To spray or not to spray?

Avoiding chemical contamination of food product within your food business is not rocket science.  It is common sense and basic food safety not to spray pest or cleaning chemicals directly onto the surface of the food....right?  You would think so - but it is this very issue that has resulted in me issuing corrective action requests (CARs).

What went wrong?

There have been two separate food safety incidents of late.  The first involved an abnormal chemical showing up on a laboratory report and the second actually occurred whilst I was standing observing a food handler undertake a cleaning activity.

Linking food safety laboratory results

An item of produce was tested for a range of pesticides as part of a routine food safety verification program.  Product was sent to an external laboratory and tested for a range of different pesticides to confirm compliance with the law around MRL’s (maximum residue limits).  It was from the laboratory report that a pesticide not usually associated with the produce was identified.

This chemical was later found to be the same as an active constituent found in common house ‘fly spray’. Cans of ‘fly spray’ were found around the produce packing rooms. So in short, food handlers were controlling flies in the packing area by the use of common fly-spray but did not consider the spray landing on food product.

Cleaning 101
On the second occasion, I was standing watching a food handler cleaning a piece of equipment. Cleaning chemical was being applied to the surface of a hot grill using a spray bottle.  They continued to spray chemical onto the grill without any concern for the open cold storage server located right next to the grill.

You could actually see the chemical spray drifting and landing directly onto the freshly prepared salad and sandwich ingredients. When the food handler was questioned about their actions, they had no idea what they had done or what the food safety implications were.

Food Safety Lessons Learned

Hopefully from these two examples, you can avoid the simple food safety hazard of chemical contamination within your food business.  It is also highly recommended that all food handlers are trained in the correct storage and use of chemicals.  Take a minute to think about the use of chemicals in your business and if you have correctly assessed the risk in your HACCP hazard analysis.

http://www.salamandafood.com.au/

How to control External Documents for HACCP

The control of external documents is a requirement of the majority of food safety and quality standards including WQA, SQF and BRC.  External documents are defined as being any document that comes into your business from an external source or a document that has not been developed directly by your food business.

As a food safety auditor, I see many different methods for the control of external documents. However, from an evidence base (proof to support compliance), a food business cannot go wrong with having an external document register.

The register should list the following:

• The name of the external document
• The source of the external document
• The date of the publication of external document
• The location of the external document (where is it stored within your food business)

There is no need to mark the external document in any way if you have it listed on the document register.  To test your current system (mini internal audit), check that the following random documents are currently controlled.

• Certificate of Currency for your Liability Insurance
• Pest Control Bait Location Map
• Customer Requirements / Standard eg. BRC, SQF, WQA, Spotless, Cosco, McDonalds
• Chemical Material Safety Data Sheets (MSDS’s)
• HACCP Training Certificates

I am sure that you can come up with many more but these will get you started.  Do you have another method that you use for external document control? Let us know.

http://www.salamandafood.com.au/

What does Clean really mean?

Cleaning is a basic requirement of the food industry but often one of the hardest requirements to achieve.  All food law and customer standards require that the food business is clean, so what does clean actually mean?  Clean means you can’t see it, you can’t feel it and you can’t smell it.  To expand on this let me explain further.

You can’t see it

When you visually look at a food contact surface or another surface (say the floor), you cannot see any dirt, dust, food scraps or any other material - so visually it looks clean.

You can’t feel it

If you were to run your hand over a bench, you can’t feel any grit or granules.  If you were to walk across a floor, the surface does not feel slippery or sticky.

You can’t smell it

If you were to say walk past a drain, you cannot smell any filthy, rotting or putrid smells.  There should be no smells that would indicate spoilage of any sort.

So, if you want to avoid a host of problems that come with an unclean food premises (bacteria growth, slip and fall injuries, prosecution, foreign matter in your food and pest infestation) follow the three simple actions to ensure your place is clean.


http://www.salamandafood.com.au/

The Value of Your Food Safety HACCP Consultant

The HACCP certification process can be very daunting for any food business and even more so when there is trade at stake.  The majority of the time, it is the responsibility of one person (normally the QA representative) to write, implement and make sure certification is successful.  But those of us who have ever been expected to achieve this outcome know too well, that this is a massive job. Enter the trusted food consultant.

As an auditor, I have had many experiences with consultants – some good and some not so good.  I get very irritated when I see that someone is being paid to do a job and they really just have no idea what so ever.  So here are some tips of what to look for in a Food Safety Consultant.

Professional Credentials

The consultant should have at least some level of qualification in the food safety / food quality / food compliance arena.  A degree in Food Technology, Environmental Health or Food Microbiology is a fantastic start.

Knowledge of the Criteria

Depending on the certification that your company requires, specific knowledge regarding the audit criteria is essential.  Different certification criteria’s include Codex HACCP, BRC, SQF, WQA, McDonalds, ISO22000 etc.

