Friday, November 16, 2012

Small Independent Growers and Shippers

  Please refer to these food safety recordkeeping requirements along with the product trace-ability. Currently, the most common recordkeeping is performed with paper and transferred to spreadsheets for all food safety records. 

These are the two most critical points many traceback systems are not accomplishing at this point:

1. Tracing of food safety activities and prevention with time-stamped reports along with complete documentation with the food safety plan a chain of responsibility to maintain these records. Important note to keep in mind, if you export goods overseas, your traceback system must be in a format to exchange into foreign tracing systems (Unix is supported by foreign applications).

2. Maintain surveillance of food borne illness prevention practices to be made available upon inspections, or on demand. You can either dedicate an employee to the surveillance of practices, or implement a surveillance recording system to provide this data. Once again, a dedicated employee will need to be monitored with time-stamped recordkeeping. Or, a time-stamped surveillance system can accomplish the same thing with much higher ROI than labor.

These are just two parts to the new act that are misunderstood. There is no traceback system on the market besides ScoringAg that are fully FSMA compliant to meet the standards required by the new law. Please, take the time to review your recordkeeping systems and compare them to the new law. These two rules along with updating your food safety and food defense plans will be essential.

Systems Consulting can help you meet these two requirements.

Sunday, October 21, 2012

FDA releases an updated guidance

Important Updates Regarding Food Safety Modernization Act (FSMA ) Recordkeeping Requirements

Registration Update

Registration Update

Guidance for Industry: Necessity of the Use of Food Categories in Food Facility Registrations and Updates to Food Categories

Monday, October 15, 2012

Things are getting serious

Keep in mind: PTI is not FDA compliant as it is only a produce organization initiative with a brand tracking code, much of which applies to Big Box stores in the US and Canada. It still doesn’t work throughout the whole food and feed supply chain. If you ship to other countries you are aware of the significance of this situation.

If the customer of your product is one of the more then 60,000 small and medium size retailers, without the new readers on the check-out counter, it is useless to put them a GTIN code on it. If you are re-sorting, re-packing and commingling you will experience difficulty with GTIN tracking code. We can implement easily a GTIN code on existing labels as there is no science behind it without extra charge if someone has one.

When you have to make a decision which system is the right one for your company, just let them take the pizza test.
Think about all the ingredients in a pizza with all your favorite toppings. Every single ingredient with their compounds has to be traced back to the source.
As a producer you need to think about where your product will end up. Will it become a nut in a candy bar, an anchovy on the pizza, a berry in a jam jar or cake or the flour on breaded fish? Or will it simply be your cheese or your tomato on a hamburger?

The labels have to match the information from the required records and have to be 100% human and machine readable on the case level; soon it will be also on item-level.
The searchable product code has to point to the record to confirm the information on the label like, date harvested, and have proof of origin plus product and PLU code.

 Dr. David Acheson (former acting director of FDA)

Friday, September 28, 2012

Mandatory Federal Registration - FSMA - Starting on Monday, October 1, 2012

As we are receiving every day more and more phone calls about the new FDA Facility Registration that will be coming mandatory starting on October 1, 2012 and ending on December 31. 2012, we have decided to put the answers together as it is not easy to find them on one piece of paper on the FDA pages.

Who is required to register as food facilities, which farms or Food/Feed handlers are required to register as food facilities with the Food and Drug Administration?

All domestic and foreign facilities that manufacture, process, pack or hold food for human or animal consumption in the U.S. are mandated to register with FDA.

What do I have to do if my facility is already registered?
All facilities that are required to register must renew their registrations during the period beginning on October 1 and ending on December 31 of each even-numbered year.  

What is a food/feed facility?

A food facility includes any factory, warehouse (course grain/hay storage, drying or grain cleaning or mixing or conditioning facility) or establishment that manufactures, (mills, or feed grinding/mixing operation) or processes, packs, or holds (bin storage) food or feed.  Manufacturing/processing activities include making food (feed or rations) chopping from one or more ingredients, or synthesizing, preparing, treating, modifying, or manipulating food or feed crops or ingredients. 

On farm washing, trimming off outer leaves, and cooling produce are considered part of harvesting and would not require classification as a facility if done on the same day as harvesting. If you hold the harvest in a storage/cooler or warehouse you are a facility.

Which farms are required to register as food facilities with FDA?
if you grow it, store it, pack it, ship it

Farms must register as food facilities with the Food and Drug Administration if they:
Manufacture, process, pack, or hold food/feed beyond what is considered harvesting.

Direct market less than 50% of their product. (Tester Amendment)
In this instance, direct marketing means direct farmer-to-consumer sales and does not apply to stores, restaurants and schools.

Manufacturing/processing activities include making food/feed from one or more ingredients, or synthesizing, preparing, treating, shelling, drying, modifying, or manipulating food/ crops or ingredients.  Examples of manufacturing/processing include: Grains/Seeds and other Foods/Feeds

  • Cutting, Silage, Hay Processing
  • Peeling,
  • Trimming,
  • Washing,
  • Waxing,
  • Eviscerating,
  • Rendering,
  • Cooking, Grain Roasting
  • Baking, Cotton Ginning
  • Freezing,
  • Cooling, Drying, conditioning
  • Pasteurizing, Proponic acid treating grain
  • Homogenizing,
  • Mixing, Commingling
  • Formulating, Hulling
  • Bottling, sizing, sorting
  • Milling, Mixer/grinder TMR / rolling/ flaking
  • Grinding, Nut Hulls,
  • Extracting juice, Shelling
  • Distilling, DDG’s
  • Labeling, or
  • Packing.

