Is there a situation where this would be ok?

Guys,

I've just found out that the upperest of management has in the past stated that a bag of ingredient with obvious signs of pest infestation should still be used but with the section of ingredient where the hole was in the bag should be "isolated" and not used.

I am so hoping this is a situation in which I'm wrong and there is some possible way this is not a major food safety issue.

Is there any way you guys can see that this would not be a gigantic issue?

Any help at all is appreciated.

In my opinion a package of anything that shows infestation should be disposed of. At what point do you say that the vermin or whatever it is stopped and the "clean" ingredient starts? Are they going to let you retain the ingredient and have it tested then released if it comes back good?

I found this..

E1.3 Pests are not a source of contamination:  Observation of pests or infestation on ingredients, packaging, work in process or finished goods shall be assessed as a critical non-conformance.

How big bag, bag of what, what kind of pests, what signs of pest activity?

Need more info for risk assessment. :smile:

Regards,

Simon

Thanks Brian but that sounds almost contradictory. They are NOT a source of contamination but evidence of them is a critical NC? What am I missing here?

How big bag, bag of what, what kind of pests, what signs of pest activity?

 

Need more info for risk assessment. :smile:

 

Regards,

Simon

Always so demanding, Simon.  :sleazy:

45 lb bag of protein eaten through by a mouse, hole in the bag about an inch and a half to two inches in diameter. Mouse droppings along the side of the pallet.

PS. We're looking for a new pest control supplier now.  :spoton:

Saying that Pests are not a source of contamination. They would be if there is...Observation of pests or infestation on ingredients, packaging, work in process or finished goods shall be assessed as a critical non-conformance

Read it as an auditor reading a standard from his audit. Pests are not a form of contamination. Yes they are, there is Observation of pests or infestation on ingredients, packaging, work in process or finished goods. I shall assess you a critical non-conformance.

I'm told that upperest management will override me on this. And maybe my attitude of saying it absolutely shouldn't be used is more of a layman's attitude but...

We just had a thorough pest analysis yesterday (working with our food safety consultant) -- this responsibility lies with my boss and I just started to delve into it as we move to SQF. My boss sent me this: 

Because deer mice are known carriers of Hantavirus, which causes the extremely dangerous and sometimes fatal Hantavirus Pulmonary Syndrome, you shouldn’t take any chances with handling mouse carcasses or droppings. Trust the professionals at Griffin Pest Solutions to remove mice from your home. There are plenty of reasons for doing so:

1. Mice waste products can transmit pathogens for human diseases like salmonella food poisoning, rickettsial pox, meningitis, ringworm, and dermatitis.

2. Mice will chew and gnaw through walls, baseboards, and other materials to create access tunnels through your home. If they chew through electrical wires, a fire could result.

3. The mousy odor they carry, not to mention the smell of urine and droppings, is highly unpleasant.

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

I do not yet know what type of mice we have but we absolutely have a problem which is why I met with individuals today (basically forcing my boss to let me take this). If the mouse entered the protein and urinated or defecated in the protein, it is entirely possible we would not catch it which is why I'm so insistent we need to dispose of the product - regardless of how expensive it may be!

In answer to your question and emphatic NO!.

The minimum correction would be to dispose of the directly affected product (all of it) and clean, inspect, clean, inspect until you are satisfied there is no possibility of further contamination. Plus ensure that rodents are prevented as a matter of urgency.  In the meantime store things off the floor or move them.

Your management need to read the food safety news PCA.  

Mice can carry pathogenic organisms that if transferred to food could KILL!

Those involved with PCA never meant to kill, they just could not see the risk, it wasn't in their hands, not in front of their faces unlike their balance sheets.

I'd blow the whistle on them, get fired or take constructive dismissal and sue their ass off.

I don't envy your position Emily.

Regards,

Simon

this is as bad as i thought, then.

i've already told my boss (ops mgr - not ownership which is who is supposedly going to override me) not too long after i started that i am a cross my t's, dot my i's kind of gal and i will not break or bend rules when it comes to this food safety gig - especially because i'm so new and it'd be easy to push responsibility off on me when i don't know what i'm doing. i said that if he/they can't handle that then they need to reevaluate my role within the company. he said he understood and respects and supports me. i guess we'll find out just how much he really meant that on monday.

i plan on putting my foot down and i guess we'll see how things hash out. 

thanks for your help, guys,

~emily~

I agree with Simon. Health inspectors shut down restaurants IMMEDIATELY if there is that level of infestation. The food is not ok to eat, the remaining powder is not safe.  Take a look at this page.http://blog.usfoodsa...ts-cockroaches/

Get copies now of your emails, send them to a home email, but get records of your advising them not to use this.  And anything else you feel is relevant!  Good Luck to you!

