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earl

Earl Arnold, Subject Matter Expert, Food Defense, AIB International

Free Live Webinar Tomorrow!

Conducting a vulnerability assessment for intentional contamination

Taking place:
Friday, December 16, 2016 - 03.00 PM - 04.00 PM UK Time (10.00 AM Eastern US Start)

Presenter:
Earl Arnold, Subject Matter Expert, Food Defense, AIB International

Webinar Overview:
Do you know what risks and weaknesses lie beneath the surface at your food facility? This webinar will help you identify security hazards throughout your operation – from structural flaws to program limitations – so that you can assign physical and procedural security countermeasures to mitigate the risk. Learn about common vulnerabilities in food facilities and integrate risk management planning at all levels to safeguard your plant against threats of intentional contamination. After the webinar, you’ll know more about how to:

• Identify hazards
• Assess the risks
• Analyze risk control measures
• Make risk control decisions
• Implement controls to eliminate the risk
• Integrate risk management planning at all levels
• Routinely review vulnerabilities

Register for Free >>

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Last Week's Webinar Recording

Training for FSMA’s Food Safety Preventive Controls Compliance: Is it working?

Presentation Slides and video recording from last week's Food Safety Fridays webinar.

How effective is the training for FSMA’s Preventive Controls for Human Food training in motivating facilities to comply with the requirement for developing and implementing a Food Safety Plan? Based on Level II (follow up surveys with class participants) and Level III (follow up surveys with participants’ supervisors), the perceived effectiveness of the trainings presented for U.S. FDA’s Food Safety Modernization Act (FSMA) Preventive Controls for Human Food (PCHF) rule will be reviewed. Director of Training for California based SCS Global Services and a Lead Instructor for the PCHF, Margaret Kolk, will conduct surveys of course participants two months post training. Surveys will be sent to the supervisors of course participants three months post training. This webinar will present the results of these surveys for trainings beginning in January, 2016 and ending in July, 2016.

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New Member Introductions

New Member
Dear All, I would just like to introduce myself. I am Professor Shaun Dent I have worked in many different industries as a HSEQE Consultant. Food plays a major part in all of the industries I have worked over the past 35 years so I am looking forward to reading some of your articles and discussion.

Hello Everyone!
Hello Everyone! I am Priyadarshini Mudaliyar from Fine Organic Industries, India. Associated with Process Quality for last 9 Years. Glad to join this forum and looking forward to mountain of knowledge to be explored.

Thanks,
Priyadarshini M

Hello Everyone!
I am Yvette. I am working with an export food manufacturing company that already have markets in the US, Australia, Canada, Asia and Middle East. I am handling the Quality Assurance and Quality Control Department. Our company is FSSC 22000 certified.

Click here to say hello >>

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Topic of the Week

Formal Certification for a Food Safety Professional

Dear All, This would be my 2nd question on this forum. I am working in the seafood industry as a quality assurance officer (in middle east ) Even though I brushed with most of the standards like HACCP, ISO 22000, BRC, BAP I don't have a formal certification (training) on these. What would be the starting point? which certification should I take up first & from which certifying body would be good? I am willing to work hard so the more stringent the better .I heard ASQ is good but they only provide certification training in USA.

(PS: My goal is to be a part of a certification body in few years time).

Thank you in advance.

Regards

Read More >>

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Latest Topics from the Forums

Anyone have experience with an Anton Parr Alcolyzer?
Do anyone have experience with an Anton Parr Alcolyzer?

Quality metrics: KPIs
Fellow IFSQN colleagues, There are lots of articles and literature about quality metrics which can be measured in a food processing plant. Costs of quality, Overall Equipment Effectiveness (OEE), percentage of products in compliance, on time and complete shipments, customer complaints & new products introduction (NPI). Apart from costs of quality, we track and trend the rest of the metrics. Anybody here familiar with any other Quality or Food safety metrics which are being measured? How do you measure and report them?

Thinking about expanding our key performance indicators (KPIs) with a special focus on quality and food safety metrics.

