Blog

Welcome to the section of Sabal Food Safety Consulting's web page dedicated to brainstorming discussions about food safety and related topics. Feel free to leave your comments or opinions about the topics under discussion. Should you enconter any difficulty using the Blog, send us an email to This email address is being protected from spambots. You need JavaScript enabled to view it. so we can investigate the problem.

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System's Consistency & Continuous Improvement

www.sabalfsc.com

 

Consistency and continuous improvement of a system

 

Whenever a decision is made to implement a system, the expected outcome is to achieve consistency on whatever will be done, the purpose. The system must be able to attain its purpose consistently.

I learned many years ago that, when developing systems, what is critically important is to make sure we comply with the requirements identified, which could be mandatory (legal requirements) or voluntary (like following an ISO Standard). This is what I believe is the most difficult aspect during the development of the system. This is understanding what we are trying to control and how we are going to do it, all in compliance with the requirements.

Understanding what we are trying to control is the first step. No matter what sector of the industry a system will be developed and implemented for, the “hazards” or “not desirable conditions” to the finished product or service must be adequately identified and understood, as well as knowing their sources. This should allow us to develop procedures that will effectively control them.

Now, some of the requirements may not be related with hazards or conditions we are trying to control but with the systems’ management components. As an example, making senior management aware of the overall effectiveness of the system is a common requirement in any system, with the intention to make them aware of the overall operations and potential needs for resources to maintain consistency and/or to improve the system.

In theory, when a system is developed, the intention is to design it to be effective all the time. That’s why it’ll be necessary to make sure that all elements, individually, and the system as a whole will achieve the purpose of the system.

It’s a fact that systems do not operate as intended all the time and deviations will occur. Whenever a system deviates from the requirements being followed it is not effective anymore. Therefore, all systems must include, as one of the its management components, procedures on how to deal with deviations, commonly known as corrective and preventive actions.

These corrective and preventive actions’ procedures have a very particular and unique purpose, to bring the system back into compliance with the requirements, which is the definition of a corrective action and, to do something to prevent the cause of the deviation from happening again, which is the definition of a preventive action. Corrective and preventive actions’ procedures are critically important to be well understood within the purpose of a system as they are the only resource a system has to recover from a deviation, including dealing with the affected product or service and, to prevent the reoccurrence of whatever caused the system to deviate from its purpose.

Corrective and preventive actions’ procedures are not related with the hazards or conditions controlled by the system. They are related with the assurance that the system is achieving the intention of the requirements and its overall purpose. Proper implementation of these procedures will provide the system with continuous improvement.

Feel free to contact us should you want to develop or improve your food safety system at This email address is being protected from spambots. You need JavaScript enabled to view it. .

 

FSPCA Certificate - Printing or downloading instructions

 

Procedure to download or print your FSPCA Certificate

Note: The pictures may take some time to load depending on the speed of your connection to the internet. Please, allow some time for them to load.

Step 1 - You’ll be receiving an email from the “International Food Protection Training Institute” ( This email address is being protected from spambots. You need JavaScript enabled to view it. ). Be vigilant as the email may fall in your junk email folder. The email looks like the picture below.

 

This email has a link (https://ifpti.absorbtraining.com/#/transcript) to the webpage that you'll be accesing to print your certificate. Also, the email contains the username and password that you will be using to sign-in after the webpage opens.
 

When you click the link in your email, the following webpage will open:

 

Step 2 - Populate the first field of the “Login” box with the username provided in the email. Populate the second field with the password provided in the email. Be careful as the password is case sensitive.

Properly populating the fields will take you to the following page:

 

Step 3 - This page has two sections that can be clicked to “Print Transcript”. By clicking any of the two, another page will open with the certificate in PDF. Download it to your computer and/or print it.

If for any reason this does not work, contact your trainer or the training center.

 

Best regards,

Jose Sabal

 

 

 

 

 

 

 

The value of a person

 

My brother recently sent me a link to see a short video. The video was taken during Victor Küppers’ presentation organized by TEDx Andorra La Vella and the topic was "The Value of a Person". I was delighted with the content and I would like to summarize his presentation and use it as an introduction to the attitude towards food safety.

