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Corrective Action Plans: Step Up Your Environmental Monitoring Program


Sound the alarm – your facility received a positive pathogen result, like listeria or salmonella. How can you address the issue? Are you prepared to eliminate the source and not just the symptoms? A corrective action plan allows you to detect and fix a problem that occurred during food production, including actions associated with a corrective action procedure.

So, where do you begin?

In this blog, we outline three necessary aspects of successful corrective action plans you can use to improve your environmental monitoring and safeguard your facility.

Initiating Your Corrective Action Plan

A positive or presumptive positive pathogen results in any zone of your Environmental Monitoring Program (EMP) triggers a corrective action.

As you move through your corrective action plan, ensure thorough documentation of all investigations conducted, steps taken, and include a complete description of the trigger. It helps to define a responsible party or person who can handle initiating, completing, and documenting corrective actions.

Intensify Cleaning

The USDA requires intensified cleaning and sanitation immediately following a positive sample of a pathogen. FDA regulated facilities should follow similar steps as those recommended by the USDA. Begin by identifying all possible harborage sites and cross-contamination pathways in your facility. Consider employee traffic routes or product moving equipment, like pallet jacks and forklifts, during this process.

Next, fully disassemble and clean the equipment. The means of sanitation depends on your machinery’s sanitary design. Intensified cleaning should always include deep cleaning, high sanitizer concentration application to the affected equipment and surrounding areas with adequate residual time, and then rinse and final sanitizer application at normal concentration.

If you continue to see positive pathogen results, you may need to repair or replace the equipment in question.

Note that the surrounding production areas and supporting equipment are subject to additional monitoring and cleaning activities. Regard them as potential harborage areas until your corrective action proves successful.

Swab Your Way to Success

Look at the size of your operation and the type of products you produce to determine what kind of follow-up sampling method you’ll enact as part of your corrective action plan. Your chosen method should include 2 to 3 sets of swabbing performed in the days after an initial positive result.

When swabbing these areas, consider vectoring. Vector swabbing is a method based on the location of the original positive sample. To learn more about the process of vector swabbing, consult our online Environmental Monitoring Program training.

During this process, you may need to quarantine the area from any personnel traffic or product movement to prevent any additional contamination.

Holding Procedures and Root Cause Analysis

If a zone 1 test in your facility receives a positive pathogen sample, consider whether all affected finished products should be placed on hold or under quarantine after sanitization, pending the corrective action and retest results.

Of course, to truly eliminate harmful bacteria and mitigate risk, you need to know the root source. In other words, you need to determine the underlying cause of the situation. Where did the bacteria originate? How did it enter your facility?

If you find a root source not incorporated into your corrective action, there’s a good chance that corrective action proves ineffective. Always consider root cause analysis as part of your corrective actions, not a step to take after the fact.


To ensure you’re not consistently battling the same issues on the production floor, you need to implement thorough corrective actions. After detecting a pathogen, take care to sanitize the area and surrounding equipment beyond daily cleaning routines. You may need to quarantine the area while you get to the root of the risk and conduct retests until negative results prove the bacteria is no longer present in your facility.

Remember, an effective EMP’s objective is to identify potential pathogen harborage areas that could become sources of contamination and serve as verification of a company’s sanitation program.

The Alchemy Academy Solution

As per 21 CFR 117 Subpart B, any facility that handles ready-to-eat (RTE) and microbiologically sensitive foods must develop an environmental monitoring program to mitigate inherent food safety risks. Our online EMP training course helps you improve your program and corrective action plan for continued food safety success.

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Recognize the Difference Between Food Defense and Food Safety

food safety

Can you spot the difference between food safety and food defense? While both have an important place in your facility, each presents distinct characteristics and consequences. Knowing the difference helps your team better protect the food and strengthens their contributions to your Food Defense Plan.

Let’s take a closer look at food safety vs. food defense.

Variations in Terminology

The purpose of a food defense program is to protect foods from intentional adulteration and to reduce the impact of an attack on the food system. Food defense, however, is not a globally recognized term. Some countries refer to everything as “food safety.” Others use terms like “food integrity,” “food protection,” and even “food crime.” Keep this in mind when interacting with partners in different countries or regions.

At Alchemy Academy, we emphasize the definitions provided by the Food Defense Modernization Act.

Food Safety vs. Food Defense

You already know that food defense refers to intentional adulteration prevention. Food safety, on the other hand, concerns unintentional adulteration. This means that food defense stems from a system attack, while food safety originates in system failure.

Both food safety and food defense involve microbial chemical agents and potential contamination from physical agents, like metal or glass. Even so, food defense primarily focuses on unexpected agents. For example, you wouldn’t expect anthrax to show up in your food.

All in all, food safety contaminants usually occur at low levels and are reasonably likely to pop up during your hazard analysis. Conversely, food defense contaminants happen at higher levels (so that the attacker can produce an effect). Food defense threats do not often occur during hazard analyses.

Regulation & Responses

Food safety involves a history of regulation, while food defense only recently saw regulation.

It’s important to note that there is a significant difference in the responses to food safety vs. food defense incidents. While the FDA and USDA regulate both, intentional adulteration is a crime. Therefore, a food defense threat could involve law enforcement – including the FBI. The perpetrators of intentional adulteration are subject to investigation, prosecution, and even jail time.


Understanding the difference between food safety and food defense helps everyone detect and respond to contamination issues in your food manufacturing facility. Food defense deals with intentional harm posed to your facility, while food safety concerns itself with those unintentional risks.

