Food Safety Audit Report

FOOD SAFETY AUDIT REPORT

# SYS-B-195

Fresh Point Overton Distributors, Inc.

1100 6th Ave N

Nashville, TN 37208-2649

SUSAN P. DOOLEYSUSAN P. DOOLEY

Food Safety Auditor

October 16, 2007October 16, 2007

AIB International

1213 Bakers Way • PO Box 3999 • Manhattan, KS 66505-3999
(785-537-4750) • (800-633-5137) • Fax (785-537-0106)

RATING

A food safety audit was conducted at this facility on October 16, 2007. The writer was accompanied throughout the audit by Mr. Marty Grove, Operation Manager.

Excellent cooperation was received by the writer, and on some occasions, the items were immediately corrected.

At the conclusion of the audit, a meeting was held to discuss the observations, recommendations, and rating.

Based on the observations made, the information obtained, and the criteria set forth in the AIB Consolidated Standards for Food Distribution Centers, the overall food safety level of this facility was considered to be:

SUPERIOR
(920)

SYSCO HACCP VERIFICATION
(135)

The “serious” or “unsatisfactory” items are shaded, boxed, and bolded in the text of the report. Refer to the definitions in the AIB Consolidated Standards.

The “improvement needed” items are designated in bold type and require prompt attention.

The AIB International states that the report as given herein is to be construed as its findings and recommendations as of the date of this report. The AIB International accepts no responsibility and does not assume any responsibility for the food safety program in effect with (customer). That further AIB International is only making report of the food safety conditions of (customer) as of the date of this report and assumes no responsibility or liability as to whether (customer) carries out the recommendations as contained in this report or does not carry out the recommendations as contained in this report.

RATING ANALYSIS

DATE OF AUDIT: October 16, 2007

TYPE OF AUDIT: UnannouncedUnannounced

OVERALL RATING: SUPERIOR

ADEQUACY OF FOOD SAFETY PROGRAM / 190
PEST CONTROL / 180
OPERATIONAL METHODS AND PERSONNEL PRACTICES / 175
MAINTENANCE FOR FOOD SAFETY / 195
CLEANING PRACTICES / 180
TOTAL: / 920

RATED ITEMS

UNSATISFACTORY ITEMS:

None

SERIOUS ITEMS:

None

IMPROVEMENT NEEDED ITEMS:

