FOOD SAFETY INSPECTION REPORT For SYSCO. #SYS-B-193 FreshPoint Tomato, LLC - Nashville 1320 Vashti St Nashville, TN

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1 FOOD SAFETY INSPECTION REPORT For SYSCO #SYS-B-193 FreshPoint Tomato, LLC - Nashville 1320 Vashti St Nashville, TN TYPE OF AUDIT INSPECTION DATE April 9, 2010 AIB International Inc Bakers Way PO Box 3999 Manhattan, KS ( ) ( ) Fax ( )

2 RATING A Food Safety inspection was conducted at this facility on April 9, The writer was accompanied throughout the inspection by Joe May, Operations Manager. At the conclusion of the inspection, a meeting was held to discuss the observations, recommendations, and rating. Based on the observations made, the information obtained, and the criteria set forth in the AIB International Inc. Consolidated Standards for Inspection: Food Distribution Centers, the overall food safety level of this facility was considered to be: SUPERIOR (925) AIB International Inc. states that this report as dated and provided herein is to be construed as its findings and recommendations, category scores, total score, and rating. A passing score of 700 and above is not a certification of the facility, products or programs. AIB International Inc. does not accept or assume responsibility for the Prerequisite and Food Safety Programs in effect with (customer). AIB International Inc. is only reporting the food safety conditions of (customer) as of the date of this report and assumes no responsibility or liability as to whether (customer) does or does not carry out the recommendations as contained in this report. #SYS-B-193-p.1

3 RATING ANALYSIS DATE OF INSPECTION: April 9, 2010 TYPE OF INSPECTION: Unannounced OVERALL RATING: SUPERIOR OPERATIONAL METHODS AND PERSONNEL PRACTICES 185 MAINTENANCE FOR FOOD SAFETY 165 CLEANING PRACTICES 200 INTEGRATED PEST MANAGEMENT 200 ADEQUACY OF FOOD SAFETY PROGRAMS 175 TOTAL: 925 #SYS-B-193-p.2

4 Discrepancy Totals Serious Items Total: 0 Improvement Needed Items Total: 4 Unsatisfactory Items Total: 0 FACTUAL OBSERVATIONS AND SPECIFIC RECOMMENDATIONS OP = Operational Methods and Personnel Practices IPM = Integrated Pest Management MS = Maintenance for Food Safety AP = Adequacy of Prerequisite and Food Safety Programs CP = Cleaning Practices IMPROVEMENT NEEDED MS MS MS AP A broken light fixture cover was found in the cooler. Closer inspections should be done of the light fixture covers, the frequency of inspection should be evaluated. (IMPROVEMENT NEEDED) The overhead door on the east wall of the facility was out of adjustment, creating a gap of more than a 1/4", the door should be adjusted to seal tightly and should be checked daily during the pre-op inspection. (IMPROVEMENT NEEDED) The restroom in the facility should have a second door or barrier installed for the restrooms which open directly into the repack and operating area of the distribution center. (IMPROVEMENT NEEDED) Evidence of registration under the FDA Bioterrorism Act was on file at the facility. The facility had conducted a Vulnerability Assessment to identify food defense risks. The facility needs to write a formal food defense program, the written program had been vandalized and should be replaced. Training had been given to employees during the annual GMP reorientation, 2/19/09. (IMPROVEMENT NEEDED) MINOR ISSUE NOTED OP MS MS The GMP practices of the employees should be reviewed, specifically the positioning of hair nets during work on the packaging line. Also the company policy of letting employees wear watches should be reviewed. The insulated ceiling panel above the box drop mezzanine was hanging loose, the panel needs to be attached back to the ceiling. The wall at the entry to the cooler had been damaged by forklift impact. PM is needed, also some type of bumper should be installed to prevent further damage. #SYS-B-193-p.3