To learn more about food defense concepts and to identify vulnerable points in your food production, consider our Food Defense Supervisor Awareness course developed in partnership with the FPDI of the University of Minnesota – the leading authority on Food Defense.

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What Safety and Hygiene in the Hospitality Industry Means For You

hospitality management

Increased hotel hygiene is the order of the day. Your guests’ expectations for safety in the hospitality industry are more stringent than ever, but are you ready to address a broad spectrum of infections beyond coronavirus? An enhanced hotel sanitation program is a crucial piece of the puzzle to protecting your consumers and employees.

Keep reading for an overview of the hotel practices needed to lead your team to sanitation success.

Hand Hygiene

Hand hygiene is one of the simplest yet most effective ways to promote hygiene in the hotel industry. Guests, staff, and suppliers should wash hands:

  • Before touching your mouth, nose, and throat
  • Washing hands before handling, preparing or serving food
  • Using tissue paper to cover your mouth and nose while sneezing and coughing
  • After using the toilet
  • After touching public installations or equipment, such as escalator handrails, elevator control panels or doorknobs

Respiratory Hygiene

  • Think of respiratory hygiene, or cough etiquette, as a means of source control – especially for viruses like COVID-19. Always remember to:
  • Cover your mouth and nose when coughing or sneezing
  • Use tissue paper to contain respiratory secretions and dispose of them promptly in lidded bins
  • Perform hand hygiene steps after hands come into contact with respiratory secretion
  • Offer masks to persons with respiratory symptoms when tolerated

Environmental Hygiene

The next step in your hotel sanitation program is environmental hygiene or the cleaning protocols applied to physical areas and objects. Think guest rooms, lobbies, restrooms, and so on. Here, the housekeeping department represents the core of your efforts.

To perform their jobs effectively, housekeeping needs to follow a specific order of operations and know what to do when faced with contamination. Our new Hospitality Management Principles for Preventing the Spread of Infection course is an excellent resource for this type of granular view.

Linen Management in Your Hotel

Housekeeping must also handle linens with care. Always handle, process, and transport used linen as little as possible and separately from clean linen.

Special Areas to Consider

Some areas of your hotel require different measures due to their individual uses. Examples include gyms, spas, and children’s activity areas. Health and wellness spaces are commonly shared among several people and require an increased frequency of cleaning. Children’s clubs require heightened attention to everything from toy choice to cleaning methods.

The Final Word on Hotel Hygiene

Giving your guests and employees peace of mind requires a more rigorous hotel hygiene routine. On top of elevated sanitation procedures, encourage everyone to practice hand and respiratory hygiene. To learn more about the detailed operational alterations needed to show customers your commitment to safety, check out Alchemy Academy’s selection of in-depth eLearning materials.

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10 Steps to Jumpstart Your Occupational Health and Safety Program

osha program

Building an effective occupational health and safety program can sound intimidating at the start. Without it, you run the risk of illness, injury, and even death in your facility. With it, you help ensure the safety of both your employees and your financial assets. According to the Occupational Safety and Health Administration, you can set your facility up for health and safety program success with the outline provided below.

Make health and safety a core value

Establish a policy that emphasizes your organization is committed to workers’ health and safety.

Lead by example

Everyone needs to follow the protocols set in place, no matter the pecking order. More buy-in from your employees at all levels early on leads to a more successful OHS program (and audit).

Establish communications

It’s essential to form ways for your workers to report incidents, hazards, and concerns without fear of retaliation. This practice instills trust and could prevent further accidents from happening in your facility.

Provide Required training

Knowledge is power. Provide your personnel with the training they need to actively participate in the OHS program.

Set up inspection programs

Work with your employees to audit activities, equipment, or materials that could create hazardous conditions. Use checklists! The more documentation you have, the better.

Collect ideas from the workforce to identify and control hazards

Get people involved in your regular inspections of all operations, equipment, plant vehicles, and work areas.

Implement hazard controls

Train your employees to incorporate new hazard controls into their routines. Remember always to integrate their feedback.

Prepare for emergencies

Next, identify any foreseeable emergencies. Develop emergency action plans, continue training your workforce, and perform drills to ensure everyone knows what actions to take.

Implement a process for management of change

Consult with your employees on potential health or safety concerns before making changes. Creating a safe working environment should not make your workforce’s tasks more difficult.

Plan for ongoing improvement

An effective occupational health and safety program is one that adapts to improve performance. Continually verify that the corrective actions put in place are doing their intended job and adjust if needed.

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How to Impress a Buyer with your Food Safety Plan

laptop sqf

After long months, you have carefully crafted a product you are certain customers will love; next is the ultimate goal: to see your product on store shelves or better yet featured on a menu. But how do you catch the eye of a buyer? A buyer’s concern beyond taste, appeal and marketability is the safety of your product – the last thing either of you want is to be associated with a food safety recall. Make it easy for a retailer or foodservice establishment to trust your product by demonstrating you have a solid food safety plan in place.

But what food safety programs will convince the buyer you’ve got this? From hand washing to food fraud, some programs you are likely to already have but will need to evolve them as you grow and expand, other programs you may never thought of.

8 Steps to Food Safety Success

An SQF Fundamentals certification is a great way to tackle this. These 8 steps will help you along the path to food safety success.

