Classes

 

 

 

 

 

 

 

 

Environ Health Associates, Inc.

ACCREDITED HACCP COURSE

“APPLYING HACCP PRINCIPLES™ TO PRODUCE”

ü LEARN THE ELEMENTS OF HACCP

ü APPLY THEM IN YOUR OPERATION

ü REDUCE RISK AND IMPROVE EFFICIENCY

ü EARN RECOGNITION OF HACCP COMPETENCY

Class held Feb 13th and 14th 2014. THIS IS A 2 DAY *ADVANCED HACCP COURSE

Persons taking this course include:

Facility managers, production supervisors, quality assurance staff, trainers, food safety consultants, regulators and auditors responsible for food inspection

On Day 1, learn and apply methods to develop effective GAP and GMP programs and 1. Conduct a hazard analysis, 2. Identify critical control points, 3. Set limits, 4. Monitor the system, 5. Initiate corrective actions in your operation, 6. Verify and, 7. Document the system. On Day 2, learn the required features of the GFSI HACCP audit process, with a focus on verification and validation.

The HACCP Alliance Certification seal on the “Applying HACCP Principles™” course means it is the most recognized HACCP certified course offered to the food industry.

We designed Advanced Applying HACCP Principles™ for those seeking a higher level of HACCP competence: 

 (*A basic understanding of food safety management, GMP, GAP, and SOP is desirable before taking this course).

 

COURSE INSTRUCTOR

Roy E. Costa, RS, MS (MBA) Registered Sanitarian and President of Environ Health Associates, Inc. He is a retired Sanitation and Safety Supervisor and Education and Training Specialist with the Department of Business Regulation and the State of Florida Department of Health. Mr. Costa is a highly qualified food safety auditor, trainer, consultant, author and international presenter on the topics of food safety and HACCP.

COURSE SCHEDULE AND LOCATION

This 2-DAY course will be presented on FEBRUARY 13TH AND 14THat the *Clarion Hotel, Deland, Florida.  Day 1: Registration and reception at 7:30 AM, class 8 am to 5 pm. Day 2: Class from 8 am to 12 pm. Complimentary lunch from 12-1 on Day 1. Continental breakfast served each morning at 7:30 am.

 

*See attached hotel map, ask for special rate.

 

Class Registration Form: Call Katherine Jones at: 386-316-7266 or send message to

kjones.environhealthassociates@yahoo.com

 

Payment method: Bring company check to class; check made payable to Environ Health Associates, Inc.

Cost: $699.00 per person includes 2 continental breakfast and lunch.

FSMA Progresses but Confusion and Apprehension Build in the Produce Industry

I suppose anytime one enacts a sweeping new law that affects an entire industry we can expect an outcry from the newly regulated. When it comes to the US Food and Drug Administration’s Food Safety Modernization Act, this is no exception.

FSMA has been plodding along to its final conclusion in 2015, with FDA laying the ground work for what will be a long and difficult process of implementation of the rules.

See also:

http://www.foodsafetynews.com/2013/12/2013-was-a-big-year-for-fda/

While there has been progress in rulemaking with the release of two critical rules, preventive controls for human food, and produce safety, and five more, we have still have only a murky idea of the impact this legislation will have..

The produce rule is difficult to interpret. For example, the Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption contains provisions that apply to farms, but also exempts farms based on a number of factors, such as type of crop, size, ownership of growing areas and production facilities, as well as commercial vs noncommercial operations. With all the exemptions, it is a roll of the dice whether a farmer will need to comply with any, all, or part of the proposed rules.

Naturally, with the present uncertainty there is concern. Publically, the produce industry seems to begrudgingly accept FDA’s powers, but in private, produce industry professionals express doubt about FDA’s abilities to effectively carry out the regulation in such a vast industry, and few operators have actually read the rules, even though two key ones have been out for comments since Jan. 2013.

Some of the apathy is due to the major produce operators in large part having already applied most of the required food safety initiatives outlined in the rule. The larger firms in the industry adopted the main tenants of Good Agricultural Practices and Good Manufacturing Practices in the form of industry guidance and third party audit standards years ago. The problem now seems to be, as it was from the beginning, the so called small farmers and producers. Most of these minor suppliers have not been brought under the same requirements as those imposed upon major suppliers to the large retail stores. These are the produce suppliers who grow and handle products at the end of the supply chain. It includes facilities that store, re work and deliver products weeks after harvest directly to food service and small groceries. Currently, our third party system of food safety controls has not affected these operators, and thus the fear.

Some amount of fear may not be bad thing, however. In my experience, many of these operations are in poor condition and lack hygienic standards. I recently visited a wholesale distribution and cold storage facility in Miami. The operation handled flowers, plants and produce, commingling them! Re-packing was going on throughout this poorly kept operation on the tops of old boxes and wooden pallets. The dirty hands of the cloth gloved workers touching previously washed products while they graded out decayed and non conforming product, with no hand wash sinks available.

This is the kind of operation I occasionally find in the backwater of the produce industry. It’s not my role to fix these issues, I was there to bid on a consulting project, which I did, and I was glad when I walked away from this mess. But I am left with the question of whose responsibility is this?

With that thought in mind, it was with some annoyance that I read the comments of the State of Georgia Commissioner of Agriculture, Gary Black on FSMA.

Black said in late December “new food safety rules proposed by the federal government could prove cumbersome and costly for Georgia farmers”. That cost is probably not as high as Mr. Black might make out, but I agree it can be expensive to hire a consultant to develop a program of food safety controls in operations where they never existed before, perhaps $2,500.00 to $5,000.00 or more for the consultant in a business doing $500,000. Add to this, the costs to upgrade operations such as refrigeration, acquire equipment, and make structural improvements to meet inspection requirements.  FDA suggests that about $30,000 might be needed in large operations. My own experience is that currently, a medium sized produce packing facility can spend up to $250,000 a year to comply with the third party food safety standards already imposed by the major buyers.

