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DQM Blogs Food Safety News

Is it a Risk? Is it a Hazard? What's the Difference?

As I talk to people about FSMA and other food safety regulations, I am constantly asked the difference  between a risks and hazards.

As FSMA comes into effect there is going to be a lot more emphasis on systems that put in prevention programs..."

Under the proposal, each owner, operator or agent in charge of a facility (those required to register with FDA under Section 415 of the FD&C Act), with certain exceptions, would be required to comply with the hazard analysis and risk-based preventive controls. The preventive controls are science- and risk-based in that the rule would require controls only where necessary to prevent hazards to public health and exempt certain facilities from requirements or modify requirements for certain low-risk activities. Second, they are flexible in that firms could develop preventive controls that fit their products and operations, as long as they are adequate to significantly minimize or prevent all food safety hazards that are reasonably likely to occur."

Risks are the big picture.  From 3000 feet in the air, places like FSIS look at the public health impacts of various risks.  The FDA has also identified a lot of different risks in the food chain.

• Food from unsafe sources
• Inadequate cooking
• Improper holding time and temperature
• Poor personal hygiene

The FDA has identified 5 interventions, outlined in the Food Code, that inspectors look at during assessments of plants to ascertain the level of management control over those risks.

• Demonstration of Knowledge
• Implementation of Employee Health Policies
• Hands as a Vehicle of Contamination
• Time/Temperature Relationships
• Consumer Advisory

Essentially if a plant can show that the food safety systems use the interventions to mitigate risk, the FDA deems the food fit to eat. Many scientists over many years and with a lot of money investigated just where in plants food risks come from and came up with that list.


So using the FDA Food Code risks, we can identify some hazards.  For example

Risk: Food from unsafe sources (for example, leafy greens that are picked in unsanitary conditions) 
Hazard: E. coli
Intervention: Approved supplier program can make this not reasonably likely to occur (remember, critical control points control hazards, pre-req programs make hazards NRLTO).  This would be a knowledge based intervention

Risk: Inadequate cooking (let's take eggs) 

Hazard: Salmonella 
Intervention: Cooking shell eggs to 145F for 15 seconds, or to 160 if they are with other foods.  This is an example of a critical control point. There's going to be nothing else after the cooking step that would kill salmonella.  This would be a time/temperature intervention.  A consumer advisory intervention would be telling consumers that eating undercooked eggs can make them sick.

Risk: Improper holding time and temperature (for example, cooked veggies in a sauce in a buffet)
Hazard: Staph aureus intoxication
Intervention:  This one actually needs several.  First, a time/temperature intervention of keeping hot foods hot and out of the staph danger zone, this would be a critical control.  Second, employee health policies need to emphasize not handling food with open cuts, need a pre-req program that complies with GMPs here.  And third, understanding how hands are a vehicle for contamination and emphasizing hand washing, again a pre-req program on personal hygiene.

As FSMA comes into affect, FDA regulated entities are going to have to catch up to USDA regulated entities.  Written food safety plans that take scientifically developed risks and delineate the hazards that come out of those risks will be required.  DQM is set to help small growers and processors cope with the coming onslaught.  Call today for your free phone consultation and ask for Dr. P.  90-907-7798

Food Safety from Producer to Plate: Part 1- E. coli in Beef

We talk a lot around here about what processors can do to improve food safety.  That's where most of the inspection is and that's where it is possible to put in the controls to eliminate food borne illness (FBI).

However, one of the main reasons why the processors need to put in these controls is because their supply comes in contaminated.  Animals and plants grown on a farm harbor pathogens.  Nothing we can do about it.  Biological systems are complex and we are never going to eliminate pathogens from our food completely.  Nor do I think should it be a goal to eliminate them, because these microbes exist for a reason.  They work in the soil and they work on an animals gut to aid digestion.  We find trouble when microbes are in the wrong place, occur in much too high a concentration, or occur at the wrong time.

As our local food movement moves forward, producers needs to know about the various pathogens of FBI that occur in their livestock and what they can do about them on the farm.  A lot of times this stuff is obvious, but, putting in FBI controls at the farm can save a lot of headache down the road.

