Food Safety Talk Newsletter

Issue 205, July 15, 2015

Hello and welcome to the latest update from the International Food Safety & Quality Network. In today's newsletter we have the latest from the Food Safety Friday’s webinar program, all the new discussion topics from the forums and the member poll on GFSI Certification.

Best Wishes,
Michelle Timperley
The International Food Safety & Quality Network

The IFSQN Sponsors

Last Week's Food Safety Fridays Webinar Recording

Video Recording and Presentation Slides from last Fridays Webinar.

Please note we are taking a break from the Food Safety Fridays webinars for the summer and will be back August 14. Please check the schedule and in the meantime you can watch the recordings.

New Topics from the Forums

What are CCPs in deboning of chicken?
What are CCPs in deboning of chicken? Is raw material temp control CCP? Please let me know you thoughts.

2.5.1 Responsibility, Frequency, and Methods
Hey guys! I'm slowly and painstakingly making my way through Module 2 of the SQF Code and I'm not quite sure how to proceed at this point. The guidance document for section 2.5.1 Responsibility, Frequency, and Methods states that a validation and verification procedure should be prepared for an audit but I'm not sure how to go about writing that procedure.

We are a small snack manufacturing company with two critical control points - metal detection & nut cooking temperature and both of these CCPs are heavily validated (metal detection functionality tests every two hours and thermometer readings of nut cooking temperatures every hour). All validation activities are documented and the documents are then submitted to me, the QA Manager. I verify that the temperatures met the critical limit and that no FAILED tests were run when testing the metal detector. In addition to CCP validation, myself or our QA technician will perform bi-monthly inspections of the plant and surrounding grounds to ensure compliance to all GMPs. There are several other validation and verification activities that take place on a frequent basis also.

Am I supposed to generate a procedure unique to each verification and validation activity or can I make a general procedure that umbrellas over all verification and validation activities?

Any help would be appreciated!

Raw Material Risk Assessment as it relates to GFSI
Hi All! First off, great forum; I've really enjoyed lurking here & there! Quick background on us. We're a smallish custom dry blend plant (SQF 2) with literally hundreds of ingredients.

When it comes to Raw Material Risk Assessment.

We're getting more & more pushback upon documentation requests (HACCP flow charts, etc) from suppliers esentially saying you have our GFSI certificate, what more do you need?

I guess my question is: is a GFSI cert enough to let the ingredient 'pass go' so to speak?

Here I sit trying to piece together the HACCP program of these suppliers on my little computer in my corner of the world. . how can my assessment compare to a GFSI auditor's assessment on-site?

Can ingredients be added to our HACCP register & thus purchased & used based on the merit of their cert?

I do hope that all made sense.

I'd appreciate anyone's opinion--thanks much!

Joan

Organic and NON-GMO in Food Quality Plans
I have a question, we have been certified SQF at Level 3 for about 6 years, one of our plants has been Organic for about 4 years and another one is just picking up Organic in addition now all three of my plants will be going NON-GMO.

The guidance document under 2.8.1 says Organic and Non-GMO should have separate Food Quality Plans, current state we have never had organic in our Food Quality Plan. Now I have one plant saying it does not need to be in there it never has been and another one feels we should add to our current plant not create a separate plan.

What is everyone's thoughts on this?

Thanks in Advance.

Testing regarding flexible packaging and blow moulding
Dear friends, I want to know what types of testings are involved in blow moulding for making of pet bottles .what are the names of equipment used for testing and what type of testing we should perform ?

BRC Standard Management Review Minutes Sample
Good day Family, I am new in BRC so is there anyone who can assist with management review minutes sample.

Thanks in advance

Residual Bacteria, Coliform, and Mold for Dairy Food Packaging
Hello, I'm looking for guidance and regulation limits for Bacteria, Coliform, and Mold for Dairy Food Packaging. We are currently following the guidelines for the FDA's Grade A Pasteurized Milk Ordinance. This ordinance is specific for bacteria and coliform, but not mold for food packaging. I cannot find limits and test methods in any CFIA or Health Canada documentation for dairy food packaging. Anyone have information they could share or direct me to? Thanks in advance!

Outer Case Labels and the Label/Packaging Register
We are in the midst of trying to perfect our label/packaging register and we've audited all of our labels and packaging, with the exception of our outer case labels. I feel strongly that these labels need to be verified and approved, but I'm getting push back about whether or not it is required per the SQF code to include these labels in the register. According to section 2.3.2.7 A register of raw and packaging material specifications and labels shall be maintained and kept current.

