Monday, May 21, 2018

FDA’s Data Dashboard Helps Companies Meet FSMA Supply Chain Requirements


FDA has launched a new section of its Data Dashboard to help food importers, manufacturers and processors meet supply chain requirements put forth by FSMA (specifically FSVP, and the PC rules). The dashboard provides ease in finding compliance and enforcement information related to companies.

“The Foreign Supplier Verification Programs rule requires importers to perform risk-based activities to verify that their suppliers are meeting applicable U.S. food safety standards. One such activity is an evaluation of a supplier’s performance and the risk associated with the food, a process that includes evaluating a supplier’s compliance with FDA regulations such as whether the supplier is subject to an FDA warning letter, import alert, or other FDA compliance action related to food safety. The Preventive Controls rules require manufacturers/processors to perform supplier approval if the ingredient supplied contains a hazard requiring a supply-chain applied control. Supplier approval includes consideration of the supplier’s compliance with food safety laws and regulations.” – FDA

The agency also made improvements to its supplier evaluation resources page and added it to the dashboard so that companies can simultaneously search several databases. Users can search for information about warning letters, import refusal and import alerts.

Article Source: https://foodsafetytech.com/news_article/fdas-data-dashboard-helps-companies-meet-fsma-supply-chain-requirements/

Friday, May 18, 2018

The Top 6 Benefits of On-Site Training


On-site training is becoming more and more of a necessity for organizations around the world, specialized training in accordance with the organization's needs helps teams become more productive and innovative. On-site training has also grown from just training employees in a specific location to training employees globally via online training which reduces cost and allows multiple branches of the organization to learn together.

1. Location
The biggest advantage of on-site training is the location. With the training done on the company's premises, employees save valuable time, which otherwise would have been lost on commuting from another location to the trainer. On-site training also allows the organisation to be free to make last minute changes and make additional changes to who might or might not be helpful to include into the training, for example an operations manager who could share a few experiences with the class or an up-and-coming executive who might be willing to sit in the next available training program

2. Privacy
Delicate organizational data can be shared by members and utilized as solid illustrations amid intuitive and confidential workshop sessions in complete confidence. Upper-management may train specific mid-leveled executives on the internal workings of the organization.

3. Tailored Program Content
Organizations have the ability to tailor each and every aspect of the training process as well as customize the lessons according to the company's own policies. Guiding employees on which area's the organization would like them to focus on for a specific time period or financial year.

4. Boosts employee productivity and profits
Employees are able to build new skills, develop existing skill sets, and gather new knowledge about products and services that will boost their on-the-job productivity. Given that most training programs from universities and training institutes are quite time consuming and expensive on individual based training. With on-site training employees do not have to time out of the office and instead clock back to work as soon as the training is complete and since they are based on group lessons, the cost for such training is significantly reduced.

5. Employees have access to training that work around their schedule
With on-site training, training can be scheduled to the organization's needs and learning and development professionals can plan training to suit their own employees rather than the usual classroom style of universities which have a specified schedules that often clash with work hours.

6. Keeps employees up to date on current company protocols
While many employees are offered entrance training when they first join an association, continuing onsite training offers them the capacity to further build up their aptitudes and extend their expert learning. Since company processes are constantly evolving, it's critical that representatives are offered access to new training and stay up-to-date. On-site training gives professionals the opportunity to grow their abilities or find out about new subjects inside of their specialty so as to stay competent and innovative with industry trends or new insights that may give them an advantage at work.

Article Source: https://www.findcourses.com/prof-dev/l-d-articles/top-6-benefits-of-onsite-training-9873

Tuesday, May 15, 2018

On-site PRIVATE Classes in English & Spanish and Consulting Services


Classes Available in English & Spanish and Consulting Services

WE OFFER PUBLIC AND ON-SITE TRAINING CLASSES:
  • HACCP Workshop
  • Implementing SQF Training - Version 8.0 - English and Spanish
  • FSMA Preventive Controls for Human Foods
  • FSPCA For Human Food Compliance
  • Produce Safety Rule Training Official Program
  • SQF Quality Systems For Food Manufacturers
  • Internal and External GFSI Audits
  • Crisis Management
  • Gluten Free Certification Program
  • SQF Advance Practitioner Course
  • Prerequisite Programs

WE ALSO OFFER:

  • Food Safety Consulting Services

Please visit our website or send us an email for more information!

Saturday, May 12, 2018

Food Fraud Requires Companies to Think Like a Criminal

Mitigating the risk requires implementing control measures and establishing traceability systems.


In a two-question format, the authors discuss pressing issues in food fraud.

1. Where are the current hot spots for food fraud?

Food fraud activities have been known for centuries. For example, in ancient Rome and Athens, there were rules regarding the adulteration of wines with flavors and colors. In mid-13th century England, there were guidelines prescribing a certain size and weight for each type of bread, as well as required ingredients and how much it should cost. In the United States, back in 1906, Congress passed both the Meat Inspection Act and the original Food and Drugs Act, prohibiting the manufacture and interstate shipment of adulterated and misbranded foods and drugs. However, evidence and records of actions taken over those events were not officially collected.

It was not until 1985, when the presence of diethylene glycol (DEG) was identified in white wines from Austria, that authorities, retailers and consumers started to have serious concerns about the adulteration of food and the severity of its impact on consumers. In addition, there was increased interest to regulate, investigate and apply efforts to enforce requirements.

Other examples include the following:

  • 2005: Chili powder adulterated with Sudan (India)
  • 2008: Dairy products adulterated with melamine (China)
  • 2013: Beef substituted with horsemeat (UK)
  • 2013: Manuka honey where it was known that bees were not feeding from pollen of the Manuka bush (New Zealand)
  • 2016: Dried oregano adulterated with other dried plants (Australia)

This list can go on and on.

Lately there have been more cases of food fraud. Fortunately, even limited international databases are helping to identify the raw material origins of products in the supply chain that could be more exposed to adulteration. Also, food manufacturers, brokers and agents are conducting assessments to ensure that they are buying ingredients and products from sources, where food fraud could be prevented. The following products are identified as having more adulteration notifications:

  • Olive oil
  • Fish
  • Vegetable products with claims of “Organic”
  • Milk
  • Grains
  • Honey and maple syrup
  • Coffee and tea
  • Spices
  • Wine
  • Fruit Juices

2. What can companies do to mitigate the risk?

Control measures to prevent food fraud activities include the adequate evaluation and selection of suppliers, as well as the ‘suppliers of the suppliers’. Typical risk matrices of likelihood of occurrence versus consequence can be used to measure risk—and determine priorities for assessing and putting control measures in place. Assessments can be focused on points of vulnerabilities such as food substitution, mislabeling, adulterations and/or counterfeiting, usually due to economic advantages for one or more tiers in food chain production.