Thank you.
Mambo

Maintaining Food Safety/Security During a Cyber Attack
Hello everyone! So...a few weeks ago our small company had an incident where our internal tracking software was hijacked and held ransom (ransomware) by a hacker. This of course was very bad, as we keep track of all of our production, shipping, receiving, and more through that system. It's since been fixed (thank goodness), but we realized we were totally unprepared for such an incident.

As a result, I've been asked to come up with a backup plan for when our tracking system shuts down or fails. I know, our company should have had this in place years ago, but I wasn't here at that time to say "hey, what if this happens?"

Basically, I need to come up with a paper way to track our inventory and shipping, along with a procedure to follow in case it ever happens again. I'd use the check sheets we had from years and years ago before the company switched to electronic tracking, but they've been lost over time, so I have to come up with everything from scratch. Re-invent the wheel, so to speak.

Has anyone addressed a cyber attack in their company's emergency action or business continuity plan? Do you have any tips on how to write such a procedure? Or any tips on how to break down an entire computer trace system into a paper version?

Thank you in advance!

Swab vs Sponge for environmental sampling
Hello, If I use sponge instead of swab for environmental sampling, would it change expected range of result for microbial count.

Thanks
KT

Sanitizing fresh fruits and vegetables
Hello members! Just would like to know -- can anyone recommend a good, organic fruit and vegetable sanitizer? Is white vinegar (commercial) an effective sanitizer? What about baking soda?

angie0612

Wearing paper caps instead of hairnets
Good day, I am working in a catering company where we are using hair net for preventing possible contamination. We had a stock of paper caps from long time and operation is requesting to use it in catering in winter season. I would like to know the history behind shifting from paper caps to hair nets.

Regards
Sawmya

Query regarding withdrawal/recall for iso 10393:2013
Dear all, There is iso for withdrawal and recall it is ISO 10393:2013. But it is hard to build up record. Can you tell me which record that we have to keep ?

BRC Audit Storage and Distribution
Hi all, I need clear examples of Measurable quality objectives for a Cold Room that stock Frozen Fish.
Thank you

Internal verification, internal calibration and external calibration
Hi there, I am confused with the terms internal verification, internal calibration and external calibration? What is the difference? Is internal verification same with internal calibration?

Thanks .

Soy Lecithin Hazard Analysis
We are a dry manufacturing facility with Soy Lecithin as the only allergen that we declare. We adhere to the labeling and storage requirements. What I have struggled with is there is no test capable of detecting protein in soy lecithin.
If we swab the ingredients directly it will not show soy proteins. I have an expert opinion from University of Nebraska stating that they don’t believe special cleaning procedures are needed for shared equipment with ingredients that do contain soy lecithin and those that don’t.

How would I implement a comprehensive thought out Allergen program in this scenario. I believe a hazard analysis would drive the requirements for internal controls. But how do i do this if Soy is a known allergen but likelihood of the hazard is low but severity (at least for soy is high)?

Soy lecithin seems to be in the grey area for the FDA and creates ambiguity.

I am uncertain how to validate that operators running one line with Soy Lecithin at the same time they operate another line without soy Lecithin, shared draining vacuum equipment, and utensils dont need to be controlled for.

Water System Gauge Calibration
Hello! Does anyone have any thoughts on calibration of the gauges in a DI/RO water system for Dietary Supplement manufacturing? I do not know of a requirement for it, but I have seen it done, and not done. Is it industry standard?

Thanks!

Past recall explanations/walkthroughs/breakdowns
Hello all, I am looking through our internal audits and am at the section (I am FSSC 22000 certified) on hazard identification. It reads as:
7.4.2.1 All food safety hazard that are reasonably expected to occur in relation to the type of product, type of process and actual processing facilities shall be identified and recorded. The identification shall be based on

a) The preliminary information and data collected according to 7.3,
b) Experience,
c) External information including, to the extent possible, epidemiological and other historical data, and
d) Information from the food chain on food safety hazards that may be of relevance for the safety of the end products, intermediate products and the food at consumption

Do you have to have procedure for every topic in Module 11?
Hello! I am new to the food safety world and trying to develop / implement Level 2 in our facility, which has presented me with several questions that I would LOVE to get some clarification on.

