Tag Archives: HACCP

Gary Smith, Eurofins’ Food Safety Systems

Why Food Safety Training Fails, and What Can be Done?

By Sangita Viswanathan
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Gary Smith, Eurofins’ Food Safety Systems

The food industry has multiple levels of people involved, ranging from leadership and supervisors, all the way to line and front-end workers. Training, thus, has to not just give directions, but also provide better understanding of why we do what we are supposed to, says Gary Smith at Eurofins.

Smith, who leads the strategic development and oversight of Eurofins’ Food Safety Systems division, including auditing, certification, and training programs, says that “training for supervisors and leadership usually works well. But training workers is fraught with challenges. General training is focused more on giving directions, but not so much on providing understanding. People often skirt this rationale with the line workers, or it’s lost in translation, or missed out due to time constraints, turnover, vacation days etc. That’s where training fails.”

What would happen if we don’t spend this time address the ‘why’ behind training? People then get busy, and then miss out on steps and processes, and that causes problems, Smith replies. “It’s also critical to aim to strike a balance, for instance with line workers training – you have to ensure they understand the importance of what you are training them on, but at the same time, you cannot go too deep into the training, that would be either unnecessary or redundant.”

So what kind of training will continue to be the focus for the industry? The usual ones will continue to be important, according to Smith: Regulatory requirements for seafood, specific HACCP requirements for meat, HACCP training for employees directly responsible for food safety and quality, standards training; training for audits… For line workers, training also needs to cover specifics of their jobs, employee hygiene practices (for instance, why it’s important to wear gloves, hairnets etc.), and how to handle customer complaints.

Proposed rules under the Food Safety Modernization Act are having a positive impact on training needs, says Smith. “Everyone is now waiting for the final set of rules to be announced and implemented. A lot of good things are coming out of it, such focus on risk management and process control, understanding which products are high risk and low risk. FSMA has brought back HACCP for those industries that haven’t really had strict regulatory requirements for food safety – such as seafood, fresh produce, juice etc., or ready-to-eat products that may have escaped regulatory scrutiny in the past, such as fresh produce, and bakery products. Now the industry as a whole needs to focus on FSMA implementation, by companies helping its employees understand where the food safety risks are, how to manage them, document them, and mitigate them.

How can training help companies towards certification? When training leaders that are going to be implementing the food safety standards within their facility, it’s important to be comprehensive about understanding the specific standard. There is also the opportunity to focus on common non-conformances and say ‘this is where others have struggled and this is what you can do to avoid those non-conformances.’ Training can provide lessons, solutions and ideas to address common problems to addresses non-conformances before an audit. It can help drive continuous improvement, and help secure management commitment.

What are some of the common training themes that have resonated with Smith? He says that mostly employees bring up the issue of getting management to understand the need to focus on food safety training and procedures. “People who have attended my classes are usually struggling with getting management commitment. They are often told they need to be certified to a particular standard by end of the year, and so figure it out, but there’s no skin in the game from management. I help these trainees walk through the various steps that they can take to secure that commitment, how to talking their language in terms of more efficient production, and higher dollar savings etc.,” Smith describes.

Some challenges that he has observed in his years of training? Smith says that often times the trainers are great auditors, but poor trainers. “They will quote standards, and regulations. They are too black and white, and objective. However, training can have successful outcomes only when it’s practical and linked to real situations and ideas.”

John Kukoly of BRC Global Standards

Where BRC is Going, and How Can You Get There?

By Sangita Viswanathan
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John Kukoly of BRC Global Standards

Food Safety Tech (FST): We’re very excited to have you participate in the SafetyChain/ FoodSafetyTech’s GFSI Leadership Webcast Series with the October 24 BRC – The Road Ahead webcast. We know that you’ll first be addressing what is new with BRC today. What are some of the things you’ll be talking about in terms of current changes?

Kukoly: We are just on the cusp of releasing Issue 7 for BRC. This is scheduled to be released in January 2015. With this, there will be some changes made to how food companies and facilities can obtain the BRC standard. We have a really unique system, termed BRC Participate, that we propose to unveil during this time, which I will talk about more during the webinar.

