially unfamiliar with the process, so they hired a consultant who was also an assessor to walk them through the process. “We took about four to five months with a consultant,” says Agin,. “In addition to creating the necessary systems, we gathered the troops and did a deep training on what ISO 17025 is, why we were pursuing it, and why it was important to our business.” The Q Laboratory team created a deep sense of ownership during the education and training process from the supervisors to the bench analysts, which they credit to their ongoing success years later. Erin Crowley, chief scientific officer at Q Laboratories suggests new labs consider hiring a consultant to ease them through the process and get them audit-ready. “If you’re not accustomed to having certain systems in place, a consultant can provide clarity and help initiate processes,” says Crowley. “Having an open forum with an expert helped give our entire team confidence.”

A consultant can streamline the initial process and help avoid some of the pitfalls in creating a robust quality management system for the first time. Tim Osborne, senior director of training services at A2LA offers advice for organizations when vetting a consultant. “While certainly not required, a qualified consultant may be a good asset to have in your quiver,” says Osborne. “Look for industry references and pay close attention to involvement in the industry outside of its own laboratory. Does this person work for an accrediting body? What are the areas of analytical expertise? Does this person also provide training for an accrediting body? If so, it is likely the consultant will offer the quality of services you need to be successful.” It is important to note that assessors and consultants should be upfront with the accrediting body to avoid conflict of interest issues during the actual assessment. Impartiality is critical within the assessment process.

Application Process

Accrediting bodies publish their own “readiness” documents. Laboratories seeking accreditation should request an itemized guide that walks the organization through each phase of the process. The following is a general outline:

  • Obtain copy of ISO standard (17025, 17065, 17020, etc.). Review any specific requirements relevant to your field; these are generally available in a checklist format allowing the laboratory to prepare through an internal audit process.
  • Determine estimated costs with the accrediting body
  • Obtain a copy of the accrediting body s assessor checklist. This usually has to be completed as part of application process
  • Prepare the intended draft scope of accreditation (outlining, specific tests/test methods, calibration parameters/ranges, certification schemes)
  • Implement the management system, and ensure personnel are aware and accept the content
  • Perform an internal audit to verify compliance with the conformity assessment standard requirements, accrediting body requirements, your own management system requirements, and applicable technical requirements
  • Perform a management review
  • Foreign applicants may need to translate supporting application documents to English
  • Identify one specific individual to be responsible for accreditation efforts and interactions with the accrediting body. Identify the “quality manager” who is in charge of the management system
  • Obtain, prepare, and submit the application for accreditation to the accrediting body

Once the initial assessment is complete and the final response and corrections to any deficiencies is in, the laboratory will be reviewed and considered for accreditation through the accrediting body. When the decision is made in favor of accreditation, the laboratory will receive their accreditation certificate, which will correspond to a specific location and set of tests (commonly referred to as a Scope of Accreditation (“Scope”) for the Field of Testing (“FOT”) for which they were assessed). Depending on the accrediting body, the certificate may be valid for one to two years, and will require re-assessment and surveillance at defined frequencies. The laboratory is responsible to maintain conformance to the ISO 17025 standard in between assessments.

Continue to page 2 below.

Zia Siddiqi, Orkin
Bug Bytes

How to Find the Right Pest Management Partner

By Zia Siddiqi, Ph.D.
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Zia Siddiqi, Orkin

When you choose a new vendor to partner with you, the decision is always important. Every vendor plays a role in your business and bottom line.

Some vendors, like pest control providers, can protect your brand and even help boost your reputation in the industry. When you factor in everything your pest control program can affect, it’s clear that picking the right pest management provider is one of the most important vendor decisions you’ll have to make.

Under FSMA, food processing facilities must execute proactive pest control programs and documentation efforts that not only follow and but also implement a risk-based prevention program to protect their product and consumer base
Under FSMA, food processing facilities must implement proactive pest control programs  and a risk-based prevention program to protect their product and consumer base. Image courtesy of Orkin.

Consider how pest management can impact your audit scores, especially when you’re expected to be audit-ready at any time. The success of your third-party audit hinges on documentation, and the pest management portion can make all the difference in your score, accounting for up to 20%. FSMA requires food processing facilities to execute proactive pest control programs and documentation efforts that not only follow and but also implement a risk-based prevention program to protect their product and consumer base. Just one low score can cause your customers to lose trust in your business—and if they pull their support, you could see a major impact on your balance sheet.