So with that said, today's post is the first in DQMs "Producers to Plate" series!  And we are going to start to tackle E.coli from the viewpoint of what a livestock rancher can do to control it.

First, what is  E. coli?  E. coli is a group of bacteria that live in the large intestine of warm blooded animals.  E. coli, like other bacteria, isn't a problem unless it is too high in number, or in the wrong place. E. coli can use the flagellum to migrate out of the gut of an animal and "walk" itself to an aberrant site like the urinary tract causing a UTI.  E. coli contamination of an udder can cause mastitis by the same mechanism.  The bacteria gets where it shouldn't be, has a lot of nutrients and no bacteria to compete against, and POW, infection.

In the food supply, we worry about E. coli because it can cause very serious FBI, like hemolytic uremic syndrome.  Though cases of E. coli are going down the CDC estimates that there are 26 cases not reported.  So we have a lot of people not being diagnosed.  Which means there's no traceback to where the illness might have come from.

However, livestock ranchers can help protect their product by taking some steps to decrease E. coli in their herds.  Also, implementing these can help to protect a rancher's family from E. coli, as it is also a zoonotic disease.

Vaccinate the herd against E. coli
Feed probiotics with Lactobacillus (like Bovamine)
Test for supershedders and cull them (and not into the food supply)
Make sure the cattle are clean before slaughter.  Work with your processor and find out what his/her plan is for killing clean animals.  Preventing hide contamination of meat can not be over estimated.  This should be one of the pre-req programs (or part of a pre-req program) the processor has.

This

Not this

As the CDC has indicated, E. coli contamination is a battle we are actually making headway against.  The local food movement has a great opportunity here to make sure that our consumers have access to meat that's as free of E. coli as possible.  It will drive confidence and sales.

What does the OIG report mean?

Well, as the wheels of governance turn, the OIG has audited how FSIS tests beef trim for grinding.

BLUF: "The Office of Inspector General (OIG) found that the Food Safety 
Inspection Service (FSIS) needs to re-evaluate its E. coli testing 
methodology, as it relates to the downstream processing of boxed beef 
products. FSIS tests product designated as ground beef or likely to 
become ground beef, but they do not sample all boxed beef product. 
Some downstream processors grind such boxes of unsampled cuts of 
beef without sampling it for E. coli prior to grinding. Similarly, 
“retail exempt establishments”—grocery stores, butcher shops, etc.—
potentially grind their own ground beef; but unlike Federally 
inspected plants, FSIS does not sample and test bench trim at these 
establishments for E. coli. FSIS does have a program for periodically 
testing the final ground beef products at downstream processors and 
retail exempt establishments before it enters commerce. Also, FSIS is 
not testing tenderized meat products for E. coli despite several recent 
recalls."

So, there are a few gaps.  FSIS tests the beef trim that's obviously going for grinding, but it doesn't always test boxed beef that can end up being ground.

Raise your hand if you work at an establishment that grinds boxed beef.  Yep, that's a lot of you.

Directive 10010.1 sounds like it was a big target of this audit.

Which means, small USDA inspected producers, get ready for more testing.  Make sure your supplier program is pristine.  Are you keeping track of where that boxed beef is coming from?  Do you have a really good lotting system? If you get the boxed beef from a broker, it is going to behoove you to trace that beef trim back to the original source.

And for heavens sake, if you are tenderizing beef test your needles, test the tubing and keep really good records.  Because FSIS is probably going to be taking a really close look at what you are doing.  Nobody wants and OIG report out there, even on a Friday afternoon, that says you aren't fulfilling your primary mission.

PS- BLUF is Army speak for Bottom Line Up Front.

Validation- Are Your Systems Aimed at the Right Spot?

It is really easy to confuse verification and validation.  Validation is a subset of verification, so when you are validating, you are verifying, though the converse is not true. Confused yet?

Verification= are you doing what you say you are doing?
Validation= is what you are doing protecting the public health?