One could argue, however, that such expenditures for safe facilities and hygienic operations are simply the cost of doing business and it is unfair for only parts of the industry to shoulder the obligation.

Dr. Michael Doyle, director of the University of Georgia's Center For Food Safety gave some balance to the discussion. “From my perspective, it's all about public health," Doyle said. "We've had so many of these outbreaks." According to FDA there have been 131 outbreaks attributed to produce between 1996 and 2010, and that list has obviously grown.

Read more here:

http://www.macon.com/2013/12/24/2848660/ga-agriculture-commissioner-faults.html#storylink=cpy

Read more here:

http://www.macon.com/2013/12/24/2848660/ga-agriculture-commissioner-faults.html#storylink=cpy

Negativity comes not only from the ranks of government, but from so called “food freedom” groups.

Read more here:

http://foodriotradio.com/2013/11/food-safety-modernization-act-the-end-of-fresh-living-food/

Due to the push back from all sides, the end of the year saw FDA express reservations about some of its new FSMA requirements, especially those proposed for agricultural water testing, and is reevaluating the impacts of the regulation on farms, generally.

Read more here:

http://www.agweek.com/event/article/id/22372/

What this means is a setback for consumers who will wait even longer for the safety of produce, and in the meantime, the produce industry is still very vulnerable to large outbreaks of foodborne illness, as we saw in 2013 with Hepatitis A in imported pomegranate seeds,

http://www.cdc.gov/hepatitis/outbreaks/2013/a1b-03-31/index.html

and the parasite Cyclospora in imported greens used in salad mix.

 http://www.fda.gov/food/recallsoutbreaksemergencies/outbreaks/ucm361637.htm

Another Jenson Farms type of outbreak is not out of the question, either.

See here:

The Produce Industry Still has a Long Way to Go to Ensure Food Safety

The Produce Industry Still has a Long Way to Go to Ensure Food Safety

While there is quite a bit of controversy concerning what happened at Jenson Farms, there is no denying that the fresh produce industry has been forced to reevaluate its food safety efforts.

The Buyer Driven Food Safety Model

Third party food safety audits are still what they have always been, an industry led method to determine conformance with a set of voluntary standards.  As third party auditors, we have no control over the operations we audit. The only real control lies with the customers of the operation. The customer can choose not to purchase from a supplier, work with the supplier to correct problems uncovered in the audit processes, or ignore the audit findings. Increasingly however, customers are becoming more selective and looking much more closely at audits before making buying decisions. Unfortunately, the dictates of supply and demand still apply, and if a customer needs product and the price is right, buyers will purchase from suppliers with questionable records, or even those without any oversight at all. In the end, audit findings are still just one of the criteria that a prospective customer uses to make a buying decision.

Traceability and Recall

Traceability is improving, with some firms investing considerable resources in advanced electronic record keeping and coding of unit packaging. Still, recent outbreaks show that traceability is a difficult matter. The recent outbreak of cyclosporiasis in leafy greens this year illustrates the difficulty with traceability. Even with over 600 cases of illness affecting numerous states, investigators did not conclusively link the outbreak cases to a supplier. The final report by CDC indicated that both cilantro and bagged salad items were involved, without pointing to a single source of the contamination of both products. Products might be coded when they are packaged, but processors do not always maintain the needed batch coding records to tie inputs to outputs, and there is plenty of comingling going on throughout the supply chain. While traceability systems such as PTI, Harvest Mark and ScoringAg are available, the industry has not come to a consensus as to what it wants, leaving suppliers with uncertainty as to what system to choose.

Antimicrobial Treatments

Packers and processors are using a variety of antimicrobial treatments such as ozone, chlorine dioxide, chlorine and peracetic acid; however, we lack clear scientific evidence for the sanitizing effect of these treatments on fresh produce. Treating the water used to wash produce is a wise idea, especially if the wash water is reused (recycled), and we can reliably determine the effectiveness of that type of treatment. The problem with sanitizing produce is that each product has its own world of microbial issues, such as surface area characteristics and vulnerability to microbial colonization, and each antimicrobial treatment process has its own set of variables, e.g., concentration, contact time, and coverage. Determining the precise methods needed to inactivate a wide range of microbes in such diverse products and processes remains elusive. Currently, the USDA does not recognize any microbial treatment for whole fruits and vegetables as capable of sanitizing and therefore no antimicrobial product has a registration for reduction of human pathogens on whole fruits and vegetables. Much more research is needed in this particular area of produce safety.

The Food Safety Knowledge Gap

The produce industry is moving forward with the education and training of its personnel, but currently there is no approved or recognized program of instruction in food safety in the produce industry. Unlike training programs at the restaurant level, very little has been done to identify the core curriculum needs of the produce industry. For example, operators of complicated antimicrobial addition systems are usually recruited from existing production staff having no training in chemistry or microbiology. Such operators often do not fully appreciate the complexities of sanitizing processes and concepts such as free chlorine, oxidation-reduction-potential (ORP), and pH. While microbial treatment of process water and surfaces are becoming standard operating procedures, the industry lacks the expertise to perform tests or interpret results. Findings often get filed without an evaluation by a knowledgeable person.  The use of ATP as a verification tool is required by most third party standards (and FSMA), yet few firms have the skills needed to effectively establish such programs and/or benefit from this type of monitoring.

While a HACCP program is often required (by buyers) the understanding of the concept by the produce industry is marginal. Without a grasp of epidemiology, microbiology and science in general, this concept is nothing more than window dressing in many firms.