Item #39

FACTUAL OBSERVATIONS AND SPECIFIC RECOMMENDATIONS

ADEQUACY OF FOODSAFETY PROGRAM

A current organizational chart was maintained and dated April 20, 2006. The responsibility and authority for ensuring food safety and security, and the facility's compliance with federal, state, governmental, and/or any other appropriate regulatory laws or guidelines were clearly assigned to the General Manager/VP. This responsible person remains up to date on regulatory issues and has obtained the required regulatory food security registration. The food security registration information was available in the Security Guidance document dated April 4, 2007, (rev) and reviewed by the Auditor.
The department responsible for maintaining the distribution center’s food safety program had established written procedures outlining the specific responsibilities of each department manager and employee in an operations or procedure manual. The HACCP manual included a statement defining the company’s intention to meet its obligations to keep the products safe with appropriate signatures from the President, Executive Vice President and VP/General Manager of the NashvilleDistributionCenter, dated April 4, 2007. The auditor reviewed the job descriptions for the Distribution Manager, dated April 30, 2004, and Shipping Manager (HACCP Team Leader), dated February 6, 2007.
This facility had established a multidisciplinary food safety committee to conduct monthly inspections of the entire warehouse. Due to the size of the facility, facility managers rotated each month to a different area of the facility to inspect. A “Monthly GMP Self-Inspection Checklist” was used for identifying the GMP exceptions. Documentation of the monthly inspections included identified deficiencies, specific assignments, and actual accomplishments. Follow-up inspections were done to ensure that the items were corrected. Based on the facility review of the inspections conducted in June 28, 2007, and more previously, the inspections conducted on September 27, 2007, August 27, 2007, and July 7, 2007, with conditions noted on the inspections corrected. However, it was recommended that the facility inspections become more detailed in identifying and correcting potential food safety issues, such as the allergen storage practices discussed in the “operational practices section” and the cleaning of the tomato grading room discussed in the noted during the survey.
The facility appeared to maintain an adequate budget and support to maintain the proper and timely acquisition of appropriate tools, materials, equipment, monitoring devices, chemicals, and pest control materials.
A Master Cleaning Schedule (MCS) for periodic cleaning assignments and a daily housekeeping schedule were developed as a formalized, written plan and implemented in this facility. This MCS specified frequency and responsibility. Postcleaning evaluations were conducted. The schedules were documented as current, and the conditions observed in the warehouse supported the documentation. The MCS consisted of weekly, monthly and “as needed” sanitation checklists. The calendar of events was reviewed from September, May and April 2007, as being completed. The schedules included the outside grounds, buildings, drains, and equipment. The schedule was reviewed periodically to ensure that it was still applicable. In addition, the supervisors conducted an end of shift check for area cleanliness with the shift report dated March 16, 2007, reviewed by the auditor.
Detailed, written cleaning procedures were developed and on file for most cleaning tasks in the facility relating to the cleaning of food storage equipment, the building and the exterior grounds. It was recommended that additional tasks of cleaning the walls and curbs in the tomato room be developed and rack cleaning procedures for the racks in the dry storage room.
All incoming material entering the facility was inspected for objectionable material according to a written procedure, “Receiving Dock Procedure”, dated March 24, 2006. This procedure included a visual inspection for pests, damage, cleanliness, and product integrity. A stamp is used to document the condition of the trailer on the Purchase Order, which is the receiving record. In addition, receiving records (logs) were maintained that included the date of receipt, carrier, quantity, and information to facilitate a recall. Seal numbers were recorded when applicable. The auditor reviewed the “daily receiving log” and “driver sign-in record”, dated October 16, 2007. Procedures dated March 16, 2007, for “Seafood Receiving” and a procedure dated February 2, 2007, for “Tomato Receiving” were followed by the facility. The auditor reviewed the receiving documentation and trailer inspection documentation for “apples” dated October 16, 2007.
A hazard analysis for all products being stored or shipped from the center had been conducted. Where fish and seafood products were being stored in the facility, a Hazard Analysis Critical Control Point (HACCP) program had been developed and implemented for all of these products. The program included the following components:
Description of the products manufactured and hazards inherent to them
Identification of critical control points (CCP) and critical limits
Procedures to control the CCPs
Determination of the monitoring frequency for the CCPs and designation of the person(s) responsible for testing
Established and documented deviation procedures
Written verification program, with proper documentation
Documentation of procedures, records of conformance, and corrective actions

The facility identified one CCP in the operation as “product receiving temperature”. The HACCP Plan was last reviewed in February 15, 2007.

The company had established written employee guidelines and food safety policies. Specific written procedures were on file for providing food safety training to all personnel, including temporary personnel and contractors. Records of training completion for new employees and annual refresher training documentation were maintained for all personnel. The most recent employee training was conducted through the Safety meetings with various months reflecting some GMP/Food Safety Topics. Training for Food Security, HACCP and Food Safety training documents were reviewed from February 1, 2007. Additional training for cross-contamination, handwashing and sanitation were noted from July 10, July 10, and July 19, 2007. Microbiological training (E.coli) was conducted to truck drivers on May 21, 2007.
A formalized, written program for evaluating customer complaints, particularly those related to adulteration, was established at this location.
A written recall program, “Product Recall Procedure”, dated March 16, 2007, was on file and routinely reviewed. Contact names and phone numbers with regulatory phone numbers were on file and dated March 2007. Distribution records were maintained to identify the initial point of distribution to facilitate segregation and recall of specific lots. Test traces and mock recalls were conducted every six months with appropriate documentation maintained on file. The date of the last date of an actual recall was July 26, 2007, on a “Spring Mix” produce. The recalled product was 100% traced to customers and product that was maintained on hand.
Written procedures, “Returned Product Policy”, dated April 30, 2004, “Return Product QA Receiving” and “Product Hold”, dated March 16, 2007 were in place to control damaged or returned product. Records were kept of the corrective actions and disposition of the product and adjustments were made to the product inventory records to accurately account for the damaged or destroyed materials.
A written policy on how to handle regulatory and third party inspections was on file. These procedures included the person(s) delegated to accompany all inspectors and company policies regarding photographs, records, and samples. Included in this area was a policy on “Media Response”, dated July 2007. The most recent regulatory inspection was conducted by the Tennessee Department of Agriculture on February 5, 2007. The facility score was 99%. The issue noted was corrected.
A written policy, “Glass & Hard Plastics Policy And Clean-Up Procedures”, dated March 16, 2007, stating that no glass was to be used in the facility, except where absolutely necessary was in place. Included in the policy was a procedure to handle any glass breakage in the facility. A list of all essential glass had been developed and was audited during a monthly GMP inspection to ensure that any accidental breakage was found and addressed. The auditor reviewed the glass inspection conducted June 28, 2007.
A preventive maintenance program and maintenance checklist system was contracted to an outside maintenance service company for maintaining and servicing structural, forklift equipment, or cooling maintenance problems that could cause food adulteration. The service included a quarterly PM/cleaning schedule. A program to ensure that the safety of the product was not jeopardized during maintenance operations was implemented at this facility.

