Tag Archives: fssc 22000

Animal Feed Industry: Steps to Success to Meet FSMA Requirements

By Maria Fontanazza
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As industry awaits next month’s final rule on preventive controls for animal food, companies in the animal feed business must be prepared for the changes, especially as it relates to having an aligned system with HACCP principles. In a Q&A with Food Safety Tech, Victor Muliyil, food technical project manager at SGS SSC North America, and Mary Williams, a quality assurance and regulatory affairs expert at Land O’Lakes, Inc, discuss where companies should be looking for gaps in their systems.

Food Safety Tech: What critical changes does FSMA introduce to the animal feed industry?

Victor Muliyil: FSMA introduces the primary change that all feed manufacturers must have a feed safety hazard control program that is in line with HACCP principles. Hazards likely to occur must be identified and controls implemented; and [although] hazards related to medications and prohibited material must still be controlled, the responsibility is on the manufacturer to identify all hazards and controls. The focus is on prerequisite programs, not just on critical control points.

In addition, feed industry recalls can now be mandated by FDA, not just recommended. HACCP certification is not mandated by FDA, but several feed and food industry customers are looking for competent independent audit and certification of feed safety control programs. Trained internal auditors are required to verify the system. Traceability is required to the next level of distribution, as well as backward to key ingredients such as medications.

Mary Williams: Food industry leaders must now show they have “planned to work safely,” and this plan must be written down with documented evidence of training. This is a fundamental shift in approach, as FSMA indicates that all feed manufacturers must control feed safety hazards consistent with principles many of us have learned in HACCP. This speaks to prevention vs. reaction, so the prerequisite programs as a foundation must be in place first. This is a time of unprecedented change in the U.S. Food/Feed industry plus global supply chains that are expanding. While it is widely accepted that zero risk is unattainable, the approach that companies take to prevent having an issue, and to prepare for efficient and effective response in the event of a problem is seen as critical.

Product Safety Culture must be leadership driven and reinforced and furthermore, a strong product safety culture is a “choice”.  Leaders of an organization set the tone and must proactively reinforce the expected outcome because it’s the right thing to do, not just because it is the newest food safety law.

While many feed companies are moving toward HACCP certification, it is not mandated by the FDA.  Regardless of whether you build a HACCP plan or a Food Safety Plan, it is important for feed/food companies to start now. The cGMPs, new GMPs and most FSMA requirements are generally understood thus having more time to live and practice the programs implemented allows time for adjustments.

FST: Regarding GFSI certification, in what areas are companies in the animal feed industry the most under-prepared?

Muliyil:  Management commitment, understanding and communication are key. Better training is needed to understand feed industry specific hazards and realistic controls. Currently, internal auditing is not very thorough and must be more structured. Corrective actions are not followed through to gauge effectiveness and are often not documented in adequate detail. Finally, validation is not well understood, nor is there specific guidance on this topic.

Williams: Management does not always clearly understand the need and requirements of “Management Commitment”.  It requires active and visible participation at all levels of management. Managers must “walk the walk” and “talk the talk”.  It may also require an investment in resources such as staffing, capital improvements, and training, to name a few. Management commitment is essential to support the development of a strong product safety culture. Failures in product safety culture increase the potential risk of outbreaks and deaths from foodborne illness.

The skills needed in the industry to meet these new expectations are different than what we needed before. It is not enough to just adopt new standards.  We have to train and educate those who implement them.

We need to train for behavior – what do we want the trainee to be able to do? The training needs to be clear and practical. In addition, we need to educate for increased knowledge across the employee base.  Don’t just send the managers and supervisors to HACCP class or auditor training, make sure we educate a multi-disciplined team including production employees.

Continuous improvement is an everyday concept and involves having a strong corrective action/preventive action program. Often deficiencies are corrected quickly, but not prevented over the long term, and this requires increased due diligence.

FST: Are companies with FSSC 22000 certification more prepared for the preventive controls rule?