The safety of your products and even the health of your employees are also at stake. Cockroaches and ants can pick up and transfer harmful bacteria. Flies can spread disease-causing organisms when they land—and they land frequently, it can lead to them leaving their traces in an abundance of places.

Then there are rodents, which can also cause serious health problems. According to the Centers for Disease Control and Prevention, rats and mice are known to spread bacteria like Salmonella and E. coli, as well as more than 35 diseases worldwide, such as Hantavirus.

A Blueprint for Success

From its impact on audit scores to its role in abating health concerns to brand protection, pest control should be a priority for any food processing facility. There are several best practices to follow, most of them falling under the umbrella of Integrated Pest Management (IPM). IPM is the preferred proactive pest management practice in the food processing business, and it can help meet and exceed the requirements of industry auditors.

IPM programs are ongoing, comprehensive and well-documented, focusing on risk-based preventive strategies like sanitation and facility maintenance to help prevent pest activity. They’re also customizable based on your property and the pests you face.

It’s essential to find the right, licensed and experienced pest management professional who will partner with you and your staff to implement a customized IPM program for your facility and help keep pest problems away. When starting your search for a pest management partner, be sure to ask about IPM. One-size-fits-all pest management solutions are simply not effective, so look for a provider who can tailor an IPM program specifically to your needs.

When searching for a pest management partner, look for one that stands out with the following guidelines.

Talk to your peers. If you’re looking for pest management recommendations, start by talking to your industry colleagues about the successes—or challenges—they’ve had with their vendors. If you’re a member of a larger network or GPO, you may have a preferred provider in which to start your search.

Start with an inspection. Once you have a list of options to check out, it’s time to put them to the test. As IPM programs are customizable, insist that your prospects inspect your facility to determine the challenges you face and the services you need.

Get the details in writing. Remember, FSMA requires written risk-based preventive food safety plans that detail likely hazards, corrective actions and results. With this in mind, your pest management professional should thoroughly document any service visits and corrective actions.

Documenting your pest management plan does more than fulfill the FSMA requirement. The best pest management providers will document their every move, using the information to determine pest trends, which can aid in decisions about how to best manage pest activity going forward. These records should be kept on-site for any surprise audits.

Ask for audit help. In addition to documentation, your pest management professional should work with you to ensure all documents are in proper order and audit-ready at any time. Look for a provider that can help you prepare for the third-party auditor and food safety standards with which your facility is required to comply, and even provide on-site support the day of your audit.

Think about your entire staff. One of the most overlooked variables when choosing a pest management provider isn’t how the company works in your facility, it’s how it works with your staff. For your new pest management program to be effective, your staff has to buy in—and your new provider can help.

Your employees play an important role in reporting pest sightings and keeping your facility clean. With this in mind, make sure to ask about resources that your pest management professional can offer your staff. Many offer staff training and educational resources like tip sheets and checklists, and often at no extra cost.

Add accountability, establish thresholds. You may pick an outstanding pest management partner, but ideal results won’t happen overnight. Depending on your facility, creating a pest-free environment can be difficult, even with the best of help.

Progress is achievable and quantifiable when you have pest thresholds. Thresholds dictate how much and what kind of pest activity is acceptable before corrective actions need to be taken, and they are best set by working with your pest control professional because several factors can come into play.

Older facilities or buildings in environments more conducive to pest activity, such as areas near water, locales in warm environments or heavily wooded spaces, may face more pest pressures than newer establishments. Your pest management professional may want to counter these challenges with exclusion recommendations that can include extensive building maintenance and repairs.

If you’re in a newer building and don’t currently battle any present pest issues, it may be perfectly reasonable to move forward with a “one pest is one too many” threshold. To make sure your program stays this effective, your provider may need to adjust tactics of your IPM program over time.

Even with a sound IPM plan, however, if you are currently battling pests like cockroaches, flies or ants, reaching your threshold goals will take time. Work with your pest management provider to create a timeline for steady and reasonable improvement.

Once you choose a pest management partner, keep the lines of communication open and establish roles for everyone involved. Set benchmarks for your pest management program and specific times throughout the year to evaluate the program’s success and areas of improvement with your provider.