Other food fraud activities include effective traceability systems, monitoring current worldwide news and notifications on food fraud using international databases (EU-RASFF, USA- EMA NCFPD and USP, etc.), and product testing.

Product testing is becoming an important tool for the food industry to become confident in sourcing raw materials, ensuring the management of food fraud control measures, fulfilling applicable legal requirements, and ensuring the safety of consumers.

Product testing laboratories offer different kinds of testing methods depending on the required output; for example, if it is possible and requested, a targeted or non-targeted result.

Targeted analysis involves screening for pre-defined components in a sample:

  • Liquid chromatography
  • Gas chromatography
  • Mass spectrometry (LC-MS and GC-MS)
  • Nuclear magnetic resonance spectroscopy (NMR).
  • PCR technique

Non-targeted analysis aims to see any chemical present in the sample:

  • Isotopic measurement-determination of whether ethanol and vinegar and flavorings are natural or synthetic
  • Metabolomics: Maturation and shelf life
  • Proteomics: Testing for pork and beef additives in chicken, confectionery and desserts

Due to the importance of food fraud for a food safety management system, GFSI published Version 7.1 of Benchmarking Requirements, including subjects on food fraud, as vulnerability assessment. In 2018 all certification schemes have incorporated such requirements and started enforcing them.

Fraud cases threat consumer trust in products and services. Companies are learning to “think like a criminal” and put in place measures to prevent fraud and protect their products, their brands and their consumers.

Article Source: https://foodsafetytech.com/feature_article/food-fraud-requires-companies-to-think-like-a-criminal/

Wednesday, May 9, 2018

2 Seats Left in our May Classes - Register Today!!


SQF Food Safety Code For Manufacturing Edition 8 
($125 Special Price!)

GFSI Internal & External Audit Workshop
($125 Special Price!)

Sunday, May 6, 2018

Three Ways Sanitation Automation Helps Food Processors Reduce Costs

Sanitation is a major undertaking for food processors. Automating certain tasks, however, can help facilities overcome common challenges, including labor, safety and sustainability, leading to significant savings and increased productivity.

Butcher cleaning the floor at meat factory. Image courtesy of Birko.

Sanitation in a food processing plant is a large-scale effort that many organizations see as an added cost of doing business. Yet, it’s essential and can have costly consequences if done improperly.

Because time is money and facilities want to avoid any necessary downtime, the window for completing proper sanitation procedures is small. Many food processors simply put more people on the job while requiring them to work third shift, hoping to get things done faster.

Automating certain sanitation procedures in your plant can provide real benefits, many of which will help reduce the costs associated with food safety and keeping your facility clean. Here’s a look at the three main ways food plants can save by implementing automated sanitation solutions.

1. Resource Management

When you invest in sanitation automation, one of the biggest advantages is the increased understanding of how resources are being used. This knowledge and improved visibility gives you control of how resources such as water and chemicals are used during sanitation.

Perhaps the most significant area in which facilities experience savings is through reduction of water usage. Automated solutions improve the efficiency of rinse cycles while ensuring appropriate water pressure is being used. Every plant has unique water needs, but you should expect water savings between 30% and 50%, depending on the solutions that are applied.

Sanitation automation will also lead to a reduction in energy costs. Using less water means less energy is required to heat that water. Advancements in sanitation technology have made certain solutions more energy efficient. Features such as multi-stage pumps for full alternation, motors that allow pumps to ramp up and down as needed, and flow switches that send pumps into “hibernate” mode help reduce electricity usage.

Waste water from food processing also needs to be treated before it goes down the drain. Less water treatment means fewer chemicals are needed.

Food processors that introduce automated sanitation solutions will use cleaning chemicals more efficiently. Automation ensures chemicals are dispensed precisely where they are needed at the correct concentration, without any over spray. Again, while every situation is unique, most facilities can expect a 20–30% reduction in chemistry costs.

In the end, you will have a very clear picture of the amount of water and chemistry needed to complete sanitation, and you’ll know the amount of time it should take. That means you can plan for more uptime.

Overall, not only can automation help food processors make efficient use of resources, it also makes them more sustainable.

2. Labor Costs

Labor is yet another resource that can be more effectively managed when there’s an investment in sanitation automation. The labor market is tight, and it is becoming increasingly difficult to hire the people needed to carry out sanitation work.

Sanitation often involves menial and tedious tasks that also require attention to detail. It usually entails working overnight when production stops, and certain responsibilities can be dangerous. At the same time, minimum wage is rising, and many organizations are looking to reduce labor costs.

Introducing sanitation automation can certainly cut labor expenses and remove the need to hire more people, but more importantly, it can make the workers you do have more productive. Automation should be used to eliminate menial tasks from sanitation workers. For example, instead of a person standing in front of a conveyor belt and spraying it down with a hose for hours on end, the job could be easily automated.

We worked with a brewer who was having two employees take as long as three hours to clean a filler. By automating that task, they turned it into a 45-minute job and allowed those employees to refocus their efforts. Plus, the before and after pictures of the equipment show a visible difference in cleanliness.

You can trust an automation solution to do a consistent job, and it will never call in sick. Still, you’ll always need to have “boots on the ground” and human eyes evaluating sanitation. Automating certain sanitation practices will free up employees to work on more important duties that add value and keep them engaged in their work.

3. Mitigating Safety Risks

The most important thing sanitation automation provides is more peace of mind. No one wants to lose sleep worrying about a failed inspection or the potential for a worker injury. Automation reduces the risk of product contamination and lessens potentially dangerous situations for employees.

For instance, spiral freezers are particularly precarious areas to clean. Automating its cleaning process eliminates the need for a worker to maneuver through an unsafe space, reducing the likelihood of a workplace injury.

Human labor can also lead to human error. But, when sanitation tasks are automated, they become more consistent and easily repeatable. This is especially important for cleaning hard-to-reach problem spots that become harborage areas for bacteria. There may be a tendency among human workers to skip areas they can’t reach, or fail to clean them properly, but a machine cleans everything the same every time.

The monetary risk of contamination inside your facility is significant. For example, if Listeria were to take up residence in a plant, it could cost your business millions of dollars.

According to a study from the Food Marketing Institute and Grocery Manufacturers Association, the average food product recall will have direct costs of $10 million while indirect costs could reach into the hundreds of millions. That’s because you also need to consider the ongoing cost of a damaged brand reputation, not to mention lost productivity from business interruptions and lost profits from disposing of potentially contaminated product.

Sanitation Automation: The Future is Now

There are many reasons to start implementing automation into your food and beverage plant’s sanitation practices. Food processors in Europe have been quicker to adopt these solutions because many of the same issues U.S. manufacturers face, such as wages and resource scarcity, can be even more pronounced overseas.

