HACCP Mentor

This week I have had the pleasure of presenting at Food Safety Live 2014 on Understanding Raw Material Traceability. My […]

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Food product innovation can be an exciting part of any QA role. In this episode of HACCP Mentor review check […]

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Welcome to Episode 41 of HACCP Mentor Review

Thanks for checking out Episode 41 of HACCP Mentor Review. In this episode we take a look at product claims made on food packaging, garbage skips bins and how to apply document control to excel spreadsheets.

Product Claims

Product claims are becoming more and more popular as food manufacturers seek a business advantage over competitors, satisfy corporate vision statement or to meet the particular needs of a food consumer niche. It seems that the marketing department love to be able to make claims on the product packaging and labels – but is your food business claiming something that it is not?

Requirements for product claims made by you food business are covered under the certification by the major GFSI recognised standards. Product claims can be grouped into the following:

* Nutritional – eg. high protein, low fat, low carb, high calcium, no added sugar

* Health related – eg Good source of omega 3, Multigrain, Diabetic, Gluten Free

* Religious – eg. Kosher, HALAL

* Ethical – eg fair trade, workforce labour issues, sustainable palm oil, free range

* Provenance – statements of origin, Grown in, made in

Whatever product claim your food business makes on your product packaging you have to be able to verify the claim in addition to having a good working knowledge of relevant regulatory requirements in your country of manufacture and any country that you may export to. If you make false or misleading food product claims you may find your business faced with some hefty court action and financial impacts.

Examples of False and Misleading Food Product Claims

In April 2009, Kellogg Company in the USA, agreed to a settlement of $4million dollars after they were charged by US Federal Trade Commission with making a false advertising claim on their Frosted Mini-Wheats cereal. The claim stated that the product was “clinically shown to improve kids’ attentiveness by nearly 20%”.

More recently, a game farm located in Australia was recently fined over A$20,000 after it made claims on its product packaging and its business website that their birds were “range reared”, when in fact they were grown in commercial sheds with no access to the outdoors.

Baiada, another Australian based company, made a similar claim stating that its birds were free to roam in large barns. $400,000 in civil pecuniary penalties were ordered to be paid in this case of false and misleading advertising.

Now is a good time to have a look at the product claims that you make on any of your products. For each product, map the evidence and records that supports the claim and have this information on file. You can do this by undertaking a mini food audit of the product claim.

Raw material risk assessments

I have had a fair bit of interest for further training on how to undertake a raw material risk assessment. If you haven’t already registered your interest you can do that by clicking the link called ‘raw material risk assessment training’ in the show notes to this episode.

Garbage skips and pests

This week’s action item is to go outside and check that lids on external garbage skips are closed. Pests are attracted to uncontrolled waste so having lids closed on these bins can dramati...

One of the most common document control mistakes that I see is when food businesses forget to add document control […]

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This episode covers mapping your HACCP documents, how to risk assess raw materials, a round-up of recent food poisoning outbreaks […]

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Transcript Welcome to Episode 39 of HACCP Mentor Review, I am Amanda Evans and in this episode we […]

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Find out how to verify your food shelf life along with dealing with customer extortion, testing air quality and what are the risks associated with spices.

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HACCP Mentor Episode 38

Welcome to Episode number 38 of HACCP Mentor Review. In this episode we talk about customer extortion, how to verify food shelf life, undertaking air quality testing and some interesting stats on spices which will help in your raw material risk assessments.

Customer Extortion

I had a very interesting telephone call from a client this past week about a customer complaint that they had received. The customer claimed to have broken a tooth after consuming one of their products. The product contained olives in which the pip had not been removed.

The injury allegedly happened 6 weeks ago. Anyway, this guy calls up to say that he has been to the dentist to have the tooth fixed. Now keep in mind that this was 6 weeks ago and this is the first contact since the alleged incident.

He then proceeds to tell management that if he doesn’t get $800.00 for his dentist bill by 5pm that day, he is going to the media. There is no denial from my client that this type of incident could occur – we know it can – pits are found naturally in olives. Regardless of who is a fault, the customer does not have the legal right to extort payment from a food business.

If you want to find out what to do if your food business is ever in this position check out HACCP Mentor’s post on “How to handle attempts of food extortion”.

