The FDA Comes Calling
I've been away from blogging for a few days while responding to the PCA recall. The FDA inspector came in last Thursday to follow up and make sure that we didn't have any PCA product (we don't). The State of Michigan called Friday to do some additional follow up on the phone. The FDA inspector also looked over our little peanut butter plant. All three of our lines -- peanut butter, nut roasting, and confectionary -- are shut down for our annual maintenance and cleaning period, so he'll have to come back to watch the peanut butter run.
Studying the FDA’s Observations at PCA, #10
Observation #10 -- Finally!
Roaches! Yikes. I lived in the South for many years. Chapel Hill and Carrboro, North Carolina. Washington, D.C. Charlottesville, Virginia. And in New Orleans. Being of Dutch descent and raised in a family of fanatical cleaners, I never adjusted to the roaches. There are roaches everywhere in Dixie. When our kids were small, messy eaters we once had roaches in our SUV.
This is not to defend PCA, but to keep roaches out of a South Georgia peanut plant it would have to be sealed as tight as drum. If the FDA's reports and press accounts are correct, the PCA plant was not.
Pest control is a huge deal in the peanut business, because everything that crawls, flies, and walks seems to love to eat peanuts. It is a matter of endless vigilance.
The FDA has posted the report on its inspections of the PCA facility on the FDA website, here. As PCA has noted on its website, the FDA's findings are not final, and PCA will have the opportunity to respond
Studying the FDA’s Observations at PCA, #9
Obeservation #9 covers several basic cleaning and sanitation issues. The washroom sounds icky, that's for sure. I confess that the FDA would have said the same thing about our ingredient feed area back when we were in the industrial market -- it was impossible to keep clean.
The FDA has posted the report on its inspections of the PCA facility on the FDA website, here. As PCA has noted on its website, the FDA's findings are not final, and PCA will have the opportunity to respond.
Studying the FDA’s Observations at PCA, #8
Observation #8 is that a sink was used both for cleaning hands and cleaning mops. That is nasty.
The FDA has posted the report on its inspections of the PCA facility on the FDA website, here. As PCA has noted on its website, the FDA's findings are not final, and PCA will have the opportunity to respond.
Studying the FDA’s Observations at PCA, #7
I'm working my way through the FDA's report on its inspections of the PCA facility. The agency made 10 observations, this post deals with #7.
The FDA has posted the report on its inspections of the PCA facility on the FDA website, here. As PCA has noted on its website, the FDA's findings are not final, and PCA will have the opportunity to respond.
Observation #7 notes that the building does not have positive air pressure in the production area. The idea here is that if the production area has postive air pressure, then when a door is opened to a warehouse, raw material storage, the outside, etc., air will flow out. If air flows in, there is the risk the air flow will carry in something nasty.
For a typical high volume peanut roasting operation, this is a problem, because the large roasters consume large volumes of air -- they have huge exhaust fans on them to take away smoke and cool the peanuts. To create positive air pressure in a roasting area would require a huge air make up unit to replace the air the roaster was exhausting out. The make up unit would use outside air, which, it seems to me, carries the potential for nasties as well. Unless this must be filtered in some way. This is not a simple fix.
PCA's problem, however, appears to have been more fundamental -- their production area was not behind a wall at all. Perhaps is this allowed by the Georgia Dep't of Ag. -- in Michigan, it is absolutely forbidden. All receiving and warehouse areas must be physically separated from production areas.
Studying the FDA’s Observations at PCA, #6
Observation #6 addresses two everyday health inspection matters. You have to be able to properly clean and sanitize food contact surfaces and you have to keep stuff covered up as much as you can.
The FDA has posted the report on its inspections of the PCA facility on the FDA website, here. As PCA has noted on its website, the FDA's findings are not final, and PCA will have the opportunity to respond.
Studying the FDA’s Observations at PCA, #5
Halfway there. This is number 5 of 10 FDA "obersvations." The FDA has posted the report on its inspections of the PCA facility on the FDA website, here. As PCA has noted on its website, the FDA's findings are not final, and PCA will have the opportunity to respond.
Observation #5 deals with leaks around skylights and air conditioning units. Anytime one cuts a hole in the roof of an industrial building for skylights, air conditioning, exhaust, roof access -- you name it -- you risk a leak. Enough holes in your roof, and a leak will happen, regardless of your vigilance in inspection and caulking. In fact, even with no holes in your roof, the typical steel pre-engineered building will leak. This is not to excuse PCA, especially if press accounts are accurate indicating that they had ongoing active leaks. The issue is not leaks, but whether you fix them right away and make sure that no product is affected.
Studying the FDA’s Observations at PCA, #4
The FDA has posted the report on its inspections of the PCA facility on the FDA website, here. As PCA has noted on its website, the FDA's findings are not final, and PCA will have the opportunity to respond.
Observation #4 addresses a basic tenant of food safety: keep finished product and raw materials apart. More interesting are the reports of positive environmental swabs for salmonella. A bad sign which indicates real problems. We'd flip out if we ever had a positive swab.
Studying the FDA’s Observations at PCA, #3
The FDA has posted the report on its inspections of the PCA facility on the FDA website, here. As PCA has noted on its website, the FDA's findings are not final, and PCA will have the opportunity to respond.
Observation #3 sates that PCA recognized the roasting step as a "control point" for salmonella. This indicates that PCA did in fact have a HACCP plan in effect, which is consistent with their ratings from AIB. (See also PCA's statement on their AIB inspections.)
More interesting is the FDA's assertion that the effectiveness of this control point had not been proven for PCA's specific roaster. Peanuts are typically roasted for 20-30 minutes at temperatures of 275 degrees F or more, which is enough to effectively sterilize them. And though PCA could show records indicating that the nuts had in fact been roasted for that amount of time at such temperatures, this was not enough. They had to show that these times and temperatures actually would produce control of salmonella. Which means that they had to do an experiment in which they innoculate nuts with salmonella, put them in little mesh bags, run them through the roaster, and then test them. This is consistent with the position the FDA took with respect to almond pasteurization after the last almond recall.
Studying the FDA’s Observations at PCA, #2
The FDA has posted the report on its inspections of the PCA facility on the FDA website, here. As PCA has noted on its website, the FDA's findings are not final, and PCA will have the opportunity to respond.
Observation #2 is that certain production lines were not cleaned after positive salmonella tests on product produced on those lines.
If this observation holds up, this is bad.