Ten Commandments – Food Safety Plan

Ten Commandments – Food Safety Management

You have seen the ten commandments in your spiritual life but what about the food ten_commandments_hebrew_stonesafety life?

 

As we all know, the DoJ has stepped into the food industry and they can seek to prosecute cases where illnesses have occurred – restaurant companies, manufacturers, etc. Our consumers are demanding “cleaner” products as they eat out or purchase their food. With the science of genome sequencing, it’s possible to link illnesses from years earlier to their source, meaning a past incident can come back to haunt a company – long after the event.

Food Safety Modernization Act (FSMA) – based regulations are here. The first impression that restaurants and grocery stores would not be impacted is now becoming clear that the ripple effect of FSMA will increase the food safety demands on them as well. FDA has written the rules for some flexibility – which is causing significant confusion and it carries the risk of many in the industry getting something wrong and placing considerable and unnecessary strain on already overburdened QA professionals.

Therefore, the food safety professionals cannot manage food safety program in the same old way. There has never been a more important time to stop, take a critical and unbiased view of the food safety management systems and processes, and emulate best practices being used in the industry.

Follow these 10 simple commandments:

  1. Senior Leadership Team on your side

Senior leadership want to know: ROI, key issues and plans to address those, business trending, strategies employed to move the business in the right direction, and how the quality and food safety strategies support business strategies and objectives. These strategies are always focused on the customer.

Be clear with the senior leaders’ group about the investment required in food safety, and the benefits gained through the investment. As we all know, the investment is significantly less costly than the problems. Provide simple but impactful food safety training to the senior leaders. This will highlight that effective food safety training is provided for every team member in the company.

  1. Suppliers audited

Regularly audit all suppliers, especially prior to their first delivery of items. Must review supplier’s track record so it can be established that appropriate systems and processes exist. The audits need to be structured so that all of the elements supporting the supplier’s ability to reliably meet all the quality and food safety requirements are checked, and where deficiencies are found, formal corrective actions are established. There are a number of good auditing schemes in widespread use, accredited under the Global Food Safety Initiative (GFSI).

Best practice in this area: Obtain full copy of every audit, review the audit outcomes to establish that risks are effectively identified and managed; and ensure that corrective actions requested by the auditor are resolved in a timely manner.

  1. Supplier Specifications

To ensure consistency of the items you are using in your restaurant, specification is required for most items.

The specification should include the chemical, physical, and biological parameters the supplier has promised to comply with to ensure the item is safe. The specification should also contain a full ingredient list of the product, including the presence or otherwise of any allergens. This is essential to enable rapid investigation of the presence of a particular ingredient of concern that may be subject of a wider recall.

  1. Supplier Performance

Supplier audit is merely a point-in-time assessment, and may or may not reflect the typical week-to-week performance of a given supplier. Be sure to include conformance to specifications, the number and rate of corrective actions and timely responses to measure performance. The best industry practice is to keep your dialogue and communication with the suppliers – – fact based; transparently providing comments to the supplier on their actual performance.

  1. Risk Assessment and Preventative Controls

Hazard Analysis and Critical Control Point (HACCP) is used on a voluntary basis by few operators, though not currently required. The HACCP process identifies all hazards that may exist and clarifies the point at which the hazard can be managed or controlled. This process prevents the hazard: a) from entering the food, b) eliminating it in product, or c) reducing it to acceptable levels.

FSMA’s requires for the supplier to identify particular hazard, if not controlled by their process. In this case, they must advise users of their non-compliance in writing.

Restaurants must acknowledge that items such as raw meats, fresh produce, and many other items contain hazards, and take on the responsibility for controlling specific hazard. Implement HACCP (if possible) to ensure that the hazard is effectively controlled.

  1. Validate | Monitor | Document |

The validation step determines that the control measures put in place are scientifically sound and will control the identified hazard. Managers and team members are required to “monitor” the control measures to ensure the hazard is eliminated/controlled.

The best way to verify a restaurant’s plan is being followed is to document the evidence. One can also include a review of the execution and evidence for corrective actions being taken when control measures are out of compliance. Verification is providing proof that you are doing what you said you needed to.

