PLAYING IT SAFE

Food Safety Systems, Audits,
And Vendor Certifications

AS THE FOOD SUPPLY CHAIN has grown longer and more complex American consumers have been subjected to an ever more alarming series of food recalls; California spinach, Honduran melons, Mexican jalapenos and serrano peppers, and Florida tomatoes, just in the last year alone. Add contaminated hamburger and Chinese processed pet food and the list is long indeed. The list grows even longer still when you add in foods recalled for simple mislabeling (or not so simple if you happen to be allergic to a missing ingredient in a mislabeled product). Meanwhile, many of us in the coffee roasting world continue to ignore the implications of these recalls to our businesses.
     Many coffee roasters run their businesses with an underlying and ultimately mistaken belief that coffee is not a food product. Oh, sure, we all know coffee is a food; that it will ultimately be consumed by some discerning specialty coffee consumer sometime in the future. We use the requisite food words: freshness, origins, quality and that panoply of flavor terms on the taster’s wheel. However, often our actions belie our words. And nowhere is this hypocrisy more apparent than in our roasting facilities, many of which look like poorly organized chaos: open bins of roasted coffee often unlabeled or mislabeled, personnel with personal listening devices near moving equipment, packaging material strewn about, dark corners, poorly lit production and packaging areas, open hoppers over grinders, and dirty walls, rafters and floors. Face it, many of our facilities do not look at all like what a consumer would think of as a food manufacturing facility.
     So why do we do it? Because we can! Coffee, as a non-perishable, that is not quite raw (it still needs to be brewed) and that does not easily cross-contaminate or get cross-contaminated is a low priority for municipal, county and state inspectors overwhelmed with higher, riskier food inspection concerns. One only has to Google coffee-related deaths to see why we are such a low priority for food manufacturing inspectors: It just doesn’t happen.
     Even with the relative safety of coffee compared to other food products, coffee roasters need to respect coffee as a food; roasting as a food-manufacturing process and delivering the transparency and traceability that we demand of others. A good place to start is a Food Safety Audit.

What Is a Food Safety Audit?

     A food safety audit is a third-party audit, inspection or certification that checks a facility’s compliance with federal and state regulations, and/or generally accepted principles of good food manufacturing management, including safety, sanitation, hygiene and record keeping.
     These inspections are not unlike other third-party certification inspections that many coffee roasters already undergo, especially organic inspections. Inspectors are looking for high degrees of transparency and traceability in all aspects of your production, as well as a high level of sanitation in your manufacturing and packaging facility and good hygiene among your employees.

Where Do the Standards Come From?

Standards for the safe processing, handling and packaging of foodstuffs have existed in the U.S. for well over a hundred years. However, the standards regimes relied on today began to be codified immediately after World War II. And although some processes are customer-specific, many of the standards, regulations and checklists seek to comply with the International Organization for Standardization (ISO) for food manufacturing and management (ISO 22000:2005). Unfortunately, as with any bureaucratic endeavor, there is what seems to be an infinite number of overlapping organizations each with their own area of regulation, responsibility and expertise, as well as many acronyms and terms associated with food manufacturing compliance. To at least help unmuddy the waters a little, please see the list of food safety terms on page 25.

So Why Get a Food Safety Audit (FSA)?

The quick answer is three-fold: efficiency, lowered liability and increased sales.