PEST CONTROL

A formalized pest control program was established with written procedures outlining the requirements of the program to reduce the potential for product contamination from pest activity or use of materials and/or procedures designed to control pest activity.
Facility management contracted Terminix Pest Control Company to provide monthlypest control services. A copy of the service agreement dated February 13, 2007, that included materials to be used, methods, and precautions was maintained on file. Copies of the current liability insurance (expiration date January 1, 2009) and current applicator's license (expiration date December 31, 2007) were maintained on file.
Material Safety Data Sheets (MSDS) and sample labels were maintained on file for all pesticides applied on the premises. The rodenticide used on site was Generation Blue Max Miniblocks (EPA Reg. No. 7173-239).
A service report was left after each visit by the outside pest control service. These records included the treatments and tasks carried out, documentation of the checks and findings for the pest monitoring devices, descriptions of the current levels of pest activity, and recommendations for actions needed to correct conditions allowing a potential for pest activity.
Documentation of all pesticides applied on the premises, including rodenticides, included materials applied, target organism, amount applied, specific area where pesticide was applied, method of application, rate of application or dosage, date and time treated, and applicator's signature. This documentation indicated that the applications were made in accordance with the label directions.
A schematic, dated March 14, 2007, depicting the locations of the interior and exterior pest control devices, including mechanical rodent traps, glue boards, pheromone lures, insect light traps, and bait stations, was maintained on file and appeared current.
Thirty-one mechanical mousetraps (Tin Cats) were installed to monitor for rodent activity inside the facility. These traps were properly positioned along walls and beside doors to the outside. The PCO checked the traps monthly and a designated facility person checked the traps the remainder of the month. The PCO recorded the information through the “Scan Master” database program and facility recorded the information on the “Pest Control Weekly In-House Checks” record. The interior traps were checked weekly up through September 24, 2007; however, week of October 7 and 14, 2007, had not been completed at the time of the inspection by the facility person. It was understood that a transition of responsibility was currently in the facility. The traps that had been serviced appeared properly maintained and a record was maintained of service and cleaning of each rodent control device though the “Scan-Master” program. A rodent activity log was used to record captures and help direct any necessary corrective actions. The traps randomly examined appeared properly maintained. The traps should be checked on a weekly basis to maintain an effective program in the event of a live catch.
Twenty bait stations for rodent control were installed around the exterior perimeter of the facility at appropriate intervals. These stations were tamper resistant, properly positioned, anchored in place, locked, and properly labeled in compliance with regulatory requirements. All stations were serviced at least monthly. Fresh bait had been supplied in the stations randomly examined. The service and results of the checks were documented on the “Scan-Master” database program and printout.
No pesticides or pesticide application equipment was observed to be stored on site at the time of the survey.
No evidence of insect, rodent, or bird activity was noted in or around the facility.
The internal rodent trap (Tin Cat) #14 in the Main Cooler was missing the site window, which made the tin cat inoperative.

