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Food Safety, Security, and Defense in the COVID-19 Pandemic

food safety

As COVID-19 cases soar across the country again, we’re reminded not only of the impacts pandemics can have on the healthcare system but also on the food industry as a whole. “At the very beginning of the pandemic, there was this sense that there would be short-term lockdowns and restrictions. People treated the pandemic much like they would a severe weather event – make a run to the grocery store, we’ll be home for a few weeks then everything will go back to normal,” says Dr. Jennifer van de Ligt, Director of the Food Protection and Defense Institute at the University of Minnesota. “That challenged the food industry. At the same time, people were preparing to stay home, restaurants, and others eat away from home venues closed. This meant that the amount of food people were consuming in those venues had to be available for home preparation. This may it difficult to resupply retail outlets with shelf staples at the rate they were being consumed. It wasn’t a food shortage — it was a food distribution system disruption that placed a great deal of stress on supply chains as it shifted from a split of foodservice and retail supply to almost exclusively retail supply for a period of time.”

Of course, the food industry adapted. Today, the ability to supply our retail sector has enormously improved. “Overall, the food industry as a whole has done an amazing job. They have been incredibly resilient in the face of the pandemic. They’ve learned. They’ve adapted. They’ve found new ways to manage ingredient shortages, distribution disruptions, and worker health and wellness.” But the food supply chain’s pandemic preparedness and its ability to prove resilient doesn’t end there. Instead, it lies in an integrated approach to food safety, food security, and food defense.

Food Safety

The ties between a pandemic brought about by a foodborne illness and food safety are apparent, but the most difficult challenge facing the industry today is worker health. The well-being of the food industry’s workforce is a central part of its food safety plan. Within it, procedures are implemented to ensure the production of safe food for consumption. While businesses have always considered how to keep workers from contaminating food, the pandemic has forced companies to take a closer look at worker health and craft different mitigation strategies to this end.

Food Security

Food security is the state of having reliable access to a sufficient quantity of safe, affordable, nutritious food. As the food supply chain becomes more agile in adapting to the pandemic, a return to normalcy around food security occurs. However, as of October 2020, AAMC reports that 54 million American consumers still face food insecurity[1]. In the face of this uncertainty, customers moved from purchasing perishables, like fruits and vegetables, to shelf-stable items. This negatively impacts sales of manufacturers and, perhaps most notably, the produce industry.

Food Defense

While food defense focuses on preventing acts of intentional adulteration that could cause widespread public health-harm, there are lessons from the pandemic that serve your food defense system well. Companies must reevaluate their food defense plan and vulnerability assessment practices to incorporate any operational practices that have changed during the pandemic. Food defense is a part of the entire food supply chain necessary to assure safe, healthy food for all.

Successful Strategies for Operating in the COVID-19 Pandemic

Your companies particular experience during the pandemic and the changes you implement may differ from your peers. Still, there are a handful of successful strategies you can employ to promote sustainability. “The companies I’ve seen that are most successful are those that are open, listen to new ideas, take in the best science available, and create ways to work within this new structure of the pandemic,” says Dr. van de Ligt. “They have prioritized the health of their workforce. They communicate well to their workers about what they’re doing and how they’re helping workers stay healthy.”

“Another strategy for success is being willing to try new things, to think outside the box,” she continues, “Saying, ‘we used to do it this way’ is likely not the best approach in an evolving pandemic. Successful businesses have shown that they’re adaptive and resilient.”

As for unsuccessful strategies? “Companies who believe they can hunker down and wait out the pandemic so they can return to normal might not be the best approach. The way the food industry looks post-pandemic conditions will not be the way it looked pre-pandemic. There have been too many changes in the way we operate and communicate with both our workforce and our consumers in both retail and foodservice locations.”

Conclusion and Resources

The food industry will continue to evolve and see change. Food safety, food security, and food defense are integral parts of keeping our food supply chain healthy and operating. A comprehensive, holistic approach to all three, coupled with a willingness to change, can ensure your business’s survival and success beyond the COVID-19 pandemic.

To learn more about creating, improving, and implementing food defense systems, consider Alchemy Academy’s exclusive course library. Developed in partnership with the FPDI of the University of Minnesota, these courses offer flexible food defense training for frontline workers, managers, and supervisors.


[1] https://www.aamc.org/news-insights/54-million-people-america-face-food-insecurity-during-pandemic-it-could-have-dire-consequences-their

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How To Perform Effective Internal Audits

Internal Audit

The best preparation for an external audit is perfecting your internal audit processes. While each facility’s procedures will be unique to its operation and products, you can apply the following internal audit process best practices to perform and evaluate effective assessments in your facility.

