Sabal Food Safety Consulting

01/13/2021

Here is the link to one of the food safety chats with Bryan Armentrout about CCPs and Preventive Controls

Jose and Bryan discuss CCP's and Preventive Controls under FSMA and HACCP.

05/12/2020

Sixty one persons attended a 2.5 hour choir practice, including a COVID-19 symptomatic index patient. Then, 32 confirmed and 20 probable secondary COVID-19 cases occurred (attack rate = 53.3% to 86.7%); three patients were hospitalized, and two died. This the summary of a case study in Washington State.

Interesting to read as part of the root cause investigation of contagion and the implementation of effective measures to control the spread of the virus in food facilities.

On March 17, 2020, a member of a Skagit County, Washington, choir informed Skagit County Public Health (SCPH) that several members of the 122-member choir had become ill.

04/30/2020

On the vol 69, No 17 Morbidity and Mortality Weekly Report (MMWR), titled: "Preliminary Incidence and Trends of Infections with Pathogens Transmitted Commonly Through Food", the CDC compared the incidence of foodborne pathogens between 2016-2018 with the 2019 incidence.
Amazingly for me is that the summary of this report indicates: "The incidence of most infections transmitted commonly through food has not declined for many years" (Page 513).
This summary made me think about what we all commonly see publicized as a reference for foodborne pathogens incidence: 1 in 5 Americans get sick on an annual basis, 128,000 are hospitalized and about 3,000 die (about 8 per day).
During 2019, based on the MMWR report, FoodNet identified 25,866 cases of infections, 6,164 hospitalizations and 122 deaths. This is 0.3% deaths per day or approximately 1 death every 3 days.
Conclusion: we might not be reducing the incidence of foodborne pathogens since 2016 but I believe that, generally, we are doing better.

03/06/2020

On an email from the FDA today:
The FDA is "...concerned that some people wrongly think that the myriad of CBD products on the market have been evaluated by the FDA and determined to be safe, or that using CBD ‘can’t hurt.’ Aside from one prescription drug approved to treat two rare, severe pediatric epilepsy disorders, no other CBD products have been evaluated or approved by the FDA."
As of today, CBDs are drugs. Drugs must be approved by the FDA for its intended use, labeling claims and dose. Nobody can make food in the US when any of the ingredients is a drug (CBD). Food safety systems are designed to use "food ingredients". Otherwise, the food is adulterated by definition of the food Law (21 USC 342).

FDA is providing updates on its evaluation of cannabidiol products with the goal of continuing to protect public health and working to provide market clarity.

02/08/2020

Inviting anyone interested in attending to an introductory presentation about the FDA's Foreign Supplier Verification Program (FSVP). I'll be explaining the basics about this regulation. Here is the link to the Eventbrite website
https://www.eventbrite.com/e/intro-to-fsvp-foreign-supplier-verification-program-tickets-91811248917?aff=js

How to prepare for compliance with new rules for food importers

02/04/2020

FoodForum Conference Keynote Speaker in Guadalajara, MX

01/22/2020

For second year in a row, the regulatory requirement with most violations is 21 CFR 1.502(a). Importers of food regulated by the FDA for sale in the US don't have developed a Foreign Supplier Verification Program.

09/06/2019

Food Safety Culture is something that is not going to happen without senior management involvement.
"Trust in senior leadership, including decisions leaders make and leadership communications often are key drivers of organizational engagement and so potentially impact performance. It therefore is leadership’s role to inspire, motivate, role model and live values & behaviors and to communicate."
This is what will be evaluated in the future during GFSI benchmarked schemes' audits. Are we prepared?

Leadership is critical to formulating and implementing strategy and implementation requires strategic leadership

06/15/2019

After reading the first few pages the Gallup report "State of the American Workplace" I couldn't stop sharing my first thoughts about culture and engagement in the food industry.
We are very committed to develop, implement and maintain food safety systems. However, systems ONLY work when people perform their assigned duties effectively. Question: What is their level of commitment?
When reading the introduction, written by Gallup's CEO, I was just shocked: "The American workforce has more than 100 million full-time employees. One-third of those employees are what Gallup calls engaged at work. They love their jobs and make their organization and America better every day. At the other end, 16% of employees are actively disengaged — they are miserable in the workplace and destroy what the most engaged employees build. The remaining 51% of employees are not engaged — they’re just there".
Really?
And now, food safety auditors are going to be evaluating the "food safety culture" of a company. Are food safety auditors qualified to evaluate culture?
Fact: without the proper culture and engagement, it's possible to have an employee that belongs to the 16% group monitoring a CCP or Preventive Control. Right?
What are we doing to improve the food safety culture in our facilities?

04/17/2019

In the US, it is a fact that dietary supplements are considered food under regulatory requirements and yes, with a few specific regulatory requirements. Which this in mind, the definition of "food" in 21 USC 321(f) means (1) articles used for food or drink for man or other animals, (2) chewing gum, and (3) articles used for components of any such article. To make dietary supplements, manufactures MUST assure that only ingredients recognized as "food" are used! Anything that is not "food" will make the finished product "Adulterated" as defined in 21 USC 342.

03/27/2019

Continuing on the "engagement" topic, "engagement, in its purest form, is how much someone cares about their work, their co-workers and their organization"
How to engage people? Can you train people on engagement?

Engagement is something all top organizations share, but it's easy for leaders to get it wrong.

03/24/2019

Effective food safety (...and quality) systems desperately need workers' commitment and dedication at all levels. The chart from the NYT article indicates that about only 1/3 of the workforce is engaged.
All companies train people. However, assuming the data in the chart is accurate, 2/3 of the workforce is not engaged with their assigned duties. How does this affect companies in the food, beverage, and feed industries? Besides training, are we doing something else to promote engagement?