Effectively Managing a Complex Supply Chain

Hormel Foods CorporationBrent Brehmer

Corporate Manager of RegulatoryCompliance & HACCP

• What Keeps Me Awake At Night?

Partial List of Recent Recalls• Black Pepper - Salmonella• HVP Recall - Salmonella• Gnd Beef – 5,750,000# - E. coli. O157:H7• Canada – ALL RTE Products – Lm• Peanut Based Items – Salmonella• Non-Fat Dry Milk, Whey Prot., Gums – Salmonella• Raw Beef – 825,000# - Salmonella• 5,500,000 Eggs – Salmonella• Several on Allergens Too

QC Involvement With Ingredient Suppliers• Years ago, from a food-safety

standpoint, QC had little to do with Ingredient Suppliers.– R&D would try ingredient.– If it worked,– Purchasing ordered it & Plants ran it

• Purchasing had protocols – but QC did not.

OK – So What Do We Do?• > 3,400 Ingredients• > 900 Suppliers• Copacker Approach as a Goal– 105 Copackers– Audit every 1-2 Years

• Not staffed for this, so what do we do?– Added 3 people to our staff– Ingredient Risk Assessment– Third-Party Audits

Ingredient Risk AssessmentSalmonella

High-Risk Ingredients for Salmonella(Table 5.1 – Page 49)

• Chocolate/Choc. Prod.• Nuts / Nut Products• Coconuts• Seed / Seed Products• Grains / Grain Prod.• Dried Egg Products• Fruits / Fruit Prod.• Dairy Ingred. & Blends• Spices, Herbs, Blended

Seasonings

• Soy Products• Gums / Thickeners

(Excluding Starches)• Yeast / Yeast Extract• Gelatin• Dry Vegetables• Enzymes / Rennets• Dry Meat or Meat

Byproducts

RPN (Risk Priority Number) - Calculated By:

Risk Severity (Ingredient Risk & How Used)

Detection (Hormel Foods Assessment Result)

Third-Party Audit Result (GFSI, Other)

(The Higher the Number, the Higher the Risk)

x

x

RPN – Risk Severity - Ingredient RiskIngredient Risk – Rated on combination of:

• Is the Ingredient High Risk for Salmonella?

• How are we using the ingredient?• Added Directly to RTE?• Added to Raw item that will be cooked?• Added to Item we cook internally?

RPN (Risk Priority Number) :

Risk Severity (Ingredient risk & use)

Detection (Hormel Foods Assessment Result)

Third-Party Audit Result (GFSI, Other)

x

x

Likelihood and Detection Scores (based upon Hormel Foods Assessment on Suppliers of Ingredients)

- Not Acceptable Assessment Results (Assessment Score < 85%) OR Supplier not yet reviewed by HFC

- Conditionally Approved Assessment (Assessment Score > 85% - < 92%)

- Acceptable Hormel Foods Assessment Results (Assessment Score > 92%)

High Risk Ingredients – RPN Calculation

RPN (Risk Priority Number) Now Calculated By:

Risk Severity (Ingredient risk & use)

Likelihood (Hormel Foods Assessment Result)

Third-Party Audit Result (GFSI, Other)

x

x

Third Party Audits- No Third Party Audit provided or just a

score page was provided ORUnacceptable Results from Third-Party Audit

– Acceptable Non-GFSI Third-Party Audit Results

– Acceptable GFSI Audit Results

High Risk Ingredients – RPN Calculation

Current List of GFSI Accredited Certification Bodies (to the Guidance Document)

• BRC – (British Retail Consortium)

• IFS – (International Food Standard - Germany)

• SQF – (Safe Quality Food 2000 Code Level 2 - USA)

• GlobalGAP – Fruit & Vegetable Version– Commodity GAP – (Good Agricultural Practices)

• FSSC 22,000– (Foundation for Food Safety Certification – ISO)

• Dutch HACCP – Option B– Being phased out?

High Risk Ingredients – RPN Calculation

Red RPN > Y (Re-Assessment Conducted This Year)*Yellow RPN X - Y (Conduct Assessment Next Year)Green RPN < X (Conduct Assessment Every 2 Years)

* Will evaluate reasons for Red rating. Certain situations may warrant immediate discontinuance of Supplier relationship. Some situations may allow for a follow-up after 60 day corrective action period. If follow-up results in a continued Red rating, begin discontinuation process.

RPN for Suppliers of Low Risk Ingredients

Risk Severity (Ingredient risk & use)

X

Third-Party Audit Result (GFSI, Other, None)

Low Risk Ingredients – RPN Calculations

Red Purchasing to obtain audit or begin supplier discontinuation processYellow Purchasing to require GFSI AuditGreen Acceptable

Audit Results

Highest Risk Ingredients/Suppliers

Assessments Completed

Results

New Ingredients• Implemented Protocols for:– R&D– Purchasing– QC

• At “Line Trial” stage.

Use Of U:\ Drive File• When R&D is looking at new

ingredient/supplier, review file to see if:– Another Entity is Using ingredient or supplier;– Have we visited supplier (G, Y or R)?– If Red, contact us and ask status.

Pathogen Testing of Incoming Ingredients• Old Protocol– Routinely Test Incoming Ingred. for pathogens

• New Protocol– Require COA from Supplier– Periodic Validation – working with supplier.

Summary• Food Safety Modernization Act– More FDA Scrutiny– Verify Adequacy of Suppliers

• Marketing– Advertising & News

• Reportable Food Registry• Due Diligence– Right Thing To Do!

Thank You!