Keep all of this in mind, and you can help build a solid, long-lasting partnership. As a result, pest sightings can fall as your audit scores rise.

Vice President, Science Operations, Grocery Manufacturers Association
FST Soapbox

GFSI and FDA’s Preventive Controls: Complementary or Redundant?

By Jennifer McEntire, Ph.D.
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Vice President, Science Operations, Grocery Manufacturers Association

Accreditation, certification, certificates…the structure that supports the third-party audit system can be very confusing! Further, an audit company offers a menu of audits: An audit to their own private standard, audits to several GFSI benchmarked schemes, and perhaps in the future, an “FDA accredited” audit. How do you know which one you need? How do you know which best prepares you for FSMA?

Jennifer McEntire spoke during the session, “Staying Ahead of New USDA and FDA Mandates for Controlling Pathogens in Food Processing” at the Food Safety Consortium conference.  LEARN MOREUntil the compliance dates for the Preventive Controls rules pass, food manufacturers really only need to be compliant with good manufacturing practices (GMPs), from a regulatory standpoint. There are some specific audits that evaluate adherence to GMPs, but many companies wanted to take their food safety programs to the next level by demonstrating that they were implementing effective food safety management systems. Certification to a GFSI-benchmarked audit scheme (BRC, SQF, FSSC22000, IFS, etc.) was a primary means to show a commitment to food safety and the demonstration of exemplary programs. With the finalization of the Preventive Controls Rules, FDA is catching up. So how do the FDA requirements compare with the main elements of the GFSI Guidance Document?

Let’s evaluate the extent to which the scope of GFSI aligns with FSMA. In September, the Preventive Controls for Human Food rule was finalized, and the areas addressed within that rule constitute the bulk (although not all) of the topics covered by GFSI (GFSI covers additional areas for which FDA has not yet finalized rules, such as food defense and traceability). The question on everyone’s mind is, “If I’m certified to a GFSI-benchmarked audit scheme, am I compliant with the rule?” The answer is, “You’re probably in way better shape than someone who is not certified.” The reason is, regardless of which GFSI benchmarked audit scheme you choose, your facility will need to demonstrate, through fairly exhaustive documentation, the nature and validity of the programs that are in place, and the proof that those programs are followed day in and day out. FDA is looking for the same thing.

The Preventive Controls rules go beyond strict HACCP in that they require facilities to consider what has historically been termed the HACCP system. This includes programs that may not be critical control points (CCP) per se, but are critical to the safety of the food product. FDA identifies elements of sanitation and allergen control, as well as a supplier program, in this category. If you’re familiar with FSSC 22000, you might call these “operational prerequisite programs”.  FDA will want to see how each and every hazard is evaluated to determine if it needs a preventive control, whether that is a traditional CCP or another control. For the most part, this is aligned with the GFSI benchmarked schemes, although some of the language may differ.

When it comes to the implementation of a supplier program, facilities should be aware that FDA’s requirements of such a program are much more explicit than most of the GFSI-benchmarked schemes. Even if the result is the same at the end of the day, FDA inspectors may be looking for companies to follow a fairly structured approach compared to a GFSI auditor.

To further complicate matters, FDA will be finalizing a program for the accreditation of third-party auditors. If an effective private third-party audit system exists, why is FDA adding another layer with its own form of audits (separate from inspections)? The answer lies with Congress, not FDA, as it identified two specific circumstances in which a special regulatory audit would be necessary. One situation is when a facility (or their customer) wishes to participate in the forthcoming Voluntary Qualified Importer Program. The second is if FDA has determined that the food poses food safety risks such that a facility wishing to export that food needs a certification issued by an auditor under this program. In neither case will domestic facilities be audited under this program; this program only applies to foreign facilities and only in very limited instances.

Since the rule and accompanying guidance documents related to accreditation of third-party auditors hasn’t been issued by FDA, it is premature to comment on how these audits will compare to those in use by private industry today.

