FoodHACCP Newsletter



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12/22. Dir, Food Safety - SQF Practitioner – Fresno, CA
12/22. Food Safety Manager – Bellevue, WA
12/22. Sr Qual & Food Safety Specialist – Chicago, IL
12/20. Res Assistant - Food Safety – Fort Valley, GA
 12/20. Food Safety Specialist – U of Idaho - Moscow
12/20. Food Safety Technician – Sebastopol, CA
12/18. Quality Manager – Columbus, OH
12/18. Senior Specialist Food Safety – Arlington, VA
12/18. Food Safety Auditor – Charlotte, NC

12/25  2017 ISSUE:788

 

Non-profit group wants to remind consumers about food safety
source : http://www.kwqc.com/content/news/Non-profit-group-wants-to-remind-consumers-about-food-safety-466456873.html
By kwqc.com (Dec 25, 2017)
Many of us are preparing a large holiday spread for our friends and family this holiday season, but you don't want to serve up a stomach ache!
The non-profit group 'Stop Foodborne Illness' has some helpful tips for providing a delicious and safe meal.
First, be sure to cook everything thoroughly. Poultry needs to be at least 165 degrees, while whole cuts of meat and seafood should be at 145 degrees. Also, be sure to use pasteurized eggs when making eggnog or other treats.
After the meal is over, get any leftovers back in the refrigerator within two hours. And if no one has eaten that turkey leg after 3-4 days, throw it away.

Bah, Hum (Stomach) Bug! Essential Holiday Food Safety Tips
source : https://consumer.healthday.com/public-health-information-30/food-safety-news-589/bah-hum-stomach-bug-essential-holiday-food-safety-tips-729028.html
By consumer.healthday.com (Dec 25, 2017)
A stomach bug can quickly put a damper on your Christmas Day festivities.
If you're teaching children how to prepare favorite family recipes, include important lessons about food safety, says the American Academy of Pediatrics.
The last thing you want to give your family is a foodborne illness. Here are some suggestions from the pediatricians' group to avoid one:
Every cook should have clean hands, including little helper chefs. Be sure kids wash their hands well and often when handling food.
Bacteria often lurk in uncooked foods, particularly meats and poultry. Thaw frozen meat in the refrigerator, not on the counter. Wash raw fruits and vegetables thoroughly before they're eaten or added to dishes.
It's tempting to lick the batter off bowls and spoons, but sampling certain raw ingredients, including eggs, can be risky. Also, any time someone tastes food during preparation, you should wash or replace the utensil used.
After cooking, store perishable foods in the refrigerator. They should not be left at room temperature for more than two hours. It's also important to keep raw ingredients separate from cooked foods. Similarly, keep kitchen tools used to stir or chop raw foods separate from other utensils.
When cooking with young helpers, remember to push bowls, cups or platters that contain hot foods or liquids away from the edges of counters or tables. Children could accidentally knock them over and get burned.
Likewise, turn pot handles toward the back of the stove, and make sure microwave ovens are out of little ones' reach.
Following the festivities, clear away any remaining food or drinks, even if it's late. Young children could wake up early and sample leftovers, which could lead to foodborne illness or choking.

 

 

 