  1. Learn about SQF Fundamentals
  2. Register in the SQFI assessment database
  3. Identify your food sector categories (FSCs)
  4. Build your food safety team
  5. Document and implement SQF Fundamentals
  6. Select a certification body
  7. Conduct a pre-assessment
  8. Schedule the sQF Fundamentals audit


#1 The first place to start is to learn about SQF Fundamentals.

One of the best ways to learn how to put together a food safety program based on SQF Fundamentals is to use one of our SQF training solutions, such as the Implementing the SQF Fundamentals Code for Manufacturing e-Learning Course.

#2 Register in the SQFI Assessment Database.

Sites are required to register in the SQFI assessment database before they begin the certification process. This lets SQFI know you’re interested. Registration is annual, and there is a fee per site payable at registration and renewal. The database and fee chart can be accessed from the SQFI website ( Your site must register with SQFI prior to certification and must remain registered to retain your certification. If your site fails to maintain registration, your certificate will be invalid until you are properly registered in the SQFI assessment database.

#3 Identify your food sector categories (FSCs)

SQF food sector categories help identify which food safety requirements best fit your product and its production process. In other words, the food sector category points you to the applicable GMP module you will follow and be audited to.

Use the chart below to figure out which FSC is right for you:

#4 Choose your type of certification

Even though there are still the initial three levels of certification (Level 1, 2, 3), they have different designations now. Fundamentals (Level 1) is meant for small- and medium-sized food suppliers that are wanting to build or strengthen their food safety management program and move toward GFSI certification. Food Safety (Level 2) uses a HACCP-based approach to meet almost all of the GFSI-benchmarked food safety standards. Food Safety and Quality (Level 3) is meant to monitor and control threats related to food quality in facilities that already have a robust SQF Food Safety Plan.

#5 Obtain proposals from SQF Licensed Certification Bodies.

Use resources on the SQFI website to find a Certification Body. These Certification Bodies employ the site auditors and they have to be accredited as well and this accreditation has to be renewed annually. Reach out to at least one of these businesses in your area to get a proposal to see which one is best for you.

#6 Conduct a pre-assessment (optional).

Once you’ve done all the previous steps, either an SQF Auditor or SQF Practitioner can perform a pre-assessment of your program. By doing this, you can evaluate your program and identify where it might be missing something to get the kind of certification you’re wanting. Even though this step isn’t required, it’s a good idea to do this so you can make sure what you’ve put in place is enough to meet requirements and if it isn’t, get a better understanding of what you still need.

#7 Choose a certification body and schedule an audit.

By having multiple proposals, you can compare and learn which company best suits your needs and your facility. After you choose, contact that Certification Body so that you can set up a scheduled time for an audit with them.

#8 The Certification Body conducts initial certification audits.

When you’re first getting your SQF Certification, the initial audit is different than any that follow. Initial audits consist of a Document Review, or Desk Audit, and a Facility Assessment, or Facility Audit. The combination of these two assessments decides if you meet the standards just in theory or in practice as well.

These steps don’t all take the same amount of time, obviously. Getting to know what the SQF Code is and how to actually put everything in place takes more time than just scheduling the audit. If you’re looking to designate your SQF Practitioner or get a better understanding of the code, Alchemy Academy is here for you. Our online catalog has resources to get you on track for whichever aspect you need—from updates to SQF Practitioner training. Taking your first step to SQF Certification sets you apart and supplies you with the resources and recognition to make your food safe and provide reassurance to your consumers.

Three Free Tip Sheets for Food Safety Fundamentals


About the SQFI Fundamentals Program

SQFI has created a solution for small and medium sized suppliers who don’t have a robust food safety management program in place or want to take their existing program to the next level.

SQFI has developed the Fundamentals Program for Food Manufacturing and the Fundamentals Program for Primary Producers, just for business owners like yourself.

The goal of the SQF Fundamentals Program is to help protect your brand from the risk of a recall and satisfy your buyer’s requirements. The SQF Fundamentals Program helps to facilitate retailer acceptance of entrepreneur’s like you, providing food safety security and acceptance along the supply chain.

Built as a step-wise approach, The SQF Fundamentals Program is designed to help you integrate robust food safety standards into your existing practices, while creating  a pathway to achieving globally accepted GFSI certification.

The codes within the fundamentals program provides a seamless transition to the SQF Food Safety Program, which is bench-marked to the GFSI standards.

The SQF Fundamentals Codes were developed using the GFSI Global Markets Programme toolkit, which meets retailers and buyers requirements for small and medium food producers. This new program will help to create a win-win scenario where all parties can benefit from safer food and increased brand protection.

Download the SQF Fundamentals for Manufacturing – Basic Edition 1.1.

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Building Your Produce Safety Program: Focus on Agriculture Water

A careful examination of the potential hazards and the contamination risks they might represent to your agricultural water is a critical step to avoiding a foodborne illness incident associated with your company’s products. Certainly, USDA’s Good Agricultural Practices (GAPs) and FDA’s Produce Safety Rule provide a blueprint for the types of hazards you might look for in your production environment and offer insights into the preventive controls you might employ to manage any potential cross-contamination risks.

But, let’s look a bit further into agricultural water and share some thought on:

  • How to define agriculture water

  • Why agricultural water is so impactful

  • Factors to consider for preharvest water

  • Practices to improve postharvest water quality

Types of Agricultural Water

Preharvest water is used during the production of the crop right up until harvest. Preharvest water commonly includes water used for all types of irrigation, mixing agricultural chemicals like pesticides or fertilizers, frost protection, and dust control.

