haccp will be required of all types of food processing facilities with a few exceptions • having...

WWW.SGS.COM

GFSI FSMA HARPC & FUTURE OF AUDITS

Presented at the North American Millers Association

May 14, 2015 Peoria, IL

Walter P. Saraniecki, MS, LDN, LEHP, REHS/RS

Food Safety Auditor, SGS North America


WHAT MAKES A FOOD SAFER THAN OTHERS?

n  A great food safety management system

n  A certified HACCP plan that is properly followed

n  Attention to allergens

n  Verification

n  Validation

n  A trusted and respected food safety auditing firm

n  Great employees


JUST A FEW NOTABLE FOOD BORNE DISEASE OUTBREAKS & RECALLS

n  Spinach outbreaks

n  500,000 eggs recalled

n  Peanut butter outbreak

n  Cantaloupe outbreak

n  China’s food safety woes now a global concern

n  E. coli outbreaks

n  Raw cookie dough outbreaks

n  Navajo Pride Bleached Flour recall

n  Cornmeal recall


WHY WAS GFSI NEEDED?

n  Large food manufacturers and retailers had/have little faith in any government’s ability to ensure the quality and/or safety of the food supply they were buying or selling

n  Nearly all of them had either their own food safety/quality inspection teams or utilized third party inspectors (auditors) to inspect not only their own facilities but also their suppliers and their suppliers’ suppliers (farm to fork for real)

n  There are hundreds of different inspection (audit) ‘schemes’ currently in use across the globe


“SUPERFLUOUSLY REDUNDANT” INSPECTIONS

n  This resulted in each supplier of food or food grade packaging being audited by almost everyone of their customers’ inspection teams annually!

n  “Superfluously redundant” inspections resulted in: •  Waste of time, money, and productivity •  Wide variations in the quality & effectiveness of audits •  Wide variations in the competency of the auditor •  False sense of security that the inspections/audits were

actually accomplishing added food safety and quality


THE EFFECT OF REDUNDANT AUDITS


VERIFYING AND NOT VALIDATING

n  Many audits were only verifying and not validating that the food safety program was reducing or eliminating the hazard identified in the HACCP plan

n  The large buyers, suppliers, government, academia, audit certification bodies, accreditation bodies, scheme owners, retailers, and others got together and said enough of this redundancy!

n  Too many recalls and FBDOs


ONCE CERTIFIED…ACCEPTED EVERYWHERE

n  If your facility is certified by a GFSI certified body then all (most) other companies have to accept the facility as meeting the benchmarked standard

n  Redundancy is dead and gone therefore food safety, quality and efficiency is improved (allegedly)


PROVEN VALUE FROM GFSI AUDITS

n  Walmart: University of Arkansas Study shows safer food for consumers

n  Walmart: 31% reduction in product recalls

n  Metro: 90% decrease of recalls in Germany

n  Migros: 50% reduction of audits

n  Cargill: $5mm/year in reduced redundant audit costs. Estimated $15mm/year savings once fully implemented

n  Danone: € 4 million in reduced redundant audit costs in the first year Source: www.mygfsi.com


GFSI APPROVED AUDIT SCHEMES

n  FSSC 22000 - October 2011 Issue (5K worldwide)

n  SQF CODE 7TH Edition Level 2 (5K worldwide)

n  BRC Global Standard For Food Safety Issue 6 (18K)

n  11 total schemes + 2 in progress including China HACCP


GFSI & FSMA

n  FSMA requires that Importers give the FDA ‘prior notice’ for all high risk foods entering the US.

n  FSMA places the burden of proof on foreign food IMPORTERS that their imported foods are safe

n  FSMA states that this safe food certification can be performed by foreign governments or THIRD PARTY Certifying Bodies (CB)

n  Once fully implemented there will be a great demand for auditors in foreign countries


FSMA MANDATED INSPECTION FREQUENCY

From the date of the President signing the law:

n  High Risk Domestic Facilities: •  Once in the first 5 years •  Once every 3 years after

n  Non-High Risk Domestic Facilities: •  Once in the first 7 years •  Once every 5 years after

n  vs GFSI Audits: •  Minimum once every year; more if high risk


FSMA MANDATORY PREVENTIVE CONTROLS FOR FOOD FACILITIES

“Proposed Rules:”

n  Evaluating hazards that could affect food safety

n  Specifying what preventive steps, or controls, will be put in place to significantly minimize or prevent the hazards

n  Specifying how the facility will monitor these controls to ensure they are working

n  Maintaining routine records of the monitoring

n  Specifying what actions the facility will take to correct problems that arise


FDA’S NEW TOOLS FROM FSMA

n  Mandated inspection frequency

n  Mandatory recalls

n  Expanded records access

n  Expanded administrative detention

n  Suspension of registration

n  Enhanced product tracing

n  Third party laboratory testing


FUTURE DIRECTIONS IN AUDITING

n  Better qualified auditors

n  Standardizing auditors

n  Higher benchmarks of audit schemes

n  Risk based audits

n  Attention to backflow prevention

n  Attention to cross connections of potable water

n  Targeted customer audits of GFSI certified facilities

n  Sanitary transport of food and packaging

n  Protection against intentional adulteration


NEHA’S CCFS CREDENTIAL CERTIFIED in COMPREHENSIVE FOOD SAFETY

www.neha.org


HARPC PROVISIONS OF FSMA OR “HACCP ON STEROIDS”

Hazard Analysis Risk-Based Preventative Controls

n  HACCP will be required of all types of food processing facilities with a few exceptions •  Having total sales of less than $1 million •  Less than 500 employees must comply in 2 years •  USDA facilities

n  Prevention is the cornerstone

n  HA will now encompass radiation (P, B, C & R)

n  Requirement to Reanalyze •  Any significant change at the facility that might increase

a known hazard or introduce a new one or •  At least every three years


HARPC PREVENTIVE CONTROLS EXAMPLES

n  Sanitation procedures at food surface contact points

n  Sanitation of utensils and equipment

n  Staff hygiene training

n  Environmental monitoring program (for pathogen controls)

n  Food allergen control program

n  Recall plan

n  Current Good Manufacturing Practices (cGMPs)

n  Supplier verification activities

THANK YOU FOR YOUR ATTENTION. LUNCH OR QUESTIONS?

WWW.SGS.COM

haccp will be required of all types of food processing facilities with a few exceptions • having...

Documents