Muliyil: FSSC 22000 is one of the GFSI benchmarked schemes that offer effective integrated food safety management, covering:

  • Specific controls and scheme criteria for animal feed and pet food
  • Global buy-in and adoption by many of the world’s leading feed and food manufacturing companies
  • A top-down focus, including defined roles for management, requirements for policies and regular management review
  • Prerequisite programs focused on hazard control, in line with HARPC and FSMA
  • The HACCP system approach to structured food safety control, focused on medications & prohibited material control
  • Traceability from suppliers through to customers
  • Communication:External: Consumers, customers, service providers, suppliers, associations and regulators.
    • Internal: Within a company and between all elements of the system
    • Internal audit of the entire food safety management system and follow up
  • Regular system updating to maintain rigor

Williams: A company certified in FSSC 22000 or one of the other GFSI benchmarked standards has implemented Codex HACCP and hygiene principles in their foundation programs. These same HACCP and foundation programs overlap with the requirements in the preventive controls rule and will support compliance to FSMA.  It will be important to review all the FSMA requirements to ensure all elements are effectively covered in the current company program.

FSSC 22000 requires annual recertification and an annual self-audit. These two elements of review ensure that internal and external eyes are always looking for program compliance before a failure occurs.  These are solid “prevention” elements that support FSMA compliance as well.

FSMA Final Rules Almost Here, Guide to GFSI

By Food Safety Tech Staff
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With a host of mandatory requirements under FSMA means, businesses may want to consider GFSI certification.

The first FSMA deadlines are now two months away, and manufacturers may wonder how and where GFSI certification ties into increased regulation. First, what are some of the main differences between GFSI and FSMA? GFSI is seen as more global, while FSMA is more US-focused. Of course, the final FSMA rules will require mandatory compliance, and GFSI is voluntary. However, GFSI certification is recognized among major domestic and international retailers, so compliance with a GFSI-recognized scheme is an important part of a company’s food safety program.

The Food Safety Consortium Conference features a GFSI Services & Compliance track. With increased regulatory demands under FSMA, speakers will discuss the role of food safety certification systems. A GFSI-certified facility is one step closer to compliance with FSMA and may be held in higher regard by FDA from an auditing and inspection standpoint versus a business that has not opted to obtain certification.

Obtaining GFSI certification provides several benefits to the food industry, according to a recent TraceGains blog about the GFSI journey, including:

  • Reducing duplication of audits
  • Creating a comparable audit approach and outcomes
  • Enabling continuous improvement and customer opportunity for GFSI-benchmarked companies
  • Enhancing trade opportunities
  • Gaining cost efficiencies throughout the supply chain
  • Increasing competitiveness in the global market

Several food safety management schemes are recognized by GFSI. Among them is FSSC 22000, which touts the certification of more than 10,000 businesses worldwide. This year’s Food Safety Consortium also includes the first FSSC 22000 North American Harmonization Day on Tuesday, November 18. The meeting will provide a technical update of FSSC 22000, along with current scheme and future plans for expanding scopes and preparing for GFSI benchmarking.

Dr. Jacqueline Southee, U.S. Liaison for FSSC 22000

“Make Consumer Safety and Food Safety a Hard Priority”

By Sangita Viswanathan
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Dr. Jacqueline Southee, U.S. Liaison for FSSC 22000

On September 26, Dr. Jacqueline Southee, U.S. Liaison for FSSC 22000, will present FSSC 22000 – The Road Ahead, as part of the 2014 GFSI Leadership Webcast Series presented by SafetyChain Software and FoodSafetyTech.

Dr. Southee will talk about what’s new for the scheme, what changes are expected in 2015 and beyond, how these changes will affect you, and why it’s important to embrace these changes to be better prepared for upcoming food safety regulations such as FSMA. In this interview with Food Safety Tech’s Sangita Viswanathan, Dr. Southee discusses some of the topics that will be examined in more depth during the webinar – including FSSC 22000’s international food safety management certification scheme and its global integrity program.

Food Safety Tech (FST): We’re very excited to have you participate in the GFSI Leadership Webcast Series. What will you be talking about in terms of current changes with FSSC 22000?

Dr. Southee: The most striking change that FSSC 22000 is undergoing revolves around the rapid uptake of the scheme by industry and the increase in the number of certified sites which currently stand at more than 8000. This represents a 48 percent increase since mid-2013. The standard is currently operating in 146 countries, and has become a truly global scheme. We are also working to extend the scope in line with the GFSI goal to cover the entire supply chain. For instance, we have added animal feed to our scope, and will soon be adding animal farming. We are constantly making adjustments within the scheme to keep in line with GFSI requirements in terms of maintaining the highest possible scheme integrity. Overall, FSSC 22000 is creating a lot of buzz out there and we continue to work to meet the growing needs of the industry.

FST: We know that audits will be a topic of many questions. Is FSSC 22000 planning changes on the way it does audits? What are some of audit-related topics you’ll be addressing in the webinar?

