Tag Archives: audit

US to Canada: your meat inspection sorta sucks, only send us the good stuff

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The dean of Canadian food and farm reporting, Jim Romahn, has written a powerful piece about the continuing failures in Canadian meat inspection – failures that had to be pointed out by Americans.

More than a year after 21 people died after eating Maple Leaf Foods Inc. products contaminated with Listeria monocytoges, the Canadian Food Inspection Agency was failing to enforce its own standards and there was sloppy follow-up when hazardous conditions were identified.

Those worrisome facts are contained in a report prepared by two U.S. inspectors who visited in the fall of 2009 to check Canada’s compliance with its own standards. They visited headquarters in Ottawa, 23 meat-processing plants and two labs.

They found that the Canadian Food Inspection Agency generally has good manuals and intentions, but falls short at the plant level, including failures to identify lax sanitation and to enforce its standards.

Thirty years ago, when Canadian reporters began to obtain U.S. inspection reports on our packing plants, all of the deficiencies identified applied to specific problems and individual plants. This audit has identified similar deficiencies at the plant level, but far more serious, it found deficiencies in the overall system.

Had the U.S. inspectors not checked it’s likely that the deficiencies would have persisted, putting Canadian consumers at risk and the meat industry under threat of losing export markets.

The report also indicates some of the systemic deficiencies were identified during previous annual audits, the Canadian Food Inspection Agency promised to fix them, but they persisted. This is after the Maple Leaf crisis and frequent promises by Agriculture Minister Gerry Ritz and Prime Minister Stephen Harper that corrective action would be taken as swiftly as possible.

They have never talked about the U.S. audit reports that highlighted things that needed attention.

During the inspections of 23 plants – Canadian officials went along with the two U.S. officials – they identified problems so serious that three plants were banned from marketing their products in the U.S. and three more were issued warnings that they would be banned if they failed to immediately correct deficiencies.
Four of these six plants were processing ready-to-eat meat products, meaning they would go directly to consumers without any further steps to eliminate hazardous bacteria.

They also found by checking records that some of the plants were running overtime hours without any government inspectors checking conditions.

At another plant, they said the documents that indicated compliance “did not consistently reflect the conditions encountered at the time of the audit.” Later in the report, they write “the actual conditions of the establishment visits were often not entirely consistent with the corresponding documentation.”

Supervisors are supposed to periodically check the performance of front-line government inspectors, but the auditors found “system weaknesses . . . in the manner in which supervisory reviews were conducted.”

They also said there was “an inconsistent identification of potential non-compliances or potential inadequate performance by the inspection personnel.

“The deficiency concerning the lack of supervisory documentation is a repeat finding from the 2008 audit,” this report says.

The two U.S. auditors say the Canadian Food Inspection Agency needs to improve its communications its employee training and awareness and its feedback systems.

They found inspectors were failing to do their duties, as outlined in agency manuals, because they noticed:

– “Lack/loss of consistent identification of contaminated product and product-contact surfaces and other insanitary (sic) conditions.
– “Inconsistent verification of adequate corrective actions . . . with regards to repetitive non-compliances.
– “Inconsistent and loss of documentation of non-compliances in a manner that reflects actual establishment conditions, and
– “Lack/loss of increased inspection activities when non-compliance is observed . . .”

They add that “many of these findings are closely related to those identified during the previous audit.”

They also “identified system weaknesses regarding implementation and verification of HACCP (Hazard Analysis Critical Control Points) systems within the CFIA (Canadian Food Inspection Agency).”

More specifically, they identified “inaccurate analyzing of hazards” for HACCP protocols, “Inadequate implementation of basic elements of the HACCP plan, including monitoring and ongoing verification procedures” and “inappropriate verification of corrective actions taken in response to deviations from the critical limit (for harmful bacteria)”

In addition, they identified lapses in recording instances of non-compliance, such as failures to enter problems in the record book, failures to identify the level of bacterial contamination ad failure to record the “actual times when the entries were made.” They also noted that border inspectors conducting spot checks of Canadian hamburger heading to customers in the U.S. found “several occurrences of zero-tolerance failures in addition to two positive results for E. coli O157:H7.”

Between Jan. 1 and Oct. 31, the U.S. border inspectors turned back 61 million pounds of Canadian meat, calling for repeat inspection by Canadians, and rejected 7,277 pounds that “involved food-safety concerns.” Labeling could be the problem with some of the shipments that were sent back.

