Category

Food Safety

Keeping Your Workplace Safe

By Teri Danielson

Right now, your employees and customers’ safety is top priority for your food or farm business.  Two stories in the news over the past week have brought home the importance of developing and implementing COVID-19 practices in the food industry workplace:

1)  Oregon OSHA received over a year’s worth of workplace complaints in the past month as a result of the pandemic.
2) Several large meat packing plants in the U.S. have closed their doors as they have become hot spots for the COVID-19 virus with large numbers of employees testing positive.

With the Food Industry being considered critical infrastructure in the country, most food manufacturing facilities have remained open to ensure the nations food supply chain can meet the demand.  The FDA and CDC have both stated that there is no evidence that the virus can be transmitted via food due to the nature of the virus itself.  The risk at this time, is to our food industry workers and their health and safety.

To protect employees and ensure a stable food supply chain, it is critical that food manufacturing companies take time to assess their COVID-19 practices including:

  • Developing a written COVID-19 best practices document
  • Training and implementing best practices in the workplace
  • Checking that the best practices are effective
  • Engaging the workforce in improving those practices

Adapting new practices into your workplace to prevent the spread of COVID-19 is a challenge.  Northwest Food Solutions has posted resources for food companies looking for help and ideas in implementing best practices.  If you have resources or ideas for best practices, please share them with us via email at info@nwfoodsolutions.com.  We will share these in our next newsletter.

Thank you to all the food industry and other critical infrastructure workers who are continuing to do the heavy lifting to keep our nation functioning. Stay safe!

Mock Recalls – Testing the Front End

It’s your worst nightmare as a food producer – you get the call, whether it be from a consumer or a regulatory agency, and find out your company is in a situation where products need to be recalled.  Are you prepared?  How do you know?  What can you do to ensure you are ready should an event arise that requires you to recall.

First, don’t panic.  Preparation for a recall requires focus on four main areas:

  1. Assessment
  2. Team Preparation
  3. Traceability
  4. Communication

We are going to focus on the first area – assessment.

Assessment

This is an area companies sometimes forget to consider when creating a recall plan or running a mock recall.  The assessment area includes the initial notification that triggers the recall team to get together, data gathering and the decision whether or not to recall.  Questions to ask to help prepare include:

  • What are the ways we might learn about a recall?  Do we have processes in place to ensure that information gets to the right people?
  • Have we trained our employees how to respond and gather information from customers and others when a food safety situation is reported?
  • Do we have a simple way to objectively look at the data and information to decide if we are in a recall situation?

So what should your company have in place to address these questions?  A good starting place is to create a customer complaint record or log that walks through the common questions that should be asked when a customer calls in with a comment or complaint.  You may want to create a similar record for notifications that come from other sources, too, like regulatory agencies, suppliers or a media notification.

Once you have created the record or log, sit down with the employees in your company who typically handle customer calls and walk through some examples of how to gather information using the log, and when to escalate a complaint to the next level.   Having a process in place to quickly identify if a complaint requires further action, and knowing what information to gather from the customer will save time in the event of an actual recall, and help your team make a better decision.

Finally, using an evaluation template to lay out all the information you have gathered is a great way to help the recall team decide whether or not a recall is warranted.  A good evaluation template lays out the information in a way that makes the decision apparent.  We use a form with our clients, that includes sections to identify the category of issue, the type of hazard and the severity and likelihood of the hazard.

When we run mock recalls with our clients, we like to start with a mock customer complaint.  That way, the team handling consumer calls gets practice as well as the recall team.  And the assessment portion of the recall plan gets a good workout, too.  Next time you run your regular scheduled mock recall, try testing your notification and assessment processes, and see what you find.

If you would like to get a copy of our recall assessment form, drop us a note here.

How is your preparation for FSMA going?

How is your preparation for FSMA going?

FSMA as a topic is making its way to almost every client discussion we have these days. Everyone is at a different point with preparation and the same is true for us. Teri has begun her 9 week training on Preventative Controls through Washington State University Extension and I will take a 3 day intensive course through Northwest Food Processors Association in June.

So what is FSMA? FSMA is the Food Safety and Modernization Act which was signed into law in 2011 and the regulation compliance requirements begin this year, 2016, in September. It intends to be the next step towards prevention within our federal food safety regulation. The goals of FSMA are to focus efforts on prevention of problems and implementing food safety controls throughout the supply chain.

