FOOD SAFETY INSPECTION REPORT For SYSCO. #SYS-B-139 FreshPoint of S. Georgia 313 Stiles Ave Savannah, GA 31415

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1 FOOD SAFETY INSPECTION REPORT For SYSCO #SYS-B-139 FreshPoint of S. Georgia 313 Stiles Ave Savannah, GA TYPE OF AUDIT INSPECTION DATE June 7, 2011 AIB International Inc Bakers Way PO Box 3999 Manhattan, KS ( ) ( ) Fax ( )

2 RATING A Food Safety inspection was conducted at this facility on June 7, The writer was accompanied throughout the inspection by Mr. Ernie Lane, Safety Director; Mr. Sean Coenen, Purchasing; Mr. Stever Tipton, Operations Manager. At the conclusion of the inspection, a meeting was held to discuss the observations, recommendations, and rating with Mr. Ernie Lane, Safety Director; Mr. Sean Coenen, Purchasing; Mr. Stever Tipton, Operations Manager. Based on the observations made, the information obtained, and the criteria set forth in the AIB International Inc. Consolidated Standards for Inspection: Food Distribution Centers, the overall food safety level of this facility was considered to be: SUPERIOR (935) AIB International Inc. states that this report as dated and provided herein is to be construed as its findings and recommendations, category scores, total score, and rating. A passing score of 700 and above is not a certification of the facility, products or programs. AIB International Inc. does not accept or assume responsibility for the Prerequisite and Food Safety Programs in effect with (customer). AIB International Inc. is only reporting the food safety conditions of (customer) as of the date of this report and assumes no responsibility or liability as to whether (customer) does or does not carry out the recommendations as contained in this report. #SYS-B-139-p.1

3 RATING ANALYSIS DATE OF INSPECTION: June 7, 2011 TYPE OF INSPECTION: Unannounced OVERALL RATING: SUPERIOR OPERATIONAL METHODS AND PERSONNEL PRACTICES 185 MAINTENANCE FOR FOOD SAFETY 175 CLEANING PRACTICES 195 INTEGRATED PEST MANAGEMENT 190 ADEQUACY OF FOOD SAFETY PROGRAMS 190 TOTAL: 935 #SYS-B-139-p.2

4 Discrepancy Totals Serious Items Total: 0 Improvement Needed Items Total: 1 Unsatisfactory Items Total: 0 FACTUAL OBSERVATIONS AND SPECIFIC RECOMMENDATIONS OP = Operational Methods and Personnel Practices IPM = Integrated Pest Management MS = Maintenance for Food Safety AP = Adequacy of Prerequisite and Food Safety Programs CP = Cleaning Practices IMPROVEMENT NEEDED MS Condensation was observed in the following areas of the facility: (a) Heavy ice build up from condensation was observed on the ceiling of freezer and on the top of case product that was being stored in there. (b) Minor condensation was observed on the ceiling behind racking sections B041A and D025A. It should be noted that this condensation was not over products. Prompt efforts should be made to address this issue, as the condensation was within a product zone/product area and considered to be a potential food safety hazard. (IMPROVEMENT NEEDED) MINOR ISSUE NOTED OP OP Footprints were observed on the outside cases of potatoes stored in racking section A010A. It was recommended that all employees be reminded to not walk on the products, as debris from their shoes can become a potential product contaminant. During the inspection, the writer observed a bag of sliced carrot sticks, Two 50lbs. bags of Cane Sugar, one bag of Breading Mix, one bag of Bleached Flour being stored on wooden pallets without a slip sheet. It was recommended that a slip sheet should be provided between these stacked ingredients in order to prevent any potential contamination concerns due to broken wood, foreign material, etc. #SYS-B-139-p.3