5 AP A risk-based audit of procedures was documented by competent inspectors. Audit documentation included identified observations, specific assignments, Corrective Actions, and actual accomplishments. Due to the size of the operation the Operations Manager reviews all programs. The revision date is posted on the document. The facility as part of the annual audit should initiate a log where the date of review and changes to documents, if made, can be listed. COMMENT OP OP OP OP OP OP OP OP OP OP OP The specialty line, extra large line, forklift room, large line, wash line and the tray line were clean and well organized. Transports/containers and ingredients were inspected upon receipt for cleanliness, pest activity, structural defects, or other issues that could jeopardize product integrity. Inspection documentation, including rejected shipments, was maintained. The facility does pulp temperature on product from the front and rear of the shipping trailers. Food products were stored and removed from storage to prevent product contamination. Materials were stored off the floor and 18 inches (45 cm) away from the wall to facilitate cleaning, inspection, and pest control activities. The stock rotation is determined by the ripeness and quality of the fruit (tomatoes) shipped from the facility. Storage areas were clean, well ventilated, and dry. Materials in storage were protected against contamination. Packaging materials, toxic chemicals and non-product materials were segregated. Ingredients, packaging supplies, and other materials were rotated on a "First-In, First-Out" basis or other verifiable method to ensure stock rotation. The facility is a fresh pack tomato distributor no product is kept longer than one week. Pallets were clean, dry, and in good repair. The tomatoes were packaged in corrugated boxes, no slip sheets are used. Release procedures were a defined requirement for materials stored at this facility. Release procedure for fresh tomatoes were in place, the Operations Manager or other management could only release product. Sampling of incoming raw materials for testing was not conducted at this facility. Trash or inedible waste were in properly identified and covered containers. All trash tomatoes were ground and washed to the sewer. Single-service containers were not used at this facility. Materials, work-in-progress, and finished products capable of supporting the rapid growth of pathogenic microorganisms were properly stored. The facility had storage coolers for the tomatoes and other vegetables. #SYS-B-193-p.4

6 OP OP OP OP OP OP OP OP OP MS MS Incompatible materials were stored under conditions that prevented cross-contamination. All products stored in the facility were fresh tomatoes and some vegetables (peppers and cucumbers). No iced product was received in the distribution center. Containers and utensils were not used for product handling at this facility. There were no processing rooms at this facility. All shipping vehicles were inspected prior to loading for cleanliness and structural defects that could jeopardize product integrity. Inspection documentation was maintained and included lot code designation, amounts, and the point of distribution to ensure traceability and recall. Security seals and locks were provided and documented for outbound materials. The shipping trailers are inspected, pre-cooled and documentation is maintained for the daily shipments. Adequate hand washing stations were located at appropriate locations and were stocked with single-use towels or air dryers and sanitizers as appropriate. "Wash hands" signs were displayed by sinks and entries into production areas. The facility uses purchased hand sanitizer at the sinks to the repackaging floor. Washrooms and locker areas were maintained in an acceptable sanitary condition. "Wash hands" signs were displayed in restrooms, lunchrooms, and smoking areas. Lockers were inspected on a defined frequency, weekly,and no open food or drink was allowed. Trained supervisors were in place to monitor compliance with personnel practices. Personnel were observed washing hands appropriately, and good personal hygiene practices were observed. The shift supervisors monitor the employees hand washing when they come from breaks or lunch. Personnel were not observed eating, drinking, or smoking in unauthorized areas. Personal property was stored in appropriate locations defined by company policy. Effective procedures were in place to ensure that personnel with boils, sores, infected wounds, infections, or other communicable diseases were not permitted to come in contact with food as required by law. All non-facility personnel, including visitors and contractors, followed the facility personnel practices requirements. Facility boundaries were defined and controlled. Measures were in place to prevent contamination from local activities or neighboring properties that could impact the facility. The facility is in the inner city, in a combined industrial, residential and business area. Outside grounds were maintained in a way that prevents product contamination. Measures included, but were not limited to, managing drainage, litter, weeds, and dust and maintaining waste and equipment graveyards to eliminate pest attraction to the facility. #SYS-B-193-p.5