Validation requires collecting and evaluating scientific and technical information to determine if the HACCP plan, when implemented correctly will effectively control the identified hazards (paraphrasing from a NACMCF definition).

Validating your HACCP means that you are assuring the plan is adequate for controlling food safety hazards.  If that seems like a big task, it is because it is.  You can't find a scientific paper that validates an individual HACCP  plan as a whole.  But, you can break it up and validate the CCPs.  Every CCP needs to be validated.  Taken together validated CCPs validate your HACCP.

So, start googling.  But not just anywhere.  Read up on your regulatory agency and validation

• USDA 
• FDA- dairy
• FDA- juice look in section F
• FDA- seafood (lumped into verification)

Start with those resources and look for scientific papers that pertain to the process you are working on.  Then start looking at the known physical, chemical, and microbiological hazards in your process.

Then, ask around to see if you are on track.  Ask your extension agent for help.  Shoot me an email, I'm always up for a conversation about food safety!

Once you have scientific papers to back up your CCPs, look at your actual process to see if it is delivering those critical limits.  Is your bacon being smoked at 144F?  Every single slab?  In all parts of the smoker?  Every single time?  Got records to prove it?  How about your cooler?  Is it supposed to be below 41F?  Is it?  In all parts, even right next to the door?  How are you going to test it?  Do you have records to prove it?

Validation can be hard, make sure you are doing it right.

Charcuterie For the Small Processor

DQM spent the weekend at the New England Meat Conference.  It was a fantastic gathering of entrepreneurs, producers, processors, chefs, meat cutters and just about anyone else working to create the New England market for local meats.

And if there was one over riding interest after "isn't this cool?  All the people I know and like are in one place!!" it was charcuterie.

From a food safety perspective, charcuterie is challenging.  But hey!  Let's break it down!  Food safety challenges are what we do here at DQM!  The following is by no means an exhaustive list, but, it is a good start.

First- figure out what you want to make.  And don't just say sausage.  Do you want to make Spanish sausage?  Mexican?  Polish? The more specific you define your product the easier it is going to be.  You need a recipe.  Even if it is your grandmother's that you used to make in the basement, you need to know what and how much is going into the product

Second- Understand what process steps are.  When you write a HACCP plan, you need to have a process flow diagram.  And your commercial charcuterie production needs to have one full of excruciating detail.  You are going to get inspected on how well you adhere to this flow, and if you don't, there can be huge consequences.  Make sure your process flow diagram starts with Receiving Meat.

Third- Once you understand what you are making and how, then start thinking about the whole food safety plan including pre-req programs, the HACCP plan itself, training, and what avenue of inspections are available.

Putting a delicious and safe charcuterie product in the marketplace is absolutely possible.  However, it takes attention to detail, and frankly, is tough to do without some help.  When you are ready to take that step, give DQM a call, and we will be right there with you to put your wonderful product into the marketplace!

Verification of CCPs

So, are you telling the truth?

Is your production team doing what it says?  Are you sure?

Wanna know how to be sure?  It's through verification!

First, an easy way to remember the difference between verification and validation.  Verification comes from the latin root vera meaning truth.  Ergo (ha! more latin) verification is the HACCP step where you determine if you are telling the truth about your HACCP plan.  Validation asks if what you are doing is useful to control hazards.

Verification has 3 components:

• your CCPs are being followed
• the whole HACCP is in place and being followed
• regulatory verification

Verifying can be done many ways.  In meat production, a pre-shipment review is a regulated verification step.  In other types of production, any step where you review your logs and sign off that you have reviewed them, is a verification.  Audits are another good way of verifying work.  Finally, having the regulators pay you a visit and give you their findings is a way of verifying.

