Top 10 Food-Safety Inspection Issues (Part Two Of Two)
By Laurel Maloy, contributing writer, Food Online
Part One of this series explored the top five inspection failures food makers fall victim to during inspections. These next five food-safety inspection issues, though not formally regulated, most often result in FDA warning letters or non-compliance disciplinary action and/or facility closure.
Facility Maintenance
Maintenance can be a difficult issue to deal with, though it falls under the umbrella of Good Manufacturing Practices (GMPs). It is a necessary evil, but one that also interferes with production schedules and delivery performance. Many facilities put maintenance on the back burner, pushing the limits of equipment and personnel until failure occurs. Failure could mean a total breakdown of the production line, but could also result in undetected foreign material contamination of your product. Preventive maintenance is the surest way to circumvent a catastrophic occurrence at a later date and should be included in your Hazard Analysis and Critical Control Points (HACCP) plan. For example, can the erosion of a gasket result in food contamination? What about those moving metal parts that, with proper maintenance, will not only last much longer, but can be replaced before they contaminate your product with metal shavings? Maintenance, especially of the preventive kind, should be built into your company’s food-safety culture and production schedules. Doing this will ensure your customers have realistic expectations and that your product will be of the highest quality.
Facility Layout And Construction
Under this label also falls the security of your site and external grounds maintenance. Some things to take into consideration concern the materials your facility is constructed of. The most food-friendly materials will be smooth, durable, moisture-proof, and easily cleaned. As many facilities being used have been constructed decades ago, you may face the realization that your facility, as it is, is no longer practical. It is harder to keep clean and may be unsightly, even to the consumer passing by. New construction is an option, albeit an expensive one. Another, less-expensive option may be to refit your facility with walls or wall coverings, floors, and ceilings more in keeping with an environment designed to produce safe food. The up-side of a renovation of this type is value-added employee morale, ease of cleanliness, lower utility bills, possibly reduced insurance costs, and an overall enhanced appearance when the FDA comes to call.
Also, pay some attention to the exterior of your facility. Fix pot holes and water-collection areas where vermin and mosquitoes can be a problem. Inspect for and secure the gaps and crevices on exterior walls where pests can get in. Muddy foot prints coming through your front door are a prime indication of a problem outside creating a cleanliness problem inside. Cross-contamination is a common problem. For example, if an employee also raises chickens and has contaminated shoes, he or she walks through the mud, leaving some behind for the next person to pick up on his/her shoes. The same can be true of petroleum products, which can create a slippery floor and lead to employee accidents and injury.
Finally, ensure you have a plan documented and implemented to deal with vendors, visitors, and even your staff. Intentional Adulteration is addressed in the Food Safety Modernization Act (FSMA); therefore a facility security plan is a necessity.
Product Review & Prerequisite Verification
When it comes down to an audit, the FDA is going to look first to your recordkeeping. Your prerequisite programs and HACCP plan is liable to set the stage for what steps the FDA takes next. Your prerequisite program is actually a separate entity of your HACCP plan, though the two are closely integrated. Where the Critical Control Point (CPP) is meant to control a food-safety hazard; the prerequisite program is intended to prevent one from occurring. Some examples of prerequisite programs for your facility may include: a pest control program, allergen or foreign material control, GMPs, or maintenance and sanitation.
Product review will include verification of updated ingredient lists from suppliers, which is logically followed by labeling review. It will also include any testing, either of your product or of your facility, up to and including air and water quality. Expect to supply the inspector with a testing schedule, specifying the types of tests, the dates, the parameters, and the results. Also include the person(s) responsible for performing the tests and contact information. Ensuring that every aspect is continually monitored and updated will demonstrate your commitment to compliance and earn you a thumbs up from the inspecting authority.
Supplier Approval & Documentation
Again it comes down to recordkeeping. Every single transaction must be well documented. Your service suppliers, such as those for pest control, laundry, cleaning products, or waste must be approved for performing the service they are contracted for. If certification of some type is required, make sure to get a copy and to request an updated copy on a predetermined schedule. New employees of service vendors should be vetted and documentation provided as to their qualifications. The same goes for raw materials. Some suppliers are known to have questionable practices that have already gained the attention of the FDA or your local inspection authority. The FDA’s negative profile of one of your suppliers may decrease your standing as well. Be aware that paying a lower price may, in fact, be indicative of a lesser quality product. Monitor all procedures in place and ensure compliance. By the same token, if a procedure is unnecessary or redundant, take it out of play.
Training
The value of training is immeasurable and, if done cost-effectively, can provide the greatest return on your investment dollar. FSMA compliance will not necessarily be easy, but it is attainable. Having an educated staff not only puts you on an easier road to compliance, but will foster an environment more in-keeping with a culture for food safety. Studies have shown that trained employees are engaged employees. An engaged employee will have a more emotional and purposeful commitment to his or her employer. Dale Carnegie’s study demonstrates that engaged employees could potentially increase a company’s performance by over 200 percent. Engage an employee by training in order to improve management/employee relationships, build confidence, and develop a previously lacking sense of pride. Investing in management training and utilizing a train-the-trainer type program will go a long ways to demonstrating the value you place on your employees. From this aspect, management can then identify those most motivated and inspired, and then utilize those people to further train and monitor the workforce. Training is a win-win for the entire company, as illustrated in the 2014 Global Food Safety Training Survey.
For decades now, we’ve heard the mantra, “Work smarter, not harder.” In fact, though we don’t hear it as much anymore, it is actually the basis for successful businesses everywhere. If you feel your facility has lost its edge, look to the FDA for inspiration. Since 2011 the agency has streamlined and main-lined its organization to work smarter, not harder. Money doesn’t grow on trees, in anyone’s backyard. Getting your food processing establishment in shape now will put you ahead of the competition later. Paying particular attention to these Top 10 food safety issues will get you there sooner, rather than later.