One caveat to this is that we print all of our own outer case labels so it would seem that in order to implement more controls with regards to these labels we would want them all "Approved" and documented within our already existing database and hold them to the same standards as we do our other packaging and labels.

If anyone could supply me with some additional support regarding this I'd greatly appreciate it. I may be incorrect and more than happy to consider the alternative if someone can give me compelling reason why my reasoning is not accurate. Either way, just looking for some feedback on this topic.

Thank you greatly!

Outsourcing a Sanitation Crew
Hi Everyone, I've been having a horrible time finding a sanitation company who would be able to clean our production facility in New England. Does anyone have any suggestions with companies that would be able to do this in the RI, CT and MA areas?

Thank you!
Weebus

Country of origin labeling
Hi, We have always declared the COO for Canola oil on our labels. I have a customer who does not want this information on their label. I have tried looking around for literature to see if it is mandatory to declare the Country of Origin for Canola Oil in the USA but cannot find any information.

Does anyone have the information? Please assist.

Allergen Registry (SQF)
The SQF code requires a manufacturer to have a registry of all allergens applicable in the country of manufacture and country(ies) of destination.

I am confused by what SQF considers to be the country of destination. Is the customer we ship product directly to consider the country of destination, or the consumer who receives the product from our direct customer?

We manufacture product in the US and bulk pack it for customers located in Canada. These customers then re-pack the product into individual units and then sell the product to consumers located all over the world.

So.. If we manufacture product in the US and then ship it to our customers warehouse in Canada we would have to control allergens regulated both by the FDA and the CFIA. The customer may then sell the product in retail stores located throughout the US, Canada and the European Union.

In this scenario would our Allergen Control program have to account for allergens that are regulated in the EU?

Our customers have not specified what countries they plan to sell the product in and do not specify what allergens they require us to declare.

If we want to be certified FSSC22000 must we be certified ISO9001?
Hello, if we want to be certified fssc22000 must we be certified iso9001 in first?

Best regards

Temporary Auditor Wanted, Derbyshire, UK
Hi, just wondered if anyone living near Ashbourne, Derbyshire who is a qualified auditor might be interested in auditing a small company for a month to cover all the requirements of the current Packaging Standard and produce written reports? Although we have trained auditors it would be good to get someone who has no knowledge or preconceptions to visit the processes & systems.

What parameters to check for dried beans in brine?
Dear friends, Greetings to all. I am Mohammed salim, was basically from the dairy and chocolate food industry. Recently I moved to canned food industry, which is quite fresh industry for me. So I will we very grateful if some someone from the same field advice me on following my queries. Basically we are filling different dried beans in different brine. Beans are generally fava beans, broad beans, red kidney, navy beans, split fava beans and some peas, chick peas, sweet corns. Brines are generally, according to different industry, we are mixing salt, sugar, citric acid, tomato paste, EDTA, and spices like chilli, cumin, garlic, onion paste, modified starch etc.

Now my queries are:

1) what are the quality parameters we need to check for the brine analysis
2) what are the devices I need to set up for those parameters.
3) since our daily beans feeding daily is very huge for eg;- 720000 Kg per day, anyone knows about the best laboratory devices to check the quality of dried raw beans?

I look forward for your valuable comments

Thanks and regards,
Mohammed salim

Personal Hygiene, Kitchen Hygiene, GMP Posters/Displays
Dear All, Can anyone please support me for Personal Hygiene, Kitchen Hygiene, GMP posters for Centralised kitchen/catering industry. Please send me if you have any. plzz..

Thank you,
Regards,

Food and Veterinary Office criticizes HACCP implementation
Dear All, Some information to read. All member States of the European Union recognize the importance of HACCP-systems. According to a report by Food and Veterinary Office it fails sometimes on the implementation. FINAL OVERVIEW REPORT REPORT ON THE STATE OF IMPLEMENTATION OF HACCP IN THE EU AND AREAS FOR IMPROVEMENT

Supplier Approval Program
I'm trying to create a more robust supplier approval program and need some guidance. We've been a food manufacturer for over 20 years and have 500+ ingredient suppliers. Our ingredient types range from IQF vegetables & proteins, to cheeses & other dairy products, to dry goods.

