Tuesday, May 30, 2017

FSMA Brief: Industry Challenged by Training and Produce Safety Rule

Companies are struggling with the cost of resources, and how and which regulatory rules apply to them.

With several FSMA compliance dates now in effect, much of the focus is on where companies need help. According to Kathy Gombas, former deputy director at CFSAN, the industry is struggling with FSMA training. Many companies don’t understand the FSMA rule exemptions and supply chain requirements, and they just don’t know where to start. “Industry needs affordable and timely resources,” said Gombas during a panel discussion at the Food Safety Summit earlier this month. “There are a lot of tools out there, but they’re costly.”

Efforts are underway to address these challenges. FDA has issued more than a dozen guidance documents pertaining to the rule. In addition, tools such as model plans and templates can help companies with their food safety plans, and the agency is almost ready to publish a web-based food safety plan builder that will be freely accessible on FDA’s website, according to Gombas. Several sources of technical assistance are available, including state and trade associations, academia, and the technical assistance network (TAN). However, when companies have inquiries, the key is to provide them with a response in a timely manner, said Gombas.

The Produce Safety rule is another hot spot for hurdles. Although 90% of it aligns with Good Agricultural Practices that have been in place for more than a decade, industry’s response to the rule remains one of fear and confusion, said David Gombas, former vice president of technical services for the United Fresh Produce Association. “Water testing is probably the most complicated aspect of the regulation,” he said. The rule calls for testing procedures that many produce companies never had to conduct before. Some testing must be done within a certain period of time, and the lower number of testing labs in rural areas of the United States will pose a problem for some producers, warned David Gombas.

There is also confusion among producers regarding whether they should follow the Produce Safety Rule or the Preventive Controls rule, which could significantly impact the steps they must take to be in compliance of either rule. To further complicate matters, Gombas pointed out that many foreign suppliers aren’t even aware that they have to be in compliance with the rule. Finally, the Produce Rule does provide a lot of room for flexibility, so Gombas predicts much of the responsibility will fall on the agency inspectors and how they expect rule to be met.

Article Source: FoodSafetyTech.com

Saturday, May 27, 2017

Superior Food Safety's Recent Internal/External Audit GFSI Class

Oscar Camacho, Founder and CEO of Superior Food Safety, with the Staff of Gavina Plant, after teaching The Internal/External Audit GFSI class.

Wednesday, May 24, 2017

Superior Food Safety 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

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

Sunday, May 21, 2017

Reduce Foodborne Illness Causing Microorganisms through a Structured Food Safety Plan

In 2011 three U.S. government agencies, the CDC, the FDA and the USDA’s Food Safety Inspection Service (FSIS) created the Interagency Food Safety Analytics Collaboration (IFSAC). The development of IFSAC allowed these agencies to combine their federal food safety efforts. The initial focus was to identify those foods and prioritize pathogens that were the most important sources of foodborne illnesses.

The priority pathogens are Salmonella, E. coli O157:H7, Listeria monocytogenes and Campylobacter. To research the most important product sources, the three agencies collaborated on the development of better data collection and developed methods for estimating the sources of foodborne illnesses. Some of this research was to evaluate whether the regulatory requirements already in effect were reducing the foodborne pathogens in a specific product matrix. The collection, sharing and use of this data is an important part of the collaboration. For example, when the FDA is in a facility for routine audit or targeted enforcement, they will generally take environmental swabs and samples of air, water and materials, as appropriate, which are then tested for the targeted pathogens. If a pathogen is found, then serotyping and pulsed-field gel electrophoresis (PFGE) fingerprinting is performed, and this is compared to the information in the database concerning outbreaks and illnesses. This data collection enables the agencies to more quickly react to pinpoint the source of foodborne illnesses and thereby reduce the number of foodborne illnesses.

The IFSAC strategic plan for 2017 to 2021 will enhance the collection of data. The industry must be prepared for more environmental and material sampling. Enhancement of data collection by both agencies can be seen through the FSIS notices and directives, and through the guidance information being produced by the FDA for FSMA. Some examples are the raw pork products exploratory sampling project and the FDA draft guidance for the control of Listeria monocytogenes in ready-to-eat foods.

Starting May 1 2017, the next phase of the raw pork products exploratory sampling project will begin. Samples will be collected and tested for Salmonella, Shiga-toxin producing E. coli (STECs), aerobic plate count and generic E. coli. In the previous phase, the FSIS analyzed 1200 samples for Salmonella for which results are published in their quarterly reports. This is part of the USDA FSIS Salmonella action plan published December 4, 2013 in an effort to establish pathogen reduction standards. In order to achieve any objective, establishing baseline data is essential in any program. Once the baseline data is established and the objective is determined, which in this situation is the Health People 2020 goal of reducing human illness from Salmonella by 25%, one can determine by assessment of the programs and data what interventions will need to take place.