As the labor market in the United States presents challenges for hiring managers, and drought conditions in some regions make water a scarce commodity, automation presents an opportunity to bring your facility into the future. Add to those concerns the increased regulations from FSMA, and there is even more reason to invest in dependable sanitation solutions.

Food processors need to find trusted advisors who can evaluate operations inside the plant and look for ways to implement automation in ways that make the largest impact.

While there is certainly an upfront cost in automating sanitation, the potential savings and added visibility these solutions provide won’t take long to pay for themselves. In most cases, facilities that invest in sanitation automation will see a return within a year to 18 months. If done properly, you can achieve impressive cost-saving results through automation.

Article Source: https://foodsafetytech.com/feature_article/three-ways-sanitation-automation-helps-food-processors-reduce-costs/

Thursday, May 3, 2018

SQF Food Safety Code for Food Manufacturing - 2 day course - Special $125 Pricing!!


Wed, May 9, 2018, - Thu, May 10, 2018
8:00 am - 5:00 pm

Napa Valley College 
2277 Napa Vallejo Highway Bldg 3000, Rm 3004 
Napa, CA 94558 


DESCRIPTION

Attention food manufacturing professionals!

SQF Code, Edition 8 introduces a new approach for assessing individual food industry sectors with customized requirements in separate, stand-alone codes: Food Safety Fundamentals, Primary Production (Produce), Manufacturing, Distribution, Food Packaging, Retail, and Quality.

Attend this two-day course offered by Napa Valley College.

Course Description - What You'll Learn:

  • The updates and implications of the updates in Edition 8 of the SQF Code from the former Edition 7.2.
  • Implementing and maintaining an SQF system and its mandatory elements.
  • Validating and verifying your food safety plan within the SQF system and meeting FSMA requirements.
  • Undertanding the process for aligning with FSMA regulatory requirements.
  • Overview of the SQF certification process.
  • How a HACCP-based approach manages food safety and quality hazards in an operation.
  • The SQF Food Safety Code for Manufacturing as it applies specifically to Food Sector Categories 7-22, 31-34. This includes Modules 2 (Systems Elements) and Module 11 (Food Safety Fundamentals for Food Manufacturing).

Who Should Attend?

SQFP, Food Safety Professionals, Sr. Management, Suppliers, Food Safety Auditors, Support Staff. This course is designed to provide current and new SQF Practitioners, Sr. Management, Production Personnel, and their team members with the tools and knowledge to develop and maintain their SQF food safety management system and understand the process for aligning with FSMA regulatory requirements.

Two Day Course: May 9 to May 10, 8:00 AM to 5:00 PM each day.

Price: Only $125 for an entire 2-day course thanks to special grant funding.

Price Includes: Event registration, morning and afternoon snack breaks, lunch for both days, course materials and certificate of attendance.

Questions? Contact Charlie Monahan at 707-256-7254 or cmonahan@napavalley.edu.

Monday, April 30, 2018

On-site PRIVATE Classes in English & Spanish and Consulting Services


Classes Available in English & Spanish and Consulting Services

WE OFFER PUBLIC AND ON-SITE TRAINING CLASSES:
  • HACCP Workshop
  • Implementing SQF Training - Version 8.0 - English and Spanish
  • FSMA Preventive Controls for Human Foods
  • FSPCA For Human Food Compliance
  • Produce Safety Rule Training Official Program
  • SQF Quality Systems For Food Manufacturers
  • Internal and External GFSI Audits
  • Crisis Management
  • Gluten Free Certification Program
  • SQF Advance Practitioner Course
  • Prerequisite Programs

WE ALSO OFFER:

  • Food Safety Consulting Services

Please visit our website or send us an email for more information!

Friday, April 27, 2018

Internal and External GFSI Audits Workshop - Special Price of Only $125 - Register Today!



Internal and External GFSI Audits Workshop - 1 day course 

Fri, May 11, 2018 
8:00 AM – 5:00 PM 

Napa Valley College 
2277 Napa Vallejo Highway Rm 3004 Napa, CA 94558

Register HERE

Attention food manufacturing and processing professionals!

Learn all about Internal and External Global Food Safety Initiative (GFSI) Audits and food safety management systems, including:
  • Good Manufacturing Practices and Good Agricultural Practices
  • Hazard Analysis and Critical Control Point (HACCP) Program Development
  • ISO-19011 Auditing Principles
  • GFSI schemes (SQF, BRC, FSSC2200, Global G.A.P.) from the auditor point of view

This workshop complies with the training requirements for GFSI professionals and Internal auditors for GFSI approved schemes (SQF, BRC, FSSC22000, Global G.A.P. among others)

Who Should Attend?
Food Safety Professionals, Sr. Management, Suppliers, Food Safety Auditors, Support Staff.

One Day Course: May 11, 8:00 AM to 5:00 PM.

Price: Only $125 for the entire 1-day course thanks to special grant funding.

Price Includes: Event registration, morning and afternoon snack breaks, lunch, course materials and certificate of attendance.

Questions? Contact Charlie Monahan at 707-256-7254 or cmonahan@napavalley.edu.

Tuesday, April 24, 2018

Six Best Practices To Make Audits Stress-Free


Your next audit is already on its way. Now that many regulatory bodies and certification agencies are no longer required to give you a heads-up about upcoming audits, it’s completely up to you to stay on top of compliance, recordkeeping, and a myriad of other tasks on a day-to-day basis. And without that buffer of warning from auditors, falling behind can be more detrimental than ever.

Let’s walk through some effective practices that keep you ready for an audit at a moment’s notice, make the process go smoothly once the auditor arrives, and get rid of some unnecessary stress all along the way.

Connect All Departments to an Online Database
When it comes to collecting and moving data from one department to another, there’s nothing as inefficient as disconnected documents. Not only are they a strain to keep organized in big filing cabinets or file folders, but they take a long time to create, share and edit. It seems cliche to harp on this point in 2018; yet, many food safety coordinators have a purely manual system.

By connecting your entire company to an online database, you enable different departments to organize, share and update documents in seconds, rather than minutes. This level of connectivity can shave time off dozens of tasks per day, which ultimately leads to hours or days of extra productivity over the course of a year. When you adopt a system that updates connected documents in real time, you won’t have to make manual changes to multiple documents for small changes. If you want to get extra efficient, the real trick to this best practice is to find software that you can incorporate into every department. Then, as people go about their normal jobs, the information they collect is automatically uploaded to the central database.

Utilize the Internet Of Things to Streamline Data Collection
These days, it’s possible to connect almost every piece of equipment to the Internet of Things. Even if your machinery doesn’t have measurement tools built-in, there are almost certainly additional tools you can install to create that functionality.

Having your equipment feed data directly into your central database is faster than manually collecting information and eliminates the risk of human error when it comes to data entry. Thanks to that simple degree of automation, already standard in large parts of the global economy, you can also use system dashboards and alerts that let you know when something’s off, like the temperature in the freezer or the production speed of equipment on the floor.