Victor explains that the value of a person can be expressed by a simple formula: V = (K + S) x A, where V is the value of a person, K is the knowledge, S are the skills and, A is the attitude. For anyone with train-the-trainer background, this sounds very familiar.

The objective of the presentation was to highlight the importance of the attitude of a person. Victor explained that the attitude is multiplying the sum of K and S! You make a difference in your environment because of your attitude. You influence people with your attitude. Knowledge and skills are not only necessary but crucial factors. However, we select our friends by their attitudes…we don’t ask our friends for their Curriculum Vitae’s to determine if they will become our friends or not.

So, how does the attitude of a person correlate with food safety? The life of the consumers of food products is in the hands of the companies manufacturing them.

We all need knowledgeable and skillful individuals to work processing or manufacturing the products we consume. The training of these individuals must be effective and there must be a way to measure how knowledgeable and skillful they are.

For the knowledge, a test or a meeting to discuss the content of the training is satisfactory as long as the trainer, who must be knowledgeable on the topic, evaluates the results. Now, tests do not assess the effectiveness of the skills of people, only the knowledge. A solid training program must include an evaluation of the skills required to safely work in a food processing environment.

The last component of Victor’s formula is attitude. How can we determine if a person working in food processing has the right attitude? This may not be easy; however, not impossible.

The Bell curve is mentioned often when anyone wants to assess probability of distribution. Any method used to determine the distribution of the value of a person in the food industry could be plotted in a Bell type curve. The results would be analyzed to determine potential risk from employees to the food manufacturing operations.

Generically, any Bell type curve has three zones. The center is the average, one of the sides is below average and the other side is above average. Employees’ value falling in the average, or above it, represents low risk to food manufacturing or processing operations. However, those employees that fall into the “below average” side of the curve represent a high risk, a significant hazard.

In a HACCP environment, what do we do whenever we have a significant hazard? We have a critical control point for which we identify a critical limit, continuously or frequently monitor the limit to make sure we remain in the acceptable range, we develop corrective actions, verification procedures, and record-keeping.

Senior management of any food facility is responsible to understand the hazards in the process and provide resources to acquire knowledgeable and qualified individuals that will be directing and controlling food processing or manufacturing operations, also known as: human resources. Senior management is also responsible for the effective implementation of the training program in any food facility.

Senior management is responsible to find a way to determine the value of all employees and implement corrective and preventive actions according to the risk the employees present.

Preventive Controls & HACCP Integration

 November 2015

 

Preventive Controls and HACCP Integration

Almost everyone in the food & beverage industry is concerned with the implementation of the new FDA’s “Food Safety Plan” and with the development and implementation of the “Preventive Controls”. From my point of view, the greatest worry is: how to integrate current food safety programs, where HACCP is the main component for the analysis of the risks of food safety hazards, with the FDA’s “Food Safety Plan”?

In my opinion, the core of the integration process greatly relies on the analysis of the risks; the difference between a hazard that requires a critical control point and a hazard that requires a preventive control is their risk.

When reading 21 CFR 117 - Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food, Section 117.3 – Definitions, the definition of a “hazard requiring a preventive control” is: “a known or reasonably foreseeable hazard for which a person knowledgeable about the safe manufacturing, processing, packing, or holding of food would, based on the outcome of a hazard analysis (which includes an assessment of the severity of the illness or injury if the hazard were to occur and the probability that the hazard will occur in the absence of preventive controls), establish one or more preventive controls to significantly minimize or prevent the hazard in a food and components to manage those controls (such as monitoring, corrections or corrective actions, verification, and records) as appropriate to the food, the facility, and the nature of the preventive control and its role in the facility's food safety system”.

As the FDA also developed the guidance document for the implementation of the HACCP method for seafood products under 21 CFR 123 – Fish and Fishery Products, I’m going to use this as reference for definitions for HACCP and to compare with the preventive controls rule. A “significant hazard” is a hazard that is “reasonably likely to occur”. The definition of a food safety hazard is: a hazard that is reasonably likely to occur and “one for which a prudent processor would establish controls because experience, illness data, scientific reports, or other information provide a basis to conclude that there is a reasonable possibility that it will occur in the particular type of fish or fishery product being processed in the absence of those controls.”