Postharvest water has always been a high priority for producers since it contacts the crop after harvest and closer to when the product is consumed. If the water was contaminated with human pathogens, the potential for large-scale cross-contamination onto the crop is significant and could negatively impact public health. Postharvest water uses includes hydro-cooling, cooling with ice directly, water used for transporting products from harvest gondolas or field bins, and wash water.

Why Agricultural Water Matters

When it comes to foodborne illness outbreaks and fresh vegetables, agricultural water is often one of the first avenues of investigation. Agricultural water, both preharvest and postharvest, generally contact the edible surface of the product and can transfer pathogens to these surfaces facilitating the consumption and in some cases cause illness. It has been postulated that some of the recent national advisories focused on romaine lettuce contaminated with E. coli O157: H7 was due to the use of contaminated irrigation water. Outbreaks associated with the use of contaminated water used for ag chemical mixing have also been reported.

So, what can be done to ensure postharvest water quality?

Each source of water used in preharvest applications is different physically, chemically or microbiologically. One well might be deep, another shallow. Another might be an open irrigation canal or a fast-moving river, an on-farm pond or lake. For this reason, it is important to perform a hazard analysis and a risk assessment on each field and the water source you intend to use. What is the area around your water source that might represent a cross-contamination hazard where pathogens could find their way into the water? Animal feeding operations, wild animal intrusion, leaking sewage systems, runoff from adjacent composting areas, human interaction with the water like swimming are all potential hazards to consider. You must then consider the risk for cross-contamination these observed hazards represent. Could wind, animals, humans, or water runoff from adjacent fields or landscapes carry pathogens from the hazard to the ag water source for the farm? If it could, then you must develop preventive controls to manage the risk and take steps to measure its effectiveness. In some instances, disinfectants are being used on open water sources on farms though this must be carefully implemented to make sure the disinfection is effective and continuously monitored.

It is also important to assess the method for delivering water and how it is used on the crop. An open water source subject to cross-contamination used in overhead irrigation where the water contacts the edible surface of the plants would be expected to pose a more significant risk than the same water delivered via drip irrigation directly to the subsoil. It is also important to make sure the delivery systems; pipes, valves, sprinkler heads, filters, pumps and the storage areas for these pieces of equipment are all in good condition and not compromised so that they are not contaminated or could introduce pathogens themselves. Recently owing to suspected contamination issues with irrigation water, some commodity groups are mandating inspection protocols for water delivery systems prior to use as a mitigation step.

The challenges with postharvest water

Because postharvest water used in washing, cooling or transporting the crop contacts the surfaces and because these systems are in a continual flow, i.e. large volumes of crop move through these systems in between water changes, the chance for large-scale cross-contamination is significant. For example, if a field were harvested where only ten or twenty leaves of spinach were contaminated with Salmonella owing to bird droppings, as the leaves entered the wash water and the droppings containing the pathogen were rinsed into the water, the freed Salmonella cells in the water could contaminate thousands of uncontaminated leaves moving through the wash system over the next few hours. So, what was small contamination of only a few leaves becomes a much larger public health risk spread among a large volume of finished packages. That is why so much emphasis has been placed on postharvest water disinfection and management.

Some best practices to consider:

  • Know your water source. Characterize the water used in your wash, transport or cooling operations. Is it municipal water and therefore drinking water quality or is it from an open water source that is likely to be contaminated periodically?
  • Use properly managed water disinfectants. Choose a disinfectant that meets your systems requirements and monitor the concentration of the disinfectant continuously to avoid depletion and subsequent periods where the water might become a source of cross-contamination.
  • Validate and verify the disinfection of your water. You cannot add disinfectant and assume it will control pathogens in the water. It is important to prove what you are doing to control pathogens in the water is effective and defines the operating conditions for success. This is called validation. Thereafter, you must verify you’re your validated system is operating within the parameters. This is called verification. Verification is generally accomplished by measuring the water chemistry, e.g. disinfectant level, pH chemical oxygen demand or other factors.
  • Change the water. Over time, water that is in continuous use or in contact with large volumes of raw produce can change chemically and accumulate several organic compounds. These changes in chemistry often work against disinfectants, inactivating them; causing the system to fail to control microbial populations. Many operators choose to change the water periodically to prevent large organic loads from building up. The time it takes to change out water should be scheduled during the day as part of the operations of the plant.
  • Keep your systems cleaned and sanitized. Clean and sanitize dump tanks, flumes, wash tanks, and hydro-coolers daily. It is important to have a master sanitation schedule and standard sanitation operating procedures (SSOPs) in place to ensure efficient and effective and verified sanitation.
  • Perform regular inspection and maintenance of water systems. Equipment used to maintain your water quality like disinfectant injectors, filtration systems, and backflow devices should be well maintained to prevent contamination.


When developing a comprehensive, science and risk-based produce safety program, agricultural water uses must be a top priority. To find more information on ag water management and other aspects of produce safety programs, check out our Essentials of Produce Safety course. It’s your next step to better protecting your company against food safety incidents and building a brand customer’s trust. Alchemy Academy and the Produce Marketing Association (PMA) developed this course to help you explore all the facets that can impact the safety of your products.

