135 | Top 5 Non-conformances | Food Defence 101 | Crabs, Crabs, Crabs |
Celebrating unofficial crab day
Crustacean-related food safety risks in new foods;
Food defence 101;
Top 5 food safety non-conformances;
Food Safety News and Resources;
Crabs, Crabs, Crabs;
Food fraud news, emerging issues and recent incidents
Cover image: Cover image by Rod Long on Unsplash
Warning, this issue contains crab jokes.
Hi, Welcome to issue 135 of The Rotten Apple, not-boring food safety news for busy professionals.
This week, we celebrate (or should that be 🐚shell-ebrate) International Crab Day 🦀the (un)official day for all things crab-y, as decreed by the Crab Museum in Margate, UK. With crab jokes.
On a more serious note, this issue also has food safety non-conformances to learn from and food defense procedures to keep consumers safe from harm.
This week’s food fraud news for paying subscribers also has crabs! It includes a white paper which discusses legal approaches to seafood fraud.
Enjoy,
Karen
P.S. A big hello and welcome to new subscribers 👏👏 Richard, Graham, M, Elia, Nasa, Greg, Mariane and Ellen 👏👏 for upgrading to paid subscriptions. Thank you!
“I'm happy to support the incredibly valuable work you do, Karen!” Michael, new subscriber (Portland, USA)
Crustacean-related Risks in New Foods
Since we’re celebrating crabs this week, I thought I would share some insights from the Food and Agriculture Organisation of the United Nations (FAO)’s report Thinking About the Future of Food Safety.
New food sources are defined as those which previously haven’t been widely consumed across the world, and include jellyfish and insects.
Edible insects are not new food sources, but they are new on a global scale because they haven’t been widely consumed in Western countries previously. Food safety risks from edible insects include pathogens from the insects’ microbiota, improper handling of insects and unhygienic storage of edible insects.
Chemical and biological contaminants in the insect feedstock can also give rise to food safety risks. These include pesticide residues, heavy metals, flame retardants, dioxins and other chemicals.
Allergenicity to crustacean-allergic consumers is a key concern for insect foods, due to cross-reactivity between crustacean proteins and insect proteins. Experts are concerned that the number of allergic consumers, or the intensity of reactions may increase with increasing exposure to insect-containing foods.
If you have a food allergen to crustaceans such as crabs, you might be at risk from insect proteins in novel foods
In crab-adjacent food safety news 😊🦀 the report also discusses potential risks associated with jellyfish consumption.
Jellyfish food safety hazards are poorly understood. The animals are expected to sometimes contain pathogenic marine bacteria including Vibrio species, which can cause severe food poisoning.
Reminder: Jellyfish are a type of cnidarian, a group (phylum) of soft-bodied animals that include corals, jellyfish, and sea anemones. Crabs belong to the subphylum Crustacea, of the phylum Arthropoda which also includes insects, arachnids, and centipedes.
When it comes to chemical hazards, jellyfish have plenty. They are able to bioaccumulate heavy metals from the water in which they were raised or caught. Their bodies can contain algal toxins, so algal toxin poisoning from jellyfish consumption is also possible.
Commercially prepared dehydrated jellyfish is dried using aluminium-containing chemicals, resulting in high levels of aluminium in some jellyfish products. Microplastics are another chemical hazard mentioned in the report, with jellyfish known to ingest both microplastics and macro-plastics.
Jellyfish allergenicity is poorly understood, however anaphylaxis from eating jellyfish has been reported. The allergens have not been identified.
Source:
FAO. 2022. Thinking about the future of food safety - A foresight report. Rome. https://doi.org/10.4060/cb8667en
🍏 More from The Rotten Apple: Allergen Cross-reactivity: What is it and why should we care? 🍏
Food Defence
This month’s supplement for paying subscribers is an introduction to food defence with a focus on how to understand and meet food defence requirements in regulatory and voluntary standards.
It includes best practices for threat assessment methods and an expertly curated collection of resources including free training for food safety managers and front-line workers.
Top 5 Audit Non-Conformances
BRCGS spills the beans on a year of audits
What do you get when you collect audit data from more than 23,000 food sites in more than 125 countries?
One-hundred and forty-five thousand (145,000) non-conformances in total, an average of 6 per site. Let’s review the data and see what we can learn.
Here are the top 5 clauses with the most non-conformances in the past year, plus how to avoid getting stung by these requirements in your next audit.
1.1.10 Recertification audits must occur on or before the audit due date
New unannounced audit requirements may have proved a challenge for many sites. It’s likely the global auditor shortage is also having an impact on sites’ ability to get audited on time.