In response to this audit, the Canadian Food Inspection Agency said it would increase inspections at 126 of the 190 plants certified to export to the U.S. There is no mention of what will happen at plants selling only to Canadians.

They say “supervisors are now required to accompany inspectors on a quarterly basis. . .”

“The sanitation task was re-structured to focus more on a global assessment of plant sanitation including more emphasis on Ready-to-Eat areas and equipment.”

The CFIA is also stepping up its training programs, its identification of critical control points for its HACCP protocols, its “Listeria related inspection tasks associated with operational/pre-operational sanitation, ventilation (e.g. condensation), building construction and maintenance of equipment.”

The CFIA also says “an electronic application is being developed to allow inspection staff access to historical data at the field level which will provide for more timely compliance decisions.”

When he was asked about the audit, Agriculture Minister Ritz said he has committed an additional $75 million to meat inspection since that audit was completed.

The results of the 2010 audit are not yet available from U.S. officials.
 

JBS adopts video auditing at US beef plants

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In April 2009, Cargill Beef announced it had implemented a third-party video-auditing system that would operate 24 hours a day at its U.S. beef plants to enhance the company’s animal welfare protection systems. All of Cargill’s U.S. plants were expected to have the program in place by the end of 2009.

In Feb. 2010, Cargill announced its expanded remote video auditing program will monitor food-safety procedures within its 10 beef-harvest facilities in North America.

Angie Siemens, Cargill technical services vice president for food safety and quality, said,

“We’re working to eliminate the opportunity for cross-contamination. We want to have the right steps at the beginning of our process to enhance the efficacy of our intervention technologies later in the process. The major objective of the video auditing application is to design a ground-breaking program that can further reduce the E. coli and Salmonella contamination.”

Yesterday, Meatingplace.com reported that JBS USA’s beef division is installing remote video-surveillance camera systems at all of its eight beef plants to enhance food safety, product quality and animal handling.

John Ruby, head of technical services for JBS USA’s beef division, said in a news release the system helped the company improve the accuracy of its auditing within weeks of implementation. JBS uses the system to measure the performance of its workers and give them immediate feedback, ultimately helping to improve its food safety systems.

Audit finds sanitation problems at some Canadian meat, poultry plants

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There’s nothing new here, but once again, the Americans say the Canadians sorta suck at food safety, and the Canadians say, politely, thanks, we’ve fixed that.

The Toronto Star reports tonight that an American audit concluded Canadian Food Inspection Agency documents often painted an inaccurate picture of the conditions at some of Canada’s meat and poultry plants where sanitation problems persisted.

The audit, which looked at 23 of the 455 establishments certified to export to the U.S. between Aug. 25 and Oct. 1, 2009, identified weaknesses particularly in the areas of sanitation, oversight and record keeping.

A review of manuals and procedures at the food inspection agency’s administrative offices found acceptable controls for sanitation, but auditors found a different story at some plants.

“The actual conditions of the establishment visits were often not entirely consistent with the corresponding documentation,” the report says.

Among the sanitation issues identified in the report were: not consistently identifying contaminated product and inconsistently verifying plants were taking adequate corrective actions to problems.

Agriculture Minister Gerry-listeria-is funny- Ritz, responded with a statement emailed to The Canadian Press on Monday, stating,

“This audit is from a year ago and in that time our government has invested an additional $75 million to improve food safety and are hiring 170 new inspectors.”

Uh-huh.

Third-party audits: missing the forest for the trees

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Irwin Pronk of HACCP By Design, writes in this contributed piece:

Conducting food safety audits is hard work. It is a very difficult task requiring technical background, industry experience and people skills (especially in stressful environments).

There are a number of problems with third-party audits these days, and each in its own way undermines the effectiveness of audits as food safety tools.

One of the main dangers is that HACCP certifications can become mere “optics,” where the audit is not about reality, but about the “show” that was put on for the auditor for those two or three days. With the pressure of an audit, it is too easy for plant staff and management to forget that the goal of food safety programs is simply not the short-term one of passing the audit, but the ultimately more important one of producing safe food for the consumer. Easily said, but the reality of day-to-day operations in a food plant can make the result very different from the principle. For one thing, an audit must get past the enthusiastic descriptions of a few people and assess the food safety attitude, or culture, of the entire group. Any blame there might be for the thoroughness (or lack thereof) of audits obviously does not rest entirely with auditors, but must also be shouldered by Plant Managers and QA Managers who may feel it necessary to create these “shows” for the auditors without realising how putting on a “show” sends the plant the message that food safety is just a game. Perhaps that is why we see so little progress in reducing recalls and protecting the consumer.

