Food Safety Talk Newsletter Issue 182, January 28, 2015 Hello and welcome to this week's newsletter. Today's edition includes Tony C's latest blog
Food Safety Talk Newsletter
Issue 182, January 28, 2015
Hello and welcome to this week's newsletter.
Today's edition includes Tony C's latest blog on validation and verification, details of the next Food Safety Fridays webinar, our latest member poll and lot's of interesting discussion topics from the forums.
Best Wishes,
Michelle Timperley
The International Food Safety & Quality Network
The IFSQN Sponsors
Food Safety Fridays Webinar
Printing, Packaging, and Protecting Food
Speaker: Thomas J. Dunn, Managing Director, Flexpacknology llc
This Live Webinar is free-to-attend and takes place:
February 06 2015 - 03:00 PM - 04:00 PM GMT (Starts 10.00 a.m. EST)
Reacting to the market recall of millions of Euros worth of packaged goods, governments and industry in Europe have established frameworks for good manufacturing practices and chemical limitations that apply to formulating and printing inks used for food contact materials. These proactive efforts have stopped what seemed to be an unmitigated risk to packaged foods. This webinar reviews expectations these frameworks have for food packaging manufacturers and the procedures manufacturers should follow to assure food safety.
If you have a question about the subject please post it here and we'll try to get it answered for you during the webinar session.
This subject of validation and verification is right up there in the list of food safety areas which cause the most confusion among members and the variety and often conflicting definitions and requirements in food safety certification standards as to what should be validated, what should be verified and what should be done to meet the criteria for validation and verification only adds to the confusion.
In this blog post I review what the main texts and food safety certification standards say about the subject of validation and verification comparing and contrasting their ideas whilst hopefully removing some of the confusion.
What will be the biggest food safety challenge in 2015?
Unsafe food is linked to the deaths of an estimated 2 million people annually and new threats to food safety are constantly emerging. Continual improvement in the food supply chain is therefore mandatory. So what do you think will be our biggest challenge this year?
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Maintenance toolboxes in workshops
20 January 2015
Hi, Yesterday I performed an audit of maintenance chemicals in our maintenance workshop to ensure all MSDS sheets were available in advance of our SQF audit next week. The workshop is in the corner of the dry/ambient warehouse which is sectioned off by metal caging where the maintenance guys perform 'dirty' work such as welding and grinding.
I could not get hold of a maintenance guy so myself and a QA did a quick inventory of the chemicals to compare against our MSDS book. Whilst performing the inventory we noticed that there were a number of oils/lubricants/glues in the numerous tool boxes in the area - we then went through all the toolboxes and noted down any chemicals present which we did not have safety data sheets for so that we could then obtain the sheets for the file. We also found numerous personal items in the toolboxes such as personal pain medication, boxes of snuff and cigarettes which we confiscated to the QA office.
The workshop was open when I went to perform the audit - it is required to be locked when not in use - and all the tools and tool boxes were left open and unattended.
The maintenance guys have now thrown absolute fits as the toolboxes are apparently 'personal' equipment - they are owned directly by each maintenance person and not by the company - and as such they are claiming that QA have no right to go through the toolboxes or to remove personal items from them. It also transpires that these tool boxes regularly travel between the workshop and the homes of the maintenance guys for personal work.
I did not know that these were personally owned and I have apologised that I did not have the owners present at the time of inspection -however all the toolboxes were unattended at the time and not locked to prevent 'unauthorised' access. I also stated that the personal items are not permitted to be stored in the toolboxes as the maintenance cage is still under GMP rules as is the warehouse, and that all chemicals must be registered to ensure safety data sheets are obtained which is a requirement of SQF and OSHA. The maintenance guys are now saying that they will not allow inspections of their tool boxes which they will keep locked, and that as personal items we have no right to request inspection.
My concern is that although these are personal toolboxes they are in our facility in a GMP controlled area and although there is a dedicated toolbox which is kept in the processing area there are times when tools from the personal toolboxes are used in the factory. The policy is to clean/sanitize all tools going into the factory but it just feels wrong that we have no 'authority' to inspect items in our GMP areas which may compromise food safety due to the movement of tools between work and home use and the storage of personal items in the toolboxes. Even if we retrain the GMP/Food Safety policies to the maintenance guys how to we check compliance if we are unable to inspect the toolboxes?
Has anyone else faced this kind of issue and how do you manage the situation? I now have 3 very angry maintenance guys and with my SQF audit next week I want to get this resolved ASAP.