So with the implementation of new rules from FDA, is there still a market for audits? Absolutely. From a very practical standpoint, FDA won’t be inspecting most facilities on an annual basis, and many private audits are conducted on an annual schedule. Plus, industry typically pushes itself further than regulations, which lag behind. Regulations can be viewed as the floor for expectations, but not the ceiling. Moving forward, we expect audit standards and private audits to become even more stringent and aggressive in terms of promoting the very best food safety practices. But beware, as history has shown us, a certificate is not a guarantee or indication of the ongoing quality of a plant’s food safety system. This is why FDA will not blindly accept that a facility has a favorable audit; regardless of the audit certifications you hold, FDA will still inspect you. That said, depending on the audit, it can serve as a credible certification of a food safety system in a plant and demonstrate to your customers your level of food safety commitment.  And poor performance during an audit can find its way to FDA too, since in some instances the agency will have access to the conclusions of the audit and corrective actions taken in response to significant deficiencies identified during the audit. FDA initially proposed that serious issues uncovered during consultative audits conducted as part of the third-party accreditation of auditor program would be shared with FDA, and when audits are used as part of supplier programs, FDA will see how serious deficiencies in audits have been addressed. Be clear on why you are pursuing a particular audit, and take the program seriously. Audits should reflect your food safety culture, not serve as your motivation.

Why Management Reviews and the SQF System Go Hand-in-Hand

By Clare Winkel
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SQF certification is an ongoing process; once you have attained it, you have effectively committed to a continuous improvement program for your business. Conducting regular, thorough and transparent management reviews will play a key role in ensuring that you continue to achieve your SQF goals.

The first and most important thing to understand about management reviews is that they don’t have to be a cost to your organization. In fact, when conducted correctly, these reviews should become the cornerstone of your continuous improvement program, assisting you in measuring company performance against documented objectives.

Once you’ve committed to a management review, it’s important to be aware of the fact that these reviews take significant preparation. The senior management team will be responsible for reviewing the SQF system, preparing for and documenting the review procedure in its entirety. As outlined in clause 2.1.2.4 of the SQF system, there are four key elements against which company performance must be reviewed:

  • The SQF policy manual
  • Internal and external audit findings
  • Corrective actions (investigation and resolution)
  • Customer complaints (investigation and resolution)
SQF Management Review Procedure
Click to enlarge this document on how to conduct a Management Review Procedure

The management team is required to make adequate resources available for food safety and quality objectives and to support the development, implementation and maintenance and ongoing improvement of the SQF system (clause 2.1.2.3). This team must also establish processes to improve the effectiveness of the SQF system in order to demonstrate continuous improvement (clause 2.1.2.9).

Keeping Good Records

One cannot overstate the importance of thorough and effective documentation of the review, so remember the mantra: If you don’t write it down, it didn’t happen.

Every aspect of your review must be clearly and thoroughly documented. These records are important documents in the SQF audit process and also as benchmarks against which company performance and subsequent reviews can be measured.

Management Review Process

The management review process comprises four key stages:

  • Identifying objectives
  • Collecting and analyzing data
  • Management review meeting
  • Disseminating results

1. Identifying Objectives

Identifying objectives should be your first step. You cannot start collating data before you know what you’ll be measuring it against. Objectives are essentially short statements that outline what you want your company to achieve in specific business areas. They should encompass a whole-of-company approach in that they should contribute to overarching company goals rather than delivering a one-sided or fragmented approach to continuous improvement. It is important to note that objectives are neither mission statements nor warm and fuzzy statements.

As a general rule of thumb, objectives should be:

  • Measurable. They should outline specific quantities and quotas for what you are trying to achieve.
  • Business-specific. Objectives should be relevant to the future of your business and to the individual business improvement process. Don’t worry about what your competitors are doing.
  • Relevant. Make sure the objectives will have a significant and lasting impact on your business once they are achieved. This might mean choosing complex objectives versus taking the easy way out.
  • Linked to a key performance indicator. Every objective should contribute to the company’s KPIs and be part of its broader strategic goals..
  • Clearly defined. Be clear about what you are trying to achieve and how you plan to achieve it.
  • Documented. Write your objectives down! The review process, future audits and your ongoing improvement efforts will be measured against them, so it is important to accurately capture the details.
  • Communicated across the breadth of the organization. Don’t make the mistake of keeping them in a filing cabinet somewhere. Put them in the lunchroom, put them in induction packs, hand them out during annual updates—share them with your team so that everybody understands the goals.

2. Collecting and Analyzing Data

Data collection is one of the most time consuming components of the management review process, so have a clear game plan ready before starting. Ask the following questions:

a.    What information must be extracted from company records?