Too often, auditors spend a disproportionate amount of time reviewing documents (procedures and records) and comparatively little time in the plant. A contact at one plant recently told me of a three-day audit where the auditor spent only three hours in the plant.

If some auditors spend too little time in the plant, others skew the results of their third-party audits by inflating scores, recording evaluations much higher than the plants deserve and giving the wrong impression of their performance. The difficulty for auditors is this: if the plant staff and management have been steadily making improvements, they naturally expect their score to rise; on the other hand, the standard also gets tougher every year, and so, even with all their improvements, they may not really deserve a higher score. The pressure on the auditor to “improve” the score can be considerable. It takes a strong person not to give in, but many do. Over time this inflation can result in some very strange scores. For example, there have been cases where a mediocre score for an audit is 92.5 percent, while a good score is 96.6 percent. What happened to the concept of the “average” being 65 percent? Sure, everyone wants to look good, but …

The most consistent complaints of auditors is that they are inconsistent and too often make “mountains out of mole-hills.” With the number of audits being required lately by retailers and other customers, and growing steadily, there is a shortage of knowledgeable, experienced auditors. To audit a food plant properly, the auditor should be technically capable and have working experience in that industry. How can an auditor from, say, the bakery industry audit a yoghurt plant, or meat person audit a winery? The Prerequisite Programs certainly form a common ground across industries, but a thorough understanding of the particular industry is necessary to apply the principles appropriately in the particular situation. But going beyond Prerequisite Programs to HACCP, it is much more difficult to determine whether Critical Control Points (CCPs) are appropriate, designed correctly, or managed effectively. For example, should the pH of a salad dressing be a CCP? What about the seal on a package of hotdogs, or the baking of a loaf of bread? Answering either yes or no requires a deep understanding of the technical issues in each industry. Too often, auditors are not qualified to audit plants in a particular industry, and plant staff and management need to be aware of this fact, and require of the Certification Body (auditing firm) that the auditors are qualified to assess their plant. Yes, you have the right to ask for the résumé of the auditor who is to come to your plant and refuse them if you do not feel they are qualified.

On top of this, with un-scored audits (where no numerical scores are recorded but Major and Minor non-conformances are identified and listed), it is not in the auditor’s best interests to point out non-conformances since they result in volumes of paperwork and perhaps even return visits to resolve Major non-conformances. As a result, an auditor may choose to downgrade Major non-conformances Minor, and Minors to Observations.

Not all the issues lie with auditors. Unrealistic expectations can make an audit unworkable. If an auditing firm is told, for example, that they only have one day to do an audit on a 600,000 ft2 facility, they have certain choices. They can refuse to do the audit, since it cannot be done adequately, or they can acquiesce and take the money. That can –and, for some, has– turned out to be an expensive $1,200 audit. Which leads to the fundamental problem that is, money is changing hands, and this can lead to undue emphasis on competing for business rather than ensuring quality. The plant is paying the auditing firm and even though the standard may be the same, each auditing firm enforces the requirements with varying degrees of rigour. Food plants can choose their auditing firm and too often choose based on which is the easiest.

So who is pointing fingers at whom? No one is guilt-free in the area. There is plenty of blame to go around, but we likewise we share equally the responsibility to change the system, to put the emphasis back where it belongs, on the ultimate goal of ensuring the safety of the food products being shipped from our plants, not racking up great audit scores. Hard as it is, we need to combine integrity with excellence, remembering that the short-term goal of good audit scores is only one piece in the larger picture of producing reliably, demonstrably safe food for our customers.

Irwin Pronk has worked with over 300 companies to implement food safety and quality assurance programs over the past 15 years. He has worked on all sections of the supply chain from agriculture through animal feed production, food processing, distribution and food service. He is a resource for many clients with in-plant facilitation of HACCP & GMP programs (SQF, ISO22000) and is an ISO22000 Lead Assessor. Irwin was a contributor to the Quality Auditor’s HACCP Handbook (ASQ). When it comes to management systems, he is a firm believer in the integration of risk management systems as well as using a behaviour-based approach. He was the winner of the OFPA’s Sanitarian of the Year award in 2005. Prior to consulting he worked with both Pillsbury Canada and Maple Leaf.