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CDC Offers Food Safety Tips for the Holidays
source : https://foodpoisoningbulletin.com/2017/cdc-offers-food-safety-tips-holidays/
By Linda Larsen (Dec 22, 2017)
The holidays are upon us. Many people are cooking more at home, and with that in mind, the CDC is offering food safety tips for the holidays to make sure you don’t end up in the emergency room with food poisoning.
First, wash your hands before you prepare food and after you touch raw meat, raw eggs, or unwashed vegetables. That last one is new – but good to know, since raw vegetables have been linked to many foodborne illness outbreaks over the years.
Follow good food safety practices and cook food thoroughly. Always use a food thermometer to check the final internal temperature of meats, poultry, egg dishes, and seafood. And remember that roasts, chops, steaks, and fresh ham should stand for 3 minutes after they are removed from the oven or grill.
The “danger zone” is something everyone should know about. Between the temperatures of 40°F to 140°F, bacteria grow at a rapid pace. To prevent this catastrophe, keep hot food hot and cold food cold. Refrigerate or freeze any perishable foods within 2 hours. Make sure the temperature in your fridge is set at 40°F or below, and that your freezer is below 0°F.
Never make a recipe that uses raw eggs and isn’t cooked. Eggs harbor Salmonella bacteria and can make you very sick. Pasteurized eggs can be found at practically any supermarket. This time of year, it’s especially important to make eggnog, hollandaise sauce, Caesar dressing, and tiramisu with pasteurized eggs.
Do not eat raw cookie dough or batter. Eggs aren’t the only risk in these products; flour can contain pathogenic bacteria, as the E. coli outbreak linked to General Mills flour last year proves. Don’t let children taste raw dough or batter or play with dough at home or in restaurants for food safety reasons.
Keep foods properly separated to avoid cross-contamination. Keep meat, poultry, seafood, and eggs away from foods that are to be eaten raw. And don’t store these items on shelves above produce, because juices can drip or leak onto other foods.
To thaw a turkey, let it stand in the fridge for a few days, according to the size of the bird. You can also thaw it in a sink of cold water that is changed every 30 minutes. Or you can cook your turkey from the frozen state.
Finally, if a pregnant woman is coming to your house for a holiday party, make sure you don’t see any raw or unpasteurized milk or cider. Soft cheese and deli meats can also be problematic. These women should also avoid refrigerated smoked seafood, and any alcohol-spiked punches or eggnog.
Keep your family and guests safe and have a wonderful holiday!

How Blockchain Technology Could Transform the Food Industry
source : https://www.ecowatch.com/blockchain-technology-2519373206.html
By Sylvain Charlebois (Dec 22, 2017)
There has been a lot of noise on cryptocurrencies and Bitcoin of late. While some suggest cryptocurrencies are a fraud, others believe them to be the next biggest economic revolution the world has seen since the internet. Bitcoin has brought to light blockchain technology, which offers great potential for food safety and verification in the agrifood sector. Yet it is far from being the panacea for a range of issues affecting the industry—at least for now.
Simply put, blockchain technology is a way of storing and sharing information across a network of users in an open virtual space. Blockchain technology allows for users to look at all transactions simultaneously and in real-time. In food, for example, a retailer would know with whom his supplier has had dealings. Additionally, since transactions are not stored in any single location, it is almost impossible to hack the information.
For consumers, blockchain technology can make a difference. By reading a simple QR code with a smartphone, data such as an animal's date of birth, use of antibiotics, vaccinations and location where the livestock was harvested can easily be conveyed to the consumer.
Food Safety
Blockchain makes a supply chain more transparent at an all-new level. It also empowers the entire chain to be more responsive to any food safety disasters. Massive organizations such as Nestlé and Unilever are considering blockchain technologies for that reason.
Walmart, which sells 20 percent of all food in the U.S., has just completed two blockchain pilot projects. Prior to using blockchain, Walmart conducted a traceback test on mangoes in one of its stores. It took six days, 18 hours and 26 minutes to trace mangoes back to its original farm.
By using blockchain, Walmart can provide all the information the consumer wants in 2.2 seconds. During an outbreak of disease or contamination, six days is an eternity. A company can save lives by using blockchain technologies.
Blockchain also allows specific products to be traced at any given time, which would help to reduce food waste. For instance, contaminated products can be traced easily and quickly, while safe foods would remain on the shelves and not be sent to landfills.
Preventing Fraud
However, it will work only if the data at the source is accurate, as current practices in the industry are much more open to human error. Much of the compliance data is audited by trusted third parties and stored either on paper or in a centralized database. These databases are highly vulnerable to informational inaccuracies, hacking, high operating costs and intentional errors motivated by corruption and fraudulent behavior.
Blockchain operates anonymously, so mistakes would be traceable to individual culprits. Considering recent food-fraud scandals in Canada and elsewhere, this feature is not trivial. Blockchain technology provides a method with which records are kept permanently.