Don’t Settle for Uninspired Internal Audits
Many food safety coordinators are so focused on specific issues that they forget to take steps back to look at the situation from a bird’s eye view. When the time for an internal audit comes around, they do it with one eye on the audit and one eye on the next fire that needs putting out.

Lazy internal audits are not only noticeable to external auditors, they keep you in the dark about what’s really happening in your facility. Here are a few ways you can ensure your internal audit empowers you rather than slows you down:

Schedule the internal audit ahead and make it immovable

  • Plan out your scope, objectives and process to establish momentum and direction
  • Dedicate your full attention to running the audit and managing relevant staff
  • Report your findings in detail and discuss with necessary employees
  • Schedule and verify corrective actions

A well-performed internal audit is a powerful way to regroup, refresh goals and stay on track.

Train All Employees for Go-Time
Do you know which employees an auditor is allowed to interview? Any of them. No person is disqualified from interviews, which means every employee needs to be well trained on food safety procedures. While most facilities only train employees until they know the basics of food safety for their department, going above and beyond here can have some major gains.

Consider the perspective of the auditor. When they are asking your employees questions, they’re not just trying to complete a basic inspection. They want to see signs that you haven’t done the bare minimum, but that your employees are immersed in a food safety culture, that they have been receiving training long-term, and that food safety is a fundamental value of your company.

When auditors get the sense that your employees are up-to-speed, things tend to go a little smoother, stress levels lower, and the auditor becomes less suspicious.

Give Food Safety Coordinators the Appropriate Authority (and Budget)
One issue that many facilities run into is an unempowered food safety coordinator. When that person discovers ways to improve or correct operations or employees that are not following protocol, he or she is often unable to take the appropriate action.

Hazards aren’t the only things that need corrective actions from time to time. Sometimes employees need to face consequences for compromising the production area with food or for haphazardly completing safety-related tasks. Other times, employees don’t have the necessary software or equipment to perform their job well and even though their managers may be aware, they don’t allocate the appropriate budget to improve the situation. In order for any company to thrive, standards must be enforced by relevant leaders; and there’s no one better to call the shots on food safety than the designated coordinator.

Establish a Company-Wide Food Safety Culture
When it comes down to it, companies that value food safety thrive. Companies that consider food safety an annoying task to check off the list—they’re the ones that run into extra trouble.

Building food safety into your company’s system of values starts at the very beginning with how you train your new hires. It continues on into how you provide ongoing training even to experienced employees. It’s not an item on the list of meeting topics; it’s a value that underscores the entire agenda.

In order for this approach to be successful, it has to start at the top. Facility owners and managers that value food safety will organically pass that on to the people below them. But when the upper levels can’t be bothered with food safety, the entire organization struggles to hold onto it as a value.

Some of these best practices you can start working on tomorrow; others will take time to implement. Embedding these into your company can be a long road, so keep your eye on the prize: A safe, efficient food safety program that impresses auditors and keeps things running smoothly.

Article Source: https://foodsafetytech.com/column/six-best-practices-to-make-audits-stress-free/

Saturday, April 21, 2018

SQF Food Safety Code for Food Manufacturing - 2 day course - Special $125 Pricing!!


Wed, May 9, 2018, - Thu, May 10, 2018
8:00 am - 5:00 pm

Napa Valley College 
2277 Napa Vallejo Highway Bldg 3000, Rm 3004 
Napa, CA 94558 


DESCRIPTION

Attention food manufacturing professionals!

SQF Code, Edition 8 introduces a new approach for assessing individual food industry sectors with customized requirements in separate, stand-alone codes: Food Safety Fundamentals, Primary Production (Produce), Manufacturing, Distribution, Food Packaging, Retail, and Quality.

Attend this two-day course offered by Napa Valley College.

Course Description - What You'll Learn:

  • The updates and implications of the updates in Edition 8 of the SQF Code from the former Edition 7.2.
  • Implementing and maintaining an SQF system and its mandatory elements.
  • Validating and verifying your food safety plan within the SQF system and meeting FSMA requirements.
  • Undertanding the process for aligning with FSMA regulatory requirements.
  • Overview of the SQF certification process.
  • How a HACCP-based approach manages food safety and quality hazards in an operation.
  • The SQF Food Safety Code for Manufacturing as it applies specifically to Food Sector Categories 7-22, 31-34. This includes Modules 2 (Systems Elements) and Module 11 (Food Safety Fundamentals for Food Manufacturing).

Who Should Attend?

SQFP, Food Safety Professionals, Sr. Management, Suppliers, Food Safety Auditors, Support Staff. This course is designed to provide current and new SQF Practitioners, Sr. Management, Production Personnel, and their team members with the tools and knowledge to develop and maintain their SQF food safety management system and understand the process for aligning with FSMA regulatory requirements.

Two Day Course: May 9 to May 10, 8:00 AM to 5:00 PM each day.

Price: Only $125 for an entire 2-day course thanks to special grant funding.

Price Includes: Event registration, morning and afternoon snack breaks, lunch for both days, course materials and certificate of attendance.

Questions? Contact Charlie Monahan at 707-256-7254 or cmonahan@napavalley.edu.

Wednesday, April 18, 2018

Internal and External GFSI Audits Workshop - Only $125 - Register Today!



Internal and External GFSI Audits Workshop - 1 day course 

Fri, May 11, 2018 
8:00 AM – 5:00 PM 

Napa Valley College 
2277 Napa Vallejo Highway Rm 3004 Napa, CA 94558

Register HERE

Attention food manufacturing and processing professionals!

Learn all about Internal and External Global Food Safety Initiative (GFSI) Audits and food safety management systems, including:
  • Good Manufacturing Practices and Good Agricultural Practices
  • Hazard Analysis and Critical Control Point (HACCP) Program Development
  • ISO-19011 Auditing Principles
  • GFSI schemes (SQF, BRC, FSSC2200, Global G.A.P.) from the auditor point of view

This workshop complies with the training requirements for GFSI professionals and Internal auditors for GFSI approved schemes (SQF, BRC, FSSC22000, Global G.A.P. among others)

Who Should Attend?
Food Safety Professionals, Sr. Management, Suppliers, Food Safety Auditors, Support Staff.

One Day Course: May 11, 8:00 AM to 5:00 PM.

Price: Only $125 for the entire 1-day course thanks to special grant funding.

Price Includes: Event registration, morning and afternoon snack breaks, lunch, course materials and certificate of attendance.

Questions? Contact Charlie Monahan at 707-256-7254 or cmonahan@napavalley.edu.

Sunday, April 15, 2018

Current 2018 Classes - Special Pricing for May


SQF Food Safety Code For Manufacturing Edition 8 
($125 Special Price!) 

GFSI Internal & External Audit Workshop 
($125 Special Price!)

