How Did That Happen?

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Practical QA Solutions

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August 10, 2011

A child becomes sick from insecticide poisoning found in a milk container. Customers are shocked by blood found in tortillas. Lab testers find fresh bread tastes gritty from sand found in the flour. An auditor is surprised to find a live mouse in a tailings container. People become sick from Salmonella found in dry cereal. Children become sick from Salmonella found in dry pet food.

Although these incidents are fictitious (and any similarity to real events is purely coincidental), there are lessons to be learned from the examples and their similarities to actual events. With this column, I am starting a series of “How did that happen?” The articles will focus on examples of such issues that can, and do, happen in the industry; the lessons to be learned from each; and practical solutions to prevent similar incidents from happening to you. While following Good Manufacturing Practices (GMPs) is always a solution, as each occurrence is a violation of parts thereof, there are also some particular practical solutions specific to each.

 The closer I get to farming operations, the more often I see containers being used for contents other than those for which they are labeled. Is this due to GMP education not reaching the farm? It seems a customer-requirement approach is reaching select farmers but not the masses. Is it time the farming industry implements a GMP education initiative reaching out to its members? The Food Safety Modernization Act will likely impact farm operations through transportation requirements.

Auditor's Soapbox

Incident: A child becomes sick from insecticide poisoning found in a milk container.


How did that happen?
A food plant maintenance man was spraying a residual insecticide treating for ants around a trash compactor. He was called away to an operations need. Although he took the sprayer with him, he left behind an unmarked plastic milk container with an insecticide solution. Three children on bikes rode by, spotted the milk jug, and decided to have a club initiation. The oldest told the youngest, “Drink this old milk and you can be a member of my bike club.” The child took a big gulp of the white liquid and …. the lawsuit named the food plant owners along with the pest management service provider.


What are some practical solutions learned from this incident? An obvious solution is to not reuse containers for anything other than their intended use. All containers must be labeled with the contents. Containers may range from small spray bottles to waste receptacles. Some think it is acceptable to use containers for short-time use, such as the plastic milk container, but empty ingredient packages with other contents could make their way into the process; or empty packaging in the warehouse with floor sweepings could make their way onto a truck as part of a customer shipment. All containers must be labeled—with the key word being All.

The second solution is having shared responsibility with an outside pest management service company. Stay away from doing self treatment and hold accountable the pest management service provider for pest activity. Do your part through exclusion and sanitation efforts.

Third
is good documentation practices. The pest management service provider was conducting a routine ant bait treatment and was called away to a more urgent service need. There was no documentation of either the residual insecticide or bait treatments. The importance of documentation is often understated but is, in actuality, a big part of our life beginning with a birth certificate and ending with a death certificate. Using key journalism words as a guide, good documentation centers on: who, what, when, where, why, and how.

In addition, four basic rules of good documentation are:

  • Do it legibly.
  • Do it now.
  • Do it right.
  • Do the organizing.


With hand-held technology, documentation should be legible, instant, accurate, and organized. You might be judged by your written word some day. Make good documentation your friend and poor documentation your enemy. In front of a customer, third party auditor, FDA investigator, or even a court judge, good documentation will make a good impression.

Fourth
, follow GMPs without exception; they provide guidance and prerequisites of HACCP and other food safety programs. They have withstood the test of time and continue to remain effective today.

When people are in a hurry, mistakes and accidents happen more often. When you sense you are in a hurry, slow down. Prevent an oncoming mistake or accident. Haste does make waste—or worse.