DRAFT
FOOD SAFETY AUDIT REPORT
SYSCO SYS Template 20070426
#SYS-C-150SYS-C-150
By
JOHN BOYCEJOHN BOYCE
Food Safety Auditor
April 10, 2008April 10, 2008
AIB International
1213 Bakers Way • PO Box 3999 • Manhattan, KS 66505-3999
(785-537-4750) • (800-633-5137) • Fax (785-537-0106)
http://www.aibonline.org/
DRAFT
RATING
A food safety audit was conducted at this fresh-cut produce facility on April 10, 2008. The writer was accompanied throughout the audit by Mr. Bill Hum – General Manager.
Excellent cooperation was received by the writer, and on some occasions, the items were immediately corrected.
At the conclusion of the audit, a meeting was held to discuss the observations, recommendations, and rating.
Based on the observations made, the information obtained, and the criteria set forth in the AIB Consolidated Standards for Fresh Cut Produce, the overall food safety level of this facility was considered to be:
SUPERIOR
(915)
The “serious” or “unsatisfactory” items are shaded, boxed, and bolded in the text of the report. Refer to the definitions in the AIB Consolidated Standards.
The “improvement needed” items are designated in bold type and require prompt attention.
The AIB International states that the report as given herein is to be construed as its findings and recommendations as of the date of this report. The AIB International accepts no responsibility and does not assume any responsibility for the food safety program in effect with (customer). That further AIB International is only making report of the food safety conditions of (customer) as of the date of this report and assumes no responsibility or liability as to whether (customer) carries out the recommendations as contained in this report or does not carry out the recommendations as contained in this report.
RATING ANALYSIS
DATE OF AUDIT: April 10, 2008
TYPE OF AUDIT: UnannouncedUnannounced
OVERALL RATING: SUPERIOR
ADEQUACY OF FOOD SAFETY PROGRAM / 175PEST CONTROL / 200
OPERATIONAL METHODS AND PERSONNEL PRACTICES / 200
MAINTENANCE FOR FOOD SAFETY / 170
CLEANING PRACTICES / 170
TOTAL: / 915
RATED ITEMS
UNSATISFACTORY ITEMS:
None
SERIOUS ITEMS:
None
IMPROVEMENT NEEDED ITEMS:
3, 6, 9, 48, 54, 55, 56, 61, 62, 63, 64, 65
FACTUAL OBSERVATIONS AND SPECIFIC RECOMMENDATIONS
ADEQUACY OF FOOD SAFETY PROGRAM
1. A current organizational chart was maintained. The responsibility and authority for ensuring food safety and security and the facility's compliance with federal, provincial, municipal and/or any other appropriate regulatory laws or guidelines were clearly assigned to the Vice President of Finance and Warehouse Operations. This responsible person remains up to date on regulatory issues. The facility ships no products to the United States but has obtained the FDA biosecurity registration.
2. The department responsible for maintaining the distribution center’s food safety program had established written procedures outlining the specific responsibilities of each department manager and employee in the “Operational Manual-GMP.” This manual included a statement defining the company’s intention to meet its obligations to keep the products safe. A CFIA manual was also maintained on site, detailed all current regulations and specifications for produce handled by this facility.
3. This facility had established a multidisciplinary food safety committee to conduct monthly inspections of the entire plant. However, there had been no inspections performed in January or March of 2008. It was recommended that inspections occur no-less-than monthly to ensure any deficiencies with an adverse impact on food safety are addressed on a timely basis. It was noted that some identified issues from the self-inspections had not been addressed, including some of the issues identified during the AIB audit from December of 2007. The completion of corrective actions needs to be routinely tracked (either on the inspection form or the Maintenance Work Orders). It was further recommended that the scope of the self-inspections be significantly expanded in order to more readily identify and correct the types of food safety concerns raised during this audit. (IMPROVEMENT NEEDED)
4. The facility appeared to maintain an adequate budget and support to maintain the proper and timely acquisition of appropriate tools, materials, equipment, monitoring devices, chemicals, and pest control materials.
