Tom Huge
President, ASI Food Safety Consultants
TOMSBLOG.ASIFOOD.COM
FSMA Stalled
The Food Safety Modernization Act has stalled. It's been stalled for months now at OMB. This is the government Office of Management of Budgets. Appearently it's such a big act, that they are having trouble digesting it and getting through it.
There are some consumer groups glamoring to get this thing through, and now we are thinking that what if another food safety illness or death occurs when this thing is stalled, what the heck is going to happen. The backlash may be voluminous. Can you imagine the fingerpointing?
Is this going to happen at all during an election year?
Interesting, isn't it. We'll keep you informed.
Tom
There are some consumer groups glamoring to get this thing through, and now we are thinking that what if another food safety illness or death occurs when this thing is stalled, what the heck is going to happen. The backlash may be voluminous. Can you imagine the fingerpointing?
Is this going to happen at all during an election year?
Interesting, isn't it. We'll keep you informed.
Tom
Is Your Steak Glued?
Have you heard this one? Particularly they were referring to filet mignon. Filet mignon is pieces of other steak glued together. It's done at the restaurant.
It sounded like bunk to me so I called some folks. It is bunk. One of my sources said it would #1 be too expensive to do. Another guy said "glue in an oven?"
Enjoy your filet mignon for Mother's Day. Don't worry about your lips getting glued together.
Tom
It sounded like bunk to me so I called some folks. It is bunk. One of my sources said it would #1 be too expensive to do. Another guy said "glue in an oven?"
Enjoy your filet mignon for Mother's Day. Don't worry about your lips getting glued together.
Tom
Is Your Food High Risk?
As promised in our last blog, we were going to give you a list of foods that FDA considers high risk. There's one problem with that. They've never put a list together.
But, when they do, it means that their inspectors will visit your facility first. As we've mentioned in previous blogs, make sure your risk assessment plan or HACCP plan is up to date and working. We think they may ask to see that maybe before they begin inspecting.
From reading FDA stuff, here are some of the foods that I think will be on their list:
1. Foods that have been associated with outbreaks in the past. Ground beef, sprouts, cantaloupe, lettuce, peppers, etc.
2. Tomatoes
3. Peanut products
4. Chicken
This is a good start.
Tom
But, when they do, it means that their inspectors will visit your facility first. As we've mentioned in previous blogs, make sure your risk assessment plan or HACCP plan is up to date and working. We think they may ask to see that maybe before they begin inspecting.
From reading FDA stuff, here are some of the foods that I think will be on their list:
1. Foods that have been associated with outbreaks in the past. Ground beef, sprouts, cantaloupe, lettuce, peppers, etc.
2. Tomatoes
3. Peanut products
4. Chicken
This is a good start.
Tom
Update on FSMA
It might be time to update you folks on the Food Safety Modernization Act
Just to remind you again, if you haven't registered your facility with FDA, you must do so if you produce and or distribute, warehouse or repackage food.
Also you must have some kind of a risk assessment plan. This is law.
FDA has recognized what they think are the high food risk facilities. They will probably pay particular attention to these facilities. We will mention and list these on next week's blog.
FDA has initiated a reinspection fee. If they have to revisit your facility because of a non compliance, they will charge a fee.
There is a lot going on in the food industry.
Tom
Just to remind you again, if you haven't registered your facility with FDA, you must do so if you produce and or distribute, warehouse or repackage food.
Also you must have some kind of a risk assessment plan. This is law.
FDA has recognized what they think are the high food risk facilities. They will probably pay particular attention to these facilities. We will mention and list these on next week's blog.
FDA has initiated a reinspection fee. If they have to revisit your facility because of a non compliance, they will charge a fee.
There is a lot going on in the food industry.
Tom
Do What the Good Doctor Says!
Sorry about not getting a blog out last Wednesday. We were up at the vacation house putting away the winter stuff and getting out the summer stuff.
Please go to www.blogtalkradio.com and listen to Dr. Larry Goodridge's presentation on who is responsible, ultimately, for food safety in our food production environment. It is very intersting to hear his perspective.
Remember. Keep your hands washed a don't cross contaminate in your own kitchen at home.
Tom
Please go to www.blogtalkradio.com and listen to Dr. Larry Goodridge's presentation on who is responsible, ultimately, for food safety in our food production environment. It is very intersting to hear his perspective.
Remember. Keep your hands washed a don't cross contaminate in your own kitchen at home.
Tom
Pet Foods Same As Human Foods
Oh boy do we love our pets. They really do become part of the family. And they never do get me at you. My wife and I stayed out a little too late once on a Friday night and they missed their dinner that night. It was too late to feed them when we finally got home. We have three male labrador retrievers (all rescued) and when we got home that night they were still happy to see us. We have a pretty long driveway and their tales were wagging the whole way as they followed us down the driveway. Dinner? Who cares? Mom and dad are home.
