Paper Trail

Does the ISO/HACCP/HARPC Always Make Sense?

Over 1/5 of the food production in the United States is grown by small family farms. These operations are often only family members as workers or a couple helpers at most. You can find the same thing happening now in the craft food movement. Can you assure safe and quality food at this level of production with the same tools used on an operation with 20, 200 or 2,000 management and field staff?

Although a process based on analysis, documentation and monitoring may seem pretty simple to understand, at an implementation level, the concepts often do not translate well. The goal of any quality control system can be lost in the effort to maintain the system. Why build a bridge that will carry an elephant to a place it does not need to go? Give me a plank to just get me there.

A neighbor of mine does quality control for the aerospace industry. They work with small engineering and machining companies building highly critical parts of which very few are needed. While doing audits of ISO certified firms, it was discovered that all the compliance costs had gone into the documentation to comply and there was no understanding of how to apply it to the process of building parts. They have since switched to process audits that look to see, no matter how simply documented, if the controls are implemented in the process.

The space industry faced the same issues small farms and craft foods face in doing critical tasks whether rocket parts or safe food. A GFSI farm audit is going to have 300 questions whether you have 2 employees or 2000 employees. Do you really need to have an SOP template so Ma can tell Pa to wash his hands before heading out to the packing shed?

Rather than the scale determining when FSMA implementation should take place, it should determine how it is implemented. This would also mean having a scaled approach to GFSI or Food Safety audits in the checklists. I have yet to meet an operator that understood the HACCP Plan or Risk Assessment left with them by a previous consultant. Since 95% of the risk issues are common in either food production or food processing, it would be better to assist small operators with understanding and implementation rather than dump materials on them for 300 control points as a further barrier to implementation.

The industry ASC is part of is on a constant steeplechase to help clients meet the increasing audit standards often at the cost of well-implemented practices. Perhaps it is time to stop and look at the models we are building for documented compliance and develop a model focused on effective implementation at any scale.

• C. Lawrence

Apple Pie Day

Apple Pie Day

I move fast. I know it, I try hard to not do it but it is inevitable with all there is to do. So I look for things that purposely slow me down. Yoga. Breathing. Meditating. Cooking.

I relish food buying. Each Sunday, the ritual of shopping at Farmers Market and buying the fruits and vegetables from our local area and meeting all that labor to get them to me inspires me beyond belief. Since it is Apple Pie Day (Huh?! Isn’t it everyday?!) I wanted to share my recent discovery. The beauty of this simple apple, that I discovered last fall, was enough to remind me to pump the breaks a little, slow it down and soak in what is right in front of me. Apples are a perfect food and I found a most amazing variety that I had never heard of before; The Hidden Rose Apple.

My husband and I discovered this special fruit at a little farm stand in Malibu, California. The proprietor had about five of them left and the act of handing one of these special apples to me seemed was like she was sharing a family secret.  Biting into it was a revelation and tasted so much like strawberry lemonade it was unbelievable!

I took a few home and savored them, took pictures of them but sadly there were not enough to make my grandmothers crust to encircle them within a pie. So I just allowed the apples be an inspiration all to themselves. The color, the flavor, the attention that they quietly asked for, made me pine for a good, homemade pie as that simple creation makes everything feel better. Unless of course it’s not cooked all the way through!

For years I’ve been making my grandmothers crust while lovingly following her original recipe. Both my dad and uncle, each wonderful pie makers themselves reminded me through these years to keep careful attention to all my grandmothers’ finely attuned details. Keep it simple, let it cook all the way and take your time to do it right! These lessons in pie making from my two exacting critics continue to keep me on my toes in the kitchen today. I savor the beauty and mind the process. Those are two things I try to do in my everyday life working with food, with people who create food, evaluating food safety and working alongside our team to reach our goals. I’m so glad a simple apple pie can reinforce my values while creating an experience of reaping what we sow with delicious abandon! I am always reminded of the beauty waiting for me and can be enjoyed in a single bite.

-Adrienne Steele

Recall

Recall Causes and Effects

The demands on small food manufacturers to manage and track activity to meet food safety guidelines is increasing every day. Recalls are the high pressure event that can highlight the need for a robust monitoring and records system. ASC recommends clients install inventory systems early on to reduce the administrative burden, and increase monitoring and traceability. Let our experience staff help you with setting one up today. 

A recall is hard enough, without the process dragging on for several cycles and several months. The years long Takata airbag and 2016 General Mills flour recalls that go through cycle after cycle are some examples of long painful recalls that never seem to go away. We got our Honda recall notice years after the first Takata announcement. Taking the steps to get traceability done right the first time will greatly reduce this long term negative exposure and protect your customers.