5. A Master Cleaning Schedule (MCS) for periodic cleaning assignments and a daily housekeeping schedule were developed as a formalized, written plan and implemented in this facility. This MCS specified frequency and responsibility. Postcleaning evaluations were conducted. The schedules were documented as current, and the conditions observed in the warehouse supported the documentation. The schedule included the outside grounds, buildings, drains, and equipment. The schedule was reviewed periodically to ensure that it was still applicable.
6. Detailed, written cleaning procedures were developed and on file for all cleaning tasks in the facility relating to the cleaning of food storage equipment, the building and the exterior grounds. In order to address the cleaning deficiencies noted during this audit (in particular, the Triangle bagging equipment), it was recommended that these procedures be reviewed and revised as necessary. Emphasis should be placed on removal of all produce debris after the production runs are complete. (IMPROVEMENT NEEDED)
7. All incoming produce, packaging supplies and other material entering the facility was inspected for objectionable material according to a written procedure. This procedure included a visual inspection for pests, damage, cleanliness, and product integrity. In addition, receiving records were maintained that included the date of receipt, carrier, quantity, and information to facilitate a recall.
8. All produce suppliers were required to provide a “Hold Harmless” agreement and/or be SYSCO approved for supply.
9. A hazard analysis for all products being processed at this facility had been conducted. Separate Hazard Analysis Critical Control Point (HACCP) programs had been developed and implemented for all of these products. It was noted that some of the HACCP forms in use in the fresh-cut operations had not been updated to comply with the FreshPoint corporate HACCP manual. For example, the critical limits for function of the metal detector were different than the corporate guidelines. This was not considered problematic because the facility was using smaller test pieces than the corporate standard. It was recommended that the plan be completely reviewed and revised as necessary to comply with the corporate plan and ensure that all potential hazards have been adequately addressed. When the forms are updated, it was recommended that spaces to log the actual times of the checks of the metal detector, sulphite levels, etc, be included on the form in order to be able to demonstrate complete compliance with the monitoring requirements of the program. (IMPROVEMENT NEEDED)
10. The company had established written employee guidelines and food safety policies. Specific written procedures were on file for providing food safety training to all personnel, including temporary personnel and contractors. Records of training completion for new employees and refresher training documentation were maintained for all personnel. The date of the last such training was October 30, 2007. It was recommended that the training documentation provide more details, such as the length of the class, the specific topics covered, the name of the instructor, whether or not translation was provided, methods used to ensure employees have understood the training, etc.
11. A formalized, written program for evaluating customer complaints, particularly those related to adulteration, was established at this location.
12. A written recall program was on file and routinely reviewed. Distribution records were maintained to identify the initial point of distribution to facilitate segregation and recall of specific lots. Test traces and mock recalls were conducted every six months with appropriate documentation maintained on file. An actual recall of cantaloupe had occurred on March 24, 2008, which had impacted the fresh-cut operations. The CFIA monitored the facility’s response to the recall. A mock recall was conducted on a specific lot of produce on December 24, 2008. 100% of the affected lot was traceable with twenty minutes. It was recommended that the facility ensure its ability to conduct a trace based on a specific lot of food-contact packaging material by conducting a mock recall based on a packaging material trace.
13. Written procedures were in place to control damaged or returned product. Records were kept of the corrective actions and disposition of the product and adjustments were made to the product inventory records to accurately account for the damaged or destroyed materials.
14. A written policy on how to handle regulatory and third party inspections was on file. These procedures included the person(s) delegated to accompany all inspectors and company policies regarding photographs, records, and samples.
15. A written policy stating that no glass was to be used in the facility, except where absolutely necessary, was in place. Included in the policy was a procedure to handle any glass breakage in the facility. A list of all essential glass had been developed and was audited on a weekly frequency to ensure that any accidental breakage was found and addressed. It was recommended that a prohibition against ceramic mugs and other glass-like materials be added to the program.