We produce dry drink blends, therefore none of our incoming materials or finished product requires refrigeration or temperature control. Am I required to write procedures for PRP's that we don't use (ex. refrigeration) or do I have to write out that our products don't require it, or can I just not address it at all and skip it? Also, can I combine 11.6.6, 11.6.7, and 11.6.9 and list it all under 11.6.6 and have the loading/unloading sheet listed under 11.6.6? or do I need to make two trailer inspection sheets specifically for 11.6.7 & 11.6.9?

I really hope my question's aren't confusing, I just really need help.

2.4.2 Food Safety Fundamentals vs Pre-requisite program vs GMP
Hello everyone, I'm trying to figure out the difference between Food safety fundamentals (2.4.2.2) , Pre-requisite programs (2.4.2.3) and GMP. If we cover all the items in Module 13 (we are a packaging supplier) would that be enough to satisfy 2.4.2?

Thanks!

Cris

SQF Traceability
We are a coffee roasting and beverage distribution company. We track all our coffee by lot number, packaging, flavor additives etc.. Everything WE produce I can trace back and forward. My question- we have several pass through items. Syrups mainly. We do nothing with these other than pull a bottle out of a case and ship it to a customer. The seal is never broke and we do not add it to anything we manufacture. A few of our suppliers for these syrups do not have lot numbers on their product. Do I need to push back and get lot numbers or from a distribution standpoint am I safe just knowing what flavors went where? SQF Level 3 is what we are going for. This is the last issue I am dealing with. Any thoughts would be appreciated!

SQF and Repositrak
Hi All, Any comment/experience about SQF in Repositrak?

Thank you

Jam

Appropriate Code for non contact carton manufacturer
We are a paperboard carton manufacturer for non contact food items. Although we are non contact, and only <5% of our product goes to food manufacturers, we chose SQF level 1 for certification. Last year's audit produced a non-conformance for inadequate training on the SQF code. All SQF training classes seem to be level 2-3 with a HACCP plan that I don't feel applies to us. Does anyone have any thoughts as to proper training for our situation? Would training for PCQI (preventive control qualified individual) suffice? I did have HACCP training 3 years ago but without the need for a HACCP plan our third party auditor says that training is not sufficient. I have asked our third party auditor for clarification 3 times but they have not given me any response (but of course are demanding we schedule our annual audit). Anyone else in this situation or also a manufacturer of non contact food cartons? Possibly a more appropriate code to follow? Thanks in advance for any help on this matter.

Confirmation of attendance for training
I would be interested to see how others manage the requirement regarding confirmation of attendance for internal SOP refresher training sessions please. Our sessions are typically short and specific to people that need to be reminded about procedural steps.
BRC (issue 7) 7.1.5
Records of all training shall be available. This shall include as a minimum:
• the name of the trainee and confirmation of attendance
• the date and duration of the training
• the title or course contents, as appropriate
• the training provider.
Where training is undertaken by agencies on behalf of the company, records of the training shall be available.

Knife control policy - template
Hello everybody, I am new to this forum & new to the firm i joined due to some issues (Manager passed away) currently I am the in charge of quality in my business until some replacement comes on board. Can anyone please show me a template of knife control policy. I will be really grateful.

Thank you in advance.

Regards

Chicken processing best practice
Hello, Can anyone please working in chicken processing supporting me in some processing inquires, like as drum breader block and how to avoid ,the best way to process breaded breast strips (best line setting for every product)

Thanks in advance

CCP decision tree problem
Dear everybody, I am confused of answering CCP decision tree (follow HACCP Codex Alimentarius).

Beginning with Q1 : Yes
Then Q2 : No
Q3: Yes
And Q4 :No
Finally, that processing step turn to be CCP following decision tree.
The thing that make me confused is that the content of Q2
Q2 = Does this step eliminate or reduce the likely occurence of the hazard? The answer is "No". How could this step be CCP if this step can’t eliminate or reduce the likely occurence of the hazard?

The decision tree result in CCP but CCP cannot reduce or eliminate hazard.
So in this case, in Q4 if there is no subsequent step eliminate or reduce hazard. Next step could back to Q1a (or Q2b in other CCP decision tree version) which is to modify the step or process or product. If we don’t re - modify, the final product would be unsafe.