5 OP MS MS CP CP IPM Trash or inedible waste were stored in properly identified and covered containers. Trash was properly handled. It was noted that the lid was propped open due to overflowing trash in the outside dumpster. It was also noted that the trash bins located on shipping/receiving dock did not have lids and were attracting flies. It was recommended that the facility consider breaking down case containers prior to placing them into the dumpster in order to allow the lid to close properly. It was also recommended that the trash containers located on the shipping/receiving dock be removed. Only trash receptacles with lids should be used in this area. These recommendations will aid in the elimination of insect around this area of the facility. Lighting levels were adequate. Most fluorescent light tubes, light bulbs, essential glass, brittle plastics, and ceramics in the facility were of the safety type or otherwise protected from accidental breakage over exposed product storage areas. It was noted that the plastic protective film on several of the dock lights were beginning to peel. It was recommended that these lights should shatterproof and/or otherwise properly protected to guard against any accidental glass breakage or dispersion. During the inspection, several gaps were noted around outside doors to unoccupied sections of the building that were sealed off from the storage area of the facility. The writer observed gaps in the following areas: (a) A gap was observed on the bottom left side of the dock door to the old storage room located in the front of the building. (b) A gap was observed at the bottom corners of the sealed sliding doors to an unused storage area of the facility near bait station #4. It was recommended that the facility seal these areas in order to prevent the ingress of pests and insects. This will also facilitate the cleaning and pest control activities in this location. Trash build up was observed in the left corner near the entrance of the "C" cooler. It was recommended that daily housekeeping task are completed to support the work area. A dead lizard and cock roach was observed near the wash bay/cleaning area located in the dry storage area. These areas were cleaned upon being brought to the attention of management. A detailed facility survey was documented and used to determine placement of all pest monitoring devices. A current site map that lists the locations of interior and exterior pest control devices was on file. It was noted that there was no record of interior traps checks after May 24, It was recommended that the facility records all services performed on all pest-monitoring devices. #SYS-B-139-p.4

6 IPM AP AP Exterior pest monitoring devices, such as traps or bait stations, were provided for exterior rodent control. Exterior rodent monitoring devices were installed around the exterior perimeter of the facility at appropriate intervals. Most stations were tamper resistant, properly positioned, anchored in place, secured, and properly labeled in compliance with regulatory requirements. Bait station(s) #7, #10 and #48 located along the exterior perimeter of the building were not secured in place. Exterior Bait stations were monitored on a monthly basis. Fresh bait was supplied in the stations randomly examined. Minor Feeding activity was noted around bait station #11. All bait stations should be locked and secured in place to prevent any potential tampering issues and to meeting AIB International and EPA requirements. The facility had a written policy stating that no glass, brittle plastics, or ceramics were to be used in the facility, except where absolutely necessary. Included in the policy was a procedure to handle any breakage in the facility. A list of all essential glass brittle plastics and ceramics was developed. The list of all essential glass brittle plastics and ceramics was audited daily to ensure that any accidental breakage was found and addressed. The inspection documentation was current and complete. It was recommended that the dock lights are added to this program to ensure that are being checked for the issues observed during the AIB inspection. A formal Preventive Maintenance Program and work order system was used to prioritize problems in structural and equipment maintenance. It was understood that the maintenance services were performed by outside contractors. It was also understood that service records for routine maintenance were kept at the facility's sister facility in Jacksonville, FL. The writer reviewed PO records provided from March 29, 2011 and April 26, It was recommended that continued emphasis be placed on ensuring that maintenance issues, such as the condensation buildup in the freezer are identified and promptly eliminated, this was a potential food safety hazards that was observed during the AIB International inspection and outlined in the text of this report. COMMENT OP Transports/containers and ingredients were inspected upon receipt for cleanliness, pest activity, structural defects, or other issues that could jeopardize product integrity. Inspection documentation was maintained. It was understood that no materials had been rejected. Procedures were maintained for the rejection of materials. Temperature documentation was maintained for refrigerated loads. The writer reviewed inspection records provided from June 6, #SYS-B-139-p.5