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

Kukoly: One of the changes I will be talking about is the auditor-competency program. Other topics will include expansion of our unannounced audit program. BRC is currently the leader in this area, and Wal-Mart has specifically asked us about this. We have done such audits in over 600 sites already, and are currently the go-to people for unannounced audits now. We are also forming BRC Global Markets, which will help small and less developed companies to get ready for certification.

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

Kukoly: In my opinion, the two most critical areas of focus for the food industry right now are risk management and supplier management. These are the two main key elements being covered in all new regulations under development, and if a food facility has these covered, then they are in a good place. These are the two specific drivers that are shaping future changes to the BRC standard.

FST: While we all know that while 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 BRC certification?

Kukoly: I don’t think ‘why’ should be the right question. We should focus on ‘HOW’ to go about this. And I think we need to talk about food safety culture and change management. These are the areas that are key to success and embracing change.

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

Kukoly: One of the topics I will be addressing is training, not necessarily for BRC, but for obtaining the right skill sets such as risk assessment or HACCP. These are necessary for any food manufacturing organization to prepare for tomorrow’s BRC, and to have robust systems and processes in place.

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 alignment with BRC?

Kukoly: If you look at FSMA expectations, they are very well aligned with requirements of BRC standards, whether it be supplier management and verification requirements, or risk assessment etc. Beyond that, it is about strength of traceability procedures, knowledge of FSMA within the facility and its qualified individual. The focus is primarily on robust supplier management programs and implementation. If all these are in place, then you are in a very good starting place for FSMA compliance.

Listen to John Kukoly talk more on these topics and take your questions live in the BRC – The Road Ahead webinar on Friday, October 24, 2014 at 10:00 PT/ 1:00 ET. Click here to register

Dr. Douglass Marshall, Chief Scientific Officer – Eurofins Microbiology Laboratories

Environmental Monitoring – Another Leg on the Food Safety Management Stool

By Sangita Viswanathan
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Dr. Douglass Marshall, Chief Scientific Officer – Eurofins Microbiology Laboratories

Eurofins laboratories routinely test for the presence of the infectious bacterial generaSalmonella and Listeria monocytogenes in the food processing environment. While L. monocytogenes long has been known as an environmental contaminant, only recently Salmonella has been considered a persistent environmental contaminant.

At this year’s Food Safety Consortium (November 17-18, 2014, Schaumburg, IL), Dr. Douglas L. Marshall, Chief Scientific Officer – Microbiology, for Eurofins Scientific Inc. will present a workshop on Environmental Monitoring. This workshop will provide an overview of analytical methods used, a discussion of the zone approach to environmental monitoring, and a practical example of the use of microbial genetics in Eurofins’ Source Tracking Program to identify and eliminate a pathogen harborage.

In this Q&A with Dr. Marshall, we present a sneak-peek into what to expect in this workshop. Register today to learn more.

Food Safety Tech (FST): How are environmental monitoring requirements changing under FSMA?

Dr. Marshall: The Food Safety Modernization Act passed by Congress contains language in SEC. 418. HAZARD ANALYSIS AND RISK-BASED PREVENTIVE CONTROLS stating: ‘‘(4) the preventive controls implemented under subsection (c) are effectively and significantly minimizing or preventing the occurrence of identified hazards, including through the use of environmental and product testing programs and other appropriate means” and ‘‘(C) An environmental monitoring program to verify the effectiveness of pathogen controls in processes where a food is exposed to a potential contaminant in the environment.”

The Preventive Controls for Human Food Proposed Rule has moved environmental testing to the appendix. It is clearly FDA’s intention that firms use environmental monitoring but how this will ultimately play out in the final rule is unknown. The companies we work with are finding a substantial non-regulatory push for environmental monitoring from their customers. As a result, firms without environmental monitoring programs will find it challenging to escape criticism from inspectors, auditors, and customers.

FST: What are some broad topics you are going to be covering in your FSC presentation?

Dr. Marshall: This EMP workshop will deliver tips for an effective pathogen monitoring program. Highlights include information relevant to answering many EMP questions such as what to test for, what is the value of indicators; where to test, what methods to use, what test volumes are appropriate, how to use trending, and how to remediate an environmental problem.

FST: What are some key challenges when companies do environmental monitoring? For Salmonella, and for Listeria?