Additional Food Categories for Foods for Human Consumption:
  • Acidified Food (see 21 CFR 114.3(b));
  • Cheese and Cheese Product Categories: Soft, Ripened Cheese; Semi-Soft Cheese; Hard Cheese; Other Cheeses and Cheese Products;
  • Dietary Supplement Categories: Proteins, Amino Acids, Fats and Lipid Substances; Animal By-Products and Extracts; Herbals and Botanicals;
  • Fisher/Seafood Product Categories: Fin Fish, Whole or Filet; Shellfish; Ready to Eat (RTE) Fishery Products; Processed and Other Fishery Products;
  • Fruit and Fruit Products: Fresh Cut Produce; Raw Agricultural Commodities; Other Fruit and Fruit Products;
  • Fruit or Vegetable Juice, Pulp or Concentrate Products;
  • Low Acid Canned Food (LACF) Products (see 21 CFR 113.3(n));
  • Nuts and Edible Seed Product Categories: Nut and Nut Products; Edible Seed and Edible Seed Products;
  • Shell Egg and Egg Product Categories: Chicken Egg and Egg Products; Other Egg and Egg Products;
  • Vegetable and Vegetable Product Categories: Fresh Cut Products; Raw Agricultural Commodities; Other Vegetable and Vegetable Products; and
  • Baby (Infant and Junior) Food Products Including Infant Formula.
Additional Food Categories for Foods for Animal Consumption:
  • Grain or Grain Products (i.e., barley, grain sorghums, maize, oat, rice, rye, wheat, other grains or grain products);
  • Oilseed or Oilseed Products (i.e., cottonseed, soybeans, other oilseeds or oilseed products);
  • Alfalfa Products or Lespedeza Products;
  • Amino Acids or Related Products;
  • Animal-Derived Products;
  • Brewer Products;
  • Chemical Preservatives;
  • Citrus Products;
  • Distillery Products;
  • Enzymes;
  • Fats or Oils;
  • Fermentation Products;
  • Marine Products;
  • Milk Products;
  • Minerals or Mineral Products;
  • Miscellaneous or Special Purpose Products;
  • Molasses or Molasses Products;
  • Non-protein Nitrogen Products;
  • Peanut Products;
  • Recycled Animal Waste Products;
  • Screenings;
  • Vitamins or Vitamin Products;
  • Yeast Products;
  • Mixed Feed (e.g., poultry, livestock, equine);
  • Pet Food;
  • Pet Treats or Pet Chews;
  • Pet Supplements (e.g., vitamins, minerals); and.
  • If none of the above food categories apply, print the applicable food category or categories (that does not or do not appear above).
Total list in the link below:

Here is the link to the registration page:

Monday, September 24, 2012

Food Safety Modernization Act (FSMA)

     Information Resources
    FDA Delays Registration For FSMA RENEWALS ONLY. All NEW registrations are required between October 1, 2012 and December 31, 2012. Take the time to register, however, you will need your product safety plan completed prior to registration. Contact us at for assistance. Free initial consultation


      Food Maker Registration Under FSMA Including Farms Begins Oct. 1

      Leavitt Partners Blog

      Food Safety Magazine   


   Technology has recently come the front of agriculture safety. From time-to-time, the government recognizes the need to protect the public from diseased produce and fruit. The immediate challenge is quality testing and  tracking methods for early detection of salmonella contamination. Additionally, efficient tracking subsequent to early detection potentially thwarts salmonella casualties by providing "field to fork" tracking. Imagine having instant information tracing your food on the table to the field it was produced in. Additionally, tracking where the see was produced. Systems Consulting introduces ScoringAg, a cloud based software completely customized for your select product and handling from the seed producer to the fork.

   The United States Food and Drug Administration begins the Federal Registry process beginning October 1, 2012. Many feel there is a lack of preparedness and education for the producers to fully comply. While this may be true, Washington has made it clear they expect the FDA to push this program into place or face legal action. For producers failing to meet new sanitation compliance and documentation failures along the supply chain face additional penalties enforced under the code. The fines can be very costly expenses to the producer.

Sunday, August 26, 2012

Why have a consultant?

   The simple reason is two fold, it saves you time and money. Think about what you do for a living. Are you a doctor, mechanic, plumber, or electrician? That's right, I stink at each one of those occupations and I am much more productive in my day by hiring you to do that task. I can spend my time doing what I do best and make more income because of it. So, what I do for you is find the solution that best fits your needs at a better price because you and I are partners on this. I want the best for you.

  • Network Solutions
  • VoIP Solutions (local hardware or hosted?)
  • Co-Location/Data Center
  • Disaster Recovery
  • Virtualization
  • Audio
  • Video
  • Home or Commercial media centers and automation
  • Security Systems and Monitoring

Saturday, August 25, 2012

Future Communications

   Network carriers have the products in place and priced to the advantage of the customer right now. We should see a rise in virtual platforms between the interconnects. In a rude explanation, they will cannibalize each other. Competition will be rabid as sales people will cut their commissions for the purpose of the sale. However, after communications with a few IP hardware companies, we will see some tremendous pricing for the small business to take advantage of. Keep your eyes and ears open. Stay in touch with me @ (208) 994-1350 to learn how your business will benefit financially with an incredible ROI.