Past Experience

Check out what the consultant’s background experience is.  Have they worked in your industry or actually been exposed to successfully writing, implementing and managing a certificated food safety system.  Keep in mind that the consultant should compliment your HACCP team.  It is not necessary for them to know the ins and outs of your processes as your company would have that expertise. Knowledge around the different types of hazards that would occur in your process should be expected.

Professional Development

Keeping up to date is essential in the food safety and quality arena.  Knowledge of emerging trends in food safety hazards and changes in legal requirements is a must.  As an auditor, we are required to undertake 6-monthly calibration training to ensure that we are up to date with the latest standards and their requirements.

Past References

Get in contact with previous businesses that the consultant has undertaken work for.  Ask about how they found the consultant to work, what Criteria (Customer Standard) they consulted on and how the certification process went.  It is also important to find out what the scope of the consultants work was.

The Final Word

A little bit of research into your chosen consultant (before you sign a contract) can save you a lot of money and a lot of time.  Also, you should be wary of any consultant that tells you that they can write and implement a HACCP based food safety program in 2 weeks.  It takes time to change workers habits and behaviours so this cannot happen effectively within such a short period of time.

http://www.salamandafood.com.au/

Hand Washing for HACCP

The legal requirements for food handlers in regards to hand washing are documented the relevant food safety legislation applicable to your country location. Food handlers are generally required to wash their hands whenever they are likely to be a source of contamination.

This includes washing hands:

• Before working with ready-to-eat foods
• After handling raw food
• After using the toilet
• Before commencing and re-commencing handling food
• After smoking
• After coughing or sneezing
• After touching hair, scalp or a body opening
• After using a handkerchief or disposable tissue
• After eating or drinking
• After using tobacco or similar substances

It is recommended that a food handler, whenever washing his or her hands:

• Use only the designated hand washing facilities provided
• Wash hands with warm running water and soap
• Only dry hands with single use or disposable towels

6 Step Hand Washing Technique

1. Remove all rings and wet your hands with warm running water
2. Put a small amount of liquid soap in the palm of one hand
3. Rub your hands together for 20 seconds so you produce a lather
4. Make sure you scrub between your fingers, under your finger nails and the backs of your hands.
5. Rinse your hands with clean running water for at least 10 seconds. Try not to handle the taps once your hands are clean. The provision of hands - free taps helps to reduce post hand washing contamination.
6. Dry your hands with a single use paper towel.  Single use towels help to prevent the spread of germs.  All used towels should be disposed of in the waste bin.

http://www.salamandafood.com.au/

How to document a HACCP Flow Chart

The HACCP Flow Chart is the basis of any HACCP based food safety program.  It is imperative that the food business documents this flow process correctly as the remaining HACCP principles are developed from this flow process chart.

Over the years there has been a gradual shift from the use of symbols that represent certain production operations to the use of words.  By documenting your flow process chart as a series of words, it helps to clearly indicate the steps in your process.

What is a HACCP Flow Chart?
A flow process chart is a pictorial representation of a process.  Within the food industry, it generally represents all the steps that raw materials go through to become a finished product.  Steps in a flow process chart can include Receival of raw materials, store of ingredients, preparation, cooking, cooling, packing, labelling, bulk storage and distribution.  Depending on your process, you may have many more or less steps and types of steps than these listed.

Flow Chart Symbols
Traditionally, HACCP flow chart symbols have been used to illustrate the actions within a flow chart.  The most common actions are shown below:

Flow Chart Text Boxes
It is more common now to use worded text boxes.  This helps to give a better description of the process step and is more also easily understood.  Text boxes also allow you to document as much detail about the process step as you need.

Clear documentation
Whatever method you choose to use, the flow chart should clearly indicate all steps in the process.  Please ensure that you consider steps involving re-work and services in eg. Water, compressed air (food safety hazards can be identified at these process steps).  If you find that you have several processes within a process, a separate flow chart should be documented.  Your first level document can be an overview with subsequent layers drilling down into each of these processes.
For more information and guidance on the flow process chart requirements, please check the HACCP certification standard which you have based your HACCP system on.

http://www.salamandafood.com.au/

HACCP Gap Audits

Prior to getting HACCP certification or certification to a customer standard, a food company may elect to have a HACCP GAP audit performed.  In the majority of situations, food businesses elect to try to achieve HACCP certification in the first instance. Unfortunately, this is where the business fails.  Not understanding the value of a HACCP GAP audit can have a significant effect on the food business. Let’s review the benefits of a HACCP GAP audit.

Auditor Guidance

A Gap audit is the only situation where the food auditor can give some level of guidance. Auditor guidance at this stage can assist you and your business in fully understanding the requirements of HACCP or the customer standard that you are going to be later certified to.

Independent Review

A Gap audit allows an independent eye to look at your HACCP documentation, records and practices.  You can then make applicable changes if needed, before your HACCP certification audit.

