Tag Archives: inspection

By Alex Kinne

The USDA estimates that foodborne illnesses cost more than $15.6 billion each year. However, biological contamination isn’t the only risk to the safety and quality of food. Food safety can also be compromised by foreign objects at virtually any stage in the production process, from contaminants in raw materials to metal shavings from the wear of equipment on the line, and even from human error. While the risk of foreign object contamination may seem easy to avoid, in 2019 alone the USDA reported 34 food recalls, impacting 17 million pounds of food due to ‘extraneous material’ which can include metal, plastic and even glass.

When FSMA went into effect, the focus shifted to preventing food safety problems, necessitating that food processors implement preventive controls to shift the focus from recovery and quarantine to proactive risk mitigation. Food producers developed Hazard Analysis and Critical Control Point (HACCP) plans focused on identifying potential areas of risk and placement of appropriate inspection equipment at these key locations within the processing line.

Metal detection is the most common detection technology used to find ferrous, non-ferrous, and stainless steel foreign objects in food. In order to increase levels of food safety and better protect brand reputation, food processors need detection technologies that can find increasingly smaller metal foreign objects. Leading retailers are echoing that need and more often stipulate specific detection performance in their codes of practice, which processors must meet in order to sell them product.

As food processors face increased consumer demand and continued price-per-unit pressures, they must meet the challenges of greater throughput demands while concurrently driving out waste to ensure maximum operational efficiencies.

Challenges Inherent in Meat Metal Detection

While some food products are easier to inspect, such as dry, inert products like pasta or grains, metal foreign object detection in meat is particularly challenging. This is due to the high moisture and salt content common in ready-to-eat, frozen and processed, often spicy, meat products that have high “product effect.” Bloody whole muscle cuts can also create high product effect.

The conductive properties of meat can mimic a foreign object and cause metal detectors to incorrectly signal the presence of a physical contaminant even when it is nonexistent. Food metal detectors must be intelligent enough to ignore these signals and recognize them as product effect to avoid false rejection. Otherwise, they can signal metal when it is not present, thus rejecting good product and thereby increasing costs through scrap or re-work.

Equipping for Success

When evaluating metal detection technologies, food processors should request a product test, which allows the processor to see how various options perform for their application. The gold standard is for the food processor to send in samples of their product and provide information about the processing environment so that the companies under consideration can as closely as possible simulate the manufacturing environment. These tests are typically provided at no charge, but care should be taken upfront to fully understand the comprehensiveness of the testing methodologies and reporting.

Among the options to explore are new technologies such as multiscan metal detection, which enables meat processors to achieve a new level of food safety and quality. This technology utilizes five user-adjustable frequencies at once, essentially doing the work of five metal detectors back-to-back in the production line and yielding the highest probability of detecting metal foreign objects in food. When running, multiscan technology allows inspectors to view all the selected frequencies in real time and pull up a report of the last 20 rejects to see what caused them, allowing them to quickly make appropriate adjustments to the production line.

Such innovations are designed for ease of use and to meet even the most rigorous retailer codes of practice. Brands, their retail and wholesale customers, and consumers all benefit from carefully considered, application-specific, food safety inspection.

Ensuring Safety

The food processing industry is necessarily highly regulated. Implementing the right food safety program needs to be a top priority to ensure consumer safety and brand protection. Innovative new approaches address these safety concerns for regulatory requirements and at the same time are designed to support increased productivity and operational efficiency.

May 18, 2020

Food Fraud Quick Bites

No Celebration During These Days Of The Dead

By Susanne Kuehne

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Food fraud — Find records of fraud such as those discussed in this column and more in the Food Fraud Database.
Image credit: Susanne Kuehne.

One of the worst suspected alcoholic beverage poisoning incidents has claimed dozens of lives in Mexico. A possible cause may be tainted liquor from illegal bootleg sources; the suspicion is pointing to methanol as a contaminant, which can lead to blindness and even death. Due to the coronavirus crisis, some Mexican states banned alcohol production and sales, which may have promoted the sales of illicit alcoholic beverages. An Euromonitor report mentions that about 25% of alcohol beverages in developing markets are illicit and may endanger consumers’ health and lives.