I agree with Simon. Health inspectors shut down restaurants IMMEDIATELY if there is that level of infestation. The food is not ok to eat, the remaining powder is not safe.  Take a look at this page.http://blog.usfoodsa...ts-cockroaches/

Thanks, Setanta. 

My mind is reeling for so many reasons. The idea that it would be thought of as okay is abhorrent to me. The idea that I'm actually right is fantastic cuz it's about time --- I just wish it were about something much more fun. (Sorry, I had to add a little levity - I'm crashing big time over here.) I am contemplating making the executive decision myself and dumping it while the bosses are out of the office the rest of the week. That may be the answer...for this specific situation, at least. And then I've bought myself time to address it with them and they CAN'T override me.

If your food safety consultant is worth anything they should be acting as an expert witness and helping you lay it all out clearly to the management, without emotion, but with facts; and that is done by conducting an honest, technically sound and thorough risk assessment.  Whatever the outcome off that is the law.  If that means the business incurs cost, so be it. If they won't have it, you must not let them carry on regardless.

I agree with Simon and Setanta, evidence of pest presence is enough to dispose of the product in question, the mouse doesn't need to be there.  Your customers are paying for clean, safe finished product, not mouse droppings as a new "secret" ingredient.

As a USDA Inspector, if I found evidence of pest droppings, or damage done by pests, I would investigate, with plant personnel, until we found the source, which included checking every bag on a pallet, and then the damaged bag(s) would be tagged and disposed of in my presence.  Currently, as a QA Manager, if I find damaged ingredient bags, I fill out our "Ingredient/Product Disposal Form, and observe it being disposed of properly in a trash receptacle, then sign off that the procedure has been completed.

As a QA department employee, we have the responsibility and obligation to protect the consuming public from food safety hazards.  I think you should dump the bag in question, and document it.  Document the email trail, too, as Setanta suggested.  PCA is a good example of what ignoring food safety can snowball into.  If they question you, remind them 1 bag of ingredient is less costly (on many different levels) than a recall. 

Our food safety consultant is not a paid one but she is an expert in her field. I have not discussed this with her but just finished composing an email to my boss in which I unequivocally state that I will not be a party to releasing the ingredient into production. I am holding it for now because one of the owners is here tomorrow and I may decide to just sit down with him and discuss it. If I choose to do that, I will also bring a coworker into that meeting so there is a witness. 

This sucks.

"I've just found out that the upperest of management has in the past stated that a bag of ingredient with obvious signs of pest infestation should still be used but with the section of ingredient where the hole was in the bag should be "isolated" and not used."

Do these guys do comedy routines?

Seriously, it's not like an apple where you just cut out the part with the dead worm in it and eat the rest - the entire package is subject to disposal.

ladytygrr, as a consumer and head of a family who eats food  :ejut:  I thank you for taking a stand.  As a professional, I thank you for taking a stand and being a role model to the rest of us.  This is what we're supposed to be about.  We should be prepared to lose our jobs if necessary.  Like Simon said, let facts, not emotion rule the day. Stay calm and you may win over those who might wish to use potentially deadly material. 

"I've just found out that the upperest of management has in the past stated that a bag of ingredient with obvious signs of pest infestation should still be used but with the section of ingredient where the hole was in the bag should be "isolated" and not used."

 

Do these guys do comedy routines?

 

Seriously, it's not like an apple where you just cut out the part with the dead worm in it and eat the rest - the entire package is subject to disposal.

My take, exactly, GOC. 

There's no way to prove the rest of the protein is safe. No way to know/prove that the mouse didn't burrow all through the entire bag, urinating and defecating. Even if there wasn't urine or feces, it still is not a safe situation.

My options are these:

1) Register my disagreement via email to my immediate boss, the Ops Mgr, and then let it play out on Monday when he returns and see if he overrides me and/or takes it to ownership who then overrides me.

2) I can make an executive decision tomorrow and toss it and let the (disciplinary) chips fall where they may.

3) Go over my boss's head tomorrow and speak with an owner (not majority owner and one who I'm told usually defers to majority owner but an owner nonetheless) to register my opinion/thoughts/feelings.