7 MS MS MS MS MS MS MS MS MS MS MS MS MS MS Some measures were taken to maintain facility security. Security strategies included locked doors, limited access to sensitive areas, surveillance cameras, truck seals, employee screening, and awareness or training programs. Adequate space was observed between equipment and structures to facilitate access for cleaning and maintenance activities. Floors and walls throughout the facility were well constructed and maintained. Floor drainage was designed and maintained to allow access for cleaning and to prevent product contamination. There was no evidence of roof leakage. Fixtures, ducts, and pipes were properly installed and maintained to prevent contamination from leaks, condensation, or loose material. Fluorescent light tubes, light bulbs, essential glass, brittle plastics, and ceramics in the facility were of the safety type or otherwise protected from accidental breakage over exposed product storage areas. Those that could not be protected were accounted for in the Glass, Brittle Plastics, and Ceramics Program. Adequate ventilation was provided in the facility. Filters were in place in air makeup units which were serviced by an outside contractor. The facility was air conditioned and heated, no insect screens were used in facility. Adequate barriers were in place to prevent rodents, insects, and birds from entering the facility. Cracks, crevices, and other pest harborages were eliminated and doors were pest-proofed to prevent pest entry. There were no processing rooms with equipment that required the use and control of food-grade lubricants at this facility. Operations were separated to prevent product contamination. The rooms were separated by process flow/room separation. The rest rooms that opened into the warehouse had exhaust vents that were vented to the outside. The facility did not have any exposed recoup or processing areas that required a written temporary repair procedure for repair of these surfaces to be defined. The food contact surfaces, sorting belts used to sort the tomatoes, at this facility were clean and well maintained. Temperature measuring devices, including thermometers and recording controls, were installed in coolers or other temperature-controlled storage areas. The outside refrigeration company does the calibration on the thermometers when serviced. Transporting equipment, such as forklifts and pallet jacks, was maintained to prevent contamination of materials. The fork lifts were maintained by an outside contractor. Parts were stored off the floor in a clean environment. #SYS-B-193-p.6

8 MS MS CP CP CP CP CP CP CP CP CP CP CP CP A Program was in place to monitor water quality, and records were provided. The tests were done by an outside laboratory, every six months. The Program included water used for food contact. Back siphonage devices were provided and records of checks of the devices was current. Hand washing facilities provided hot and cold running water. Hand washing facilities were labeled. All hand wash stations used the foot pedal operating system. The floors, walls, ceiling and racks along the dock were clean and well organized. The floor, walls, ceiling and product racks were clean and well maintained. The floors, product racks, ceiling and walls were clean and well maintained. The outside grounds around the facility were clean and well maintained. The locker area, restrooms and break room were clean and well maintained. Cleaning was done in a way that prevents contamination of raw materials, products, and equipment. Food approval documentation was not needed for cleaning chemicals and sanitizers used as there were no food contact surfaces requiring cleaning. The facility uses 200 ppm chlorine rinse on the sorting tables and water rinse in the facility. The facility uses test strips to test the chlorine concentrations. Adequate cleaning equipment and tools were available and stored away from production and/or storage areas. Cleaning tools were color-coded to separate them based on their intended use. Daily housekeeping cleaning activities were carried out in a way that prevents contamination. Housekeeping activities were assigned to the appropriate department to maintain work and support areas. Chlorinated water is used to clean the surfaces daily, using high pressure hoses. Deep cleaning of equipment and structures was conducted according to the Master Cleaning Schedule to prevent the development of microorganisms, insects, or foreign material. Periodic cleaning tasks complied with written procedures. A daily, weekly, bi-weekly, monthly and semi-annual schedule is used, monitoring is done and initialed by the Operations Manager. Maintenance cleaning appeared to be completed in a way that prevented product contamination. No improperly stored tools were found in the facility. There were direct food contact surfaces, conveyor belts, in use at this distribution center. The belts were clean and well maintained. The belts were cleaned daily with high pressure water, using 200 ppm chlorine. #SYS-B-193-p.7