Resource

Taylor, P. (May 14, 2020). “Another illicit alcohol tragedy as dozens killed in Mexico”. Securing Industry.

March 2, 2020

Bug Bytes

Sanitation and IPM Inspection

By Peter Jardine

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Register to attend the complimentary webinar: New Technology’s Impact on Pest Management in a FSMA Regulated World | March 5, 2020 | 12 pm ETMillions of pounds of food are lost every year due to pest activity. A lot of those lost food products could have been prevented through a quality sanitation program. One of the best ways to protect your facility from the potential damage and pathogen spread caused pests like rodents is to maintain a quality sanitation program.

Every sanitation program should take into consideration conditions that are conducive to attracting and supporting unwanted visitors. As rodents are incredibly agile and intelligent creatures, one of the best ways to keep them out of a facility is to give them no reason to be interested in coming in. This means eliminating access to each of their basic needs: Food, water and harborage—in any amount. Remember, they are small, scrappy creatures and only need crumbs and droplets of water to survive. Once you change your perspective from that of a human being to that of a rodent you may be surprised by the bountiful conditions that are at your feet.

February 3, 2020

Bug Bytes

What’s the Most Important Tool for Proper IPM Inspection?

By Peter Jardine

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As technologies become more and more advanced, the best pest technicians are often those willing to use the latest and greatest, most advanced tools on the market to provide superior service. However, if your technician is not carrying this one basic item in their toolkit, there is a good chance you’re not getting the quality of service you deserve. Any guesses at what that tool might be?

Register now for the complimentary webinar: New Technology’s Impact on Pest Management in the FSMA Regulated World | March 5, 2020 | 12 pm ETIf you guessed flashlight, you’re correct. Whether or not your technician carries a flashlight with them when they perform the inspection speaks volumes about the quality of service you are getting. A flashlight tells you two important things. First, that your technician is not just checking traps, but performing an investigation. He or she is looking for conditions that attract and foster pests. Second, a flashlight sends the message that your technician is willing to inspect dark or difficult-to-reach places. This is the type of technician willing to get on hands and knees to check under equipment. They will climb and crouch in order to reach the places pests are likely hiding. They value a pest-free environment more than their own convenience.

In short, the most important work your pest technician can provide is a thorough investigation to help prevent pest problems before they occur. If your pest technician is not performing an investigation each time they enter your facility, you’re not getting the value you need and should expect from your service provider.

November 19, 2019

Bug Bytes

How to Prepare an Integrated Bird Management Audit Program

By R. Brett Madden

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Birds of different species can become a pest problem depending upon where they are landing, roosting or nesting. In terms of food facilities, birds can cause various concerns: Product safety risks, possible contamination (bird droppings/feathers), poor audit grades, inspection failure, secondary insect pest problems, vectoring of foodborne illness pathogens, plant closures or fines. It is for these reasons that it is essential that food, beverage and product manufacturers (FBP) establish an integrated bird management (IBM) program.

An IBM program will ensure that every essential team member is on the same page in terms of the protocols for managing pest birds within and around the facility. Even if a facility has taken a proactive approach to bird control, the potential exists for birds to enter a facility. Especially considering bird pressures around adjacent properties, buildings, bodies of water and food sources near the facility.

Read Part I of this series: Bird Problems and Control Methods for Food Production FacilitiesIBM for food industry facilities is a systematic approach to preventing birds from gaining access within a facility and reducing the length of time birds remain within a facility. Nuisance birds, depending upon how severe the bird pressure—i.e., how many birds are landing, roosting and/or nesting within a given area—can cause severe damage to equipment, property, food products, displays, vegetation, façade signage, ledges, roofs, HVAC equipment, drains, fire suppression, electrical equipment and more. The longer that birds are permitted to remain within and around a facility, the more damage they can cause, and the harder it is to remedy the problem. Thus, it is critical to remove any birds that have gained entry as soon as possible to prevent possible FBP contamination and the birds getting comfortable within the facility.

