Thursday, April 15, 2010
It has been some time since we have sent out an update, but that is because we have been very busy behind the scenes, gearing up for the official launch of our new web based tracking system - ConcernTrak. We unveiled the beta version of the system at the PTNPA Convention in January, and there was a great deal of interest. Since then, our IT team has been busy tweaking, testing, and readying the program for full scale commercial use.
This inexpensive, comprehensive, web based (no software to install or purchase) system will simplify product tracking. It incorporates a user feedback module - PerformanceTrak, which will quickly revolutionize purchasing by enabling you to check the ratings of different suppliers for a variety of food and commodity based products. This user rating system allows for a transparency that has never before been possible in our industry.
We are also in the process of redesigning our website to better reflect the ever widening scope of our services. For now, please visit www.commodityconcern.com.
PLEASE NOTE: The firstname.lastname@example.org email address is no longer functional. Our email is now email@example.com .
PEANUT CORPORATION OF AMERICA REVISITED
In January of 2009 we published an article on the peanut butter recall. (HERE is a link to that article.). Peanut Corporation of America has been out of the news for several months, but recently an NBC investigative news team released a report on Stewart Parnell, the owner of PCA. HERE is a link to the article and video.
The article discusses the impact the incident had on the industry, and reports that if there are insufficient funds available from Peanut Corporation of America's bankruptcy to settle the claims, victims will pursue lawsuits against manufacturers who unwittingly purchased peanut products from PCA.
Friday, January 22, 2010
When I joined this industry 20 years ago, cashews seemed be the nut category to monopolize the complaint department. Issues regarding infestation, foreign material, glass, hair, lead solder and various and other sundry items would be the topic of conversation at industry conventions. Unfortunately the progression of time, communication and technology has had little effect, and the problems we had 20 years ago still plague the industry today (although we did solve the lead solder dilemma with the advent of flexible packaging...) These issues still result in unnecessary cost to the product, in addition to wasted time and manpower.
Investigating Conditions at the Source
Several months ago we proposed an initiative to investigate conditions at the source that result in problems with cashews. During these difficult economic times, budgetary considerations must be taken into account. We have sharpened our pencil, and also have obtained a contribution that will offset costs associated with the project, so that we can offer this invaluable service for a fraction of the original price. Our hope is that the lower price will enable more participants to join the program and thus set the stage for the beginning of a new way to approach the sourcing of cashews and other agricultural commodities, while meeting new demands placed upon us as and industry by legislators, retailers and consumers.
The Need for Audits
The CCC has developed comprehensive, cost effective third-party supplier auditing programs for the nut and agricultural industry. Audits are a huge and necessary step to ensure quality and food safety.
Audits help form and cement the necessary partnership between the buyer and supplier. A good partnership helps both sides achieve their aims.
An audit is an effective way for a supplier to understand the exact needs/requirements of the buyer.
Buyers can assess the capabilities of suppliers. It's no good ordering 10 containers if the chosen supplier can only really produce 5.
Properly audited facilities can have a direct effect on a company's finances by proactively addressing issues that can have a significant effect on the bottom line, such as:
Glass: Glass found in food will cause a recall, and is particularly problematic because it is hard to detect and remove even if the food item is subject to further cleaning and processing.
Metal: Apart from being a health hazard in food (try eating razor blades) metal can damage valuable machines leading to loss of production.
Pests: Consumers absolutely hate finding live insects in their food, and dead ones receive the same response. But pests, especially rodents, birds and mammals carry a whole range of nasty diseases, such as salmonella, listeria nd E.Coli. Food contaminated with these organisms, or with live insects, will be recalled.
Personnel: It's a fact of life that humans carry many things that can contaminate food. It can be hair from someones head, or it can be more serious. Humans can carry and distribute diseases like salmonella, listeria and E.Coli.
Traceability: We need to understand where our food comes from. If we know where it has been then there is a good chance we can find out at what stage a particular problem arose and then take action to prevent the same thing happening again.
In addition, third party audits are soon going to be law. The Food Safety Enhancement Act of 2009, HR2479, has already passed. Page 51, section xii reads:
"The qualified certifying entity shall not be owned, operated, or controlled by a trade association whose member companies operate facilities that it certifies."
That's pretty clear. No trade association can do this. It must be third party. Additionally, this project, and existing conditions require more resources than traditional certification agencies can provide.
We are all aware that there are conditions in facilities that compromise the integrity of the food products they produce. There is a need to investigate conditions in these facilities so that manufacturers can come to grips with why problems are occurring, how they can be avoided, and who is reliable. We have assembled a program and with your support, are ready to go forward. I want to make it clear that this program was developed not with the intention of exposing poor manufacturing conditions as a way to discredit suppliers, but as means to identify what conditions result in compromised product and in turn develop programs to assist these companies to make necessary improvements and raise the bar of the industry.