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Use OSHA Best Practices to Prevent Chemical Catastrophe

Cue the stereotypical crime scene music. The toxicology is in. Oh, wait, the wrong kind? The National Institute of Environmental Health Services defines toxicology as a field of science that helps us understand the harmful effects that chemicals, substances, or situations, can have on people, animals, and the environment.

In the workplace, toxicology relates to chemical hazards and how you can protect yourself, your workers, and your facility from possible incidents. Let’s explore some of the things you can do to make sure that you have chemical safety in your workplace and minimize chemical exposure.

One of the most frequent OSHA citations in recent history has been related to the hazard communication standard or HAZCOM. HAZCOM specifies what we must do to keep employees informed and keep them safe from exposure in the workplace.

Ensure that chemical containers have labels and that the labels are not defaced.

All hazardous chemicals shipped after June 1, 2015, must be labeled with specified elements including pictograms, signal words and hazard, and precautionary statements. All of this information should be legible in order to be fully compliant. Labels are a brief way to convey a lot of the information that’s included on the SDS. The pictogram is a visual notation so anyone can quickly see any hazard of that product. Labels should also include a product identifier, which might include the product’s common name or chemical name. Be sure that the name on the label matches up with any SDS that might belong with it. Common audit and regulatory citations are due to chemicals not being properly labeled when they are transferred into secondary containers such as spray bottles or cleaning equipment containers such as foamers. It is critical that all containers with chemicals are properly identified with a label stating the name of the chemical in the container.

Designate someone to properly maintain SDSs.

Give someone the responsibility of keeping track of safety data sheets, or SDSs, from any chemical shipments that you receive. Thinking back to old labs, you might remember them as MSDSs, or Material Safety Data Sheets. Safety data sheets include critical information about the properties of the chemical as well as any hazards that might be associated with it. SDSs also include protective measures and safety precautions to keep in mind when handling, storing or transporting the chemical. The person assigned this duty should:

  • Maintain SDSs, making sure that you have the SDS for every specific chemical in the facility.

  • Obtain SDSs if they are somehow left out of the chemical shipment.

  • Make them accessible in the facility and well organized so they can easily be located in an emergency. Assure they are available in languages spoken in the facility so employees can understand them in their applicable language.

  • Train workers at least annually on the SDS format and use so all employees are able to use them if needed.
Train employees on hazardous chemicals in their work area.

Other than knowing how to read the SDS, employees should also be aware of any hazardous chemicals in their work area. Training should be done before employees work in that area, any time new hazards are introduced, and when they are performing non-routine tasks. Inform employees of methods and observations so they’re able to see when a chemical is present in their work area or when any chemical is released. Make sure they’re aware of any descriptions of the hazards as well as protective measures against them, including personal protective equipment. Also, train them on where and how to obtain additional information in case it’s needed. As always, training must be documented to prove it has been completed. HazCom Right To Know Training must be completed as part of new employee orientation programs as well.

Know the exceptions.

In certain cases, you might not need to follow the hazard communication standard. Sometimes, you might use household products the same way in the workplace as you would at home. If you’re not changing the use, you might not need an SDS for it. For example, if you use Windex to clean a mirror, you don’t need an SDS for it. If, however, you need a massive quantity of it to wash the side of the building, you will probably need one. Another instance of an exemption might be when an office worker uses a small bottle of correction fluid. Food, drugs, and cosmetics brought into the workplace for employee consumption are exempt, as well as rubbing alcohol or alcohol pads in a first aid kit.


By following these HAZCOM standards, you can ensure chemical safety in the workplace. The OSHA standards are in place to minimize chemical exposure and prevent accidents. By knowing which chemicals you have and use, as well as fully informing your employees, you minimize the risk of exposure. Keep these best practices in mind to comply with OSHA chemical safety regulations and protect yourself and your employees.

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How Root Cause Analysis Strengthens Your Production

Root Cause Analysis

Root Cause Analysis is a method used to find the source of a problem once a problem has already occurred. By identifying the underlying cause of any incident, you can further prevent future incidents from happening. Within Root Cause Analysis, two of the more common methods are the “5 Whys” method and the Ishikawa, or fishbone, Diagram. We’ll explore both of these methods and show how each method has its merits to food manufacturing and production facilities.

In order to perform a root cause analysis, you need to gather the facts and evidence for the issue that’s occurring.

  • What is the nonconformity? —Consider what is going on in your facility that needs to be addressed.

  • When did the nonconformity occur, and when was it discovered? —Identify the time period when the issue happened and take into consideration how much time passed between when it happened and when you realized it happened.

  • Are there any products or processes that may have been implicated? —Follow the incident to any later processes to discover what products may have been impacted as a result.

  • Has the immediate correction or corrective action been completed? —Even though you realized what happened, make sure that the immediate cause has been identified and corrected to prevent additional incidents or nonconformities.

Once you identify the root cause, it’s time to implement a proposed action plan. Outline who needs to do what in order to fix the nonconformity. There is no set way to discover the root cause, but let’s explore two of the more common, simple methods.

5 Whys

The 5 Whys is the method commonly used by facilities who are certified by GFSI standards. The 5 Whys method is more or less like a toddler—just keep asking, “Why?” until you get to your true “because.” The true definition is a bit less straightforward. It is “an iterative, interrogative technique used to explore the cause-and-effect relationships underlying a particular problem.” The 5 Whys method benefits companies because it encourages deeper probing. The whole point of this method is to keep asking why to find the source of the issue. By repeating this question, you go past the superficial answer. Unfortunately, the results of this method are not always repeatable. Depending on who is asking the question, you may get different causes. Also, this method relies on experienced staff to know which questions to ask.  

