FOOD SAFETY INSPECTION REPORT For SYSCO. #SYS-B-195 FreshPoint Nashville 740 Massman Dr. Nashville, TN 37210

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1 FOOD SAFETY INSPECTION REPORT For SYSCO #SYS-B-195 FreshPoint Nashville 740 Massman Dr. Nashville, TN TYPE OF AUDIT INSPECTION DATE April 20, 2010 AIB International Inc Bakers Way PO Box 3999 Manhattan, KS ( ) ( ) Fax ( )

2 RATING A Food Safety inspection was conducted at this facility on April 20, The writer was accompanied throughout the inspection by David Smith, Risk & Safety Training Manager. At the conclusion of the inspection, a meeting was held to discuss the observations, recommendations, and rating. 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 (950) 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-195-p.1

3 RATING ANALYSIS DATE OF INSPECTION: April 20, 2010 TYPE OF INSPECTION: Unannounced OVERALL RATING: SUPERIOR OPERATIONAL METHODS AND PERSONNEL PRACTICES 200 MAINTENANCE FOR FOOD SAFETY 170 CLEANING PRACTICES 195 INTEGRATED PEST MANAGEMENT 200 ADEQUACY OF FOOD SAFETY PROGRAMS 185 TOTAL: 950 #SYS-B-195-p.2

4 Discrepancy Totals Serious Items Total: 0 Improvement Needed Items Total: 2 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 MS Two light fixture covers suspended over the aisle in the area were cracked. Neither lens was over exposed product. (IMPROVEMENT NEEDED) Cracked light fixture covers were found in front of racks C015A and A092A, neither lens was over exposed product. Both had been identified on the product safety audits. The budget for replacing the lenses should be reviewed by the company and product safety committee. (IMPROVEMENT NEEDED) MINOR ISSUE NOTED MS MS CP AP The walls on the outside of the facility behind the truck bumpers need the concrete behind the metal bumpers being hit by trailers repaired, to repair the broken/cracked concrete. The top barbed wire strands on the security fence around the facility was damaged/broken. The wire should be repaired or replaced as needed. Minor cob webs were found on the ceiling above the dock doors. More detailed inspection is needed with a high intensity light to identify the cob webs. 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. The facility should review its budget regarding replacing damaged light fixture covers. The covers should be replaced when they are found either by the facility or the company who is leasing the property. #SYS-B-195-p.3

5 COMMENT OP OP OP OP OP OP OP OP OP OP 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, including rejected shipments, was maintained. A temperature check is performed on each load received, the checks are documented. 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 to facilitate cleaning, inspection, and pest control activities. The receiving date (expiration date if available) is used to maintained stock rotation. Storage areas were clean, well ventilated, and dry. Materials in storage were protected against contamination. Packaging materials, toxic chemicals, non-product materials, and R& D materials were segregated. Ingredients, packaging supplies, and other materials were rotated on a "First-In, First-Out" basis or other verifiable method to ensure stock rotation. A formal procedure was not in place to monitor and repalletize insect-susceptible raw materials that were stored for more than four weeks, because the facility only handled fresh produce, none of which was kept longer than 4 weeks. Pallets were clean, dry, and in good repair. The facility ships in corrugated boxes, no slip sheets are used. A designated rework area was provided to segregate rework and salvage materials. Rework/Salvage materials were identified for traceability. Any produce which does not meet quality requirements is disposed as trash. Release procedures were not a defined requirement for materials stored at this facility. All product must meet the USDA standards for fresh fruit and vegetables to be used for shipments to customers. Sampling of incoming raw materials for testing was not conducted at this facility. Quality testing is done on products received, visual, brix and taste samples are done on various products. Trash or inedible waste were in properly identified and covered containers. 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 facility has one chest freezer and several walk in coolers, all have recorders and are monitored twice daily manually, the facility also has a computerized system which monitors the cooler temperatures 24 hours/day, seven days/week. #SYS-B-195-p.4