Some good ways to verify:

• Review your monitoring records.  You are spending ages recording everything, take a look at it, make sure you are recording correctly.  Review at a frequency that makes sense.  Don't review your cleaning step once a quarter only to find out that your concentrations of cleaner is WAY off.  Imagine THAT recall.
• Calibrate!  Got a thermometer?  Is it working?  You sure?  Fill a container with ice water, stick the thermometer in.  Make sure the thermometer is reading 32F.  If you don't remember why this works, consult your high school chemistry notes.
• Grab your accountant, promise you will take her out to lunch if she'll spend some time looking at your workers work.  Put her in a lab coat and have her watch one part of your production process.  Don't worry, the workers will do it right for about 3 minutes, and then, they'll do it how they always have done it.  Over lunch, talk to your accountant and figure out what's working and what isn't.
• Get some lab samples done.  Finished product testing is ok, but non-specific and expensive.  Test something specific, like your injector, or swab a food contact surface in your processing room.  If it turns up positive...

Call me, I'll help.  Dirigo Quality Meats can help with straightening out all sorts of processing problems.  908-907-7798

HACCP training coming to New England

I've been spending my week in Washington DC with the good folks of the GMA doing a HACCP "Train the Trainer" class.  In addition to covering every nook and cranny of HACCP plans for both USDA and FDA plants in exhaustive detail the course has gone into great detail about how to teach adult learners.

When my courses are approved, I am going to start teaching IHA accredited "Introduction to HACCP" courses.  I am also going to bring shorter 1 day courses into the market on Pre-Req programs, SOPs, and sSOPs among others.  Currently, these courses are simply not available to Norther New England producers without traveling out of the region.

But no more.  The highest quality, most rigorous HACCP training is come to New England.  Brought to you by Dirigo Quality Meats.

The first one day general class is going to be April 24 9-5 at the Androscoggin Chamber of Commerce.  Sign up on the webpage.

Pre Req Programs

HACCP plans can not exist without the proper pre requisite programs (PP).  PP are the basis of a comprehensive food safety program.  PP's do two things in food production:

1. They make hazards "Not Reasonably Likely to Occur" (NRLTO)
2. They control just about everything else in a plant that isn't hazard.

So, what's a hazard?  A physical, chemical, or microbiological adulterant of food.  Think metal shards, allergens, and E. coli.

PP don't control those hazards.  Critical Control Points (CCPs) do.

But what do PP do?  They use Standard Operating Procedures (SOPs) to bring control into the plant and impose the order necessary to reduce the likelihood of physical, chemical and microbiological contamination of food.

So what are some PP?

• Chemical hygiene plans
• Pest Control plans
• Receiving SOPs
• Approved supplier programs
• Personnel hygiene programs

The truth is that most of the food borne illness outbreaks occur because of improperly implemented and executed PP.  CCPS do.  CCPs are generally observed and controlled, that's the point.  They work. But, it takes a whole culture of food safety for everyone to make sure that PP are also observed and practiced.  Fail at them, and all the CCPs won't help.

Need help evaluating your Prerequisite Programs? Email Dr. P

Is it getting chilly in here? Cooling as a CCP in Meat

I talk a lot on this blog about broad food safety issues, but today, I am going to talk about a specific CCP point as it occurs in both Fully Cooked RTE foods, and Heat Treated, Not Fully Cooked, not RTE foods.

When writing a meat/poultry HACCP the CCPs we put in control for Physical, Chemical, or Microbial hazards.  Most of the time, we spend a lot of time worrying about what those microbes are doing on our meats.  Writing a heat treatment CCP makes us feel all good because we are killing a lot of those microbes.

But we don't kill the spore formers.  Those Clostridia and Bacillus can survive boiling water, freezing cold, and pretty much all the chemicals we might want to throw at them.  The spore itself is pretty fascinating.  However, what spore forming bacteria can do to us and our food can be problematic at one end of the spectrum, and deadly at the other end of the spectrum.

When spore forming bacteria are heated, they form their spore, lie dormant till the threat is passed, then return to their normal, active vegetative state where they are the greatest threat to health, because they are making toxins and multiplying.  Cooling food can spend a lot of time in the danger zone of these bacteria.  Ergo, we must cool them quickly so that the spore formers go dormant once again.  

