Here are the posts for the Food Safety portion of Domain 1 originally posted on the Facebook Cheese Study Group page:
Domain 1 – Food Safety CCP Study Group – Day 1
First and foremost is to consider the ACS Body of Knowledge your study bible. While not everything in the expanded version will be on the exam, this is where you start.
I consider Food Safety to be the most important part of your cheese world. Keeping cheese safe manifests into many other areas of your operation: decreasing waste, increasing profits, keeping customers coming back (if you make your customers sick, you can kiss them and possibly your entire operation goodbye). The road of Practicing Poor Food Safety, Poor Hygiene and Cutting Corners is littered with bankrupt cheesemakers, distributors and retailers.
My good friend and Cheese Safety Manager, Jane Gau, says “bad food safety is what keeps me up at night.”
This past semester at Culinary School, I took and passed the ServSafe Food Protection Manager Certification Course: 16 weeks of study to master the “art” of Food Safety. In addition to that Certification, I also secured my Food Protection Manager’s Instruction Certification… so these days I am VERY sensitive regarding Food Safety.
Today I want to start with only one, but extremely important, Article that Janet Fletcher recently wrote for Specialty Food Magazine. She interviewed several Cheesemongers and Cheese Shop Owners and asked them to share “their best food safety advice on everything from employee training to sanitation to temperature monitoring”. It is one of the best and most concise articles regarding food Safety behind the counter in a cheese shop. Commit this to memory… you’ll thank Janet Fletcher and those who contributed later.
https://www.specialtyfood.com/…/cheese-focus-food-safety-8…/
Domain 1 – Food Safety CCP Study Group- Day 2
Today’s mission is to steer you to articles about Food Safety which will help you with both exam preparation and day-to-day operations. First, I’d like to share a story with you:
A couple of weeks ago, I was at a local grocery store at the deli counter ordering some cut-to-order Boar’s Head cold cuts. An employee came to the counter and asked could she help me. I ordered a half pound of ham to be cut thin. She rummaged around in the reach in display until she found the ham I wanted. She took the ham to the slicer. Before beginning, she stopped to put on gloves and commenced to slice the ham. The deli counter was not busy and while she was cutting the ham, the Deli Manager came and asked did I want anything else. I ordered rare roast beef, Genoa salami and hard salami. I watched as she took out the three meats and put on gloves before beginning to slice the meats. While I was standing there, a store manager came up and told the Deli Manager that the trash needed to be taken out. As the first employee was finishing up my ham, the Deli Manager told her to take the trash out and she would finish my order. The employee grabbed the trash container, still wearing the gloves, and rolled it to the back part of the department. Upon returning, she stopped to pick up sliding glass doors for the hot display case and inserted them into the case, still wearing the same gloves. After that she turned around and went to the meat slicing station, picked up an open bottle of water and proceeded to drink out of it. After drinking, she set the bottle down by one of the slicers. (Keep in mind, since January, I have been immersed in the ServSafe Food Safety Manager’s Class at Culinary School.)
The Deli Manager brought my roast beef and one of the salamis to the counter. I told her what I had observed and she told me she would address it. I cancelled my order for the second salami and walked away. As I walked off, the employee asked the Deli Manager what I had said and she replied, “Oh, it was nothing”. Well, you can imagine how I felt. I went and found the store manager and told her what I had observed. She assured me she would address it. As I was checking out, the manager came and told me she had spoken with the deli manager and the employee and was confident the employee “just wasn’t thinking” and it was an isolated incident.
A week later those three packages of cold cuts remained in my fridge, unopened. I couldn’t serve nor eat them. I finally took them back to the store, found the original store manager and asked for a refund reminding her of my earlier complaints. She asked if I would prefer to exchange for new meats to which I replied, “No, I want a refund. I will never again buy anything out of your deli.”
So many issues: not washing hands BEFORE putting on the gloves, which meant the gloves were dirty. Both the employee and the deli manager. (I’ll overlook the Boar’s Head requirements that were ignored.)
There’s a reason the gloves are called “single use”. The employee continued to wear them through several uses INCLUDING taking out the trash.