There are several components to developing an IBM program. First, you need to conduct a complete inspection of the interior/exterior of the facility, followed by a review of the current data as well as any historical bird data. Now that you have all the raw data, you can begin developing the site-specific IBM plan for the FBP facility. Now that you have the program designed, the program can be implemented. Finally, after a defined timeframe that the IBM program has been active, the program needs to be evaluated to determine if any adjustments need to be made to the program.

Inspection

The first step in developing an IBM program is to conduct an initial site inspection audit of the interior and exterior of the facility.

Integrated bird management, audits, food safety — An example of an integrated bird management food safety audit checklist. Credit: Aviaway

The following various elements need to be inspected and with said findings documented.

Interior audit, pest management — An example of an interior audit spreadsheet. Source: Aviaway. (Click to enlarge)

On the interior of the facility, look at the following items:

Active Birds with the Facility
- List the areas and locations of birds
  - Example: Location(s): Food prep area(s), warehouse, etc.
- Any history of birds and related areas
Interior Landscaping
- Type(s) and necessity
Food Processing Areas
- Any active control measures in place
- Assess the level of risk
Bay Doors
Location(s): Gaps
Location(s): Bumpers
General Doors
- Location(s): Gaps
- Location(s): Bumpers
- Location(s): Structural
- Location(s): Doors left open
Additional Access Point(s)
- Check all equipment areas that enter/exit building
Pipe-Line Penetrations
Sanitation
Conductive Conditions
- Location(s): Standing water
- Location(s): Food Sources
- Debris
Bird Droppings or Nesting Materials
Staff feeding birds
- All access to food and water

Exterior audit, pest management — An example of an exterior audit spreadsheet. Source: Aviaway. (Click to enlarge)

On the exterior of the facility, look at the following items:

Active birds with the facility
- List the areas and locations of birds
  - Example: Locations(s): Rear loading dock
- Any history of birds around the exterior of the facility
Adjacent Structures
- Accessory buildings and structures
Sanitation Practices (Exterior)
- Location(s): Dumpsters
- Exposed food sources and spillage
Trash Receptacles
Trash Removal Frequency
Food Waste on Ground
Cleaning Practices
Cleaning Practices Schedule
Cleaning Food Waste Bins
Motion Doors
Bay Doors (Exterior)
- Location(s): Gaps
- Location(s): Bumpers
- Location(s): Structural
General Doors (Exterior)
- Location(s) Doors Being Left Open
Additional Access Point(s)
Bodies of Water
Conductive Conditions
Structural (Exterior)
- Location(s): Pipe-Line Penetrations
- Location(s): Flashing
- Location(s): Pipes
- Location(s): Openings
- Location(s): Roof
- Location(s): Roof Hatches
- Location(s): Windows
- Location(s): Canopy (Front/Rear)
- Location(s): Awnings (Front/Rear)
- Location(s): Façade Signage (Front/Rear/Side)
Drainage
Standing Water
Clogged Drains
Landscaping
- Retention ponds
Bird Droppings or Nesting Materials
Exterior Storage
Merchandise Displays
Existing Bird Control Devices

Review

Next, after all the above items have been inspected and findings recorded, all the data needs to be reviewed. In addtion, all the current bird management practices within the facility, documentation practices, and current audit/inspection findings should be all evaluated together. All this information is your road map for developing your IBM Program. Make sure that while you are collecting all the said raw data, you also speak with all necessary staff to get the most accurate information possible.

Documentation

Now that you have conducted your inspections and collected all the data, it’s time to create a site-specific IBM Policy & Plan for the facility. The development and implementation of the IBM plan will provide the appropriate procedures that are to be implemented to prevent, control and exclude birds from entering a facility and from keeping birds an acceptable distance away from the facility. With proper training and implementation of IBM procedures, there will be a reduced likelihood that birds will be able to enter the facility, and the length of time birds remain inside the facility will be reduced—thus, reducing the level of pest bird damage caused, reducing hazards to food sources, equipment, the public, and the facility environment.