Clostridia is especially active at 130F to 80F and thus cooling must be as rapid as possible within that range.  But keep in mind, that cooling (like heating) is a dynamic process that takes place at a different rate in different cuts of meat.  A uniformly ground and packed sausage will heat and cool uniformly.  A bone-in ham will not.  And a bone-in ham will cool at a different rate than a brisket.  The cooling of the product depends on the temperature differential between the hottest portion of the piece and the coldest portion of the piece (for you calculus types this is dT/T).  The greater the difference between the hottest part and the coldest the more rapid the cooling.  So what can a processor do to speed things up?

Use potable water to continually chill the outside of the meat.

Put the meat through a tunneling system.

Put the meat in the freezer

FSIS really likes it if the meat can drop from 130F to 80F in 1.5h and then to 40F in 5h (Option 1).  

Keep in mind though that cooling meat puts heat in the air, hot air rises, hits the cool ceiling of your establishment, cools and condenses.  And that my friends brings out the Listeria!  But that is a post for another day.

Many small processors don't have the myriad of expensive equipment to cool the meat and handle the moisture in a way that satisfies Option 1 of Appendix B which leaves cooling meats in the finished product cooler under Option 2, which brings the temp from 120F to 55F in no more than six hours.

Both options are valid.

But, you have to test that the cooling is occurring in all parts of the meat, in all the sizes you are using.  Thermometers and time temperature graphs are a great way to test this.  

Interested in learning how to make a validation test?  Send me an email for a validation testing procedure.

Hazards and FSMA

The regulations that are part of the FSMA, are becoming clear.  The FDA is clearly working hard on making sure the marketplace has adequate information.  They've re-organized the website and added a Small Business Page.

But here's the short and dirty version.  Processors that need to register:

• Dietary supplements and dietary ingredients
• Infant formula
• Beverages (including alcoholic beverages and bottled water)
• Fruits and vegetables
• Fish and seafood
• Dairy products and shell eggs
• Raw agricultural commodities for use as food or components of food
• Canned and frozen foods
• Bakery goods, snack food, and candy (including chewing gum)
• Live food animals
• Food for animals (e.g., pet food, pet treats and chews, animal feed)

Farms don't have to register IF all the food  "is grown, raised, or consumed on that farm or another farm under the same ownership, as well as facilities that manufacture/process food, provided that all food used in such activities is consumed on that farm or another farm under the same ownership."

FDA compliant businesses will need to address the following hazards:

•  Biological
• Chemical
• Physical
• Radiological hazards
• Natural toxins
• Pesticides
• Drug residues
• Decomposition
• Parasites
• Allergens
• Unapproved food and color additives
• Hazards that occur naturally
• Hazards that may be unintentionally introduced
• Identify and evaluate hazards that may be intentionally introduced, including by acts of terrorism

That is no short list!  

Fortunately, help is at hand  I will teaching a Risk Analysis/HACCP 101 course on April 24 at the Androscoggin Chamber of Commerce.  The Course wil cover the risk analysis and HACCP that the FDA requires.  Registration is on the website.  We look forward to seeing you!

Labeling out of RTE

Back in September, the USDA rolled out a new Listeria Compliance Guideline.  At first glance this Guideline seems to be only for RTE foods.  Fair enough, that's where Listeria is most problematic.

But, Attachment 1.2 updates how they consider products that receive a full lethality treatment that are not RTE, and are not defined as such by 9CFR 430.1.  Value added products that are not hot dogs or deli meat can now be "labeled out" of RTE status.  Producing those products under a Heat Treated, Not Fully Cooked, Not Ready To Eat, then labeling them as NRTE, and clearly marking them with cooking instructions, now seems to be an acceptable way to put cooked product into the marketplace, without having to comply with Listeria controls.

This means that plants that have hesitated to put smoked meats, pot pies, or frozen dinners into the marketplace, now have clear and concise guidelines on what to do and how to justify their decisions.  Thanks USDA!

Do you have a product that you are wondering about?  I offer free initial phone consultations on HACCP and other food safety plans.