The FDA has revised its draft guidance for the control of Listeria monocytogenes in ready-to-eat food, as per the requirement in 21 CFR 117 Current Good Manufacturing Practice, Hazard Analysis and Risk-Based Preventive Controls for Human Foods, which is one of the seven core FSMA regulations. Ready-to-eat foods that are exposed to the environment prior to packaging and have no Listeria monocytogenes control measure that significantly reduces the pathogen’s presence, will be required to perform testing of the environment and, if necessary, testing of the raw and finished materials. Implementing this guidance document helps the suppliers of these items to cover many sections of this FSMA regulation.

The purpose of any environmental program is to verify the effectiveness of control programs such as cleaning and sanitizing, and personnel hygiene, and to identify those locations in a facility where there are issues. Corrective actions to eliminate or reduce those problems can then be implemented. Environmental programs that never find any problems are poorly designed. The FDA has stated in its guidance that finding Listeria species is expected. They also recommend that instead of sampling after cleaning and/or sanitation, the sampling program be designed to look for contamination in the worst-case scenario by sampling several hours into production, and preferably, just before clean up. The suggestion on this type of sampling is to hold and test the product being produced and to perform some validated rapid test methodology in order to determine whether or not action must be taken. If the presence of a pathogen is confirmed, it is not always necessary to dispose of a product, as some materials can be further processed to eliminate it.

With this environmental and product/material testing data collected, it is possible to perform a trends analysis. This will help to improve sanitation conditions, the performance of both programs and personnel, and identity the need for corrective actions. The main points to this program are the data collection and then the use of this data to reduce the incidence of foodborne illness. Repeated problems require intervention and resolution. Changes in programs or training may be necessary, if they are shown to be the root cause of the problem. If a specific issue is discovered to be a supply source problem, then the determination of a suppliers’ program is the appropriate avenue to resolve that issue. Generally, this will mean performing an audit of the suppliers program or reviewing the audit, not just the certificate, and establishing whether they have a structured program to reduce or eliminate these pathogens.

IFSAC collected and analyzed previously collected data to assess if older programs, such as 21 CFR 118 production, storage and transportation of shell eggs, actually reduced the incidence of Salmonella enteritidis illnesses. This is a structure for the environmental testing of hen houses for this pathogen which, if found, requires the testing of the eggshells for the same pathogen. If the pathogen is found on the eggshells of a product destined for the processing market, a kill step can be performed to eliminate it and avert consumer illness. The review of this data proved that this program and other interventions have been effective in reducing illness caused by Salmonella enteritidis from eggs.

Data collection to reduce the incidence of foodborne illnesses is taking place in many locations. The Food Standards Agency (FSA) in the United Kingdom has been monitoring Campylobacter in chickens since 2014. FSA sampling was performed at the retail level. By sampling and testing, then working with the industry and retailers, the percentage of chickens testing positive for Campylobacter has been reduced from 78% in 2014 to 56% in 2016. The level of chicken with more than 1000 cfu/g of campylobacter reduced from 20% in 2014, to 7% in 2016. Additionally, by working with consumers to improve kitchen practices, the surveillance agencies have reported a 17% reduction in foodborne illness related to Campylobacter contamination (see Figure 1).1
Figure 1. From 2014–2016, laboratory reports of human cases of campylobacter decreased in line with the proportion of chickens in the highest contamination band. 

The FSA will be changing the way it monitors Campylobacter levels on chicken so it can better focus on those processors that are not making significant improvements in their reduction of this pathogen.

Sampling and testing is just one of the many aspects of a good structured food safety plan. Process and program audits, training and other key elements are essential too, but sampling and testing is an area that is often neglected because of the fear of finding results that are out of compliance. This fear is not warranted. If the food safety plan is designed properly then these out of compliance results are used to perform continuous improvement in the food safety plan. Essentially, continuous improvement is necessary to become a major player in the industry, and this is how the most successful companies excel. Governments have shown that a structured plan that incorporates the correct sampling and testing will result in a reduction of foodborne pathogens. Although it is still essential that the materials be handled properly throughout the supply chain, it is also essential that consumers are trained to properly handle and/or cook these materials, as there is a risk involved with some raw ingredients. Foodborne pathogens are part of some products’ risk, and making a structured plan to reduce, and hopefully one day eliminate these pathogens, is an essential part of doing business.