16. Processing records were maintained and contained sufficient information to comply with government regulations. These records included, but were not limited to, product in process packing and shipping temperatures, microbial testing of raw materials, in process materials, and finished product, and monitoring and documentation of the concentration of the peroxyacetic acid and metabisulphites in the product sanitizing system. The product labels indicated the use of sulphites when applicable.
17. A formal preventive maintenance program and work order system was in use to prioritize the elements of identified structural, equipment, or utensil maintenance problems that could cause food adulteration. The production equipment appeared very well maintained. A program to ensure that the safety of the product was not jeopardized during maintenance operations was implemented at this facility.
18. The facility had established and maintained a formalized program for the control of bacteria, yeast, and mold. Records of laboratory analysis and/or environmental samples were maintained on file. Raw materials were tested for total plate count, coliforms, yeast and molds. Finished goods were tested, based on customer requirements.
PEST CONTROL
19. A formalized pest control program was established with written procedures outlining the requirements of the program to reduce the potential for product contamination from pest activity or use of materials and/or procedures designed to control pest activity.
20. Facility management contracted the Abell Pest Control Company to provide weekly & monthly pest control services. A copy of the service agreement that included materials to be used, methods, and precautions was maintained on file. Copies of the current liability insurance and current applicator's license were maintained on file.
21. Material Safety Data Sheets (MSDS) and sample labels were maintained on file for all pesticides applied on the premises.
22. A service report was left after each visit by the outside pest control service. These records included the treatments and tasks carried out, documentation of the checks and findings for the pest monitoring devices, descriptions of the current levels of pest activity, and recommendations for actions needed to correct conditions allowing a potential for pest activity.
23. Documentation of all pesticides applied on the premises, including rodenticides, included materials applied, target organism, amount applied, specific area where pesticide was applied, method of application, rate of application or dosage, date and time treated, and applicator's signature. This documentation indicated that the applications were made in accordance with the label directions.
24. A schematic depicting the locations of the interior and exterior pest control devices, including mechanical rodent traps, glue boards, pheromone lures, insect light traps, and bait stations, was maintained on file and appeared current.
25. Mechanical mousetraps were installed to monitor for rodent activity inside the facility. These traps were properly positioned along walls and beside doors to the outside. The traps were inspected on a weekly basis, and a record was maintained of service and cleaning of each rodent control device. A rodent activity log was used to record captures and help direct any necessary corrective actions. The traps randomly examined appeared properly maintained.
26. Bait stations for rodent control were installed around the exterior perimeter of the facility at appropriate intervals. These stations were tamper resistant, properly positioned, anchored in place, locked, and properly labeled in compliance with regulatory requirements. All stations were serviced at least monthly. Documentation indicated that fresh bait had been routinely supplied in the stations.
27. Electronic flying insect light traps (ILTs) were used in the facility to aid in monitoring insect activity. These traps were more than ten feet from exposed product. The traps were scheduled for weekly cleaning in the summer and monthly cleaning in the winter. A record of the service and cleaning of each ILT was maintained, and the activity levels documented. The light tubes were replaced annually and supporting documentation was maintained.
OPERATIONAL METHODS AND PERSONNEL PRACTICES
28. The procedures for receipt, storage, and handling of raw materials were established to comply with the Good Manufacturing Practices (GMPs).
29. Damaged and/or badly soiled or infested containers were not accepted and materials shipped in damaged, dirty, or infested vehicles were rejected. Proper documentation was maintained specifying defects and reasons for rejection. Perishable materials met specific minimum temperature requirements at point of receipt and documentation was recorded for all temperature sensitive materials.
30. 50-cm perimeters were maintained in all storage areas to provide cleaning and inspection access. Adequate space for cleaning was maintained between rows of stored products.
31. All perishable materials were stored at or below 40°F (4°C).
32. Toxic chemicals, including the cleaning solutions, maintenance compounds, and non-food-related materials, were completely segregated from all food ingredients and packaging materials.
33. Ongoing housekeeping operations by production and all support departments were completed throughout the operating hours to maintain the work areas in a reasonably sanitary environment. Operational debris was kept at a minimum.
34. An allergen control program was in place. The use of sulphites was the only identified allergen at this time.