How to verify food shelf life

Establishing food shelf life and regularly verifying the shelf life of your food products is a basic food safety requirement. This means – you have to be able to back up (with evidence) the food shelf life or expiry date that you label on your products. When establishing the shelf life, consideration needs to be given to not only your process environment but also target food safety and quality parameters. The packaging that the product gets sold to the consumer in needs to also be considered. When setting up your shelf life verification program make sure that it includes:

* Testing of retention samples at different points in the product shelf life eg. day 2, day 45, day 100 for all parameters.

* Challenge testing of the product to support your storage instructions eg. to account for the cold chain process post dispatch.

* Testing the product beyond the stated shelf life eg. test at 13 months if the product has a 12 month shelf life indicated on the label.

Just a quick note for any food business that is starting out. Establishing your food shelf life from what your competitor has labelled is not acceptable. The way that they make their food product may be very different to how you manufacture your food product. Their manufacturing site is going to be very different to yours as well.

 

Testing Air Quality

The action for this episode is to check that air quality testing has been completed in the previous 12 months. In this regards, I am referring to testing compressed air that comes into contact with any food or food contact surface. The quality of the air used in your food manufacturing business can have a direct impact on the quality and safety of your manufactured food products.

Risk Profile for Spice

The USFDA has recently released a risk profile on pathogens and filth in Spices. If you use spices in any of your food products this is a great resource to check out. The information provided will assist you in undertaking your own raw material hazard analysis which the majority of GF...

Find out what happens when the marketing / sales team do not communicate with food safety QA along with what are measurable food safety objectives, updating pest contractor credentials, the art of being organised and understanding food-grade statements.

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Transcript to Episode 37 of HACCP Mentor Review

Welcome to Episode 37 of HACCP Mentor Review. In this episode we find out what are measurable food safety objectives, updating pest contractor credentials, the art of being organised and understanding food-grade statements. I also share a personal story of what happens when sales and marketing don’t communicate with a QA team.

What are measurable food safety objectives?

Food safety objectives are the same as business objectives but just with a food safety focus. You are required to identify your food safety objectives in a way that can be later assessed to see if you actually met that objective. This is what we call “measurable food safety objectives”.

For example, if you set one of your food safety objectives as “we will to respond to all customer complaints within 24 hours”, you would need to set up a mechanism to capture or record the time taken to respond to customer complaints.

Your business can then assess these results on a regular basis to see if the food safety objectives are being met. If this is not the case, your management team can then review what is not working correctly in your food business and then implement suitable adjustments or corrective action.

Does your marketing and sales team talk to your food safety QA team?

This week I received an email from the marketing sales manager of a client of mine. I have never met this person and to be honest I did not even know the role existed in the business. Anyway, he emailed me with a copy of a HACCP logo with the intention of using it on their product packaging. His emailed read like this:

“We have used a new HACCP logo (which we were under the impression was generic). We used this logo for the simple fact of in the event of changing auditing companies we do not have to change the carton print each time”.

When I opened the email attachment I was horrified to see that the logo was not only that of another certification body, but that particular audit company is not even a recognised certification body in the world of food safety. This will be a very expensive lesson for this marketing sales manager as his email also stated that food packaging has already been printed and due for delivery next week.

This particular food business has been with their current certification company for over 8 years and have no intention of changing any time in the future.

So there are a few lessons to be learnt from this scenario:

* There is no such thing as a generic HACCP logo. You cannot make a claim that you cannot validate.

* Only use the logo from the certification body that audits you as per their food safety HACCP certification marketing guidelines.

* Make sure that the Food Safety QA department is involved in all packaging artwork decisions at your food business.

* Never order food packaging without first checking and validating each and every section of the artwork (including ingredient lists, marketing claims, nutritional panels and warning statements).

* Educate the marketing and sales team within your food business about the certification audit process and what it actually means.

Pest Contractor Licences

The action item for this episode is to check that licences issued for pest contractors are current. It is a requirements of the majority of GFSI standards that only trained personal are used in the chemical pest control application.

The art of being organised

I had two of my clients audited this week with both having a successful outcome. I can put this down to their hard work and commitment to their f...

HACCP Mentor Episode 36

 

Welcome

Welcome to episode 36 of HACCP Mentor Review where this episode we discuss bushfire contingency, organising your verification activities, calibrating product scales and how to reduce stress in a multi-standard audit.

Have you got a Bushfire Contingency?