6 OP OP OP OP OP OP OP OP OP Incompatible materials were stored under conditions that prevented cross-contamination. Protective measures were in place in areas where iced product was stored over like or dissimilar items to prevent product contamination. The iced product was stored on the bottom tier in the racks or with drip pans if stored on an upper tier. Allergens were tagged and segregated in the racks in the cooler. Containers and utensils were not used for product handling at this facility. There were no processing rooms at this facility. 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. Security locks were provided and documented for outbound materials. The facility maintained a daily truck wash log for the company trailers used to ship product. The trailers are pre-cooled and a log is maintained of the pre-cooled trailer temperatures. The temperature of the trailer is recorded at every customer delivery. All trucks are maintained on a PM program through an outside contractor. Adequate hand washing stations were located at appropriate locations and were stocked with single-use towels or air dryers and sanitizers as appropriate. "Wash hands" signs were displayed by sinks and entries into storage areas. The facility had anti-microbial hand soap in the restrooms. The facility also had purchased hand sanitizer in the restrooms and work areas which were supplied to employees. Washrooms, showers, and locker rooms 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, monthly, 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. The facility managers monitored hand washing through training and visual observation. 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. No violations were noted being done by any visitors in the facility. All visitors must read and sign the company GMP policies sheet before being allowed to enter the facility. #SYS-B-195-p.5

7 MS MS MS MS MS MS MS MS MS MS MS MS Facility boundaries were defined and controlled. Measures were in place to prevent contamination from local activities or neighboring properties that affect the facility. The facility is located in an industrial park. Outside grounds were maintained in a way that prevents product contamination. Measures included, but were not limited to, managing drainage, litter, weeds, and dust and maintaining waste and equipment graveyards to eliminate pest attraction to the facility. Some measures were taken to maintain facility security. Security strategies included fencing, locked doors, limited access to sensitive areas, surveillance cameras, truck seals, employee screening, and awareness or training programs. Adequate space was observed between equipment and structures to facilitate accessing for cleaning and maintenance activities. 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 leaks, condensation, flaking rust, flaking paint or loose material above any product zones. 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. Those that could not be protected were accounted for in the Glass, Brittle Plastics, and Ceramics Program. Adequate ventilation was provided in the facility. The facility did not have HVAC. The facility doors were only opened when shipping or receiving product. The facility did not have any air ventilation systems which required insect screens. Adequate barriers were in place to prevent rodents, insects, and birds from entering the facility. Cracks, crevices, and other pest harborages 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. All operations in the facility were separated by walls, due to the different storage temperatures maintained. 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. #SYS-B-195-p.6

8 MS MS MS MS MS MS CP CP CP CP CP CP CP CP CP There were no food contact surfaces at this facility. No processing was being done in the facility. Any quality sorting or examination of product was done using carts which were cleaned and sanitized after each use. Temperature measuring devices, including thermometers and recording controls, were installed in coolers, freezers, or other temperature-controlled storage areas. The facility does weekly calibrations for the thermometers using a NIST certified thermometer. The NIST thermometer had a certification letter on file. The Safety/Risk Manager gets a print out 2/day and the facility performs manual checks 2/day of all temperature readings. Transporting equipment, such as forklifts and pallet jacks, was maintained to prevent contamination of materials. These pieces of equipment were serviced by an outside contractor. The daily equipment checks performed by the company operators and the outside service were on file and current. Parts were stored off the floor in a clean environment. A Program was in place to monitor water quality, and records were provided. The Program included water a potability test conducted by an outside laboratory. No water or ice were for food contact in the facility. Back siphonage devices were provided and records of checks, performed annually, of the devices was current. Hand washing facilities provided hot and cold running water. Hand washing facilities were labeled. The facility had foot pedal operated hand wash stations. The battery charger area, maintenance room and uniform storage area were clean and well maintained. The room was clean and well maintained. The room only used temperature, 78 F, to ripen, no gas was used to ripen product. The chest freezer in the area was clean and well maintained. The floors, walls and ceiling in the area were clean and well maintained. The dock area floors and walls were clean and well maintained. The cooler floors, walls, ceiling and product racks were clean and well maintained. The dock pits, parking lot and perimeter grounds around the facility were clean and well maintained. Cleaning was done in a way that prevents contamination of raw materials, products, and equipment. 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 labeled to separate them based on their intended use. #SYS-B-195-p.7

9 CP CP CP CP IPM IPM IPM IPM IPM IPM 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. The facility does daily floor sweeping and runs a floor scrubber twice/week. 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. The facility stored fresh produce, any daily product stored was finished product, no processing was performed by the facility. Maintenance cleaning appeared to be completed in a way that prevented product contamination. No unattended maintenance parts were found in the facility. 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 facility program was a combined system using an outside PCO and facility personnel. An annual facility assessment that addressed all areas inside and outside of the facility was documented. An assessment had been performed by the outside PCO on 3/10/10. The facility did not manage their IPM Program under an alternative guideline. A signed agreement was in place with the Steritech 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, a current list of approved chemicals, emergency call procedures, service records to be maintained, and notification requirements for changes in materials or services. The outside PCO comes 1/month and the facility conducted interior and exterior trap inspections weekly. Current copies of certification or registration documents were on file for all persons providing IPM services for the facility. The facility had on file the PCO license, business license, certificate of insurance and the GMP training certificate of the outside PCO. 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 pesticides used in the facility Contrac Blox, Generation Blue Max Mini, Advance Dual Choice, Propoxur and Advion Ant Gel Max Force FG. #SYS-B-195-p.8