Several people have done a great job summarizing the regulations, compliance timelines, and topics. Rather than attempt collating all of the details of the regulations, we’ve gathered together a few websites we found helpful when researching and monitoring FSMA. Below are our collection of helpful links:

Techhelp.org is a good resource for up to date information and they offer a series of different trainings on the FSMA by some of the most experienced and knowledgeable food safety experts on the west coast. If you weren’t aware, the FDA will require completion of specialized training for processors of human food and animal feed/pet food. Their next 3 day Preventative Control Qualified Individuals course begins May 23. http://www.techhelp.org/food-safety-modernization-act-information-training-compliance/

 

WattAgNet.com gives a clear, concise overview on the regulation and timing. The table below is handy summary of compliance dates from the article.

 

Achart

Follow this link for the full article at WattAgNet.com.

http://www.wattagnet.com/articles/24693-fsma-preventive-control-rules-outline-final-requirements

 

FDA.gov is the complete source for complete rulings and history of the regulations. The frequently asked questions section is helpful and you can see past webinars.

http://www.fda.gov/Food/GuidanceRegulation/FSMA/default.htm

 

SQFI.com has some interesting information. For those of you using SQF standards, here’s a matrix comparing SQF and FSMA from the SQFI website.

SQF Level 2        FDA Preventive Control Food Safety Plan (FSMA) FDA GMPs (117 subpart B)
Overarching policy statement Yes No No
Written Plan Yes Yes No
Experienced individual in charge Yes Yes No
Trained Staff Yes Yes* Yes
Prerequisite Programs Yes No Yes
Raw material/ incoming   product safety assurance Yes No No
Supplier Verification Yes Yes, in specific cases** No
Allergen Management Yes Yes Yes
Validation of Controls Yes Yes No
Finished product testing No Yes, in specific cases** No
Sanitation Control Yes Yes Yes
Environmental monitoring Yes Yes, in specific cases** No
Corrective Actions Yes Yes No
Traceability Yes No[1] No
Recall Yes Yes No
Records Retention Yes Yes No
Food Defense Yes No2 No
Internal Audit Yes No3 No

 

For more information on SQF or FSMA, check out their “Are you FSMA ready?” page on their website: http://www.sqfi.com/suppliers/fsma-resource-page/

 

If you find other sites to be helpful, please let us know. We are eager to see how the regulation roles out onto shop floors; we expect lots of learnings on all sides.

Keeping Up With Food Safety

When I started out in the food industry 25 years ago, food safety wasn’t even a buzz word yet, and many in the industry believed that making food safe was merely a matter of adjusting the pH or pasteurizing.  I had a boss whose favorite saying was, “no self-respecting pathogen would be caught alive below pH 4.6”.  How little we understood back then and how different the food safety landscape is today.  The Global Food Safety Initiative and the Food Safety Modernization Act have arguably had the biggest impact on the industry since Upton Sinclair’s “The Jungle” spurred passage of the Pure Food and Drug act in 1906.  GFSI was created as an outcome of food safety crises in 2000 that rocked the industry and resulted in the large retailers taking a bigger role in driving food safety initiatives.  The aim of the initiative is to strengthen consumer trust by creating a universally accepted food safety audit schema that reduces food safety risk to the consumer, while at the same time managing cost, redundancy and operational efficiency in the food industry, and improving the effectiveness of global food systems.

The vision is fantastic, but implementing a GFSI food safety schema in a food manufacturing facility is a daunting task, especially for small to mid-sized food companies.  It can take a year or longer to prepare for a certification audit and maintaining the certification becomes critical as no facility wants to end up on the “de-certified” list.  The most important thing to understand about achieving certification from one of the GFSI approved certification bodies, is that it takes a team of people, and everyone in your facility has to be involved to some degree.  As consultants, our role is to help clients put the structure in place to support an on-going food safety team and help clients understand how to build a food safety culture that is supported by upper management.  With a food safety culture in place, achieving and maintaining certification is just part of the everyday work of a company.  Without it, a plant may achieve certification, but it will be costly and challenging to maintain it.

Recently, I completed the SQF Institute’s “Implementing SQF Systems” training and received a certificate of attainment as an SQF Practitioner.  As I sat through the class, it struck me just how much documentation is required to pass an audit and how challenging and time consuming it is to put the documentation in place, especially for small companies.  Another key tool for any company embarking on certification is good project management.  The team implementing the food safety program needs to first understand the scope of what needs to be done, and then determine how to identify the tasks to be completed and break those down into manageable chunks for the team to work on.  Taking an iterative approach to passing a certification audit can be a great way for a team to keep from being overwhelmed by the project and stay on track with their certification timeline.

So while, implementing a GFSI compliant food safety program can be a scary thing for a small food company, it is manageable if companies use the right tools and take an approach that instills food safety into their culture.  If you want more information about how to do this, give us a call, we can help.  And check out our free Excel based supplier document request tracker.  This is a great tool to help small to medium sized food companies track supplier document requests and supplier/ingredient approval.