Imports and Exports: Ensuring Food Safety Down Under
By Food Safety Magazine
With global food safety more important than ever before, Food Safety Magazine is taking a closer look at how various regions of the world are addressing current issues facing the food industry today.
The conversation that follows highlights responses from New Zealand King Salmon Company Limited, a dedicated leader in the world’s commercial salmon farming industry, to questions surrounding industry best practices for safe seafood production in their isolated island environment.
FSM: What practices are you implementing to comply with increased demands on imported food safety?
NZKS: The focus of regulatory authorities in New Zealand has always been on prevention of contamination during processing operations; New Zealand Industry and Regulatory personnel have been at the forefront of this internationally through international forums such as Codex Alimentarius
Access to the U.S. market is a combination of meeting the requirements prescribed by the New Zealand competent authority New Zealand Food Manufacturers Association (NZMAF)– New Zealand Food Safety Authority (NZFSA) who communicate with either the U.S. Food and Drug Administraion (FDA) or U.S. Department of Agriculture Food Safety and Inspection Service (FSIS) and information from importers pertaining to local U.S. requirements. So very much a watching brief on the impact of this legislation on NZKS operations that should become clearer as full implementation of the provisions of the Food Safety Modernization Act come into play.
In a recent FDA mission (Sept/Oct 2010) to New Zealand, NZKS hosted NZFSA auditors and U.S. officials. The FDA brief was to determine how NZ regulators conduct audits and verifications. The mission was a success for the observers’ auditors and the company. The auditors were generally complementary about the company’s processes and systems and noted improvements in the culture of the organization from its “lean” implementation.
NZKS has recently subscribed to an international organization for the dissemination of compliance information, which enables member customers to view NZKS compliance information online. This access is currently under development.
The company strive to satisfy the demands of all our customers both regulatory and the purchasers of NZKS Product. In this respect, NZKS meets the various standards required by customers and are successfully audited by third-party agencies to these standards (currently accredited to “WQA” and “Spotless” Standards).
FSM: What are your greatest food safety-related challenges?
NZKS: The production of safe cold smoked RTE seafood and the challenge of getting our product into international markets largely via airfreight and the maintenance of the cold chain during these activities.
FSM: What controls do you implement when importing raw ingredients or materials for processing?
NZKS: NZKS implements three documented programs that form part of our registered risk management program approved by the NZ Regulatory Authority and customer third-party auditing agencies.
1. Approved Supplier Program
• Recently developed risk-based assessment model that determines the level and frequency of the monitoring of suppliers and the supplied /ingredients consumables etc.
• Risk assessment is based on the intended use of the final product [ready-to-eat (RTE) or cooked]; history of the supplier; regulatory controls if any the supplier is subjected to; risk that the ingredient or consumable poses (does it support growth of harmful organisms (microbes/yeasts/molds/etc,)
2. Testing Program
• Test for a range of organisms: aerobic plate count (APC), coagulase-producing Staphylococcus, Bacillus cereus, fecal coliform, Escherichia coli, yeast, mold, Salmonella, Listeria. The company also monitor minimum reportable limits and monitors regulatory alerts for imported foods.
• Testing is risk-based with ingredients/consumables either pretested prior to receipt at factory, tested on arrival and held or tested routinely post use as appropriate.
3. Allergen Program
• All ingredients/consumables assessed for any allergenic component.
• Company-employed qualified product technologists to provide expertise.
• Some experience in the use of the vital tool in understanding the transfer of allergenic components.
• New products go through a managed process where input is sought from all aspects of expertise within the company.
FSM: Has the isolated environment of New Zealand been challenging with regard to food safety? Why or why not?
NZKS: Generally No. New Zealand Industry and regulators have been recognized internationally and have taken lead roles in various international forums related to food safety.
FSM: What “best practice” would you like to share with your sector of the food industry?
NZKS: The introduction of lean methodology to the NZKS business. Benefits for food processors like us are the following: engagement of the work force, 5 -min morning meetings, and the problem-solving use of tools, process flow and minimal accumulation of inventory during processing, root-cause analysis of problems, etc. These are all best practice principles in the processing of safe food.
Founded on the principles of 5S:
• Sort: Identify and remove unwanted items materials, etc.