This week I have experienced extremes of weather conditions from working down in southern Victoria and having to wear a jumper and socks to bed to returning home to Newcastle only to experience some of the worst bush fires this season. Because of the fires, many of our roads in and out of Newcastle were closed. Newcastle airport was also closed for a day and a half. I was lucky to change my flight and get back home before the airport was closed. Now you are probably wondering why I am telling you this. If your food business was subjected to this type of crisis, would you manage? If the roads were blocked and staff or supplies could not get through, have you got contingency plan in place? Take a moment to check if you have considered these questions in your crisis management or business continuity plan.

 

 

Organising your Verification Activities

As part of the HACCP process and HACCP audits, all businesses have to undertake verification activities. Verification activities can include things like micro testing of finished product, water testing, internal audit and undertaking a mock recall. Keeping track of all these activities and making sure they are completed can become an issue if you are not organised. I find that the easiest way to track verification activities is to use the calendar on the computer. I schedule the date that each activity is due and it sends a reminder via email of what has to be done. Another method that I have seen used when I audit, is spread sheet with activities plotted on an excel calendar. This works well as you can also print out the spread sheet and stick it to the wall in your office.

Organise your HACCP documentation with this simple system– (Click Link)

Action of the Week

The action for this episode is to go around and check that your scales have been calibrated. Use your calibration schedule to also make sure you have documented the scale name, serial number, location and tolerance.

How to reduce stress in multi-standard HACCP audits

With more and more customers and retailers wanting to undertake their own food safety and HACCP audits, your food business may be subjected to multi-standard audits. The client that I audited in the past week was audited to four (4) different standards in the one audit. It can become a bit over-whelming for the auditee to be part of this kind of audit but the stress can be considerably reduced if you are organised. The number one thing you can do is map all of your HACCP food safety system to the requirements of each of the standards that you get audited against. By this I mean, go through each clause of the standard and match or reference where in your HACCP Food Safety Quality Manual where this requirements is covered.

Tell me what you think

Well that wraps up episode 36 of HACCP Mentor. I hope that you have got something out of it and as always l would love to get your feedback. Leave a comment below on how you organise your verification activities. Until next time, I am Amanda Evans from www.haccpmentor.com

 

HACCP Mentor Episode 36

HACCP Mentor Episode 36

 

Welcome

Welcome to episode 36 of HACCP Mentor Review where this episode we discuss bushfire contingency, organising your verification activities, calibrating product scales and how to reduce stress in a multi-standard audit.

Have you got a Bushfire Contingency?

This week I have experienced extremes of weather conditions from working down in southern Victoria and having to wear a jumper and socks to bed to returning home to Newcastle only to experience some of the worst bush fires this season. Because of the fires, many of our roads in and out of Newcastle were closed. Newcastle airport was also closed for a day and a half. I was lucky to change my flight and get back home before the airport was closed. Now you are probably wondering why I am telling you this. If your food business was subjected to this type of crisis, would you manage? If the roads were blocked and staff or supplies could not get through, have you got contingency plan in place? Take a moment to check if you have considered these questions in your crisis management or business continuity plan.

 

 

Organising your Verification Activities

As part of the HACCP process and HACCP audits, all businesses have to undertake verification activities. Verification activities can include things like micro testing of finished product, water testing, internal audit and undertaking a mock recall. Keeping track of all these activities and making sure they are completed can become an issue if you are not organised. I find that the easiest way to track verification activities is to use the calendar on the computer. I schedule the date that each activity is due and it sends a reminder via email of what has to be done. Another method that I have seen used when I audit, is spread sheet with activities plotted on an excel calendar. This works well as you can also print out the spread sheet and stick it to the wall in your office.

Organise your HACCP documentation with this simple system– (Click Link)

Action of the Week

The action for this episode is to go around and check that your scales have been calibrated. Use your calibration schedule to also make sure you have documented the scale name, serial number, location and tolerance.

How to reduce stress in multi-standard HACCP audits

With more and more customers and retailers wanting to undertake their own food safety and HACCP audits, your food business may be subjected to multi-standard audits. The client that I audited in the past week was audited to four (4) different standards in the one audit. It can become a bit over-whelming for the auditee to be part of this kind of audit but the stress can be considerably reduced if you are organised. The number one thing you can do is map all of your HACCP food safety system to the requirements of each of the standards that you get audited against. By this I mean, go through each clause of the standard and match or reference where in your HACCP Food Safety Quality Manual where this requirements is covered.

Tell me what you think

Well that wraps up episode 36 of HACCP Mentor. I hope that you have got something out of it and as always l would love to get your feedback. Leave a comment below on how you organise your verification activities. Until next time, I am Amanda Evans from www.haccpmentor.com

 

HACCP Mentor Episode 36