CARs

No corrective actions requests (CARs) are raised during a HACCP Gap audit.  If you have performance indicators identified or bonus payments for “no CARs” in your position description, a HACCP GAP audit can save you explaining to management why you haven’t succeeded in your job role.

Familiar Process

If it is your first HACCP audit, a Gap audit will allow you to get comfortable with the process in order to be prepared for your HACCP certification audit.

Identify process gaps

The whole idea of a HACCP GAP audit is to assess where your food business is situated in regards to compliance. The identification of the level or magnetite of GAP can assist you in determining resource allocation, certification timeframes and current / required compliance.

I would always recommend a GAP audit for any new standard that you may wish to obtain HACCP certification for.  In the long run, it can save you and your food business a lot of time and money.

http://www.salamandafood.com.au/

Food Safety of Japanese Imports

With the recent nuclear disaster issues in Japan there have been many media reports concerning the safety of both the food and water supply. FSANZ (Food Standards Australia New Zealand) have now taken this into consideration and requested that the regulator responsible for food importation in Australia, AQIS (Australian Quarantine Inspection Service) to undertake testing of food products imported from Japan.

This action comes off the back of both the Japanese and Singapore governments detecting levels of radionuclide well above the international CODEX guidelines. Australia’s actions follow that of other countries, namely China and South Korea who have also scaled up their testing regimes.

At this stage, The World Health Organisation has reported that leafy green vegetables, milk, egg and meat products are the biggest concern for possible contamination. Eating food containing radioactive materials could increase the risks of certain cancers in the future.

A check of your raw materials and review of raw material specifications should aid in the identification of any products that may have been imported from Japan. Another area to check is if your food safety risk assessment has considered the likelihood and consequence of increased levels of particular chemicals outside of regulatory limits.

www.salamandafood.com.au

Food Safety Hazards

The identification of food hazards forms an integral part of reducing the overall liability that your food business may be faced with. It is through this identification that we can ensure that adequate controls are in place to reduce or eliminate the hazards to support a safe food product.
Food safety hazards can be categorised as being microbiological, chemical and physical. At a minimum, the HACCP (hazard analysis critical control point) concept requires the identification and control of food safety hazards.

Stress Free Audits

Any type of audit of your work systems and practices can be a daunting process to go through. The level of anxiety experienced by auditees seems to be greater when your business is dependant upon successful certification.

After 17 years of auditing regulatory, compliance and certification standards, I have often reflected on why one company can obtain a good audit result when another company performs poorly. What I have observed is that there are common practices that have contributed to both successful audit outcomes and failures.

HACCP Flow Process Charts

The first part when developing a HACCP plan is to undertake the 5 preliminary steps. The preliminary steps are intended to help you gather and collate background information that will help with implementation of the 7 principles of HACCP. The HACCP preliminary steps form an important precursor to effectively identifying and controlling food safety hazards within your food business.

7 Non-chemical pest control methods

My faith in effective pest control has been renewed this week. After auditing a medium sized bakery, I was pleasantly surprised to find that I did not have to raise a corrective action request for any level of pest infestation. I think it had a lot to do with the fact that it was a newly constructed building with an exceptional level of cleanliness.

The presence of pests within food premises is not a given and this attitude held by many food businesses needs to change. Failure to maintain adequate pest control may result in your business being fined, prosecuted or ending up on a “Name and Shame” database.

Identifying Food Safety Hazards

Why is it that so many food businesses fail to identify their food hazards correctly? The identification and control of food hazards forms the basis of every HACCP Program. It is really HACCP 101! The worst case scenarios for not identifying and controling food hazards adequately are food poisoning outbreaks, product recalls and very bad media coverage (damage to your brand). So how do you work out what hazards could occur in your business?

Investigating Non-Conformances

As a food auditor an important part of the job is identifying non-conformances during the audit process. Unfortunately, many food businesses struggle with what is required to rectify non-conformances. Any non-conformance identified during an external or internal audit should be seen as an opportunity to really get in and resolve an issue before it escalates to a point where significant damage can occur to the business.

Welcome to the Food Safety, Quality and Compliance Blog

I spend 50% of my working life auditing food businesses for compliance against food safety legislation and customer standards like BRC, McDonalds, SQF, WQA. Don't get me started on why there are so many different standards - I will save that for another day.

When I audit, I get asked all these weird and wonderful questions by Quality Assurance Managers and food business owners that the majority of the time I think are pretty straight forward. I think from working in food compliance auditing I automatically assume that everyone knows what I know (because I don't think it is rocket science!). After 18 years doing this gig, I have finally got it that people don't. It is not through lack of intelligence, just lack of time and priority.

I live and breathe this food safety and compliance stuff and I am very very passionate about it. I am also very passionate about trying to help small business to be aware of their business risks in regards to food safety, quality and compliance. So hence starting this blog.

I hope to bring you insight into my world and hopefully you will learn stuff along the way. So without further to do, let's get started on this journey!