FSMA, the FDA’s Federal Food Safety Modernization Act, is here. We are now in the year, or two, of compliance for most companies. This is the headline driving many of you to pursue food safety certification. In many cases, your buyers have already asked for it.
In order to take the first step on this journey, it would be helpful to understand the food safety universe a little and some of the acronyms.
HACCP- Hazard Analysis Critical Control Point, a NASA inspired process to analyze and document hazards to a process. http://www.fda.gov/Food/GuidanceRegulation/HACCP/ucm2006801.htm
GFSI- Global Food Safety Initiative, a collaborative standard to which many high level food safety standards certify to. www.mygfsi.com
Food Safety Standard- These can be private or accredited(many companies do them) standards against which the audit is done.
Certifier-CB- Certification Body- The actual company that manages the certification and arranges the auditor visit.
All of this food safety world existed before FSMA legislation. The regulation does require third party certification. This is just the measuring stick many buyers and companies will use to validate the plan put in place. The FSMA legislation just requires you have a compliant plan in place.
The deadline for business less than one million in sales to have a plan in place is August 30, 2018. For operations with more than one million in sales, but fewer than 500 employees, the deadline is August 30, 2017. If you are larger than this, you better have one in place already, but if not, you have until August 30, 2016.
Since your buyers or your boss are likely to require a 3rd party certification, you might as well use that as your guidepost for setting up a Quality Assurance plan. A good QA plan makes sure the facility produces a quality product with consistency. Food Safety is just an inherent part of this process.
There are three options to choose from before you start. The first is to just put a simple pl
an in place without certification. If you have a buyer like Whole Foods that requires some type of certification no matter how small your operation, you can contract with a private standard. When trying to land the larger distribution deal or client, you may have to go the GFSI route with an accredited standard.
For very small operators without the need or resources for a third party audit, you can find simple plans and record keeping systems on the internet. You will want some basic controls and records for product handling, cleaning and staff hygiene with the records to back it up. The one major requirement that many organizations will miss is the traceability. Keep logs of every roast batch with incoming green lots, and note the roasted lots going out to customers on the sales records. These lot codes can be as simple as the roast date.
You may have a buyer or internal request for an audit or certification without specification. There are private standards out there like UL and NSF for small operations. Call and get pricing along with a copy of the audit from either your buyers recommended company, or a couple private standards. You will use the audit to verify you have all the policies, procedures and records systems in place required to pass that audit.
If you are going for distribution deal or large client, chances are you will need to step up to a GFSI level audit. Most of these audits are extensive and resource heavy. They can require special staff certifications and several days. There is an exception now.
The PrimusGFS audit was designed as a Fresh Produce audit, but includes agricultural handling up to and including cooking and cutting(or roasting and grinding.) Maranatha Import Export, Inc was the first US based roaster pass this audit done by Food Safety Certifiers.
Preparation for a GFSI level audit can be much more substantial than an internal plan or private standard requires. These audits tend to be several hundred questions and all require a HACCP based plan with analysis of production. At minimum, you will either need someone to take an online or local HACCP course, or hire a HACCP consultant to do this part.
The HACCP plan and the standard chosen will determine the policies, procedures and records systems needed for the operation. Luckily for coffee roasters, the HACCP plans will all be very similar and have similar control points requiring monitoring such as de-stoner and magnets. There are even some sample HACCP plans for coffee available.
If you have a consultant working on the HACCP with you, be sure they have the standard you are working off. You should end up with one comprehensive plan. It may be a couple manuals such as a Quality Assurance Manual and a Good Manufacturing Process(GMP) manual, but they all work together. If you are an organic operation, include those operating guidelines.
Far too often we see operations ending up with 3 or 4 manuals and multiple records systems because HACCP was by one person, the food safety manual by another and the organic by somebody else. There should be one manual to run one business one way. Once you have the manual with policies and procedures along with a records system, it is time to check yourself.
Every GFSI audit requires a self-audit annually. You basically use the same standard the auditor is going to use. The first step is to review the HACCP plan and make sure the process flows and control points are still correct and being monitored. You then do the entire Food Safety audit on yourself.
The result of this annual review should bring up all the items that need correction. These are cleverly referred to as “Corrective Actions”. Once you have done the internal audit and the corrective actions, you can schedule the 3rd party audit with a certification body. This outside audit will lead to another set of Corrective Actions that need to be responded to before final certification.
Some big take-aways fom this should be that FSMA and your buyers will require action. There is a process that is not impossible to do. There are options that are right for your size. With the availability now of PrimusGFS for roasters, even a GFSI level certification can be achieved by medium sized roasters.
Food Safety Certifiers- http://www.foodsafetycertifiers.com/