Ishikawa Method

When the “5 Whys” method is too basic, the Ishikawa method may be more appropriate. The Ishikawa method divides various root causes into categories (which are not predefined). From there, arrows indicate where causes can cascade into a nonconformance during the audit process. These diagrams were first used in 1968 by Kaoru Ishikawa. Causes act as a source of variation, which is then grouped into categories to identify and classify the sources.

In manufacturing, the Ishikawa method is also called the 5M Model:

  • Machine
  • Method
  • Material
  • Man
  • Measurement

For food, these have been transitioned to:

  • Equipment
  • Process
  • People
  • Materials
  • Environment
  • Management

The Ishikawa Diagram considers many factors that may have caused the initial problem by dividing the causes into finite categories within production.

Both the 5 Whys and Ishikawa methods are considered two of the more basic methods of root cause analysis. Even though they are considered basic, they still encourage you to keep searching for the initial cause of the incident or nonconformity that occurred. Alchemy Academy offers an online solution to your root cause analysis learning. Explore additional methods and find your answer to root cause analysis today.

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Addressing the 5 Dimensions of Food Safety Culture


Safety culture, more specifically food safety culture, has been a focus more and more in the workplace as a key factor in providing the best possible product for your consumers. The Global Food Safety Initiative, GFSI, wanted to develop a concrete definition for this term so they could have a clearer outline of what to address:

“A company’s food safety culture is the shared values, norms, and beliefs that affect mindsets and behaviors toward food safety in, across, and throughout the company.”

As with any process, there are different stages to make sure that you attain this concept. With food safety culture, GFSI expects that to fully internalize the concepts and have a solid grasp, it could take up to eight years depending on the size of the facility.

For a better understanding of what safety culture really is, Cultivate Food Safety worked with GFSI and companies across a variety of industries to divide it into five dimensions for a full picture.

#1 Vision & Mission

What message is leadership consistently sharing with employees in the organization?

Vision & Mission really amounts to the fact that positive practices start at the top and work their way down. Managers and others in leadership positions can affect a positive culture by setting expectations and priorities for food safety in the business strategy. Additionally, you can emphasize its importance by dedicating resources to help the food safety culture cause.

#2 People

What is the reward or recognition for exhibiting positive food safety culture attributes?

Where ‘Vision & Mission’ focuses on the top of your organization, ‘People’ focuses on the people behind the product. What management does to motivate those who implement daily processes can have an impact on how engrained food safety culture is within the organization.

  • Offer training to let employees know what to do.
  • Give incentives, rewards, or recognition for people who show these traits.
  • Establish an infrastructure of people at all levels who are passionate about food safety culture to act as influencers in your facility.

While this dimension stresses the positive, there should also be consequences for those who don’t follow best practices. Ideally, the rewards should outweigh the consequences, but you need both to make sure the culture sticks.

#3 Consistency

How do you document and hold people accountable for food safety measures?

To be truly effective with food safety culture, you need to be consistent with the rhythm you have for communicating results. Keep track of the consequences, both positive and negative, for every process you have in place. Hold workers accountable for their actions but remember that people respond better to positive reinforcement than negative.

#4 Hazards & Risk Awareness

What do you do to make sure that everyone is engaged, regardless of business size?

At times the food industry might face more challenges than other industries, in particular the issue of turnover. Having a successful food safety culture means that everyone is involved, despite a number of factors. There needs to be an awareness of the hazards and risks that are involved within specific roles and particular to the facility or product. In addition to the initial training, you need to make sure that employees retain the information.

#5 Adaptability

How do you respond in times of crisis and are you able to respond quickly?

There are many change-management tools to help businesses of all sizes to be agile in dealing with crises. Additionally, we have to consider expectations and regulations and fit the culture to these ideals. Cultural implications might also come up in this dimension. Importing and exporting can change the lens with which we need to view our product and the safety culture behind it.

Because of evolving science and industry, we need to be able to problem-solve and update our internal culture to match external expectations. Using managers to support their team members can help affect change quickly. In a recent survey, 43.2% of supervisors reported that they rarely or never receive coaching from managers. Keeping your managers as a resource trickles down and impacts workers at all levels.

These five cultural dimensions work together to form a mindset of food safety culture. Driving these behaviors can be a lengthy process, but it really is important to your facility’s success. You might hit roadblocks along the way because people’s individual experiences can create challenges with truly internalizing this mindset. By keeping a consistent commitment to it throughout the organization, you can help you bring the importance of food safety culture to life. Reinforce your commitment by using tools to increase worker confidence in your food safety’s daily implementation. By using your resources to support your employees, recognizing their success, and keeping a consistent message of food safety culture’s importance, you drastically improve your chances for long-term success.

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The 5 Essential Steps to Creating Your EMP


You don’t have to be in the food industry to be aware of recalls that happen, seemingly more and more. Every day people are aware of listeria and E. coli that might have never heard of it forty years ago. How do we protect our products and keep from having to recall? Environmental monitoring (EM) is an important way to identify things that might harm your consumers. It’s a part of many different regulatory requirements, but it’s also the best manner of checking that your cleaning has been effective and keeping disease out. The food industry considers Environmental Monitoring Programs (EMPs) as a control in your facility, but there’s a clear outline of how to best set them up.