Determining the sort of data you need depends largely on your management review objectives. Your data should deliver insights on company performance and provide an evidence base for changes you make to your business processes. As a food company, your SQF systems should monitor and collect data on a wide range of business activities, including:

  • Preventative maintenance result reports
  • Equipment breakdown reports
  • Goods inwards records
  • Verification results (i.e., swab results, lab results)
  • Cleaning records
  • Corrective action reports
  • Near miss incident records
  • Pest control records
  • Swab and microbiological results from cleaning processes
  • Microbiological results from water supply and product testing, or raw material testing
  • Insurance and credit claims
  • Chemical product results
  • Mock recall tests
  • Product traceability tests

Think about the data sources that respond directly to the objectives you developed for your review. You should be leveraging the systems you already have to collate information, with a view to feeding the information back into work practices to create a loop of continuous improvement.

b.    What format is the data in and how can you make it accessible?

Like most food companies, your company is likely to be home to a mix of paper-based and electronic data. Different data types throw up different challenges when it comes to data acquisition. Paper forms are easy for staff to use and easy for management to collect, but they require double handling in order to translate relevant data into a format that can be analyzed with any degree of depth. Electronic data collection is more useful when it comes to number crunching, but you need access to specific expertise when it comes to data extraction if you want your data to work effectively for you. Newer, more sophisticated data management systems will help automate data collection activities and will also ensure that your database systems can communicate with each other to share relevant information.

Data access is another issue to think about early in the process. Who is responsible for all the different data sets that must be accessed for the review? Is he or she the right person to manage that data? Will he or she be available at the time you need to access the data before the review?

c.     Who will analyze the data, and do you have the requisite skills in-house?

Another important element of the pre-planning process is the question of who will analyze the data once it has been extracted from your systems. Does your staff have the skills and time required to conduct effective statistical analysis? Do you have suitable software systems to support the analysis process? If so, you’ll need to allocate each data analysis task to a staff member, making roles, responsibilities and timelines for the analysis process clear. In addition, ensure that all managers have access to (and an understanding of) the previously identified management review objectives so they can target their analysis appropriately.

If you don’t have the requisite data management skills in-house, you need to think through potential solutions during the pre-planning stage, whether it involves providing training for staff or bringing in outside expertise.

Prior to the data analysis process, you should also be looking at your raw data and reviewing data outliers (that is, data that lies above or below the mode)—these can sometimes provide interesting insights about your processes and procedures. It’s important to have an experienced quality assurance team on board before you start assessing your outliers; your QA team should already understand the variables within your processes and procedures, and will therefore be able to identify whether the outliers are one-off data spikes or trends requiring further investigation.

3. Management Review Meeting

a. Meeting preparation

Meticulous preparation is key to a successful management review meeting. Ensuring all meeting attendees are on board with the agenda and meeting outcomes is a good way to get started. First, develop a written agenda and timeline for the review. Think about the timing of your meeting in conjunction with your unannounced SQF audit. Set the date of the meeting with enough time to ensure close off of the corrective actions issued as a result of the meeting. Yes, if you’re doing it properly, you should have corrective actions issued.

Next, you’ll need to get all participating staff members up to speed with the review process. Pull together the requirements of the review, the relevant SQF clauses, customer requirements and company objectives, and put them into a document that can be circulated well in advance of the meeting. Identify the individual managers who will be involved with the review—that is, the managers whose business areas will make a contribution to, or be impacted by, the review process itself. Ask participating managers to prepare the data that is relevant to their key performance areas and to the management review objectives you’ve identified, as this will be distributed at the meeting.

b. At the meeting

Good record keeping is particularly important during the management review meeting itself. Poor documentation can undermine the review and its subsequent outcomes, not to mention the SQF auditing process. As such, it’s important to capture the details of the discussion that occurs at the meeting—you need more than just a few scribbled notes. Nominate a scribe whose sole responsibility is to take notes at the meeting. Ensure they capture (at a minimum) the following:

  • Meeting date and time
  • Meeting attendees and no-shows
  • Discussion of each agenda topic
    • Key items
    • Outcomes
    • Conclusions
    • Action points
    • Objectives. Were they met? If not, why not? Do they need to be modified for next year? If so, why, and to what?
  • Action points, role responsibilities and verification of actions being undertaken
  • Conclusions

The scribe should also be responsible for compiling all supporting documentation from the meeting for audit purposes and for review prior to future management review meetings.