He lives in Fergus, which is near Guelph (that’s in Canada).
 

Third-party food-safety audits fall under intense scrutiny

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I spent the morning hanging out with a couple of visiting food safety types from Jordan. What was striking was how much we agreed that arguments about government turf, the inadequacy of audits, and the failure of food safety messages with consumers and other humans was a global phenomenon.

Beth Weise writes in tomorrow’s USA Today that if you’ve never heard of a third-party food-safety audit, you’re not alone. Few Americans know or care what they are. To the companies that produce much of our food, they’re an important tool to make sure it’s safe and wholesome — but critics say the certificates the auditors issue often aren’t worth the paper they’re printed on.

Recent foodborne illness outbreaks have raised questions in Congress and elsewhere about the effectiveness of these audits and the impartialness of the process.

Auditors are the eyes and ears of a company buying food from a producer. A frozen-pizza maker hires an auditor to make sure the company it buys tomato sauce from has a clean, safe and well-run plant. But many problems — including dead chickens, rats, manure and salmonella — can fall through the cracks of their visits.

Last year, the Peanut Corp. of America, whose products sickened over 600 and may have killed as many as nine, got a "superior" rating at its Texas plant even as it was churning out peanut paste tainted with salmonella.

And last week Congress showed that one of Wright County Egg’s egg-packing plants got a "superior" rating from the same company on June 8, just two months before Wright became part of the largest known egg recall in the United States.

The company, AIB International (of Manhattan, Kansas, sigh), lists five standards on its website that inspectors expect to see in a "facility that maintains a food-safe processing environment." They are: ensuring that raw materials are safely stored and handled; equipment, buildings and grounds are properly maintained; cleaning and sanitizing is adequate; pests monitored and managed; and staffers are working together to deliver a safe final product.

When FDA inspectors actually went into Wright County’s henhouses at its Galt, Iowa, plant, they found vermin, filthy dead chickens and manure oozing out of doorways. More than 1,600 people were sickened in a salmonella enteritidis outbreak linked to the farm, and over 550 million eggs were recalled due to contamination at this plant and at nearby Hillandale Farms, where lesser problems were found.

"Superior" clearly doesn’t mean much, says Rep. Bart Stupak, D-Mich. "How many dead mice do you have to find in your food before you get an ‘Excellent’ rating?"

Third-party food audits, like restaurant inspection, are a snapshot in time. Given the international sourcing of ingredients, audits are a requirement, but so is internal food safety intelligence to make sense of audits that are useful and audits that are chicken poop.

The third-party food safety audit scheme that processors and retailers insisted upon is no better than a financial Ponzi scheme. The vast number of facilities and suppliers means audits are required, but people have been replaced by paper.

Audits, inspections, training and systems are no substitute for developing a strong food safety culture, farm-to-fork, and marketing food safety directly to consumers rather than the local/natural/organic hucksterism is a way to further reinforce the food safety culture.

After the salmonella-in-peanut paste crap, Costco, a retail store, which previously limited AIB’s inspections to its bakery vendors, has now instructed suppliers to not use AIB at all.

“The American Institute of Baking is bakery experts,” said R. Craig Wilson, the top safety official at Costco. “But you stick them in a peanut butter plant or in a beef plant, they are stuffed.”

Or as Mansour Samadpour of Seattle said at the time,

“The contributions of third-party audits to food safety is the same as the contribution of mail-order diploma mills to education.”

I asked weeks ago, who were the buyers of DeCoster eggs who used AIB audits to justify putting salmonella on grocery store shelves? Any retailers want to step forward?

And market food safety at retail so consumers can choose the poop they wish to purchase.
 

Food safety auditors can suck: Salmonella-in-egg producer got A-OK from same auditor that OKed salmonella in peanut paste

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The same third-party auditor that approved salmonella-tainted peanut paste that killed nine and sickened 600 also gave DeCoster egg operations a “superior” rating and “recognition of achievement” in June 2010, just as thousands of Americans began barfing from salmonella in DeCoster eggs.

Beyond the theatre of yesterday’s House hearing about the salmonella-in-eggs outbreak that has sickened well over 1,600 was the revelation that DeCoster’s Iowa egg operations had been audited by the American Institute of Baking based in Manhattan (Kansas).