Each facility is unique in its operation, location and potential for bird activity. The facility’s IBM plan will be designed to factor its control options when remedying and preventing bird pressure.

Implementation

Now that you have an IBM Plan, it’s time to implement the plan. First, make any necessary changes based upon findings of the audit and review of all data. Next, correct any conducive conditions that were discovered during the inspection. All the items that may require adjustment may need to be planned out depending upon budgetary constraints. Define staff roles regarding bird control efforts on a front-line facility level. Each member of the action team must fully understand their role and responsibility about the implementation and day-to-day operation of the plan.

The IBM Plan is the roadmap that should be followed for managing pest birds throughout the interior and exterior of the facility and related structures. It will set forth the facility’s bird threshold levels and site-specific facility needs. Furthermore, the IBM Plan will provide in detail how each phase of the plan will be implemented at each facility. The facility coordinator, in collaboration with the IBM coordinator, shall be responsible for the administration and implementation of the IBM plan. Each of their roles and responsibly should be thoroughly reviewed and understood.

Next, conduct staff training on proper bird control removal methods if handing live removal internally. Otherwise, what are the approved processes for third-party vendors who are providing removal services? Finally, conduct a review of the new documentation process to record all necessary data for the IBM program. Data collection is a critical component in evaluating the success of the plan and determining if any adjustments need to be made.

Evaluation

To ensure goal compliance, the IBM program should be evaluated at each site annually. The review must consist of all records, the number of birds that gained access into the store, corrective actions taken (at the facility level and outside efforts), and any plan adjustments. By reviewing all the data collected, the plan’s effectiveness can be determined, and whether alterations need to be made. Note that the IBM plan is not a static document that sits in a binder. The plan will have to evolve as operations change, or the set goals of the program are not met.

Conclusion

A proactive approach to reducing bird populations is critical for food industry facilities. As such, the IBM program will ensure that your entire staff is adequately trained on all the site-specific bird control methods, reduce the frequency of birds entering the facility and create a documented bird control program that is designed for your specific facility.

November 14, 2019

FST Soapbox

USDA Publishes Hemp Rules: Will It Impact Food?

By Cori Goldberg, Adam Brownrout, John Kendzior

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On October 29, 2019, the USDA released its long-awaited draft rule establishing a domestic hemp production plan, providing clarity to growers and ancillary businesses about how the USDA will regulate the hemp crop. The USDA, under authority provided by the 2018 Agricultural Improvement Act (2018 Farm Bill), was tasked with promulgating regulations and guidelines to establish and administer a program for the production of hemp in the United States. This rule has now arrived and been published in the Federal Register. The rule provides requirements for all state and tribal hemp production plans including requirements for testing hemp, licensing growers, disposing of non-compliant hemp, and collecting and storing information related to hemp production. The USDA will now accept public comment on the rule until December 30, 2019.

Although the USDA rule will greatly contribute to the expansion of legally grown hemp in the United States, this rule does not alter the law regarding CBD foods and CBD dietary supplement products. This is because the 2018 Farm Bill left intact FDA’s authority to regulate the sale and marketing of CBD foods, dietary supplements, drugs, and cosmetics, as those product types fall under FDA’s purview generally. FDA has allowed the sale of CBD cosmetics, with certain restrictions, and companies may submit CBD products to FDA through FDA’s drug approval process. However, it has maintained that the addition of CBD to foods and dietary supplements is illegal. Under the federal Food, Drug, and Cosmetic Act (FDCA), once a substance is approved as an Active Pharmaceutical Ingredient (API) in an FDA-approved drug, that substance may not be placed into interstate commerce in a food. Also under the FDCA, once a substance is approved as an API in an FDA-approved drug, that substance is excluded from the definition of a dietary supplement. FDA approved the pediatric epilepsy drug, Epidiolex, whose API is CBD. Therefore, FDA has concluded that CBD may not be placed into foods in interstate commerce and that CBD products are excluded from the dietary supplement definition and therefore may not be sold as dietary supplements. The USDA rule does nothing to change the legal status of CBD food or dietary supplement products. Thus, despite the expected increase of hemp availability following the passage of the USDA rule, CBD companies must wait for the FDA green-light in order to manufacture or sell hemp-derived CBD food products lawfully.Learn more about important regulatory & quality issues in the cannabis space from Cannabis Industry Journal