Equipment Design and Construction Standards

There is no formal registration process for equipment used in the produce industry. Unlike the dairy industry where processors have very successfully applied the 3-A standards, there is no set of criteria for the finish of surfaces, or even the types of equipment used to pack or process fruits and vegetables. We see everything from cast iron to stainless steel construction of various grades, with rubber, plastics and even cloth and wood used as food contact surfaces.

Control of Wastewater

There are several commodities that are not typically washed before packing, such as berries and watermelons, but many produce items are washed, generating a substantial amount of wastewater. The systems for collection and discharge of wastewater from washing- flumes dump tanks and spray bars are often poorly designed, resulting in water flooding production areas. Wherever there is water collecting, these is a substantial risk of microbial contamination; workers splash through wastewater pooling on floors, and forklifts splash such water onto packaging and products . Poorly designed and located floor drains and floors that are not properly sloped to drain are common problems throughout the industry.

Facility Construction and Design

Just as there are no recognized industry standards for equipment, there is no national industry standard for design of produce facilities. Facilities can be open sheds with no walls and bare concrete floors while other are enclosed production facilities with a variety of layouts and construction types. Facilities in the produce industry are often viewed as part of farming operations and resemble farm buildings (pole barns), as opposed to the processing facilities one might find in fisheries or meatpacking. Attempting to control contamination, (physical, chemical and microbiological) in such facilities can be frustrating to those tasked with sanitation.

Microbial Testing

Probably the best deterrent to an outbreak in high risk commodities is a robust microbial sampling program for products and surfaces. There is some controversy as what constitutes a high risk commodity, but those fresh produce commodities with an edible peel and those that are in a ready to eat form (no cooking required) might be targeted, along with those produce items with a history of causing outbreaks. It is reasonable that since outbreak investigations can often isolate the pathogen on incriminated produce that such contamination could be spotted ahead of time before such products cause harm. The problems remain as to what to sample, what analysis methods to use, what microbial indicator organism to use, or pathogen to look for, and how much and how often to sample; and then there are the problems of how to interpret the results, and when to initiate a recall. The produce industry is by and large poorly prepared to employ microbial testing to its advantage.

FSMA

FDA rules under FSMA are still not clear. After years of waiting, the produce industry is still uncertain as to what the impact of the new requirements will be, and FDA itself appears to be groping for answers. It will be years before the FDA can effectively enforce its rules, and the industry must move forward on its own, now.

While the produce industry is frightened by what happened to the Jensen brothers, the industry remains perplexed as to what to do, and the reality is this same scenario could play itself out again at any number of firms. What is clear is that in spite of the progress that has been made in food safety, the fresh produce industry has a long way to go to prevent another Jensen Farms type of incident.

HACCP CLASS FORMING

 

HACCP CLASS FORMING

Many produce firms have adopted Hazard Analysis Critical Control Point systems, only to find that when they are audited, there are major deficiencies and non-conformances.

We are offering a HACCP class that addresses the major issues in developing and implementing produce HACCP plans. This course will provide you with the following:

·         A solid overview of the 5 preliminary steps and 7 HACCP principles as outlined by the USFDA and CODEX Alimentarius.

·         A step by step process for building your HACCP plan

·         They key elements of HACCP audits under GFSI and Standard Primus and how to comply

·         A certification that is recognized throughout the world

This is a workshop format and most of the class work is done by teams, so there is a great degree of interaction.

Please plan on joining us, and if you have already been certified under this program, pass this information along. This class is offered a few times a year so please take advantage of this opportunity if you need it. If you have a HACCP plan we will show you how to tighten it up, if not, its best to come prepared at least with an idea about your process and flow and we will walk you through the process.

Thanks and we look forward to hearing from you. Click link below for registration form.

 www.safefoodsblog.com/uploads/file/Deland_Produce HACCP trainingflyer.doc

Airline Food Safety and Industry Denial

http://abcnews.go.com/US/mice-roaches-fda-inspecting-airline-food/story?id=17739284&page=4

I had the opportunity to help develop the above report, and review the findings of FDA inspections over the last few years at the nation's top air carrier caterers. The findings, as reported by ABC 20-20 are clearly indicative of lack of control over production environments, people and production processes, the very things food safety management systems are supposed to address.

The comments by industry are predictable. The "we didn't do it" philosophy, "head in the sand" approach is apparent, in spite of spin doctor statements. When you get caught with these types of issues, the public is not going to listen to the rhetoric about how great your food safety programs are, quite the contrary. Not one of these spokespersons would admit that their company had a problem or offer solutions, its all about denial. We see this again and again, especially after outbreaks.

The heads of these companies apparently are so disconnected from reality that they feel they can boast about how great their food safety programs are, even in the face of 1,500 FDA violations and many instances of gross sanitation conditions. Again, this is the same mantra we hear after an outbreak in FDA regulated facilities.

I lay much of the blame at the feet of FDA. This agency has the authority to stop such conditions and they opt time and again to walk away from problems and not take the tough stand that as consumers we expect, except in the most egregious of cases.

All we have to do is look at the poor record on FDA in the pharmaceutical compounding business or at Sunland (peanuts), or in the myriad of other outbreaks where the agency had performed inspections. No one is accepting responsibility, we get the same pathetic answers from FDA as from industry.

Taking a tough stand by inspectors is personally costly, it means confrontation, its perilous to careers and even to ones personal safety. I know this only too well, so I am very grateful to have an opportunity to again stand some ground against the food industry representatives who want to claim all is well in the face of mounting sanitation and health code violations and deceive themselves and the public.

This type of public confrontation is what we need to dispel the false sense of security the food industry and FDA has created for itself.

I applaud ABC 20-20 and all the other media who go to bat for the nation's consumers. This type of work is actually a preventive approach, as it pushes the issues in a way that compels both FDA and industry to respond, unlike third party audits and FDA inspections that occur behind closed doors.