We are in the process of requesting third party audits, certificates, and corrective actions from all of them. This task is monumental espescially with the lofty goal of actually trying to read everything we get back. I know the quick glance and a gut feeling are not going to cut it with FSMA. Some aren't willing to share their audit and just send the certificate. Do I accept this? What are my options?

My main question is what are people using for accept/reject criteria when approving suppliers?

Thanks in advance!

Allergen Labeling Concerns
Greetings All, I am looking for some guidance concerning receiving a non-allergen product from a allergen producing co-packer for inclusion in a kit we are producing for a customer. The product we would be receiving for the kit is a flavored cranberry packed in a machine sealed film pouch. The "master cartons" of packaged film sealed pouches have a label from the manufacturer stating the following: *This product is manufactured in a facility that processes peanuts, tree nuts, soybean, milk, egg, wheat (gluten), and fish products". This statement does not however appear on the individual pouches we will be including in the assembled kit.

Do we need to include any allergen warning statements on the assembled kits that contain this product?

Our facility does produce, process or store any of the 8 major allergens.

In summary. The product packaged for us is not an allergen, but is packed in a facility that does produce allergens and sent to us in a master carton that states "allergens are produced in their facility". What is the bottom line for us as far as the need for "any" labeling requirements?

Thanks in advance!

Complaints CPMU
Hi All, Looking for general thoughts on targets for CPMU. I work in whisky and rum bottling and we set a target of 9.5 CPMU for end June 2015 but we failed, we achieved just over 10 CPMU. What does everyone else set their target at and do you know of a food manufacturing best target. Some research carried out by someone else I work with suggested that 7 is a gold standard achievement.

All thoughts, suggestions etc will be greatly appreciated.

Many thanks

Data Sheets, COAs, etc
Hi guys, You've been extremely helpful thus far, and I just wanted to extend a question in hopes someone here will be able to assist me.

I guess I'm in an odd position. I'm great at technical, IT, and related problems. I ended up partially involved in the food safety side due to helping our HACCP officer with document generation. He isn't great on the PC side, so I did proof reading and generated some of the more interesting flow charts, etc.

Now, as a result of this I'm often asked to make COAs, data sheets, and product specifications. My only problem is I'm not entirely sure how these documents differ from one another? If a customer requests a COA, how is that COA meant to differ from a product spec? Can anyone enlighten me? I've asked the HACCP officer, but he actually isn't quite sure himself.

I've attached a "template" of what I've been using as our product specification sheet. We don't really have a lab to run any kind of tests. I often see some COAs describe moisture tests, etc. Would we be required to get third party to test this, or possibly even buy our own equipment? I've currently just shown that we do some visual inspection. A sample of all produced product is also tested internally in our own test bakery (we produce premix), so perhaps I could list feedback from the test bakery on our COA?

I'm also curious regarding ingredient declaration. I'm putting this on our product labels and product specs. I'm trying to improve how we do this, mainly, I thought one method might be to include the E numbers. I.e. Calcium Carbonate (E300) instead of simply putting Calcium Carbonate. Does this ACTUALLY provide any benefit or am I wasting my time going through the extra effort?

Lastly, regarding declaring ingredients I often run into a problem of my bosses wanting to maintain a blend of openness and confidentiality. Rather than declare the exact enzymes used, for instance, we will simply state "Enzymes". Is this acceptable? If so, how do you determine which ingredients you HAVE to declare and which can be kept "secret" under a general banner like "Flavourants" or "Enzymes"? Is there a set rule?

(Sorry for the stupid questions, guys. I sadly have no background in food technology and I would just like to know I'm somewhere on the right track with these things)

BRC Production Risk Zones
Hi everyone; I am attaching a copy of my draft for production zone, but I'm not sure if I'm on the right track or not, therefore would like to seek anyone's kind assistance if they could this draft and give comments. ....this my first time doing this, and i'm totally confused with the justification of the designated identified zones. Please note that I am using the guide for zoning in BRC std. I would really appreciate any comments given.

Thank you in advance.

Alternative 'non-certified' supplier supplying to customer
Hi all, It has come to our attention that some of our customer always quoted we are only main supplier to them when local authorities come to their premis inspection, this is because we r ISO certified company. But the fact is customers do buy product from other manufacturer which is no ISO system in place. May i ask any of ur encounter such situation and how to tackle it? Thanks in advance

MSDS for food ingredients
Hi there, We are an edible oil manufacturing company. Certified SQF level 2. We pack oils and do blends of oils. We don't add any additives or flavors or preservatives to our oils. Some of our customers ask for MSDS for the finished products and I'm not sure if it's required or not. Can someone help me with this please?

