Are pesticides reasonably likely to occur?

The U.S. Department of Agriculture (USDA) released the latest data from the Pesticide Data Program annual summary.  The agency found that in general terms, U.S. food does not pose a safety concern based upon pesticide residues.

The HACCP Consulting Group, LLC (HCG)  recommends that, as with all supporting material, companies ensure the data used for support matches their process.  For example, in this summary,  produce was rinsed with water prior to testing as this represents what the USDA believes is typical consumer practice.  If your procedures do not include a rinse, the data may not accurately represent the potential hazard as associated with your process and HACCP Plan.  HCG recommends companies maintain a copy of this report to  support your hazard analysis if your conclusion regarding pesticides is that they are not reasonably likely to occur.  The report can be found here –   USDA Pesticide Data 2012 Summary

New Sanitary Design Principles Published

The American Meat Institute has released an updated version of their document on sanitary design principles.  Although originally intended and proven effective for the meat and poultry industries, these principles are excellent advice for all those in the food industry creating, purchasing or maintaining food processing  equipment . The document can be obtained here.   AMI Sanitary design


Remember Typhoid Mary? If not, Consider Gastro Mari.

Remember the story of Typhoid Mary?  It happened so long ago, we forget the implications.  Mary Mallon was a carrier of the pathogen that causes typhoid fever.  She never contracted the illness, but did pass it on to others over a period of several years in the early 1900s.  She was neither the only known carrier nor the ‘worst’ one in history, but her name is the most often remembered.  It was not her fault that she was a carrier, but many suffered the consequences.

Let’s skip forward to 2013.  According to Food Safety News ( Mari Haughey contracted Salmonella Gatroenteritis at a Las Vegas restaurant in April of 2013.  Having recovered from the illness, she continued to carry the pathogen for nine months until testing negative for it on January 22. The testing continued until a negative result was obtained.    Mari and her employer were aware of the hazards.  Her work duties were changed to minimize contact with patients.  This case is different from Mary Mallon because Mary was never ill from the Salmonella and Mari was quite stricken. 

What we should be reminded of is the importance of restricting work when food handlers are ill and in some cases, even beyond the time when illness symptoms have gone.  It is not known if Mari passed the illness to anyone inadvertently.  Because of her training as a nurse, she likely was more cautious than most people would have been.   As responsible food safety professionals, we need to ensure food handlers are just as cautious. Work restrictions are not punishments for the worker.  They are essential public health actions.  The nature and duration of those restrictions will most often be management judgment calls based on education and risk. These actions must be supplemented with continual efforts toward appropriate hygiene training, especially hand washing.  We can only achieve and ensure public health through appropriate precautions at home and in the work place. Training, refresher training and leading by example are essential.



Medical Foods to comply with CFR and be intended for those seriously ill or requiring the product.

On Dec 26, 2013 the FDA issues two Warning Letters regarding medical foods.  The FDA alleges the associated products are misbranded as medical foods because there are no distinctive nutritional requirements or unique nutrient needs for individuals with mild to moderate Alzheimer’s disease and for Polycystic Ovarian Syndrome (PCOS).  It has been reported these are the first two Warning Letters where FDA asserts another requirement for medical foods.  Under FDA’s interpretation, medical foods must not only meet all the requirements of FDA’s regulation, 21 C.F.R. 101.9(j)(8), they also must be intended for “the patient who is seriously ill or who require use of the product as a major component of a disease or condition’s specific dietary management.”  This requirement is within Agency guidance from 2007 and draft guidance of 2013, but this was the first indication of it included in a Warning Letter.

SQF Asistance for Transport and Ditribution Companies: A Module 11 /12 Comparison

A practical aspect of the SQF Code is that  it is divided into Modules, all of which are not needed by every company.  Early in the certification process, companies identify their specific Food Sector Code and this leads them to an understanding that the entire Code need not be printed and used.  One can save considerable time knowing what must be read and applied  or not. ( You also can save a good amount of paper and printer ink !)

Rather than discuss the entire code, SQF courses typically focus on the details of Module 2 and 11 because these are the most often needed Modules.

The HACCP Consulting Group has prepared a comparison of Module 11 and 12 for those companies trained using Module 11, but needing to ensure compliance only to Module 12.   That information can be downloaded here – A Comparison of Module 11 and Module 12 in the SQF Code.    We will be posting a comparison of Module 11 and 13 for food packaging companies soon. We hope you find this helpful and continue to contact us for assistance in this and other food safety system endeavors.


FDA Provides Final Guidance on Beverages and Dietary Supplements

When is a dietary supplement really a beverage?  The FDA provides final Guidance.