Part of me wants to register my disagreement with my boss and then see what happens during the course of discussion on Monday. BUT, I have enough fear that they will use it without me that I am reluctant to do that.

To get around that, I am strongly inclined to combine steps 2 and 3 above. Pitch it and then explain why I did it.

Please, anyone who has any suggestions on what steps I should take, I am all ears. 

Thank you guys for your support. I'd be completely lost here without you all.

~em~

ladytygrr, as a consumer and head of a family who eats food  :ejut:  I thank you for taking a stand.  As a professional, I thank you for taking a stand and being a role model to the rest of us.  This is what we're supposed to be about.  We should be prepared to lose our jobs if necessary.  Like Simon said, let facts, not emotion rule the day. Stay calm and you may win over those who might wish to use potentially deadly material.

Thank you for your words of support, RMAV.

This is NOT a fun situation. I know it'll work itself out. And, on the bright side, if I pitch it and they end up telling me they would have used it, I now will know the truest colors of those I work for. 

I have a kid - I don't want my kid or anyone else's (child or adult!) to eat this stuff!

Brian is correct but he is losing a bit of clarity in his articulation. Bottom line is your incident clearly fits the second part of his statement , you have physical evidence of rodent activity and now the responsibility is on you to formulate your response so that you can make a powerful business case.  Don't do quality control without making the business case, lay out the risk to the business and why they should support you and don't be guilty of making a "knee jerk reaction"

You should do a food safety risk assessment and much of the information you needs is captured in the treads associated with this post, then you need to reach a conclusion and issue the appropriate  disposition.

I am back in the private sector but for the prior 3.5 years I have audited against ISO22000:2005, SQF and ISO 9001:2008 and in my opening meetings I always reminded management that for a QMS or FSMS  the Food Safety Team Leader, SQF practitioner or BRC champion rules as King ( or Queen as the case may be). Its your "hill" defend it , it is your right and responsibility to explain to, coach and  educate management as to why the disposition needs to be what it is. They have to get to trust you it takes time.

In Brian's scenario seeing a mouse running down the pack of an aisle among food ingredients would not be objective evidence of contamination or infestation; however finding a bag with the tell tale signs of rodent activity and maybe finding mouse droppings is objective evidence of a food safety risk and  you should first move to "correction" which for me means a 100 inspection of the bags of concern and a removal and discarding of any and all affected bags, second, quickly get a non conformance issued  and contact the pest control provider to start the process of containment and eradication. At the same tie do your root cause and identify the appropriate corrective action measures needed to avoid a recurrence.

Finally you need a safe way of reminding that upper management that the FSMS is driven my management commitment, skimming the bag and using what may appear to be the good fraction ( if I am understanding you correctly) is not an example of good management commitment  nor is it sound food science.

My personal strategy is to issue non conformance's proactively in other words if the FSMS takes a hit  I do not wait for the auditor I flag it and then deal with it as an audit finding. This means that in your case if this situation was repeated I would make a finding against management commitment. Seems risky but the truth is upper management also likes to know that they have competent technical support , that you are not afraid to make your case and hold your ground.

Hope this helps 

Hi Emily,

As per previous post and one of yr earlier threads, this is -

(1) Why you need a (quotable) HACCP Plan.

(2) Why you need a (distributable) NUOCA form.

FS is Everybody's Business.

Brian is correct but he is losing a bit of clarity in his articulation. Bottom line is your incident clearly fits the second part of his statement , you have physical evidence of rodent activity and now the responsibility is on you to formulate your response so that you can make a powerful business case.  Don't do quality control without making the business case, lay out the risk to the business and why they should support you and don't be guilty of making a "knee jerk reaction"

 

You should do a food safety risk assessment and much of the information you needs is captured in the treads associated with this post, then you need to reach a conclusion and issue the appropriate  disposition.

 

I am back in the private sector but for the prior 3.5 years I have audited against ISO22000:2005, SQF and ISO 9001:2008 and in my opening meetings I always reminded management that for a QMS or FSMS  the Food Safety Team Leader, SQF practitioner or BRC champion rules as King ( or Queen as the case may be). Its your "hill" defend it , it is your right and responsibility to explain to, coach and  educate management as to why the disposition needs to be what it is. They have to get to trust you it takes time.