I hope I have more opportunity to tell it like it is, and I hope the airline food industry is listening. I know they are hearing, but are they listening? Time will tell, but from the sound of their statements, I don't think so.

Continue Reading...

Today Show's Rehash of the Auditor Bash

Despite that all of this has been said before, Bloomberg and the Today Show still think there is something to say about third party food safety audits, but they say nothing new. Of course, there are going to be outbreaks in facilities that have third party inspections. Just like there are outbreaks in facilities regulated by USDA, FDA and every county health department across the US. Why is that a surprise? Third party auditors are in almost every facility that should be inspected by FDA. Where is FDA? Do the agency and its inability to police the food industry share the blame for the situation? What about the thousands of facilities that do not have outbreaks THAT ARE AUDITED? It’s impossible to measure prevention…let’s see…show me the data on how many outbreaks didn’t happen? Hmmm.

All of these stories expose the weakness in the third party system, which I admit there is. As an auditor, I do not carry a badge, cannot stop production, and cannot close an establishment. I can even be constrained from taking pictures, samples and can be denied access to records and documents at the discretion of management.  I can only evaluate the questions on the audit template and only those that are in the so called scope of the audit.

Doug Powell asks for the data, and well he should, but he is not likely to get it since this data is proprietary. Audit companies are not going to publish the scores of auditees, and why should they? These audits are simply tools for the buying community to make purchasing decisions, not public health protection documents. If there is weakness in the system, it is that retailers will buy from anyone, and simply hide behind a smoke screen of due diligence, putting the burden of food safety on the supplier, while the buyers themselves are free to scour the markets for the best price and ignore food safety.

And forget the scores, there are so many questions that the points do not always indicate the real level of risk, but buyers and retailers do not read the reports, they simply go by scores. In my opinion, the buyers need to be educated because few if any of them really know how to interpret the findings from third party audits.

Left to its own devices, due to the inability of our public health agencies to afford us food protection, the food industry has created a system it can live with. Such is the case with third party audits. No retailer is going to make the system so strict that it constricts the supply, or God forbid causes a shortage and prices rise. And there is the profit motive, as this article brings out, and not just at AIB. Remember, FMI the billion dollar voice of the food industry owns the most recognized GFSI scheme called SQF, and they are not alone- all auditing companies work for the industry and adjust themselves to the prevailing powers that be- to make money, that is business and just what you would expect from an industry driven concept. It is so naïve to think any other way.

If you want independent auditors who are not beholden to someone, then we better fund a righteous FDA and keep the political honchos in Washington away from the inspectors. It can’t be done either-so there.

So now what?

More outbreaks, more tragic deaths and more of the blame game; this nightmare is not going away just because the Today Show runs a story. The problem is that the microbes have become firmly entrenched in our environment and attack our food supply at will, and we seem to lack the ability to detect them or eradicate them. Our best hope is a huge infusion of scientists, science and technology into the food industry, but we are a generation away from seeing the beneficial effects, even if we start now.

So on we go with incompetent people running our food safety programs, basic hourly workers with no knowledge of chemistry or microbiology in charge of food safety in too many plants, coopted auditors, and poor little old FDA limping to the scene after some tragic event to tell us what went wrong. Pathetic.

Read on and try not to barf.

Show us the data, forget the faith; food sickens millions as company-paid checks find it safe

10.Oct.12

barfblog

Doug Powell

http://barfblog.com/show-us-the-data-forget-the-faith-food-sickens-millions-as-company-paid-checks-find-it-safe/

William Beach loved cantaloupe -- so much so that starting in June last year he ate it almost every day. By August, the 87-year-old retired tractor mechanic from Mustang, Oklahoma, was complaining to his family that he was fatigued, with pain everywhere in his body.

On Sept. 1, 2011, Beach got out of bed in the middle of the night, put his clothes on and walked into the living room. His wife, Monette, found him collapsed on the floor in the morning. At the hospital, blood poured from his mouth and nose, splattering sheets, bed rails and physicians.

He died that night, a victim of Listeria monocytogenes. Beach was one of 33 people killed by listeria that was later traced by the U.S. Food and Drug Administration and state officials to contaminated cantaloupes from one Colorado farm. It was the deadliest outbreak of foodborne disease in the U.S. in almost 100 years.

“He died in terror and pain,” says his daughter Debbie Frederick.

That’s how Stephanie Armour, John Lippert and Michael Smith begin their food safety and aduits and inspections opus for Bloomberg. The Today Show may run a version this morning, because I taped a bit for it at Brisbane’s Channel 7 studios last week.

About seven weeks after Beach started eating cantaloupes, a private, for-profit inspection company awarded a top safety rating to Jensen Farms, the Granada, Colorado, grower of his toxic fruit. The approval meant retailers such as Wal-Mart Stores Inc. (WMT) and Wegmans Food Markets Inc. could sell Jensen melons.

The FDA, a federal agency nominally responsible for overseeing most food safety, had never inspected Jensen.

During the past two decades, the food industry has taken over much of the FDA’s role in ensuring that what Americans eat is safe. The agency can’t come close to vetting its jurisdiction of $1.2 trillion in annual food sales.

In 2011, the FDA inspected 6 percent of domestic food producers and just 0.4 percent of importers. The FDA has had no rules for how often food producers must be inspected.

The food industry hires for-profit inspection companies -- known as third-party auditors -- who aren’t required by law to meet any federal standards and have no government supervision. Some of these monitors choose to follow guidelines from trade groups that include ConAgra Foods Inc. (CAG), Kraft Foods Inc. and Wal-Mart.

The private inspectors that companies select often check only those areas their clients ask them to review. That means they can miss deadly pathogens lurking in places they never examined.