However, the rule does state that additional hemp is necessary to support the growing CBD market, and it notably put pressure on FDA by stating that if “FDA does not provide clarity about their plans for future regulation of CBD, there will continue to be uncertainty and downward pressure on the CBD portion of the hemp market.”

So what does the USDA rule do? Under the USDA rule, states and tribes will have the option of either submitting a proposed hemp regulation plan to the USDA for approval or agreeing to submit to the USDA’s general requirements. All state and tribal plans must include certain provisions, including but not limited to:

Land used for production: State and tribal plans must identify a process for collecting, storing and maintaining relevant information regarding land used for growing hemp in the state. This includes information regarding the description, acreage, and boundaries of the farm land.
Sampling and testing for delta-9 tetrahydrocannabinol (THC): State and tribal plans must implement testing procedures to ensure that plants do not exceed THC levels above 0.3% (as provided in the 2018 Farm Bill). All testing facilities must be DEA approved, as non-compliant product with THC levels over 0.3% would be considered “marihuana” and a schedule 1 substance under the Controlled Substances Act of 1970 (CSA). Additionally, laboratories will be required to report a “measure of uncertainty” in their testing, designed to provide a buffer for the potential variation in sampling and testing procedures. Accordingly, plants testing higher than 0.3% THC but still within the “measure of uncertainty” will be considered compliant.
Disposal of non-compliant products: States and tribes must develop a procedure for destroying non-compliant cannabis containing more than 0.3% THC. Because non-compliant product is considered a controlled substance, all product must be disposed of in a manner consistent with the CSA. Therefore, product must be collected and destroyed by a DEA agent or law enforcement officer.
Inspection of hemp producers: States and tribes must develop procedures for inspecting hemp producers on an annual basis and also for inspecting random samples. The state must also develop procedures to identify and attempt to correct certain negligent acts such as not obtaining licenses or producers exceeding acceptable hemp THC levels.
Information sharing: State and tribal plans must include procedures for reporting information to the USDA. This information must be provided to the USDA within 30 days of receipt from the hemp producers and includes contact information for all hemp producers in the state, legal descriptions of the land used for hemp production, and the license status of all hemp producers in the state.
In states and tribes without an approved or proposed plan, hemp producers will be subject to the USDA general plan. The general plan also provides similar requirements for the testing and sampling of hemp. The USDA will provide licenses directly to hemp producers in states without an approved or submitted plan as some states may not want to have primary regulatory authority of hemp. These states will essentially hand over regulatory responsibility to the USDA. These licenses will be available by application 30 days after the final rule is published. Notably, the draft USDA rule also provides that states and tribes are restricted from prohibiting the transportation or shipment of hemp or hemp products produced under a state plan, tribal plan or a license issued under the FDA. The interstate commerce provision should put an end to the arrests of those transporting legally produced hemp from one state to another. For example, in July 2019, a trucker was arrested and charged with felony possessions of marijuana and intent to distribute while transporting legally grown hemp through South Dakota (South Dakota still considers hemp a controlled substance).

So while the USDA rule is much anticipated and grabbed the attention of many when published, food and dietary supplement manufacturers, distributors, and retailers are still stuck where they were before. We will all continue to wait and see what FDA will do.

Resource

“Establishment of a Domestic Hemp Production Program”. (October 31, 2019). Federal Register. Retrieved from https://www.federalregister.gov/documents/2019/10/31/2019-23749/establishment-of-a-domestic-hemp-production-program.