Dr. Marshall: Many companies find it difficult to start an EMP program and fail to use the program in a proactive manner as an assessment tool. Environmental monitoring is an essential tool for microbial control, but it is not a control program. Robust programs target areas in a processing plant where environmental pathogen control is critical to product safety. The pathogen of concern may differ depending on food product type and processing conditions.

FST: Why is it important for food companies to pay attention to this critical area of testing?

Dr. Marshall: Numerous recent high-profile foodborne disease outbreaks and large recalls have been traced to poor environmental controls. Lack of effective environmental monitoring by producing firms contributed to these events. As a result, inspectors, auditors, and customers are demanding the placement of environmental monitoring programs as an additional leg on the food safety control stool, adding to GMPs, SSOPs, and HACCP.

FST: What kind of technologies will you be talking about in your presentation?

Dr. Marshall: The talk will present an overview of analytical tools required for routine monitoring and give an example of the use of genetic strain typing as a source-tracking tool for remediation.

Learn more, and register today for the Food Safety Consortium – Multiple Conferences, One Event, featuring 30 plus expert industry speakers, and speakers from FDA, CDC and USDA. 

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!

Katie Moore, Intelligent Platforms’ Global Industry Manager for Food & Beverage, GE

Big Picture Understanding for Better Food Safety

By Sangita Viswanathan
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Katie Moore, Intelligent Platforms’ Global Industry Manager for Food & Beverage, GE

Having worked in the food & beverage industry as a plant manager, Katie Moore knows just how important food safety is to a company’s brand and profits. As GE Intelligent Platforms’ Global Industry Manager for Food & Beverage, she uses today’s connected technology to help prevent food safety issues and expensive recalls.

Companies want to do the right thing and try to control what is known. They want to mitigate risks when possible. But without a clear and complete line of sight to real-time process data and information, like whether or not your HACCP processes have been followed, correctly, each and every time as stated in your HACCP Plan, how can you truly have peace of mind going to sleep every night? That’s the gap that’s plaguing food companies and managers, says Moore.

Against the backdrop of evolving food safety rules under the Food Safety Modernization Act, Moore sees manufacturers in the food and beverage industry in a wait-and-watch mode.

“Since these rules are still in the process of being finalized, everyone’s waiting to see what the final regulations will look like. This is the right time for manufacturers to educate themselves, and implement new steps and programs to assess and mitigate risk,” she explains. Moore feels larger companies are much better at addressing these changes, because of having greater resources or collaborations with industry associations, while small and medium sized companies are continuing to implement HACCP and GFSI standards, but are a step or two behind their larger counterparts.

There is a lot of risk management going on, and it all begins with HACCP, says Moore. But a gap she’s noticing is a lot of records still being paper-based.

“There is still a lot of work being done on paper. And data is not being transferred automatically. Because of this, there is no way to go back and learn from what’s going on and identify trends and issues. There is truly no electronic capture of data. This lack of learning and understanding of trends and changes is a big gap,” Moore adds.

A lot of recent recalls are due to supplier problems, so everyone focuses on that. Companies are managing the biggest risk, which is their suppliers, and there are a lot of solutions available to manage supplier compliance. “But true value can be realized when this is tied in with your manufacturing processes and specifications. How is the food handled in my line, my tanks and my processing facility…. If companies have this continuous visibility it will contribute to food safety and quality improvements growing by leaps and bounds. And also companies will be able to track and trace throughout the process, and react a lot quicker,” she describes.

Mergers and acquisitions in the F&B space

These days, there is a lot of consolidation happening in the F&B space. Historically, whenever there is a merger of two food companies, there is a challenge to have in place a sound business continuity plan. For instance, Moore asks, if there’s a recall, then how do we react? If there is an issue isolated to one facility, how can we cover our bases and mitigate risks? How can we make sure our customers get our products? From an IT perspective also, there are some challenges that need to be addressed. For instance, what GFSI scheme are we using? Do we merge these two standards and our supporting IT infrastructure, or continue to work with two separate standards? The key in making this decision is to utilize big data analytics to determine which process has been working most efficiently and to factor in the cost of replacing or retrofitting the extremely expensive manufacturing equipment.

According to Moore, F&B managers need tools that can help them improve compliance to food safety, have better visualization and hence greater visibility either on the plant floor or via mobile platforms, have the ability to pull up a wide range of information and share it with people. F&B companies usually handle a wide range of project management systems, typically working on different software from different vendors.