4. Disseminating Results

Once the review process is completed, any processes and procedures identified as requiring modification must be updated. This is also the time to follow up on action items—your meeting documentation should clearly show who is responsible for each item and their respective tasks. Engage with the staff members responsible for each item at regular intervals to chart their progress, and follow up again at subsequent management meetings to ensure that all actions have been completed.

Communicating review outcomes is very important. Charting a specific course requires an understanding of, and commitment to, that course by everyone involved in the navigation process—and you need your team to understand where you’re going so that they can help you get there. This means communicating all the outcomes, both good and bad, to all relevant personnel, and taking the time to thank and congratulate staff who were instrumental in achieving positive results.

The last step of the review process is to share your success—don’t let your hard work go unnoticed! Communicate the value of the review both to your team and your superiors, and demonstrate the link between the review itself and the achievement of individual, team and company KPIs.

Conclusion

A completed management review will deliver significant benefit to your company in the form of documented, measurable and communicated objectives that are reviewed on an annual basis. Additional benefits include:

  • Increased business value
  • Enhanced safety (for staff) and quality of product (for clients)
  • A more targeted approach to business strategy
  • Reduced financial risk and increased profitability
Ron Harrison, Ph.D., Director of Technical Services, Orkin, LLC
Bug Bytes

Make Employee Training a Team Effort in Your Pest Management Program

By Ron Harrison, Ph.D.
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Ron Harrison, Ph.D., Director of Technical Services, Orkin, LLC

Pest management plays a key role in food safety and product integrity, and ensuring such is a critical, facility-wide undertaking. The success of a pest management program can be the difference between acing a third-party audit and facing a plant shutdown. An effective program is not just a one-person job; it requires an ongoing team effort from a company’s pest management provider and all employees. As such, beyond selecting an effective pest management provider, it’s equally important to recruit employees to help enhance your efforts. After all, they are the eyes and ears of your facility, as they spend a lot more time there than your pest management provider.

Arming your employees with the right tools and pest control knowledge will set up your pest management program for success. The following steps outline how you can get your entire team involved in your company’s program.

Teach the what, where and how

Your employees can be the first responders to any pest problems, but only if they know what they should be looking for and where they should be looking. For that reason, it’s essential that they complete training on the specific pest pressures your property faces and the red flags that alert them to pest activity.

Many pest control providers offer complimentary employee training, so ask your pest management professional to conduct an on-site training session for your team. These training sessions should include not only information about the specific pest pressures on your property, but also the conducive conditions and pest hot spots that your employees can help control. Pest hot spots are the key areas inside and outside your building that pests target as entry or harborage points. These areas are in constant danger of being penetrated by pests and are areas that currently or have previously had pest issues. Areas with standing water, excessive condensation or improper drainage are just a few examples.

Your pest management professional can also teach your employees the key components of integrated pest management (IPM). Rather than reacting to pest issues, IPM takes a proactive approach through a combination of non-chemical solutions, relying on chemical treatments only as a last resort. Proper sanitation practices, ongoing property maintenance to exclude pests, and regular monitoring are paramount to a pest-free facility.

Training sessions are also a great way for your employees and provider to build a strong relationship so your team is more likely to proactively report any pest issues.

Keep the lines of communication open

An open, ongoing line of communication between management, employees and your pest management provider is also an important component of successful pest management programs. Regular communication helps ensure that your employees are kept in the loop on important pest control information and initiatives. Furthermore, an open line of communication will keep you thinking proactively about pest management, which can help reduce decisions that lead to reactive chemical treatments.

This open dialogue will also help build rapport with your employees so they are more comfortable talking about sensitive issues, including the potential for bringing pests into the facility from home. 

Know your role

Your pest management program will work best when everyone involved knows his or her role. Consider assigning each team member a specific pest management task based on his or her daily duties. For instance, employees involved in facility maintenance can monitor for small holes or gaps in the building façade and seal them immediately to help prevent pest entry. 

 

In case of a pest sighting

Sometimes no matter how effective your IPM program is, resilient pests can still find their way inside your facility. Further, pest activity may not only originate locally, but from other parts of the country throughout the supply chain, making it somewhat difficult to immediately pinpoint the pest issue. This means there is a chance for both live and dead pests to make their way into your product, which can pose a nationwide health and safety threats to consumers.