The N.Y. Times reports that documents released by the committee showed that Wright County Egg achieved a “superior” rating and “recognition of achievement” from AIB International, a private inspection company based in Manhattan, Kan., after a June inspection of its processing facility. That came just as the company was causing thousands of illnesses from contaminated eggs.

In 2008, AIB gave a “superior” rating to a Peanut Corporation of America plant in Blakely, Ga., that was later found to be riddled with salmonella that caused a nationwide outbreak and the largest food recall in American history. A spokesman for AIB could not be reached.

Elizabeth Weise of USA Today reported today that Wright County Egg, one of the Iowa farms at the center of this summer’s recall of 550 million eggs, earned "superior" ratings for its facilities from a third-party auditor the past three years.

But the auditor was the same one that gave a superior rating to the Peanut Corp. of America, whose shipments were linked to a salmonella outbreak that sickened hundreds a few years ago.

AIB International, of Manhattan, Kan., audited Wright’s egg-packing plant twice in 2008, four times in 2009 and at least once in 2010, and every time found it to be "superior," Rep. Diana DeGette, D-Colo., said during the hearing. … Calls to AIB were not returned Wednesday.

AIB International also gave the Peanut Corp. of America’s Plainview, Texas, plant a "superior" rating. An outbreak of salmonella linked to some peanut products shipped from that plant and another PCA plant in 2007 and 2008 sickened as many as 600 people and may have contributed to nine deaths.

This is beyond embarrassing. It’s criminal.

A Kansas State student wrote in 2009 that after a March 6, 2009 article in the N.Y. Times sorta shattered the myth of third-party food safety audits, he couldn’t get anyone at AIB to talk.

Since the release of the Times article, AIB now requires a minimum of two days or longer to complete an inspection at a food processing facility. AIB has also announced it will change the name of its Good Manufacturing Practices inspection certificates from “Certificate of Achievement” to “Recognition of Achievement.”

Is that like Homer Simpson winning the First Annual Montgomery Burns Award for Outstanding Achievement in the Field of Excellence?

Apparently, the answer is yes, given the salmonella-in-eggs poopfest.

Third-party food audits, like restaurant inspection, are a snapshot in time. Given the international sourcing of ingredients, audits are a requirement, but so is internal food safety intelligence to make sense of audits that are useful and audits that are chicken poop.

The third-party food safety audit scheme that processors and retailers insisted upon is no better than a financial Ponzi scheme. The vast number of facilities and suppliers means audits are required, but people have been replaced by paper.

Audits, inspections, training and systems are no substitute for developing a strong food safety culture, farm-to-fork, and marketing food safety directly to consumers rather than the local/natural/organic hucksterism is a way to further reinforce the food safety culture.

After the salmonella-in-peanut paste crap, Costco, a retail store, which previously limited AIB’s inspections to its bakery vendors, has now instructed suppliers to not use AIB at all.

“The American Institute of Baking is bakery experts,” said R. Craig Wilson, the top safety official at Costco. “But you stick them in a peanut butter plant or in a beef plant, they are stuffed.”

Or as Mansour Samadpour of Seattle said at the time,

“The contributions of third-party audits to food safety is the same as the contribution of mail-order diploma mills to education.”

Who were the buyers of DeCoster eggs who used AIB audits to justify putting salmonella on grocery store shelves? Any retailers want to step forward?

Coincidentally, Enreco Inc., a maker of flaxseed flours, bragged in a press release yesterday they had earned a “superior" rating from a recent AIB inspection at its Wisconsin production facility.

Enreco president Sean Moriarty said, “We are absolutely pleased to have achieved AIB’s highest rating for four consecutive years now, even while incidents of food product recalls in the last two years have caused AIB to toughen their inspections considerably."

Sean, you may want to rethink that PR.

Salmonella in eggs outbreak: an eerily repetitive story involving lots of sick people, food, filth and faith; where are those supplier audits?

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In January 2009, Peanut Corporation of America (PCA) was linked to a growing outbreak of illness across the U.S. caused by Salmonella serotype Typhimurium. Eventually, all peanuts and peanut products processed at PCA’s Blakely, Georgia, plant since January 1, 2007 were recalled, including over 3,900 peanut butter and other peanut-containing products from more than 350 companies. The U.S. Centers for Disease Control and Prevention (CDC) reported that 691 people were sickened and nine died across 46 U.S. states and in Canada from the outbreak.

