BEST BUSINESS PRACTICES FOR PRODUCING BEEF HARVESTING, RAW NOT GROUND BEEF, RAW GROUND BEEF - PART 9 of 15

Blog #10 of 15 of this series shall cover raw not ground beef (RNGB) HACCP.

Todays blog, #9 of 15 - shall cover employee training (food safety, OSHA safety) and Sanitation, Preventive Maintenance Practices, Outside Vendors and Food Defense Programs for ABC Meat Company - a vertically integrated beef harvesting, further processing and grinding operation.

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IMPORTANCE OF AN EFFECTIVE HUMAN RESOURCE DEPARTMENT

Today the challenges that meat manufacturers face with regards to Human Resources (HR) is as diverse as the products they produce. A unique world within its own, human resources is much more than making sure that all of the T’s and I’s are properly crossed and dotted on W-4s and I-9s.

HR’s expansive breadth of responsibilities in the meat manufacturing industries involve such issues as bridging language and cultural barriers, developing, implementing and supporting both existing and new company policies and procedures, battling turnover rates, eschewing worker injuries, and keeping abreast with labor laws including their amendments. 

To be truly effective, HR personnel must also understand the wide and rather expansive world of food and employee safety, be preferably bi-lingual and have a solid grip on all pertinent governmental regulatory agencies.

Human resources are just that.

It’s finding, focusing and cultivating the resources that are available for the benefit of the company as well as the employees themselves.

Regardless if companies are union or non-union, there is a proven pathway for all of these sources of humans that will lead to unearthing each person’s inherent and unique qualities, aptitudes and ultimate potentiality. 

This antidote’s common denominator smoothly glides over geographic borders, language barriers, deep-seated cultural differences and seemingly draconian labor and regulatory laws. It’s merely respecting, hearing, listening, training and persistently educating the people that you’ve elected to employ.

A rather large segment of workers in the Food Industry are of Hispanic, Latino and Asian decent. These generally low skilled workers normally have had no subsequent experience involving Quality Control/Assurance including the more intricate systems of HACCP, SSOPs and the burgeoning SQF and BRC Systems.

Neophyte workers will only do what there are instructed to do and in some instances even less. Unless otherwise trained, apprentice employees will quickly adapt and skew to the unfavorable working habits that may already exist, which will undoubtedly be mimicked by the next wave of newly hired workers.

Depending on the specific food segment involved, newly hired and existing employees are consigned to competently and dexterously manufacture, package and ship a vast kaleidoscope of cooked, frozen, perishable and/or fresh foods and beverages.

It’s an established norm in the food and beverage processing sector that science based HACCP and SSOP systems are supported by a melting pot of Good Manufacturing Practices. But what foundation do GMP’s rely on?

Its people.

It’s not only the production line people, but also sanitation, shipping & receiving and maintenance people as well. After all, they are the ones who prepare and ship the product, clean the facility, and apply repairs to the equipment on a quotidian basis.

If people are the foundation for a company’s success, and, they most certainly are, then well-planned hiring, training and educating practices need to be in place and working.

If a company wants to constantly improve its position in its given industry, it must focus on its people.

Educating workers will help to inveterate self worth.

Self worth connotes self-esteem.

Self- esteem amplifies individual morale that naturally manifests itself into improved productivity and augmented longevity with employers.

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GENERAL PRODUCT & EMPLOYEE SAFETY TRAINING – HARVEST / RAW NOT GROUND BEEF (RNGB) AND RAW GROUND BEEF (RGB)

All newly hired employees as well as veteran employees continuously receive product safety and OSHA training each year. Training includes all departments including office personnel. All training is documented and placed in each employee’s personal file.

Top management at ABC is fully cognizant of the critical importance of initial and continuous training of all employees with regards to product safety and OSHA training.

The Human Resource Department plays a KEY, KEY role with helping to manage all activities of each employee and must have a general knowledge of all job assignment including general food and OSHA safety in order to be effective.