FSSC 22000 LogoDr. Southee: FSSC 22000 does not do audits itself. It oversees the FSSC 22000 scheme which provides the specifications for the audit which is conducted by a qualified Certification Body. We work with 96 licensed Certification bodies and more than 1500 auditors throughout the world who conduct FSSC 22000 audits. Our goal is to ensure that these audits are conducted consistently and in line with GFSI requirements. We focus on having a global integrity program, and are in regular contact with auditors and Certified Bodies to monitor auditor competence and to ensure that both CB’s and auditors are meeting these requirements. This monitoring may require an increase in the communication that we have with our CB’s and may even result in an increase in the number of visits that we pay to them. The overall goal is to maintain the highest standard of food safety audits for FSSC 22000 certified companies.

FST: You will also be talking about the direction of FSSC 22000 in 2015 and beyond? Is there a “theme” or specific set of business drivers that are driving future changes to FSSC?

Dr. Southee: The main business drivers for FSSC 22000 are increasing transparency across the supply chain, maintaining the highest standard of consistent audits around the globe to promote a continuous improvement in food safety. As a global scheme, we are in a good position to work with many of the world’s leading food manufacturers. We work on ensuring transparency throughout the supply chain to maintain efficiency in the control of food safety, raise the confidence of the customers and the regulators in the third party certification process and to ensure the production of safe food ingredients and products for the consumer.

FST: While we all know change is important, it’s not always easy to get already-burdened food safety organizations to embrace change. What are some of the things we’ll learn in the webinar about why embracing change is critical to the ongoing success of FSSC 22000?

Dr. Southee: The global food manufacturing industry is currently under a tremendous burden with pressures coming from all sides. They must produce safe food efficiently and effectively to meet the demands of the retailers, the regulators and the consumer. What’s more in this truly digital age, where social media drives consumer preference more than anything else, they need to show their commitment to food safety. The new norm is that consumers are “involved” in what they eat. Every step industry takes is scrutinized by everyone with access to the information, and if anything slips out of compliance, it is public knowledge almost within the hour. There’s a constant demand for information, so food manufacturers need to invest in management systems such as FSSC 22000 to manage their food safety effectively, maintain transparency across the industry both for their customers and their consumers and be quick to respond to issues.

FST: We know that you’ll be providing advice on how companies can start today to prepare for tomorrow’s FSSC. Can you tell us some of the topics you’ll be addressing in this part of the webinar?

Dr. Southee: One topic I’ll be addressing is that food safety management should not be considered a cost center. In order to prepare for FSSC 22000, it is critical for senior management within an organization to recognize the need to take responsibility for food safety and that this will involve the need to have a robust food safety management program in place. Many companies now recognize the importance of investing in food safety and this is to the benefit of all. We also hear about the importance of establishing a “food safety culture” and we can talk more about what this means.

FST: It has been said that GFSI certification is a very good start to preparing for FSMA compliance. What are some of the key points you’ll be addressing when it comes to FSMA compliance and FSSC 22000?

Dr. Southee: First of all, I think that the establishment of the GFSI is an example of the food industry already regulating itself. The benchmarking approach has raised the standard of the accredited third party certification process and a company that is certified under a GFSI scheme is already meeting a high standard of food safety. A scheme such as FSSC 22000 provides additional evidence of a company’s commitment to food safety practices and management. The FSSC 22000 scheme meets many of requirements specified by the initial draft of the FSMA rules and existing data suggests that GFSI certification is a very important start to ensuring compliance with FSMA requirements.

To learn more about all of these and many more topics on FSSC 22000 – including live questions from the audience – register today for FSSC 22000 – The Road Ahead, Friday, September 26, with Dr. Jaqueline Southee.

Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

SQF: Where is it Going and What Does it Mean to You

By Sangita Viswanathan
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Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

In a recent webinar, Robert Garfield, Senior Vice President of the Safe Quality Food Institute talked about the SQF standard, changes made in 2014, what is expected in 2015, and how companies can use SQF to be better prepared to comply with rules proposed under the Food Safety Modernization Act. We present below some excerpts from the webinar, organized under the 2014 GFSI Leadership Series. The next webinar in the series will focus on FSSC 22000. Click here to register.

Where is SQF going in 2015 and beyond?

Garfield: The standard is going to be focused on enhanced compliance programs and improving the database reporting systems. For instance, if it concerns someone in the bakery or dairy industry, we would like to know how they are doing versus the industry as a whole. We are hoping that better database reporting can help with this, especially when it comes to non-compliances.