By Feb. 15, 2009, The Washington Post described the business culture at PCA from the viewpoint of a former buyer for a major snack manufacturer — a filthy plant with a leaky roof and windows that were left open, allowing birds to enter. The company purchased only low quality, inexpensive peanuts and paid food handlers the minimum wage lawfully allowed. The lack of a food safety culture was most evident in the description of how PCA dealt with finished product that tested positive for Salmonella spp. A report by the U.S. Food and Drug Administration identified many instances in which the product was retested until a negative result was achieved; in other instances PCA shipped the product to their customer despite the positive test or before the test result was received.

FDA further noted there were inadequate controls at the PCA plant to prevent contamination and insufficient cleaning and sanitation. Facilities for handwashing were also used to clean utensils and mops, increasing the potential for recontamination of washed hands. Equipment settings — for example, roasting temperature and belt speed — had not been evaluated to ensure that the roasting step was sufficient to kill bacteria. Raw and roasted peanuts were stored directly next to one another, allowing for potential contamination of the roasted finished product. Gaps in the physical integrity of the building were observed around the loading bays and the air conditioning intakes in the roof that provided pests with open access to the plant. Despite these deficiencies, PCA maintained the highest possible rating from auditing firm AIB International.

Earlier this year, Basic Food Flavors Inc., the Las Vegas company at the center of a recall of more than 100 food products containing hydrolyzed vegetable protein, or HVP, continued to make and distribute food ingredients for about a month after it learned salmonella was present at its processing facility, according to a Food and Drug Administration report.

Yesterday, similarly eerie details started to emerge from investigators going through the salmonella-in-eggs mess that has sickened almost 1,500 over the summer and led to the recall of about 550 million eggs. Highlights of the reports (called 483s) and public comments by FDA-types include:

• David Elder, director of the FDA’s Office of Regulatory Affairs, told a press conference Monday the 483 forms show "significant objectionable conditions;"

• at Wright County Egg facilities, live mice were found inside laying houses at four sites, and numerous live and dead flies were observed in egg-laying houses at three locations;

• chicken manure accumulated 4 to 8 feet high underneath the cages at two locations, pushing out access doors, allowing open access for wildlife and other farm animals;

• at one location, uncaged birds were using tall manure piles to access egg-laying areas;

• inspectors saw employees not changing or not wearing protective clothing when moving from laying house to laying house;

• three Hillandale Farms locations contained unsealed rodent holes with evidence of live rodents at one of the facilities, with gaps in walls and doors at other sites.; and,

• uncaged chickens were observed tracking manure into the caged hen areas.

Dr Michael Taylor, the FDA’s deputy commissioner for foods, told reporters that though the FDA has no reason to believe the practices that investigators turned up are common at all egg-producing facilities, inspectors will be inspecting about 600 large egg producers, those that have 50,000 or more laying hens, over the next several months starting in September with what it believes may be the highest-risk facilities.

Kenneth E. Anderson, a professor of poultry science at North Carolina State University said,

“That is not good management, bottom line. I am surprised that an operation was being operated in that manner in this day and age.”

How did this happen? A gap in federal or state inspection requirements may be partly to blame – but only partly.

What firms and retailers were buying these eggs? Don’t they require internal or third-party food safety audits of their suppliers? Who were the auditors and where are their reports? Has any buyer looked at owner Jack DeCoster over the years and said, your farm’s a dump, I’m not buying your eggs?

While waiting for government and Godot, it’s the thousands of American egg farmers who are going to suffer if sales decline, so why not unleash the power of food safety marketing and let consumers choose at retail.

Repeated outbreaks have shown that all food is not safe: there are good producers and bad producers, good retailers and bad retailers. As a consumer, I have no way of knowing. Telling me an egg is local and grown with love is food marketing but has nothing to do with food safety and salmonella.

Tell consumers about salmonella-testing programs meant to reduce risks; put a URL on egg cartons so those who are interested can use the Internet or even personal phones to see how the eggs were raised. Boring press releases in the absence of data only magnify consumer mistrust.

Food producers should truthfully market their microbial food safety programs, coupled with behavioral-based food safety systems that foster a positive food safety culture from farm-to-fork. The best producers and processors will go far beyond the lowest common denominator of government and should be rewarded in the marketplace.
 

FDA needs to fix ‘audit creep’ if it can says Georgia fruit and veg growers

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Audit creep is not something Chapman was knowingly called while visiting farms – maybe behind his back.