What for-hire auditors do is cloaked in secrecy; they don’t have to make their findings public. Bloomberg Markets obtained four audit reports and three audit certificates through court cases, congressional investigations and company websites.

Six audits gave sterling marks to the cantaloupe farm, an egg producer, a peanut processor and a ground-turkey plant -- either before or right after they supplied toxic food.

Collectively, these growers and processors were responsible for tainted food that sickened 2,936 people and killed 43 in 50 states.

“The outbreaks we’re seeing are endless,” says Doug Powell, lead author of an Aug. 30, 2012, study on third-party monitors called “Audits and Inspections Are Never Enough.” Powell, a professor of food safety at Kansas State University, says Americans are at risk whenever they go to a supermarket.

“You need to be in a culture that takes food safety seriously,” Powell says. “Right now, what we have is hidden. The third-party auditor stickers and certificates are meaningless.”

In some cases, for-hire auditors have financial ties to executives at companies they’re reviewing. AIB International Inc., a Manhattan, Kansas, auditor that awarded top marks to producers that sold toxic food, has had board members who are top managers at companies that are clients.

Executives of Flowers Foods Inc. (FLO), which makes Tastykake, and Grupo Bimbo SAB in Mexico City, which makes Entenmann’s pastries, Sara Lee baked goods and Wonder Bread, serve or have served on AIB’s board.

“There’s a fundamental conflict,” says David Kessler, a lawyer and physician who was FDA commissioner from 1990 to 1997. “We all know about third-party audit conflicts. We’ve seen it play out in the financial world. You can’t be tied to your auditors. There has to be independence.”

As flawed as the inspection system is in the U.S., it’s more problematic with imported food, especially coming from countries with lower sanitary standards, says Michael Doyle, director of the University of Georgia’s Center for Food Safety. In some emerging markets, farms growing food for export to the U.S. aren’t inspected at all.

The U.S. will import half of its food by 2030, up from 20 percent today, Doyle says. Bloomberg Markets visited growers in China, Mexico and Vietnam and found unsanitary conditions for produce, fruit and fish exported to the U.S.

Auditors evaluate their clients using standards selected by the companies that pay them, says Mansour Samadpour, owner of IEH Laboratories & Consulting Group in Lake Forest Park, Washington, which does testing for the FDA. The auditors sometimes follow a checklist that the company they’re inspecting has helped write.

“If you have a program for adding rat poison to a food, the auditor will ask, ‘Did you add as much as you intended?”’ Samadpour says. “Most won’t ask, ‘Why the hell are we adding poison?”’

Not only has the government outsourced auditing to the food industry; the auditors themselves often outsource their vetting to independent contractors -- people over whom they don’t have direct management control.

While Primus Labs declined to comment directly for this story, it did supply a response from its law firm, Kaufman Borgeest & Ryan LLP in New York. Auditors, the statement says, serve at the pleasure of their clients and cannot go beyond what they are asked to do.

“Third-party auditing will continue to be as effective as those requiring the audits (buyers/suppliers) and the audited suppliers make them,” the law firm writes. James Markus, a lawyer representing Jensen, didn’t return calls seeking comment.

From the outset, the FDA lacked the resources to inspect all of the country’s food producers.

The food industry moved to fill that vacuum with private auditors in the 1990s. Danone SA (BN), Kraft, Wal-Mart and other companies created the Paris-based Global Food Safety Initiative in 2000 to write guidelines for third-party auditors.

The program, whose vice chairman is Frank Yiannas, Wal- Mart’s vice president for safety, requires companies to be audited once a year. It doesn’t mandate testing for pathogens. In 60 manufacturing plants, Wal-Mart suppliers reported a third fewer recalls in the two years after adopting GFSI standards, Yiannas says.

In some cases, companies use their own auditors to check suppliers. In 2002 and 2006, Nestle USA, a subsidiary of Vevey, Switzerland-based Nestle SA (NESN), refused to use Peanut Corp. of America as a supplier. Nestle inspectors found rodent carcasses and pigeons in Peanut Corp.’s Plainview, Texas, plant.

Nestle’s rejection didn’t stop Lynchburg, Virginia-based Peanut Corp. from doing business with other customers or seeking approval from third-party auditors. In 2008, AIB International auditor Eugene Hatfield gave Peanut Corp.’s Blakely, Georgia, plant a “superior” rating.

And there’s a whole lot more. Our take on all this is below:

Food Control

D.A. Powell, S. Erdozain, C. Dodd, R. Costa, K. Morley, B.J. Chapman

http://www.sciencedirect.com/science/article/pii/S0956713512004409?v=s5

Abstract

Internal and external food safety audits are conducted to assess the safety and quality of food including on-farm production, manufacturing practices, sanitation, and hygiene. Some auditors are direct stakeholders that are employed by food establishments to conduct internal audits, while other auditors may represent the interests of a second-party purchaser or a third-party auditing agency. Some buyers conduct their own audits or additional testing, while some buyers trust the results of third-party audits or inspections. Third-party auditors, however, use various food safety audit standards and most do not have a vested interest in the products being sold. Audits are conducted under a proprietary standard, while food safety inspections are generally conducted within a legal framework. There have been many foodborne illness outbreaks linked to food processors that have passed third-party audits and inspections, raising questions about the utility of both. Supporters argue third-party audits are a way to ensure food safety in an era of dwindling economic resources. Critics contend that while external audits and inspections can be a valuable tool to help ensure safe food, such activities represent only a snapshot in time. This paper identifies limitations of food safety inspections and audits and provides recommendations for strengthening the system, based on developing a strong food safety culture, including risk-based verification steps, throughout the food safety system.

http://www.bloomberg.com/news/2012-10-11/food-sickens-millions-as-industry-paid-inspectors-find-it-safe.html

http://barfblog.com/losing-my-religion-faith-based-safety-has-to-go-audits-and-inspections-are-never-enough/

http://www.bloomberg.com/video/toxic-food-can-the-fda-keep-u-s-consumers-safe-yk~bX~hPRSupw33re4cGvQ.html

Who Was the Peanut Auditor?