10 IPM IPM IPM IPM IPM IPM IPM IPM IPM IPM IPM 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. 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. The weekly checks were on file and up to date. A detailed facility survey was documented and used to determine placement of all pests monitoring devices. A current site map that lists the locations of interior and exterior pest control devices was on file. 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. These stations were tamper resistant, properly positioned, anchored in place, secured, and properly labeled in compliance with regulatory requirements. The traps were checked monthly by the outside PCO and weekly by the Risk/Safety Manager. All documents were current and on file. 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. The traps were inspected monthly by the outside PCO and weekly by the Risk/Safety Manager. Insect light traps (ILTs) were used in the facility to aid in monitoring insect activity. These traps were more than 10 feet (3 meters) from exposed products. The traps were scheduled for weekly cleaning and monthly cleaning. A record of the service, cleaning, and activity levels of each ILT was maintained. The bulbs were changed 9/20/09. Pheromone monitoring devices were not used to monitor insect activity in this facility. Bird activity was not noted in or around the facility. Wildlife, including domestic animals, was not observed at the time of the survey. Pest habitats and pest activity were identified and eliminated. No evidence of rodent or insect activity was noted in or around the facility. #SYS-B-195-p.9

11 AP AP AP AP AP AP AP AP AP The facility had a documented policy statement outlining its commitment to produce safe and legal products. The statement is reviewed with employees during the annual GMP orientation. The statement was signed by the President and General Manager. 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 Safety/Risk Manager. The Safety/Risk Manager was responsible for keeping current on regulatory, food safety, industry and technical developments. The facility was licensed by the State and the license was current and on file. Written procedures were established to define step-by-step processes to ensure product safety. The job descriptions were on file in the company position handbook. 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. The facility conducts exit criteria testing for all employees trained in the facility, documentation was on file. A multidisciplinary Food Safety Committee was established to conduct monthly inspections of the entire facility. Documentation of the monthly inspections included identified observations, specific assignments, Corrective Actions, and actual accomplishments. The product safety addressed any findings committee, with documentation for verification. A risk-based audit of procedures was documented by competent inspectors. Audit documentation included identified observations, specific assignments, Corrective Actions, and actual accomplishments. The facility maintains a change log summary, also a change date is placed on the document. 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. The log was up to date, all complaints were reviewed by the product safety team. The complaints are charted and categorized to try to prevent repeating items. A written Chemical Control Program that addresses all chemicals used in the facility was established. The facility had a limited number of chemicals, which were all monitored in the system. A documented Allergen Control Program was in place to address the allergens handled or stored at this facility. The allergens stored in the facility were identified and segregated in the storage racks. #SYS-B-195-p.10

12 AP AP AP AP AP AP AP AP 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 audits were done monthly in conjunction with the monthly GMP audits. 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 affected handling and storage of food products and packaging materials. A formal Preventive Maintenance Program and work order system, using outside contractors, was used to prioritize problems in structural and equipment maintenance. Incoming ingredients, packaging, and transports received into the facility were inspected by trained personnel according to established written procedures. 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 had an inspection by the Tennessee Department of Agriculture, all minor violations had been corrected. The facility had contracted a new waste management company, to correct problems noted on the inspection. Evidence of registration under the FDA Bioterrorism Act was on file at the facility. The facility had conducted a Vulnerability Assessment, performed annually, to identify food defense risks. The food defense plan was on file, with all the required elements. 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 last mock conducted was September 8, #SYS-B-195-p.11

13 AP AP A written Program was in place to control nonconforming products, including work-in-progress, finished products, and returned goods. Corrective Actions equal to the seriousness of the risk appeared to be taken. Returned goods if accepted cannot have left the possession of the company. If the product has it must be examined by the quality department before being disposed of, any product that does not meet quality standard is sent to trash. 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. Documented training was current for management and non-management personnel and for those with designated CCP responsibilities. The produce stored in the facility did not have any CCP's. The cross docked seafood brought into the facility had one CCP, temperature. The HACCP Plan was validated by the Safety/Risk Manager. #SYS-B-195-p.12