7 OP OP OP OP OP OP OP OP OP OP OP Food products were stored and removed from storage to prevent product contamination. Materials were stored off the floor and 18 inches (45 cm) away from the wall. Adequate space was provided for accessing areas to facilitate cleaning, inspection, and pest control activities. No materials were stored outside. Receiving labels were visible on the bottom unit of the individual container. These dates were a permanent part of the packaging material. Storage areas were clean, well ventilated, and dry. Materials in storage were protected against contamination. Infrequently used raw materials are included in this inspection. Packaging materials, chemicals, and non-product materials were segregated. No special handling procedures were required. Materials returned by customers are inspected and dispositioned by authorized personnel. Packaging supplies and Produce were rotated on a "First-In, First-Out" basis or other verifiable method to ensure stock rotation. A formal procedure was in place to inspect insect-susceptible raw materials that were stored for more than four weeks. The writer reviewed monthly Dry Goods Inspections from January May Pallets were clean, dry and in good repair. Pallets were not stored outside. Slipsheets were placed between most pallets and bags of produce or products to protect ingredients from damage by the pallet. Rework was not performed at this facility. Release procedures were not a defined requirement for materials stored at this facility. Sampling of incoming raw materials for testing was not conducted at this facility. Single-service containers were not used at this facility. Materials, work-in-progress, and finished products capable of supporting the rapid growth of pathogenic microorganisms were properly stored. The writer observed the temperature of the freezer at 14 degrees, which was considered to be a high reading however work was being performed at the time of the inspection. The writer observed the temperature of the A,B and C coolers between degrees. Incompatible materials were stored under conditions that prevented cross contamination. This included segregation of hazardous ingredients, such as allergens. Systems were in place to reduce any potential physical, chemical or microbiological contamination risks. Storage guidelines were provided to prevent contamination. The writer also specific areas for the storage of allergen products. Containers and utensils were not used for product handling at this facility. There were no processing rooms at this facility. #SYS-B-139-p.6

8 OP OP OP OP OP OP OP MS MS MS MS All shipping vehicles were inspected prior to loading for cleanliness and structural defects that could jeopardize product integrity. Inspection documentation was maintained and included lot code designation, amounts, and the point of distribution to ensure traceability and recall. Finished products are handled and transported in a way that prevents actual or potential contamination. Finished products were loaded or transferred in covered bays to protect the product from weather damage. Adequate hand washing stations were located at appropriate locations and were stocked with single-use towels and pre-mixed sanitizers as appropriate. Washrooms and locker areas were maintained in an acceptable sanitary condition. "Wash hands" signs were displayed in restrooms, lunchrooms, and smoking areas. Lockers were inspected on a defined frequency, and no open food or drink was allowed. Trained supervisors were in place to monitor compliance with personnel practices. Personnel were observed washing hands appropriately, and good personal hygiene practices were observed. Personnel were not observed eating, drinking, or smoking in unauthorized areas. Personal property was stored in appropriate locations defined by company policy. Effective procedures were in place to ensure that personnel with boils, sores, infected wounds, infections, or other communicable diseases were not permitted to come in contact with food as required by law. All non-facility personnel, including visitors and contractors, followed the facility personnel practices requirements. All visitors to the facility were required to read and agree to adhere to the plants Good Manufacturing Policy before entering the facility. Facility boundaries were defined and controlled. Measures were in place to prevent contamination from local activities or neighboring properties that could impact the facility. The facility was located next to a drainage area that was filled with water. Outside grounds were maintained in a way that prevents product contamination. Measures included but were not limited to managing litter and weeds and maintaining waste and equipment graveyards to eliminate pest attraction to the property. The roof was accessed and found to be in good condition. Some measures were taken to maintain facility security. Security strategies included some fencing, locked doors, surveillance cameras, c truck locks, employee screening, and awareness or training programs. Adequate space was observed between equipment and structures to facilitate access for cleaning and maintenance activities. #SYS-B-139-p.7