Initiate the Internal Audit Process

With your audit schedule complete, it’s time to begin the internal audit process. The lead auditor will call for the audit and identify what team members are appropriate and necessary for the audit in question. At a minimum, an audit team for departmental audits (like GMP audits) should include representatives from Operations, Quality Assurance, Maintenance, and Sanitation departments if available. Single individuals may perform other types of GFSI system audits, but this is up to the lead auditor’s discretion.

With the internal audit team assigned, you must define the audit, objectives, scope, and criteria. Consider:

  • What type of audit will your team conduct? Is it against a specific standard?
  • Will the internal audit include departments or the entire company? A specific product? An individual process? Your facility as a whole?
  • What is the expected duration of the audit? How much time should your team and the auditee set aside?
  • How should the audit results be documented?

Schedule the Audit

Next, determine the feasibility of your audit. Consider the time and resources available to you in terms of both your audit team and the auditee. Choose a time that is mutually acceptable for all parties. Keep in mind your audit team should be independent from the area being audited.

Inform the auditee(s) of the date, time, scope, and team members selected to complete the audit. The exception to this rule is the unannounced audit. A company may choose to conduct an unannounced audit to have a more accurate representation of what’s happening in a plant without any advanced preparation.

Documentation Review

Once initiated and scheduled, your audit team should complete a documentation review. This helps your team understand the requirements of all major programs undergoing the audit, so that they know what to look for and may verify these programs with confidence. The internal audit team should also examine previous audit records to refresh their memory of any non-conformities needing reinspection.

Create the Internal Audit Plan

How will you allocate your time between defining the scope, reviewing documentation, performing the audit, and recording results? This responsibility once again falls to the lead food safety auditor. An integral part of assembling the audit plan is preparing any documents your team may use to complete the internal audit process, such as checklists. This checklist streamlines and safeguards the internal audit process.

Perform the Audit

Your on-site internal audit activities need to begin with an opening meeting. Include the members of the internal audit team and representatives of the auditee so that they may become familiar with and agree to the audit scope. Be upfront about the communication process required during the audit process. Will you need to interview employees? What types of questions will you ask?

A third-party audit opening meeting should include members of all departments undergoing audit. During the audit, the auditor should have an escort around the facility to ensure everyone’s safety.

Now, the rubber meets the road – your audit begins, and the internal audit team must collect and verify the necessary information as indicated by their checklists. Internal audit best practices dictate direct observation as an integral part of the audit process. Direct observations make sure employees follow programs exactly as they’re written.  Current records in progress may also be part of the audit to assure they are being completed in a timely and accurate manner.

Generate Audit Findings

Next, you’ll generate audit findings. This is a summary of your observations – both areas of compliance and nonconformities. For the latter, you must designate a classification: Are these minor, major, or critical? These classifications should be communicated to the auditee by the end of the audit.

Conduct Closing Meeting

Prepare your audit conclusions with an eye on what you will share during the closing meeting. Always begin this meeting by pointing out the positives. Thank the auditee for their time, and the courtesies extended to the audit team. Call out good practices in employee training, GMP compliance, sanitation, maintenance, and so on. From here, discuss the details of any non-conformities. Explain the standard that stemmed the issue, the objective evidence found, and what evidence the auditee should submit to verify its corrective actions.

Prepare the Internal Audit Report

The internal audit report may be done on or offsite. The format of this document is flexible to the type of audit performed. The auditee, senior management, and consumers may have access to this report, and so it must prove accurate, complete, and concise. The internal audit report should include a conclusion section, identify the total number of non-conformances in conjunction with some rating for a score or grade. 

Once complete, the lead auditor should perform a technical review. For third-party audits, this is done by a certification body. Issue the report within an agreed-upon amount of time, typically within seven days.

Conclusion

Internal audit best practices help ensure the process goes smoothly for all involved and leads to continuous improvement. By following the outline above, your internal audit team will perform an effective internal audit assessment that fulfills your audit schedule’s demands and ensures successful external audits.

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5 Tactics for Managing Regulatory Compliance

Regulatory Compliance

Beyond maintaining regulatory compliance, effectively regulatory change management is critical to your food production and manufacturing business’s success and sustainability. Of course, the implementation process provides its own set of challenges depending on the company size, industry, breadth of regulatory guidelines, and so much more. However, companies can utilize an integrated approach to help plan, implement, and monitor new regulations and revisions.