Continuous employee training is the “Keystone” to the success of this company. 

Through the continuum of receiving livestock to final shipment of excellent conditioned product it is the people who make the difference - not the programs.

Training is conducted individually as well as in group sessions. Plant meetings are held throughout the year with a quorum established and minutes of the meetings contents being recorded for any needed future references.

The subject matters that are held during training sessions are amended throughout each year. There are a number of reasons for this; New USDA Notices & Directives, Quality Assurance and Control issues to name but a few.

Periodically product training is received from outside resources as well as attendance to food safety workshops and conventions.

GENERAL SANITATION – HARVEST/RAW NOT GROUND BEEF / RAW GROUND BEEF

Master Cleaning Schedules are checked for all equipment in harvesting including the infrastructure itself.

ABC'S assorted SSOP’s and GMP’s have been put into place for the straightforward goal of preventing direct and indirect product contamination of meat products that are manufactured.

Both Quality Control/Assurance personnel have been trained and delegated with the implementation, responsibility and daily monitoring of our myriad SSOP’s.

Any needed corrective actions are documented on our PIP, Daily Pre-operational and Operational Sanitation Reports and when applicable, Corrective Action Reports.

XYZ Products Company supplies the industrial chemicals that are used for cleaning and maintaining our equipment and infrastructure.

Video training and bi-lingual materials are periodically scheduled for all chemical handlers to ensure that the chemicals are properly mixed and used as intended by the manufacturer as well as instructions of their safe handling. Diplomas of completion are awarded to each participant.

Exterior areas of the facility are included in our GMP’s and SPSs. Pest Control order is maintained by OKAY, a State Licensed Company and is supplemented with trained employees who document each interior and exterior traps for pest activities every production day.

PREVENTIVE MAINTENANCE PROGRAM

Plant Management at ABC holds true that a well-documented Preventive Maintenance Program (PMP) will augment significantly the overall operations.

ABC’s PMP Program is comprised of four (4) separate but interconnected categories:

A Logging of Maintenance Tasks Performed & To Be Performed

Planned Improved Program (PIP)

Maintenance Sanitation Operating Procedures (MSOP)

Written Job Safety Analysis (JSA)

Plant Management is fully cognizant that adherence to SSOP’s and general sanitation are critical areas of our operations. If sanitation is not consistently focused upon, accurately managed, monitored and verified, then there exists possibilities that cross-contamination can occur to our raw products. Listed directly below are the maintenance tasks that are performed every production day without fail;

LOGGING OF MAINTENANCE TASKS

The only method in which a company can accurately monitor and ultimately supervise and manage the infrastructure of our facility and its machinery is to have verifiable maintenance logging of all applicable maintenance tasks. 

The Logging sheet designed for ABC have been customized to eliminate (as much as possible) the daily burden of the maintenance workers themselves having to write out each and every task that are performed. Rather a simple “check-off- list” with sub-categories (i.e.; Jarvis Equipment, Carcass Cabinets, Walls, Floors, Ceilings, et cetera) ABC shall document and verify any trends of breakdown equipment(s) while verifying that all work performed is conducted in a safe and sanitation manner.

LOGGING OF MAINTENANCE TASKS

The maintenance log has listed “preventive maintenance tasks” that are carried out every production day and documented as such. The maintenance log was intended to be flexible enough to append or delete certain tasks when required.

An integral part of the logging are work and power tool permits that are issued and documented by the hired 24/7/365 guard-service to all outside contractors. Work performed by an outside contractor will be recorded with a copy of the completed work order(s) and will be incorporated with that particular day’s security log.

CONTRACTOR/SUB-CONTRACTORS, VENDORS

The 24/7/365 Security Guard-Service has been assigned the responsibility to issue one-day work permits for all outside maintenance related contractors/sub-contractors. Both the arrival and departure times of contractors are noted in the security logs. As part of normal protocol the guard service will contact a ABC representative prior to the contractor entering onto the plant premises.