Most importantly though, it facilitates data-sharing between disparate actors in a food value chain. Many retailers have sold fraudulent food products unknowingly. With the use of blockchain, those days could come to and end.
Faster, Fairer Payment
Blockchain will allow everyone to be paid more quickly, from farm to plate. Farmers could sell more quickly, and be properly compensated as market data would be readily available and validated.
Blockchain technology could represent a legitimate option for farmers who feel compelled to rely on marketing boards to sell their commodities. The use of blockchain could prevent price coercion and retroactive payments, both of which we have seen across the food supply chain.
Blockchain technologies could "Uberize" the agrifood sector by eliminating middlemen and lowering transaction fees. This can lead to fairer pricing and even help smaller outfits desperate to get more market attention.
Limits of Blockchain
Our current traceability systems need work, and blockchain technologies could be the evolution they need. Given its architecture, blockchain technology offers an affordable solution to both small-to-medium enterprises (SMEs) and large organizations. However, there are noteworthy limitations.
The amount of information which can be processed is limited. Since all of the information would be out there and accessible, several contracts between organizations would need to be secured for some level of confidentiality to be retained. How to balance confidentiality with transparency would need to be worked out.
The agrifood arena is filled with secrets. Blockchain technology as it is currently being deployed would be problematic for many food companies. For many, blockchain is just a solution looking for a problem. Simply put, some companies, like Walmart, have more power and influence over other companies within the same supply chain.
Marketplace Confusion Limits Participation
In addition, blockchain is really in its infancy and most people are uncertain about its potential. The innovation in blockchain architectures, applications and business concepts is happening rapidly. It's a decentralized, open-source organism which is challenging to grasp for many, including governments.
In food, innovation is always desirable until it becomes real. Once it manifests itself, guards go up. Some organizations are moving ahead while others wait to see what happens. The marketplace is currently fueled with confusion due to the Bitcoin phenomenon, which is labelled by many as being irrational and ridiculous. Cryptocurrencies allow for transactions to occur while using blockchain technology, but it remains just an option.
Nevertheless, the most important challenge for blockchain technology remains participation. All parties must adopt the technology in order for it to work. In food distribution, not all companies are equal and some can exercise their power more than others.
A successful integration of the blockchain requires the engagement of all participating organizations. Walmart's blockchain will likely be successful because it's Walmart. But thousands of companies do not have the same clout.
Blockchain technology in agrifood has potential but it needs work. Industry public leaders should embrace blockchain as an opportunity and should be added to a digitalization strategy currently affecting the entire food industry. Transparency, productivity, competitiveness and sustainability of the agrifood sector could be enhanced.
Nonetheless, research should look at how to generate evidence-based blockchain solutions to democratize data for the entire system before we get too excited.
Reposted with permission from our media associate The Conversation.

Scientists Find New Way to Fight Antibiotic Resistant Bacteria Through the Cell Wall
source : https://foodpoisoningbulletin.com/2017/scientists-find-new-way-fight-antibiotic-resistant-bacteria/
By Linda Larsen (Dec 20, 2017)
Antibiotic resistant bactéria are becoming a serious threat to human health. The CDC estimates that 2,000,000 Americans are sickened with antibiotic resistant bacterial infections every year, and 23,000 die. For instance, antibiotic resistant Salmonella causes at least 6,000 illnesses every year in this country. Those numbers will most likely increase over the next few years.
But a new study published in PLOS Biology has found that bacterial cells have a weakness in the wall surrounding them that could be used to destroy them. Gram negative bacteria, such as E. coli, have a cell envelope that is made up of an outer and inner membrane. The two membranes are separated by an area that is called the periplasm.
That double membrane in the cell wall makes the bacteria more resistant to antibiotics. The two membranes communicate with each other, and can find and fix damage caused by antibiotics.
Professor Jean–François Collet, of the Université Catholique de Louvain, one of the study’s co-authors, told the Independent that, “On the wall there is a protein that serves as a guard, and so when there are antibiotics coming this protein will feel that and will then turn inside and reach another protein on the inner membrane, and they will communicate.”
Scientists removed the physical connection between the outer membrane and periplasm and discovered that the bacteria lost the ability to sense defects in the envelope. Drugs that target the envelope structure in the cell wall may be an effective method for destroying these cells. Even a slight increase in the size of the periplam disrupted the communication between the layers of the envelope.  We showed that if you increase the distance between the two walls, the protein will turn inside and try to reach its friends on the inner wall, but it will not be able to reach them.”
Researchers are developing compounds that could interfere with the bacterial cell walls and kill more antibiotic resistant bacteria. This could make older antibiotics, and those that are becoming less effective, more effective again.