Monitor the Regulatory Environment

To begin, gather timely and accurate information on the regulatory environment. Is there a single source of data from the regulator containing tracked updates? If so, this guidance will be a vital source for your business’ implementation timeline.

An excellent resource for helping to source and interpret information related to regulatory changes is events put on by regulators and training partners. For example, Alchemy Academy has partnered with SQFI to put on a live Conversion Primer for Edition 9 code changes.

Identify Relevant Regulatory Changes for Compliance

Next, you’ll need to summarize, analyze, and classify changes as relevant to your organization. Having this information in plain language will help you quickly and efficiently perform impact and threat assessments.

Perform an Impact and Threat Assessment

Now, you’ll need to determine which employees the regulatory changes affect. What internal policies govern their work? Will changing these processes impact any legal requirements? Determine the practical impact of regulatory changes on everyday tasks to avoid bottlenecks and audit non-conformances later on.

Provide Training

Communicate the planned changes to affected employees, i.e., those carrying out the regulatory change. Provide them with adequate training and context on adapted processes, policies, and procedures. This may require multiple and consistent refreshers.

Deploy Changes and Produce Reports

Finally, deploy the changes to processes, policies, and procedures in your organization. Of course, you’ll need to demonstrate how your facility conforms to new regulations. Reports should provide insight into the current state of change management, action items by priority, and any hazard or risk assessments.

Conclusion

These change management tactics come together to ensure a smooth transition in your facility and continued regulatory compliance within your industry. To learn more about resources for SQF Edition 9 compliance, consider Alchemy Academy and SQFI’s live Conversion Primer

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Introducing Academy Live: Alchemy’s New Virtual Roundtable

Academy Live

With face-to-face training and consulting harder than ever, we’re introducing a next-level Livestream to the market: Academy Live. Crafted with the new state of professional growth in mind, these 60-minute sessions allow participants located anywhere in the world direct and instant access to an industry expert and each other. The goal? To help food manufacturing professionals and beyond get real-life answers to the everyday issues their textbooks don’t address and achieve their professional development goals.

The Gist

Academy Live utilizes an intimate, time-efficient roundtable approach to cutting-edge educational sessions. Broken out into dedicated spaces for the content presentation from an industry expert and a live Q&A, participants connect, learn, and have their unique process questions answered – all within minutes. Register like you would for any other Alchemy Academy online training course.

The First Academy Live

Topic: Top 10 Audit Non-Conformances

Date: November 10, 2020

Time: 12pm-1pm CT

Improve your audit score with direct guidance from members of The Alchemy Consulting Team. The first Academy Live session takes a magnifying glass to the Top 10 Audit Non-Conformances across a variety of systems, uncovering what exactly auditors look for when they enter your facility and the special precautions your company needs to take to achieve its best score yet. Sign up today to guarantee your seat and meet your professional development goals.

Future Sessions

Academy Live: SQF Edition 9

Discover and discuss the most frequently cited FDA standards and potential penalties.

Academy Live: Top 10 FDA Regulatory Violations

Strategize your rollout of SQF Edition 9 and have your specific questions answered by an authority on SQF Code.

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COVID-19 Safety Protocols: Managing Hotel and Restaurant Suppliers

COVID Safety Protocols

Your hospitality business is once again open. Are your pandemic safety protocols far-reaching and evolving? Just as the hospitality industry must successfully manage infection transmission amongst staff and guests, so too must they not forget managing risk associated with hotel and restaurant suppliers and third parties. These entities pose a threat to your business via the goods and services relied upon for operation.

When it comes down to it, this risk amounts to three pieces of prevention: procurement, transporting, and receiving.

Hospitality Suppliers Management: Procurement

Beyond ensuring the goods and services purchased for your hotel or restaurant come from hospitality suppliers included on your list of approved suppliers, you must verify these companies have altered working practices to reflect the new requirement for increased infectious disease prevention. Remember, this may lead to delays and restrictions on product availability and must be factored into your purchasing timeline.

Hospitality Suppliers Management: Transporting

Similarly, the transportation process needs to maintain the safety of products on their way to your facility. How can you do this? As you review the infection control measures put in place by the supplier, ensure that they include effective and hygiene and disinfection protocols for vehicles, drivers, and packaging materials.