Monday, April 9, 2018

Internal and External GFSI Audits Workshop - Only $125!!



Internal and External GFSI Audits Workshop - 1 day course 

Fri, May 11, 2018 
8:00 AM – 5:00 PM 

Napa Valley College 
2277 Napa Vallejo Highway Rm 3004 Napa, CA 94558

Attention food manufacturing and processing professionals!

Learn all about Internal and External Global Food Safety Initiative (GFSI) Audits and food safety management systems, including:
  • Good Manufacturing Practices and Good Agricultural Practices
  • Hazard Analysis and Critical Control Point (HACCP) Program Development
  • ISO-19011 Auditing Principles
  • GFSI schemes (SQF, BRC, FSSC2200, Global G.A.P.) from the auditor point of view

This workshop complies with the training requirements for GFSI professionals and Internal auditors for GFSI approved schemes (SQF, BRC, FSSC22000, Global G.A.P. among others)

Who Should Attend?
Food Safety Professionals, Sr. Management, Suppliers, Food Safety Auditors, Support Staff.

One Day Course: May 11, 8:00 AM to 5:00 PM.

Price: Only $125 for the entire 1-day course thanks to special grant funding.

Price Includes: Event registration, morning and afternoon snack breaks, lunch, course materials and certificate of attendance.

Questions? Contact Charlie Monahan at 707-256-7254 or cmonahan@napavalley.edu.

Tuesday, April 3, 2018

Internal and External GFSI Audits Workshop - Only $125!!



Internal and External GFSI Audits Workshop - 1 day course 

Fri, May 11, 2018 
8:00 AM – 5:00 PM 

Napa Valley College 
2277 Napa Vallejo Highway Rm 3004 Napa, CA 94558

Attention food manufacturing and processing professionals!

Learn all about Internal and External Global Food Safety Initiative (GFSI) Audits and food safety management systems, including:
  • Good Manufacturing Practices and Good Agricultural Practices
  • Hazard Analysis and Critical Control Point (HACCP) Program Development
  • ISO-19011 Auditing Principles
  • GFSI schemes (SQF, BRC, FSSC2200, Global G.A.P.) from the auditor point of view

This workshop complies with the training requirements for GFSI professionals and Internal auditors for GFSI approved schemes (SQF, BRC, FSSC22000, Global G.A.P. among others)

Who Should Attend?
Food Safety Professionals, Sr. Management, Suppliers, Food Safety Auditors, Support Staff.

One Day Course: May 11, 8:00 AM to 5:00 PM.

Price: Only $125 for the entire 1-day course thanks to special grant funding.

Price Includes: Event registration, morning and afternoon snack breaks, lunch, course materials and certificate of attendance.

Questions? Contact Charlie Monahan at 707-256-7254 or cmonahan@napavalley.edu.

Saturday, March 31, 2018

FSMA: What Does ‘Qualified’ Mean?


The term “qualified” appears a few different ways in the FSMA rules. In a Q&A with Food Safety Tech, Cathy Crawford, president of HACCP Consulting Group, was invited by DNV-GL to clear up some of the ways the term is used in the FSMA rules.

Food Safety Tech: Can you break down the difference what “qualified” means as it relates to a qualified individual, qualified auditor and qualified facility?

Cathy Crawford: Explaining the term happens all at once. I think it’s not clear in the preventive controls or sanitary transportation [FSMA] rules; they use the word in two different ways. “Qualified” sometimes means that you’re officially recognized as trained or suitable for something, but “qualified” can also mean modifications or limitations or exceptions. That’s why it is confusing, because it can seem like it has opposite meanings.

“Qualified” [means] trained or ready to do a certain job—that’s the most common meaning. The preventive controls rule talks about a qualified individual, as a person who has the training, education or combination of those needed to manufacture, process or hold food. That’s appropriate to their duties—meaning not everyone has to be qualified to do everything, but individuals have to be qualified when it comes to doing their job when it pertains to food safety.

The regulation goes on to say that it might be education and experience, but there is also some mandatory training. I think a lot of companies aren’t paying attention to this—that all qualified individuals have to be trained in food safety, hygiene and the specific duties of their job, and because that’s a regulatory requirement, they have to have documentation to support that they did this. The regulation also says that supervisors should have the education or experience necessary to supervise, so their training should demonstrate that it’s a little more in depth than what other qualified individuals would get.

Then there’s the PCQI, the preventive controls qualified individual. That’s someone with the education, experience or training to be able to perform specific functions that are called out in the preventive controls rule—meaning they can create a food safety plan, they can conduct or oversee verification, validation and corrective action, or they can reanalyze the food safety plan. The regulation specifically says the PCQI has to do those things. So that’s a different sort of qualified individual; it’s another step basically.

The other term is the qualified auditor. That definition starts with a qualified individual (QI) and elevates from QI to supervisor to PCQI and then to a qualified auditor. A qualified auditor is a QI who has the technical experience needed to conduct audits. That’s about as far as it goes in the regulation, except that they give examples such as that it could be a government employee or an agent of a certification body, but you have to take it in context. The regulation doesn’t say those are the only examples, so I think there’s some flexibility in those examples, and we have yet to see how FDA is going to implement the rule going forward.

When we talk about these qualified individuals, we mostly think about the preventive controls rule, but it also pops up in the sanitary transportation rule. In that rule, the term isn’t defined at all, so I suspect they would share the definition that’s in the preventive controls rule for a qualified individual. But under the sanitary transportation [rule], only the qualified individual can make decisions about what to do when there is an unusual circumstance in transportation such as an accident or a refrigeration unit that breaks down.

FST: Can a “qualified” person be company staff or is there an inclusion that someone can be brought in to take care of these duties, for example, on an outsourcing basis?

Crawford: That’s certainly an option. I haven’t experienced any companies that have chosen that option. I suspect maybe smaller companies or those that are members of a strong affiliation like a coop or trade association might reach out to get someone to play the role of PCQI. But it’s a very significant role, and there’s a certain level of responsibility and therefore liability associated with it, so I think it’s best that the person is a company employee.

I also highly recommend training. Although the two-and-a-half-day class on the preventive controls rule isn’t technically mandatory, it’s extraordinarily helpful.

At first when our company (as a consulting group) was teaching this course, many of the classes contained 50% or more of participants from FDA. It was interesting because industry and FDA were learning together. I think most companies are sending one or two people so they can get the information and share it when they come home.

FST: Discuss some of the confusion surrounding the term “qualified facilities”.

Crawford: This is where “qualified” has almost the opposite meaning. Here’s an analogy: There’s the concept of a lifeguard—you can be qualified to be a lifeguard like a person can be a qualified individual in a food facility, but you could also have a qualified lifeguard certificate, which means you’re limited and can only do lifeguarding when there’s no more than 25 people in the pool; versus someone who has more training and can do it anytime. It’s a limitation.

