2013 Editorial Subcommittee Meeting Summaries

Feburary 7, 2013

The Editorial Committee completed review of “Chapter 1 Introduction to Course and Food Safety Preventive Controls,”pending modifications of definitions and dates as other chapters are completed. The chapter covers the history of risk-based, preventive controls, including HACCP, and provides a conceptual image of how a food safety plan fits into overall preventive controls.

Feburary 14, 2013

Format for a Product Description Form was finalized and preliminary discussion on a Hazard Analysis Worksheet was held. Finalizing the format is needed to develop models for training purposes. Examples will be used for a Face-to-Face meeting of Working Group Chairs and Co-chairs in Chicago on March 25.

February 20, 2013

Hazard Analysis Worksheet Options were discussed to accommodate Allergen Controls and Sanitation Controls included in the proposed rule. Discussions continue and the form will be used during a Face-to-Face meeting of Working Group Chairs and Co-chairs in Chicago on March 25. A draft of the prerequisite programs chapter is drafted for review and comment by the Editorial Committee.

February 28, 2013

Agreement was reach by those on the call for model templates for Preventive Controls Forms. Modifications will be shared with the rest of the Editorial Committee and used for Face-to-Face meeting with the Working Group Chairs and Co-chairs on March 25. The forms are very similar to those used in HACCP curricula, with additional text to ensure consideration of allergen controls, sanitation controls, supplier control and radiological hazards.

March 7, 2013

The committee agreed to the model form to be used to document Process Controls, which is similar to forms currently used in HACCP Plans. Plants could continue to call these HACCP plans if they wish, recognizing that other controls may be required as well (e.g., Sanitation Controls, Allergen Controls, etc.). Deliberation on a Hazard Analysis for a model product began and discussions will continue next week.

March 14, 2013

The Editorial Committee finalized the ingredient receiving and storage steps in Broccoli, Carrot and Pasta Salad Hazard Analysis. Further work on the Hazard Analysis will continue at a face to face working session of FSPCA Working Group Chairs and Co-Chairs on March 25 at IFSH.

March 28, 2013

Those on the call reviewed the outcome of the Working Group face-to-face meeting; however quorum was not present for most of the call. Potential modifications and next steps were discussed for further review by the Editorial Committee.

April 11, 2013

Food Safety Plan for Broccoli and Carrot Pasta Salad was discussed. The Product Description has been finalized. The Flow Diagram cannot be finalized until other steps are finalized. The Process Narrative requires additional review after reorganization to follow the flow diagram. Hazard Analysis was not discussed but suggestions were provided.

May 2, 2013

Reviewed new editorial subcommittee process – first review with the core group of the subcommittee then provide that work product to the full subcommittee for their comments. Calls are now scheduled every 2 weeks for 1 hour. All members agreed that this made better use of people’s time.

May 9, 2013

Finalized preliminary steps and hazard analysis for Broccoli and Carrot Pasta Salad for review by the Steering Committee. Decided to send chapters on Preliminary info, Introduction, Prerequisites, and Hazard Analysis to Steering Committee for their prioritization in planning a work session for the face-to- face meeting.

May 23, 2013

Steering Subcommittee feedback on Chapters 00 – 03 was reviewed and organization for the upcoming face-to-face Steering Committee meeting was determined.

June 13, 2013

Reviewed how comments from the Steering Committee are being incorporated into work to date. A notebook graphic has been developed to help visualize the elements of a Food Safety Plan. The concepts will be trialed at an IFT Sunrise Session in July.

July 11, 2013

Chapters 0-5 were reviewed prior to sending out for peer review. Chapters 0-4 were deemed ready for peer review, while Chapter 5 needs a final regulatory review prior to sending out. Swanson will begin the peer review process.

August 8, 2013

Reviewed the Hazard Analysis and Preventive Controls Determination chapter, making final adjustments to the Hazard Analysis Worksheet. The chapter is almost ready for peer review after sources of information on outbreaks, recalls and scientific information are added.

September 5, 2013

Peer review comments up to Chapter 5 are near completion. The Editorial Subcommittee will review suggested modifications for these chapters and the chapters will be “final” pending publication of the final rule or other modification deemed necessary during development of chapters beyond Chapter 5. A new and simplified example for an omelet will replace the Broccoli and Carrot Pasta Salad in response to reviewer’s comments that the Salad example is too complex. Development of new chapters will wait until the new example is finalized.

September 19, 2013

Peer review input on the Hazard Chapter was finalized, pending FDA review against their current thinking.

October 24, 2013

Omelet Example reviewed through Hazard Analysis. Need to review Process Control Plan and add Allergen Control Plan, Sanitation Control Plan.

October 31, 2013

Omelet Plan finalized except for Sanitation section and monitoring record forms.

November 7, 2013

The Omelet Food Safety Plan was “finalized” with the exception of the monitoring record forms that will be needed for each of the preventive controls. The Hazard Analysis chapter is ready for Steering Committee review. The Process Control Chapter should be broken into sub-chapters for flow and presentation. The Editorial Subcommittee needs input on whether the Verification and Record Keeping Chapters should be stand along chapters that cover Process/Allergen/Sanitation aspects at the same time, to allow compare and contrast OR if the Process, Allergen, and Sanitation Control chapters should individually cover these elements relevant to the type of control.

November 14, 2013

Despite lack of quorum, consensus was reached that covering all of the elements of Process Control in one chapter is too much information. This is consistent with the consensus from the previous meeting, which also had lack of quorum, but different attendees. Therefore it was decided that Verification and Record-keeping would be separate chapters that would compare and review these elements for the different types of plans.