Every contractor, sub-contractor and vendor who contractually / verbally agrees to provide services and/or supplies to ABC must be in full compliance with existing USDA, (GMP’s, SSOP’s), CAL/OSHA and EPA requirements including any other applicable governing regulatory agencies. This includes but is not limited to the following:

The Contractor Sub-Contractor, Vendor will maintain an effective Injury and Illness Prevention Program as set forth in Senate-Bill 198:

They shall provide adequate safety and training programs to their employees including routine inspections of the equipment used in carrying out their contractual/verbal duties.

A Contractor Safety Policy Statement must be completed by all outside contractors with a copy of the contractors existing Worker’s Compensation Contract prior to any work being performed. These documents are filed by plant management for any possible future references.

The plants refrigeration system is presently contracted out to an outside contractor. All needed preventive maintenance and general repairs to the refrigerated systems have been assigned to them. Electrical work is contracted out to various Electrical Contractors. Only pre-authorized state licensed Refrigeration/ Electrical Contractors will be contracted to perform any additions/preventive maintenance and/or repairs to the plants electrical systems.

New construction (i.e.; interior, exterior, machinery placement, etc.), will entail specific written precautions to each situation at hand in order to preclude any cross-contamination. No construction will be allowed during production hours. Eclectic preventions in the guise of coverings, increased micro testing implemented in writing and made aware to both the construction contractor and Quality Control, Assurance personnel.

All construction personnel will be subject to all applicable GMP’s and SSOP’s. Applicable written GMP’s and SSOP’s will be forwarded to the construction personnel An inaugural meeting will be held, including daily monitoring by assigned plant personnel, with follow-up meetings to ensure compliance is being followed. 

Planned Improvement Program (PIP)

Slightly over a quarter of a century ago on April 5, 1972 the FSIS of the USDA developed and introduced a Planned Improvement Program (PIP) (MPI-W-NOTICE 47) that was intended for Establishments themselves to identify deficiencies/deviations and to initiate and document corrective actions to their facilities, equipment and general operations.

This indirect pre-cursor to the HACCP philosophy of 2022, which was intended for facility and equipment improvements, and situations where contamination of products is a potentiality, advocated that Establishments themselves become more preventive in nature and more accountable for the conditions and actions of their entire operations.

ABC Management believes that utilizing the elderly but respected PIP Program and expanding it with our myriad wellspring of Good Manufacturing Practices will help to ensure that our plant and its entire operations are being properly monitored and maintained in a clean and safe manner. 

Clearly documented in the Federal Register dated July 25, 1996 on Page 38834 its stated:

“Establishments that identify and correct unsanitary conditions in a timely manner and make proper disposition of any affected product will be considered to be in compliance with the Sanitation SOP’s regulations.” 

Our voluntary PIP Program has been developed and designed to monitor, amend and verify thereafter, acceptable conditions for our entire facility. The Maintenance Department acts as a key player for our PIP Program.

Fusing together with a seamless thread, the four elements that comprise the Preventive Maintenance Program allows Quality Assurance and Quality Control personnel be in a superior position to both focus and prioritize the myriad areas that are ubiquitous with harvesting and further processing Establishments.

ABCs PIP Program covers all interior and exterior areas of the plant up to the legal property demarcation line. Digital pictures are intermediately taken that helps to verify that a particular item is either identified to be corrected, in the process of correction or has been completed as planned. Each individual PIP Item, (“Work Order”) will contain the following monitoring points:

• A documented date of the discovered deficiency/deviation.
• The deficiency/deviation is assigned an individual number.
• The location of the needed deficiency/deviation is documented.
• The person who identifies the deficiency/deviation is recorded.
• A Brief explanation of the deficiency/deviation is noted.
• A target date for the successful completion of the deficiency/deviation is documented.
• The completed date of the deficiency/deviation is recorded
• Verification initials that a responsible QC employee performs a particular PIP item has been corrected and/or eliminated.
• Any relative comments when necessary are recorded as such.