Using seasoned auditors, we will conduct audits of a representative sample of 10 cashew processing facilities in Vietnam. Supporters of this effort will receive, in a timely fashion:
- Access to an expanding data base of audited vendors
- A white paper summarizing the results and assessing the state of the industry, based on analyses from an inspector who has 30 years experience in food safety inspections with a concentration in nuts and dehydrated fruit.
- Full audit report from each facility
Prior to this round of audits (scheduled in March 2010),supporters will be able to:
- Submit questions for our inspector that directly relate to the issues they want addressed
- Submit specific shippers to be considered for inspection.
By utilizing the pooled support of the industry, the CCC inspection program can eventually provide a world-wide audit program to its supporters at a fraction of what it would cost a single company. As a result supporters can advertise themselves as companies that are taking steps to proactively improve the supply of raw cashews, and eventually other imported nut and agricultural commodities.
How to Participate
Our funding goal for this project is $500.00 per participant. The average cost of an audit, not including transportation, accomodations, meals, etc. is about $1500 per audit, making this a very reasonable price for ten audits.
If you have any questions, or if your firm is interested in participating in this collective project, please contact us at firstname.lastname@example.org , or 804-745-2848, for more information. We will also have a booth at the upcoming Peanut and Tree Nut Convention.
We can do this, and we can do it cheaply if all the stakeholders participate!
Monday, January 18, 2010
On January 15th 2010 Hines Nut Company initiated a recall of 270 packages of pine nuts packaged under the brand name Harris Teeter Farms Market. According to the FDA press release (http://www.fda.gov/Safety/Recalls/ucm197825.htm the pine nuts were purchased from Red River Foods in Camarillo, CA and were found to be potentially contaminated with salmonella. To date there have been no complaints or any reported illnesses related to the product. However this incident is another warning about the vulnerabilities that the imported nut industry has regarding microbial contamination.
We urge any company that sells pine nuts, pine nut products, or any nut product that is sold raw for human consumption, to contact their supplier immediately to verify that the product has been tested for microbial contaminants, and that the integrity of the manufacturer can be verified.
Last year at the Peanut and Tree Nut Processors convention we mentioned that there had been an increase in rejections from customers who test for microbial contaminants in imported nut products, but emphasized that testing upon arrival was not a substitute for responsible sourcing, which includes taking steps to ensure that the overseas supplier adheres to good manufacturing practices, and that this integrity is present throughout the distribution chain. The entire presentation, entitled "An Ounce of Prevention, or a Metric Ton of Cure" can be viewed on our blog at this link: http://theresponsiblesource.blogspot.com/2009/01/ounce-of-prevention-ptnpa-2009.html.
Apparently in the present incident, a routine inspection by Red River Foods produced the evidence that the pine nuts have the potential to be contaminated with salmonella. But this one step does not ensure public safety, nor does it address the potential for contamination that may go undetected. We have emphasized on many occasions that testing upon arrival is not a substitute for ensuring the good manufacturing practices of suppliers. It is merely a validation step confirm these practices.
Historically the imported nut industry has had no organized programs for inspection of overseas facilities. Little is known about the conditions that exist overseas - conditions that could have a severe impact on the safety of the consumer, as well as devastating financial consequences to any company involved in a major recall. Warning signs of any kind are an indication of serious problems. The industry has had several warning signs in various nut products, and it is important that we address these issues head on, and that we address them immediately.
Our blog, which offers insight to the problems and proposed solutions, can be viewed at http://theresponsiblesource.blogspot.com
Wednesday, November 4, 2009
Recently, the GMA issued a draft document entitled "Industry Handbook for Safe Processing of Nuts". This 146 page guide explicitly details the processing procedures that the GMA members expect of their suppliers. As with many of the documents that we have seen recently it details what they want but it does not offer much in the way of "how" to achieve these goals. Alarmingly, while the requirements may be perfectly reasonable for US sourced commodities, many overseas facilities would fall far short of even the minimum standards.
At the core of the GMA's message is the emphasis that safety controls must be in place throughout the processing chain, and that accurate records must be kept.
"Today's nut industry relies on a web of inter-company relationships. Successful implementation of preventive food safety plans and supporting prerequisite programs are required at shellers, processors, and manufacturers to ensure effective food safety management. Preventing the production and shipment of contaminated or adulterated food is heavily favored over reliance on interventions once contaminated goods have entered distribution channels and, subsequently, the food supply" (Page 5, Industry Handbook for Safe Processing of Nuts)
Adapting to Changing Regulations
The standards for facilities that produce raw nuts are specifically detailed. As we move forward it is important for the industry to develop programs to address the conditions that exist in many overseas nut processing facilities so that roasters and processors can adapt to changing regulations. Without a doubt, in the near future there will be increased scrutiny of these facilities.