At GE Intelligent Platforms, Moore says, the products ‘talk’ to different systems and data management software to try and address the challenge of collecting, managing and trending large amounts of data.

So are companies embracing technology solutions to better manage food safety and quality? Moore feels that a driving force is lacking.

“Once something happens and FDA has to react, the chips will start to fall. There will be a lot of recourse to technology that will be required, but right now there’s no driving force. Once FDA puts the hammer down on electronic documentation, F&B companies will start to move faster,” she sums up.

Food Safety and Sustainability

By Aaron G. Biros, Michael Biros
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What is sustainability and how does it relate to food safety? This article, the first in a series on the topic, introduces the concept of sustainability.

The global food industry is already feeling the destabilizing and disruptive effects of climate change. Drought and wildfire are ravaging California while flooding is inundating the Midwest. With the effects of climate change projected to amplify, companies are becoming increasingly aware of vulnerabilities to their business. In addition, current modes of food production are seen as a major driver of environmental problems such as deforestation, desertification, eutrophication and fisheries collapse. All of this is set to the backdrop of a booming world population, rapid urbanization, diminishing natural resources, and critically stressed ecosystems.

Food companies are increasingly becoming aware of these challenges and are looking for innovative ways to adapt their business models to account for them. One approach is to incorporate sustainability into business strategy and planning.

Sustainability is a conceptual framework that has the potential to mitigate business vulnerabilities while simultaneously reducing the stress that food production has on social and natural resources. In general terms, sustainability is the endurance of systems and processes. More specifically, it integrates ecology, economics, politics, and culture. Connecting environmental stewardship with a solid business plan while advancing social justice is an innovative as well as profitable approach to streamlining business operations.

There are different methods to assess sustainability, with the most common being the Triple Bottom Line and Circles of Sustainability. These methods are multi-dimensional and allow for the inclusion of complex qualitative issues. Sustainability has also been deceptively referenced in a number of marketing campaigns aimed at altering how a company is publicly perceived, not how it operates. This is a practice known as greenwashing.

In the upcoming series of articles, topics such as co-management, food waste, water conservation, agriculture, and others will be observed through an interdisciplinary lens, tying food safety with sustainability. Given the connection to the entire food production process from farm to fork, food safety professionals are poised to lead in sustainability. Many of the systems already developed to detect, prevent, and trace contamination can be retooled and applied toward sustainability. Elements of food safety programs and auditing schemes such as HACCP, GFSI, and SQF could be adapted to cover environmental and social benchmarks.

Food companies must develop more sustainable solutions in an effort to protect food safety and natural resources. Businesses, driven by C-suite oversight and stakeholder initiative, need to co-manage food quality, safety, and sustainability in a collaborative approach.  Decision making at every step in the supply chain should comprehensively approach food safety, quality, and sustainability where possible.

Andrea Moffat is the Vice President of the corporate program at Ceres, a non-profit organization that publishes findings on corporate sustainability and progress. She believes that, “Businesses need to look at sustainability and food safety as part of their core business framework in identifying risks and competitive advantages. We are beginning to see teams of executives involving sustainability issues in setting sales and revenue targets.”

By reaching across borders within a company and working toward these benchmarks, businesses can improve operations while maintaining customer loyalty and brand confidence. At the end of the day, food safety professionals are stewards of public health. Sustainability offers food safety professionals the opportunity to expand their influence on public health and safety.

Uncertainties around climate change are now threats for businesses in every sector. The food industry is witnessing the effects of climate change on vital natural resources, and thus business planning now.  Food companies are beginning to look at sustainability as an opportunity to improve business operations at the moment and in the future. The upcoming articles will focus on the interconnectedness of food safety and quality with sustainability.

Stay tuned for more articles on this topic.

Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

Pet Food Safety: Regulations and Challenges

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

Alan Baumfalk is Pet Food Safety Specialist and food safety Auditor at Eurofins US Foods Division. After more than three decades of experience in human food production facilities, Baumfalk began inspecting and auditing pet food companies with a fresh pair of eyes and in his opinion, “pet food plants typically are very well maintained, embrace technology, are highly automated, have great productivity and are very efficient with their sanitation and production.”