Another area we are working on is establishing Cooperative Agreements. In 2014, we finalized an agreement with the American Feed Industry Association and we are working with their food safety program. We are hoping to not just work cooperatively with the private sector, but also with various government agencies and other stakeholders.

Other areas we are growing in 2015 are expanding our language alternatives, subject matter training and developing industry specific guidance.

There are many changes proposed to food safety regulations and food safety schemes such as SQF. How will companies be affected by these changes and why is embracing these changes so important to industry?

Garfield: Embracing all these changes is critical for the food industry to do everything they possibly can to ensure that they are making and selling a safe product. At the end of the day, there is no one ‘magic bullet’ solution to food safety. Embracing these changes to food safety rules and standards will help the CEO and management team sleep better at night, knowing that they are doing what they can to protect their product, their brand name and their consumers. Also, companies need to understand that the regulatory climate will completely change in the next few years, so it’s critical for companies to start acting now to meet these new requirements that will start being in effect from October 2015.

How can companies start preparing today for tomorrow’s SQF?

Garfield: I tell companies and retailers I talk to that if they are interested in doing SQF because they want to be ‘GFSI certified,’ that’s the wrong reason to do this. To get started, management commitment and changing the culture of the entire company is critical. Starting from the CEO and going all the way to the man operating machinery on the floor, you should aim to get a commitment to food safety, where food safety management is the most important issue for the company. If you start working on that today, you can accomplish great things for the company in not just reducing recalls, but improving the overall functioning of that company.

How can SQF help prepare companies for FSMA?

Garfield: The first step is to look at the Preventive Controls and the Fresh Produce rules and see how these apply to your company. I suggest hiring an independent expert to take a look at your facility and see how your company fares against these rules and have a better understanding about where you will be when these rules are finalized by October 2015. While you will have one to three years to comply with these rules after that point, you need to get the management buy in and strong food safety management systems in place now. Start now, and don’t wait for the final rules to be announced.

Listen to this complimentary webinar today to learn more about how SQF differs from other food safety programs, unannounced audits, changes with allergen control standards, and how to become SQF certified. Click here to access the recording.

2014 GFSI Leadership Series continues with FSSC 22000: The Road Ahead. Click here to register for this informative webinar on Friday, September 26, 2014, featuring Jacqueline Southee, U.S. Liaison, FSSC 22000, who will talk about what’s new for FSSC 22000 this year, where FSSC 22000 is going in 2015 and beyond, how you will be affected by the changes, and how to start preparing today. Plus Jacqueline will take your questions live!

Training in the Food Safety Industry

By Sangita Viswanathan
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Dr. John Surak food safety trainer and Warren Hojnaki of SGS talk about trends they see in food safety training, areas of focus, how to keep training relevant and useful, and what they are expecting to see in the future.

FDA, FSMA, FSMS, HACCP, GFSI, BRC, SQF, IFS, FSSC… The food safety sector is a cornucopia of new regulations, abbreviations and standards. Helping navigate this maze are food safety training courses and the instructors. However, the success of training programs depends on how applicable these courses and the curriculum are to the industry and the specific client, and how experienced and knowledgeable the instructor is in understanding current regulations, specifications of standards, hazard profiles and compliance requirements of that client. 

In an interview with FoodSafetyTech.com, Dr. John Surak, food safety trainer, and Warren Hojnaki of SGS, talk about trends they see in food safety training, areas of focus, how to keep training relevant and useful, and what they are expecting to see in the future.

John Surak, Ph.D., is principal of Surak and Associates, a full service food safety and quality consulting service. He works with the food processing industry in developing food safety and quality management systems, designing and implementing process control systems, and implementing Six Sigma and business analytics systems. Warren Hojnacki is Training Manager, for SGS North America. His department delivers training services for North American clients. 

FoodSafetyTech.com: What are some broad trends in food safety training that you are noticing?
Hojnacki: What we are seeing is a lot of clients needing foundational training. For instance, our most popular training programs are still HACCP, implementation for FSSC 22000, SQF etc. On the other side, clients are still very confused about what they should do regarding new and proposed food safety regulations. While they are following the directives that they receive from their customers, currently there still is a wait-and-see mentality. 

Dr. Surak: I notice the focus on food safety moving up the food chain. About 5 to 7 years ago, our primary clients for food safety training programs were food processing companies. Now our clients are suppliers to these companies as food companies are pushing the requirement for training on them. These supplier companies then need to make decisions on what schemes they want to be certified under. Most of the time, the customer accepts any GFSI-recognized scheme, but sometimes the customer names a specific scheme. Different GFSI schemes have different sweet spots and advantages. They all assume different knowledge about food safety and some are more prescriptive than the others. Clients have to figure out which scheme would be the best fit for them. 