If you are doing your job right in the Food Safety area, it is very likely that your recall will be based on an issue with a purchased ingredient. Small food manufacturers just do not have the resources to test every lot coming in the door. This means that if you are a typical food processor, you are going to find that ingredient in more than one product and more than one batch. This is where the one up and one down can catch you off guard.

With the multiple use of ingredients in different batches and recipes, a likely complaint will filter through your production cycle and customer base when an ingredient is involved. In your typical FDA trace of a lot, you might only identify the ingredient as the source of contamination but not trace forward again to other production. This would still leave you with tracing every other batch and product the ingredient was used in.

This is where a new generation of simple inventory and production software can greatly reduce your risk and increase the traceability of your product. Many of my clients have dozens of ingredients, 10 or more products and hundreds of clients. The permutations for this complexity would overwhelm most hand or excel based record systems.

Even very small producers and Brand Holders with contract manufacturing should consider an online inventory system to track the distribution of lots. We provide hand systems when helping clients start down the road to food safety, but the ability to track even a moderate amount of production and distribution with records that have to be updated offline as paper or Excel sheets quickly results in insufficient ability to search and find sources. Choosing a system that is both easy to use, and has integrations with many of the business support tools such as CRM and accounting will increase your production control and traceability, while reducing the actual time you spend offline entering data.

By: C. Lawrence

Women's History Month

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Inspiring Women as Women’s History Month Comes To A Close

Who is in your circle? I’ve never written about Women’s History month putting into words. Who’s in my circle and what they have meant to me both past and present. I’m excited to share this story with you. I’ve always thought of myself as lucky to have an amazing circle of women around me since I was a child. My mother, Diana was front and center. She was ahead of her time in the 1970’s getting her degree later in life with four young kids in tow. She dreamt of becoming a nurse and despite her father’s objections she rose up, stood in her power, and made it happen.

My German and Spanish grandmothers showered me with their love and cooking/baking prowess from all corners of their cultures. I was born into the sacred light of their family-centric holidays filled with baked goods, the essential smells of roasted meats. A strong feeling of love wafting from their kitchens surrounded by my aunts, cousins, and sisters. I was raised to be aware of my femininity and how powerful that is. Looking back at it, abundantly supported in this world of expressing love through food as a young girl.

In college living on my own for the first time, I found solace in reading Sylvia Beach who had started Shakespeare and Company bookstore in Paris. Ms. Beach helped James Joyce write and publish his mammoth novel, Ulysses. I was astounded at her declaration and hubris. Gertrude Stein leading the ex-pats in Paris in the 1920s commanded attention. Her salon was her living room filled with men and women alike enjoying a feminine-centered perspective on art, conflict, writing, and music. So many women both historically and in my present life were inspiring me to keep reaching to find my own unique perspective in the world.

At Expo West 2022 for the first time in two years, we all reconnected. The shift of #MeToo and that empowerment was evident and clear to me. With amazing WBEC certified organizations, I relished meeting so many incredible female leadership companies. Those transformative women at that dynamic event held up a mirror to me. As I engaged and connected with them, I too realized that I had also begun a revolution in my own life.

I’m proud to share that it’s my turn, that I too have raised an incredible daughter who embodies her femininity. She speaks, writes, and shares her experiences as a woman in the world. She too has a circle of people who inspire her and each other. Bringing this all into focus I am reminded that I have a company of exceptionally smart, and beautiful women who are growing in their own knowledge, experience, bringing so much to myself and this culture of food safety. I have extraordinary clients, both men, and women. The women that I have collaborated with professionally like Diana Trout of Health-Ade Kombucha and Cassandra of Little West have inspired me to keep going with my own leadership role. To keep my company thriving and being of service in our category as well as provide opportunities for younger women to grow and find their power in their own capabilities as well.

The men in my life always included a strong father George and my beautiful brother Eric. I certainly would not be the same person today without my amazing husband Ken, and our company would not be the same without my business partner Carlos.

But someone now in celebration of Women’s History Month I celebrate so many women that have touched my life. Scrappy fighters like Frieda Kahlo, elegant and poignant women like Maya Angelou, and with whom I count on daily. Amy, Stephanie, Kristina, Gabby, Ann-Marie, Nicole, Brene, Oprah, Glennon. MY "ROCKIN' 12" My circle! I celebrate us.

I love the clear message Expo West had sent me and I love this little company too!

I say a humble thank you for completing my circle. Cheers to all of you women who came before us and will come after us too. There is room for all of us.

By: Adrienne Steele