Even without knowing the specifics one can only speculate that cartons of imported raw nuts and seeds that frequently contain infestation, hair, foreign material, webbing etc. do not come from facilities that would pass the GMA's test. It makes sense to be proactive and begin now to identify those processing facilities that adhere to Good Manufacturing Practices, and to encourage those companies with compromising conditions to bring their facilities into compliance with 21st century food safety concepts.
Inspection and Assessment are the First Steps Inspection and assessment are the first steps towards a comprehensive food safety program. Many potential scenarios, such as salmonella contamination, cannot be dealt with on the basis of testing and corrective treatment. These problems will not go away without effort on our part. It's time for a change.
Wednesday, September 30, 2009
It has been awhile since our last post but we're still here!
We've been working on a third-party supplier auditing program for the cashew industry. Audits are a huge and necessary step to ensure quality and food safety. Audits get us information about conditions and specific companies overseas. Audits funded by the right parties - the roasters and manufacturers in the USA - get us the RIGHT information about conditions overseas. Importers can't do it alone.
And, third party audits are soon going to be law. The Food Safety Enhancement Act of 2009, HR2479, has already passed. Page 51, section xii reads:
the qualified certifying entity shall not be owned, operated, or controlled by a trade association whose member companies operate facilities that it certifies
That's pretty clear. No trade association can do this. It must be third party.
Here is the program we are proposing:
We are all aware that significant quality problems are present in the cashew industry. There is a need to investigate conditions overseas so that manufacturers can come to grips with why problems are occurring, how they can be avoided, and who is reliable. We have assembled a program and with your support, are ready to go forward.
Using seasoned auditors, we will conduct audits of a representative sample of 20 cashew processing facilities at each major origin on an annual basis. Since Brazil has 9 facilities, we will perform at least 69 audits per cycle.
Supporters of this effort will receive, in a timely fashion:
· Access to an expanding data base of audited vendors
· A white paper summarizing the results and assessing the state of the industry, based on analyses from an inspector who has 30 years experience in food safety inspections with a concentration in nuts and dehydrated fruit.
· The full audit report from each facility
Prior to each round of audits (schedule to be announced), supporters will be able to:
* Submit questions for our inspector that directly relate to the issues they want addressed
* Submit specific shippers to be considered for inspection.
By utilizing the pooled support of the industry, the CCC inspection program can provide a world-wide audit program to its supporters at a fraction of what it would cost a single company. And, supporters are advertising themselves as companies that are taking steps to proactively improve the supply of raw cashews.
Our funding goal for this project is $235,000, which will be used to fund the audits, prepare and make available the reports, and for related ancillary expenses. Funds collected in excess of the goal will be rolled over to fund the next round of the CCC inspection project.
If your firm is interested in participating in this collective project, please contact us at email@example.com , or 804-745-2848, for more information.
We can do this, and we can do it cheaply if all the stakeholders participate!
Our goal is 100 doners. At that level the cost to each is just $2,350.
Please fill out the non-binding form below and express you support (or tell us to go away).
Friday, July 10, 2009
President Obama has followed through with his pledge to address food safety, forming the Food Safety Working Group in March. The project continues to gain momentum as a new, public health-focused approach to food safety is developed.
"One in four people get sick every year due to food-borne illness. Our food safety system must be updated" said Vice President Joe Biden. Secretary of Agriculture Tom Vilsack was even more forceful: "We owe it to the American people to deliver on President Obama's bold promise to greatly enhance our food safety system, moving our approach into the 21st century, employing the best surveillance techniques available, and ensuring that we are doing all we can to prevent illness before it occurs."
The growing concern with food safety and traceability will impact not only domestic production, but imported foods as well.
A New Three-Part Quality Initiative
The Commodity Concern Certification program, with its unique three part quality promotion initiative is an excellent, cost efficient resource for companies who need to take proactive steps to comply with the new, stricter requirements. The program benefits consumers, retailers, importers and quality producers.
Facilities carrying the CCC-CERT logo have been inspected to verify that they follow Good Manufacturing Practices proven to minimize cross-contamination, infestation, and the presence of foreign material. CCC-CERT inspections are carried out by industry experts using criteria specifically tailored to the nut and agricultural industry. Shippers that pass inspection are given the CCC-CERT and entered into our data base.
The CONCERNTRAK system documents that product sold with the CCC-CERT comes from certified facilities. Each case is stamped with a tamper proof label that includes a tracking number, lot code, and production date, and is traceable back to the supplying facility.