I am looking forward to hearing from you,

Re-Sanitizing of Dairy Processing Equipment After So Many Hours
Morning, So many different answers & opinions about after how long, how many hours must past before the equipment needs to be re-cleaned and sanitized in a dairy processing facility.( ice cream) My question is this true? Do we have to re-clean & re-sanitize after a certain amount of time when the equipment is not being used? What they do here is; a final deep down clean on Friday, off Saturday then come back Sunday night to re-clean & sanitize. I asked why they re-clean and re sanitize and the reply, that's what they always do. Is there an ordinance / clause stating this? or is this at the companies will? Any direction would be appreciated.

Gap analysis between FSSC 22000 V3 and FSSC 3.1 (PAS 222) +GMP
Hi all, We are already having FSSC 22000 V3 in place. We are planning to extend our scope to 3.1 which includes PAS 222 and GMP requirement. Kindly help me with a summary to identify the gap between the mentioned standard requirements.

Thanks in advance,
Priyadarshini M

Metal Detector Validation, looking for a challenge procedure
Hello all, Does anyone have a template and procedure that can be used for metal detector challenge?

Any help or guidance would be appreciated.

Thank you very much, in advance.

b

Raw material Specifications
Hi all, Hope you all are fine and in good spirits! My question is "A contract manufacturer/own manufacturer of foods and supplements, are they required to have their own raw material specification sheets for all the ingredients that come into their warehouse or they use?"

Additional information: Manufacturer qualifies most of their suppliers. All their suppliers are required to provide spec sheets and CoAs and any other documentation (GM statements, country of origin and other certifications if any).

Thank you,
AK

Purchasing Alcohol purchased from LCBO (Canada) in glass bottle for us
Hello all, I need your opinion on how to bring in Alcohol from a non-approved supplier.

In Canada, alcohol is a controlled product.
You can only purchase it at the LCBO (in Ontario Canada).
It also comes sold in a glass bottle.
We have a no glass policy in effect.
We are receiving the alcohol through the front offices and storing it in a locked storage room in the front offices.
We are then transferring pre-determined amounts into a plastic container with cap that is being brought into production from the front offices for production to use.

Any information or input you can offer in how we can implement this procedure successfully would be greatly appreciated.

Thank you.

Purchasing raw materials from a grocery store in a bind - problem?
Hi again all. I have developed a relatively extensive Approved Supplier and Supplier Validation program and all of our suppliers adhere to our written requirements. However, there are some days where our suppliers cannot provide us with product in a timely fashion, and as a small company we have orders to fulfill, at which point the owners simply purchase small quantities of material from a grocery store for use in the product.

I have expressed my concern to them for this as I don't believe it should be allowed, considering the grocer isn't an approved supplier, nor have they provided us with any type of quality documentation for the product being purchased.

Will cause any issues if noticed during an audit? What are everyone's thoughts on this - allowed or disallowed?

HACCP plan for pulses, cereals and spices
Can someone provide me with a haccp plan for pulses, cereals and spices.

What is the difference between clause 7.3.3.1 and 7.3.3.2?
Dear all, what is the difference between clause 7.3.3.1 Raw material ingrt and product contact material vs 7.3.3.2 characteristics of end product.

thanking u

Achieved Halal Certification, thanks for your support!
Hello All, We have already received our Halal site and product certification. Thank you all for the much needed informations, pointers and helps.

regards,
Redfox

Crustacian vs Fish- should they be segregated?
HI, I am new to the seafood processing industry and is trying to wrap my head around when kind of allergen control is necessary if a facility processes both fish and crustaceans. I looked at major allergens listed under US and Canada and can see that Crustaceans and fish are usually in separate categories- what I wasn't sure is if the industry typically keep crustacean processing separate from fish processing (and vise versa) to mitigate allergen cross-contamination?

I am assuming ingredient storage/final product storage between these 2 different types has to be segregated, as well as there need to be an adequate allergen cleanout before changeovers if a facility processes crustaceans and fish in the same processing line? I don't think having a precautionary statement to mention may-contain-fish/crustacean will provide an exemption for not having a system to control the 2 groups of allergens separately....?

