Top 10 Food-Safety Inspection Issues (Part One Of Two)

By Laurel Maloy, contributing writer, Food Online

The top 5 inspection failures are also the ones that are important to implementing and maintaining a safe food supply

Each summer, Australia hosts a Hazard Analysis and Critical Control Points (HACCP) conference. 2014 marked its 21 year with the keynote address entitled: Your Reputation Is Key! Behaving Your Way Into Effective Leadership! That pretty much says it all, but one particular speaker, Amanda Evans, known as the HACCP Mentor, broke it down to the 10 most common areas of non-conformance in Australia and New Zealand. A quick bit of research for U.S. statistics has proven that the same top 10 issues are prevalent domestically. Somewhat surprisingly, the top 10 are also the most elementary. It’s all about getting back to basics.

Here are the TOP 5 Inspection Issues with suggestions on how to better comply:

HACCP
Many facilities have a really difficult time putting an HACCP plan in place. It may be a matter of simply being so familiar with the environment, that the hazards are not highly visible. Or, it might be that the very mention of HACCP puts you into a state of immovable fear. Whatever the reason, HACCP is not an option; it is a requirement and is at the very heart of food safety. It is an invaluable tool, which, when utilized properly, is capable of putting your establishment on the FDA’s short list of “good guys.” Ensure your flow charts are up-to-date and verified. Critically assess your manufacturing process for Critical Control Points (CCPs) at which hazards can be eliminated and then monitor those CCPs, being sure to keep complete and concise records. Establish Critical Limits (CLs) well within recognized, science- and risk-based guidelines. Don’t just strive to be in compliance; strive to be better.  

Cleaning
Whether it is blatant or hidden, filth is not acceptable and must be addressed. Simply put, if an FDA inspector walks into your facility and does not see sparkling clean, you will be called on the carpet. It is really quite simple to comply with the requirements for “at first glance” cleanliness. What becomes more difficult is assessing your facility for those hidden dirt and grime catchers that are oh-so capable of harboring foodborne pathogens. The premises, equipment, and all utensils must be spotless. Look at some of these spots in your facility for hidden muck — floor drains, under and around equipment legs, and in deteriorating grout lines. Also, look at your processing equipment and discover all the nooks and crannies capable of catching food debris, and then do something to change that. Include a close inspection of any utensils used as well. Those with seams, rivets, or screws can be the source of your next recall. Seamless, stainless steel utensils are easy to keep clean and a relatively inexpensive investment. Floor drains can be made more accessible by raising equipment above it or cutting access holes. Grout lines can be cleaned out and then filled with an epoxy-type grout. Castors on equipment legs can make heavy equipment easier to move for cleaning around and under. Any areas that cannot be corrected to the point that debris collection is impossible should be included in your HACCP plan for regular inspection and cleaning.

Pest Control
The first step towards pest control is cleanliness. Food debris, moisture, and darkness are invitations to pests to move right in and get comfortable, regardless how small the accommodations might be. One small corner where the power washer consistently pushes debris and then doesn’t dry out is like a party invitation. Mice, cockroaches, and flies are all notorious garbage lovers and it is no secret that they carry disease. The Food Safety Modernization Act (FSMA) targets the subject of pest control as a primary method by which to control foodborne contamination. Your food safety plan must include an Integrated Pest Management (IPM) strategy. So, look first to cleanliness and then to those areas where pests can make their way into your facility. Finally, develop an actionable plan for IPM that makes sense for your particular establishment — stick to it, monitor it, and improve it as needed.  

Foreign Matter Contamination
Foreign matter in food products continues to be one of the primary reasons for food recalls. Behind foodborne pathogens, foreign matter — such as glass, metal, or plastic — accounts for a rising number of emergency room visits. It is almost always unintentional and is also almost always preventable. Having an effective HACCP plan in place is a first-line-of-defense against foreign material contamination. We all know this contamination is possible. The trick is to identify the most at-risk areas of your operation and then to deploy an adequate detection system(s). You have a multitude of choices available. Your answer for the best foreign matter prevention and detection may be in a combination of choices. Once in place, it is essential that the efficacy of your detection system is verified regularly. Consider including this operational aspect into any purchase of new equipment or upgrade to existing equipment.  

Traceability
As FSMA is implemented, recordkeeping is a top priority, with an emphasis on traceability. As recently demonstrated in the ever-expanding caramel apple and spice recall, the ability to quickly and effortlessly identify the “chain of supply” is critical to effectively initiating and implementing a recall. If you get a cup of fresh parsley from a farmer down the road, document it. Regardless of how small the quantity or how trusted the source, documentation is key to identifying the source for food contamination. The FDA’s new authority means that you need to get super serious about this issue. Having a traceability system in place is not an option, it is a requirement. 

These first five issues are the most-common subjects for FDA recalls and/or warning letters. It is not only a legal responsibility, but a moral responsibility, to ensure your facility is providing the safest food possible to the consumer. Part two of this series will explore the five next common food-safety inspection issues. Stay tuned.