Work orders are PIP schedules, Pre-Operational and Operational copies or direct letterheads describing needed maintenance is maintained. Completed work orders are filed for one (1) year in the QA office for any needed future references.

MAINTENANCE SANITATION OPERATING PROCEDURES (MSOP’S)

A well-defined and proactive MSOP Program naturally angles the maintenance workers towards the intrinsic philosophies involving the deterrence concepts of fundamental HACCP / SSOP's & GMP’s. 

Personnel of the Maintenance Department are given the responsibility and accountability regarding the physical, chemical and microbiological hazards that could conceivably be conveyed whenever they apply their services to processing and non-processing areas. A hands-on and well organized PMP Program assists plant management with helping to “rein in” the incidences of the chances of cross-contamination involving physical, chemical or microbiological hazards

In general maintenance personnel can instigate any of the following misfortunes involving our production processes;

PHYSICAL HAZARDS: Any single assortment of hand tools nuts, bolts, washers … including but limited to … ferrous and non-ferrous, stainless steel shavings, glass, plastics and wood oddments.

CHEMICAL HAZARDS: A mishmash of oils, solvents, acids, paints, lubricants & other chemical hazards.

MICROBIOLOGICAL HAZARDS: A blend of sullied hand’s, besmirched clothing and/or defiled hand-held work tools including the workers themselves who can act as silent vectors of viruses and other relevant pathogenic cross-contamination hazards.

A catchall antidote for any physical, chemical or microbiological hazard(s) is to institute a MSOP Program as an integral appendage of the PMP Program. The MSOP System has been explicitly tailored to every one of the company’s unique manifested needs.

The foundation of the MSOP System is comprised of the company’s already established Good Manufacturing Practices (GMP), Standard Sanitation Operating Procedures (SSOP’s) as well as our science based pathogen reduction HACCP System. 

All mechanical tools and germane items i.e.; food grade lubricants that are used in the interior area of the facility must be maintained in a sanitary manner. Listed below are company policies regarding MSOP practices:

• Food grade lubricants and their applicators are stored separately as well as unique “color coded application guns” being used only for production uses. 
• Equipment that has undergone repairs during or after production proceedings are cleaned, sanitized, checked and documented by QC personnel.
• All hand-held working tools are clean prior to and after maintenance tasks involving production equipment. This task is performed by the use of a Quat DS. A blue lugger containing 600 PPM is located and monitored by QA/QC. Maintenance personnel always verbally inform QA/QC prior to and after maintenance tasks are completed and part/tools inventories can be verified.
• Maintenance workers are to wear clean dark colored smocks, a hairnet and black bumper cap while working. All personal hygiene requirements contained in the plant’s SSOP’s must be followed as well. Failure to follow company policies regarding personal hygiene will result with disciplinary actions being taken.
• MSOP forms are filled out to verify that such action is carried out on a consistent basis. 
• During production any repairs in the production areas are verified during and after needed tasks. This is accomplished by the initials of maintenance personnel as well as QC personnel. 
• In the event a floor drain back up occurs resulting with waste water flooding into critical area(s) of the facility (production rooms, storage coolers, shipping/receiving docks, bathrooms, exterior areas of the facility) the area’s will be cordoned off and tagged by QA/QC personnel.. Maintenance will be immediately notified to rectify the problem. Any product or packaging materials that had come into contact and or are suspected of coming in contact with the waste water will be tagged and de-natured disposed of and noted on either the pre-operational or operational report.

PRODUCTION COOLERS

Any product/pallets/packaging materials being processed or stored in the near proximity will be removed/covered until the clearing of the drain(s) is accomplished. Once the drain has been cleared the immediate area of the floor will be cleaned and sanitized as per Procedure D under the heading of floor.

