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The Value of GMPs in Achieving Globally Recognized Certification
by Heather Angus-Lee
As this year marks the 10th anniversary of the current Good Manufacturing Practices (cGMP) Coalition—formed by 60 food companies and food trade associations working with the FDA to revise guidelines for preventing adulterated foods in production, packing, and holding facilities—it seems a good time to review the role GMPs play today in the industry. As well as serving as the basic principles guiding personnel, equipment, facilities, production, and process controls, GMPs relate directly to Hazard Analysis and Critical Control Point (HACCP) programs, and serve as building blocks for Global Food Safety Initiative (GFSI)-recognized food safety and quality standards. SQF, BRC, FSSC 2200, and other global standard schemes are growing in importance as retail customers demand certification from their food suppliers. GMPs also play an increasingly vital role as the Food Safety Modernization Act (FSMA) emphasizes requirements for a food safety plan that are similar to what is needed for a HACCP plan.
Giovanni Food Company knows all about HACCP plans and globally recognized food safety standard certification. The Syracuse, N.Y.-based company makes and sells salsas, spaghetti sauces, and juices to retailers as well as to the food service industry. Giovanni incorporates GMPs as fundamental prerequisites to their HACCP programs, including the juice HACCP program that is FDA-mandated. In turn, their HACCP programs tie into the SQF Level 2 certification that Giovanni received in 2013.
A couple of years ago, Giovanni underwent a Cook and Thurber audit through NSF International, an audit that “doesn’t have the same recognition within the industry as SQF,” says Alan Patapow, quality manager at Giovanni. “So when it came time to renew our audit, we thought SQF would be more advantageous to us.” They stayed with NSF for the SQF audits; NSF also oversees Quality Assurance International (QAI), the auditor of Giovanni’s organic certification and soon-to-be gluten-free certification.
“SQF seemed more suitable to us than other GFSI-recognized food safety standards,” says Patapow. “BRC is a lot more involved, and we didn’t feel we needed it all.” A lot of BRC deals with marketing of goods in Europe and while Giovanni Food exports to Israel, Asia, and Canada, they don’t do much business in Europe. Unlike the BRC standard, SQF requires a full-time, onsite standard practitioner employed at the company before, during, and after audits. Patapow is the SQF practitioner at Giovanni; he underwent training at a NSF workshop prior to taking up his role in 2012.
Patapow explains that there are modules within the SQF code that are either general—such as Module 2 that emphasizes food safety through traceability, recall, validation, verification, and management commitment—as well as modules more specific to Giovanni’s business, such as SQF Module 11 that has stipulations around GMPs for personnel hygiene and welfare, building construction, equipment, and pest control. “SQF basically mimics the HACCP program for food safety and risk assessment,” says Patapow, quoting part of SQF Module 2.4.3: “‘A food safety plan must be prepared in accordance with steps identified with HACCP guidelines’…” He also notes the similarity of that alignment with HACCP with that found in FSMA requirements.
GMPs relate directly to HACCP programs, and serve as building blocks for GFSI-recognized food safety and quality standards.
The SQF process “took us a little longer than we anticipated,” says Patapow, who spent about 18 months working on the certification project with a quality assurance assistant. “We had to get practitioner training out of the way, then develop the program. To help us out, we brought in a SQF consultant for several days to conduct a pre-audit. Based on those recommendations, we made the changes needed to our facility and processes, and completed the final audit for Level 2 certification in September 2013.” Giovanni demonstrated their exceptional food safety and quality control practices during the two-day facility audit by NSF.
Process changes were the biggest adjustments for plant workers transitioning into SQF, says Tim Budd, plant manager, Giovanni. “GMPs and food safety were already top priority here,” he notes, but there were changes to the scheduled processes for the products and more formalized monitoring of CCPs for the various HACCP plans. Working with Cornell University Cooperative Extension, processes were established that incorporated these critical factors into HACCP programs to achieve not only food safety, but desired product quality and shelf stability.
Patapow says, “Our QA team would go out and do monitoring training with plant employees, walk the facility and observe these activities, and conduct mock SQF interviews to determine their understanding of some of these changes.”
Budd thought TV would be a good way to make sure that critical data is, literally, in the face of his employees “instead of just standing in front of them talking at meetings,” he says. So the company mounted a large, flat-screen TV in the lunchroom on which information constantly scrolls about HACCP, SQF Level 2, as well as allergen management, handwashing, and other GMPs, even photos such as right and wrong label placements on Giovanni products. “The information includes explanations,” says Budd. “If you don’t explain the ‘why,’ it’s meaningless—you don’t get the cooperation from employees.”
Patapow says “the TV approach certainly has bolstered our training and awareness for our food safety and quality programs,” including helping workers prepare for “pertinent information for when the auditor came in.” Indeed, the SQF auditor from NSF told Patapow that she was “quite satisfied by the interviews conducted with employees.”
Giovanni uses ERP software built for the food industry, with functionality that includes automated traceability and recall processes. “Our processes were very manual and time consuming before we started using JustFoodERP. Now it’s easier to show processes for food safety and quality, and we’ve noticed large, rapid increases in the ways we can do the traceability study and mock recall required in our various audits,” says Patapow.
Giovanni also uses quality holds within the ERP system with plans to expand the quality management functionality, says Virginia Shields, production and systems analyst.
SQF Level 2 certification “affords us the opportunity to work with new retailers as we continue to look for ways to grow our business,” says Louis DeMent, CEO, Giovanni. “This certification exemplifies our continued commitment to providing safe, high-quality products to the marketplace.” The company intends, within the next couple of years, to begin working towards SQF Level 3 certification, the highest level that includes more focus on quality, such as quality control points.
Angus-Lee, a long-time business and trade journalist, now writes for IndustryBuilt. Reach her at email@example.com.