In an interview with Food Safety Tech, Baumfalk talks about differences in production of human food and pet food; lessons learned from historical incidents such as melamine in pet food and contaminated chicken jerky; what are some gaps in pet food safety he’s noticing and impact of the Food Safety Modernization Act or FSMA on this sector.

Food Safety Tech (FST): What are the differences between the production of human food and pet food?
Baumfalk: In most cases, pet food facilities are dry facilities, making kibbles and similar products, and their cleaning sanitation processes are mostly sweeping and dusting, with very little water involved. When it comes to regulations covering pet food facilities, most of these fall under FDA jurisdiction, and pet food facilities need to have in place risk-based HACCP plans to ensure food safety. Some of the challenges involved in pet foods are how do you do sensory testing on dry pet food or test for taste or consistency? Pet food testers look at certain quality attributes such as color, look, smell and taste of the product. They look for data such as amount of protein in the food etc. They also need to consider if humans – especially the elderly, or children – would consume the pet food product, because this can have many food safety implications.

FST: Humans have allergic reactions to certain food ingredients. Do pets have similar concerns of allergens?
Baumfalk: We don’t know if pets suffer allergic reactions to any specific food ingredients similar to humans. Pet food manufacturers are not subject to allergens and are exempt under FDA’s allergen management regulations. However, there are strict GMPs maintained in pet food production facilities, so that known allergens are identified. Pet food manufacturers give attention to allergens though they are exempt because it’s possible that the allergens could get transferred to a human in the house who could be allergic to nuts or soy, and this could be a huge problem. In our experience, we have seen that pet food can be occasionally consumed by a child or an elderly pet owner, out of curiosity.

FST: How about pathogens such as Salmonella and E.coli, are pets susceptible to these?
Baumfalk: Pets are not typically affected by pathogens such as Salmonella or E.coli, and this goes back to their genetic background, which is, dogs coming from wolves, and cats from tigers and lions. These animals are used to eating things with pathogens, fecal matter etc. However, humans are at risk of infection by Salmonella and E.coli, so while the end consumer of pet foods are not affected by these pathogens, their handlers are. Hence, pet foods are tested for Salmonella and E.coli to make sure they are pathogen free. They have Critical Control Points (CCPs) and kill-steps just like human foods, and pet foods are diligently sampled before they are released in the market. Environmental monitoring is also strictly carried out – such as extensive swabbing of processing floor, walls etc. to test for Salmonella/ E.coli/ mycotoxins etc. If a raw material exceeds FDA guidance for mycotoxins, then they are rejected. Many manufacturers test for mycotoxin levels in finished product as well.

FST: Are there differences in auditing pet food companies versus human food manufacturers?
Baumfalk: All pet food companies are looking to get certified and audited under a GFSI-recognized scheme. SQF is probably the biggest standard though some choose BRC. Eurofins has close ties with the American Feed industry Association (AFIA) which recommends SQF, and so we follow the same standard when auditing pet food facilities. SQF has modules specific to pet food category and dry pet food products. There are a lot of similarities with requirements for human food – for instance, pest control within a pet food plant is the same as within a human plant. The commitment and requirement for compliance is the same.

FST: What are some gaps or challenges in pet food safety?
Baumfalk: Most of the folks working in the pet food industry have a background in human food and are very much aware of the technical and regulatory requirements for making human food, so they end up carrying it over to pet food production. They typically follow GMPs and HACCP, and safety plans to ensure there are no food safety gaps. While most pet food companies meet, or even exceed, compliance requirements, there are always some people in the industry that don’t get the message.

FST: When we think about pet food safety, the history of melamine contamination of pet food, and tainted chicken jerky from China come to mind. What are lessons learned and how can the pet food industry be prepared for the unknown?
Baumfalk: The melamine adulteration and chicken jerky contamination incidents have taught the industry to be on guard. The industry has to make sure that they are in close alignment with their industry association which speaks for them, read technical documents, hire and train knowledgeable staff – all of which helps constantly look for the next thing that we weren’t aware of. Apart from diligently monitoring the global supply chain, it would help to have strict audit specifications for global suppliers. If something is coming from the other part of the world, where there’s a history of food safety standards not always being up to par, the pet food industry needs to make sure to buy only from a known and approved entity. Also look for lessons that can be learned from the human foods industry. Read about recalls and withdrawals and find out why that happened, if the pet food industry has similar exposure, and how this can be addressed.

