© EAGLE Food Registrations Inc CONFIDENTIAL 1 Food Safety ASQ Milwaukee Section November 18, 2013 Nancy Berger EAGLE Food Registrations, Inc November 2013
2 © EAGLE Food Registrations Inc CONFIDENTIAL Agenda FSMA – what it means to the consumer GFSI – what it is & how it is making the food chain safer Food Safety – heading in the future
3 © EAGLE Food Registrations Inc CONFIDENTIAL Challenges Food Safety Crisis – global Government FDA/USDA budget cuts/not enough manpower Too many individual audits with different expectations Recalls and Media Consumer health # 1 priority
4 © EAGLE Food Registrations Inc CONFIDENTIAL FSMA FDA Food Safety Modernization Act (FSMA) Signed into law January 4, 2011 Most sweeping change in 70 years Applies to human and animal food products Special areas of the law for imports and produce Helps the food chain build consumer confidence
5 © EAGLE Food Registrations Inc CONFIDENTIAL FSMA 7 Foundation Standards (such as food safety defense) still under development, deadline 6/30/2015 for feedback to finalize 5 Areas of FSMA Law Prevention GMPs/HACCP Inspection & Compliance Regulatory Response Import Safety Enhanced Partnerships
6 © EAGLE Food Registrations Inc CONFIDENTIAL FSMA Prevention goal of the entire FMSA revisions: Preventative rather than reactive approach Stop it before it happens Reduce the likelihood of bad product out in the industry HACCP Program defined and implemented −Some exclusions apply (seafood; juice; small business less than $500,000 annual revenue) −Hazard Analysis Critical Control Points - Evaluate hazards; identify and implement preventive controls; monitor performance; maintain records −Sounds like a FMEA doesn’t it! Prevent Food Hazards!
7 © EAGLE Food Registrations Inc CONFIDENTIAL FSMA Inspection and compliance -greater access to reports and plant Catching up to USDA USDA has been strong in this for a long time – USDA plants have inspection in each day; each shift
8 © EAGLE Food Registrations Inc CONFIDENTIAL FSMA Regulatory Response – stronger recall processes if reasonable probability of causing serious adverse health consequences or death to humans or animals Registration of all food manufacturing facilities −Any manufacturer, processor, packer or warehouse/distribution −Not farms, restaurants, retail food establishment Detainment of product or suspension if reasonable probability of causing serious adverse health consequences or death to humans or animals
9 © EAGLE Food Registrations Inc CONFIDENTIAL FSMA Import Safety is a big focus of FSMA Foreign supply verification program - 3 rd Party Audits Importer will have to have the audit certificate on file Set criteria for who can do the audits – approved government agencies/staff and approved auditing companies −Not enough FDA inspectors to do audits −Auditors will also have to be accredited −Starting with imports, but you know it will move to US manufacturers in near future ! Safety BIG Focus
10 © EAGLE Food Registrations Inc CONFIDENTIAL FSMA Enhanced Partnership FDA staff will not be able to do it alone −Budget restraints Look to other agencies and organizations involvement −State health agencies −Local health agencies −Third Party Certification Bodies or Groups −BRINGS US TO GFSI AUDITS
11 © EAGLE Food Registrations Inc CONFIDENTIAL What is GFSI? GFSI launched in 2000, following a directive from the CEOs in the food business Now managed by The Consumer Goods Forum Benchmarking process of schemes against guidance documents (by sectors) Encourages stakeholders to share knowledge and strategy for food safety – develop best practices for common global framework
12 © EAGLE Food Registrations Inc CONFIDENTIAL Benefits of an FSMS Preventive system Provides systematic approach to managing food safety Provides standards and guidelines for food safety Provides verification and validation of system Improves compliance to regulatory standards Provides confidence to consumers Demonstrates due diligence by processor Auditable
13 © EAGLE Food Registrations Inc CONFIDENTIAL Oversight vs. Non-oversight Non-oversight, Third-Party Audits Audits which are the product of a specific company −Examples = AIB, Silliker, Cook & Thurber These audits are created and controlled by the company who developed the audit criteria Type of audit used at Peanut Butter Corporation of America Oversight Third-Party Audits All GFSI schemes
14 © EAGLE Food Registrations Inc CONFIDENTIAL Certification Process Which program is best for their company? What are the reasons for seeking certification? −Required by customer Global business Mature vs. New FSMS Standards are similar in a lot of ways, but unique Let’s share some of them
15 © EAGLE Food Registrations Inc CONFIDENTIAL Certification Process Training on the Standard Implementation - Internal or consultant - What fits your company’s needs On-site Pre-Assessment GAP analysis – internal or external
16 © EAGLE Food Registrations Inc CONFIDENTIAL Certification Process (continued) Supplier Implements The System Create Documentation Identify gaps & correct the gaps Implement System & Train Verify - you do what you say you are doing Validate - Is it working? System Operational* *System must be operational for minimum of two months so records are created and it can be verified and validated