Your guide to use-by dates and food safety this Christmas
source : http://www.netdoctor.co.uk/healthy-eating/advice/a29341/use-by-dates-and-food-safety-this-christmas/
By Claire Lavelle (Dec 21, 2017)
Fridge full to bursting and fond of a potluck dinner of leftovers? Here's what the food scientists recommend to stay safe
According to the Food Standards Agency (FSA), there are one million cases of food poisoning reported annually and two seasonal spikes during which numbers shoot up dramatically. The first is over summer - think BBQs and salads left to simmer gently in the summer sun - and the second is Christmas, as we throw caution to the wind and stuff fridges full of leftovers and ignore use-by dates in our efforts not to waste food (or money). Poultry tops the list of offenders, courtesy of the campylobacter bacteria it can carry, with beef and lamb not far behind.
However, it's not just meat you need to treat with respect. Vegetables (including potatoes), rice, fruit, nuts and seeds also have the potential to make us ill, with fresh berries and bagged salads containing particularly nasty bugs (cyclospora and E.coli respectively, both of which can cause nasty stomach upsets). So tempting as it may be to throw berries that have gone a bit mushy into a smoothie, it's better to bin them. And that bag of slimy rocket? You know what to do…
What's the difference between use-by, sell-by or best before dates?
According to an FSA spokesperson, the term 'sell-by' doesn't actually exist in legislation. Instead, the organisation encourages the use of 'use by' and 'best before'.
Dr Edna Nyangale, scientific affairs manager at the Institute of Food Science and Technology (IFST), confirms this approach. 'The use-by date is concerned with food safety and is used on food items which, from a microbiological perspective, have a shorter shelf life, are highly perishable [go off quickly] and therefore may pose a risk to consumer health if eaten after this date. Food items on which use-by dates are used include fish, poultry, meats, dairy and some pre-packed cut salads.
'The 'best before' date is used for items where the quality of the product may not be at its best after the date – for example, bread may taste stale. However, as long as the storage conditions have been adhered too, items should be safe to eat.'
Can I extend the use-by date by a couple of days as long as the packaging hasn't been opened?
The short answer is no. 'The Food Standards Agency strongly recommends not consuming or freezing food after the use-by date as it may pose a risk of illness,' says Dr Nyangale. 'You shouldn't freeze it either, as freezing at this stage only acts to pause bacterial growth, not kill it. Freezing prior to the use by date is fine, on pack instructions often indicate how long the product can be stored for using this method.'
Is the 'sniff test' a reliable way to tell whether food has gone off? In consumer research published by the Waste and Action Resources Programme (WRAP) in 2011, Cheddar cheese, milk and yoghurts are products that consumers said they would eat after the use by date if it looked and smelled OK. If you regularly take this approach, think again! 'Use-by dates are there for the safety of the consumer and this approach is not appropriate,' says Dr Nyangale. 'People probably are less cautious about foods where there is no 'off' smell or visible signs of spoilage; however this does not mean that the food will be safe to eat.'
How are use-by dates calculated?
'These dates are calculated using shelf-life testing, which means the item is stored at the recommended conditions and tested regularly to monitor growth of any potentially harmful bacteria,' says John Bassett, policy and scientific development director at the IFST. 'This way, we can assess how long a product is safe for and confidently give a timeframe in which the item can be eaten without causing the consumer harm.'
As a nation, do Brits tend to adhere to these dates or take a slightly cavalier approach?
Data published by WRAP found that 39% of consumers as 'date driven' and always keep an eye on dates at home, while 48% were 'date savvy' – in other words, had a general awareness of use-by dates. 'Although this data doesn't tell us about the numbers who eat foods after the use by dates, it does indicate an overall awareness of the importance of the date labels,' says John Bassett.
Finally, what's the best way to store leftovers after Christmas?
'This really depends on what the leftovers are,' says Dr Nyangale. 'Foods like turkey and rice – i.e. high-risk foods – should be kept in the fridge and eaten within around two days. When reheating, you must make sure they're piping hot before you eat them.' And remember to allow food to cool sufficiently before putting it in the fridge, otherwise you run the risk of raising the temperature inside, creating a breeding ground for bacteria. Around two hours is plenty (don't leave it on the worktop – or in the oven – all night!)
Be careful with the cheeseboard
Surely the riper and runnier the better, no? Only as long as it's within the use-by date, especially if it's made with unpasteurised milk. That stinky star of the cheeseboard may harbor both listeria and E.coli, so while bring to room temperature before serving is fine, no more leaving it on top of the Aga for days on end…
Hate waste? Try these simple but effective leftover ideas…
•Add vegetable stock to leftover veggies, such as potatoes, carrots and parsnips, and whizz up into a delicious soup
•Stir fry turkey or beef with crunchy stir-fry veggies, garlic and chilli
•Cube leftover ham and chicken and make into a pie (there's no shame in shop-bought pastry)
•Freeze fresh berries in small portions and defrost as required
•Slice and freeze cooked turkey to be used later for sandwiches or stir fries