• Set in order: needed items have a home, clearly identified and available for use
• Shine, cleanliness: operator attention to own workspace, cleaning and inspection at end of each day
This has a special significance for food manufactures and numerous regulatory and other third-party auditors have commented on the orderliness and cleanliness of the premises.
FSM: Do you have a story where some issue/difficulties were successfully alleviated (e.g., contamination that was identified and solved, potential recall event averted, etc.)?
NZKS: Perth Incident 2010 (see following timeline):
December 21: Late afternoon call received by compliance manager while in Australia from Australian Quarantine and Inspection Service (AQIS) notifying positive Listeria.
The customer “Big Fresh Direct “ in Perth was contacted by New Zealand King Salmon Australia Pty Ltd immediately and asked to hold and collect from the floor all stock of the product date in question as a precaution.
• Five packets taken from consignment by AQIS for testing
• Eleven packets purchased by consumers (one of these packets were consumed by the shop manager)
• Balance of 284 packets was held
AQIS were notified of customer contact details “Big Fish Direct.”
NZKS senior management notified of incident back in New Zealand (evening).
The NZKS recall team, formed per NZKS standard procedure, and all required stock movement, inventory and production records needed were determined and actions taken to generate and verify them overnight.
Advised from AQIS that a request for product to be tested for count against Food Standards Australia New Zealand (FSANZ) food standard code part 1.6.1 prior to a “food inspection advice” being issued.
Silliker Lab Director Gill Parton contacted for a copy of the original results and whether a visit could be arranged. Listeria monocytogenes on Lab report number PER-50267389-0.
Travel arrangements made for the compliance manager to fly to Perth to meet with the customer, laboratory and AQIS.
December 22: NZKS Nelson investigation into the pending incident proceeded based on records gathered since prior evening.
NZFSA Verification Agency (VA) contacted in regards of the pending incident and dialogue begun.
NZKS (Perth) investigation into the pending incident got underway.
December 23: Received verbal confirmation from Silliker that the retest results were negative (<10 CFU/g for all samples).
NZKS Nelson notified of result.
NZFSA VA contacted regarding the result.
December 24: Copy of final report received from Silliker. Lab report number PER-50268078-0.
Notified by phone from AQIS that product could be released into the marketplace.
Jan 2011: Report wrap up and improvements done.
This incident highlights how manufacturers of RTE seafood products are constantly exposed to this threat from this microorganism and how our rigorous responses to any detection of Listeria spp. detected as part of the company’s Listeria management program are designed to prevent infection and gave the company confidence that in this instance the product was in fact unadulterated and safe.
The company was required by legislation to operate a Listeria management program that is subject to regulatory oversight. This program divides the processing environment and product into numerous zones that elicit different defined responses: after Critical Control Point (CCP) Zone 4 = product and product contact surfaces, Zone 3 = non-product contact surfaces in a product area, Pre-CCP Zone 2: non-processing areas, etc. The implementation of this program is overseen by a qualified microbiologist.
All testing is done in government approved laboratories that demonstrate conformance to specified standards.
NZKS takes it responsibilties to supply safe food extremely seriously and responds vigorously to each and every detection. Emphasis is on prevention of reinfection:
1. A task force is assembled for each detection. Personnel involved have knowledge of and understand the premises and the processes to enable a competent response.
2. Comprehensive decontamination processes are followed to eliminate any potential spread of the microorganism.
3. The RTE facilities are gridded to enable traceback and detect spread.
4. Recent and repeated detections of L. innouca in an area defined as K88 (smoke and brine facility) were eventually traced back to an infection behind a stainless steel wall lining. This lining was removed, the wall thoroughly cleaned and disinfected and then had a bonded surface applied to the wall with redesigned (removable) equipment redesigned hygienic facilities (hand basins). Since these improvements were implemented, we have received no further detection from this area. Prevention of infection from this source was successful.
Responses to these same questions by New Zealand vendors Cawthron, which provides high quality research, advice and analytical services to support the development of New Zealand’s seafood industry and sustainable management of the coastal and freshwater environment, and Oritain, a provider of commercial food origin systems, can be found at www.foodsafetymagazine.com/signature.asp.