First Time SQF Gap Assessment-Help Needed
27 January 2015
Morning All, We have our first SQF gap assessment scheduled for next week ( small Food Contact Packaging ). I would like to know if I need to have a schedule laid out for him or he just goes clause by clause. I heard through past others experiences that they have / had a somewhat schedule made up, like first half of the morning- plant inspections, then paperwork, then lunch, then continue with paperwork...Not sure what approach I need to take.. I know he is there on our dime, but I want to take full advantage of his stay and not miss anything.... So if there is anyone that has gone through this and had success in getting everything covered / looked at...your feed back would be much appreciated.....
Thanks,
JJ
Continuous Improvement, What? and How far?
27 January 2015
So if anything, Im just throwing this out there to see what others are / are not doing, and how they are doing it.
Our company has been established for sometime (we've been in continuous production since the mid 80's), but we've only been GFSI certified for the last 5/6 years. And only very VERY recently have made a full-time position for Quality Systems (Me!) That was about 1 1/2 years ago. Someone to solely focus on quality systems, maintaining and updating to current standards.
I've found that in digging into just about everything, that I've had opportunities to better our QS. So I've tweeked some programs, and made major changes to others. (For awhile, we were talking the talk, and not so much walking the walk - you know how that goes...but I think we are around the bend on that now)
Anyway, I've heard that a good measure of continuous improvement is to monitor or track these intangible quality system updating activities.
How much time / money has been spent fixing a program - shows commitment, and in a very quantifiable way.
Documenting before and after figures like holds, or customer complaints shows involvement, and understanding, again in a very quantifiable way.
But what else should be done with these projects, if anything at all?!
Most of these projects are my day to day work, but at the same time I feel like I should be trending my work, and essentially validating my position with the company (not that it is needed), for the sake of documenting continuous improvement.
And if that is the case, should I be opening Corrective Actions on how the programs that were so far off mark in the first place? That seems like the logical place to start, (but if an auditor were to come across a major program gap through a corrective action, it seems like a dangerous place to go).
Like I said, just curious to see how others are communicating continuous improvement, whether it be to internal managers or to auditors / customers, and how much they are analyzing what they are changing.
Thanks in advance,
IRI
HACCP Plan and CCPs
27 January 2015
Hi All, I just have a quick question. In relation to a haccp plan for a meat plant - Is it ok to have a CCP for chilled storage on intake and call it CCP1 and then to have a CCP for chilled storage on dispatch and call it CCP1 also (As they are for the thing - i.e. chilled storage).
Appreciate the advice.
Thanks.
Continuous Improvement Strategies in Low-risk Processing Sites
27 January 2015
Hi all, Wanted to get some feedback from the community on various ways you have engaged and provided continuous quality management guidance/motivation at low-risk sites to prevent complacency and create a culture for continuous improvement. In particular, when dealing with outsourced processing or suppliers, how have you been able to engage them to strive for a high-standard when the normal push-back is "well we're low risk and it hasn't happened before... etc. etc"?
Many outsourced, toll-processors I have been dealing with meet minimum FDA requirements but are all very new to being involved in the food and beverage processing industry. Coming from working in BRC facilities to visiting places where trying to explain why personnel still need to follow GMPs in warehousing areas where finished goods are stored and picked for dispatch while getting responses such as "well everything is sealed and packed so nothing can get in" has been a new adventure for me.
Background: Our operation is a Frozen vegetable blending and packaging.
Has anyone implemented HARPC Plan yet?
Would like to know how much documentation is required besides the HACCP Plan?
Any help information you could share, it is greatly appreciated.
Kelio
Diesel Power Washer Use During Non-Production?
26 January 2015
Just looking for a bit of help - and here's the situation. I work for a large-scale bakery. We have a portable diesel powered power washer in the event our main washer breaks down. When needed, we currently run the diesel one outside (We do monitor the water for Coliforms/TPC, no issues there) and run the line back into the building.
However, one of the managers has recently challenged whether or not we must use it outside if there is no production going on. (During cleaning on the weekends - presumably to allow for better access and pressure in areas of the plant far away from it).
We (Quality Personnel) are quite against it for a few reasons. 1) Fumes for worker comfort and safety (We do have a 3 story tall fairly expansive building so it likely would not be very concentrated) 2) We store ingredients in all different areas of the plant (including adjacent to production lines), and are concerned about the smells permeating the packaging and possibly causing dry ingredients to get off flavors. 3) Potential of fumes/residues settling in or on equipment. (As we have large ovens, fryers, etc.).