17 © EAGLE Food Registrations Inc CONFIDENTIAL Certification Process (continued) Certification Steps Different by Standards −FSSC: Stage 1 and Stage 2 » Readiness visit (1) Certification Audit (2) −SQF: Document Review & Certification Audit Close out Findings Certification Granted Some GFSI audits are scored / some mirror ISO 9001 and are not scored Surveillance and or recertification audits −Requirements by standard
18 © EAGLE Food Registrations Inc CONFIDENTIAL GFSI Schemes The Three Major FSMS in the U.S. are: Safe Quality Food (SQF) British Retail Consortium (BRC) FSSC 22000
19 © EAGLE Food Registrations Inc CONFIDENTIAL SQF – Overview SQF = Safe Quality Food Developed in Australia in 1994 Food Marketing Institute purchased in 2003 One code with defined modules for industry specific operations 3 Levels of Certification (Benefit) Level 1 = Food Safety Fundamentals (GMPs, PRPs) Level 2 = Food Safety Plan (HACCP) Level 3 = Food Quality Plan (HACCP driven)
20 © EAGLE Food Registrations Inc CONFIDENTIAL SQF – Basic Facts & Benefits All documentation is free on their website (Benefit) Auditor approval controlled by scheme (Benefit) Nine basic elements and HACCP based Includes some elements found in 9001 and Document Control, Management Review, Internal Audit, Corrective and Preventive Action Standard by modules by food sector categories (Benefit) Offers additional tools such as guidance documents for specific industries to strengthen program (Benefit)
21 © EAGLE Food Registrations Inc CONFIDENTIAL SQF – Basic Facts & Benefits Provides discipline for document control SQF Practitioner responsible for program (Benefit) Includes 12 Step HACCP Plan Food Safety Fundamentals Details for building and equipment design and construction Specific PRPs with defined criteria Special attention to identity of preserved foods (i.e.; Kosher, Organic) Requires verification and validation of system Includes quality – based on HACCP method (Benefit)
22 © EAGLE Food Registrations Inc CONFIDENTIAL BRC - Overview Developed in 1998 Published by the British Retail Consortium Developed in response to retailer demand Developed by BRC with contributions from retail, manufacturing, industry associations, and certifying bodies Edition 6 released 2011, effective 1/2012
23 © EAGLE Food Registrations Inc CONFIDENTIAL BRC – Basic Facts & Benefits Different schemes/standard by food sector categories Eight fundamental requirements HACCP based Includes quality (Benefit) Includes some elements found in ISO programs Document Control, Management Review, Internal Audits, etc.
24 © EAGLE Food Registrations Inc CONFIDENTIAL BRC – Basic Facts & Benefits Provides discipline for document control Includes 12 step HACCP plan Very prescriptive PRPs Special attention to foreign material control such as sharps control (Benefit) Requires verification and validation of system Auditor qualifications (Benefit) Strong in Europe/Canada and for exporting there (Benefit)
25 © EAGLE Food Registrations Inc CONFIDENTIAL FSSC Overview Newest of the three major GFSI standard Combination of ISO 22000, PAS 220 (ISO :2009) and a few more requirements in Part 1 of FSSC ISO was published in September 2005 Developed by joint effort of ISO & the food industry Truly a global standard - 14 different countries represented
26 © EAGLE Food Registrations Inc CONFIDENTIAL FSSC – Basic Facts & Benefits 100% Food Safety driven (Benefit) Does not include a quality component HACCP based – very specific requirements Includes pre-requisite programs PAS 220 (ISO :2009) Most aligned elements to 9001 (Benefit) Document control, resource management, management review, internal audit Not scored – aligns with 9001 progress (Benefit)
27 © EAGLE Food Registrations Inc CONFIDENTIAL FSSC Basic Facts & Benefits Provides discipline for document control Foundation for continual improvement Creation of a Food Safety Team Includes all steps in the development and implementation of a HACCP plan Control of non-conforming product critical (Benefit) Validation & verification of system Traceability
28 © EAGLE Food Registrations Inc CONFIDENTIAL Last revision changes to FSSC22000 Category M – food grade packaging - added to scope of standard with the use of PAS 223 −Previously it did not offer an approved GFSI standard to the packaging industry Audit time requirements – minimum on site Surveillance audit are FULL SYSTEM audits FSSC – Basic Facts & Benefits
29 © EAGLE Food Registrations Inc CONFIDENTIAL Future of Food Safety SQF, FSSC and BRC are benchmarking to FSMA Show gaps SQF completed GAP analysis and only a few FMS requirements fell short but they have many requirements that are more stringent Copy of this comparison is on the SQF website –
30 © EAGLE Food Registrations Inc CONFIDENTIAL Future of Food Safety Complete roll-out of FSMS More accountability Proactive not Reactive Culture GFSI keeping up with the changes in industry Unannounced audit Adding HACCP Hazards when identified More involvement with certified client recalls from auditing requirements Making a safer food chain!!!!
31 © EAGLE Food Registrations Inc CONFIDENTIAL Contact Information Questions For more information please call , visit or www.eagleregistrations.com