Any pointers/thoughts from experts from the seafood industry is greatly appreciated!

Cheers and Thank You!
Just passed our level 2 certification audit. Thank you for all the excellent knowledge this site provides. IFSQN was definitely a useful tool that helped us achieve our goal.

South Jersey Food Facility - Sanitation Supervisor - Overnight
Posting a job opening which I am trying to fill with a highly experienced, trustworthy, and independent supervisor. Experience in sanitation is a must. Our production ends daily between 6pm and 10pm. The overnight sanitation supervisor will train and oversee a crew of 3-5 hourly sanitation employees, who are responsible for cleaning and sanitizing all equipment and surfaces.

Bilingual competency (English and Spanish) is highly sought after, as well as the ability to work in a cold environment. You will be working with, and directly supervised by, our operations coordinator and food safety coordinator, and will help to augment our current SSOPs and training curricula. Forklift license/experience is a major plus.

Please reply to my post if you or someone you know may be interested in this position! We are located approximately halfway between Philadelphia and Atlantic City.

Is Titanium filter recommended after ozonation in bottled water?
Hello, In bottled water, is titanium filter (less than 1 micron) recommended to use after ozonation? what are the advantages and disadvantages?

Product water parameters are as follows

TDS : 80 - 100 ppm
pH : 6.7 - 8.0
Hardness: less than 30.
Ozone concentration : 0.25 to 0.45 ppm (for disinfection)
We have 300 mesh strainer immediately before filler.

Kindly share if any supporting documents available.

HACCP process flow chart
Hello, I'm new to this HACCP process flow chart and integrating it into Food Safety Risk Analysis matrix and worksheet. There is a plan in process but how do you incorporate a new machine into the plan and understand it.

Percent Alcohol in Finished Food Products
Hey guys! We make jams, jellies, preserves, sauces, marinades, etc. at my food manufacturing facility. We have a few products that contain wine/beer/liquor as an ingredient. When one of our products contains any type of alcoholic beverage as an ingredient, we send samples out to a lab to be tested for % alcohol in the finished product.

My question is - Is there a maximum % of alcohol in a product in which you have to label the % of alcohol on the product label? I have searched the FDA website and cannot find any information on this. I know that if a product contains less than 7% alcohol, it is regulated by the FDA, but that is all I can really find.

Thanks!

Why should corners be avoided in food manufacturing
Hallo IFSQN members, I have a pretty simple question. Why should you prevent corners (example: square tank) in your design for food manufacturing for a viscous food paste product (like peanut butter and choco paste).

I've found some minor information that round (cylindrical) tank is better to use because it's easier to clean and sanitize but I've not found better and more accurate information (the science behind it). And if you have corners in your design, is there a critical limit for this until is not consider safe? Is this something that can be calculated with an equation?

Thank you for your time reading my Topic.

Greetings,

VACCP for slaughter/cutting meat process
Hi, Help Required.......VACCP for a red meat slaughter and cutting plant..... what type of things will need to go on this for a supply point of view? we have live cows coming in and packed going out?

Thanks

Great integrated training record management
I can't be the only person with this problem. We have a training system which is excessively paper based. We sign people off against everything from power point presentations, tests, documents etc. Some of it is only reading, some requires some kind of competency assessment etc but you know the deal. The Auditor asks for a training file and you're sweating thinking "is everything up to date?"

I've used QPulse many years back but their training module wasn't as fully integrated as I'd like. What I want is a fully integrated training package which will do all this for the team. So will record the training records electronically, can have some forms of competency assessments built in, send out reminders when training or reassessment is due. Automatically set up for retraining when a standard changes. Have some elearning built in and come out with a matrix so I can see at a glance who is and isn't trained.

Does it exist? Is there anyone out there making something like this?

Timing of Annual Review
A warning! We made a mistake last year and were late with our management review (trying to get everyone in the room at the same time). It was less than 2 weeks, we were honest and while it wasn't perfect, that was all we could do. We got a minor from it. Apparently BRC global standards have clarified that any lapse over 7 days is a minor and if it's >365 days at time of audit and the next one hasn't been done, it's a major.

Word to the wise!

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Edition 271, December 15, 2016

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