  1. Corrective Actions

Organize workflow, take prompt and timely corrective action when something fails and always follow-up. Documentation of all the required communication of the details between the parties is very important. Train and re-train as necessary.

  1. Documentation

An arduous food safety management system ensures that everything is documented—a challenging task in today’s dynamic work environment because of pressure on new product development, constant change in the supplier world, pressure on value engineering, and staff turnover. For documentation to be truly effective, each element of data needs to be dated, and each action must be trackable. Thankfully, technology has changed, and in this cloud-based computing age and with the right software, data can be available to anyone who is authorized, from any device, at any time and from any location.

  1. Complaints and Social Media

While employee empowerment is a great approach to resolve complaints at the point of receipt, there must also be an entrenched process of identifying and resolving common causes. Social Media (Facebook, Twitter, Instagram, Snapchat, etc.) being used by the masses – can’t be ignored and must be effectively monitored and managed.

  1. Professional FTE

One must have a food safety professional on staff – company’s growth and future plans must include a FTE, if not already! Consultants can help and assist you and your team as well – but there are limitations to this.

In short: Almost 60% of all food borne illnesses in the US is caused by food consumed from a food service facility, the business must take every possible step to ensure brand protection and that all food served is safe to eat.

Image: via leewoof.org

Win Super Bowl – Food Safety Defense

Defense wins Championship

As you get ready to serve food to your guests in a restaurant or your loved one, follow these simple FOOD SAFETY DEFENSE rules to avoid food safety penalties during fast-paced Super Bowl celebratiosb51_game_ball_front_1ns.

Personal foul

That hand towel on your oven or hanging from your belt is a 15-yard penalty. Not sanitizing food-contact surfaces before, during, and after prepping raw vegetables and meat is going to
create challenges for your coaching staff. Disposable sanitizing wipes are convenient, fast, and effective at home to prevent cross-contamination that may cause foodborne illnesses.

Illegal formation

Two hours is the maximum time foods should be kept at room temperature. Just one bacterium, doubling every 20 minutes, could grow to over 2 million bacteria in seven hours! Don’t hesitate – refrigerate at 41°F or colder. Meat, poultry, fish and dairy products, pasta, rice, beans and cooked vegetables should be consumed in 2 hours or place them in refrigerator. Refrigerate salads with meat/fish/chicken/seafood, fresh-cut fruits until used.

Clock management

Pre-moistened sanitizer wipes are the smartest way to maintain clean and sanitary hands and surfaces when every second counts.

Unnecessary roughness

Refrigerate take-out
foods right away if you won’t be eating them within two hours after buying. For large quantities, divide food into loosely covered shallow containers before refrigerating and then cover tightly when cool. If you leave your pizza and other perishable foods at room temperature for more than two hours, you will be moving back 15 yards.

Delay of game

Plan to eat take-out foods and leftovers within a day (Monday) for greater safety and quality.

Illegal substitution

Don’t reheat take-out food in its original container in the microwave, unless the container is described as safe for microwave use. Reheat all foods to 165°F. Use a food thermometer and proper utensils.

Illegal use of hands

Provide hand sanitizing wipes before, during, and after preparing or handling food. Wash your hands as many times as you can when preparing/handling food items – especially ready to eat food items.

Neutral-Zone infraction

You can’t see, smell, or taste bacteria that cause foodborne illnesses. It takes from half an hour to two or more weeks before you get sick from contaminated food. Sometimes it’s hard to know if food has been handled safely. If you are not sure, throw it away. No delays allowed.

Hike – Wash, Wipe, Refrigerate, Toss, OMAHA Hut!

Notes: A cooler well packed with ice or frozen gel packs is a practical alternative to a refrigerator. Keep the cooler in the shade. After food comes out of the cooler, remember the two-hour rule. Keep it at 41°F or below. Use a chafing dish, warming tray, steam table, slow cooking pot or a place on the side of the cooking grill. Keep it at 140°F or higher. 

ENJOY THE BIG GAME!

Super Bowl LI is in Houston!