However the question has been raised if we can come with some kind of documentation/proof/standard/rule supporting why we do not want diesel power being used in the food processing area at any time.
We've found some documentation from OSHA indicating that Diesel fumes are a potential health hazard. I haven't had much luck beyond that yet, though I do recall an audit in the past (Cook and Thurber maybe?) that stated specifically forklifts should not be gasoline powered in the food processing area. (But haven't had luck finding that.) My hope is maybe someone can help with some kind of reference to regulatory or 3rd party standards. Or if there are perhaps other thoughts, as well.
Very much appreciated in advance!
Liz
Heinz Global Vendor Standard
26 January 2015
Hi everyone, Does anyone have experience with the Heinz Global Vendor Standard, and more in particular the SRI module (for infant food)? I am looking for a downloadable copy of this standard.
Many thanks.
1st or 2nd ISO 22000 Surveillance Audit
26 January 2015
Dear All, Do I have to cover all the audited company scope during (1st or 2nd ISO 22000 Surveillance Audit) or i can leave some clauses???
Regards,
Omar
Dealing with Non-conformances, Best Practice in Determining Root Cause
26 January 2015
Good day! I am a newbie in answering Corrective Action Requests (CARs) for Non-conformances, for we had recently had our first Internal Quality Audit in preparation for our first third party BRC and IFS audit. I would like to gather advices regarding, what are the best ways to answer a Corrective Action Request (CAR), specially in determining the Root Causes of the Non-conformities. I would like also to know what do most auditors like to see in our CARs. I am also open to additional advices, materials and references that would be reccommended. Hoping for your outmost help.
Using the word export in Scope in ISO 22000
26 January 2015
Hello All, A company its scope of ISO 22000 certificate is "Production and Export of Dry Yeast", is it true to put the word "Export" in the scope ??!!
As far I know "Export" is not included in any ISO 22000 scope.
Am I true? Or not?
Control of nonconformity / unsafe product
25 January 2015
Hi All, Simply I am confused between Nonconformity product and unsafe product what is the different between them?
Thanks
Freezer storage of raw meat/poultry and ingredients
23 January 2015
I need some opinions please. We have freezer storage of raw meat/poultry and ingredients listed as a process step in our Hazard Analysis. We do monitor the freezer with chart records and they are checked each shift and documented. We do not list any Hazards at this step.
1. Does anyone see any hazards at this step? 2. If we don't have any hazards listed should we keep the justification empty or do we add that the temp is monitored by chart recorded and checked twice a day?
I hope I have giving enough information.
Need words of encouragement - SQF level 2 renewal audit
23 January 2015
Next week is our SQF level 2 renewal audit. As I've been preparing for the last few months, my colleagues have been for the last week...
The initial SQF audit landed completely, squarely on me. This year I was told that those supervising production and warehouse would need to be involved.
The day after the 2 day audit we have a huge potential customer coming for a tour.
And 2 days of inventory.
Then a week off.
Then our USDA FSA audit...
If I have hair by the end of February it will be amazing!
Fraudulent Customer Complaints
23 January 2015
I am interested to know what procedures you all have in place to deal with customers claiming illness? What do you do in situations where you are sure that the claim is fraudulent? Look forward to hearing opinions!
Best way to clean oil (food) spills in otherwise dry environment?
23 January 2015
Hi all, I'm wondering if anyone has experience using and would suggest any oil absorbing pads or sweeping compounds that are effective at spilling food oil spills (the oil is technically camelina oil, but I know many don't know of it so just think vegetable/olive oil)?
We do a small amount of bottling/ packaging into 16 oz plastic and glass bottles, as well as 5 gallon pails, in a room with smooth concrete floors (read: slippery when wet) . The rest of the plant is all dry processes, and I am definitely leaning towards pads (so we don't have to worry about sweeping compounds creating a dust) in the event of a spill. I am hoping for recommendations, since the companies we use that sell these require a fairly large order and I don't want to waste a bunch of money ordering 100+ pads and later find out they aren't quite good enough for the job.
It has yet to happen in 7 years of production, but when I asked my production manager how we would clean the oil if it DID spill- I got a very blank look, and then "we just don't spill it?" .
Then with these pads, I imagine there will probably be a small film left on the floor-- suggestions for how to deal with this? Definitely don't want to deal with anyone slipping on oil residue and hurting themselves.