9 MS MS MS MS MS MS MS MS MS MS MS MS MS CP Floors, walls, and ceilings throughout the facility were well constructed and maintained. Floor drainage was designed and maintained to allow access for cleaning and to prevent product contamination. There was no evidence of roof leakage. Fixtures, ducts, and pipes were properly installed and maintained to prevent contamination from loose material. Adequate ventilation was provided in the facility. Insect screens were provided on areas used for ventilation to prevent pest entry. Air handling equipment was maintained on the Preventive Maintenance schedule and was accessible for cleaning. No production contamination was noted during the inspection. Adequate barriers were in place to prevent rodents, insects, and birds from entering the facility. Cracks, crevices, and other pest harborage areas were eliminated and doors were pest-proofed to prevent pest entry. There were no processing rooms with equipment that required the use and control of food-grade lubricants at this facility. Operations were separated to prevent product contamination. The facility did not have any exposed recoup or processing areas that required a written temporary repair procedure for repair of these surfaces to be defined. There were no food contact surfaces at this facility. Temperature measuring devices, including thermometers and recording controls, were installed in coolers, freezers, or other temperature-controlled storage areas. Temperature measuring devices were monitored frequently and attached to mechanical failure alarms that activate when temperatures exceed set limits. Transporting equipment such as forklifts and pallet jacks were maintained to prevent contamination of materials. The transport equipment was listed on the Preventative Maintenance Schedule for routine maintenance, cleaning, and follow-up. Parts were stored off the floor in a clean environment. Water was provided to the facility from a Municipal Source. A Program was in place to monitor water quality, and records were provided. The facility sent a water sample to the Chatham County Health Department for analysis, annually. Back siphonage devices were provided, and records of checks of the devices was current. The writer reviewed backflow documentation from November 17, Hand washing facilities provided hot and cold running water. Hand washing facilities were labeled. Cleaning was done in a way that prevents contamination of raw materials, products, and equipment. #SYS-B-139-p.8

10 CP CP CP CP CP CP IPM IPM IPM IPM IPM Food approval documentation was not needed for cleaning chemicals and sanitizers used as there were no food contact surfaces requiring cleaning. Adequate cleaning equipment and tools were available and stored away from production and/or storage areas. Cleaning tools were identified to separate them based on their intended use. Daily housekeeping cleaning activities were carried out in a way that prevents contamination. Housekeeping activities were assigned to the appropriate department to maintain work and support areas. Deep cleaning of equipment and structures was conducted according to the Master Cleaning Schedule to prevent the development of microorganisms, insects, or foreign material. Periodic cleaning tasks complied with written procedures. Maintenance cleaning appeared to be completed in a way that prevented product contamination. There were no tools or debris observed in storage areas. There were no direct food contact surfaces and utensils in use at this distribution center. A formal Integrated Pest Management (IPM) Program with written procedures that included requirements of the facility's Prerequisite Programs was in place. The program was written and implemented by the contracted pest control company. An annual facility assessment that addressed all areas inside and outside of the facility was documented. An annual assessment was conducted by the contracted pest control company on March 9, The results and corrective actions were documented. The facility did not manage their IPM Program under an alternative guideline. A signed agreement was in place with the EcoLAB Company to provide IPM services. A copy of the service agreement included materials, the facility name, facility contact person, frequency of services, description of services, term of contract, equipment and storage specifications (where applicable), a current list of approved chemicals, emergency call procedures, service records to be maintained, and notification requirements for changes in materials or services. Current copies of certification or registration documents were on file for all persons providing IPM services for the facility. Current copies of licenses (expiring June 30, 2011), certificates of insurance (expiring December 31, 2011), and business licenses (expiring June 30, 2011) were maintained on file. Records of GMP training were also provided for PCOs providing service to the facility. The writer reviewed documentation for EcoLab personnel. All personnel entering the facility was required to read and sign in under the company's GMP Policy. #SYS-B-139-p.9

