Publisher Platform: Questions Boar’s Head and FSIS need to answer

And there will be other questions for others too.

The great thing about my job is that I know a lot of smart people in Food Safety who really care. Over the past few days, people have been sending me questions that need to be asked and answered by Boar’s Head and the regulators, FSIS.

And what about third-party auditors and retailers?

Feel free to send me any other suggestions.

USDA FSIS Questions: Authority, Organization, Procedure, and Data Questions:

• Inspections:
  • Who, what are the names of each of the persons who conducted these inspections?
    • What are the qualifications of the FSIS VA contracted employees to perform these inspections?
    • How often were they in the factory?
  • Who do the contracted FSIS VA inspectors report to?
    • Who reviews their inspections? We want names. . .
    • How quickly are their reports written and submitted after the inspections? Report lead time “TAT”?
    • Who manages the corrective action procedures? Is this done by the VA office, or by the federal FSIS, or both?
      • Are the corrective actions resolved through an objective and verified process?
        • EX. Did the factory send a photo or document of the corrective actions and did an inspector or their boss sign it?
    • Where is the inspection data managed, and is the data managed so that FSIS can see food safety risks and trends?
      • Is there a time stamp on the report data?
      • Is there a way to track corrective actions within the system?
      • Is there a unique identifier for who approves reports, corrective actions, etc.?
• Listeria Testing:
  • Where are the test results stored?
  • Who has access to it?
  • Who makes decisions about NR and corrective actions?
  • Where are the results of corrective actions?
  • Is this data easy to analyze for food safety risks and trends?
• Authority:
  • Can FSIS close a facility for being unsanitary? AND does the VA state contracted FSIS by extension have the authority to close a facility for being unsanitary?
    • If so,
      • Why wasn’t this factory closed?
      • Wasn’t it “unsanitary enough”?
      • If this isn’t bad enough to close, what is?
    • If no,
      • Who has the authority to close a factory?
      • What is the process for getting the information to that department?
      • Why wasn’t that done for this Boar’s Head Facility?

Boar’s Head Questions: Procedures, testing, auditing, data management, management:

• Provide evidence for all internal and external food safety audits and inspections
  • Would you be willing to provide all third party SQF audits performed by Eagle Certification over the past 3 years for Every Boar’s Head Facility?
    • To have an SQF certification, you need a food safety program. Would you be willing to provide the complete food safety program, all SOPs and logs used to obtain that certification?
    • Are you prepared to provide all deficiencies identified and corrective actions implemented?
  • Why did you choose Eagle Certification as your SQF Certification Authority?
  • Who was your certification authority before Eagle certification?
    • If you changed certification authorities, why did you change?
• Sanitation, environmental monitoring, product testing and laboratory:
  • Which laboratory was used for environmental monitoring and product testing?
    • Obtain laboratory accreditations, for example ISO 17025
    • Provide all laboratory results
  • Provide the SOP for the Boar’s Heads Sanitation Program
    • Provide all logs associated with the SOP
  • Provide the SOP for their “Environmental Testing Program”
    • Provide all logs associated with the SOP
• Organizational structure for food safety management:
  • Can you provide a company organizational chart for food safety decisions?
  • Who manages food safety at the Virginia Facility?
  • Who at the company headquarters managed food safety for the food safety of all boar heads?
  • Did Boar’s CEO visit the Virginia facility? Were they conducting unannounced internal food safety audits and inspections at your facilities?
    • If so, can you provide the inspections, audits and corrective actions?
  • Were Boar’s directors aware of all FSIS inspections conducted, nonconformances noted, and corrective actions (or lack thereof) implemented?
    • If so, why was there no executive management and follow-up to the numerous food safety issues identified?
    • If not, why? AND do their processes now ensure that business leaders are monitoring food safety issues at every facility level?
      • If there are processes, can you share them?
• Recall management and deli: (We want to ensure that no more listeria problems pop up at random delis in the future)
  • Can you provide the SOP for your product recall program?
  • Can you provide the documented steps you have taken to manage the current recall for all products you have voluntarily recalled in the past year?
  • How many of your customers have you contacted?
  • What did you tell your customers to do with the contaminated product(s)?
    • Were you able to track which customers performed the requested actions?
  • Can you provide the correspondence sent to your customers?
    • Have you kept track of what customers saw, responded to, or didn’t respond to your recall?

I had posted this before Marler Blog.