For this story, audit creep refers to the expanding inclusion of more requirements on growers of fresh produce, many which have nothing to do with food safety. The Georgia Fruit and Vegetable Growers Association explains excetpts below from a submission to the U.S. Food and Drug Administration on ways to improve preventative controls for produce safety (thanks to Tom Karst of The Packer for continuing to keep his eye on comments being submitted).

Food safety has long been a crucial part of GFVGA with the creation of the Georgia Good Agricultural Practice Food Safety Program (GA GAP) in 2000. We provide food safety education to producers across the southeast at various conferences as well as one-on-one farm visits. The GA GAP program also helps in the implementation of food safety plans, documentation and training on farms and in packing facilities as well as preparing producers for third party food safety audits.

Currently, there are more than 75 farms or packing facilities that have passed a certified third party food safety audit through the GA GAP program. We have provided one-on-one food safety training at approximately 300 farms and packing facilities across the southeast.

The 1998 FDA document, Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables, has served as the basis for food safety policy in the United States. It has allowed our nation and the produce industry to set a foundation from which sound, safe farming and handling practices were established.

The Georgia Fruit and Vegetable Growers Association supports a federal food safety policy. Federal oversight is seen as the only way to establish and enforce a level playing field for all parts of the industry from producer to broker, retail chain to consumer.

In the current situation with no federal oversight, the food safety industry is decided by each retail supplier, food service organization, or brokerage firm. In 1998 there were no problems with food safety audit company checklists drifting far from the common foundation of the new FDA guidance. As consumers became more educated about their food and food sources and technology allowed for more quickly identifying food borne illness clusters, retail organizations began asking for more stringent food safety standards to lower their liability and tout their safer food supply.

They also began to demand the inclusion of non-food safety related materials such as business practices and sustainability on third party food safety audits. These tighter standards and non-food safety related demands are not bad, however they are not based on any science or industry practice; simply the idea that more is better.

Over the past twelve years this “audit creep” has continued and audit company’s marketing teams and delivery systems have grown more sophisticated. Many retail chains will pick one audit company format and require all suppliers use that service. Many of the larger producer, packer, shipper operations with multiple customers must undergo multiple audits.

Research has shown all audits contain 85% to 90% of the same questions. This proves to be a monetary, personnel, and time burden as audits begin at $750 (not including auditor travel expenses), audits last on average one to one and a half days and the auditor must be accompanied at all times during the audit. Food safety is no longer a small piece of the marketing program but an integral cog in the entire operation.

The common message from grower members of GFVGA is they see the value of food safety programs and are willing to make the necessary changes. What growers do not like is having the audit standards change year to year. Many of the grower’s customers will require one audit company and format one year and change to a different required audit company and format the second year. While most of the information is encompassed in their food safety, the difference in audit format, audit expectation, different metrics and constant change takes time and money.

The Georgia Fruit and Vegetable Growers Association supports a common foundation with the updating of the 1998 FDA guidance. We feel any federal food safety program, guidance and/or oversight should consist of science based regulations. This is one area that will require substantial time and resources as the research is simply not available. One example is water quality. In the absence of definitive microbial standards for irrigation water, the authors of the California Leafy Greens Market Agreement Best Practices Document have chosen to use the U.S. Environmental Protection Agency’s recreational water standards. Scientific research is needed to show if these standards are appropriate for irrigation water. …

The expense of a food safety program is not in implementing the program, changes and documentation. The expense is in having a third party audit. If federal guidance does not require a private audit from a third party, much of the monetary anxieties are taken away. An argument can be made that a smaller operation has less literal hands involved and can be more closely monitored. However E. coli and other harmful bacteria do not know whether they are in a 2 acre field or 200 acre field. Having a food safety program in place with documentation to remind and ensure Good Agricultural and Handling Practices are used is beneficial for all farms and consumers.”

Respectfully submitted,
Beth Bland
Director of Education and Food Safety
Georgia Fruit and Vegetable Growers Association
 

Pundit Prevor’s plan to pump-up food safety

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Jim Prevor, sometimes known as the Perishable Pundit, has offered a plan to improve food safety. Writing in The New Atlantis, Prevor says sure, government has an important role in food safety, but the current focus on legislation is misguided. Or at least that’s my summary. Here’s some more summarized stuff from Prevor’s article. The first two suggestions caught my attention – the rest is boilerplate stuff. (The complete article has also been translated into French by Albert Amgar and is available here.)

