- FSSC 22000 is growing in popularity as a GFSI Certified Program Owner (CPO). It is a well-defined food safety management standard that allows companies flexibility in deciding how to integrate specific requirements into established organizational system activities. Understanding the process of adapting current company policies and procedures to meet the value-added requirements of the standard is critical for success.
- FSSC 22000 version 4.1 went into effect on January 1, 2018. All current FSSC 22000-compliant facilities need to understand the changes and update their systems to ensure they are compliant with Version 4.1.
- Even if currently approved to an alternate GFSI-approved CPO (formally referred to as a food safety management scheme) such as SQF or BRC, it is important to understand industry best practices, which are highlighted in this training. It may also be necessary to evaluate suppliers that choose FSSC 22000; this training will explain what they must do to achieve and maintain this certification, which will help with Supplier Evaluation and Approval under FSMA.
- The current revision (4.1) emphasizes new requirements for food defense and food fraud. Although we recommend attending our Food Defense workshop* to truly understand vulnerability and risk, it is still necessary to clearly define what must be changed. To understand and ensure compliance, it is necessary to first understand what is being asked of us.
- If currently certified to FSSC 22000, then companies must comply with the many updated requirements of Ver 4.1 in their 2018 calendar year upgrade audits. As with any audit, the company must define, implement and provide at least 90 days’ evidence (records) that it is maintaining compliance on an on-going basis. The sooner this training is received, the sooner this documentation process can proceed.
- Debby Newslow is the primary instructor for both this class and the Internal Auditing workshop being presented after this course. Drawing from her experience as an FSSC 22000 Lead Auditor, Debby will explain best practices, both for those implementing a new system and for those involved in the on-going maintenance of a compliant, sustainable and effective management system.
- While many companies have one or two people who have attended a formal training, Murphy’s Law (and the new requirement for unannounced audits) dictates that the auditor will likely arrive when those persons are on vacation, or out sick. It is critical that we train enough back-ups to feel confident that we can welcome an auditor any day, any time, and on any shift.
We are now offering a drawing for two day passes to Disney World! Register to attend our class before January 15 and be entered to win!
*Combination discounts are always available for attendees wishing to sign up for multiple workshops. Call us at (407) 290-2754 to find out how much you can save.
I sat down one morning to write out five reasons why someone should attend our public workshop that we hold in partnership with Mr. Rod Wheeler, Food Defense, Crisis Management and Intentional Adulteration. I stopped myself at twenty, but could have kept going! Click here to find out if you are subject to this rule.
- We have a responsibility to ensure that our facilities and employees are safe from an intruder with a focus on causing harm.
- Effective Crisis Management programs protect our profits, brand, and employees.
- Even if we have had crisis management programs for years, we must evaluate them regularly to ensure they remain current and effective.
- Current management system standards (now also known as CPOs) all require a current crisis management program.
- We can learn from an experienced law enforcement detective, Mr. Rod Wheeler. Mr. Wheeler shares his life lessons learned from years of experience defusing situations that required common sense and crisis management skills to protect the public.
- It is important to learn and practice the steps necessary to perform a vulnerability assessment. Although companies often have a required vulnerability assessment, it is very important that we see this process from in independent external experienced individual such as Mr. Wheeler, who is uniquely qualified to judge its overall effectiveness.
- I know that my company must be compliant with the new FSMA Food Defense Rule (Mitigation Strategies to Protect Food Against Intentional Adulteration, 21 CFR 11 and 121) and this is a golden opportunity to get a head start on the requirements for our operation and develop a compliant program.
- I know that FSMA has included exemptions to the Food Defense rule, but how can I be sure which (if any) of the exemptions and modified requirements apply to my operation? Do I need to maintain records as proof of my eligibility for an exemption?
- I remember through history some of the horrible issues that have happened where a disgruntled employee (or just a person looking to cause harm) have penetrated a facility, causing a lot of harm and sometimes death to innocent employees. I know we can’t predict this, but we must take every measure possible to mitigate the effects of violence in our facility.
- My third-party auditor questioned me as to whether we have an effective program that ensures that our products are protected against contamination and our ingredients, packaging, software and formulas are controlled and protected against adulteration or tampering.
- We feel our facility is secure, but is it really? Can we learn how to effectively secure our operation?
- What about our visitor and contractor policy? Are we effectively protecting our operation? How do we know that? What type of inspections should we perform (and what records should we keep) to ensure that when we are asked, we can demonstrate the effectiveness of our operation?
- Is our pre-employment screening and defense training programs effective for all our employees including our seasonal, temporary, contract workers and volunteers? What type of screening should we do? What is enough?
- How do we educate our employees so that they can detect, prevent and respond to tampering, criminal or terrorist activity?