11 IPM IPM IPM IPM IPM IPM IPM IPM IPM Current copies of the pesticide specimen labels and Material Safety Data Sheets (MSDS) were on file for pesticides listed as being applied at the facility. The writer reviewed the pesticide specimen labels and Material Safety Data Sheets (MSDS) for Advion Cockroach Bait Gel, EPA# ; Weatherblok XT, EPA# ; Demand CS, EPA# A hard copy of the MSDS and sample label was missing for First Strike Soft Bait, EPA # A Material Safety Data Sheet (MSDS) and sample label should be obtained for the First Strike Soft Bait, EPA # that had been used by the pest control operator. This will help ensure that all pesticides are properly applied within the operation. It should be noted that a CD containing all the MSDS and sample label for the Materials used was located prior to the conclusion of the audit. Documentation of all pesticides, including rodenticides, applied on the premises included materials applied, registration number, target pest, amount applied, specific area where pesticide was applied, method of application, rate of application or dosage, date and time treated, and applicator's signature. Documentation indicated that the applications were made according to label directions. The certification number of the servicing PCO was provided. Pesticides and application equipment were not stored at the facility. The outside IPM service provider left a service report after each visit. These records provided documentation of the checks and findings for pest monitoring devices, descriptions of the current levels of pest activity, and recommendations for actions needed to correct conditions allowing a potential for pest activity. A pest sighting log was used and correction actions were documented. Records of the quarterly pest activity were provided. Mechanical rodent traps were installed to monitor rodent activity inside the facility and were properly positioned. The randomly examined traps appeared to be properly maintained. Traps were inspected on a weekly frequency. Insect light traps (ILTs) were not used in the facility to aid in monitoring insect activity. Pheromone monitoring devices were used to monitor insect activity in this facility. These devices were inspected on a defined frequency. The facility documented the types and quantities of insects found during device inspections and used the information to identify and eliminate the source of activity. Bird activity was not noted in or around the facility. Wildlife, including domestic animals, was not observed at the time of the survey. #SYS-B-139-p.10

12 IPM AP AP AP AP AP AP Pest habitats and pest activity were identified and eliminated. No evidence of rodent or insect activity was noted in or around the facility. The facility had a documented policy statement outlining its commitment to produce safe and legal products. The policy was signed by the President. The Policy Statement was regularly communicated throughout the facility. Management and staff were trained to understand and implement the Policy Statement. A current organizational chart was maintained. Responsibility and authority for ensuring food safety and defense and compliance with federal, state, local, and any other appropriate regulatory laws or guidelines were clearly assigned to the General Manager. The Organizational chart was signed off on May 2, 2011 by the General Manager. The facility kept current on regulatory issues, food safety issues, industry codes of practice, and scientific or technical developments through ,conference Calls, and Training Sessions. Based on a review of the facility and related documentation, an appropriate budget and adequate labor support appeared to be in place to maintain the timely acquisition of tools, equipment, monitoring devices, chemicals, and other required resources. Written procedures were established to define step-by-step processes to ensure product safety. The writer reviewed the job descriptions for the Plant Manager and Quality Assurance Specialist. It was understood that the General Manager was responsible for the duties of the Quality Assurance Specialist The alternates responsible for maintaining the Food Safety Programs were defined in the Organizational Overview document. Specific written procedures were on file for providing food safety training to all personnel and contractors. Records of new employee training and annual refresher training were maintained for all personnel. Refresher training was conducted monthly on different GMP/Sanitation and OSHA topics. Exit criteria were provided in the form of a Quiz. The writer understood that temporary employees were provided GMP training during the new hire orientation. A multidisciplinary Food Safety Committee was established to discuss issues observed during monthly inspections. The Operations Manager conducted monthly inspections on the entire facility. A checklist format was utilized to document these inspections. A review of these inspections indicated that they were up to date. Documentation of responsibilities and corrective actions were maintained. #SYS-B-139-p.11