1. Switch to a negligence standard from a strict liability standard, and switch primary liability to the trade buyer

Because of strict liability, the primary food safety concern among retailers in the U.S. is that their vendors carry sufficient liability insurance. By contrast, in the United Kingdom and certain other foreign countries, supermarkets can be held liable in court if a person becomes ill or dies and it is shown that the retailer did not exercise proper due diligence in vetting suppliers.

Second, because the standard is strict liability, farmers and processors get no return on their investment in food safety if they have the bad luck to have an outbreak. In other words, the liability is strictly theirs whether they invested millions, going above and beyond all food safety standards, or they did nothing at all.

Combining this strict liability standard with a concentrated buying environment, where large chains such as Wal-Mart, Costco, Kroger, Safeway, and Supervalu account for the vast majority of purchases, results in a potentially troublesome situation. At these big buyers, although official corporate policy may place a priority on food safety and the individuals employed may care about food safety, the day-to-day institutional imperative is to get lower prices from vendors. Most producers are more than willing to give buyers exactly as much food safety as they are willing to pay for. But buyers, who are not liable for food safety problems, have precious little incentive to pay extra for higher food safety standards. …

In other words, food safety is primarily a tradable good in the marketplace. In deciding that the producer is liable no matter how diligent his efforts and that the retailer is not liable no matter how lax his efforts, the judicial system has distorted the way the market meets the consumer interest in food safety. Solving this problem is far more likely to enhance food safety than giving the FDA additional power. After all, the FDA doesn’t produce or buy food; it is always going to be a much more indirect player in moving the needle on food safety than members of the industry.

2. Root out bribery and corruption in food safety certification

The best federal agency to enhance food safety is not the FDA but the FBI. Few buying operations have the capability to have their own personnel inspecting and monitoring producers along today’s global supply chains. The solution is to rely on third-party certification agencies. Trade buyers can establish their own standards or agree to accept other well-recognized standards, such as those of the British Retail Consortium. Adherence to these standards is then confirmed by various independent auditing groups. This is essentially the same mechanism the USDA uses to implement organic certification. The problem is that there is widespread corruption associated with these certifications, especially in areas such as China, Eastern Europe, and many developing countries, though auditors that are less than rigorous are also well known in the United States.

The corrupt sale of certifications poses a fundamental threat to food safety, and switching to government inspectors doesn’t solve the problem. First, the U.S. government has no authority to run inspections in China. Second, if the government were to use locals in other countries to run inspections, it would face the same problems as a private auditor — keeping the loyalty of local employees whose family, clan, and national interests all compel them to approve facilities and products. Third, whether through sloth or corruption, there are all too many examples of government inspectors not doing their jobs right here in the United States — from rats running wild in a KFC that had been inspected just the night before to horrid conditions at the 7th Street Market in Los Angeles to a payola scandal at the Hunts Point Produce Market in New York.

Beyond establishing a proper liability regime, increasing the reliability of food safety certifications by rooting out bribery and corruption is perhaps the single most valuable contribution the federal government could make toward food safety.

Food industry not acting on problems ‘very common’ – prof

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With economic pressures, more food safety stuff gets farmed out to others.

Whether enough food safety expertise remains in the company selling the product is questionable.

Canwest News Service reported the DeGroot children, Johnny, now 9, and sister Jessica, 6, of Waterford, Ontario, are still battling parasites the family believes are linked to juice they consumed.

More than 100,000 Strawberry Kiwi Dole juice boxes were eventually destroyed last year following a government investigation showing a container-integrity problem with the boxes during distribution. Weakened boxes can become bloated and leaky, making them magnets for bacteria and yeast.

Newly released internal documents from the Canadian Food Inspection Agency about the affair reveal a food-safety system far from perfect, where flags during distribution might not have come to light had it not been for one determined family.

And a leading food-science expert who reviewed the agency’s final report into the matter says the case demonstrates an ongoing problem in the food industry.

University of Guelph food science professor Keith Warriner said,

"It was obvious to me that what they actually have, on paper, a system in place to detect the quality control of packaging, but they didn’t actually practise what they preached. . . . It was more a case of the company, when a defect did occur, not acting upon it. That’s very common in the food industry. … A lot of companies are subcontracting. Economically, it makes sense because if you subcontract, you don’t have to pay for facilities. But if you haven’t got control, it can literally collapse an organization so you’ve got to be careful.”