On January 13, FDA announced the availability of two guidance documents concerning beverages and liquid dietary supplements: “Distinguishing Liquid Dietary Supplements from Beverages” and “Considerations Regarding Substances Added to Foods, Including Beverages and Dietary Supplements.”  

FDA considers several factors to determine the status of a substance as a dietary supplement or a drink.  The list includes labeling and advertising, product name, product packaging, serving size and recommended daily intake, directions for use, marketing practices and composition.  For each of these areas, the guidance provides examples.

FDA appears to consider use of the term “refresh” or “rehydrate” as indicating a beverage. Such terms are said to represent the product for use as a beverage offering taste, refreshment, and thirst-quenching ability.  Also classified as beverages, are products that use conventional food names such as “beverage,” “drink,” “water,” or “soda”.  Beverages are regulated under conventional food law rather than dietary supplement requirements.

Snack Food Association HACCP / FSMA Workshop

Snack Food Association HACCP / FSMA Workshop

January 23, 2014
Westin BWI
Balitmore, Maryland

This one-day workshop has been designed by SFA to assist the snack food industry in preparing and updating their HACCP (Hazard Analysis & Critical Control Points) programs in preparation for implementation of the Food Safety Modernization Act (FSMA) of 2010. Based on the proposed rules for preventive controls and cGMP, this workshop will review what is known about FDA expectations for HACCP programs including risk analysis, hazard evaluation, preventive control programs, and documentation, and how these expectations will impact snack food operations. Attendees are expected to bring an existing or developing HACCP program from their operation with them, so they can work through exercises on implementing the new expectations on their own HACCP program.

This course will be facilitated by Cathy Crawford, Vice President, The HACCP Consulting Group LLC, and Shari Plimpton, Vice President, Director of Food Industry Programs, CIFT.  Cathy is a certified HACCP and licensed SQF trainer. She also has experience as a Safe Quality Food (SQF) registered auditor for the snack food industry.

SQF Practitioner Training September 15-18, Dallas TX

Safe Quality Food Practitioner Training

Includes – Developing and Implementing HACCP Plans plus Developing and Implementing SQF Systems.

This training is provided by The HACCP Consulting Group, L.L.C. and sponsored by EAGLE Certification Group.

Developing and Implementing HACCP Plans:
This introductory course provides training in developing a HACCP (or HARPC) program for all types of food manufacturing facilities as well as food related industries such as packaging.  Personnel who will be designated as “HACCP trained” such as plant management, quality assurance personnel, and supervisory staff should take this course.
Date and Time: March 11-12, 2014 from 8:30am – 5:00pm EST

Developing and Implementing SQF Systems:
This course, provided by an SQF-licensed trainer can prepare you to meet the SQF Practitioner requirements as defined in the SQF Code, Edition 7.1. It will provide a detailed knowledge base to participants for the successful implementation and maintenance of an SQF System. This course applies to all sectors of the food industry including primary production through to distribution. The instructor is a former SQF High Risk Auditor.
Date and Time: March 13-14, 2014 from 8:30am – approximately 5:00pm EST

For details please contact me at

SQF International Conference – Cincinatti, OH November 6-8 2012

Cathy M. Crawford was a guest speaker who conducted two breakout sessions at the 2012 SQF International Conference in Cincinatti, Ohio November 6-8.

Managing Suppliers With an Effective Approval Program

A finished food product can be compared to a tapestry of complex components intricately interwoven by a blend of employees, contractors, and equipment. Just as one loose thread can unravel a tapestry, a supplier error can lead to food safety risks and recalls and cause “RIPS in the SEAM.” Remembering this analogy helps ensure the inclusion of all elements of a supplier approval program, one that addresses the Raw Materials, Ingredients, Packaging and Services (RIPS) and ensures methods for Selection, Evaluation, Approval and Monitoring (SEAM). Get practical guidance on how to set up a risk-based supplier approval program and leverage it to demonstrate continuous improvement. Learn how an examination of the relationships between Supplier Approval Programs, HACCP plans, and sound business practices will demonstrate the value of such programs and encourage stronger commitment to supply chain management.

A Guide to Writing a Better Food Safety and Quality Manual

Get practical advice and tips on how to develop an effective food safety and quality manual and/or improve existing materials. Discover how to select words and phrases that add strength and clarity while avoiding unnecessary language. Review common errors that lead to misunderstandings and examine several formats for Standard Operating Procedures (SOPs). Learn why “manual” doesn’t always mean “binder” and how SOPs can have negative as well as positive consequences. Attending this session will help you communicate your commitment to food safety through documented systems of deliberate control over risk.