Big pet retailers are now asking their dog food suppliers to follow the same guideline in producing their pet foods as human food processors have to follow. That includes HACCP plans, recall programs, pest control, employee training, self inspections and even allergen control programs. So if you are a pet food manufacturer trying to sell to retail markets, if they haven't already done so, they will probably start asking for the above.
This is a good thing for all of us.
Tom
Big pet retailers are now asking their dog food suppliers to follow the same guideline in producing their pet foods as human food processors have to follow. That includes HACCP plans, recall programs, pest control, employee training, self inspections and even allergen control programs. So if you are a pet food manufacturer trying to sell to retail markets, if they haven't already done so, they will probably start asking for the above.
This is a good thing for all of us.
Tom
Getting Good Help To Help With Meeting FSMA
With the passing of the Food Safety Modernization Act about a year and a half ago, there are probably additional items that you need to do in your food processing plant to meet the requirements. Make sure that you have surrounded yourself with good, dedicated people that understand real world food safety. People with experience who have audited.
Your facility should be conducting monthly self audits of your facility. A member of each department should be on that auditing team. And the most important. Have a viable follow up plan for the corrective actions.
Do you have a plan dealing with an FDA investigator if they show up? Who is going to deal with him/her? Are you going to allow photographs?
Is your recall plan up to date? Allergen plan. How is that?
Below is the article that I referenced for this blog: Managing People whilst meeting Regulatory Compliance- 10 Top Tips: by Lorna Elmslie
1. Senior Management commitment and support is key- they should lead by example and this should be filtered throughout the organization.
2. Your Staff selection process is important- staff should if possible, come from a variety of backgrounds, be it quality, research or academia; having this range of knowledge across the organization all helps, as does a balance of experience and qualification.
3. Engage your staff in the Auditing Process- to ensure that everyone is aware of what they should be doing and where everything is.
4.On-going Training and Performance Management- this will enable all your staff to be fully prepared if and when an audit takes place.
5. Good attitude to quality- should be company wide, it's not just the QM's job to look after quality, everyone should be aware of the importance of quality and why; a "quality culture" should be cultivated within your organization.
6. Production vs. Quality Mentality- if it exists within your organization, requires to be overcome. Your staff should be aware that quality should be a key principle in all that they do.
7. Effectively managing an Audit Inspector- and how to do this, requires to be communicated to all staff. This will overcome any "deer in the headlights" moments and help to build confidence amongst staff when or if they have to deal with an inspector.
8.Positive attitudes and behaviors- should be encouraged amongst your staff; delivering results a "can do" attitude, being flexible to change, and someone who provides solutions rather than problems, is vitally important.
9. Establishing a commitment to Quality, and effective communication of the Quality Message- is vital to translate across the entire organization. This should be done from the "top down" with effective leadership and communication from the key staff.
10. Of course none of this matters if the big wigs and/or owners of the firm don't give a hoot about food safety. You are going to have to get their committment. Just read a Form FDA 2966 (which replaces Form FDA 483) on a company where dust from the parking lot was blowing in and on exposed food and there were rodent droppings on top of packing equipment at a food plant. And this was as recently as two months ago. If you don't get top management committment, your job will be very frustrating and you will stink like a rat.
Tom
Your facility should be conducting monthly self audits of your facility. A member of each department should be on that auditing team. And the most important. Have a viable follow up plan for the corrective actions.
Do you have a plan dealing with an FDA investigator if they show up? Who is going to deal with him/her? Are you going to allow photographs?
Is your recall plan up to date? Allergen plan. How is that?
Below is the article that I referenced for this blog: Managing People whilst meeting Regulatory Compliance- 10 Top Tips: by Lorna Elmslie
1. Senior Management commitment and support is key- they should lead by example and this should be filtered throughout the organization.
2. Your Staff selection process is important- staff should if possible, come from a variety of backgrounds, be it quality, research or academia; having this range of knowledge across the organization all helps, as does a balance of experience and qualification.
3. Engage your staff in the Auditing Process- to ensure that everyone is aware of what they should be doing and where everything is.
4.On-going Training and Performance Management- this will enable all your staff to be fully prepared if and when an audit takes place.
5. Good attitude to quality- should be company wide, it's not just the QM's job to look after quality, everyone should be aware of the importance of quality and why; a "quality culture" should be cultivated within your organization.
6. Production vs. Quality Mentality- if it exists within your organization, requires to be overcome. Your staff should be aware that quality should be a key principle in all that they do.
7. Effectively managing an Audit Inspector- and how to do this, requires to be communicated to all staff. This will overcome any "deer in the headlights" moments and help to build confidence amongst staff when or if they have to deal with an inspector.