Football photo: courtesy Wilson.com

 

Raw Cookie Dough or not?

Since that late evening bowl of your favorite ice cream is not enough, you add that frozen scoop of chocolate chip cookie dough. Butter, cream, chocolate and a combination of granulated sugar sends satisfying impulses from your tongue directly to your brain, even before you pick up that first spoon. Did you just make that cookie dough in your kitchen or did you buy it from a store?

An FDA warning released earlier this week has consumers confused as to whether uncooked cookie dough is safe to eat because of potential contamination with a type of bacteria that can cause pain in your GI tract. You’re okay eating most commercial cookie dough products–in cookie dough ice cream, where the product is intended to be eaten uncooked.

Edible-Cookie-Dough-Recipe-Step-1Biggest concern is for people eating anything uncooked that contains flour purchased off the shelf or delivered in 50-pound bags to pizzerias and bakeries.

To be perfectly clear:

  • Do not eat any uncooked dough, cake batter, uncooked tortillas, etc. at home.
  • Do not allow your kids (or yourself) to play with dough or flour-based “clay” that some restaurants give away. Check with your day care center and make sure.

So, you wonder:

How can raw cookie dough sold commercially be safe while grandma’s wholesome recipe made at home runs the risk of giving you bloody diarrhea (sorry to gross you out)?

Why does no one seem to be talking about the risks of uncooked eggs that you also add to many home recipes?

The raw dough alarm

The Centers for Disease Control and Prevention (CDC) has been investigating the cause of severe intestinal symptoms in 20 states beginning back in December 2015. Ten people have been hospitalized and one patient went into a type of kidney failure called hemolytic uremic syndrome. These infections have ranged from age 1 to 95, with a median age of 18. Interestingly, 78% of people with the illness are female. I wonder who is guilty of tasting that cookie dough while prepping?

Thankfully – so far, no one has died from raw cookie dough illness.

Multistate-Outbreak-of-Shiga-toxin-producing-Escherichia-coli-O121-Infections-Linked-to-Flour-June-2016-E.-coli-CDCPhoto Credit: U.S. Centers for Disease Control and Prevention

A type of E. coli bacteria called Shiga toxin-producing E. coli O121, or STEC O121 is the common bacteria. Investigations reveal the most likely source of these bacteria is a factory in Kansas City, Missouri. As a result, General Mills issued a recall on May 31 of all sizes and varieties of Gold Medal Flour, Gold Medal Wondra Flour and Signature Kitchens. On June 11, the company confirmed that the FDA had found the bacteria in one sample among the many that were tested.

Because flour has a long shelf life, more cases may emerge.

Most manufacturers of pre-made cookie dough use a heat treatment for flour and a pasteurization process for eggs which, unrelated to this E. coli outbreak, are a known source of disease-causing Salmonella bacteria.

Lesson learned?

Just don’t make homemade cookie dough ice cream unless you have pasteurizing process and related equipment. If that’s your favorite flavor, buy commercially made products. Manufacturers (should) use ingredients that include treated flour and pasteurized eggs.

Don’t eat uncooked flour. Don’t play with it and then touch your face.  Processed foods can sometimes be safer for you than “natural.”

Local-grown or not?

FOOD SAFETY CHALLENGES FOR “TRACTOR-TO-TABLE” MOVEMENT

The “tractor-to-table” (or farm-to-fork or whatever else you call it) movement attracts restaurants and grocery stores to adapt to guests wanting locally grown foods that may be looked as more “natural.”  Food establishment operators may forget that several factors make food commodities from small local suppliers a possible source of brand protection risk, especially for quick-serve and fast-casual operations.

Factors for the operators when “tractor-to-table” movement is added:

All food establishment operators know about these risks and this is nothing new.  The operators and decision-makers must focus on how the “tractor-to-table” approach makes business sense so long as these risks are identified and remedied in a systematic way, and not just being part of a standard operating procedure (SOP) document. Unless operators manage risks with a layered approach and building food safety into daily culture, there are more chances of failure.

  • Employee knowledge and food-safety awareness.