Hospitality Suppliers Management: Receiving

At this point, the third-party or supplier will directly interact with your staff. Thus, they should maintain the same level of hygiene protocols expected of your own team. Provide drivers with instructions on what safety and hygiene procedures to follow, such as social distancing, hand washing, and mask-wearing. Where possible, design the interaction to be as contactless as possible. To do this, communicate delivery notes and invoices electronically rather than in paper form.

Conclusion

Keeping your employees, your guests and your brand safe and healthy requires buy-in at every point in your operation. By following these simple protocols for procurement, transport, and receiving, your hotel or restaurant supply is one step closer to an effective POSI management program. To learn more about developing a robust infection control program that touches all parts of your business, consider our Hospitality Management Principles course.

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Five Core Benefits of PCQI Training

PCQI Training

The Food Safety Modernization Act’s (FSMA) Preventive Controls for Human Food Rule requires every food manufacturing facility to employ a Preventive Controls Qualified Individual as part of their food safety team. This person is a key component to a company’s food safety program, carrying out specific, crucial responsibilities as dictated by the regulatory body. These include tasks like developing, implementing and reassessing a Food Safety Plan.

While individuals can achieve PCQI status as a result of adequate job experience, relying on this tenure alone can and will leave your team falling short. Only formal risk-based PCQI training based on the FDA recognized standardized curriculum can effectively and properly equip individuals to understand the latest regulations and Food Safety Plan requirements. Keep reading to discover five core benefits of PCQI training.

PCQI Training Benefits

Grasp and Monitor Federal Regulations

A thorough understanding of evolving food regulations is paramount to ensuring compliance for your facility and guaranteeing your products’ safety for consumers. Alchemy Academy’s PCQI training courses break down federal regulations so that you not only ascertain how to comply with each standard but walk away with an appreciation for the value of PCQI responsibilities.

Master Hazard Analysis and Preventive Control Measures

PCQI training builds on food manufacturing professionals’ fundamental knowledge of food safety hazards and discusses the underlying principles of crafting a food safety preventive controls system. By getting to know the motivations behind food hazards, learning the process of hazard analysis, and exploring how to apply preventive control principles, future PCQIs better understand how a systematic approach helps assure safe food for consumption.

Develop an Effective Food Safety Plan

With new learnings in place, PCQI training takes a hands-on approach and walks participants step by step through building a Food Safety Plan, including identifying tools and implementation tasks. What’s more, participants of Alchemy’s PCQI training walk away with manuals, workbooks, templates, and more to help perfect their Food Safety Plan. We also discuss when to perform reanalysis to help assure you sustain a successful food safety system.

Understand the Importance of Record-Keeping Procedures

The importance of establishing and carrying out proper record-keeping procedures in a timely, complete, and true fashion cannot be overstated. PCQI training lays the groundwork for this practice, demonstrating the proper record keeping and record review systems relevant to your operation’s Food Safety Plan.

Get Direct Guidance from an FSPCA Lead Instructor

Leverage the expertise of Intertek Alchemy’s Consulting team with instruction and guidance from two of our FSPCA lead instructors. These instructors boast decades of experience and have completed robust training to provide you with the tools and resources you need to become a competent and confident PCQI.

Conclusion

When it comes to developing your company’s Food Safety Plan and cultivating a food safety culture, the benefits of PCQI training are crystal clear. Without formal training, the process takes longer, proves more arduous, and leaves your company open to vulnerabilities and non-conformities.

Take a closer look at PCQI training with Alchemy Academy’s blended eLearning resource. Taught by an FSPCA Lead Instructor, you’ll unlock the benefits mentioned above and more.  Our course combines the benefits of a self-paced eLearning environment with a live virtual instructor-led session to ensure you walk away with a comprehensive and complete understanding of the new FSMA requirements.

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Easy As P.I.E: The Keys to Kosher Beverage Production

kosher_beverage

What makes a beverage kosher? The answer begins with a discussion of where and how kosher production impacts your beverage plant. It may sound complicated at first, but we can sum up the basics of kosher production with the acronym P.I.E.: Process, Ingredients, and Equipment. This blog touches on the processes, ingredients, and equipment particular to a kosher
beverage facility.

Principles of Kosher Beverage Production

Kosher Production Processes

The first major piece of P.I.E. is Process. While several manufacturing processes are vital to kosher production, we’ll focus on a critical aspect of kosher beverage processes: the introduction of heat. This includes pasteurization, the most heat-intensive part of the kosher production process.

To begin, before scaling and batching, you must make sure to flush any residue from previous batches out of your equipment. If the product is pareve, the dairy residue must not be present. If the product is kosher, make sure no non-kosher residue is present.