FST: What will be the impact of the proposed pet food safety rule under FSMA be on this industry?
Baumfalk: FSMA is going to tighten things up, paying a lot of attention to the global supply chain and any vulnerabilities. While regulations are still being finalized, the pet food industry is already aligning itself with these proposed regulations. The technical and regulatory folks in the industry are following it; they are reading food safety journals and interacting with their associations for guidance and for making comments on the regulations. We are also updating our auditing checklists to see how we can align better with new FSMA requirements.

For more information on Eurofins, it’s pet food and auditing capabilities, click here.

Why GFSI? And How Can It Help?

By Jennifer Brusco
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The Global Food Safety Initiative or GFSI, simply explained, is a business-to-business Food Safety and Modernization Act (FSMA). It operates quietly and privately within the marketplace between the customers and their suppliers. It operates on not only a global basis, but also on a regional and local basis.

“Although people look at the [GFSI] program and see a lot of multinational corporate logos, frankly the majority of our operations are small and medium size facilities at the local level. So we welcome facilities of all natures – large, medium, and small, across the food to fork continuum,” Karil Kochenderfer, North American representative, GFSI, said during a recent webinar.

GFSI has approximately 25 benchmarked guidances, with some of the latest scope expansions include:

  • Packaging and animal conversion – August 2011;
  • Animal feed – June 2012;
  • Storage and distribution – October 2013;
  • Food brokerage/agents, retail/wholesale – early 2014; and
  • Catering, equipment manufacturing, food safety services – 2015.

Where are these guidances coming from? How can you be sure that these guidelines are science-based, risk-based, and address the issues in your plant/facility?

Why-GFSI-June2014At the very base of our efforts that are ensconced within these guidance on a sector by sector basis, are the international standards of science based within the Codex Standard on Food Hygiene. On top of that are Hazard Analysis and Critical Control Points or HACCP standards. Above HACCP are National Regulations, which includes FSMA in the U.S. and the Safe Food for Canadians Act in Canada. In Europe it’s something different, in Japan it’s something different, but all have iterative levels of science-based regulation in place to ensure the safest control of the food and management of the food. Above National Regulation is GFSI Certification.

“We go above and beyond the science of Codex, HACCP, and national regulation to perform at the highest level of industry. And our benchmarked schemes [eg. BRC Global Standards (BRC), Food Safety System Certification (FSSC 22000), International Featured Standards (IFS)] go beyond us and corporate programs go even further,” Kochenderfer highlighted.So what you have are several layers of protection that will help protect both consumers and companies.

What are some of the shared benefits for industry?

There are several benefits, which include:

  • Meet the requirements for one, meet the requirements for all;
  • Reduce duplication of audits;
  • Have comparable audit approach and outcomes;
  • Ensure the continuous improvement and customer opportunity for those GFSI-benchmarked companies;
  • Enhance trade opportunities;
  • Improve customer confidence in food safety; and
  • Gain cost efficiencies throughout the supply chain.

“We have now built confidence in third-party certification because we have reduced inefficiency in the food system. Now, it’s ‘Once Certified, Accepted Everywhere,'” stated Kochenderfer.

John Kukoly, Director of BRC in the Americas, added that companies should pursue GFSI certification for a number of reasons:

  • Customer mandate;
  • FSMA;
  • Nearly a 40 percent reduction in product non-conformance;
  • Competitiveness; and
  • Superiority in the market.

Right now, only a third of the industry has achieved GFSI certification, which leaves the remaining two-thirds either still at the starting line or just a few steps into their journey. How do you choose a GFSI-recognized scheme and get started?

Karil Kochenderfer shared a chart to allow users to see where they fall on the farm-to-fork continuum and further determine which scheme(s) would work for them.

Further, we have developed four GFSI checklists for the four major schemes that apply to food manufacturers, co-produced with the respective scheme owners to ensure accuracy and usability. The checklists are complimentary and may serve as a great resource on your journey toward GFSI certification.

Additional Resources:

Barbara Levin, SVP of Marketing & Customer Community, SafetyChain Software

What is True Food Safety Audit Readiness… and How Can Automation Help?