November 7, 2019

Simmons Prepared Foods Recalls More than 2 Million Pounds of Poultry Products

By Food Safety Tech Staff

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Yesterday Arkansas-based Simmons Prepared Foods, Inc. initiated a Class I recall of 2,071,397 pounds of poultry products over concern of foreign matter contamination. The products, which were produced between October 21 and November 4, were shipped to Alabama, Arizona, Arkansas, California, Georgia, Minnesota, Oklahoma and Pennsylvania.

Thus far there have been no confirmed reports of adverse reactions related to product consumption.

In an FSIS news release, the agency expressed concern that some of the products may be frozen at institutions and is advising that the products be thrown away or returned to where they were purchased.

September 20, 2019

Bug Bytes

Stay Audit-Ready, Anytime with Integrated Pest Management

By Chelle Hartzer

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The unlimited supply of food sources that manufacturing facilities provide can make pest management a daunting task, especially with the scrutiny of third-party auditors, government regulators and customers. These high standards, along with yours, mean that diligence is a key ingredient in the recipe for pest management success.

Why is this important? The steps you take to prevent pests, and how issues are resolved if pest activity is detected, affects the overall credibility of your business. After all, pest management can account for up to 20% of an audit score.

Auditors look for an integrated pest management (IPM) plan, which includes prevention, monitoring, trend reports and corrective actions. If you want to stay audit-ready, all the time, implement the following five principles.

Open Lines of Communication

A successful pest management partnership is just that: A partnership. Create an open dialogue for ongoing communication with your pest management provider. Everyone has a role to play from sanitation to inspection to maintenance. For example, if there are any changes in your facility, such as alteration of a production line, let your provider know during their next service visit. During each visit, it’s important to set aside time to discuss what was found and done during the visit, including new pest sightings and concerns.

Communication shouldn’t be limited to the management team; your entire staff should be on board. During their day-to-day duties, employees should know what to look for, and most importantly, what to do if they notice pests or signs of pests. Reporting the issue right away can make a huge difference in solving a pest problem before it gets out of hand. Also, most pest management providers offer staff training sessions. These can be an overview of the basics during your next staff meeting or a specialized training on a pertinent issue.

Inspect Regularly

A thorough inspection can tell you a lot about your facility and the places most at risk for pests. Your pest management provider will be doing inspections every visit, but routine inspections should be done by site personnel as well. Everyone at the site has a set of eyes, so why not use them? This way, you can identify hot spots for pests and keep a closer eye on them. Pests are small and can get in through the tiniest of gaps, so some potential entry points to look out for are:
• Windows and doors. Leaving them propped open is an invitation for all sorts of pests. Don’t forget to check the bottom door seal and ensure it is sealed tight to the ground.

Floor drains. Sewers can serve as a freeway system for cockroaches, and drains can grant them food, water and shelter.
Dock plates. A great entry point for pests, as there are often gaps surrounding dock plates.
Ventilation intakes. These are a favorite spot for perching, roosting or nesting birds, as well as entry points for flying insects.
Roof. You can’t forget about the roof, as it serves as a common entry point for birds, rodents and other pests.

Another thing to look for is conducive conditions, such as sanitation issues and moisture problems. These are areas where there may not be pests yet, but they provide a perfect situation that pests could take advantage of if they aren’t dealt with. Make sure to take pictures of deficiencies so that can be shared with the maintenance department or third-party who can fix it. You can also take a picture of the work when it has been finished, showing the corrective action!

Keep It Clean

Proper sanitation is key to maintaining food safety and for preventing and reducing pests. You need a written sanitation plan to keep your cleaning routine organized and ensure no spots are left unattended for too long. The following are some additional steps consider:

Minimize and contain production waste. While it’s impossible to clean up all the food in a food processing site (you are producing said food!), it’s important to clean up spills quickly and regularly remove food waste.
Keep storage areas dry and organized.
Remember FIFO procedures (first in, first out) when it comes to raw ingredients and finished products.
Clean and maintain employee areas such as break rooms and locker rooms.
Ensure the outside of your facility stays clean and neat with all garbage going into trash cans with fitted lids.
Make sure dumpsters are emptied regularly and the area around them kept clean.