Risk Analysis

As I have posted on the Dirigo Quality Meats FaceBook page, I am going to start offering Risk Analysis and HACCP training. As I go about the process of writing this one day course, I am learning a great deal.

1. I probably should have stuck math in college out through linear algebra
   
2. There is practically no one bridging the gap between rigorous mathematical approach to risk analysis and a more bottom up organic approach that is common in food safety discussions.
   
3. The preferred method of teaching about risk analysis starts with a definition.  I was taught in high school English class this was a pretty weak way to start an essay.  I think the same is true of a Power Point deck.
   
4. I am trying to come up with some interesting risk analysis activities and it is HARD.

HACCP Training Coming to Maine!

Exciting news from Dirigo Quality Meats.  I am going to take an International HACCP Alliance accredited "Train the Trainer" course in DC in March.

This means that I am going to be able to off high quality, accredited, close, HACCP courses here in Maine.  No more traveling for HACCP courses for Maine producers and processors!

Over the coming months I will start offering the following IHA approved courses

• Introductory Course for Development of HACCP Plans for Meat and Poultry Establishments
• Executive Briefing on HACCP
• Sanitation Standard Operating Procedure (SSOP) Course
• Introduction to HACCP

In addition, I am going to work with Cooperative Extension to design a one day HACCP course that will give an overview of risk analysis and the HACCP approach to food safety.  This course will satisfy training requirements for regulating bodies.

It is important to note that for processors trying to achieve SQF certification, their SQF practitioner must have a certificate from a HACCP course.  The four courses listed above will satisfy that requirement.

If you are interested in taking one of the courses, I'd love to hear from you. Send an email to michele<at>dirigoqualitymeats<dot>com.

Labelling

One of the most complex process in putting food into the retail market is labeling.  How to tackle the labeling problem?

Label is a broad term, answer these questions BEFORE you spend money with a designer doing packaging.

1. Are you big enough that you need nutrition labels?  
2. How about safe handling instructions?  
3. Cooking instructions?  Are they validated?
4. Are you making a ready to eat (RTE) or a Not Ready to Eat (NRTE)?
5. Any allergens in your product?
6. How are you going to determine your ingredients list?
7. Are you a USDA product, and thus need to go through LSAS?

Once all the regulatory stuff is squared away, only then can you go to town on package design!

Veterans in Agriculture

There is a movement growing here in America.

Call it Veterans to Farmers

Call it Farmer Veteran Coalition

Call it Combat Boots to Cowboy Boots

We are veterans using the skills we've learned in the Armed Services to make American agriculture stronger and more secure.

Think about it what farming entails-

• getting up early (milking parlor is calling, it's 4AM)
• fixing things (who has money for new?)
• solving problems on your own (how are you going to get that steer out of that mudpit?)
• thinking outside the box (hmm, what can I rig up to extend the growing season?)
• following regulations (water, sewer, GAP, town, county, you name it)

Folks, this is what we train for in the military.  And when something goes wrong?  Adjust fire and keep moving.

So, if you know a veteran and that veteran is interested in any type of agriculture, send me an email (michele <at> dirigoqualitymeats <dot> com.  The US food supply is waiting.

Who is involved in food safety? Everyone.

In the world of food processing, red meat is known as a high risk food.  25% of all outbreaks of foodborn illness can be directly linked back to a meat plant.  As a result of outbreaks of illness, red meat plants are very closely regulated by the USDA.  An inspector is in the plant, walking around on the floor looking at the processing when meat or meat products are in production.  That seems like a good way to stop any potential pathogens, right?  Well, as economists say, it is necessary, but not sufficient.  One FSIS (Food Safety and Inspection Service) inspector, can not prevent all contamination of the product.

As a result, food companies have voluntarily complied with a variety of auditing schemes imposed by the market.  The Global Food Safety Initiative is an umbrella group of food processing, auditing, allied services and non government organizations devoted to food safety, that has authorized a network of auditing schemes for food processing. One such scheme, Safe Quality Food Initiative or SQF has largely been adopted by US meat and food processing companies.  SQF certification means the company has gone through a rigorous assessment of their policies, procedures, and documents to check and see if the company is saying the right thing, doing what they say they are going to do, and, whether what they are doing actually contributes to food safety?