Step 1: Conduct a risk assessment

Get a group of employees together to do a risk assessment that are subject matter experts in different areas in your facility—managers or scientific experts who know different sides of production. There are different ways to do a risk assessment and gather information. If you’re not comfortable with doing this on your own, consultants can be helpful.

Risk assessments have to be unique to each facility and make sure to consider the following:

  • the types of products produced

  • regulatory requirements

  • known hazards

Step 2: Identify your sanitary zones

Different regulations require various sanitary zones to be tested for EMPs. For example, USDA requires that you test zone one (it’s also recommended by some customers). Zone one is anything that is a product contact surface– filler nozzle, tanks, conveyor belts, employee hands, product contact utensils, and worktables. FDA facilities focus on zone two and three, which are non-food contact surfaces close to food and non-food contact surfaces. Zone three is more remote non-food contact surfaces. Outline these zones so you can tell where you need to focus your sampling program.

3: Decide on sampling sites in your sanitary zones

Make a spreadsheet to keep track of where the sampling sites are. Keep separate sheets for the different zones so you do the appropriate number of tests for the correct zones. As a general guideline, the FDA recommends 10 to 15 sites for zones two and three with tests completed weekly. Depending on the risk and your trend analysis of results, you might want to adjust how frequently you test and how many sites you test.

Step 4: Determine which bacteria to test for

Different tests offer information on a broad spectrum of pathogens. You can use recall data to find which bacteria might typically be present in similar requirements. Testing requirements vary from zone to zone. Even if it’s not a requirement, it’s usually a good idea to test for general cleanliness in zone 1. Testing for APC (aerobic plate count) or ATP (adenosine triphosphate) will check the microbial load in these areas. Zones 2 to 4 run a risk for listeria or salmonella species, which will use different tests than zone 1. Additionally, consider which ingredients you use when determining the tests to run. Eggs, for example, might have a higher likelihood of salmonella, but their risk might vary depending on pasteurization.

Step 5: Set your testing frequency

Once you establish the zones, sampling sites, and bacteria you want to test for, you need to determine how frequently you will run the tests. Depending on need, you should run tests anywhere from weekly to monthly. If a ready-to-eat food doesn’t support Listeria monocytogenes growth, then you would usually test this monthly. FDA guidelines outline the testing schedule in a straightforward way:

Zone 1: If needed, then weekly Zone 2: Every week
Zone 3: Every 2 weeks
Zone 4: Monthly

USDA uses a prescriptive formula to determine how often sites should be tested which can be found in their resources. No matter your guidelines, make sure you record all of your processes to complete your Environmental Monitoring Program. As you gather more information, if you notice increased positives then you might need to adjust your frequency.

You also have to determine the number of sites to be tested at the specified time intervals. The quantity should be at least consistent with regulatory guidance documents. It may also be determined by risk assessment after determining the total number of sites to be sampled in each zone. For example, if you identified 20 potential sampling sites in a zone, you want to consider taking 5 samples per week to assure all sites area sampled within a one month period.


Environmental Monitoring and Environmental Monitoring Programs can seem intimidating if you’re just beginning the process. Making sure you follow all the rules and adhere to USDA, FDA, GFSI, and customer requirements is an ongoing process. With training and other resources, you can establish an EMP and set your facility up for success. Documenting your process and keeping track of your results can prevent incidents in your company that might lead to recalls or foodborne illness outbreaks.

Alchemy Academy’s Solution

To get more information about EMPs, Alchemy Academy has a fully online course that helps you set up your facility for success. Learn how to set up your program, perform risk assessments and test, and manage your results. We also review software options that are available to help make running your EMP easier. Our EMP template package gives you additional resources to get you on the right track.

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Your 5 Workers’ Rights Through OSHA


Even though worker injuries and fatalities have decreased, the food industry is statistically more likely to experience either of these. As a leader in your company, you can directly affect the safety of everyone in your facility. Keeping your employees safe and helping them be aware of their rights can help you build a stronger relationship with them, too. The Occupational Safety and Health Act of 1970 started a movement to protect workers when they’re at work. We spend so much time there, so it’s important that everyone feels safe. This law makes sure that companies think of how they can keep their workers well and out of harm’s way.

What is OSHA?

Signed into law in December of 1970, the Occupational Safety and Health Administration (OSHA) is a part of the U.S. Department of Labor. It’s a continuous work-in-progress meant to keep workers safe while at work. OSHA works to make sure that workplaces have and enforce standards, plus give enough training and education to people at work.

What is the General Duty Clause?

The General Duty Clause is brief but has several parts. Part (a) has to do with the employer and part (b) has to do with employees. Each part basically says that both employers and employees will do what the OSH Act outlines to keep everyone safe from recognized hazards at work.

Who does OSHA protect?