After this step comes pasteurization, the single most kosher-sensitive part of beverage production. Whether your plant is hot-fill or cold-fill, the path a product takes through this system, and its heat source, have an enormous impact on kosher production. Your certifying agency will assess your plant’s configuration to help you identify processes that cause or may cause kosher concerns.

Kosher Beverage Ingredients

As expected, kosher beverage production also has unique ingredient concerns. Many common ingredients in commercial beverage production pose potential problems for your plant.

The most prominent ingredient concern in kosher beverages is grape. This includes grape concentrate, grape essence, grape flavor, and raising products. Why does grape pose such a problem to manufacturing facilities? Aren’t all grapes kosher? The answer, of course, is yes. However, what a facility does to that grape (its process) impacts kosher status. A vital component of this kosher-sensitivity is that grape juice is, in essence, wine. Wine’s religious significance requires precise handling rules.

Next, flavors – whether natural or artificial – serve as the building blocks of the beverage industry. They are, after all, what differentiates one product from another. When it comes to kosher, flavor can never be considered insignificant. As such, flavors for kosher beverage production must come from a reliable flavor house and be kosher certified. Liquid and powdered flavors each have unique kosher concerns. Consult with your certifying agency before you order.

Other kosher-sensitive ingredients include milk proteins, shellfish, gelatin, preservatives, and coloring. Each of these poses potential problems for pareve and equipment in your kosher beverage production.

Kosher Production Equipment

Finally, let’s take a look at the role equipment can play on your beverage plant’s kosher status. A crucial part of separating non-kosher and kosher products, a key tenant of kosher law, involves taking immense care of your equipment. Each product your run affects the equipment itself and that equipment can then affect future products. If you run dairy products, you cannot then run pareve on that same equipment. Likewise, if you run non-kosher, you cannot then run kosher.

Dedicating equipment to a single category can help you maintain this separation. Always remember that even if your equipment is dedicated, it can still be problematic if it’s considered compatible. Equipment is compatible when it looks, operates, or functions the same for kosher and non-kosher products, or dairy and pareve.

In most cases, dedicating equipment and eliminating compatibility isn’t practical. As a result, your equipment will require regular kosherizations. Take a closer look at the kosherization process in our online kosher beverage production course.

Conclusion

While kosher beverage production principles can seem complicated at first, boiling them down piece by piece can help your business approach kosher and succeed in the certification process. With the right processes, ingredients, and equipment in place, you have the tools to maximize your kosher production potential.

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How to Meet Regulatory Requirements for HACCP

HACCP

HACCP plans are the backbone of your food safety system. Built from the seven HACCP principles, these plans are mandated by regulatory bodies for the meat industry, the juice industry, and the seafood industry. In order to ensure a safe food supply, safeguard your product, and protect your brand, you’ll need to be compliant with both regulations and customer expectations.

In this blog, you’ll learn about the current status of USDA and FDA regulations for HACCP and what you need to do to comply with each.

USDA/FSIS HACCP Regulations

USDA regulations for HACCP are twofold. First, an establishment must have a written HACCP plan that includes a documented Hazard Analysis and the identification of Critical Control Points as applicable to the products. For these CCPs, a facility must identify and document critical limits, monitoring, corrective actions, verification procedures and record keeping requirements. It is normally recommended every facility should have at least one CCP identified and more as needed dependent on the results of the hazard analysis and the types of products made.

Second, the USDA requires an establishment to operate per the requirements of their HACCP plan. If you fail to meet either of these provisions, your products may be considered adulterated.

In addition, USDA may deem a HACCP system inadequate if:

  1. The HACCP plan in operation does not meet the operations outlined in Part 417 of CFR 9. Section 417.6 (a)
  2. Establishment personnel are not performing tasks specified in the HACCP Plan 417.6 (b)
  3. The establishment fails to take corrective actions, as required by section 417.6 (c)
  4. HACCP records are not maintained as required in section 417.5 or Section 417.6 (d)
  5. Adulterated product is produced or shipped. Section 417.6 (e)

For a more in-depth look at these five scenarios and how to avoid them, consult our Basic HACCP online course.

Regulatory Updates

Under the USDA, not only will you have to validate your HACCP system itself, you must validate prerequisite programs, CCP limits, and critical operational parameters for anything that has an impact on food safety, such as sanitation. Critical operational parameters could include factors like the concentration of antimicrobial lactic acid mixes or the temperature at which such a mixture is applied to a meat product.