In the regulation, a facility is the qualified facility when it meets certain characteristics that don’t have to follow the entire rule, but can follow a smaller piece of it.

“Qualified” is based on size. If a facility is very small, with inventory less than $1 million in food assets and sales annually, then they are a qualified facility, so they don’t have to follow the entire preventive controls. They follow a modified version, which is primarily around having the GMPs in place but not necessarily having a food safety plan like the larger facilities must have.

FST: When a company is uncertain about their status, where can they go to get help?

Crawford: Many companies ask their own attorneys and FDA. The FDA has a website called the TAN (Technical Advisory Network) where companies or citizens can submit questions. It takes a bit of time but you will get an answer, and that’s a good way to go.

FST: With all the differences and nuances in these terms, what can companies do to better familiarize themselves with what these terms mean as they relate to FSMA so they can effectively execute required tasks?

Crawford: Number one: Either read the regulation on your own or attend the class that goes over the regulation like the two-and-a-half-day preventive controls course.

Second, companies need to document their training activities, because it’s required to demonstrate that someone is qualified. FDA has said they don’t intend to visit a facility and then document a 483 due to lack of a PCQI or a QI. That’s not the focus of their inspection—it’s an important part of the regulation, but they wouldn’t write a 483 just for missing training records. What they’re looking for is an effective system. If they visit and the system isn’t in place or it’s not documented, then they might back up and realize the reason it wasn’t done right is because they don’t have a QI or PCQI.

Finally, understand the terms, and make sure you have qualified people in place and that you can prove with records that they really are qualified.

Article Source: https://foodsafetytech.com/news_article/fsma-qualified-mean/

Sunday, March 25, 2018

FDA Releases 2017 Retail Food Program Standards

The FDA encourages any government agency to enroll in the standards if they are involved in the regulation or oversight of retail establishments selling, serving or vending food.


FDA has released the 2017 edition of the Voluntary National Retail Food Regulatory Program Standards. These retail program standards offer recommendations for designing and managing retail food regulatory programs, help regulatory agencies pinpoint areas of improvement for the programs, and enable effective strategies for inspections and foodborne illness prevention.

“The FDA encourages government agencies responsible for regulation or oversight of the retail food establishments that sell, serve or vend food directly to the public to enroll in the Retail Program Standards. Enrollment in the Retail Program Standards conveys a jurisdiction’s intent to actively use the Retail Program Standards as a tool to assess and improve its retail food regulatory program.” – FDA

Changes to the 2017 edition of the retail program standards include:

  • Updates to the definition of the training standard
  • Clarifying the standardizing and re-standardizing criteria for food safety inspection officers
  • Aligning program elements between the Retail Program Standard 4 and Retail Program Standard 2 regarding performance elements and competencies
  • Incorporating more methods of communication efforts with industry and the community
  • Consolidating report forms and FDA forms 3519 and 3520 into one FDA Form 3598

Friday, March 16, 2018

On-site PRIVATE Classes in English & Spanish and Consulting Services


Classes Available in English & Spanish and Consulting Services

WE OFFER PUBLIC AND ON-SITE TRAINING CLASSES:
  • HACCP Workshop
  • Implementing SQF Training - Version 8.0 - English and Spanish
  • FSMA Preventive Controls for Human Foods
  • FSPCA For Human Food Compliance
  • Produce Safety Rule Training Official Program
  • SQF Quality Systems For Food Manufacturers
  • Internal and External GFSI Audits
  • Crisis Management
  • Gluten Free Certification Program
  • SQF Advance Practitioner Course
  • Prerequisite Programs

WE ALSO OFFER:

  • Food Safety Consulting Services

Please visit our website or send us an email for more information!

Saturday, March 10, 2018

Current 2018 Classes


Current 2018 Classes - Enroll Now!

FSPCA Preventive Controls For Human Food
March 14th-16th 2018 Napa CA
($150 Special Price)

SQF 8 Quality Systems For Food Manufacturers

SQF Food Safety Code For Manufacturing Edition 8

GFSI Internal & External Audit Workshop

Thursday, March 8, 2018

Pork And Chicken Empanadas RECALL


The US Dept. of Agriculture's Food Safety and Inspection Service (FSIS) announced the recall of 19,757 lbs. of pork and chicken empanadas by Linden, New Jersey-based Saker ShopRites Inc. due to misbranding and an undeclared allergen. The products contain egg, a known allergen, which is not listed in the ingredient statement on the label.

The fully cooked empanadas were produced between Oct. 7, 2017 and Feb. 12, 2018. The following products are subject to recall: Click here for list

Sunday, March 4, 2018

Update to Nutrition Facts Label Sheds More Light on Added Sugars


Yesterday FDA Commissioner Scott Gottlieb, M.D. issued a statement about updates to the Nutrition Facts label for foods. The latest label uses evidence-based information about nutrients, including added sugars, to heighten consumer awareness related to the amount of added sugars in foods, especially as it relates to dietary guidance recommendations.

One of the important factors in ensuring successful implementation of the label is that FDA provides food manufacturers with clear guidance on how to make the required changes to their labels to meet the compliance deadline. Last year FDA proposed extending the compliance date from July of this year until January 1, 2020 for large manufacturers ($10 million+ in annual sales) and January 2021 for small companies.

“We’re equally committed to providing industry the information they need to effectively implement the new version of the Nutrition Facts label in a timely fashion. Today we issued practical guidances that provide further clarity on several key elements, including fiber, added sugars and serving size declarations.” – Scott Gottlieb, M.D., FDA

FDA also released the final guidance, “Food Labeling: Serving Sizes of Foods That Can Reasonably Be Consumed At One Occasion; Dual-Column Labeling; Updating, Modifying, and Establishing Certain Reference Amounts Customarily Consumed; Serving Size for Breath Mints; and Technical Amendments; Small Entity Compliance Guide”, along with a draft guidance to assist manufacturers in declaring added sugars on labeling honey, maple sugar and certain cranberry products.

Article Source: https://foodsafetytech.com/news_article/update-nutrition-facts-label-sheds-light-added-sugars/

Thursday, March 1, 2018

Still Time to Register and Get Special Pricing!


FSPCA Preventive Control for Human Food 

DATE AND TIME
Wed, Mar 14, 2018, 8:00 AM –
Fri, Mar 16, 2018, 5:00 PM PDT

LOCATION
Napa Valley College
2277 Napa Vallejo Highway
Room 3004
Napa, CA 94558

Only $150!!


DESCRIPTION
The FSPCA training materials are designed to meet the requirements for training under Title 21 Code of Federal Regulations Part 117.155 for the Preventive Controls “Qualified Individual” who conducts Food Safety Plan activities such as developing and reviewing a food safety plan, validating preventive controls, verifying and validating process controls among others. Attending an FSPCA course will provide assurances that the course content and resulting knowledge is consistent with regulatory expectations. Each facility registered with the FDA is required to have a Preventive Control Qualified Individual PCQI.