Efficiency

As you research whether or not to undertake yet another inspection, you may notice that many of the requirements rely on process control, documentation, checks and quality assurance regimes (for organic certified roasters, you are already halfway there, as the USDA NOP is based upon many of these same concepts). Terms such as Best Practices, HACCP and GMP (see page 25 for definitions) may sound intimidating at first, however, as you research these further, you cannot help but notice that many of these concepts are based on efficient, repeatable and verifiable processes as well as common sense. With a little research and a little money, you may find a way to increase your profit margins by eliminating wasteful or redundant practices: lowering marginal labor costs, excessive product loss, energy costs, and possibly even material costs. All of the aforementioned programs are based on decades of practice by thousands of businesses—many in your own industry. Why not take advantage of their trials and errors in developing these standards and processes? Focusing on passing an audit can work as the catalyst to ensure that you will continue improving. It is an obtainable goal with a well defined set of criteria. Just set a realistic time line and you’re off to a higher profit more professional roasting operation.
     Additionally, by following the standards and instituting the processes necessary to maintain them, you will raise the professional level and morale of your staff. It is an often-repeated management truism that an investment in your facility and in staff training will increase worker productivity and happiness. Add increased employee productivity to the increased labor efficiencies of the new processes, and you are really cooking with gas.
     Finally, good processes can lower your costs by reducing the number and therefore the costs of errors. Small coffee roasters are especially susceptible to mislabeling errors as they are more likely to have multi-tasking and distracted employees on the packaging line. Applying some of the principles needed to pass an FSA audit can help lower your error rate. With shipping on the rise, this is especially important now, as reshipping mislabeled product or worse yet reshipping two orders that were mistakenly shipped to the wrong addresses (right order, wrong customer), can wipe out your profit margin and ruin an otherwise productive day.
     For many coffee roasters the initial value, perhaps even the entire value, of going through an FSA inspection is in the doing of the thing.

Lower Liability (and perhaps your liability insurance rate)

Although coffee roasters are perhaps the least susceptible group of food manufacturers to be sued for illness or death caused by product liability, we are still at risk. As a food manufacturer, your insurer often lumps you with other food manufacturers, not based on what you produce, but instead on your gross sales. FSAs are one way food manufacturers can lower both their actual liability as well as their liability rates. If you have to pay what other food manufacturing companies pay, why shouldn’t you save what they save? If you take the necessary precautions and get inspected and certified, you can have the same benefits.

Increase Sales

So let’s say that the lure of lowering your product liability costs and/or running a more efficient operation are not enough to convince you to consider undergoing a Food Safety Audit. How about increasing your sales?
     Over the last few years, the success of specialty coffee in the marketplace has convinced many of the large grocery, restaurant hospitality, and food distribution concerns and retail warehouse chains that they need specialty coffee on their shelves. Additionally, the slow and local food movements as well as the negative backlash felt by many larger retailers as they moved against smaller established businesses has opened the doors and shelves of these businesses to smaller and more local roasters. However, many of these corporations require a Food Safety Audit, vendor audit and often a site visit from corporate as well.
     These third-party audits and site visits (either a food safety or possibly a vendor audit) protect them from the liability associated with selling your or anyone else’s food products. In most cases there is no way around these requirements: they are non-negotiable if you wish to do business. Also, vendor audits nearly always have the added requirements of capacity and capability added to their inspections as well. Many of these companies want to know that you can safely produce what you say you can produce in the time you say you can produce it—safely. Unfortunately, many of these corporations will need you to complete these audits before you even receive a “for sure” on the possibility of supplying them. In other words, you will do it if you wish to get your fine coffee on those high-volume shelves.
     It is a good idea if you wish to start pursuing these types of customers that you go ahead and begin the process of getting your facility, employees, paperwork and processes in shape for an inspection. It is always better to look like a Boy Scout (prepared), than a lazy gambler (hoping for a lucky break). It may also keep you from wasting a lot of your own and someone else’s time chasing customers that you are not qualified to supply. Just ask yourself this question. “If they said yes tomorrow, could I begin to produce under their specifications immediately (provided you had the coffee)?”
     In short, food safety audits can help increase your sales by gaining you access to many accounts that you do not currently supply. In addition to the types of accounts already described, government and large non-profits often require some level of FSA or vendor certification as well. And once you have completed an FSA you should not have any trouble passing a vendor audit or any customer site visit, provided you have the requisite capacity. And with these larger accounts you are going to love your increased efficiency.