By Sangita Viswanathan
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Barbara Levin, SVP of Marketing & Customer Community, SafetyChain Software

Barbara Levin, Senior Vice President and Co-Founder of SafetyChain Software, shared her thoughts during a recent interview with Food Safety Tech

Food Safety Tech (FST): Why are food safety audits such a hot topic of conversation?

Barbara Levin: Audits are a critical component of any food safety plan, and I’ve never heard food safety and quality assurance (FSQA) folks disagree with that assumption. But between regulatory, 3rd party standards such as GFSI, customer and internal audits – most of which are still very manual processes – audit preparation and response have become a huge manual burden that can be highly disruptive to operations. And while all audits has some commonalities, each has its own specific requirements as well, adding to the challenge. 

In conversations with our clients at SafetyChain, we have heard of companies that have as many as 300 audits a year! So it’s a struggle to manage these audits while also having to get product out on time, within operational Key Performance Indicators, and of course meeting safety and quality requirements. This is why we’re also hearing more about technology solutions that can help companies be audit ready. But whether or not a particular solution is right for your company depends on how you define audit readiness. 

FST: Before we discuss the definition of audit readiness, you mentioned that each type of audit has its own requirements – can you highlight some of these?

Levin: Let’s begin with what all of the audit types have in common – which fall in to four areas: 

  • First, you have to say what you do – all of your SOPs, PRPs, GMPs, HACCP/HARPC components, etc. 
  • Second, you have to verify that you do what you say. 
  • Third, you have to validate that it works. 
  • And last, you have to ensure that everything is documented. 

On top of these commonalities, each audit type has some specific requirements. For example:  

With regulatory audits, USDA can ask for pre-shipment reviews, while FDA can do unannounced audits with just a two hour notice.  

  • With the GFSI schemes, you have to have an approved vendor program and be able to demonstrate management commitment and continuous improvement. And of course everyone is talking about the upcoming SQF unannounced audits, which, I personally think, is something that the industry should embrace.
  • With customer audits, it’s not just about safety, but also quality attributes such as weight, moisture or salt content to name just a few.
  • And internal audits can be the hardest of all as many of the above elements, among others, can get combined. 

FST: Given this wide range of requirements, what then, do you mean, when you say “true audit readiness?”

Levin: When you hear people talk about audit readiness, and audit automation solutions, the conversation is often focused on documentation – the ability to produce electronic records. And this is of course an important component of being audit ready. But in my view, true audit readiness goes far beyond documentation. It should also mean that you have the tools and processes in place to ensure that you actually PASS your audits with flying colors! It means that food safety systems have been consistently and diligently followed across all facilities; you have a robust supplier compliance program; non-conformances are caught at the earliest point possible, and CAPAs have been put in place; you have easy access to data for continuous improvement; and everything is documented. In other words, it’s not enough to just show that the paper has been gathered for the audit – but that you are doing the right things for food safety every single day. And if we’re talking about audit automation technology – these solutions should support all of these components.

FST: How can companies assess if they’re truly audit ready?

Levin: Here are some basic questions FSQA teams should ask themselves:  

  • Are we 100 percent sure that all SOPs, CCPs, PRPs, GMPs, etc., are current and being carried out, and that we can easily access verifying documentation?
  • Do we have a robust supplier compliance program to ensure vendors are meeting our safety and quality requirements? Can we easily access all of those records?
  • Are we getting non-conformance alerts in a timely manner to take corrective/preventive actions before product goes in to commerce? Can we easily access proof of CAPAs?
  • Do we have easy access to all of the data required for trending, hazard analysis and continuous improvement? 

There can be three answers to these questions: Yes, No and Hmmmmm. If you’ve had one or more No’s or Hmmms… chances are you may not be as audit ready as possible. 

FST: What are then the challenges to being truly audit-ready?

Levin: I would list the biggest challenges with being audit ready as falling into four key areas:

  1. The volume of forms, records and paper that needs to be current, managed, easily accessed and actionable – meaning the data from these records can be trended for continuous improvement;
  2. Ensuring that all food safety programs are being carried out correctly and consistently – including the ability to catch problems at the earliest point possible, put a corrective/preventive action in place and make sure that all of that is documented;
  3. Management of supplier compliance (are you sure your suppliers are following all of your requirements?) and approved vendor program management; and
  4. The amount of time it takes to prepare for audits – especially as unannounced audits become more prevalent. 