13 AP AP AP AP AP AP A risk-based audit of procedures was documented by competent personnel. The documentation included identified observations, specific assignments, Corrective Actions, and actual accomplishments. These documents were reviewed according to the document reviewed program. Corrective Actions were set for observations and Corrective Actions were verified for completion. The auditors were independent of the areas assessed. The last review date was May 11, A written Program for evaluating Customer Complaints was established. This Program included a plan for quick distribution of complaint information to all departments responsible for implementing Prerequisite and Food Safety Programs. A written Chemical Control Program that addresses all chemicals used in the facility was established. The policy included a list of all hazardous chemical and Procedures for Receiving, Storage, Training and education, shipping, Contractor chemical (Pest Control), Material Safety Data Sheet (MSDS) or Chemical Safety Data Sheet archiving. A documented Allergen Control Program was in place to address the allergens used or handled at this facility. The Allergen Policy included procedures for identification and segregation of allergens during storage and handling, Prevention of cross contact or contamination during storage and shipping by using measures such as: Personnel awareness training and education, Allergen cleaning procedures, and Weekly allergen storage checklist. A formal documented Cleaning Program that included a Master Cleaning Schedule (MCS) for periodic cleaning assignments as well as a daily housekeeping schedule was developed and implemented in this facility. The MCS specified frequency, responsibility, post-cleaning evaluation techniques, and Corrective Actions. Written cleaning procedures were developed for all equipment, structures, and grounds that impacted handling and storage of food products and packaging materials. The writer reviewed the Standard Operating Procedure Warehouse floors, Cooler Walls, Racking It was noted that the transportation section, Jack and lift charging area cleanup, and verification was incomplete. Incoming ingredients, packaging, and transports received into the facility were inspected by trained personnel according to established written procedures. Documented procedures for the inspection of tractor trailer were defined in the receiving process, and included steps for evaluation for Material condition, presence of pest evidence, and trailer condition. Inspection documentation was complete and current. #SYS-B-139-p.12

14 AP AP AP AP AP AP A written Regulatory Affairs and Inspections Program was on file. The Program included a list of personnel delegated to accompany all inspectors along with a company policy regarding recording devices, cameras, records, and sample taking. The facility was inspected by the Georgia Department of Agriculture on April 22, The violation noted was corrected on May 6, The facility had conducted a Vulnerability Assessment to identify food defense risks. The facility had conducted the vulnerability assessment was conducted in October 12, A documented program was in place that met the minor requirement of the 2009 AIB Standard. A documented Traceability Program that addressed identification of lot numbers of products, rework/repack, and packaging materials was developed and in place. All finished products were coded and recorded. A written Recall/Withdrawal Program was on file. Distribution records were maintained to identify the initial point of distribution to facilitate segregation and recall of specific lots. The Recall Program was tested twice annually, and test results were documented. The writer reviewed Mock Recall Summary for Item code# conducted on December 6, The mock exercise was started at 1515 and ended at The facility was able to recover 100% of the product. A written Program was in place to control nonconforming products. Corrective Actions equal to the seriousness of the risk appeared to be taken. The facility maintained a Hold/Segregation policy that outlined procedures for receiving and shipping. It was understood that returned good were allowed back into the facility. A Hazard Analysis Critical Control Point (HACCP) Program was developed and implemented for processes and/or products. The HACCP Plan was signed and was managed by a trained HACCP team leader with assistance of HACCP trained team members. Finished Product Profiles were provided for each product produced. A current Process Flow Diagram was in place. The seven principles of HACCP were followed in the development of the HACCP Program and included a risk assessment for both the ingredients and the process. According to the assessment there were no CCPs identified in the ass Documented training was current for management and non-management personnel. It was understood that the HACCP Plan was validated by Freshpoint Corporate Quality Assurance Department. It should be noted that this facility did not handle fresh or frozen seafood. #SYS-B-139-p.13

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