The PERFORMANCETRAK component uses the tracking and certification data, combined with reporting from roasters and importers, to create a performance history for each supplier. This summary data will be accessible online to subscribers and can be used to compare shipper quality. PERFORMANCETRAK empowers buyers by providing the data they need in order to make informed purchasing decisions.
Contact Us: We invite your comments, suggestions and questions regarding the program. Please contact David Rosenthal or Mary Smith at 804-745-2848 / firstname.lastname@example.org .
Friday, May 15, 2009
Recently the Association of Food Industries held its annual convention in Naples Florida, and of course, issues regarding food safety were the running theme throughout the meetings. Speakers included legal and insurance experts who are keeping a close eye on impending legislation that will call for significant changes to the rules under which food is imported into the United States. All of the food bills under consideration include two major components that are lacking in the current importation process. First, the ability to track lots back to their origin production facilities and lot runs. Currently this is cumbersome and ineffective. Second, there must be verification that good manufacturing procedures are being followed by overseas suppliers. At this time, verification of any kind is difficult and many facilities have never been audited.
Who is responsible? During the meeting the question was asked: Are food suppliers throughout the distribution channel responsible for ensuring the integrity of the processing plants that the raw material comes from? The answer was a definitive YES! What was not clearly determined was how it could be done effectively and affordably.
Currently the Nut and Agricultural section of the AFI and Federal Government lack the human resources and funds to ensure that every facility overseas meets good manufacturing standards. Therefore, in an effort to ensure that there is integrity to the product being supplied to the roasting and manufacturing community it was decided to put together a working group to address the possibility of having mandatory certificates of analysis with every shipment of imported nut and agricultural commodities that currently fall under AFI guidelines.
A Certificate of Analysis Is Not Enough
A Certificate of Analysis is the final validation step of good manufacturing processes, but it is not a substitute for ensuring, through third party audits, that these processes are implemented. There is a saying among food safety experts regarding the accuracy of testing: "The absence of evidence is not evidence of absence". While there are no absolute guarantees, maintaining and verifying the integrity of each step of the process reduces the risk significantly
Some companies have begun to fund efforts to inspect facilities overseas on their own. This is very costly, time consuming and only benefits the company funding the effort. To date, there have been no feasible solutions offered to address the impending necessity to inspect overseas processing facilities that would be effective, meet the demands of legislators, and benefit the entire industry at a minimal cost.
TURNING THE SHIP AROUND
It is a known fact that a large seagoing vessel cannot be turned around instantaneously; it must be turned in degrees. This holds true to turning our industry around as well. Change won't take place overnight but it does not mean that we should not begin to focus our efforts in the right direction. At present, we would not be able to effectively comply with the imminent legislation that would require third party inspections of ALL overseas food processing facilities. It is a big job but we have to start somewhere and figure out the most cost effective and efficient way to do it. The CCC has put together a group of industry experts in the fields of auditing, production, food science, food safety compliance procedures, along with legislative experts, to establish an organization that could effectively develop control systems to protect companies and provide the information needed to source from good manufactures overseas.
Currently the CCC has a database of over 200 active users of imported nut and agricultural commodities. Using our combined financial resources we can effectively begin the auditing process of overseas facilities, establish programs for track and trace procedures, and begin turning this industry around on the right course toward the future. The CCC as a Subscriber Based Organization? The CCC has the resources, infrastructure and willingness to make positive changes for the industry. Most importantly, we have time to dedicate 100% of our effort to address ways that our industry can adapt to unprecedented legislation that will change the way we do business. Our industry will have no choice but to change and as it stands now we are ill prepared for these changes. The current trade organizations do not have the time or resources to dedicate the amount of effort needed to effectively initiate programs that will be required to help us "adapt to the future" A subscriber based organization exclusive to roasters and manufacturers who use nut and agricultural products would represent an industry segment with the same common interests regarding issues pertaining to responsible sourcing and the auditing of overseas production facilities. We are not looking to replace the existing trade organizations, as they play a very important role, but this particular issue requires a special interest group.
Since CCC management is not involved in commodity trading, our approach is unbiased and focused solely on responsible sourcing initiatives to benefit its a subscriber base. The combined forces of a roaster/manufacturer exclusive organization would have a profound influence on the importing/commodity trading community to shift focus to responsible sourcing practices. The fact is that adapting to these unprecedented changes will require so much time and dedication that a special interest group with the sole purpose of protecting roasters and manufacturers must be developed. The CCC can help pave the way to make this happen.
We invite your comments, suggestions and questions regarding the development of such a program. Please contact David Rosenthal or Mary Smith at 804-745-2848 / http://email@example.com . Also feel free to leave comments on our blog. We'd like to get a dialogue going.