Training Accountability

We all have training programs.  Some good, some real good and some not so good.  What about continuous training?  If you train a line employee close to their hire date, do you ever give them a refresher?

 

What about accountability?  If you train a line employee on the proper way to wear a hairnet and they don’t abide, are they accountable?  Do they lose pay?  Vacation?

 

Tom

Federal Register

You can make comments on FSMA through the Federal Register.  Those laws can and will impact your business.  A lot of folks are making comments.  If you think there is something unfair in these upcoming regulations, you should tell FDA.

 

Tom

New FDA Stuff

There has been a lot of talk lately about when FDA does get geared up, that they are going to be paying quite a bit of attention to your environmental monitoring programs.  Update these if you haven’t done so in a while.  If you don’t have a program, get one started.  It is not that expensive or time consuming.

 

Our job is to keep you abreast of these updates.

 

Tom

Know Your Supplier …….. Well

In this blog we are recommending that you become better acquainted with your suppliers, especially the major suppliers.  They are a big part of your business.  A meeting twice a year is appropriate.  You should outline goals and objectives.  Get to know them better.  Do not make price and cost the only reason for using a particular supplier.

 

You want that supplier to make money, but also to bring you value every year.

 

Tom

FDA Stepping Up

Recently FDA through the courts issued a permanent injunction on a firm for Listeria innocua.  FDA found Listeria innocua in the facility.  Listeria innocua is considered more of a environmental bacteria, but it may lead to Listeria monocytogenes.

 

It is interesting to note that they issued a permanent injunction here and not a temporary injunction which forced the firm to stop everything (Producing, shipping, receiving ,etc.) until the problem was rectified.

 

A lot different from the old days.

 

Tom

FDA Facts

If you receive a Warning Letter from FDA, do you know what to do?  There are ways to handle it and there are things not to do.  If you do the wrong stuff, you are getting started off on the wrong foot with FDA and then they can really make your life miserable.  The first thing to do is answer the letter within 10 days.

 

Did you know, because of FSMA, FDA can suspend a company’s registration even if they only have reasonable probability that the product in your plant may become contaminated?  They don’t have to find specific examples anymore.

 

Tom

Complainers

I hate complainers.  I believe there are people out there that complain just to complain, or maybe try to get something for free.

 

So we were at one of our trade shows this past week.  The sausage on the buffet line at the hotel was not warm both mornings.  The steam table was steaming, but the sausage tray wasn’t getting warm.  The sausage was thoroughly cooked though but at room temperature.  I had bacon the third morning.  It was fine.

 

Being in the food safety business, should I have said something?  I never did.

 

Tom

SQF vs. FSMA

Everyone has been talking about FSMA and what is going on with it.  When will it happen?  When will auditors start showing up at your door?

 

We now think that the final rules will come out in 2015.  They will let the food industry digest it and then audits will probably start happening in 2016.  Remember that Obama signed this into law in 2011.

 

Anyway, an SQF audit will help you get prepared for all of this.

 

Tom

Run Man!

You walk into your local grocery store and take a number and wait at the deli counter.  As usual in front of you, there’s the person (I won’t get any more explicit) that must ask the deli guy 1,100 questions.  And not only that, but they want to point out and pick and chose exactly what piece of whatever they want.  “No.  No.  The one second from the top”.  Man, you just came in for a 1/2 pound of sliced pastrami.  That’s all you want, and you just want to leave.

 

But then you notice another deli worker coughing about every 20 seconds.  They are just walking around coughing around all of that exposed food.

 

Get the heck out of there.  Go get your pastrami somewhere else.

 

Tom

GFSI and Allergen Facts

All of the GFSI Benchmarked Standards are based on HACCP.  If you don’t have a well documented HACCP program in place, you can’t even get started on a gap, preassessment or audit.

 

All of the GFSI Benchmarked Standards require management committment.  This is a big part of the audit.  The auditor can ask management questions

 

All of the GFSI Benchmarked Standards require corrective action follow up to non conformances.  For SQF it is 14 days for a major, and 30 days for a minor.

 

Anyone who prepares, packs or holds milk, eggs, any form of peanut or treenut, fish, shellfish, any product with soybeans or wheat, must have an allergen control program.

 

We get asked these questions a lot, so we thought we would publish them.

 

Tom