Whilst I value the commentary of my friend and colleague, Doug Powell and agree almost 99% with his theory and thought, I have to question this aside at the conclusion of the story below.

Do we ask "who was the inspector" every time we have an outbreak in a regulated restaurant or meat plant? How is that relevant? 

The auditor or inspector is not in charge of food safety. As a profession, we are there to evaluate either conformance with a prescribed set of rules written by a buyer (in the case of an auditor) or compliance with laws written and enacted by government.

The findings are useful for improving an operation, and the findings may point to risks inherent in a process or product or facility, but the inspection or audit process may not necessarily uncover every defect, hidden hazards or those of such a nature that they cannot be readily discerned through visual observation or records review. In any case, breakthrough events do not invalidate either inspections or audits, nor do they undermine their value or negate the need to continue such.

On the other hand, we have seen obvious defects and unsafe conditions left unchecked by an auditor or an inspector, and then a subsequent outbreak occur. We have to ask why that happens, and I believe that reporting and observational biases are a challenge for both inspectors and auditors. The biggest prejudices that such an expert has are lack of knowledge, time constraints, failure to see the entire operation, pressure from the operator, invalid audit or inspection protocol, faulty inspection report or method used to evaluate risks, politics, business concerns and self interest.

These flaws potentially exists in every inspection or audit process and the extent of which they manifest will invalidate the outcome.

Therefore, it is important to ask more than just who an inspector was; it is much more important to look at the whole auditing and inspection process. I believe these failures are not so much the result of "who was the auditor" but how well the audit process was able to uncover issues, and of course how well the operation cooperated with the auditor and responded to concerns.

 29 sick with Salmonella linked to Trader Joe’s peanut butter; why is Penn. going public and others aren’t?
21.sep.12
barfblog
Doug Powell
http://barfblog.com/29-sick-with-salmonella-linked-to-trader-joes-peanut-butter-why-is-penn-going-public-and-others-arent/
Now would be the usual time for some consumer education group to issue yet another jackass advisory, this time about how consumers should cook their peanut butter, or choose it with care, or something else they have no control over.
It is food safety education month, don’t ya know.
The Pennsylvania Department of Health today advised consumers that Trader Joe's Valencia Creamy Salted Peanut Butter made with sea salt may be related to a multi-state outbreak of salmonella.
The department is working with the Centers for Disease Control and Prevention and public health officials in several states to investigate the outbreak. Nationally, there have been 29 cases of illness with two cases reported in Pennsylvania.
Trader Joe's has voluntarily removed the product for sale from its stores; however, consumers who have the product in their homes should discard it and should also be aware that this product is sold online through other retail outlets.
Additionally, the department advises anyone who recently consumed Trader Joe's Valencia Creamy Salted Peanut Butter made with sea salt and then became ill to consult their healthcare provider, local health department, or call the Department of Health at 1-877-PA-HEALTH.
Where did this peanut butter originate? Does hipster fave Trader Joe’s audit their suppliers? Who was the auditor?
Nothing yet on the Trader Joe’s website.
http://news.yahoo.com/pennsylvania-department-health-warns-consumers-discard-trader-joes-220200445.html
http://www.traderjoes.com

 

Retailer Double Talk on Produce Safety

One of the hallmarks of protecting the fresh produce supply is a concept known as “buyer-driven” food safety controls. In the absence of regulations, the produce industry has been working under private standards drafted by the major buyers of produce, meaning the large retailers-the major supermarket chains. While the need to satisfy the retailer that foods supplied to them are safe, retailers themselves have been less than effective in ensuring that the people they commission to buy for them, their own “buyers”, only deal with operations with acceptable food safety systems.

This means that many, if not most retailers, will buy produce from firms that have not been verified by competent third parties or by the retailers themselves (second party verification), when it is opportune for them to do so. For a revealing piece on this issue see The Perishable Pundit:

http://www.perishablepundit.com/index.php?article=2667

The sad truth is that when buyers can get produce from a vendor at a cheaper price, the requirements for safety take second place.

Even worse, buyers utilize the unapproved firm as a lever to get the operator with a food safety system, and subsequently higher production costs, to lower their price.

Even small operations may invest hundreds of thousands of dollars in satisfying the strict rules of the Global Food Safety Initiative (GFSI). Often, firms must hire food safety personnel due to the overwhelming amount of self-inspection and paperwork involved. Laboratories and auditors must be paid for. Many times there are requirements for structural improvements and maintenance, chemicals to clean and treat water and many other similar costs to be borne day in and day out by suppliers. Thanks to the attitude of the major retailers, these suppliers cannot typically charge more for their products, and must absorb the costs as best they can while trying to stay competitive.

It is unfair to say the least that buyers for the major retailers would use the lower priced unapproved supplier as leverage to keep down their costs. Instead of rewarding suppliers for diligent efforts that not only protect the retailer, but public health in general, they are causing animosity; many conscientious produce operators are indignant at the current double standard, but the fear of losing customers precludes most of them from expressing their exasperation.

http://barfblog.foodsafety.ksu.edu/blog/155900/12/08/23/less-rhetoric-more-data-market-cantaloupe-safety-retail-so-consumers-can-choose

"Food safety culture" is a much used phrase and one preached to the supply chain by many of the world’s largest retailers. Retailers should be reminded that food safety culture begins at home, and such talk becomes a mockery in the eyes of the producer when retailers say one thing and do another.

Not all produce firms have had an opportunity to be qualified by third party accreditation under any private scheme, but the population of certified firms is growing, Part of the reason for the shortfall is that the auditing firms performing such audits are themselves overwhelmed and lack the necessary manpower.