As a food safety consultant, I am deeply interested in creating a culture whereby all actions contribute to the safety and quality of the product.  A safe and wholesome product starts with understanding that a safe food is everyone’s job.  For example, anyone, even upper management, popping onto the production floor, has to follow the same hygiene procedures as a worker who is going to be on the floor all day.  Or, truckers and distributors need to understand not only that the product needs to be kept at the correct temperature, but why it needs to be kept at the correct temperature.  Shipping clerks need to understand that only approved vendors can make deliveries, and thus, the process that approves the vendor, so the clerk is empowered to accept or refuse a shipment, with logical reasons to back him or her up.

It is very exciting to implement this sort of system from the ground up.  However, most companies must go back and re-engineer their processes, and change things around in their plants to comply.  They battle entrenched cultures of “well, we’ve always done it this way”.  But, I sincerely believe that if you teach people about food safety and how to keep food safe during the manufacturing process, all levels can contribute to the process and make it successful

Presentations

The minute a baby animal hits the ground (well, the momma isn’t usually standing, so really, it is a figure of speech) the calf, piglet or lamb is exposed to all sorts of pathogens. As a food safety veterinarian, I am deeply invested in making sure that farms have healthy animals, so that consumers can have safe food.

So, as part of the efforts to have a clean food supply, I made a presentation to the ranchers re-certifying for the Beef Quality Assurance program here in Maine.  I talked about all sorts of diseases.  Both those that come into the food supply, and those that affect ranching, like foot and mouth, or that affect ranching families like rabies.   In March the Dept. of Ag will hold a PQA Plus course for pork producers.  This will be the introduction of a formal PQA program in Maine.  If you are interested in attending, you can send an email to Cindy Kilgore, the Livestock Agent at the Dept. of Ag.

If you’d like a copy of the presentation, or would like me to come and talk to your group, drop me a line.

Listeria control

Listeria.  It's in the drains, it's in the soil, it's on the shoes of the workers that walk into your building.  And if you are making a Ready To Eat (RTE) product, it can be a really big problem.  USDA guidelines  gave some great advice to processors on how to approach their listeria control program.  In short, if you are producing a product that is readily identifiable as RTE and they have risk for environmental exposure you must implement one of three regimens to control Listeria.

Alternative I- Post lethality treatment (PLT) and antimicrobial agents or processes (AMA and AMP respectively).  This option works for conventional products that can be preserved and cooked in their packaging

Alternative II- PLT or AMA/AMP

Alternative III- Implementation of a sanitation program to control Listeria

So, does your product require listeria control?  Ask yourself these questions:

1. Is it Ready to Eat?  Or, if it is on the fence (like frozen dinner) are you planning on labeling yourself out of a RTE category?
2. Is it exposed to listeria after the final pathogen control step in your HACCP?

If the answer is yes to both of those questions, then you need to implement the Listeria Rule.

Developing a HACCP

As America's food system becomes more professionalized and distribution channels widen, small producers and plants have an opportunity to move into new markets.  Consumers are looking for safe, wholesome food, and entrepreneurs are stepping up to provide new products, or put an new twist on established products.

Food however, exists in a regulatory framework.  If you want to make money selling food, someone is going to regulate you.  And whomever that someone is, you are going to have to satisfy them that your food safety plan is adequate to the task of keeping your product safe and wholesome.

Enter HACCP.  Back in the dawn of the food safety movement as it currently exists, some smart folks figured out that testing final product for pathogens was a really expensive, and not terribly effective way of keeping food safe.  So, they came up with a scheme called HACCP.  Hazard Analysis for Critical Control Points.  HACCP plans were first implemented in a regulated way at the FDA with seafood and juice.  Then the USDA adopted HACCP planning for its plants, and no one has ever looked back.