Operators attract transient workers like students, workers that are searching for any job, workers that are retired and someone who is simply new to workforce.  They lack a background in food safety. Their leader (supervisor) may also be new to their responsibilities. The risk elimination and management is a must.

  • Brand protection and regulatory compliance.

In a social media dominant world with Facebook, Twitter, Instagram, Snapchat and Yelp – bad customer experience or an alleged foodborne illness linked to a particular location/brand or food supplier can go viral—pun intended—in minutes.  Public health department and consumers will know about the problems instantly. With the federal, state and local regulatory workforce being at more aware-level, operators and risk management officials need to know how to assess and remedy each situation very quickly. These so called challenges go beyond the regulatory compliance level. The media and guests will demand to be informed.  Enhanced and efficient crisis communications strategy can be very useful in preventing severe damage to brand identity and overall reputation if rumors and wrong information is shared and re-tweeted by the consumers.

  • Farms – Supply chain issues.

The recent Food Safety Modernization Act (FSMA) requires monitoring and inspection for farm operations. Smaller food suppliers, which are not covered by FSMA, are less scrutinized. This doesn’t mean local suppliers don’t follow proper food safety and sanitation procedures. They are less regulated, which could increase the potential risk of tainted foods entering the supply chain.

How do we address these factors?

  • Being Proactive

Revise and modify training to ensure essential practices are included and related rationale is clearly explained and continuously refreshed.  This training is for everyone, not just new hires.  Review every step in food handling to document potential gaps. Where are the more transient food handlers? Where the most significant turnover? Every vendor in supply chain is visited to check their food safety and sanitation practices.  If FSMA rules exempt the vendor, the review and visit become even more important.  A crisis response plan is included in training so that food handlers know their roles before any critical event happens.

  • Timely Identification

Establishment operators must have proper system(s) in place to identify issues quickly. Example: Storage facilities are continuously monitored for safe holding temperature and sanitation. Invest in technology so that temperature monitors provide 24/7 coverage and alert you when critical issues occur.

Let the guests and customers alert you to major concerns that they experienced during their visit. Monitor these hotlines and email ID to resolve as they are reported. Most social media will display a “trending” item/topic. Have dedicated staff member monitor web-based activities.

  • Quick Remedy

Take immediate corrective actions in conjunction with senior management personnel.  Launch the crisis response plan as soon as possible.  Consult legal authority, crisis communications team or outside agencies and others who need to weigh in and manage the crisis. Identify the root cause for the problem and how it can be prevented in future.  Learning from a successfully managed crisis, update food safety and sanitation processes.

Reach out to the guest as soon as possible and inform them that the crisis has been resolved. Let them know that they should feel confident in a positive future dining experience.

I am hopeful that this will help you decide whether you want to go “local” or not!

12 days of Christmas – Inspection

12 Days of Christmas and MY INSPECTION

 