Don’t Make Canned Breads and Cakes; They Can Harbor Botulism Toxin
Source : https://foodpoisoningbulletin.com/2017/canned-breads-cakes-can-harbor-botulism/
By Linda Larsen (Dec 21, 2017)
Scientists at Penn State are reminding consumers that recipes for canned breads and cakes are not safe and should not be made at home. Recipes for these items are often appear around holiday time every year. These products are low acid foods with a pH above 4.6, are not shelf-stable, and can’t be safely stored at room temperature. In other words, they can harbor botulism toxin.
These products are made by baking batters in glass canning jars. The jars are removed from the oven and sealed and cooled so a vacuum is created. That’s where the trouble starts; in a vacuum. Clostridium botulism spores grow in unrefrigerated high moisture foods that are low in acid and exposed to little or no oxygen.
Clostridium botulinum bacteria are found everywhere. This bacteria grows under anaerobic conditions found in canning jars. As the bacteria grows, it produces a toxin that is deadly in tiny amounts.
All low acid canned foods must be processed under pressure at temperatures of 240°F or higher. This is the only way to kill the heat-resistant spores the bacteria produces under unfavorable conditions. Research at Penn State found that low acid canned bread or cake products may support the growth of these spores.
If the product is underbaked, that’s another concern. Flour and eggs can harbor pathogenic bacteria such as E. coli and Salmonella. If the product is underbaked, those bacteria can grow as well.
And there’s another hazard with these products: canning jars are not made for use in the oven. They should be used only in hot water baths or pressure canners. When used to bake cakes or breads in the oven’s dry heat, the glass can break and explode.
So don’t use glass canning jars when baking breads and cakes. Use a regular baking pan, cool the product, then use it immediately or freeze it. Or you can give a “mix in the jar” product, which is made by layering the dry ingredients in a jar. The recipient then makes the product using those premeasured dry ingredients, adding the liquid and eggs.

Protective disclosure made over alleged food safety breaches at meat company
Source : https://www.independent.ie/business/farming/agri-business/protective-disclosure-made-over-alleged-food-safety-breaches-at-meat-company-36425505.html
By independent.ie (Dec 20, 2017)
A meat factory production manager who claims he was unfairly suspended by his employer has made a protective disclosure about alleged food safety breaches to Food Safety Authority of Ireland (FSAI), the High Court heard.
The claims have been made by Alvaro Carvalho who works for Carrolls Cuisine Unlimited Company, based in Tullamore, Co Offaly which processes and packages beef, chicken, pork, ham, and turkey products for sale in Ireland and abroad expanded production.
Mr Carvalho, of Harbour Drive, Tullamore, seeks various orders and declarations from including an injunction restraining his employer from continuing with any disciplinary process against him into alleged misconduct.
He also seeks orders restraining the company from penalizing, demoting or victimising him and that the company deal with grievances he has raised.
In opposing the application, the company "strenuously denies" all allegations it has breached food safety standards.
It says it takes its obligations  "very seriously."  It has been in contact with the FSAI and the Department of Agriculture about the allegations.
Mr Carvalho who has worked in the industry for 20 years commenced work with Carrolls Cuisine in 2013.
Last October he was suspended allegedly for having a lack of respect and empathy for fellow employees.
In a sworn statement to the court he said there is "no substance" to the claims and says he was not given a chance to deal with the allegations. The suspension was a way to force him to resign.
Following his suspension he says a senior manager told him there was one way to stop this and that was for him to make an offer and he would get an excellent reference.
He said earlier this year the company began to expand production at the plant.
He said the pressure to increase production "got out of control" last September when senior management instructed staff to increase production to "an inordinate degree."
This placed an "intolerable burden" on both him and staff at the plant.
In order to meet those targets "food safety standards were blatantly ignored and normal cleaning and hygiene protocols were compromised, he said.
He said he was unhappy with this pressure to increase production and was unwilling to be a party to these dangerous practices and resisted them. He said he believes he was targeted by senior management as he had become "an obstacle to their business ambitions. "
Following his suspension, an investigation found  the allegations against him did not merit any further investigation at this stage.
Mr Carvalho said he was upset to read comments by the investigator that inter personal issues involving Mr Carvalho at the work place would be best dealt with by counselling and mediation between the parties.
The report also said it appeared Mr Carvalho had shouted at colleagues acted in an aggressive manner towards him.  
He said those findings were damaging to him, and in his proceedings seeks to have them quashed.
In early December his suspension was lifted but on his return to work he said "drastic changes" were imposed on him without his consent including that his shifts were changed from eight hours to 12 hours in length, he was moved to a smaller office, and that he was demoted.
In a sworn statement opposing the injunction application the company's managing Director Kieran  Carolan said the application is misconceived, and there was no basis for the injunctions sought. 
He also denied any breaches of food safety standards.
The application for an injunction, pending the outcome of the full hearing of Mr Carvalho's action, was heard by Ms Justice Eileen Creedon who has reserved judgment.