There are two elements to keep in mind when you perform these validations, in USDA inspected establishments. The first requires scientific documentation or literature that validates the limits you chose as sufficient. The second requires in-plant validation data to prove that processes are successful. These theoretical and application elements come together for an all-encompassing validation methodology.

FDA mandates HACCP regulations for the seafood industry and juice industry. FDA also requires validation of critical limits associated with critical control points. Supporting documentation such as regulatory references, scientific studies and/or internal plant validation must be on file to validate critical limits.

FSMA Regulations

The Food Safety Modernization Act was the most sweeping reform in food safety laws in more than 70 years. Signed into law on January 4, 2011, it aims to assure the US food supply is safe by shifting the focus from responding to contamination to preventing contamination. There are seven laws associated with FSMA regulations in total that promote a proactive approach to food manufacturing.

The FSMA Preventive Control for Human Food Rule requires a food safety plan is written and implemented by a PCQI. To learn more about the responsibilities of a PCQI and the road to certification, consider Alchemy Academy’s blended PCQI certification course.

Under the FSMA Preventive Controls rule, the food safety plan must contain as appliable to the operation:

  1. Written Hazard Analysis for all operations
  2. Preventive Controls as applicable
  3. Supplier Programs if applicable
  4. Recall Programs if a hazard requiring a preventive control is identified
  5. Procedures for Monitoring Implementation of Preventive Controls
  6. Corrective Action Procedures
  7. Verification Procedures

Get further guidance on fulfilling FSMA regulations for documentation with Alchemy Academy’s comprehensive package of applicable logs, templates, and case studies.

Alchemy Academy HACCP Plan Resources

USDA and FDA each require manufacturing and production facilities to meet stringent regulations for HACCP or Preventive Controls as applicable. Take a deeper dive into these regulations, as well as how to build, implement, and manage your HACCP plan with our Advanced HACCP eLearning course – the only accredited online Advanced HACCP training solution on the market.

Not sure where to begin with food safety training or how to progress past HACCP? Consider Alchemy Academy’s new course catalog for food manufacturing professionals.

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Your Guide to Building an Effective OHS Program

OHS Program

Taking a proactive approach with an OHS program is crucial to the prevention of incidents in your facility. Not sure where to begin? By following OSHA recommended safety practices it’s easy to break down the process into manageable stages.

Keep reading to discover 4 steps to planning and implementing your introductory OHS program.

Identify Potential Hazards in Your Facility

The first step in creating any occupational health and program is to inspect your workplace for health and safety hazards, and identify the related risks. Get people involved in your regular inspections of all operations, equipment, plant vehicles, and work areas. More buy-in from your team now results in more effective processes later on.

Always remember to document these inspections to later verify corrective actions. If company policy allows, take pictures and videos. A picture is worth a thousand words!

In addition to the inspections above, you should also conduct and document incident investigations. This includes close calls and near misses, such as instances in which someone could have fallen ill or sustained injury. Treat these incidents seriously to determine and correct for their root causes. Remember, operator error is never a root cause.

Lastly, identify any foreseeable emergency scenarios in routine and non-routine tasks. Consider your operation’s context including activities in the neighborhood of your facility. For example, you might be baking cookies with relatively low danger, but your neighbors might be making ammonium nitrate fertilizer that could cause an explosion that could affect you!



Evaluate Risk

After a thorough investigation of your facility, it’s time to evaluate each hazard’s risk. Take into account levels of severity, the likelihood of occurrence, and the number of potentially exposed people.

As you move to take corrective action, work on your highest risk hazards first. If you can’t immediately identify a permanent solution for each, you’ll need to use interim controls.

Select and Implement Controls

Now that you’ve identified your hazards and their risks, you want to control them. So, what are your options? Several resources are available to you, such as:

  • OSHA compliance standards and guidance
  • Industry consensus standards, manufacturers’ literature, and engineering reports
  • Control measures used in other workplaces
  • Input from your workers
  • For complex hazards, consult with safety and health experts

Always pick controls that are the most feasible, effective, and permanent. Discuss potential solutions with your workers to make sure they’ll function in your operation. Successful controls never make an employee’s job harder. Remember when implementing protective measures to follow the hierarchy of controls: Elimination, Substitution, Engineering Controls, Administrative Controls, then PPE only as a last resort.

Again, it’s essential to immediately eliminate or control all hazards causing or likely to cause death or severe harm. Ensure that new controls do not introduce new hazards into your facility.