  1. On the 1st day of MY INSPECTION, my inspector gave to me: light shields for all my light fixtures.
  2. On the 2nd day of MY INSPECTION, my inspector gave to me: food container covers for all my stored food items, and light shields for all my light fixtures.
  3. On the 3rd day of MY INSPECTION, my inspector gave to me: proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.
  4. On the 4th day of MY INSPECTION, my inspector gave to me: no expired (out of date) food items, proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.
  5. On the 5th day of MY INSPECTION, my inspector gave to me: proper labeled and stored chemicals, no expired (out of date) food items, proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.
  6. On the 6th day of MY INSPECTION, my inspector gave to me: all utensils stored properly, proper labeled and stored chemicals, no expired (out of date) food items, proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.
  7. On the 7th day of MY INSPECTION, my inspector gave to me: no wet nesting, all utensils stored properly, proper labeled and stored chemicals, no expired (out of date) food items, proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.
  8. On the 8th day of MY INSPECTION, my inspector gave to me: all utensils in good repair and not rusty or chipped, no wet nesting, all utensils stored properly, proper labeled and stored chemicals, no expired (out of date) food items, proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.
  9. On the 9th day of MY INSPECTION, my inspector gave to me: clean gaskets and shelves in my restaurant, all utensils in good repair and not rusty or chipped, no wet nesting, all utensils stored properly, proper labeled and stored chemicals, no expired (out of date) food items, proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.
  10. On the 10th day of MY INSPECTION, my inspector gave to me: all gaskets in good repair, clean gaskets and shelves in my restaurant, all utensils in good repair and not rusty or chipped, no wet nesting, all utensils stored properly, proper labeled and stored chemicals, no expired (out of date) food items, proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.
  11. On the 11th day of MY INSPECTION, my inspector gave to me: all foods stored at 41°F or below, all gaskets in good repair, clean gaskets and shelves in my restaurant, all utensils in good repair and not rusty or chipped, no wet nesting, all utensils stored properly, proper labeled and stored chemicals, no expired (out of date) food items, proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.
  12. On the 12th day of MY INSPECTION, my inspector gave to me: clean ice machine/bar-gun holder/dishes/utensils/cutting boards, all foods stored at 41°F or below, all gaskets in good repair, clean gaskets and shelves in my restaurant, all utensils in good repair and not rusty or chipped, no wet nesting, all utensils stored properly, proper labeled and stored chemicals, no expired (out of date) food items, proper food storage hierarchy, food container covers for all my stored food items, and light shields for all my light fixtures.

  

On the 13th day of my MY INSPECTION, my inspector gave to me: a perfect 100% score and I celebrated so much that I became sick from foodborne happiness!

Power outage? Worried about your food?

No lights? No A/C? No power to your refrigerator?

The techniques for handling food during power outages, when applied, will reduce the possibility of bacterial growth in food and help food remain safe for human consumption.

Raw Foods:

As a general rule, discard fresh meats, fish, poultry, or dairy products if the color or odor is poor or questionable. The rule is “When in doubt, throw it out.” Saving or eating a possibly contaminated food product is never worth the risk of food borne illness.

Perishable (or potentially hazardous) Foods:

Perishable food, including meat, poultry, fish, dairy products and leftovers that have been held at temperatures greater than 41ºF for more than four hours should be discarded.

Thawed food in the freezer, including raw meats and vegetables and fruits without sauces, that contain ice crystals or have been held at 41ºF or below can be refrozen and cooked. However, do not refreeze thawed cooked foods or packaged dinners that have thawed out. Pre-cooked thawed items are highly susceptible to bacterial growth.

Maintaining Foods Safe in the Freezer:

After a power outage, keep the freezer door shut for as long as possible. A full freezer will keep food at freezing temperatures for about two days. A half-full freezer will keep food frozen for about one day. If the power is off for several days consider using dry ice. Check the yellow pages of your telephone directory for “ice”. Many grocery stores have dry ice. Call ahead to make sure that the grocer has an adequate supply. Allow 2 ½-3 pounds of dry ice per cubic foot of freezer space in a chest freezer. In an upright freezer more dry ice is required so that ice can be placed on each shelf. Because dry ice can burn exposed skin, do not touch it with bare hands. Follow instructions on dry ice usage carefully. Make sure it is wrapped in several layers of newspaper before placing it in the freezer.

Temperatures

Cook or heat food to a minimum of 145º. If food is to be reheated, it must be rapidly reheated to a minimum of 165º. Use a probe-type metal thermometer to test the final cooking temperature.

Store perishable or potentially hazardous food cold food at a minimum of 41º F or below.

Water and Cleanliness

Safe potable water must be available and used for cooking, dishwashing, drinking and maintaining personal hygiene. If the Municipal water supply is not safe, use bottled, boiled or treated water. Make sure dishes and utensils are clean by washing, rinsing and sanitizing them in safe potable water. Sanitization is very important at this time. Effective sanitization can be obtained by adding one ounce of regular household chlorine bleach (unscented type) to each gallon of safe potable cool water. Wash with soap and water first, rinse with clean water second, and sanitize with bleach water, using the proper proportion of bleach to water. Allow bleach-water solution to air-dry on the utensils. Store the clean utensils in a clean place to protect them from recontamination.