- How do we identify which employees should have clearance and password to our computer process control systems and critical data systems? What are the signs that a trusted employee is having personal problems that could lead to disaster if not addressed?
- Food defense and product adulteration is so vital that our company’s management, top executive and employees can be charged with a crime if they sell a product that is contaminated or otherwise makes someone sick (whether intentionally or not). We must protect our facility, employees and products from becoming contaminated in a way that could cause illness or death.
- Because I don’t believe that the potential for adulteration of our food supply will decrease any time soon. News headlines frequently warn against attempts (or worse, success) from those focused on causing harm to the innocent. A headline in a central Florida paper twice warned again fish hooks in meatballs set out for dogs in a popular doggy park. We must do everything we can do protect the public, and taking a course like this, from someone that has experienced so much and can share how to prevent the “what-if’s”, is so valuable in todays world of processing. This applies to not only food, but other processes such as chemical or packaging manufacture. One associate told us the story of a bottle of bleach that had been filled with a different chemical – one that when added to a bleach, would have caused a massive explosion – harming or almost killing the unsuspected house wife. We must be proactive.
- If an incident has happened in your industry, you might think “Wow, recently there was a tampering issue with a product in our food category! When we did a risk assessment, it became evident that that could have been us. We thought we had an effective program! What an enlightening experience. We need to educate our associates and we must be more careful.” Keep in mind that you may or may not be aware of all incidents – do some research on violence in the workplace and you will see that it crosses all barriers and affects businesses across the globe.
- As an auditor, I remember one day during an audit, I wrote a non-conformance because the auto entrance gate for having had a space large enough for me to crawl under when closed and locked. The client accused me of nit-picking, but I stand by my finding. From a security viewpoint, access to the facility must be controlled. It is amazing what those who want to do harm can think of to enter a facility.
- As food processors and handlers, we have a direct responsibility to educate ourselves in the best way possible. Not just to comply with the law, but to protect our customers and employees. There is no better way to really examine what we do and learn where we can improve than listening to Mr. Rod Wheeler. This gentleman has evaluated operations and assisted companies from coast to coast in both preventing and troubleshooting tampering events.
When it comes to crisis management, we always think, "That won't happen to us," or, "That's what insurance is for!" but the truth of the matter is that the way is littered with broken companies who have fallen by the wayside as terrible warnings to the rest of us, who then update our plans in response to their horrific tragedy. These events DO happen, and it is just a matter of chance that it was not us this time! There but for the grace of God go I. Please join us for this excellent and enlightening presentation by Mr. Rod Wheeler.
While attending the 2017 Food Safety Consortium in Schaumberg, we had the pleasure of conversing with several FSPCA (Food Safety Preventive Controls Alliance) Lead Instructors regarding their Preventive Controls for Human Food courses. It was reported at the conference that 50,000 PCQIs (Preventive Controls Qualified Individuals) have been trained at FDA-recognized workshops since the inception of the program. As with any new system, there are concerns - although we can all agree the quality of the curriculum is excellent, no single system is ever perfect right out of the box, and we are all developing ways to optimize the experiences of our attendees.
We've been contacted by many potential clients and workshop attendees who are under the impression HACCP is going away with the advent of the Preventive Controls for Human Food Regulation (21 CFR 117, commonly known as the PC rule). While this may seem like a logical conclusion, it is not true for several reasons. HACCP (Hazard Analysis and Critical Control Points) is the foundation of all preventive food safety management systems that have followed, including the Hazard Analysis and Risk-based Preventive Controls system introduced by the regulation (see what they did there?)
In the world of industrial equipment manufacturing, 3-A Sanitary Standards, Inc. (3-A SSI) is well known for developing sanitary standards for equipment and processing systems used in food, beverage, and some pharmaceutical manufacturing applications. 3-A SSI also licenses the use of a registered mark, the 3-A Symbol. For a piece of equipment to bear the coveted 3-A symbol, it must undergo a third-party verification inspection to ensure it meets the provisions of the applicable 3-A Sanitary Standard. Based in MacLean, Virginia, 3-A SSI was originally founded by regulatory sanitarians, equipment fabricators, and processors to create sanitary standards for the design of equipment intended for use in the dairy industry. Today, 3-A Sanitary Standards are commonly recognized and specified throughout the food industry. A third party, non-profit organization, 3-A SSI has a sterling reputation as a resource for hygienic design information and educational materials, for developing and maintaining 3-A equipment standards and 3-A Accepted Practices, and for administering a rigid verification program to authorize the use of the 3-A Symbol on conforming food manufacturing equipment.
In May of 2017, the first compliance date passed for the Foreign Supplier Verification Programs regulation under the Food Safety Modernization Act (2011). Other than changing our approach to imported food safety from a reactive to a proactive way of thinking, what are some common misconceptions about this regulation, and where do we see it going in the next five to ten years?