STORAGE COOLER

Any product/pallets/packaging materials stored in the near proximity will be removed/covered until the clearing of the drain(s) is accomplished. Once the drain has been cleared the immediate area of the floor will be cleaned and sanitized as per Procedure D under the heading of floor.

BATHROOMS

The bathroom shall be closed off until any back-up drain(s) is finally cleared. The bathroom will be hosed down with hot water and soap. Once the drain has been cleared the immediate area of the floor will be cleaned and sanitized as per Procedure D under the heading of floor.

SHIPPING AND RECEIVING DOCKS

Any product/pallets/packaging materials stored in the near proximity will be removed/covered until the clearing of the drain(s) is accomplished. Once the drain has been cleared the immediate area of the floor will be cleaned and sanitized as per Procedure D under the heading of floor.

EXTERIOR AREAS

Any pallets or other items that may be brought into any of the interior areas of the plant that is near the general proximity of a backed-up drain will immediately be removed. After the drain is cleared the areas will be hosed down with hot water and soap. In the event the water treatment area becomes clogged the area will be isolated and the drains cleared. The area will then be hosed off with hot water

NOTE A: Under the plants “Preventive Maintenance Program” the issue of back-up drains is addressed. Maintenance preventive measures calls for the drains to be snaked out. This is accomplished by snaking the drains outlets from the exterior areas as well as the drains themselves. Any pre-operational or operational occurrences will be documented on those report sheets as well as the daily preventive reports that are monitored by QA/QC personnel. 

NOTE B: Wooden/plastic pallets and power jacks will be removed out of the room and cleaned with hot water and soap. This procedure would be documented by QA on the pre-operational or operational form with germane corrective action form as well as the daily maintenance form.

NOTE C: All affected employees engaged with the cleaning of any drains, despite the location, will change out their smocks if applicable, and wash the soles and sides of their shoes with hot water and soap. All other established personal hygiene practices are to be followed as well. 

• Any deviations will be corrected and noted on the SSOP Operational Log and the daisy-chained Correction Action Log. 
• In addition any physical items, (among others) are to be accounted for before and after the maintenance task at hand are addressed.
• In the event any production equipment is removed from the production site and is ready to be returned, Maintenance personnel are to notify QC personnel beforehand in order to verify that the equipment is question was properly cleaned and sanitized and signed off by QC as prior to re-entry.
• It is a longstanding Company Policy that the integrity of the product must never be ignored when maintenance exercises are being performed during the course of a production day. The equipment or infrastructure that is having maintenance applied must have a QC Tag applied up until the area is finished. Quality Control personnel will be responsible to ensure that product integrity is not violated.
• All equipment parts, lubricants, hand tools, etc., are to be placed away from any exposed products in order to avoid any possible cross-contamination (physical, chemical or biological) possibilities. This same policy applies also to finished product areas or any other conceivable area that may cause cross-contamination to raw product and/or packaging materials.

 JOB SAFETY ANALYSIS

All employees, despite their job assignments, must be continually safety trained to learn the hazards and risks that may be encountered on the job every day. When job assignments change, the hazards themselves indelibly change too. 

The general Job Safety Analysis (JSA) that has been put into place is centered on ABP unique inventory of equipment including both the inner and outer infrastructure including to the plants demarcation line with the city. The JSA’s are intended to both inform and remind maintenance personnel of the following areas:

• Is there required Personal Protective Equipment (PPE) to be used during a specific maintenance job?
• Is a Lockout/Tagout/Blockout required?
• A General Job Step Sequence is listed.
• General Potential Hazards are listed.
• A General Recommended Safe Job Procedure is listed.

A table of contents lists the entire general job tasks that could be performed by maintenance personnel followed by the JSA’s themselves. PPE is an integral part of the company’s industrial safety and health programs regardless if it is production, shipping/receiving or in this case maintenance.