FST: How can automation help with these challenges?

Levin: Technology solution that helps companies be audit ready must go beyond document management. They have to integrate supplier/vendor management; food safety and quality program management – HACCP and HARPC programs, for example; process management and workflow; GFSI program compliance; and, of course, ensure that all records and documentation is available in a central repository for trending, continuous improvement and of course audit readiness.

These solutions should automate, streamline and improve FSQA. And the final result has to be that actionable data – across all products and facilities – that allows you to find ways to improve processes, put preventive controls in place and make continuous improvement an inherent part of company’s overall food safety culture. Audit readiness then becomes the benefit – not just the goal. 

If you are using a cloud based FSQA automation solution – with roles-based security – automation can provide the kind of transparency and visibility that can actually reduce the amount of audits a company has by allowing suppliers, auditors and customers to view various slices of data. For example auditors might see non-conformances and the documented CAPA; a customer could see a finished product review; and a supplier can see that their Certificate of Analysis was received and met specifications. That’s a true change in traditional culture, but we’re seeing it more and more. 

Food companies need to remember that auditors do not expect to see that everything thing was perfect all the time. But what they do want to see is that a problem was found in a timely manner and that it was fixed before the product went into commerce. Bottom line? Automation can help food and beverage companies say what they do, do what they say, make sure it works and make sure it’s documented and actionable. And when all of this information is easily organized by the type of audit – and cloud-based – companies can be audit-ready on-demand! 

Click here to read Barbara Levin’s paper on how to be audit ready, on-demand with Food Safety Chain Management Systems.

Bob Savage, President and Founder of the HACCP Consulting Group

FSQA: Creating HACCP Excellence

By Michael Biros
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Bob Savage, President and Founder of the HACCP Consulting Group

For a successful Food Safety and Quality Assurance program, there must be management commitment and measurable expectations set. Senior management has to be committed to the program. They are the foundation for everything in food safety. They have to provide resources to develop and implement the plans across different departments as well as provide for training and encourage communication, advises Robert A. Savage, President and Founder of The HACCP Consulting Group.

Sharing some lessons learned from decades of HACCP implementation experience, Savage spoke at a recent webinar on FSQA: Creating HACCP Excellence, presented by SafetyChain Software. We present excerpts below. 

A few years ago, there was a very serious Salmonella outbreak in peanut butter. It appears that company shopped around for negative salmonella results and then shipped the product. It’s a worst case scenario, but in this case, short term profitability at the expense of food safety resulted in the over 600 illnesses and a few deaths as well as the bankruptcy of the company, described Savage.

Role of GMPs in Creating and Minimizing CCPs

Without good GMPs, facilities tend to have more CCPs than necessary. There has to be a good balance between GMPs and CCPs. When companies understand the the relationship between HACCP, GMPs, and CCPs, typically the HACCP plan would not have more than 3 or 4 CCPs and everything else is covered by GMPs. 

Best practices for HACCP management must be committed from the beginning and throughout the process. GMPs should be in place prior to even beginning to revamp the HACCP plan. Multidisciplinary HACCP teams, including QC, QA, Lab, Sanitation, Product Development and Sales, experts, should contribute to the process in developing the plan. Having a multidisciplinary team helps with achieving buy-in or company-wide commitment to the plan. 

Companies have been pretty good with monitoring, but there’s still some confusion between verification and validation. Verification is a check of the checkers. When CCPs are identified and monitored, verification is making sure that the company says what it’s doing and is doing what it says. Validation asks if the company has the right CCPs and how can they prove it. 

Best Practices for Audit Prep

USDA regulated plants have routine inspections to verify what the companies do on an everyday basis. Separate from these routine inspections, USDA also performs food safety assessments which can take days or weeks to complete. Companies under USDA jurisdiction should do their own food safety inspection to prepare for these FSIS audits. FDA regulated plants may go months or years between inspections. These facilities should have third party audits such as SQF or other audits. 

GFSI schemes have taken hold in the US and around the world. The popular one in the U.S. is SQF. Companies that meet SQF standards should have no problem meeting new FDA FSMA regulations.