According to an article published today in the Daily Globe entitled “Opportunities Abound in Food Safety”, 2.2 million people die each year as a result of foodborne illnesses and most of them are children. Food safety is an issue that impacts every country around the world and therefore, more and more people are viewing food safety as an essential aspect of producing food products around the world.
Common pathogens associated with food production are campylobacter, listeria and salmonella. Pacific Vet Group USA is currently developing a product that will drastically reduce salmonella in the chicken crop by changing the current mode of processing chickens. The product will be administered to chickens at feed withdrawal and will reduce the potential for salmonella contamination.
For companies looking to improve food safety, like Pacific Vet Group USA, economic benefits are available because foodborne illnesses tied to processing facilities, farms, or even restaurants have been known to put them out of business.
At D.L. Newslow & Associates in Orlando, we understand the importance of food safety and can cater food safety training programs to the specific needs of your business. We offer the industry’s best consulting and customized on-site food safety training. Give our Orlando office a call today at 407-290-2754.
According to a press release published on the Business Wire and endorsed by the Institute for Credentialing Excellence, advancement in food science and technology has dramatically changed the food chain system.
A statistic released by the United Nations claims that total food production in the United States alone went from 287 million metric tons in 1965 to more than 674 million metric tons in 2010. Typically, more food means more risk of food-borne illnesses, but the U.S. Center for Disease Control and Prevention estimates that 48 million people in America got sick in 2011 from food-borne illnesses, a significant decrease from the total of 78 million cases in 1999.
Are you finding that your food service business is afflicted with problems that do not necessarily have an identifiable cause? If so, implementing Root Cause Analysis (RCA) may help. RCA identifies the factors that resulted in the nature, the magnitude, the location, and the timing of harmful outcomes in the past in order to identify which behaviors, actions, inactions, or conditions must be changed in order to prevent recurrence of similar harmful outcomes. Root Cause Analysis also helps to attain better consequences.
In the food industry, there is a need for production-based RCA due to quality control and manufacturing. It is absolutely necessary for your company to incorporate RCA as a tool for continuous improvement if your goal is to always strive to be better and have the highest possible standards.
In order to perform a Root Cause Analysis, begin by defining the current problem. Gather data and evidence, creating a timeline of events that lead to the crisis. Identify the causes associated with each step in the sequence towards the defined problem or event and recognize potential root causes that may have led to the event. Distinguish solutions that are effective and prevent recurrence with reasonable certainty. Also, be certain to obtain a consensus agreement among your fellow employees. Lastly, implement these root cause corrections, and ensure the effectiveness of these solutions by observing the results.
Our trained experts at D.L. Newslow & Associates understand that the process of Root Cause Analysis can be difficult to implement. That’s why we offer training and consulting on RCA. If you are finding that your business is facing problems that you simply cannot deal with on your own, please contact our trained food industry experts at (407)290-2754 today.
Hazard Analysis and Critical Control Points (HACCP) is a systematic approach to food safety. HACCP is an industry-wide effort designed to improve food safety, especially in retail establishments. The HACCP system deals with a range of existing and potential biological (pathogens), chemical, and physical hazards.
Everyone – from the farmers to the food servers – is responsible for the safety of their food products. Taking a systems approach involves looking at each step of the food handling and preparation process. It is a preventive and proactive maintenance plan rather than a fix-it-when-it-breaks approach. It is essential to be proactive instead of reactive with food safety in order to reduce the chance of food-borne illnesses and protect the quality of food safety products.
The government is very serious about HACCP, and this has caused Americans to become increasingly concerned with food safety as well. Incidences of food-borne illnesses are receiving more and more attention as consumers are becoming more aware of new potentially dangerous food hazards.
The operating principles of the HACCP system can be applied to any food chain activities and to any size business. The seven HACCP principles are:
- Conduct a hazard analysis. Prepare a list of steps in the process where significant hazards occur and describe the preventive measures.
- Identify the Critical Control Points (CCP) in the process.
- Establish critical limits for preventive measures associated with each identified CCP.
- Establish CCP monitoring requirements. Establish procedures for using the results of monitoring to adjust the process and maintain control.
- Establish corrective action to be taken when monitoring indicates that there is a deviation from an established critical limit.
- Establish procedures to verify that the HACCP system is working correctly.
- Establish effective record-keeping procedures that document the HACCP system.
Maintaining proper food safety is essential for every company in the food industry. Companies maintain very strict food safety standards and regulations because if they do not, serious problems may occur.