Drinking water out of an open container in the food prep area.
Obviously not an isolated one-off; these employees had not been trained properly, didn’t take food safety seriously or both.
AND, the deli lost my future business.
As they liked to say at Kroger – this was a “teaching moment”…
Now for links to food safety:
Good Manufacturing Practices:
Food Safety Modernization Act (FSMA):
https://www.fda.gov/Food/GuidanceRegulation/FSMA/default.htm
2013 FDA Food Code:
https://www.fda.gov/downloads/Food/GuidanceRegulation/RetailFoodProtection/FoodCode/UCM374510.pdf
Title 21 of the 2013 FDA Food Code – updated as of April 2017:
Clemson University Handling of Cheese for Safety and Quality:
Who Will Regulate My Food Business:
https://fbns.ncsu.edu/extension_program/documents/entrepreneurs_who_regulates_food_bus.pdf
Control of Listeria Monocytogenes:
Images of Cheese Regulation Charts (fun and interesting):
ACS Safe Cheesemaking Hub:
http://guides.cheesesociety.org/safecheesemakinghub/gettingstarted
ACS Food Safety Page:
http://www.cheesesociety.org/events-education/food-safety/
Links to Other Resources Recommended by the ACS:
http://guides.cheesesociety.org/safecheesemakinghub/gettingstarted
Marcella The Cheesemongers Food Safety Bullet Points and Terms to Know:
http://www.marcellathecheesemonger.com/acs-body-of-knowledge-domain-9-regulations-and-regulators/
Day 3 – Food Safety CCP Study Group- HACCP Program
Hazard Analysis Critical Control Point (HACCP; Pronounced “HASS-ip”) program is one of many systems that can be implemented to achieve active control of foodborne illnesses. In the ServSafe Food Protection Manager Certification, it is the system covered in depth.
The FDA requires producers of canned foods, meat and juices to have a HACCP program in place and when inspected, these producers must provide the FDA inspector with required paperwork to verify the program is working efficiently. Currently, the FDA does not require cheese and butter producers to have a working HACCP program; however most do.
HACCP consists of seven principles:
- Conduct a hazard analysis
- Determine critical control points (CCPs)
- Establish critical limits
- Establish monitoring procedures
- Identify corrective actions
- Verify that the system works
- Establish procedures for record keeping and documentation
Recently, Laura Mushrush wrote a seven-part series for Food Safety New Magazine covering each HACCP principle.
HACCP Principle 1: Conduct a hazard analysis:
http://www.foodsafetynews.com/2018/02/haccp-principles-no-1-conduct-a-hazard-analysis/
HACCP Principle 2: Identify Critical Control Points:
http://www.foodsafetynews.com/2018/03/haccp-principles-no-2-identify-critical-control-points/
HACCP Principle 3: Set limits for critical control points:
http://www.foodsafetynews.com/2018/03/haccp-principles-no-3-set-limits-for-critical-control-points/
HACCP Principle 4: Establish monitoring procedure – Details matter – as does training:
http://www.foodsafetynews.com/2018/03/haccp-principles-no-4-details-matter-as-does-training/
HACCP Principle 5: Establish and execute corrective actions:
http://www.foodsafetynews.com/2018/03/haccp-principle-no-5-establish-execute-corrective-actions/
HACCP Principle 6: Verify that the system is working:
http://www.foodsafetynews.com/2018/04/haccp-principle-no-6-verify-document-repeat-to-compete/
HACCP Principle 7: Establish procedures for record keeping and documentation:
http://www.foodsafetynews.com/2018/04/haccp-principle-no-7-compliance-requires-the-right-records/
These seven articles cover the HACCP program in detail and will help you understand how the program works and why it is needed to reduce the risk of foodborne pathogens.
Food Safety News Magazine is available online and in print. Both subscriptions are free and you can subscribe here:
https://secure.sdicirc.com/foodsafetymagazine/fs_free_qualified_subscription.php
If you want to get further into the weeds regarding food safety, you can set-up a Google alert and receive links to articles about food safety and foodborne illness outbreaks. However, if you have a germ phobia, you might not want to be daily reminded of the landmines out there just waiting to make you sick.