Thank you

Nutrition Labeling of Sample Products
My marketing department had sample bags printed for distribution to consumers. These bags are marked "not for resale" and will be given away for free. 21CFR109 begins with "products intended for human consumption and offered for sale." The ingredient list (with allergens) is on the packaging but does anyone know if we need the nutrition panel as well?

Aluminum Flakes from Bakery Racks & Pans
Hi everyone, I am wondering if anyone has any experience with aluminum flakes from aluminum bakery racks and pans. We make RTE snack products and our racks do NOT go in an oven but our pans do (for the sole purpose of toasting ingredients for aesthetic reasons rather than food safety reasons). We have SOPs in place so the production and packaging teams know to load a rack from the top down and to unload a rack from the top up. However, we are still experiencing very small flakes of the aluminum falling onto the top of our product.

This just came up yesterday and I have not had a chance to go on the floor and do an audit; I had suggested there may be team members not loading/unloading racks properly but our Ops Mgr expressed confidence this was not the case. I do plan to do a walk around over the next couple of days but would appreciate your input in the mean time.

We clean all of our racks at least once per week and our pans more often (neither are food contact surfaces as we use parchment pan liners every time we use the pans). The flakes are too small to be considered a choking hazard but we've found them in-house prior to packaging and shipment and have also heard from 2 customers over the past month that they've found them. We have been able to address the customer issues with success but this is still a concern for us.

In trying to find a solution, we found shelf covers online but they are expensive and seem like they would create a larger hazard from a standing water/mold/etc. point of view.

Please, does anyone have any experience with dealing with this? If so, how did you solve your problem? I let Management know that it might come down to the man hours spent to clean all of the racks multiple times per week which wasn't a very popular idea but, hey, I didn't take this job to make friends, right?

Thanks in advance!

~Emily~

Process Flow Diagram and HACCP Analysis for Stone Fruit?
Good day...I'm looking for a process flow diagram and HACCP Analysis on stone fruit (peaches, nectarines, plums, etc.) I would like to use as reference as to the company I'm currently with thinks a HACCP team is solely the responsibility of food safety manager. Lack of management commitment seems to be common in the fruit industry.

Thanks in advance! :)

Corrective Actions and Preventive Measures, What's the Difference?
Hello all, I'm in need for you to share all your knowledge. I'm having a very hard time training some employees and management personnel on the difference between a Corrective Action and a Preventive measure for a HACCP Deviation. They don't seem to understand my explanation. I would really appreciate any ideas.

This is how my form describes it.

Deviation/What Happened?: Describe the cause of the deviation and how it was eliminated)

Immediate Corrective Action: (Describe what was done to correct the issue and if the CCP is back under control and Sanitary conditions restored)

Product Disposition: (Describe what happened to the affected Product)
Preventive Measures: (Describe what are you going to do to prevent a reoccurrence)

Internal Audit program Template ISO22000
I am Ehiboime Victor QA Manager/Food Safety Team leader of a company that manufactures Beverage Aluminium CANs in West Africa. I had just completed a an audit had a non-conformance on internal audit schedule/Program. Somebody should help me out with a sample to enable me close this non-conformity.

Swab testing standards & Air sampling standards for food industry
Hi, Please share standard requirement for below swab analysis and air quality monitoring using air sampler.

1) Hand swab for personal hygiene
2) Equipment swab for sanitation measure
3) Cloth swab

Regards,
Bhavin

The need for HACCP to counter food safety challenges
It's every ones fundamental right to expect the food they eat at any food vending outlet to be safe and suitable for human consumption at all times. This is the principal obligation for all food producers and retailers to ensure that the above right is not only observed but consistently monitored. with haccp being a system where analysis is done throughout the whole process with proper documentation in place, this has made my tasks SMART.

Kind regards,
James Wasike

Beef Jerky Marinade
So I have sliced beef, made marinade, and placed it in a large bowl in the fridge. The marinade includes soy sauce, worcestershire sauce, onion and garlic powder, brown sugar, and other spices. Is it safe to keep it in the fridge for a day and a half (36 hours)? Please state if you've had experience. Thanks!! :)

Reference-Compliance Matrix BRC7
All BRC7 requirements in one Excel file for compliance or reference purposes.

Have fun!
Steffie

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