  1. Food Standards Agency. (March 2017) “Latest figures reveal decline in cases of campylobacter”. Retrieved from https://www.food.gov.uk/news-updates/news/2017/16052/latest-figures-reveal-decline-in-cases-of-campylobacter 

Thursday, May 18, 2017

Safe Quality Institute Update

To all our valued clients:

Safe Quality Institute (SQFI) recently updated the SQF code from edition 7.2 to edition 8 and all SQF certified companies will need to be compliant by January 2, 2018.

January seems like quite a way out, but we all know how busy we get in the late Spring and Summer in the food industry.

So, that you can breeze through the compliance deadline by implementing all the changes ahead of time, we are at your service to help you achieve that objective. Changes to the Safe Quality Food standards will impact management commitment, food safety plan, supplier approval program, environmental monitoring program, food fraud issues, and allergens to name a few.

Don't feel overwhelmed. We are here to help. We can help you meet the deadline efficiently. Have new staff that need training too? No problem.

We provide On-site and Public Training in English and Spanish.

Call us at 707-628-2805, or email to Martha Camacho at: marthacamacho@superiorfoodsafety.com

Also, please visit our website: www.superiorfoodsafety.com

Thank you,

Martha Camacho
Director of Sales and Marketing
Superior Food Safety

Monday, May 15, 2017

Recall Consequences: What Consumers Think

The faster a food company addresses the problem, the better.

Consumer preferences have clearly shifted to a more personal, hands-on experience that requires food companies to maintain trust by being completely forthright about what is in their products. And when a company is involved in a recall, consumers expect a fast response—within days, according to a recent survey. Half of the survey participants expect a company to address a recall within one to two days. In addition, if a brand or restaurant has a recall or contamination that leads to illness, 23% said they would never use the brand or visit the restaurant again and 35% said they would avoid it for a few months and “maybe” come back.

The survey, commissioned by FoodLogiQ and titled, “What Consumers Care About in the Age of Transparency”, polled more than 2000 people. It also found that the same consumers who expect a one- to two-day turnaround in addressing a recall also care a great deal about clarity in food labeling: 57% want to see as much information on a label as possible. This includes country of origin, allergen information and identification of genetically modified ingredients.

With the number of recalls occurring four times as often as they did five years ago, food companies are at an even higher risk of facing a negative financial impact and losing consumer confidence. Maintaining transparency throughout the supply chain is a crucial part of managing consumer expectations and executing effective risk mitigation.

“Open, constant and transparent communication with your suppliers is a must for addressing these issues. After all, you can’t offer consumers the information they crave about your product and processes if you aren’t getting that information from your suppliers and brokers,” state the survey authors. “You cannot expect a supplier to fulfill your requirements around safety and brand promise if you aren’t open about your expectations. It’s a two-way relationship that can make a huge difference in your business.”

The authors offer recommendations on how companies can keep a clear line of communication open with consumers, including:

  • Transparency throughout the supply chain, including from where food is sourced
  • List all product ingredients and include information about allergens and animal products
  • Have open communication concerning mislabeling, and contamination and recalls

Friday, May 12, 2017

Upcoming Napa Valley Winery Events

Napa Valley College May 12th

Napa Valley Wine Library 27th Annual Wine Seminar May 13th

Dine & Donate with Puertas Abiertas May 17th

Rutherford Wine Experience VIP Welcome Reception May 19th

Rutherford Round-Up May 20th

To browse other upcoming events click HERE

Saturday, May 6, 2017

A New Era Of Food Safety Regulation Begins

This fall brings the first major compliance deadlines for rules promulgated under the Food Safety Modernization Act (FSMA), the most sweeping reform of U.S. food safety laws in over 70 years. Enacted in 2011 and now set to be implemented through seven major substantive rules-all issued within a 9-month period ending in May 2016-FSMA introduces a new era in food safety by focusing on preventing food safety risks rather than on responding to crises after they happen. As we enter the enforcement stage for the new rules, we consider the practical challenges of each rule and identify areas where enforcement may provide clarity, including in relation to one of the most difficult aspects of the final rules: regulation of the supply chain.

Read On....

Wednesday, May 3, 2017

FSPCA Preventive Controls For Human Food - Spanish - May 17,18,19, 2017

17 May 2017 - 19 May 2017
Pricing Info and Register HERE

3 sessions
#1. 17 May 2017, 8:00 AM 5:00 PM (PDT)
#2. 18 May 2017, 8:00 AM 5:00 PM (PDT)
#3. 19 May 2017, 8:00 AM 12:00 PM (PDT)

Hampton Inn & Suites 7194 Kathryn Ave, Fresno, CA 93722

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.