This Train Is a Comin’, Time to Climb Aboard While the Seats Are Cheap and Plentiful

The recent example of the Florida tomato cum Mexican jalapeño recall is a good example of what makes consumers so nervous. A national outbreak of salmonella was identified by the FDA as being caused by fresh Florida tomatoes. However, after much outrage from Florida growers (and millions in lost revenue), the FDA reversed itself and instead named fresh Mexican jalapenos as the likely culprit. Meanwhile consumers were confused by the cascading series of warnings, including trying to avoid fresh salsa, as the FDA worked to isolate the culprit. Consumers are concerned about the safety, transparency and traceability of their food supply, and rightly so, after incidents such as the one described above.
     It is just possible that with the coming change of presidential administrations that a new FDA or USDA chief may seek to restore credibility to the food supply chain by mandating a wholesale change in the way food manufacturing facilities are inspected, licensed and regulated. There may come a day when all wholesale food manufacturing facilities will need to undergo some sort of food safety audit. Where will we be then? Are we a food or not? Either way, perhaps it is time to get certified before the rush.

TERRY DAVIS is the president of Ambex, Inc., an equipment manufacturer and distributor, and New Harmony Coffee & Tea, a retail/roastery in Clearwater, Fla. He is also is a member of the Tampa Bay Chapter of the Council on Foreign Relations, the Roasters Guild and the American Civil Liberties Union (ACLU).

ANSI (American National Standards Institute)
The leading body for the writing and setting of norms and standards for American businesses. ANSI is the American representative to the ISO. The Specialty Coffee Association of America is a member of ANSI seeking to help promulgate the evolving rules for quality and freshness in coffee.

Best Practices
A business concept or belief that there is one correct or best way to produce a desired product or outcome. Focuses on identifying and creating process and quality assurance tests to lessen or eliminate errors, waste and mistakes; closely related to process efficiency theory.

Codex Alimentarius (Latin for Food Code)
A group of internationally recognized practices, guidelines and standards for food production and food safety having consumer protection as a primary goal, as well as promoting fairness in the international food trade (not to be confused with fair trade, the Codex is seeking fairness in free trade). The Codex Alimentarius is maintained by a Commission Founded in 1963 by the Food and Agricultural Organization of the United Nations and the World Health Organization, both United Nations Organizations. The Codex Alimentarius is the basis for the ISO food manufacturing standards (ISO 22000:2005)

Food Safety Audits
Third-party inspections and certifications that rely on standards set forth by ANSI (or other relevant national agencies) in accordance with ISO guidelines, GMP, HACCP and any other regulation, practice or concept deemed relevant by the certifying agency.

GMP (Good Manufacturing Procedures)
A loose outline of manufacturing processes set out by the FDA that focuses on record keeping, pest control, employee hygiene, sanitation, equipment, quality assurance and complaint and recall procedures. Inherent in the FDA’s GMP is that manufacturers should be cognizant of, and use as relevant, new technologies and systems that can help a business alleviate contamination and errors in the manufacturing process (GMP).

HACCP (Hazard Analysis and Critical Control Points)
An approach to food and pharmaceutical safety through prevention of contamination. The focus of HACCP is on the use of process control to prevent contamination in the manufacturing process instead of relying on finished product testing. This is accomplished by identifying critical points in the food manufacturing, packaging, labeling and distribution pipeline where contamination or error is likely to occur. Currently only meat, poultry, juice and seafood operations are required to apply HACCP in all of their manufacturing and packaging operations. For all other food manufacturers, HACCP is recommended but not currently required.

ISO (International Organization for Standardization)
An international nongovernmental organization that helps set standards for a wide variety of products and processes. Most ISO voting members are national, or nationally recognized standard bodies. Currently 157 countries are represented in some way at ISO. ISO was founded in 1947 to help facilitate international trade. ISO 22000:2005 is relevant to food manufacturers. ISO TC34 is currently developing standards for coffee.

Third Party Certifications/Inspections/Audits
A testing and verification regime that relies on the independence of a duly licensed or recognized inspector/verifier when conducting inspections, verifications or audits.

Vendor Audits
Inspections required by certain food retailers and vendors in order to be an approved supplier for the organization. Often incorporates a Food Safety Audit as well as capacity and capability requirements defined by a contract or customer. These audits are often mandatory before entering final contract phase with larger food retailers, restaurants, or hospitality chains.