FST: What kind of training courses are most popular, most asked for?
Hojnacki: When clients and companies decide on getting audited or certified against a particular food safety standard, training for that standard is a common requirement. Auditors specifically want to be trained to build their skill level, whether it’s getting trained for HACCP or FSSC 22000. A number of our clients also come to us saying that when they have a 3rd party audit, the most common non-conformances pertain to a less than robust internal audit system, so auditor training is a critical area that our clients ask for. 

Dr Surak: One of the biggest aspects of training that I try to focus on is lead auditor training. This course is designed to help an individual get certified in a particular audit scheme. We cover the same information for internal auditor training. However, the difference in this case is that for the internal auditor, the goal is to get his company certified. If a company has a strong internal auditor, they can reap substantial benefits. We also focus on, as part of our training, doing mock audits. This is more than going into a course or workshop and giving a lecture. For mock audits, you are put into a spot where you have to make real decisions on the floor. When we conduct such practice audits with our clients, in addition to our regular food safety training courses, we find a high level of involvement and interaction from the attendees and appreciation from the client. 

FST: What are some of the gaps in the training that you notice?
Hojnacki: What we see in general is people not covering the topic in-depth enough. Many training courses (outside those offered by SGS) seem to cover the topic in a very superficial manner and this doesn’t help. 

Dr. Surak: Many of the attendees who come to an audit training class have never taken the time to familiarize themselves with the standard. So what you are doing in that time is teaching them the standard and then teaching them how to audit. If the participants already know the standard, then you focus on just reviewing the standard and cover how to go about doing the audit. 

FST: What are some common questions attendees ask at ‘implementation/auditor’ training?
Hojnacki: Attendees very much want to know application to their respective situation. As an auditor, you need to know the right open-ended questions to ask when you are conducting an internal audit, and in our training, we provide examples for that. 

Dr. Surak: Our training focuses on enabling auditors to get the participant in a conversation and be able to answer questions during an audit. We are not in the business of writing traffic tickets, we are out to assess if the food safety system meets the standard, and also to identify the areas where it needs to be strengthened. Things that participants typically want to know are, going into a 3rd party audit, what is the auditor going to do? How is he going to react? And how can they present themselves in the best possible way to have a good audit? Also the instructor or auditor needs to understand the differences in the standards and the different hazards. There are unique challenges for different suppliers – or where along the supply chain they are, for instance are they a retailer, a supplier or a processor. It’s not a one size fits all situation. If you are looking at ingredient suppliers, the hazards are very different than what a retailer would be looking at, for instance. 

FST: How do you identify the best training company or program for you?
Hojnacki: We go through this everyday with every client call and we understand that we are not the only resource, our clients have several options. We first evaluate the trainer to understand what’s their educational and work experience background? Does it correlate to the industry you are in? Are they practitioners or just theorists? Food industry is a very big growth area right now, and we are seeing a proliferation of tutors coming into this field. Some of them have varied backgrounds, such as in automobile or aerospace industry. Often times, clients will make a decision based on prices quoted, and then realize that it didn’t work out the way they had anticipated. We (SGS) have often had to go to that client and redo things. Today, more than ever, the decision to choose a trainer/ training vendor, needs to be based on their competence, experience, and skills. 

Dr. Surak: I was recently at a client where they had completed certification training. When I asked to see the materials and bios of the instructor, I noticed that he had no prior experience in the food industry. I wondered how you could teach internal auditing in a food processing industry if you did not know about food processing! It’s imperative that clients look at the trainer’s background and experience. 

FST: Food safety training in 2015 – what will change?
Hojnacki: Food safety training curriculum will have to increasingly show greater applicability to clients to meet their needs. It has to be a round peg and in a round hole type of situation. Especially with FSMA rules getting finalized, clients are going to expect more out of their training. They are going to expect their instructors to be a resource, and to be up to date on the respective regulations and be able to tell clients how these rules will apply to them, and what they need to do differently. 

Dr. Surak: Processors are going to ask questions such as ‘I am certified to a GFSI scheme, so now do I have to do anything additional to meet new requirements’ or ‘are there areas where we have done some basic groundwork, and we have to raise the bar higher because of new regulations,’ and trainers need to be able to answer these.