Thanks in advance :)
Food Grade Sodium Acid Metaphosphate
23 January 2015
Hey all, In Japan there is a variation of sodium metaphosphate that is referred to as sodium acid metaphosphate, its main characteristics include a very low pH, around 2.0, as well as a very high chelation value for metal ions compared to SHMP as well as any other types of phosphates. Is anyone familiar with this specification and are there similar metaphosphate products in the EU or US markets?
Thanks,
Ren
Difference between CGMP and GMP
23 January 2015
Hi all, I don't really understand the difference between CGMP, or current GMP, and GMP. So is there a non-current GMP?
Thanks,
Jackson
Questions about PrimusGFS
22 January 2015
Hey all! I have a question about FoodSafety & my company gets audited by Primus btw.
1. We're certified by Primus at our current facility, but we're moving a bigger facility in about a month. How am I supposed to get our new facility certified if no one is working in it yet?
Thanks!
Are demands for Ethical Trading compliance growing in your country?
22 January 2015
In the UK the past few years there is growing demand for businesses to comply with ethical trading standards. Driven by the retailers (surprise, surprise) standards and requirements vary from customer to customer, but are roughly based on the Ethical Trading Base code.
Suppliers now are required to be members of SEDEX and undertake self-assessment and audit. All suppliers in the Walmart supply chain must undergo an Unannounced Audit.
Is this specific to the UK or are you seeing the rise of Ethical Compliance in your country...if so how does it look?
What constitutes a document revision
22 January 2015
Hi, My company currently operates a paper based document control system. Many of our production records which are filled in on a daily basis are undergoing dozens of revisions. The main problem is that the document lists products pre printed on the record but these products are constantly changing through-out the year which results in a change request being sent.
My question is... should a controlled document be expected to even contain the product list? Or would you expect the document control department to just have a blank copy of this document with no product names on? If this is the case i think i need to understand a little better of what information within a document is needed to be controlled and what isn't as this is causing certain documents to revised on a weekly basis.
Kind Regards,
Matt
Process Monitoring - Electronic System
22 January 2015
Morning All, Process monitoring paperwork is becoming a nightmare... I fear I have killed half the rainforest with the amount of paper we use (and then have to store!). I would like to go down the electronic route.... ideally with handheld units...Does anyone know of a decent company who will not rip my eyeballs out?
Thanks :)
Lead Auditor ISO 22000 Exam Questions - Examples
21 January 2015
Who has a document or a good link to example questions (preferably including good answers) for a Lead Auditor ISO 22000 (IRCA) exam?
I am especially looking for example questions of the last part of the exam, where you find 3 cases studies.
Thanks!
Trouble getting manufacturer information from agent
21 January 2015
Most of our ingredients are imported from various countries and we rely on the manufacturers technical/product data to confirm suitability and evaluate the food safety risks associated with each product. The challenge is where agents import (by name) the same product from various manufacturers, COA's are provided, but the parameters differ or the limits vary. Especially for chemicals used as food ingredients- the agent stamped the COA supplied, but it is frustrating to get food safety certification proof or data sheets from the actual manufacturers to confirm that they actually comply with food safety requirements. Please share your experience to make this effort less painful and more effective.
GMP of inoculation process at yoghurt product
21 January 2015
Hai, did anyone know about standard gmp at inoculation step in making yoghurt product? Is it need aseptic room? How if I have non aseptic room and I need to do inoculation on that room for producing yoghurt?
Please advice
Thanks :)
Food Grade processing room
20 January 2015
We are building a new food grade room and want to confirm we can line it with a powder coated or 2pac lining.
Shipping Standards
20 January 2015
I work for a small company that still uses FedEx/UPS to ship small quantities of product to local businesses. Is this 100% bad practice? My concern is obviously with vehicle inspections because we cannot determine what else might be in the trucks.
Furthermore, we do local deliveries of a frozen product using coolers (like, picnic coolers--supposedly rated to keep ice frozen for up to 5 days). Is there a risk analysis way out of this (the temperature of the product is checked at the point of delivery and is still well below 0 degrees) or is this another "never"?
We are only working towards AIB right now but I would hope that the company would start working to GFSI standard after that so I would like to put practices into place now that will satisfy BRC/SQF/etc., if at all possible. Thanks again for answering my newbie questions!
CFIA Action Plan Template
20 January 2015
Does anyone have an example of an action plan for a CFIA issued CAR?
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