8.Positive attitudes and behaviors- should be encouraged amongst your staff; delivering results a "can do" attitude, being flexible to change, and someone who provides solutions rather than problems, is vitally important.
9. Establishing a commitment to Quality, and effective communication of the Quality Message- is vital to translate across the entire organization. This should be done from the "top down" with effective leadership and communication from the key staff.
10. Of course none of this matters if the big wigs and/or owners of the firm don't give a hoot about food safety. You are going to have to get their committment. Just read a Form FDA 2966 (which replaces Form FDA 483) on a company where dust from the parking lot was blowing in and on exposed food and there were rodent droppings on top of packing equipment at a food plant. And this was as recently as two months ago. If you don't get top management committment, your job will be very frustrating and you will stink like a rat.
Tom
Pink Slime in Hamburger Meat
Poor old hamburger meat. It's always getting pinked on, I mean picked on. Hamburger meat can hold salmonella or listeria more than steak meat because it has a rougher surface is what you hear. Hamburger meat is touched more by humans than steak meat so more things can happen to it. Poor old hamburger meat. We should give it a break.
And now. Pink slime in hamburger meat. Check it out. The ABC nightly news on March 7. Ammonia is also added to kill bacteria. It's been going on for quite awhile and some whistleblowers finally stepped forward.
Anyway. Hamburger meat I love you. You have tasted good to me for many a year. It doesn't make any difference. In patty form or crumbly form. Baked, fried or barbqued. One time in college I ate 10 patties. Five Big Macs. Since it was 1am the pink could have been oozing out of them and I wouldn't have noticed or cared.
Tom
And now. Pink slime in hamburger meat. Check it out. The ABC nightly news on March 7. Ammonia is also added to kill bacteria. It's been going on for quite awhile and some whistleblowers finally stepped forward.
Anyway. Hamburger meat I love you. You have tasted good to me for many a year. It doesn't make any difference. In patty form or crumbly form. Baked, fried or barbqued. One time in college I ate 10 patties. Five Big Macs. Since it was 1am the pink could have been oozing out of them and I wouldn't have noticed or cared.
Tom
FDA Will Dig Deeper Than Ever Before
Food Processors and Distributors: During your next FDA audit, they will most likely be digging deeper into your records then ever before. The Food Safety Modernization Act has given them the authority. Here's what we think you should be prepared for.
An up to date and working HACCP plan. It must be up to date. If someone wrote it for you a year and a half ago and you've added a new line or product or deleted a new line or product it's not up to date. If you've changed container sizes it's not up to date.
An up to date and working Recall plan. It must be in your records that you practise a fake or mock recall twice a year. One or two items is fine.
A complete Allergen plan. From beginning to end. It should include separation and cross contamination.
We believe that FDA inspectors are going to be more active in the food industry in the future. How often you will be visited or when is a good question. Just be prepared.
Tom Huge
An up to date and working HACCP plan. It must be up to date. If someone wrote it for you a year and a half ago and you've added a new line or product or deleted a new line or product it's not up to date. If you've changed container sizes it's not up to date.
An up to date and working Recall plan. It must be in your records that you practise a fake or mock recall twice a year. One or two items is fine.
A complete Allergen plan. From beginning to end. It should include separation and cross contamination.
We believe that FDA inspectors are going to be more active in the food industry in the future. How often you will be visited or when is a good question. Just be prepared.
Tom Huge
Attention: Food Processors That Use Third Party Audits
Allow me to quote Michael Taylor , Deputy Commissioner for Foods, FDA, from a recent presentation he gave at the Global Food Safety Conference.
"FDA will recognize accrediting bodies and set standards for accreditation of third-party certification bodies and auditors aimed at ensuring the rigor, objectivity and, most importantly, the transparency of third party audits. Transperancy means that the results of the audits for certification will be available to FDA, which in turn means that we can both assess the rigor of private audits and rely on them as part of the public system of assurances and accountability for food safety."
How are the audit results going to be avaliable to FDA? We heard at one time that if we (ASI) were to find a critical condition in a plant, that we were supposed to call FDA. How are they going to assess the rigor of private audits?
This all sounds pretty scary to me, especially for you food processors. You may want to talk to your congressman about this.
Tom
"FDA will recognize accrediting bodies and set standards for accreditation of third-party certification bodies and auditors aimed at ensuring the rigor, objectivity and, most importantly, the transparency of third party audits. Transperancy means that the results of the audits for certification will be available to FDA, which in turn means that we can both assess the rigor of private audits and rely on them as part of the public system of assurances and accountability for food safety."
How are the audit results going to be avaliable to FDA? We heard at one time that if we (ASI) were to find a critical condition in a plant, that we were supposed to call FDA. How are they going to assess the rigor of private audits?
This all sounds pretty scary to me, especially for you food processors. You may want to talk to your congressman about this.
Tom