Monitoring

Monitoring devices for many pests will be placed strategically around your facility. Some common ones are insect light traps (ILTs), rodent traps and bait stations, insect pheromone traps and glue boards. It’s important to let employees know what these are there for and to respect the devices (try not to run them over with a fork lift or unplug them to charge a cell phone). These devices will be checked on a regular basis and the type of pest and the number of pests will be recorded. This data can then be analyzed over time to show trends, hot spots, and even seasonal issues. Review this with your pest management provider on a regular basis and establish thresholds and corrective actions to deal with the issues when they reach your threshold. The pest sighting log can also be considered a monitoring tool. Every time someone writes down an issue they have seen, this can be quickly checked and dealt with.

Maintain Proper Documentation

Pest management isn’t a one-time thing but a cycle of ongoing actions and reactions. Capturing the process is extremely important for many reasons. It allows you to analyze, refine and re-adjust for the best results. It’s a great way to identify issues early. Also, it’s a critical step for auditors. Appropriate documentation must be kept on hand and up-to-date. There’s lots of documentation to keep when it comes to pest management and your provider should be keeping all of that ready—from general documentation like your annual facility assessment and risk assessment to training and certification records, pest sighting reports, safety data sheets and more.

The documentation aspect may seem like a lot at first, but a pest management provider can break it down and make it easier. It’s absolutely necessary for food and product safety and will become second nature over time.

June 19, 2019

Food Fraud Quick Bites

The Horse Is Out of the Barn

By Susanne Kuehne

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Every horse owner (and his or her wallet) know that their equine partner will most likely consume an array of medications over the course of their lifetime, such as anti-inflammatory drugs, joint supplements, antibiotics, topical ointments, pesticides and fly repellents, and many more. Many of these horses are not fit for human consumption, but some ended up in the human food supply, starting in Ireland. The Irish Police Force is investigating this quite lucrative horsemeat fraud, including raiding the suspects’ farms and other property and inspecting the horse microchip tracking system.

Resources

Lally, C. (June 6, 2019). “Gardaí raid farms over claims unsafe horse meat entering food chain”. Irish Times. Retrieved from https://www.irishtimes.com/news/crime-and-law/garda%C3%AD-raid-farms-over-claims-unsafe-horse-meat-entering-food-chain-1.3916827

October 25, 2018

FST Soapbox

What Should I Do if I Have a Foreign Material Problem?

By Chris Keith

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Imagine this: While cleaning a slicing machine during a sanitation break, one of your employees discovered a piece of harp wire was missing from the machine. The meat that had been sliced since the cutting machine’s last inspection had already been added to your product, and the product had been packaged. It had already passed through your company’s inline inspection machines without any foreign contaminants being detected.

You enjoy a spotless reputation in the food industry and know that if consumers lose faith in the product, it will suffer significant damage to both its reputation and its bottom line. So what do you do now?

Here’s a look at four different scenarios and how each one can affect a respected food manufacturer.

Option 1: Dispose of the Full Production Run

Disposing of a full production run will give your company complete confidence that the contaminant issue is resolved and will never reach the public. However, you have to take into consideration the full cost and implications of such a move, such as:

Where to dispose of the contaminated product. The FDA has specific rules about disposing of contaminated food products, but those guidelines can be affected by local, state and even federal regulations. Among the disposal options are landfills, rendering or incineration. You must find the proper facility, arrange the safe transportation of the product and procure all the required permits for the disposal.

Food waste. With 40% of the food produced in the United States going to waste, and 50 million Americans not knowing where their next meal will come from, you don’t want to add to the problem.

Product out of stock. Having your product out of stock will be costly. In addition to the lost sales, there’s a chance that consumers will turn to another brand—and not return to buying your product.

Cost of reproduction. To re-run the entire product line, you will essentially double your costs. You will have to pay for the cost of the products used, as well as pay for new packaging and all labor costs.