Another resource is through the USDA/FDA which offers a free email subscription to food (and other) recalls. You can subscribe here:
https://www.fda.gov/Safety/Recalls/default.htm
Beware: When I first began getting recall alerts, I signed-up for all recalls. Some of the medical recalls scared the hell out of me and like government secrets, that was information I didn’t need to know and didn’t want to know. I refined my recall alerts to food… which is still scary, but in our cheese world, necessary.
Day 4 – Food Safety CCP Study Group
Today, I will cover basic, miscellaneous points in Food Safety that you should know.
According to the Food and Drug Administration (FDA) there are more than 40 bacteria, viruses, parasites and molds that cause foodborne illnesses. The FDA singles out six of these pathogens because they are highly contagious and can cause severe illness and in extreme situations death. They are known as “The Big Six”:
- Shigella
- Salmonella Typhi
- Nontyphoidal Salmonella (NTS)
- Shiga toxin-producing Escherichia coli (STEC), also known as coli
- Hepatitis A
- Norovirus[1]
In the cheese world, Listeria monocytogenes, Toxigenic E. Coli, Salmonella enterica and Staphylococcus aureus are of concern.[2] High-risk populations include the elderly, pre-school children, pregnant women and persons with compromised immune systems. Listeria monocytogenes is the pathogen of concern for pregnant women when eating raw milk cheese.[3]
For each of these pathogen issues, Good Manufacturing Practices (GMP), Good Agricultural Practices (GAP) and good personal hygiene can decrease pathogens to safe levels.
If you haven’t already, I recommend you go to ServSafe® and take the Food Handler exam for your state which will cover basic, safe food handling that you will need to know in the retail setting. That exam will also cover most questions that might appear on the exam. (Even if you have taken it more than one year ago, you should take it again.)
https://www.servsafe.com/ServSafe-Food-Handler
For example, the proper way to clean a food prep surface would be:
- Scrape/remove any excess food off the surface.
- Wash the surface.
- Rinse surface.
- Sanitize surface.
- Air dry surface.[4]
[1] 7th Edition ServSafe® Coursebook, ©2017 National Restaurant Association Educational Foundation, (Page 2.3)
[2] American Cheese Society Body of Knowledge, Domain 1. B.
[3] Donnelly, Catherine, Editor. “The Oxford Companion to Cheese”. New York: Oxford University Press. Print. (Page 341)
[4] 7th Edition ServSafe® Coursebook – National Restaurant Association Solutions (page 12.7)
The Code of Federal Regulations (CFR) cites five risk areas related to foodborne illnesses (The Food Code of the CFR exceeds 750 pages and very little of it will appear on the exam, so don’t feel you need to read all of it. You don’t.):
- Purchasing food from unsafe sources.
- Failing to cook food properly.
- Holding food at incorrect temperatures. (Danger zone is 41°F to 135°)
- Using contaminated equipment.
- Practicing poor personal hygiene.[1]
According to ServSafe® regulatory agencies us the above 5 risk factors to determine frequency of inspections along with size and complexity of operation, inspection history of operation (more issues will trigger more inspections more often), at-risk populations (for example, hospitals, nursing homes and pre-schools have high concentrations of at-risk persons) and sadly resources (agency budget, workload and availability of inspectors).[2]
Good personal hygiene includes:
- Bathing before work.
- Wearing clean clothing.
- Keeping your fingernails, short, clean with no rough edges and unpolished. No fake nails. (Some jurisdictions allow polish and/or fake nails if covered with single-use gloves.)
- Washing hands properly – washing hands properly is the #1 most important part of good personal hygiene.[3]
I remember more than one occasion having to discuss personal hygiene with cheesemongers and marveling at having to have the conversation. Once, the monger’s fingers were so filthy, that I was sure sending him to the bathroom to scrub them would not work. And there is a reason deodorant was invented.