OPERATIONAL METHODS AND PERSONNEL PRACTICES

Damaged or soiled materials and any materials shipped in dirty or infested trailers or containers were rejected at the time of receipt.
Eighteen-inch perimeters were unable to be maintained in all produce storage areas to provide cleaning and inspection access. However, adequate space for cleaning was maintained between rows of stored products. A program for cleaning of the coolers was in place for cleaning floors beneath the racks and along the curbing of the floor/wall junctions.
Ice broccoli was observed in storage on floor level to prevent melted ice runoff from contaminating other products. Trays were observed in place for use when storing product in the upper sections of the bays within the storage rack.
Pallet racking was used to maintain storage conditions. Each pallet or case (of small quantity goods) of merchandise was identified with the appropriate information to ensure "first-in, first-out" rotation. Printed pallet tags (item number, PO & receiving date). Colors are designated by week to help with FIFO rotation of produce. The auditor reviewed the rotation practices of the following specialty products and main cooler:
Black plums – received 10/11/07; no additional product in storage
Watercress - received 10/15/07; no additional product in storage
Shredded Slaw Mix – Dated 10/23/07 on top of pallet; 10/25/07 on bottom of pallet
Whole onions – Dated 10/26/07 on top of pallet; 10/25/07 in middle of pallet; and, 10/29 in back of pallet
Chopped Romaine – Dated 10/21/07; only one pallet with this date
All perishable materials were stored at or below 40F (4C), and the frozen materials were at or below 0F (-18C). A graph and a digital read out program was in place in all coolers and freezers. The refrigerated and frozen storage areas were fitted with quick-opening doors to maintain proper temperatures. The temperatures of the coolers and storage rooms at the time of the inspection were as follows:
Room 1 was 65F at the time of the observation on the digital readout. The temperature control was set at 65F.
Room 2 was 52F at the time of the observation on the digital readout. The temperature control was set at 52F.
Room 3 was 52F at the time of the observation on the digital readout. The temperature control was set at 53F.
Room 4 was 55F at the time of the observation on the digital readout. The temperature control was set at 54F.
Main Cooler (4 zones) was 41F at the time of the observation on the digital readout. The temperature control was set at 37F. This cooler was in the defrost cycle.
Small Freezer #1 was –5F at the time of the observation
Freezer #2 was –7F at the time of the observation.
Toxic chemicals, including the cleaning solutions, maintenance compounds, and non-food-related materials, were completely segregated from all food ingredients and packaging materials. The cleaning materials were stored in a designated and locked caged area within the warehouse with limited key access.
Protective measures were provided where iced-down product was observed to be stored over like or dissimilar products in order to keep the melting ice runoff from contaminating the product below. The iced-down vegetable produce that was in storage was palletized and on the floor level within the storage racks.
Rubbish and waste materials were properly stored outside the facility in a suitable compactor/dumpster, which was emptied as necessary. The area was generally well maintained and free of excessive spillage. It was observed the dumpster in use at the time of the facility perimeter walk. The dumpster is emptied on a daily basis.
Damaged goods were removed to an identified recoup area in the main cooler for repacking or eventual disposal. Damaged items were removed for suitable disposal weekly or as needed. Repacked materials were identified so as to maintain traceability.
The washrooms were maintained in an acceptable sanitary condition. The lockers were inspected monthly as a sanitary control, and no open food or drink was allowed. “Wash Hands” signs were displayed in the rest rooms, lunchroom, and smoking areas.
Shipping vehicles were inspected prior to loading for cleanliness and structural defects that could jeopardize product integrity. Temperatures of precooled vehicles to transport refrigerated or frozen product were checked prior to loading. The auditor verified a trailer pre-cooling prior to loading on the dock. At the time of the observation, the temperature on the delivery truck was 47F. Issues that were found were documented with the outside lease service.
All employees observed during the survey appeared to be practicing good personal hygiene habits. Eating, drinking, and smoking were restricted to designated areas.
Three boxes of sunflower seeds that had an “allergen sticker” on each box were observed being stored in the ‘specialty storage cooler’ with the boxes of dried mangos located on the second shelf of one of the storage shelves along the wall. It was recommended that the allergen containing products be stored on the bottom shelf to prevent potential allergen contamination issues from occurring while product is in storage. It was further suggested that employee training be conducted with those individuals responsible for receiving this product. (IMPROVEMENT NEEDED)
The auditor verified the proper MSDS sheet on file for the “HDQ-C2” a cleaner, disinfectant, deodorizer for use in cleaning the Rubbermaid containers for shipping of iced, cased fish to the designated location. The containers are cleaned and dried after each use and sanitized with Hepacide Quat II following the procedure, dated March 16, 2007. The plastic pallet used to store the ice seafood products in the cooler prior to transporting was also cleaned and sanitized after each use.

MAINTENANCE FOR FOODSAFETY