I trust everyone is over-the-top busy this time of year. Summer is such a good time to get things done, to enjoy the outdoors, and to work on your house, yard, and garden. And, of course, work plays a big part in anything we do anymore. With so much going on, I thought it would be best to just talk about some of the things we’re all working on.
So, let’s talk about …
- Summertime Pest Control is an interesting topic. With the warm weather, flies and mosquitoes interrupt our lives, both at home and at work. Keeping these pests out can be a challenge. But rodents and other vermin are also active and want to get into the plant. Now is when we test the planning work we did during the winter and the training we did with our employees. Let’s hope we’re all successful and our plants remain vermin free.
- GFSI Concerns. GFSI was supposed to replace a lot of customer audits – is it working for you? I work for a co-packer; while GFSI may have slightly reduced the number of audits, everyone still wants to review the plant and programs for themselves. Last year, we had 30 days of customer “audits” in addition to GFSI SQF audits, so I’m not holding much hope for GFSI eliminating the additional visits. Customers must start to believe in the SQF program so that it is accepted. Personally, I’m rethinking our own use of it, because until the big players accept GFSI schemes/audits, we’ll all continue to have too many audits by individual customers. And with FSMA requirements for a supplier program, I don’t have much hope that GFSI is the savior we were all hoping for.
- Speaking of FSMA … I know we’re all busy upgrading and refining our programs to be ready for the implementation dates of FSMA. Lots of new rules to prepare for and lots to look forward to. Preventive Controls for Human Foods, Safe Transportation rules and the one most of us have probably not spent enough time on – Preventive Controls for Animal Food. All our hazard analyses are being re-done. All our prerequisite programs are being tweaked into preventive controls programs (same stuff, different names). Receiving programs are being bolstered with additional controls, and steps are being built to better understand supplier controls. But on top of all this, I’ll bet you sell products to an animal feeder putting you under the Preventive Controls for Animal Feed rule. Just a little bit more work to do to have yet another risk analysis and preventive controls program. We’ll all probably end up doing more testing too. And don’t forget to validate all of those control measures. I’m certain we’ll all be busy on this one for a good amount of time.
- Personnel. Actions, teamwork, team building/partnering, training, and follow up. We’re all looking for good people and trying to “right-size” our teams. People are shuffling from one company to another to fit into the new scheme. Now is a great time to see what all these new people bring to the organization. Everyone picks up good thoughts and knows how programs were managed by their previous employer. I’m confident we all can learn from those new hires at our plants. Assuring that these folks fit in and understand the rules and programs at our site is also critical. Again, FSMA requires adequate training so that all employees know, understand, and practice the right programs to assure food safety. Now is a great time to ensure that is happening.
- The New Food Defense Rule has also been published as part of FSMA (though it’s not called food defense, rather it is Protection From Intentional Contamination). While we’re busy implementing all the elements of the Preventive Controls rule, we also get to think about food defense. This is a tough one for us on so many levels, but it does bring elements of security into the food safety arena making us think a little bit differently. And in today’s world, this may be the hardest thing to protect our consumers from. I know it’s another thing on our already overcrowded plate of tasks, but it may be the most important.
- While we’re at it, the new Nutrition Facts Panel for food packages has been rolled out. Good news is that we have two years to redesign our nutrition facts on every one of our packages. (Bad news is we have to redesign our nutrition facts on every one of our packages). Again, new things to read and understand, so we need some quiet time to read. Then we need to work with marketing and package designers to get the new panel right. As a co-packer, I’ll be getting to help 50 customers understand and update all the 400+ product labels we produce. At one per day, we’ll be in compliance when the new rule must be in place. More stuff on our plates!
- Evaporated Cane Juice. In case you haven’t notice, FDA guidance recently told us that we can no longer claim “evaporated cane juice” or “evaporated cane syrup” in the ingredient list. FDA says that it is not a juice in the typical sense of “juice,” so it confuses the consumer into thinking there is no added sugar. Evaporated cane juice is sugar and the consumer should know that. Those deceptive labels need to be changed ASAP also. More things on our plates.
It’s a good time to be a food scientist and to be needed. I’m so glad that there are new smart, well-prepared, and educated food scientists coming into the industry. There is so much to be working on, and it will take a lot of brain power to accomplish this. Whether you’re in the first wave of FSMA or you’re a smaller processor who has more time, we’ll all be looking for that new blood to help get us where we want to be. We’ll be compliant with the new regulations and we’ll all be leaders providing safe food to the marketplace.Bruce Ferree is Director of Quality, California Natural Products.