A basic tutorial for understanding pH in cheese can be found at Pat Polowsky’s Cheese Science Toolkit:
https://www.cheesescience.org/ph.html
The pH range for cheese is 4.4 – 6.8. The pH range of milk starts at 6.7. According to the CFR’s GMP’s general provisions, the general definition of acidic food have an equilibrium pH of 4.6 or lower.[4]
[1] https://www.fda.gov/downloads/Food/GuidanceRegulation/RetailFoodProtection/FoodCode/UCM374510.pdf
[2] 7th Edition ServSafe Coursebook – National Restaurant Association Solutions (page 14.4-14.5)
[3] 7th Edition ServSafe Coursebook – National Restaurant Association Solutions (page 4.11)
[4] https://web.archive.org/web/20150330214506/http://www.ecfr.gov:80/cgi-bin/text-idx?c=ecfr&sid=cefdff5373327b34dfa6f87642959825&rgn=div5&view=text&node=21:2.0.1.1.10&idno=21
For recall information, the FDA Recall Compliance Manual should be reviewed ( a lot of it doesn’t pertain to cheese, so it’s not as big an undertaking as the 88-page length might have you think)
https://www.fda.gov/downloads/ICECI/ComplianceManuals/RegulatoryProceduresManual/UCM074312.pdf
You should be aware of the difference between a voluntary recall and a mandatory recall. If you are a cheesemaker, you want to make sure the recall is voluntary.
I wrote an article regarding lactose (the sugar in milk) and cheese which you can review here:
http://www.marcellathecheesemonger.com/2012/04/01/cheese-101-lactose-and-cheese/
You should understand the differences in date labeling: “Use by”, “Best by”, “Sell by” and “Expiration date”. The CFR does NOT require most foods to be dated; according to the CFR, most food can be sold as long as it is “apparently wholesome”. Dating is the product of producers and retailers doing a CMA to avoid lawsuits. Otherwise, unscrupulous sellers might play loose with the definition of “apparently wholesome”.
“The term apparently wholesome food refers to a food that is intended for human consumption and that meets all quality and labeling standards imposed by Federal, state, local laws and regulations even though the food may not be readily marketable due to appearance, age, freshness, grade, size, surplus, or other conditions. [42 USCS § 1791(b)(2)].”[1]
Retailers set their own “sell by” dates on labeling of in-house cut and wrap cheese based on experience and internal food safety managers.
Something I learned when studying for my ServSafe® Instructor Certificate is that as long as food is cooked and cooled properly, it can be re-heated an indefinite number of times during its 7-day use by date….eeeeeewwww.
While more than 160 food items can cause allergic reactions, only 8 of them account for 90% of all reactions:
- Milk
- Soy
- Eggs
- Wheat
- Fish
- Crustaceans
- Peanuts
- Tree Nuts[2]
[1] https://definitions.uslegal.com/a/apparently-wholesome-food/
[2] 7th Edition ServSafe Coursebook – National Restaurant Association Solutions (page 3.6)
Consumers these days are more savvy regarding allergies and producers and retailers need to be aware of gluten and protein intolerances in addition to lactose intolerance; vegetarian, Kosher and Halal needs. A google search can help you with these issues.
I’ll leave you with a bit of trivia that I forgot to include yesterday while discussing HACCP program: Pillsbury was the first company to adopt a HACCP program.[1]
[1] Percival, Bronwen & Percival, Francis, “Reinventing the Wheel: Milk, Microbes, and the Fight for Real Cheese”. Oakland, California: University of California Press. 2017. Print. (Page 126)
The Cheese Study Group’s 2018 Scholarship Winners Can Be Viewed Here.
©2018 Marcella Wright, Bringing Specialty Cheese to You, Bringing Food Safety to You
In addition to being an American Cheese Society Certified Cheese Professional, I am a Certified ServSafe Food Production Manager with certifications that also include ServSafe Certified Instructor and Proctor. I am available for cheese events, cheese program development, cheese training, food safety training and 3rd party food safety auditing. See my About Me and Resume pages for more details or call me at 360 921 9908 to discuss availability.
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