In order to maintain pressure on the supply chain, the buyers for the major retailers have set deadlines for compliance, but then have to announce that another grace period or extension has been granted. Some relatively large producers of fruits and vegetables have just decided that the retail communities demands for conformance with third party food safety standards is a bluff and carry on business as usual; and they find most retailers are willing to buy their products anyway, on the basis of price and quality.

Lawsuits involving the produce industry cost retailers many millions, however, too many are seemingly willing to take a chance as long as the short term economic benefit is there.

I am sure the food safety experts at the nation’s leading retailers cringe when their buyers go outside the approved supplier list, yet the corporate decision makers do not always value a food safety department’s input.

Again, this is not “food safety culture”, when a firm puts short term profits over safety and public health; this is the antithesis-corporate greed.

Such business practices are undermining food safety efforts and causing many a bitter attitude among firms who have invested millions over the years to satisfy the demands of retailers, only to have their competitors flaunt such food safety efforts and prosper.
 

FDA Finds Insanitary Conditions-Again

FDA once again on the basis of detecting a Listeria contaminated product, finds insanitary conditions at a producer, this time at Henrys Farm Inc. of Woodford, VA. It would be much better for everyone if FDA had found these conditions beforehand. These repeated exercises by FDA should be a warning to the produce industry, that sanitary conditions in produce operations need improving across the board. It also points to the tremendous job FDA will have in cleaning up the produce industry, if and when they are able. Until then, it appears reacting is the best they can do.
 
Here are the findings as published by Food Safety News:
 
http://www.foodsafetynews.com/2012/09/fda-sends-warning-letter-to-sprout-grower-citing-unsanitary-facilities/
 
- Rodent pellets in bags of mung beans, along with gnawing on 25 kg paper bags of soybeans located in the refrigerated seed storage section. and in a shed 200 feet West of this storage area. FDA reported "a foul odor consistent with rodent infestations associated with the shed."

 
- Gaps under the door to the refrigerated seed storage area and holes in the ceiling of a shed containing soybeans 

 
- A hand-washing sink draining used water onto the floor

 
- An accumulation of debris in the exit bin of the wash chute leading to the sprout air dryers and packaging machine and on the underside of a conveyor belt that transports soy beans.  

 
- Loose metal burns on the metal mesh conveyor belt in the sprout processing area measuring about a quarter of an inch around. 

 
FDA also charges Henrys with misbranding its product, saying the company's sprouts failed to bear a label including the name and place of business of the manufacturer or the net quantity. 
 
Who are the commercial buyers and distributers of these products? Do they have a clue what they are buying and selling? Food safety at this level of the produce supply has a long, long way to go.

Fear Mongering or Facts, Plaintiff Attorneys and Social Media in Food Safety

Fear Mongering or Facts, Plaintiff Attorneys and Social Media in Food Safety

The tort system has become the fulcrum for food safety in the absence of a credible public health response to foodborne illness. Nobody goes to jail in the US for even the worst food safety breaches, even those that result from gross negligence, but they do get sued, big time. FDA especially, has lacked the power to levy any meaningful penalties against offending firms, even ones that have released contaminated foods knowingly into commerce. The Parnells and De Costers rest in their immunity from prosecution after they poison thousands and killed innocent consumers with their tainted products, but they cannot escape the long arm of the plaintiff attorney. The complacency that has developed due to the liaise-fare attitude of government, turned to fear of lawsuits, has now hardened into an attack on plaintiff lawyers, the last recourse for injured parties.

 

With that as a backdrop, the story below reeks of a reactionary mentality. The suggestions that social media be used to spin food safety information and deter consumers from getting the facts they need during an outbreak will not get very far. The public is not so easily fooled.

 

I believe that firms that practice food safety and are committed to the principles of public health protection should tout their message.

But to play games with the access to factual information especially during an outbreak just reveals the shocking and desperate state the food industry is in.

 

Instead of manipulating social media, the food industry should be redoubling their efforts to stop the foodborne epidemic in this country and come clean with the American public.

 