As a company ABC has many responsibilities to abide to, monitor and enforce. Employees have also the responsibilities to keep both themselves and others around them safe and injury free at work.

NEW EQUIPMENT & CONSTRUCTION GUIDELINES

 NEW EQUIPMENT

In the event new equipment is being purchased, Plant Management, Quality Assurance and the Maintenance Department Personnel will be included in the decision making. 

The new equipment must be constructed of non-porous materials (including FDA/USDA approved materials) as well as easy wash/cleaning down access. The manufacturer will be instructed to evince recommended cleaning and sanitizing procedures in order to ensure that proper cleaning and sanitizing procedures will be consistently carried out.

NEW CONSTRUCTION

A series of meetings involving the hired contractor, Plant Maintenance personnel, Quality Assurance and Plant Management will be held. Emphasis will be stressed concerning sanitation. Written precautions will be documented and developed to ensure against contamination of on-going production construction activities, such as; i.e. clothing, air quality, clean-up schedules, foot traffic, barrier abatements, increased environmental microbiological sampling, (listeria, APC, etc.), etc. Quality Assurance will monitor and verify on a daily basis that all precautions and abatements are continually working as intended and to report any breach concerning possible contamination.

In the event any cross-contamination to product contact surfaces/or the products themselves during either scheduled or unscheduled maintenance tasks during or prior to production proceedings, QC personnel will be notified and will the deviation(s) will be noted in either the Pre-operational or Operational Reports including Corrective Actions Logs. 

Teamwork is the name of the game here.

Any company that bases its policies and procedures on pragmatism and being proactive rather than merely reacting to regulatory consequences and their intrinsic negative side effects will have positive results.

Fixing problems before they can happen will more times than naught fulfill and often exceed any set of objectives and goals. In due course such a commitment can only result with a safe, clean and money saving workplace

HOT/WORK CONSTRUCTION PERMITS

Date/Time of Scheduled Work ______________________________________________

General Location of Work__________________________________________________

Contractors Business Name _________________________________________________

Nature of the Business _____________________________________________________

Contact Person of ABC __________________________________________________

Names of all Contractor Employees on Site

1. _____________________________________________________________________

1. _____________________________________________________________________

1. _____________________________________________________________________

1. _____________________________________________________________________

1. _____________________________________________________________________

NOTE: The use of any piece of equipment capable of producing flame or spark is prohibited without a hot work permit.

A Hot Work Permit is required for, but not limited to, welding, open flames, sandblasting, portable grinders, electric and battery operated equipment, hot tapping, etc.

Hot Work Permits are good for one (1) working day. If work is continuous, a new permit will be issued each subsequent day.

This form is to be attached and filed for the applicable day that it is issued with other Security Forms. 

THIS FORM ALSO APPLIES TO REFRIGERATION SERVICES AND OTHER GENERAL MAINTENANCE WORK THAT IS RENDERED.

GUARD SERVICE NAME________________________________________________

GUARD SERVICE SIGNATURE ___________________________________________

FOOD DEFENSE PROGRAM

ABC has in place a Food Defense Program (FDP). ABC has been registered with the FDA as per the United States Public Health Security and Bioterrorism Preparedness Act of 2002.

ABC is fully aware of the need for a well-planned and documented FDP because of the high profile items that it produces. There are delegated assignments of supervisor responsibility as well as on-going communication with newly hired and established employees. Our written security program includes;

• Hazard Assessment(s);
• Incident Investigation(s);
• Hazard Correction(s);
• Training and Instruction;
• Documented Monitoring;
• Record Keeping

A 24/7/365 Guard Service assists ABC with its FDP. Enhanced plant security is achieved as the plant boundaries are secured to prevent any unauthorized entries. Posted signs of No Trespassing, including visitor badges and dissimilar monitoring protocols are in place around the facility.

A daily checklist covers plant activities. The checklist is filed in sequential order for future references. FDP meetings are held which helps with communicating and abating any potential security hazards.