A preventive controls qualified individual is a person who has successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under the standardized curriculum from FSPCA.

The FSPCA program is based on collaboration among federal and state regulatory officials (FDA), academic food safety researchers and educators, and U.S. food industry representatives. This program is delivered by a FSPCA Lead Instructor.

This course meets the Preventive Controls Qualified Individual Training requirements. The participants will receive FSPCA Preventive Controls Qualified Individual certificate issued by AFDO.

Includes: Morning and afternoon snack breaks, Lunch, Course Materials and Certificate of Attendance.

Monday, February 26, 2018

Great Turnout for Our FSPCA Training for Fiesta Canning in Arizona!

Thank you to those that were able to attend our recent FSPCA Training for Fiesta Canning in Arizona taught in Spanish. 
To learn more and register for any of our upcoming classes, please visit our website: http://superiorfoodsafety.com/



Friday, February 23, 2018

FDA Food Recalls Up Nearly 93% Since 2012

Bacterial contamination and undeclared allergens lead the way in causes.


Over the past five years, the food and beverage industry has seen a big increase in the units recalled—a 92.7% spike in FDA recalls and an 83.4% increase in recalled pounds by USDA since 2012, according to Stericycle’s quarterly recall index. The firm cites technological advances in food testing, factory farming and more automation in food production as the main contributors to the high numbers.

During Q4 2017, bacterial contamination and undeclared allergens led the pack in food recall causes. According to Stericycle, back in 2012, about 28% of FDA food recalls were a result of bacterial contamination, while undeclared allergens accounted for 35% of pounds of food recalled by USDA. During Q4 2017, 44% of food recalls (based on units) were from bacterial contamination, followed by undeclared allergens (31%), mislabeling (13%), and quality (10%). Among the top categories for recalls were prepared foods (20%, nuts and seeds (16%), produce (15%) and baked goods (12%). In addition, nearly 50% of the USDA recalled pounds were a result of lack of inspection.

Article Source: https://foodsafetytech.com/news_article/fda-food-recalls-nearly-93-since-2012/

Tuesday, February 20, 2018

On-site PRIVATE Classes in English & Spanish and Consulting Services


Classes Available in English & Spanish and Consulting Services

WE OFFER PUBLIC AND ON-SITE TRAINING CLASSES:
  • HACCP Workshop
  • Implementing SQF Training - Version 8.0 - English and Spanish
  • FSMA Preventive Controls for Human Foods
  • FSPCA For Human Food Compliance
  • Produce Safety Rule Training Official Program
  • SQF Quality Systems For Food Manufacturers
  • Internal and External GFSI Audits
  • Crisis Management
  • Gluten Free Certification Program
  • SQF Advance Practitioner Course
  • Prerequisite Programs

WE ALSO OFFER:

  • Food Safety Consulting Services

Please visit our website or send us an email for more information!

Saturday, February 17, 2018

FSPCA Preventive Controls For Human Food - March 14-16 - Only $150!!


FSPCA Preventive Control for Human Food 

DATE AND TIME
Wed, Mar 14, 2018, 8:00 AM –
Fri, Mar 16, 2018, 5:00 PM PDT

LOCATION
Napa Valley College
2277 Napa Vallejo Highway
Room 3004
Napa, CA 94558

Only $150!!


DESCRIPTION
The FSPCA training materials are designed to meet the requirements for training under Title 21 Code of Federal Regulations Part 117.155 for the Preventive Controls “Qualified Individual” who conducts Food Safety Plan activities such as developing and reviewing a food safety plan, validating preventive controls, verifying and validating process controls among others. Attending an FSPCA course will provide assurances that the course content and resulting knowledge is consistent with regulatory expectations. Each facility registered with the FDA is required to have a Preventive Control Qualified Individual PCQI.

A preventive controls qualified individual is a person who has successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under the standardized curriculum from FSPCA.

The FSPCA program is based on collaboration among federal and state regulatory officials (FDA), academic food safety researchers and educators, and U.S. food industry representatives. This program is delivered by a FSPCA Lead Instructor.

This course meets the Preventive Controls Qualified Individual Training requirements. The participants will receive FSPCA Preventive Controls Qualified Individual certificate issued by AFDO.

Includes: Morning and afternoon snack breaks, Lunch, Course Materials and Certificate of Attendance.

Wednesday, February 14, 2018

USDA PDP Report: Farmers Doing a Good Job Complying with Regulations


Fruit and vegetable farmers are doing an “impressive” job of complying with the laws and regulations related to pesticide use in production, according to the USDA’s annual Pesticide Data Program (PDP) report. Based on data from 2016, the report found that more than 99% of samples had pesticide residues that were “well below” the EPA’s established tolerances, and more than 23% had no detectable residues. Less than half-a-percent of samples (0.46%) had residues that exceeded the EPA established tolerance.

To compile the PDP report, surveys were conducted in 2016 on several foods, including eggs, milk, and fresh and processed fruit and vegetables. The report contains data from more than 10,000 samples collected throughout the United States.

A release from the Alliance for Food and Farming states that the U.S. food supply is one of the safest in the world, yet: “Activists groups often manipulate the findings from the USDA PDP report taking the very positive results and somehow turning them into something negative. This tactic has been used routinely for 20-plus years to create a so-called ‘dirty dozen’ list, which has been repeatedly discredited by scientists.”

Article Source: https://foodsafetytech.com/news_article/usda-pdp-report-farmers-good-job-complying-regulations/

Sunday, February 11, 2018

FSPCA Preventive Controls For Human Food - March 14-16 - Only $150!!


FSPCA Preventive Control for Human Food 

DATE AND TIME
Wed, Mar 14, 2018, 8:00 AM –
Fri, Mar 16, 2018, 5:00 PM PDT

LOCATION
Napa Valley College
2277 Napa Vallejo Highway
Room 3004
Napa, CA 94558

Only $150!!


DESCRIPTION
The FSPCA training materials are designed to meet the requirements for training under Title 21 Code of Federal Regulations Part 117.155 for the Preventive Controls “Qualified Individual” who conducts Food Safety Plan activities such as developing and reviewing a food safety plan, validating preventive controls, verifying and validating process controls among others. Attending an FSPCA course will provide assurances that the course content and resulting knowledge is consistent with regulatory expectations. Each facility registered with the FDA is required to have a Preventive Control Qualified Individual PCQI.

A preventive controls qualified individual is a person who has successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under the standardized curriculum from FSPCA.

The FSPCA program is based on collaboration among federal and state regulatory officials (FDA), academic food safety researchers and educators, and U.S. food industry representatives. This program is delivered by a FSPCA Lead Instructor.

