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Please feel free to email me with additional questions after the webinar.  You can also email if you would like to take the acidified foods course at 50% off ($150).  I will need to get a discount code that you can use to register at the reduced price.  That offer would only be for regulators and coupon codes expire in a month.

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A few more Q&As

Q: What is the reference for this table presented in the webinar?

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The FDA has begun inspections under the new Preventive Controls for Human Foods rule.  Many operators have been caught unprepared when FDA requests an in-depth verification and validation of their hazard analysis within their food safety system.  Dr. Nummer will cover some best practices for the hazards analysis and verifications of the hazards analysis.  This includes an introduction to the concept of the “decision-making” document.  In short, why is a step in your food process controlled at the GMP, operational prerequisite, or critical control point levels?

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Have you put much thought into what and how you train your staff?  Did you measure their learning in the short-term and long-term? Dr. Nummer has long advocated food safety is “people, tools, and process”.  We do process food safety very well.  We often ignore “people and tools”  food safety.  With the rollout of FSMA, the FDA introduced the term “qualified”, FDA-speak for knowledge, skills, and abilities.  Staff and supervisors can be qualified through experience or become qualified via training and education.  Dr. Nummer will discuss the supervisor’s viewpoint of training and education along the food safety continuum from GMPs to ISO22000.  Some of the points covered are what to teach, how to teach, or isn’t the 600-page manual sufficient?  Do FDA or GFSI schemes require training records? How do supervisors verify staff perform critical controls?

View USU’s Professional Master’s of Food Safety and Quality Online Program teaser [Link].

This question comes up often.  ROP requires HACCP.  No ROP, no HACCP.

First, a common item exclusion for a different reason.  All acid foods pH ≤ 4.2 are non-TCS.  As a non-TCS food, no HACCP.  So, cold bagging dressings, acidic sauces, etc does not require HACCP because its non-TCS.

What about cold bagging TCS foods, like proteins?  The answer from FDA is no vacuum or removal of air, not ROP, no HACCP.  Read their interpretation carefully.

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Note concerning USDA oversight of Restaurant commissaries creating meat products.  This is 9 CFR 303.1.  Note the requirement that the commissary staff must deliver the foods to satellites.  A third party shipper cannot be used.  If third party delivery is used the operation must be under USDA inspection.

§ 303.1 Exemptions.  (iv)(c).  For purposes of this paragraph, operations conducted at a restaurant central kitchen facility shall be considered as being conducted at a restaurant if the restaurant central kitchen prepares meat or meat food products that are ready to eat when they leave such facility (i.e., no further cooking or other preparation is needed, except that they may be reheated prior to serving if chilled during transportation), transported directly to a receiving restaurant by its own employees, without intervening transfer or storage, maintained in a safe, unadulterated condition during transportation, and served in meals or as entrees only to customers at restaurants, or through vending machines, owned or operated by the same person that owns or operates such facility, and which otherwise meets the requirements of this paragraph: Provided, That the requirements of §§ 320.1 through 320.4 of this subchapter apply to such facility. Provided further, That the exempted facility may be subject to inspection requirements under the Act for as long as the Administrator deems necessary, if the Administrator determines that the sanitary conditions or practices of the facility or the processing procedures or methods at the facility are such that any of its meat or meat food products are rendered adulterated. When the Administrator has made such determination and subjected a restaurant central kitchen facility to such inspection requirements, the operator of such facility shall be afforded an opportunity to dispute the Administrator’s determination in a hearing pursuant to rules of practice which will be adopted for this proceeding.

  1. Special processes 3-502.11
    1. No mention of drying
    2. No mention of fermentation
    3. Question on canning foods in hermetically sealed containers (acid and low acid?)
  2. Fish ROP 48h rule.  Move to 3-502.11 that requires a variance (no HACCP?) so that RA can make sure safe process, or ?
  3. Did the option to remove ROP 30 d 34F to 7 day 41F get into code?
  4. ROP requirement for a manual 2X daily check of a frig with datalogger.