How to avoid this non-conformance: Contact your certification body well in advance and get paperwork in early.
4.11.1 Keep premises and equipment clean and in a hygienic condition
The high number of non-conformances against this clause is said to be the result of production and cost pressures in food manufacturing. I bet there is also an influence from the new unannounced auditing protocols!
Unclean areas were split evenly between premises (walls, ceilings, floors) and equipment, with no clear trend in the areas or types of equipment.
How to avoid this non-conformance: Keep the facility clean. Keep the facility well-maintained so that cleaning is easier (improvements to the company’s food safety culture can help). Review sanitation programs to make sure problem areas are getting the resources they need, and to maximise return on investment. The BRCGS Interpretation Guideline contains guidance on the development of effective cleaning programs.
4.9.1.1 Management of non-food chemicals
Auditors are now looking for protocols for spill management and procedures for the safe and lawful disposal or return of outdated chemicals and empty chemical containers. These are new expectations for BRCGS-certified sites.
Non-conformances for this clause related to the new expectations around spill protocols and the disposal of unwanted chemicals, as well as more typical chemical non-conformances such as lack of labelling, storage and access control problems and gaps in worker training and awareness.
How to avoid this non-conformance: Perform a robust internal audit on chemical storage areas and access protocols. Train and re-train workers who use non-food chemicals in safe handling, storage procedures and spill management. Contact local authorities for advice on disposal of unwanted chemicals including empty container disposal, and create procedures to reflect local best practices. Review spill management procedures and update if required.
4.6.2 Design and construction of equipment to prevent product contamination
This clause is new so non-conformances are to be expected. Rust, flaking paint, broken parts, and unsuitable welds and joints were the top problems identified by auditors for this clause.
How to avoid this non-conformance: Inspect equipment which is in contact with food and near food, assessing it for compliance with good hygienic design principles. Materials should be smooth, corrosion-resistant and impact-resistant. Areas in contact with food or near exposed food should be free from unsealed joints, cracks, stitch welds or spot welds. Painted areas and rusted equipment should be resurfaced or replaced. Ensure the preventive maintenance program includes inspections of all food contact equipment.
4.4.8 Doors maintained in good condition
Non-conformances about doors are entirely foreseeable and preventable. Doors that are damaged, that don’t work properly, that don’t provide adequate seals and that are propped open during production are common reasons for non-conformances.
How to avoid this non-conformance: Keep doors closed during production. Include door-related concepts in food safety culture activities and training. Inspect door function during daily or weekly checks. Include doors in preventive maintenance programs. Seal cracks and crevices around and underneath doors which could allow pest ingress (a rat can fit through a gap the width of a pencil).
Final thoughts
While some of these non-conformances are specific to new BRCGS requirements, many are typical of audit results across all food safety standards. Use the information provided in the “How to avoid this…” sections above to inform your next continuous improvement activities or food safety culture-building exercise. Good luck!
In short: 🍏 The top 5 non-conformance-generating clauses in the past year of BRCGS Food Safety Issue 9 audits are those for: timeliness of audits, cleanliness of premises and equipment, management of chemicals, equipment design and maintenance, and doors 🍏
Source:
Food Safety News and Resources
Our news and resources section has not-boring food safety news plus links to free webinars and guidance documents: no ads, no sponsored content, only resources that I believe will be genuinely helpful for you.
This week’s weird recall: gin recalled due to possible styrene contamination.
Click the preview below to access it.
Crabs Crabs Crabs (Just for Fun)
🐚 Shell-ebrate International Crab Day 🦀 on 26th April with this sideways joke from the Crab Museum.
Q: Where do crabs commute to?
A: Kings Cross station (king’s crustacean, get it?) 😐
🦀🦀🦀🦀
And…. Why don't crabs like to give to charity? Because they're shellfish!
… Why did the crab take its contract to a lawyer? Because it wanted an escape claws (clause).
Here’s a crab dinner, in every sense of the word.
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Below for paying subscribers: Food fraud news, horizon scanning and incident reports
📌 Food Fraud News 📌
In this week’s food fraud news:
📌 Food safety officials involved in extortion scheme;
📌 Seafood fraud legal approaches;
📌 New test methods for olive oil, black tea, herbs and spices;
📌 Horsemeat fraud comes to Australia? Plus potato risks, sunflower oil smuggling and more.
Food safety officials involved in an extortion scheme
Food safety officials have been arrested for their involvement in a scheme in which phytosanitary certificates and other export documents for corn and barley were exchanged for money. The group of criminals, which
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