Similarities. Preventive controls and Seafood HACCP regulations require: 1) To have a person that is knowledgeable about food safety hazards, the products processed and developing control measures. 2) To implement measures to control those hazards with risks based on severity and probability (risk). 3) Those measures will be implemented because, “in the absence of those controls”, the hazards identified will cause illness or injury. 4) Even though it’s not part of the definitions, hazards from incoming goods (raw material, ingredients, processing aids, packaging material, etc.) and hazards from the process must be analyzed in both cases.

Difference. In the preventive control rule, a control measure must be implemented whenever “a known or reasonably foreseeable hazard” is identified. In the Seafood HACCP regulation, a control measure must be implemented whenever there is a hazard that is “reasonably likely to occur”. However, there is no indication on how to measure the risk of “a known or reasonably foreseeable hazard” or the risk of a hazard that is “reasonably likely to occur”.

With this in mind, the tool that will be used to measure the level of risk is what will represent the biggest challenge to all individuals responsible for the analysis of the risks of the food safety hazards in any product/process. This tool should provide a simple but thorough description of the different levels of severity and likelihood of the hazards. I believe there is also a good opportunity to add to this risk analysis tool another variable: detection. Whenever food safety hazards are analyzed, the risk of those should be adequately assessed by determining the severity, likelihood and detection of the hazards.

What is the severity of a food safety hazard? Is the consequence that will produce. It is normally referenced as death, illness or injury. What is the likelihood of a food safety hazard? It’s the chance that the hazard identified may happen during operations. What is the detection of a food safety hazard? Is the ability to detect the hazard.

In the World Health Organization / Food and Agriculture Organization of the United Nations document titled “Risk Characterization of Microbiological Hazards in Food”, there are several methods to determine the level of risk and each method has its own pros and cons, mostly associated with the level and deepness of the knowledge and skills of the individual(s) performing the analysis of the risks to food safety.

Whatever is the method used to determine the level of risk of all hazards in a food safety system, the “qualified individual” must have very good skills on how to apply sound scientific knowledge to be able to comply with the preventive controls rule while maintaining the HACCP program in place.

Food safety hazards, the human element

 November 2014

 

When we look at the definitions and methodology of the HACCP System, we will, eventually understand that there are three basic types of hazards: biological, chemical and physical.

When implementing a HACCP System, prerequisite programs (GMPs) must already be in place and will be used by the HACCP System to “prevent, eliminate or reduce hazards to an acceptable level”. I’m borrowing this definition from the HACCP System and applying it to prerequisite programs.

Anyone responsible for the development and implementation of a HACCP System will identify specific hazards from the three available types (biological, chemical and physical) and will perform a risk analysis based on the severity and likelihood of the hazards to determine how significant they are. This process will be fundamental when identifying critical control points or preventive controls (FSMA).

What we are missing is a type of hazard that, by nature, may always be considered “Significant”, and this hazard is the “human element”.

For example, by looking at current statistics of recalls, the number one reason for recalls is allergen control. Whenever we have allergens in our facility/process, they show up in our HACCP Program as chemical hazards.

However, by using a “root cause analysis”, the main reason why allergens are cause number one for recalls is the “human element”. Why?

People is responsible for identifying the allergenic agents in food, include them in the HACCP program, handle them inside the facility, develop labels that include the allergens used and review those labels frequently and, cleaning all food contact surfaces to prevent cross-contamination. The only way this is effectively accomplished is by having “qualified individuals”, as defined by FSMA. This is training.

Here is where the effectiveness of the “training program” comes into play. People must be trained to:

1) Obtain the knowledge required to develop and implement a food safety system.

2) Start using the knowledge and converting it to skills. This is experience.

3) Have the right attitude towards the job, responsibilities and activities to be performed. This is inherent to each person, as well as the ability to be tolerant to other opinions. This is where the human element plays a big role as a food safety hazard.

Training requirements are in the HACCP regulations as well as in the Good Manufacturing Practices” regulation. Employees must be trained.

The challenge: measure the effectiveness of the training including the attitude of personnel towards the food safety program.

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