OSHA was made to protect people at work. Workers’ rights are outlined in the OSHA documentation as five separate items. OSHA protects workers by giving them the right to the following:

  1. A safe and healthful workplace
    At your workplace, employees shouldn’t have to work around serious hazards. Having a pivotal role in your workers’ welfare, you should do whatever you can to keep risks at a minimum. If there is any way to do work-related tasks in a less hazardous way, that should be the usual way, even if it’s less efficient. You should also be sure to notify employees if they’ve been exposed to hazardous chemicals. If there’s any chance that they may develop an illness due to being exposed to these chemicals, they have a right to know. If you can’t offer a safer solution to a risky task, providing Personal Protective Equipment is helpful, but not the first choice for keeping your employees safe.
  2. Complain or request corrections
    If an employee sees something that could be unsafe or unhealthful, they have the right to say something about it. OSHA works to make sure that employees don’t have to be scared of a company getting back at them if they report dangerous conditions. They should feel comfortable saying what could be done better to make work safer, plus be able to find out what is done about it. Complaints can also be anonymous, making reporting less intimidating.
  3. Information on injuries and illnesses.
    The OSHA 300 log goes hand in hand with this right. It’s an annually posted summary of any injuries or illnesses related to a facility. The recordkeeping rule is for employers with more than ten workers but is really recommended for all employers. This rule gives everyone a clear idea of how safe their workplace is. Keeping written logs of any related illness or injury helps you create a more open dialog with your employees.
  4. Receive training from employers
    When you work somewhere, you have the right to learn how you can keep yourself safe. As a leader in your facility, you should offer enough training to let workers do their job in the safest way possible. All of the training should also be easy enough to understand and in different languages, so no one misses out in the translation.
  5. Participate in OSHA inspections
    If there are any concerns, employees can also walk along during the inspection and point any concerns out. Inspectors might not have a full grasp of where things might go wrong, and this right just means that they can show where it did (or even almost did.) Their perspective might give the inspector an insight to point out how the facility can be safer for everyone.

While this is just a brief summary of what OSHA does, its purpose is driven by getting people home safe from work. Safety training, including OSHA training, is just one way to improve the workplace. Giving people a secure environment to work in makes it easier to have satisfaction at their job.

Workplace Safety Culture

Every company has a Workplace Safety Culture, whether it be good or bad. A good culture results when a company demonstrates its commitment to provide a safe workplace for employees and when employees demonstrate their commitment to practice safe work habits. The company should have well defined and implemented safety programs, accident and near-miss investigation processes, adequate machine guarding and effective training programs. Employees should take personal responsibility for their safety and those around them.

What’s your food safety culture like? Alchemy EHS Consultants can help you comply and improve to keep your employees safe, reduce potential OSHA fines and reduce workers’ compensation costs

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Your Defense Against Intentional Adulteration


The idea of contaminated food brings up images of court jesters doing taste tests to make sure that kings and queens aren’t poisoned. Stories of intentional adulteration go back hundreds of years. People have to eat, and some people have hateful intentions. So, what can we do to keep these people from succeeding? It’s no longer just people in positions of power who need to be concerned with food fraud. Using strong food defense methods helps you back your brand and comply with FSMA’s Intentional Adulteration (IA) Rule. Some IA deadlines have already passed, and enforcement inspections start as soon as March 2020.

What is the Intentional Adulteration (IA) Rule?

Intentional Adulteration was the last of the seven foundational rules that came from the Food Safety Modernization Act. The IA Rule was proposed in late December of 2013 but was finalized on May 27, 2016. This rule created requirements to prevent (or at least minimize) acts meant to cause broad public health harm. Congress and the FDA scoped the rule so that it affects the weakest points of the food supply chain.

Who does it cover?

Facilities that manufacture, process, pack, or hold human food are covered by the IA rule—so if you have to register with the FDA under section 415 of the Food, Drug, and Cosmetic Act, the IA Rule applies to you. Intentional Adulteration applies to both domestic and imported food. Retail food and farms aren’t covered, and there are exemptions for very small businesses and some others as well.

What does it mean to me?

Food defense plans and training are both required for the Intentional Adulteration. Food defense plans are made up of six parts:

  1. Vulnerability assessment—used to find the points with the highest risk for intentional adulteration
  2. Mitigation strategies—measures to minimize or prevent vulnerabilities at each actionable process step
  3. Procedures for food defense monitoring—documented steps and frequency to monitor mitigation strategies
  4. Food defense corrective action procedures—written outline for steps to take when mitigation strategies aren’t put in place properly
  5. Food defense verification procedures—what is done to make sure that monitoring, corrective actions, and mitigation strategies are done properly
  6. Records—documentation to show that all of the procedures from the other parts of the food defense plan were fully and accurately completed

Food Defense Dynamics

Food defense threats have three different factors: motivation, capability, and vulnerability. Motivation accounts for the reason someone would purposely tamper with food. Capability is someone’s power to commit the crime. That includes what was used and how they did it. Vulnerability is how likely is someone to be successful at corrupting the food. What all has been put in place to prevent outside influence? Successful food defense plans consider in what areas are vulnerabilities likely to exist and how can people take advantage of these.

The three most common motivators are economically motivated adulteration, also known as “EMA”, terrorism, and sabotage. Economically Motivated Adulteration is sometimes called food fraud. EMA is something done to have a monetary gain or economic upper hand or get around trade policies. Terrorism involves people who target the food system to either cause fear, public health harm or social and economic disruption. The target of sabotage is the company more than the public. Sabotage would be when a disgruntled employee, consumer, or competitor wants to damage the brand. This can be a bit more difficult to pinpoint since a lot of times it’s done by someone who knows the business well.

Protecting your food from intentional adulteration is important to your business’s success, even if you don’t produce high-risk foods. Whether or not you fall into the IA Rule category, keep in mind how you can avoid incidents and save yourself money and hassle, plus protect your most valuable asset—your customers. Learn how you can protect your facility with Alchemy Academy. Our Food Defense Supervisor Awareness course is fully online and helps you get a better understanding of what to think about when securing your products.