When QTrade Teas & Herbs’ Level 2 SQF Institute food safety and quality system review is complete this month, a well-deserved holiday rest awaits. For now, QTrade is fully engaged in audit preparations while filling orders without delay. Inspectors will spend two days completing their document assessment of the 70,000-square-foot facility in Cerritos, CA, where QTrade’s 46 employees blend up to 40,000 pounds of tea a day and pack 120,000 conventional and 10,000 pyramid tea bags in two shifts. The company is part of the $1 billion U.S. tea processing industry that includes 41 firms and 1,500 workers. QTrade is the largest supplier of certified organic tea in North America, serving major tea brands, tea retailers, coffee roasters, foodservice and bottled drink brands. Our supply chain is anchored on five continents. My task is to ensure the safety of imported ingredients, which includes formulating, blending and packaging of both conventional and U.S. Department of Agriculture National Organic Program-certified teas. Quality begins at origin Our initial challenge is a document determining precise performance characteristics for each client. Parameters in these specifications range from particle size, aroma, color and concentration of essential oils to overall appearance and long-term availability and price. QTrade encounters all the variables of natural products grown on many plantations, with each crop the result of unique weather patterns, soil, harvesting and processing conditions. Specialty tea requires chunkier, brighter inclusions and larger vibrant leaf that is pleasing to the eye and crafted to artisan levels. Quality is determined by examination of consistent blending against reference standards, with requirements at both the dry leaf and infused beverage stages. Tea is generally not viewed as a high-risk food. People traditionally infuse the dried teas and blends in boiling water, but the combination of tea with fruits, nuts, spices and herbs requires the same quality diligence as any food processor. In preparation for the SQF audit, we hired a consultant well over a year ago to produce a gap audit. The gap analysis determined areas to address and helped prioritize our efforts. Even with a highly skilled internal quality team in place, the gap audit revealed several areas that not only improved overall quality, but also allowed for enhanced workflow and better segregation of tasks and responsibilities. Since the gap audit was completed, we identified several other areas that needed improvement. I would not rely on the gap audit alone to outline what needs to be done. Easily forgotten by the audit process is the fact that internal quality teams will always be more aware of policy weaknesses and standards than a consultant offering an expert opinion during the course of a short series of visits. These audits are not simple checklists with set rules in black and white; they require a degree of interpretation. I recommend reviewing the associated guidance documents to understand the spirit of the requirement. The SQF Code also requires that QTrade have an employee trained as a SQF practitioner on site and interpretation necessary to adapt requirements to our own food handling risks. SQF Module 2 and Module 11 are focused on facilities and capabilities. They include a significant emphasis demonstrating management commitment, even though all employees are responsible for ensuring food safety. Success depends on continuous improvement, training and careful monitoring from top to bottom in the organization. Anyone who is not alert and engaged can lead to a lapse in quality. Furthermore, requirements for Food Defense as well as Business Continuity Planning helped to broaden the scope of responsibility. The most significant reform of the U.S. food supply in 70 years is under way. The U.S. Food and Drug Administration’s (FDA) Food Safety Modernization Act (FSMA) that was signed into law in 2011 shifts the focus from responding and containing food contamination to prevention. After the initial inspection, audits will typically take place annually. Managing food hazards FSMA requires importers to absorb much greater responsibility for overall food safety, including much closer documentation and review of supplier conduct related to managing food hazards. To minimize risk, we enter into long-term relationships with growers who consistently produce quality crops and can anticipate volumes. We spend a lot of time qualifying a handful of new suppliers each year, learning how well they understand seasonality and yield and determining the capabilities of their processing facility. We want to ensure that our entire network is reliable and can demonstrate adherence to food safety policies and regulations. Not all of our suppliers are immediately willing to adapt to a more highly regulated production and documentation environment, but QTrade believes this investment is inevitable for suppliers providing products to the U.S. market. As an importer, QTrade continuously offers suppliers guidance on the need to improve quality and on the changing regulatory environment. There is a global effort to standardize food safety procedures through the Global Food Safety Initiative (GFSI), but many of these markets are still relatively underdeveloped. Producers can often get their price from buyers who do not require these things. We explain that it makes sense to improve infrastructure and that sustainable practices are not just to attract the highest bidder; they often result in the lowest cost for preparation. As a global importer, QTrade seeks to be an extension of what our buyers want, which generally means negotiating the highest quality standards possible at the supplier level. As the size of our volume contracts increase, we impose additional quality safeguards at our company and on our suppliers, while still managing economic pressures for price stability and availability. We understand the process and are innovation partners in the supply chain. Formulating, blending, cupping and packaging are both art and science, and there is no choice for us but to improve in a deliberate, accelerated path. We had to master research and development of formulations to become the leader in specialty teas. Now our goal is to augment that innovation with quality policies and documentation that meet and exceed the evolving regulatory requirements under consideration today. Traceability It’s not good business to be careless. We would enforce exacting safety measures to control pathogens with or without SQF or FSMA. In 2012, researchers at the University of Arkansas showed that food manufacturers achieving certification with one of the GFSI internationally recognized benchmarked schemes strengthen their food safety programs, resulting in safer food for consumers. One of the most significant findings, according to researchers, was that certified facilities shared more thorough documentation of their food safety management system. Traceability, beginning at origin, is especially important to clients. QTrade relies on lot numbers controlled by barcoding to document everything that goes into the blend, as well as when it was blended and who was responsible. Packaging line, time, lot and operator — our computer system tracks all these details. Every step is reportable which is inherent in a quality system, not because it is a requirement but because it underlies accountability. And legally, in the event of a recall, you must know. No one wants to put their good name at risk. A couple of years ago, our choice was whether to invest and try to stay ahead of the curve, or to wait until government more fully regulates how we manage quality. In our minds, our clients have already answered that question for us by monitoring our performance on certified third party audits. In many ways, accountability is being shifted to the importer. New rules aimed at strengthening assurances that imported food meets the same safety standards as food produced domestically are under discussion. The Foreign Supplier Verification Programs (FSVP) proposal would establish requirements for importers to verify that their foreign suppliers are implementing the modern, prevention-oriented food safety practices called for by FSMA. A second proposed rule on the Accreditation of Third-Party Auditors/Certification Bodies would strengthen the quality, objectivity and transparency of foreign food safety audits on which many U.S. food companies and importers currently rely to help manage the safety of their global food supply chains. These new import regulations, controls on pesticide residue and considerations such as the minimum suspended tea solids in bottled beverages are national and global concerns addressed by industry bodies such as the Tea Association of the USA and the American Herbal Products Association. The effort extends beyond tea. We all benefit from consolidating our ideas, experiences and goals, all of which lead to improved safety for consumers and the entire supply channel. (Ronald Eng is vice president of quality assurance at QTrade Teas and Herbs, which heavily invested in IT to monitor compliance, reduce errors and verify the many steps required by auditors. He has an extensive scientific background in biopharmaceuticals and an advanced degree in microbiology. To learn more, visit QTradeTeas.com.) Postscript: The main feature of the SQF Code is its emphasis on the systematic application of HACCP for control of food quality hazards, as well as food safety. The SQF audit is conducted in two parts. The first part is a desk audit undertaken to verify that the supplier’s SQF System documentation meets the requirements of the SQF Code. The second part is a facility audit conducted on-site and determines the effective implementation of the supplier’s documented SQF System. QTrade completed the desk audit December 2013 and will undergo the facility audit in April 2014.