The use of single service items is encouraged to reduce the possibility of food borne illness. Paper plates and cups, plastic knives and forks that are used only once and discarded are highly recommended.

Insects and Rodent Activity

Since air conditioning usually does not work during power outages, door and windows are usually kept open. Insects and rodents may gain entrance into the building. Make sure that doors and windows are adequately screened, using screening material of not less than 16 mesh to the inch.

By discarding spoiled food, controlling food temperatures, keeping utensils clean and sanitary and by keeping pests out, the fear of food borne illness can be eliminated from your post-disaster recovery concerns.

If you have specific concerns, please let me know or call your local Health Department.

Hope you get your power and utilities back up and running soon! Stay safe!

 

Fresh Produce – Bad for you?

As you take on the challenge to loose weight by eating healthier this New Year – do you know the following facts?

According to the Centers for Disease Control and Prevention’s (CDC) annual year in review, there were 16 multistate outbreaks of foodborne illnesses in the U.S. in 2011, with five of them involving fresh produce.

Fresh produce involved: romaine lettuce, cantaloupes (two outbreaks), whole papayas and alfalfa and spicy sprouts. Two outbreaks were related to nuts, one involving Turkish pine nuts and the other involving hazelnuts. Lists for recent years are on the CDC’s website. According to the CDC, 2011 was the most active year in recent history for foodborne illness outbreaks that crossed state lines.

Some of the headlines from last year:

  • Whole fresh papayas imported from Mexico were linked to 106 people infected with Salmonella Agona. The illnesses were in 25 states and were reported between January and August.
  • Whole fresh cantaloupes from a single farm in Guatemala and sold in the U.S. were linked to 20 people in 10 states with confirmed cases of Salmonella Panama. This happened between February and April.
  • Alfalfa and spicy sprouts produced by a company in Idaho, were linked to 25 confirmed cases of Salmonella Enteritidis in five states as of July. The illnesses were reported from April to July.
  • Whole fresh cantaloupes from Colorado, were linked to 146 people in 28 states that were infected with strains of listeria. As of December 30 people died. In addition, one woman who was pregnant at the time of illness had a miscarriage.
  • Fresh-cut romaine lettuce — distributed by a distributor in Oklahoma, to Supermarkets in the St. Louis area, and other locations was involved in E. coli O157:H7 infections. As of Nov. 30, 60 people infected had been confirmed in 10 states.
  • Do we need a better safety system?
  • Do we need more regulations?
  • Do we stop eating fresh produce items? Or
  • Do we take a chance?

Challenges for the growers, farmers and everyone:

Compliance is the key to the success of any food safety system and any new system should be flexible enough so that the growers can comply.  Produce growers vary in size ranging from larger operations that grow, pack, and ship their produce both in-state and across state lines, to very small farmers who sell all their produce directly to the local public.  Some irrigate from surface water, others use ground water, some are near livestock operation.

We must consider:

1. Flexibility. Flexibility per Best Management Practices is key to the success of any new food safety system. Different regions of the country use production land very differently.  Different regions of the country use production land differently, such as continual use of specific land for produce production versus shifting use of land between pasture, other crops and production of vegetables.

2. Sound Science. Any new practices should be based upon proven and effective food safety practices and sound science.  Most of produce is not produced in an indoor or enclosed environment and should not be regulated in a manner that is unrealistic to achieve.  May be the federal government take the time to fund and complete the science and research needed to determine the most appropriate and safe practices?

3. Existing resources. Program should be coordinated with State departments of agriculture or other agencies responsible for food safety, inspection and enforcement.  Such coordination will be crucial to the success and will prevent redundancy in programming.  The funding, education and training for inspectors should be bolstered.

4. Economy. The development of any new system should consider the economic impact on various size operations across the county. Any new system should be economically viable within existing industry structures that vary across the country.

As we move forward in enhancing the safest food system in the world, we must be cost-effective, practical, use proven science and allow flexibility by working with the stakeholders in developing the best practices. We do have a diverse food production system in this country.

Now, let me go consume that fresh salad I just prepared. I am hungry!