Verification

Complete your OHS program by verifying your work. Have you truly minimized risk in your facility? Carefully test each safety control measure put in place. Have your workers join in on all parts of your internal audit to reach a safe consensus. You may need to rethink your corrective actions, introduce more OSHA compliance training and supervision, or include a new series of procedures.

For more information, please see OSHA’s Recommended Practices for Safety and Health Programs web page at https://www.osha.gov/shpguidelines/. If you would like assistance in implementing your program, including evaluating your compliance status, please contact Intertek Alchemy!

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Tackle Internal Audit Checklists for Food Safety Audits

If it’s not written down, it didn’t happen. Performing your due diligence is vital to your food safety audit process’s success and, in turn, successful production or manufacturing. Different methods exist for documenting inspection results and crafting an effective internal audit checklist. By exploring each, you’ll understand how to approach and prepare the documentation that works best for your internal audit procedures.

Internal Audit Walkthroughs

The first method, and one we do not recommend, is simply doing a walkthrough of your facility and recording any observed nonconformities. This internal audit procedure doesn’t prove to any third-party certification process that you had a structured plan of attack, objective, or scope associated with the inspection. Plant inspections are a critical part of the internal audit process. However, they need to have a specific scope and documentation to be effective.

GFSI Checklists

If auditing against GFSI Systems such as SQF, BRC, and FSSC 2200, we recommend using the GFSI standard checklist for your audit. Using a standardized document ensures your internal audit team goes through each regulatory requirement, without skipping areas of your facility or processes. Since these checklists are comprehensive, break them into sub-parts and complete a portion of the standard regularly, such as monthly or weekly. The internal audit schedule should ensure that all parts of the standard undergo an audit quarterly or annually, depending on the standard requirement.

Customized Internal Audit Checklists

The third internal audit documentation method is to use customized checklists for your plant inspections or specific processes. There are several benefits to this method, including:

  • Guides the audit – Your internal audit team will know exactly what to review
  • Ensures completion of all elements – Helps auditors address the entire scope of the audit
  • Reinforces objective and scope – Defines whether you’re auditing a process, a product, or people
  • Acts as a record – provides the documentation third parties need to prove your internal audit’s thorough completion




Setting up your customized audit checklist

Customized checklists are specific to individual facilities. However, there are general items every facility should utilize. These include the date, time started and finished, areas under audit, and a record of all the internal audit team members. For plant inspections, consider (at a minimum) including representatives from Operations, Quality Assurance, Sanitation and Maintenance.

Your checklist should go beyond general items (floors, walls, ceilings) and include an area-specific examination of equipment, processes, product handling, and people. So, you’ll need space to document each area of inspection and their results. Leave room to record nonconformities and corrective actions. Identify a target date and person responsible for corrective actions that cannot see immediate completion. Always remember to follow up!

Consider what content needs to be included and the specific requirements for each as you move through departments. Identify the relevant written program requirements and food safety policies, objectives, process interactions, activities underway, staff competencies, and process-based auditing techniques.



Managing the Internal Audit Checklist

An audit checklist may be detailed or limited, depending on the experience level of your audit team. Less experienced individuals need more detailed checklists and vice versa. Update these checklists as needed or as changes occur in each area.

The internal audit results should be reviewed by the entire team and circulated to supervisors, department managers and senior leadership.

Risks of using the checklist approach

While using a customized checklist is recommended, the process is not without risks. Never let the checklist’s details drive the internal audit process to a point where your team overlooks something crucial to your facility. Using the acronym STOP helps combat this risk.



Sometimes, the best course of action is to sit back and watch. This helps the audit team see, understand, and evaluate a department’s operation, fully thinking through the processes happening around them.

Alchemy Resources

Following these guidelines helps you achieve internal audit success and in turn receive high marks on your external audit. Learn more about internal audit best practices and gain expert insight into documentation procedures in our fully online courses Internal Auditing-Basics and Internal Auditing-Advanced.

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Food Defense 101: The Three Types of Food Defense Threat Motivations

Food_Defense

Intentional adulteration is only carried out after careful study and preparation by an attacker – is your food defense program equally prepared to address such acts? Motivation, capability, and vulnerability come together to compose food defense threats. Motivation often determines the adulterant and tactics that a perpetrator chooses to use. In addition to the threat itself, you must understand these potential drives for adulteration to help you address vulnerabilities in your process and keep the food system secure.