Without proper regulations in the food manufacturing process, productivity losses and safety issues can occur. The goal is to make a company’s manufacturing process as safe as possible, while being as effective as possible. Productivity losses in the manufacturing plant can cost a business a fortune in lost revenue. However, medical expenses from employees or customers who encounter illness due to lack of food safety standards can be even more costly. Maintaining strict food safety standards upholds the reputation of your business in the eyes of your customers and helps prevent potential hazards from occurring.
At D.L. Newslow & Associates in Orlando, we understand the importance of food safety and can cater food safety training programs to the specific needs of your business. Our team represents over 200 years of experience in combined fields of quality, food safety and system development. Give our main office a call today at 407-290-0252.
At this time in our food chain, there are many reasons why a company may choose to develop, implement, and maintain a system compliant with one of the Global Food Safety Initiative approved, benchmarked approved food safety schemes. Of course, one of the most recent drivers is the pressure being applied by major customers. However, the decision to move forward must be a decision not only because customers or regulators are forcing or encouraging the move, but also because it makes good business sense for the organization. A well-defined, managed, and compliant system adds value and reduces overall costs for the organization.
Actual cost figures are tough to identify. It is difficult to measure the savings of something that did not happen? However, there are enough companies with recalls, incidents, and ruined reputations for management to fill in the blanks, understanding what could happen and might very well happen if the organization does not take control and focus on preventing issues rather than addressing issues after a crisis. In the past, we learned from our mistakes. In modern times, we cannot afford to learn from our mistakes; we must avoid these mistakes by being proactive. The structure and discipline provided by an effective food safety management system does not guarantee food safety, but it absolutely provides the foundation for a proactive process to ensure that many mistakes can be avoided and prevented.
This type of system requires a team effort that is not only supported by top management, but also empowers and trains all associates to understand and play a significant part in food safety every day. Food safety affects everyone; each person has a role no matter what his/her area of responsibility includes.
I thought I would share my new podcast interview with Joe Dagger from APRecs. You can access it via iTunes by clicking HERE. The name of the interview is Food Safety Management Programs and the last time I checked it was #2 in the list. Thanks for listing!
Until next time,
Although this is not really a newsflash since many in our industry have been waiting a long time for the date August 31, 2015. That is the date that FDA committed to release the final regulations of the Food Safety Modernization Act (FSMA). The FDA team spent an unprecedented amount of time researching and reviewing thousands of comments from all realms of the food industry. Even though they took the time to respond to every comment (see final document), FDA was still able to provide a written document by mid-September 2015. Thank you FDA!
This document is critical to the future of food safety and will change it forever. I just wish that my friend and mentor, Jon Porter, who was an important instructor and advocate of food safety was here to see this. He would be pleased with the progress to keep our food supply safe for consumers. As I work with my colleagues, reading and interpreting this document in preparation for our future workshops, consultations and audits, many questions have arisen. Since these questions have come from a variety of sources, we have decided to make our findings and summations available to everyone on our website. Please bookmark this portion of our website to stay up-to-date on the latest developments.
Please keep in mind that there are excellent sources of information available. Our main goal is to review all the regulations and make FSMA more “user friendly” for you to understand and implement. We welcome any additional comments or questions that you may have,please submit them HERE and we will be glad to assist you. Thank you again to each of our supporters and friends. We are all on this journey together! We look forward to being a part of your journey, by assisting you with your operations. On behalf of our entire team, we look forward to your comments, questions, and suggestions.
As of today, here are the top ten questions that we have received and investigated. This is just the beginning since we continue to receive new inquiries every day. We will continue to post on our website the answers to questions that we will continue to receive on this topic. Note: Even though the following questions are numbered, they are not in any order of urgency or concern.
Question 1: What exactly does HARPC mean and how does it fit with HACCP?
Answer 1: HARPC stands for Hazard Analysis and Risk-Based Preventive Controls. Going forward, the HACCP (Hazard Analysis Critical Control Points) Programs will either become part of the HARPC Program or the Food Safety Program. A HACCP Program focuses on controlling a hazard through a CCP or an OPRP (an Operational Prerequisite Program introduced in ISO 22000:2005). The previous sentence needs rewording. How about: Under the Preventive Control Program, preventive controls include either CCPs and/or other preventive controls. The final rule requires a written food safety plan that includes a hazard analysis and preventive controls. Over the years, many operations have felt that they did not need to do a Hazard Analysis if they did not have any CCPs. Such an operation is very likely controlling its hazards through Preventive Controls or as we know them PRPS.
At this time, it seems likely that the term “Food Safety Plan” may replace the HARPC term. However, the main point is to expand the CCP focus on HACCP Programs. Preventive controls relate to key prerequisite programs that most companies have already established. We have been communicating for years that a HACCP program cannot stand-alone. It must be built on a foundation of effective PRPs or it will probably fail.
Stay tuned for Part 2!