US: Four ways plaintiffs’ lawyers leverage Google to stir food-safety fears
11.sep.12
Fast Company
Richard S. Levick
http://www.fastcompany.com/3001180/four-ways-plaintiffs%E2%80%99-lawyers-leverage-google-stir-food-safety-fears
Despite the fact that America’s food safety infrastructure is the most efficient and effective in the world, the International Food Information Council Foundation’s 2012 Food and Health Survey found that only 20 percent of Americans are “very confident” in food supply safety. At the same time, one in six U.S. consumers has stopped buying a particular food or beverage brand because of safety concerns in the last twelve months.
Given the rash of high-profile food recalls we’ve seen since 2007, the figure is understandable, even if it isn’t backed up by hard facts. Spinach, tomatoes, peanuts, lettuce, ground beef, and a host of other kitchen table staples all experienced significant incidence of contamination in the last five years. The resulting consumer anxiety got so bad in 2009 that Americans actually put their food safety fears on par with worries about the War on Terror.
That’s a compelling statistic--and it ought to make farmers and food manufacturers wonder if there’s something else that is contributing to Americans’ fear of food. Even at the 2010 height of salmonella, listeria, and E. coli outbreaks, the U.S. Centers for Disease Control and Prevention released data showing that only one in every 125 million meals served in the U.S. had the potential to make a consumer fatally ill. Science supports a conclusion that the food we eat every day is, indeed, safe. So why don’t Americans feel that way?
The answer lies in the fact that statistics can’t compete with emotion when it comes to assuaging anxiety. Numbers don’t move people the way that human drama does--and there are no more dramatic events in the food industry than when a person dies after eating something she believed was safe.
This facet of human nature explains a large part of the equation; but not all of it. There is another factor at play, and it manifests itself in the efforts of those with skin in the food-fear game. Food industry adversaries--the plaintiffs’ bar chief among them--understand how emotion impacts the marketplace. Even more troubling for the food industry, they understand how to manipulate digital and social media strategies to ensure their emotional appeals ring out in the marketplace.
By way of example, when we look at the circumstances surrounding the recent salmonella outbreak that killed two people, sickened 150, and originated at an Indiana cantaloupe farm, we see just how effective their efforts are at controlling the flow of information on food safety issues. In other words, we see just how good they’ve gotten at controlling search results on Google, the venue more people turn to for information than any other (digital or otherwise).
1.Plaintiffs control the keywords. As of this writing, a Google search for the term “cantaloupe outbreak” lists a law firm as the top sponsored link. A search for “cantaloupe lawsuit” returns six plaintiffs’ firm sites on the first page. Industry messaging on safety issues is nowhere to be found on the first page of either of these searches. Bottom line--on virtually every food outbreak issue, the plaintiff’s bar is masterfully controlling the dialogue on Google.
2.Plaintiffs dominate the blogosphere. When users click those links mentioned above, they are most often directed to blog posts that outline how the industry failed to keep cantaloupe consumers safe. While the posts provide plaintiffs with an important messaging venue, the blogs themselves ensure high search rank for the posts because they are sources of the frequently-updated content that attracts the Google spiders.
3.Plaintiffs use online video. A Google Video search for “cantaloupe listeria lawsuit” features two plaintiff-produced videos in the top three results. Just like the blog posts mentioned above, these videos don’t paint the industry as a responsible steward of public health. And as Google increasingly emphasizes the spoken word over the written one, these videos further optimize plaintiffs’ messaging.
4.Plaintiffs geo-target. As mentioned above, a Google search for “cantaloupe lawsuit” returns one plaintiff-maintained link. At the same time, a Google search for “cantaloupe lawsuit Kentucky” (one of the hardest hit states during the outbreak) returns two sponsored links. That tells us that at least one firm is targeting its efforts to the geographic areas where its messages will resonate most.
What all of this means is that the plaintiffs’ bar is operating in a virtual information vacuum when contamination strikes the food and beverage industry. “Within the legal community, they are simply outworking and outsmarting the other side when it comes to online communication,” says Bob Hibbert, a partner at Morgan Lewis & Bockius who has worked on number of high-profile food safety issues. “It’s clearly in the best interest of the food industry, and of the people who represent it, to mount a more effective response to this challenge.”
Fortunately, leveling the playing field doesn’t require any great strategic leap. Food manufacturers need to understand that the same tactics driving high levels of consumer anxiety can be employed to diminish it as well. Specifically, food companies should:
1.Own their risk terms and keywords. Plaintiffs’ keyword dominance exists because food manufacturers don’t own the risk terms that their consumers use to find information on the latest safety crises. While they likely optimize their Web properties for terms related to their products (“tomato,” “spinach,” ”cantaloupe,” etc.), they don’t do the same for terms such as “foodborne illness,” “recall,” “lawsuit,” or “outbreak”--and that enables the plaintiffs’ bar and other adversarial voices to dominate the conversation. At the moment an instance of contamination is discovered, food companies need to engage in Search Engine Optimization (SEO) and Marketing (SEM) campaigns that rank their response messages at the top of the list when their risk terms are queried. Even better, food manufacturers that do the same in peacetime not only eliminate the need to scramble when trouble arises; they create a compelling safety narrative that plaintiffs will have to overcome.
2.Address the blogosphere. Plaintiffs’ attorneys maintain blogs as a means to provide a steady stream of optimized content that keeps their messages front and center on search engines. They know that if they are active all the time, the Google spiders will elevate their sites when a food recall hits and it comes time to troll for class action clients. By blogging about all the ways they work to diminish the possibility of contamination, food manufacturers can also create the salient, frequently-updated content that ranks on Google when consumers seek information on food safety.
3.Engage via video. Food manufacturers that reach out to consumers with engaging video content not only provide themselves a leg up on the SEO front; they establish the emotional connections needed to bridge the safety perception gap. Articulating food safety statistics such as those cited above merely tells people their food is safe. Video shows them why they should consume with confidence. With video content that highlights safety procedures and the men and women charged with carrying them out, food manufacturers can powerfully articulate a commitment to safety that sticks with their audience. By going a step further with how-to videos that outline healthy food preparation steps, they can themselves take on the identity of true consumer advocates.
4.Be where the fear is. When an outbreak does occur, the companies at the center the problem--as well as those whose brands may be tarnished by mere association--need to target their messages to affected populations. Not only does geo-targeting streamline their optimization efforts by focusing resources where they are need most; it enables companies to directly reach the very consumers most likely to change their buying and eating habits as a result of a contamination incident.
Google is the portal by which consumers gain or lose confidence in products and services. As such, it is too important a venue for food manufacturers to cede to their adversaries. At a time when more than half of Americans are concerned about the foodborne illness, the industry has a compelling safety story to share. With strategies that enhance Web optimization, they can help ensure that a captive audience is there to hear it.
Follow Richard Levick on Twitter and circle him on Google+, where he comments daily on the issues impacting corporate brands.
Richard Levick, Esq., President and CEO of LEVICK, represents countries and companies in the highest-stakes global communications matters--from the Wall Street crisis and the Gulf oil spill to Guantanamo Bay and the Catholic Church. Mr. Levick was honored for the past three years on NACD Directorship’s list of “The 100 Most Influential People in the Boardroom,” and has been named to multiple professional Halls of Fame for lifetime achievement. He is the co-author of three books, including The Communicators: Leadership in the Age of Crisis, and is a regular commentator on television, in print, and on the web.