There’s something rotten inside India’s top food safety regulator
Source : https://qz.com/1161369/fssai-indias-indias-top-food-safety-regulator-is-a-mess-cag-audit-finds/
By qz.com (Dec 20 ,2017)
The country’s top food regulator is under the scanner.
The Food Safety Standards Authority of India (FSSAI), responsible for regulating and monitoring food safety, has been rapped over ill-equipped food laboratories and for following poor testing standards.
An audit report (pdf) by the Comptroller and Auditor General of India (CAG) tabled in parliament on Dec. 19 has raised several concerns over clearances and testing of food, the lack of equipment, and a shortage of staff across various testing labs affiliated with the FSSAI. It has also questioned the lack of guidelines and procedures to regulate the use of certain food items. “The audit revealed systemic inefficiencies, including delays and deficiencies in the framing of various regulations and standards,” the CAG report said.
Established in 2011 under the Food Safety and Standard Act, 2006, the FSSAI is part of India’s ministry of health and family welfare. Its primary function is to lay down scientific standards for food and to regulate their manufacture, storage, distribution, sale, and import. It works through a network of state and referral food laboratories.
In its audit, the CAG scrutinised the FSSAI’s functioning between August 2011 and March 2016, looking into 53 districts and 20 state laboratories, along with facilities in eight ports.

Here are some of the key findings from the report:
•State of food-testing labs: The CAG has underlined the shoddy state of food-testing labs under the FSSAI. “Most of the state food laboratories entrusted with food testing and certification functions were not only ill-equipped but also did not possess accreditation of the National Accreditation Board for Testing and Calibration Laboratories (NABL),” the report said. The CAG report also highlighted a shortage of qualified manpower and functional equipment in certain state food laboratories that could have led to “deficient testing of food samples.”
•Lack of standards for regulating some food items: The FSSAI “failed to devise action plans to identify areas on which standards are to be formulated or revised within specified time frames and the manner of selection of food products for the formulation of standards,” the CAG reported. In what can be seen as a conflict of interest, the CAG has claimed that the FSSAI reached out to operators of food businesses for their suggestions on revising the standards.
•Poor infrastructure for collection of samples: The CAG report has brought to light the dire conditions under which samples of food products are collected and stored in the various FSSAI facilities. “Audit observed deficiencies in the required infrastructure for safe custody of samples such as lockable, secure fridge, freezer, cold chain boxes, insulated boxes, etc. In the absence of the requisite infrastructure, the samples were stored in almirahs and cupboards,” the report noted. This led to the deterioration of samples even before they were sent to labs for testing.
•Lapses in issuing licences and clearances: The FSSAI has been found guilty of issuing licences to operators of food businesses who failed to submit all relevant documents required. In fact, the audit found out that 50% of FBOs (food business operators) surveyed by the CAG were granted licences with incomplete documents.
•Financial lapses: The CAG report has also highlighted financial lapses within the FSSAI. According to the report, the FSSAI did not frame regulations for utilisation of funds of Rs100.73 crore it had collected through licence fees, testing, and laboratory fees, etc.

 

 

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