INDUSTRY PERSPECTIVE: Human Food

Transcription

1 INDUSTRY PERSPECTIVE: Human Food Dave Cook Director of Global Auditing, Corrective & Preventive Action Kraft Foods Group

2 Industry Perspective: Human Food 1. What does systems thinking look like at Kraft? 2. What does training for corporate systems auditors look like at Kraft? 3. Based on your experience working in Global Food Safety Initiative (GFSI) on auditor competencies, how does Kraft s approach to training different than others in the industry?

3 Kraft s Food Safety Management System Fact and Scientific- Basis Written Food Safety Plans Continuous Learning and Improvement Implemented System of Controls

4 Managing Microbial Risk SAFE PRODUCT Consumer (cooking & refrigeration instructions) P R O C E S S F L O W Environmental contaminants Distribution (refrigeration) Packaging (modified atmosphere, preservatives, single use) Processing (heat, pressure, curing, etc.) Formulation (preservatives, ph, fat content) Ingredients (preservatives, irradiation, pasteurization) Environmental Contaminants Inherent food safety hazards - general controls - hurdle to prevent microbial survival

5 Kraft Systems-based Audits Auditing approach has evolved over time - Away from observation or task (e.g., checklist) to systems focus - Program, controls, data and implementation Similar shift occurred with USDA s implementation of HACCP Kraft uses a systems-based approach to strengthen food safety programs Advantages: - Effectively identifies risk and prioritizes food safety findings - More effective measure of compliance (regulatory and internal) - Promotes dialogue and good working relationships - Builds a culture of prevention and drives continuous improvement - Lines of communication to resolve questions, issues, and challenges

6 Programs Audited Examples of Programs Audited HACCP Sanitation Production Controls Allergen Control Period Cleaning GMPs Environmental Monitoring Pest Control Supplier Verification Other Controls Hygiene Training Recall Plan

7 Assigning Risks Zones Assigning risk zones to a manufacturing area is a control that helps minimize risk of cross-contamination. The implementation of zones may require other controls. 1 st Level Boiler #2 Oil Tk ph Shed Am moni a Maint. = Overhead roll up / sliding Air Comp. Spar e rm Intake/Receiving Water Soft. Heater Oil Storage Sched. Elect. Lunch Women s Restroom Men s Restroom Janit or s Dry Blend Wareho use Main Entrance 2 nd Tan k Level Lobby Conf. Ramp Dry Blen d Pit Tanks Grn M C C Back Entrance ISO Aud. Off. SSE Off. #1 Warehouse Label QA Main Off. Office Inv. Clerk Eng. Plat BAX Off. Lab Conf. Storage Offices Baler Bag Grill. Gri ll Of fic e MCC CIP Dryer #1 #1 Hallway Ferment Semi- Soft Stagin g M C C #3 Hallway Cook #3 Bag Elevator Semi- Soft Old Cooler Loadi ng Dock #2 #2 rest roo Salt m System Cheese Grinding Area #2 Warehouse Cooler Spare Motors Dryer #2 Op rm Bag rm Mix Raw Zone: N / A Raw meat/ raw milk/ raw nuts D r y e r # 2 Shp Off received High control zone: Product of high sensitivity can be exposed to the environment and/ or the operators Controlled zone: Product that are not highly sensitive can be exposed to the environment and the operators Non-manufacturing zone: There is no open product in this zone

8 Evaluating Zoning Start with conversation and overview of programs 1. Documented program including a map - Zones clearly identified 2. Preventive Controls in place to support the program - Distinctive uniforms, traffic patterns, Pathogen Environmental Monitoring (PEM) 3. PEM data supports zoning effectiveness - Findings monitored - Corrections or Corrective actions taken when necessary 4. Implementation on plant floor Not all gaps present the same risk Examples for discussion only Footbath sanitizer strength not properly documented (Opportunity for Improvement) An employee in wrong area isolated incident (Minor) No zoning program or multiple or significant gaps in program (Major) Direct raw to ready to eat cross contamination (Critical)

9 Developing Auditor Competency Technical Capability Auditing Skills Soft Skills Apprentice Program Calibration and Continuing Education Food Manufacturing Experience (3-5 years) American Society of Quality Certified Critical Thinking Trainee Observe Audits 0-6 months Monthly Auditor Calibrations Quality Fundamentals and Policy 3rd party certified practitioners Individual Development Plans Team Auditor 6 months 2years (Qualified) Annual Auditor Training Subject Matter Expertise Pasteurizers, Meat Science, Cheese Manufacturing, Technical Writing Behavioral Standards & Interviewing Skills Lead Auditor 2 years (Qualified) Policy Reviews HACCP Certified Audit Management Performance Reviews

10 Auditor Competence GFSI Auditor Competence Working Group Food Safety Inspector Food Safety Systems Auditor Define common core auditor competencies Train & test auditor technical capabilities Direct assess individual s critical thinking ability to apply skills during an audit Rigorous qualification and on-going calibration process for auditors

11 Summary Considerations A system based approach is suitable both for audits and regulatory inspections There is a well documented program Program is complete and adequate Plant can explain their programs Documentation and floor observation support compliance Observations are viewed through the lens of the relevant program(s) and food safety risk Systems Based Audits - A tool for identifying and characterizing food safety issues and addressing root cause effectively Sets achievable target of sound programs that find and address issues Enables prioritization of resources and more targeted follow-up Emphasizes programs at every step, so drives continuous improvement Promotes strong working relationship between the auditor and the facility Builds a culture of prevention