9 IPM IPM IPM IPM IPM IPM IPM IPM IPM IPM A formal Integrated Pest Management (IPM) Program with written procedures that included requirements of the facility's Prerequisite Programs was in place. An annual facility assessment that addressed all areas inside and outside of the facility was documented. The assessment was done by the outside PCO. The facility did not manage their IPM Program under an alternative guideline. A signed agreement was in place with the McCloud/Copesan Pest Control Company to provide IPM services. A copy of the service agreement included materials, the facility name, facility contact person, frequency of services, description of services, term of contract, emergency call procedures, service records to be maintained, and notification requirements for changes in materials or services. Current copies of certification or registration documents were on file for all persons providing IPM services for the facility. The PCO license, business license, certificate of insurance and GMP training certificate were on file. Current copies of the pesticide specimen labels and Material Safety Data Sheets (MSDS) were on file for pesticides listed as being applied at the facility. The pesticides used by the facility were Max Force Magnum and Weatherblox XT. Documentation of all pesticides, including rodenticides, applied on the premises included materials applied, registration number, target pest, amount applied, specific area where pesticide was applied, method of application, rate of application or dosage, date and time treated, and applicator's signature. The PCO certification number and the pesticide lot numbers were listed on the usage log. Pesticides and application equipment were not stored at the facility. The outside IPM service provider left a service report after each visit. These records provided documentation of the checks and findings for pest monitoring devices, descriptions of the current levels of pest activity, and recommendations for actions needed to correct conditions allowing a potential for pest activity. A rodent and insect light catch logs and trend reports were on file and current. All reports were appropriate for the reports. Minimal activity was noted on the bait stations, no activity was noted internally in the tin cats. Light activity was noted in the electric light traps. A detailed facility survey was documented and used to determine placement of all pests monitoring devices. A current site map that lists the locations of interior and exterior pest control devices was on file. #SYS-B-193-p.8

10 IPM IPM IPM IPM IPM IPM IPM AP AP AP AP Exterior pest monitoring devices, such as traps or bait stations, were provided for exterior rodent control. Exterior rodent monitoring devices were installed around the exterior perimeter of the facility at appropriate intervals. These stations were tamper resistant, properly positioned, anchored in place, secured, and properly labeled in compliance with regulatory requirements. The traps were inspected monthly. The traps opened during the audit were clean and no activity was noted. Mechanical rodent traps were installed to monitor rodent activity inside the facility and were properly positioned. The randomly examined traps appeared to be properly maintained. Traps were inspected on a weekly frequency, by the outside PCO and the plant personnel. Insect light traps (ILTs) were used in the facility to aid in monitoring insect activity. These traps were more than 10 feet (3 meters) from exposed products. The traps were scheduled for weekly cleaning by the outside PCO and the plant personnel. A record of the service, cleaning, and activity levels of each ILT was maintained. The bulbs were changed 5/15/09. Pheromone monitoring devices were not used to monitor insect activity in this facility. Bird activity was not noted in or around the facility. Wildlife, including domestic animals, was not observed at the time of the survey. Pest habitats and pest activity were identified and eliminated. No evidence of rodent or insect activity was noted in or around the facility. The facility had a documented policy statement outlining its commitment to produce safe and legal products. The policy was signed and communicated to the staff in GMP training. A current organizational chart was maintained. Responsibility and authority for ensuring food safety and defense and compliance with federal, state, local, and any other appropriate regulatory laws or guidelines were clearly assigned to the President. The Operations manager keeps current with regulatory food safety technical and food safety guidelines. The facility was licensed by the State and was current. Based on a review of the facility and related documentation, an appropriate budget and adequate labor support appeared to be in place to maintain the timely acquisition of tools, equipment, monitoring devices, chemicals, and other required resources. Written procedures were established to define step-by-step processes to ensure product safety. The job descriptions and alternates were on file, an annual review was done on all job descriptions by the Operations Manager. #SYS-B-193-p.9