Option 2: Rework the Product In-House

You can use your own resources and inline equipment to try and troubleshoot the problem. Running the product through the metal detector to look for the harp wire could salvage most of the product, and would give your company the ability to supervise the entire process. That way, if you find the metal, you’d know firsthand that the contaminated product is out of production and won’t reach consumers.

But there are some expensive downsides to this approach. Among the factors that your company must consider are:

Loss of productivity. Both from the standpoint of equipment utilization and the productivity of employees, reworking the product would be costly to the company. You would have to have to slow the production line and manually re-run all the product through the metal detector to look for the missing wire.

Increased labor costs. You would have to pay overtime to your employees and keep your standard production line running while it re-runs the product and looks for the suspected contamination.

Limitations of their inspection equipment. Your results are only as good as the equipment you are using, and there’s always a risk that the metal detector that missed it the first time won’t find it the second time, either.

It seems like a bit of a gamble; if the metal detector catches it the second time around, then it could be worth it. If the product is re-run and no contaminants are found, however, your company is back where it started and must decide how to move forward.

Option 3: Risk It and Ship the Product to Retailers

Since the metal wasn’t detected by the company’s inline inspection system, you cannot be absolutely sure the metal is in the product. You only know that a broken piece of harp wire is missing; it’s unclear whether that wire made it into the food.

The least expensive option—but also the riskiest—is to go ahead and ship the product, hoping that the missing wire didn’t make it into the food and, therefore, never gets discovered by consumers.

There’s a chance that the metal detector was right, the wire isn’t in the food, and things will be fine. However, if the risky gamble doesn’t go in your favor, the consequences could be severe and this becomes the most expensive option of all. Among the risks the company faces are the following.

Costly recall. Food recalls are always expensive. According to a study from the Food Marketing Institute and the Grocery Manufacturers Association, the average recall runs up a $10 million tab in direct costs alone.

This includes the cost of notifying the supply chain and consumers, retrieving the product, storage, disposal and additional labor costs associated with having to perform all of these actions.

Possible litigation. Food recalls often are accompanied by lawsuits, and if the metal wire is eaten by a customer and causes injury, you could be held liable for everything from medical bills to time lost from work due to pain and suffering.

Bad publicity and lost sales. In today’s 24/7 news world and with the power of social networking, news of a food recall can reach consumers at lightning speed. This equates directly to lost sales and can have a negative impact on your brand reputation and market value.

A recent Harris Interactive Poll found that 55% of consumers would switch brands temporarily after a recall, and 15% would never buy the product again. What’s more, 21% said they would avoid buying any other products made by that manufacturer.

Option 4: Use an X-ray Inspection Service

A fourth option can help avoid lawsuits, recalls and bad publicity, while at the same time sidestepping unnecessary waste and the costs associated with disposing of an entire production run or reworking it internally.

You can have your product shipped to an X-ray inspection facility, or use an X-ray inspection rental service.

A contaminant removal service and professional catalog reporting with full traceability could also ensure that the specific contaminant was located and removed, and you would have the confidence that the problem had been resolved as the product reached consumers. There are several other advantages to using a company that offers this type of solution as well, including:

Reduced waste. Because the only product being thrown away would be the product that was contaminated, there would be minimal waste. This is the only option that allows you to recover the rest of the product, with the certainty that it has been inspected and is safe for its customers.

Advanced detection capabilities. You can be confident in inspection process using custom technology that enables the detection of foreign particles down to 0.8 mm or smaller. In addition to metal, such systems can also detect product clumps, glass particles, stones, bone, rubber, plastic, wood, gasket materials, container defects and missing components.

This type of solution far exceeds the capabilities of inline inspection machines, and, because it can run a single pallet an hour, instead of the average 10,000 pounds an hour, and thus it spends more time focusing on what is passing through the machine to ensure no contaminants pass through.

Final Thoughts

When it comes to the quality of your product, it’s better not to take any chances. When you put your product line in the hands of a third-party X-ray food inspection company, you know you will get results since food safety is our specialty — and it’s what they do, all day, every day.