Are You Aware?

Departments - Self-check Assessments

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July 31, 2019

AL ST.CYR, President, ASC Consulting

Just how well do you know what is happening in your food plant? Are you aware of the actual or potential food contamination issues lurking in the product stream of your process? Are you prepared for what is needed to address such issues? Are your personnel following the procedures necessary to preserve the integrity of your products consistently?

If these thoughts only come to you when FDA or a serious customer inspection occurs, then things need to change. Far too many food plant programs rely on documentation review as a verification of program compliance. Documentation does not give you visual confirmation that the tasks were actually done in conformance with procedures.

As an example, while visiting a facility to develop material for a training program, we checked the testing of the metal detectors on the six production lines. The documentation sheet for this task listed the blanks as non-ferrous 2.0, ferrous 1.5, and stainless 3.0. The line had been running for about six hours when we checked it. All checks were recorded as completed.

We asked the quality assurance technician to run a challenge test for us, and it was done and documented. Unfortunately, it was readily apparent that the tech had taken the wrong test pieces that day and rather than a 3.0 for stainless, they were using a 3.0 non-ferrous test piece. You can imagine the reaction to this discovery since the past six hours of production on six lines was placed on hold to be re-run through a detector properly verified for stainless 3.0. We had to wonder just how many times this had happened before.

Did that contracted sanitation person actually clean the equipment to meet your expectation, or did you rely on them telling you they did on paper? Are critical systems properly disassembled for cleaning each time, or have shortcuts been introduced by personnel? Without someone physically verifying it, how confident should you be in your program?

Some would argue that we have our monthly inspection program, and we check our plant. Really? Are you just as clean after your walk-about inspection as you were when you started, or is there clear evidence on your clothing that you conducted an in-depth inspection of your plant? Were you on the floor looking up under your equipment? Were you up in the overhead? Did you break that drain line under the product tank post cleaning to verify that all the cleaning solution was drained and rinsed properly, or is that drop in the line still full?

These are questions for which answers are not found in the documentation. Food plant inspections are serious business. FDA investigators take it seriously and so should you. Every food plant needs a person who will take a critical look at the facility and search for the issues; a person who has the knowledge about how things should be and uses that as the criteria for the inspection.

These personnel should be recognized by upper management as their eyes and ears in the plant to keep them informed of conditions that may need their attention for changes. Management should empower them to access what is needed when they deem it necessary. If handled properly, it will not be an adversarial position; it will be one that identifies potential risks for product integrity before they can become actual issues and affect the brand.