11 AP AP AP AP AP AP AP AP AP Specific written procedures were on file for providing food safety training to all personnel and contractors. Records of new employee training and annual refresher training, 2/18/09, were maintained for all personnel. The facility performed exit criteria testing on the GMP and other training. A multidisciplinary Food Safety Committee was established to conduct monthly inspections of the entire facility. Documentation of the monthly inspections included identified observations, specific assignments, Corrective Actions, and actual accomplishments. A written Program for evaluating Customer Complaints was established. This Program included a plan for quick distribution of complaint information to all departments responsible for implementing Prerequisite and Food Safety Programs. Complaints were reviewed and categorized when received by the facility into quality or food safety. No food safety complaints had been received by the facility. A written Chemical Control Program that addresses all chemicals used in the facility was established. The chemicals used by the facility were listed and the outside contractors had a sign off document for GMPs and chemical guidelines to be signed before beginning work in the plant. The facility did not handle any of the big eight allergens, the only product handled by the facility were tomatoes (primarily) and some peppers and cucumbers. Though no allergens are handled by the facility allergen training is given to employees during the annual GMP/food safety reorientation. The facility had a written policy stating that no glass, brittle plastics, or ceramics were to be used in the facility, except where absolutely necessary. Included in the policy was a procedure to handle any breakage in the facility. A list of all essential glass, brittle plastics, and ceramics was developed. The glass inspections were performed during the monthly facility inspections. A formal documented Cleaning Program that included a Master Cleaning Schedule (MCS) for periodic cleaning assignments as well as a daily housekeeping schedule was developed and implemented in this facility. The MCS specified frequency, responsibility, post-cleaning evaluation techniques, and Corrective Actions. Written cleaning procedures were developed for all equipment, structures, and grounds that affected handling and storage of food products and packaging materials. A formal Preventive Maintenance Program and work order system was used to prioritize problems in structural and equipment maintenance. All preventive maintenance is performed through outside contractors. Incoming ingredients, packaging, and transports received into the facility were inspected by trained personnel according to established written procedures. LTL's are used for some products, the same receiving criteria is used for LTL's and full trailer loads of raw produce and packaging supplies. #SYS-B-193-p.10

12 AP AP AP AP AP A written Regulatory Affairs and Inspections Program was on file. The Program included a list of personnel delegated to accompany all inspectors along with a company policy regarding recording devices, cameras, records, and sample taking. The State had conducted an inspection for the FDA, the two deficiencies noted had been corrected. A documented Traceability Program that addressed identification of lot numbers of products, rework/repack, and packaging materials was developed and in place. All finished products were coded and recorded. A written Recall/Withdrawal Program was on file. Distribution records were maintained to identify the initial point of distribution to facilitate segregation and recall of specific lots. The Recall Program was tested twice annually, and test results were documented. The last mock recall was performed April 7, A written Program was in place to control nonconforming products, including work-in-progress, finished products, and returned goods. Any non-conforming is ground up and disposed as dump scrap and is flushed with water into the sewer. Corrective Actions equal to the seriousness of the risk appeared to be taken. A Hazard Analysis Critical Control Point (HACCP) Program was developed and implemented for processes and/or products. The HACCP Plan was signed and was managed by a trained HACCP team leader with assistance of HACCP trained team members. The facility has one CCP, the chlorine rinse, for one customer. Finished Product Profiles were provided for each product produced. A current Process Flow Diagram was in place. The seven principles of HACCP were followed in the development of the HACCP Program and included a risk assessment for both the ingredients and the process. Documented training was current for management and non-management personnel and for those with designated CCP responsibilities. The HACCP Plan was validated by the Operations Manager. The corporate office reviews the plan when changes occur. #SYS-B-193-p.11