 

In Brian's scenario seeing a mouse running down the pack of an aisle among food ingredients would not be objective evidence of contamination or infestation; however finding a bag with the tell tale signs of rodent activity and maybe finding mouse droppings is objective evidence of a food safety risk and  you should first move to "correction" which for me means a 100 inspection of the bags of concern and a removal and discarding of any and all affected bags, second, quickly get a non conformance issued  and contact the pest control provider to start the process of containment and eradication. At the same tie do your root cause and identify the appropriate corrective action measures needed to avoid a recurrence.

 

Finally you need a safe way of reminding that upper management that the FSMS is driven my management commitment, skimming the bag and using what may appear to be the good fraction ( if I am understanding you correctly) is not an example of good management commitment  nor is it sound food science.

 

My personal strategy is to issue non conformance's proactively in other words if the FSMS takes a hit  I do not wait for the auditor I flag it and then deal with it as an audit finding. This means that in your case if this situation was repeated I would make a finding against management commitment. Seems risky but the truth is upper management also likes to know that they have competent technical support , that you are not afraid to make your case and hold your ground.

 

Hope this helps 

Great first post; excellent and comprehensive advice.

Thanks.

Simon

Brian is correct but he is losing a bit of clarity in his articulation. Bottom line is your incident clearly fits the second part of his statement , you have physical evidence of rodent activity and now the responsibility is on you to formulate your response so that you can make a powerful business case.  Don't do quality control without making the business case, lay out the risk to the business and why they should support you and don't be guilty of making a "knee jerk reaction"

 

You should do a food safety risk assessment and much of the information you needs is captured in the treads associated with this post, then you need to reach a conclusion and issue the appropriate  disposition.

 

I am back in the private sector but for the prior 3.5 years I have audited against ISO22000:2005, SQF and ISO 9001:2008 and in my opening meetings I always reminded management that for a QMS or FSMS  the Food Safety Team Leader, SQF practitioner or BRC champion rules as King ( or Queen as the case may be). Its your "hill" defend it , it is your right and responsibility to explain to, coach and  educate management as to why the disposition needs to be what it is. They have to get to trust you it takes time.

 

In Brian's scenario seeing a mouse running down the pack of an aisle among food ingredients would not be objective evidence of contamination or infestation; however finding a bag with the tell tale signs of rodent activity and maybe finding mouse droppings is objective evidence of a food safety risk and  you should first move to "correction" which for me means a 100 inspection of the bags of concern and a removal and discarding of any and all affected bags, second, quickly get a non conformance issued  and contact the pest control provider to start the process of containment and eradication. At the same tie do your root cause and identify the appropriate corrective action measures needed to avoid a recurrence.

 

Finally you need a safe way of reminding that upper management that the FSMS is driven my management commitment, skimming the bag and using what may appear to be the good fraction ( if I am understanding you correctly) is not an example of good management commitment  nor is it sound food science.

 

My personal strategy is to issue non conformance's proactively in other words if the FSMS takes a hit  I do not wait for the auditor I flag it and then deal with it as an audit finding. This means that in your case if this situation was repeated I would make a finding against management commitment. Seems risky but the truth is upper management also likes to know that they have competent technical support , that you are not afraid to make your case and hold your ground.

 

Hope this helps 

Firstly: welcome to the forum, Clement Griffiths!

Secondly, thank you very much for your insight. This entire situation has gotten me more emotional that I would like and I am struggling at staying detached and technical so your suggestions along with everybody else's are greatly appreciated. 

I am currently preparing an email to my direct-report boss who I am supposed to touch base with on Monday when we both return from planned time off. This will let me put into writing my arguments which will help keep my thinking focused for when we discuss on Monday.

As Setanta suggested, that email will be BCC'd to my personal email and I am in the process of documenting the entire situation which will also go to my personal email. 

I am hoping that, come Monday, my boss will have had a change of heart and listen to me. If he doesn't, I will know for sure what I have started to suspect for a while now: I was hired more for window dressing than for actually affecting change and making this a company with a solid food safety program. If my boss overrides me, I plan on taking the situation to ownership (which is who supposedly made us use an infested bag in a previous situation before I started). But, at least I'll be taking the appropriate steps and documenting this entire situation as it unfolds.

I have the day off tomorrow to spend with my daughter and (hopefully) forget this situation for a while. I look forward to being able to report a positive development in this situation on Monday; I will update you guys regardless.

Thank you for all of your suggestions and support.

~Emily~