But HACCP is more than just a process diagram.  It is a way of thinking and planning on how to keep your product safe starting before it even comes to your loading dock.  HACCP allows your food safety team to manage your production process to keep the plant and people healthy.  And therein lies one of the keys to HACCP, and to food safety in general: teamwork.  From top to bottom in the company, people must be on board with creating safe food.  The executives must understand how safe food contributes to the bottom line (how expensive would a recall be??) and the line workers must know why the SOPs are there, why and how to follow them.  Food safety isn't just a checkoff list (though, those help a ton).  It is a thought process and corporate culture.

If you are interested in a piece on how to write a HACCP plan, drop me a line at michele<at>dirigoqualitymeats<dot>com.

It's Coming: FSMA

President Obama took office during one of the largest food borne illness outbreaks in our history.  During his first administration, the Food Safety Modernization Act was passed and signed into law.  At the dawn of his second administration the regulations are coming about as to what FSMA is going to mean for producers and importers.

Most folks who are already covered by the FDA regs are going to remain so.  They are simply going to need to update their process controls and paperwork to comply with the new regulations.  Most institutions on the following list are also going to have to institute CGMPs (Current Good Manufacturing Practices) as part of the law as well.  Likely as not, GMPs are something you are already doing!

So, the question remains...Are They Talking About Me?  Do I have to comply?

Do you have a facility that manufactures, processes, or packs human food? Yes

Are you currently registered with the FDA under current regulations? Yes

Do you store fruits and vegetables in a warehouse that are destined for further processing or distribution? Yes

Are you a farm, and don’t create or warehouse products on the farm? No

Do you sell less than $500,000 in products from your farm? No

Are you a small establishment making a low risk product, such as jams and jellies, honey or syrup? No

Are you already regulated under Low Acid Canned Food Guidelines? No

Do you produce seafood or juice? No

Do you produce alcohol or dietary supplements? No

Do you have a sales income less than $1M (might change to $500K or $250K)? Modified rules apply

Do you have warehousing with refrigeration? Modified rules apply

Do you have warehousing without refrigeration? No

Do you run a grain elevator that doesn’t further process? No

See yourself on that list?  Email michele<at>dirigoqualitymeats<dot>com or leave some contact info in the comments section and I will send you a Road Map for Ensuring FSMA compliance!

So Just What Do We DO Here?

As a public health veterinarian and former Army officer, I was responsible for the food safety program in my area for suppliers to the Department of Defense.  Working closely with the managers of the on base grocery stores (the PX system), food manufacturers that supply the DoD, and soldiers under my command, I ensured safe wholesome food was available to those who relied on the DoD system.

Ensuring a safe and wholesome food program requires excellent communication skills, a deep understanding of regulations, and training everyone to create a culture of food safety.  As an independent contractor in food safety, I work with my clients to design systems and processes that will result in safe food.  Understanding HACCP and the method to arrive at the process flow is only one part of that.  Prerequisite programs are needed to ensure that all workers know and understand the safety system that they are implementing.  As GFSI standards are becoming more important, I work with clients to select a 3^rd party auditing system and work to implement it.  As the FSMA comes into fruition, I work with clients to understand the changes and work with them.  My work has brought me in direct contact with government agencies responsible for licensing and auditing.  I understand government regulations and how to work with the Health Department and the Agriculture Department. I immensely enjoy the opportunity to train.  I have worked with the Maine Beef Quality Assurance Program to train beef producers on food borne illness from beef as well as zoonotic diseases.  My training as a veterinarian has given me expertise and insight into all aspects of the food chain.

Welcome to DQM!

Ahhh, a new business and a bright shiny new blog page.  Both are a world of possibility.

This blog will focus on the core competency of Dirigo Quality Systems; helping producers (farmers, livestock growers, dairies) and processors create safe wholesome food to improve and grow their presence in the market place.

Who is the target audience?  Small producers who wish to professionalize their farming systems.  Medium size producers who recognize that safe food means business security and ultimately growth.

So stay tuned!  Like us on FaceBook, subscribe to the blog via email below, and tell your friends to come visit.