With this in mind, it’s important to have a plan in place should a pest be spotted. Establish a pest sighting protocol that identifies the steps to report a pest incident, including who should be notified. The following are a few examples of steps that should be included in a pest sighting protocol:

  • If possible, catch and show the pest to your pest management professional.
  • Record the pest activity in a pest sighting report, making note of when, where and how many pests were seen.
  • Work with your pest management professional to determine what is causing the issue and how to resolve it.

Continue the education

Your employees need continued education to help keep your property on the cutting edge of pest control. Many pest management providers offer educational resources that facilities can use as ongoing education, including tip sheets, sanitation and maintenance checklists, and seasonal pest management tips. Ask your pest management provider if they have resources you can share with your team. You may also consider having your pest management professional provide further training sessions on specific pest problems.

Pest control is most successful when a team effort is involved. Work with your pest management provider to get your employees up to speed on the pest management efforts at your facility and ensure they have the basic knowledge needed to play a role in keeping pests out.

What Matters When Considering a Food Safety Audit?

Food companies need to get audited and their personnel need to get trained frequently, and this is a growing trend in the evolving regulatory landscape and a highly competitive and global supply chain. However, what matters the most to food companies when getting audited? How significant is auditor competence as an attribute? How about the time that the audit takes, and the time to get the report? Or for training, what role does technology play?

To understand this, Eurofins conducted a blind survey of industry participants – nearly 600 respondents answered questions related to Certification and food safety Training.

Some of the highlights included:

EurofinsSurveyMarch2015_1EurofinsSurveyMarch2015_2EurofinsSurveyMarch2015_3 Ultimately, the following factors influenced food companies’ decision to go through food safety certification:

  1. Customer Requirements/Requests Relationships;
  2. Industry Standard; and
  3. Value Proposition. 

When it came to training, the top three influencers to go through Food Safety Training were identified as:

  • Developing Competence (Gaining, Improving, Growing)
  • Relevance and Subject of Training Cost and Time

EurofinsSurveyMarch2015_4

Paul Dewsbury, B.Sc.

Honey Laundering: Food Fraud That’s Not So Sweet

By Paul Dewsbury
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Paul Dewsbury, B.Sc.

ThermoFisherpodcastAs a result of my research, I found two fantastic resources describing the background of food fraud, the first is an excellent 3-minute podcast on our website, titled, Food Fraud by Dr. Jennifer McEntire, who at the time was VP and Chief Science Officer at The Acheson Group and is now the newly appointed VP of Science Operations at the GMA. Dr. McEntire succinctly gets to the crux of the reasons pertaining to food fraud and it is well worth a listen.

The second is a 3-minute slide deck narrated by renowned food safety expert Professor Chris Elliot, Director of the Institute of Global Food Safety at Queens University Belfast. Professor Elliot highlights the impact of various food frauds including melamine adulteration in milk, spices, meat and he specifically expands on the topic of honey laundering.

There are too many honey adulteration frauds to list here and while some have resulted in huge fines and criminal charges, there is one that will not go away is the mislabeling of Manuka honey. This premium product (and premium price) is a rare honey from New Zealand produced by bees that pollinate the manuka bush and has numerous claimed medicinal properties that can be extremely profitable for the fraudsters through substitution with a basic product. As food fraud is an international issue, various organizations likeInterpol and Europol have food fraud units and here in the UK the government has committed to, and is setting up a dedicated Food Crime Unit.

Moving into the science, one of the best literature resources I would like to share is the Food Fraud Resources website which has some highly cited articles including reviews, thought leadership and analytical methods that are available for download. There are various techniques for honey analysis in the journals and I want to briefly focus on one of the most powerful for authentication, the use of isotope analysis. In our Application Note 30177, Detection of Honey Adulteration with FlashEA Elemental Analyzer and DELTA V Isotope Ratio Mass Spectrometer, we describe a fully automated system for the detection of honey adulteration with C4-syrups according to the AOAC 998.12 guidelines and is routinely used in many laboratories.

Is honey analysis or food fraud of interest to your laboratory? If so, share your thoughts and experiences in the comments below. 

Check out Thermo Fisher’s Food Community page for more resources, on-demand webinars, videos, and application notes.