This course meets the Preventive Controls Qualified Individual Training requirements. The participants will receive FSPCA Preventive Controls Qualified Individual certificate issued by AFDO.

Includes: Morning and afternoon snack breaks, Lunch, Course Materials and Certificate of Attendance.

Thursday, February 8, 2018

Current 2018 Classes


Current 2018 Classes - Enroll Now!

FSPCA Preventive Controls For Human Food

SQF 8 Quality Systems For Food Manufacturers
*DATE CHANGE

SQF Food Safety Code For Manufacturing Edition 8

GFSI Internal & External Audit Workshop

Monday, February 5, 2018

USDA Proposes Rule to Make Egg Products Safer

Plants would need to establish HACCP systems and sanitation SOPs.


Earlier this week the USDA’s FSIS proposed to amend inspection regulations, modernizing food safety inspection systems, in an effort to make egg products safer. It would require official plants that process egg products to develop HACCP systems, sanitation standard operating procedures and meet sanitation requirements consistent with meat and poultry regulations.

“FSIS is proposing that official plants will be required to produce egg products in such a way that the finished product is free of detectable pathogens,” according to a USDA news release. “The regulatory amendment also uses agency’s resources more efficiently and removes unnecessary regulatory obstacles to innovation.”

FSIS will also be taking over jurisdiction of egg substitutes.

According to the agency, the financial impact of the proposed rule could be minimal, as it states 93% of egg products plants already have a written HACCP plan that deals with at least one production step in the process.

Once published in the Federal Register, a 120-comment period will go into effect.

Article Source: https://foodsafetytech.com/news_article/usda-proposes-rule-make-egg-products-safer/

Saturday, February 3, 2018

On-site PRIVATE Classes in English & Spanish and Consulting Services


Classes Available in English & Spanish and Consulting Services

WE OFFER PUBLIC AND ON-SITE TRAINING CLASSES:
  • HACCP Workshop
  • Implementing SQF Training - Version 8.0 - English and Spanish
  • FSMA Preventive Controls for Human Foods
  • FSPCA For Human Food Compliance
  • Produce Safety Rule Training Official Program
  • SQF Quality Systems For Food Manufacturers
  • Internal and External GFSI Audits
  • Crisis Management
  • Gluten Free Certification Program
  • SQF Advance Practitioner Course
  • Prerequisite Programs

WE ALSO OFFER:

  • Food Safety Consulting Services

Please visit our website or send us an email for more information!

Friday, February 2, 2018

Can You Defend Your Food Safety Plan?

Successfully doing so could be the difference between a routine audit and a recall.


As a food safety plan manager, do you ever get asked these questions regarding your food safety plan: What was your thought process for making this decision? Why do you do it this way? How do you answer this?

And, do you ever answer with one of the following statements:

  • I’m not sure? What do you mean?
  • That’s the way it has always been.
  • Our customer asked us to do it that way.
  • That’s what our last auditor recommended.
  • We make a low-risk product.

If this is one of your answers, defending your food safety plan may be a challenge. There is a major shift taking place in the world of food safety. With the implementation of FSMA Preventive Controls, the widespread adoption of GFSI audits, along with advanced technologies such as rapid pathogen and allergen detection, whole genome sequencing, and transparency efforts such as Blockchain, as well as with the increasing use of social media and access of information via the internet, food industry professionals are more educated and informed than ever before and ready to challenge your every move. As a food safety plan manager, you and your team must be ready! Being prepared to defend your food safety plan can be the difference between a recall and a routine audit. If you cannot fully explain the reasoning behind your decision-making, then how will you be able to prove that you are in complete control and are being proactive against food safety hazards? It will not be easy.

You must be ready to defend each and every part of your food safety plan. You must be able to defend questions and challenges with certainty and facts. Every decision made in your hazard analysis should be written down and backed with factual evidence whenever possible. Even the “none identified” areas should be backed by strong reasoning if no other factual evidence is available. You can use the data that you collect daily to help justify your decisions. Data collected from your prerequisite programs (ATP swab results, allergen cleaning validations, GMP audit findings, pest control trends, etc.) and food safety plan (CCP’s, validations, verifications) is all support for your decisions. Have this on file and ready to review when necessary.


If something looks out of the ordinary in your plan, make sure you can fully explain it and can back it with solid justification. If not, auditors, regulators, customers, etc. may start to become suspicious, which can lead to unwanted questions. You will then oftentimes start to get suggestions for change based on others’ individual expertise. Regulators may make “strong suggestions” for changes, for instance, and some people will just go along with it to avoid the pushback or because they simply don’t have a better solution. If this happens, soon your plan is no longer yours—it’s everyone’s. Some of these suggestions may be good, but is it really the right change for your plan? If not, it will often make the plan less rational and often difficult to defend.

The following are tips to help you avoid this situation.

  1. Meet with your food safety team regularly. Go through each part of your food safety plan and figure out how to answer the “why’s”. Why are things done this way? Why did we decide if this hazard was significant or not? Have annual reviews to make sure your plan is still functioning as originally intended and review new industry trends to be proactive regarding new potential hazards.
  2. Write a process narrative. Writing a process narrative documenting what happens at each step of your process and explaining your “thought process” for making decisions is a great support tool. It gives your team a chance to elaborate on the “justification” column in the hazard analysis, providing more decision-making details without crowding the hazard analysis form.
  3. Gather supporting documents. Scientific studies, guidance documents, expert opinions, etc. are vital pieces to have in your supporting documents library. Make sure it is appropriate for your individual products and the documents are from reputable sources, such as FDA, USDA, universities, process authorities, etc. Oh, and don’t forget about history! A reputable supplier with a long track record of safe product, a low history of recalls for the products you produce, etc. can help justify your decision-making.
  4. Conduct Internal Audits. Having an internal audit schedule and well-trained internal auditors help with finding inconsistencies within your program and allow you to make corrections before outside parties find these issues.
  5. Prepare. Have a “mock audit” and prepare for questions that are commonly asked during audits. Practice your answers and make sure you have supporting evidence when needed. Stay up-to-date with industry trends, especially common audit non-conformances.
  6. Be organized. It’s great to have all the supporting documents that you need, but if you cannot find them, then you just as well have nothing.
  7. Be confident. People, especially experienced auditors and inspectors, can quickly sense fear and lack of confidence. This often prompts more questions. Knowledge is power, and knowledge also builds confidence. Simply put, the more knowledgeable you are about your food safety plan, the more confident you will be when someone is trying to test you.
  8. Continuously Improve. It’s understandable that mistakes will be made. However, the next logical question you will be asked is: What did you do about it? Remember, for every nonconformance you find in your system, there should be a correction or corrective and preventive action to address it. It must not simply restate the problem, but legitimately correct the issue. This will give regulators, auditors, customers and anyone else looking at your system confidence that you are in control and can provide a consistently safe product.