The three most prominent food defense threat motivations include:

  • Terrorism
  • Sabotage
  • Economically Motivated Adulteration or EMA




Terrorism

Terrorism against the food system occurs to cause fear, public health harm, or social and economic disruption. A terrorist may add toxic chemicals or a microbial pathogen directly to food set for public distribution.

Sabotage

Disgruntled employees, consumers, or competitors may or may not intend to cause public health harm but may seek to harm a company’s reputation through recalls when they carry out intentional adulteration. Each of these instances is an example of sabotage.

Dissatisfied employees represent intelligent adversaries with special access to and knowledge of your food production process and food defense program. This familiarity with your facility, procedures, security, and preventive control measures makes them of heightened concern. Consumers and extreme activists often carry out or threaten attacks on the food system to highlight a cause, such as using products thought to cause environmental harm.

Economically Motivated Adulteration

You may have heard EMA referred to as food fraud. This example of motivation involves the intention to make money fraudulently, evade regulation, or gain an unfair economic advantage.

There are multiple EMA methods, such as substituting expensive ingredients with cheaper ones to increase profit, adding unapproved ingredients to increase taste or volume, or mislabeling ingredients to avoid tariffs.

Conclusion

Individuals who commit intentional adulteration are creative, adaptable, and resourceful. Consider the three types of motivation and how to prevent and address them when creating your food defense program. To learn more about food defense threats, roles, and what happens after intentional adulteration occurs in a facility, consider Alchemy Academy’s Food Defense Supervisor online course.

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What to Expect from a Kosher Inspection

kosher production

Whether you’ve weighed the benefits of product diversification and have already entered the kosher food industry or you’re just getting your feet wet, you may find yourself curious about the steps to kosher certification. What can you expect from a formal inspection of your kosher program, and what can you do to prepare? This blog will help you better grasp the rabbi’s visit, no matter where you are in your kosher production journey.

Who is the Rabbi Auditing Your Facility?

Rest assured, the rabbi visiting your facility has years of experience studying Jewish law, particularly Kosher laws, under his belt. Of course, his knowledge base doesn’t end there. In addition to his familiarity with these rules, he has a working familiarity with food processing. After all, to properly audit and give your facility certification, the rabbi must be familiar with what you do, how you do it, and why you do it.

As you welcome the rabbi into your facility, cultural sensitivity is crucial. You may want to consider certain practices to make him more comfortable. To learn more about these precautions, consult Alchemy’s online Managing Kosher Production course.





Who Interacts with the Rabbi?

When a rabbi visits your facility, he’ll need to interface with multiple divisions of your team. Each is a vital proponent of your kosher food production and thus your compliance with kosher rules. These may include:

  • Research and Development (R&D)
  • Quality Assurance
  • Production
  • Marketing
  • Maintenance
  • And more!




Kosher Inspection Blog Post

He’ll want to talk to R & D to ensure that any reformulations or new items keep kosher laws in mind as they progress through development. Next, the rabbi will consult with quality assurance. The QA team represents the interest of your consumer. As such, the rabbi enlists them to make sure they include the Kosher consumer’s interests in all areas.

Of course, your production is paramount to the inspection. Beyond inspecting your production processes, he’ll go through records, schedules, formulas, and more. He may request to speak with engineering to verify there’s no cross-contamination of equipment or lines, and he’ll consult receiving to ensure they abide by kosher rules. Your maintenance and cleaning staff will also need to meet kosher sanitation specs to receive kosher certification.

What Happens During the Kosher Inspection for Certification?

Again, inspections come in all shapes and sizes. However, there is an outline of the basics you can expect during your journey to kosher certification. In a typical facility, the visit lasts for about an hour. Sometimes this is shorter, sometimes longer. Most of the time, these visits are unannounced and happen on a regular schedule.

The rabbi will visit all of the departments listed above, being careful to check production records and schedule. He’ll check storage areas and raw materials to make sure you have separated kosher products and ingredients from non-kosher ones.

Remember, the rabbi treats every audit as confidential. True, full, and accurate information is needed to inspect your kosher food production practice properly. As such, they understand they are guardians of proprietary and confidential information – perhaps that which acts as the basis of your entire business – and act accordingly.

Alchemy Academy Resources for Your Kosher Food Production and Certification

To further prepare for kosher food certification and ensure your kosher program includes all of the essential, consider Managing Kosher Production Online. This in-depth course leverages the Orthodox Union’s Rabbi Avrohom Stone experience and knowledge to provide participants with a step-by-step walkthrough of kosher rules, concepts, and program components. Start learning today!