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FOOD SAFETY AUDIT REPORT#19408-APeanut Corporation of America14075 Magnolia St.Blakely, GA 39823-0448ByEUGENE A. HATFIELDFood Safety AuditorMarch 27, 2008AIB International1213 Bakers Way PO Box 3999 Manhattan, KS 66505-3999(785-537-4750) (800-633-5137) Fax (785-537-1493)http://www.aibonline.org

RATINGA food safety audit was conducted at this facility on March 27, 2008.The writer was accompanied throughout the audit by Mr. Danny Kilgore,Operations Manager; and Ms. Annie Bristow, Janitorial and Sanitation Director.Excellent cooperation was received by the writer, and on some occasions, theitems were immediately corrected.At the conclusion of the audit, a meeting was held to discuss the observations,recommendations, and rating The meeting was held with Mr Danny Kilgore,Operations Manager.Based on the observations made, the information obtained, and the criteria set forthin the AIB Consolidated Standards for Food Safety, the overall food safety levelof this facility was considered to be:SUPERIOR(910)The “serious” or “unsatisfactory” items are shaded, boxed, and bolded inthe text of the report. Refer to the definitions in the AIB ConsolidatedStandards.The “improvement needed” items are designated in bold type and requireprompt attention.The AIB International states that the report as given herein is to be construed asits findings and recommendations as of the date of this report. The AIBInternational accepts no responsibility and does not assume any responsibility forthe food safety program in effect with (customer). That further AIB Internationalis only making report of the food safety conditions of (customer) as of the date ofthis report and assumes no responsibility or liability as to whether (customer)carries out the recommendations as contained in this report or does not carry outthe recommendations as contained in this report.#19408-A-p.1

RATING ANALYSISDATE OF AUDIT:March 27, 2008TYPE OF AUDIT:AnnouncedOVERALL RATING:SUPERIORADEQUACY OF FOOD SAFETY PROGRAM175PEST CONTROL195OPERATIONAL METHODS AND PERSONNEL PRACTICES175MAINTENANCE FOR FOOD SAFETY175CLEANING PRACTICES190TOTAL:910#19408-A-p.2

INCIDENCE FREQUENCY REPORT (IFR)APPCOPMSCP*TBAUNSERPLANT OVERVIEW32101700EXTERIOR AND ROOF00010100SUPPORT AREAS00010100MAINTENANCE AREAS00100100WAREHOUSE00000000PEANUT BUTTER AND PASTEOPERATIONS00122500TOTAL ITEMS BY CATEGORY3234300*TBA TOTAL ITEMS BY AREAAP Adequacy of Food Safety ProgramPC Pest ControlOP Operational Methods and Personnel PracticesMS Maintenance for Food SafetyCP Cleaning PracticesUN UnsatisfactorySER Serious#19408-A-p.3

FACTUAL OBSERVATIONS AND SPECIFIC RECOMMENDATIONSPLANT OVERVIEW1.COMA current organizational chart dated January 12, 2008, was maintained. Theresponsibility and authority for ensuring food safety and security, and thefacility's compliance with federal, state, governmental, and/or any otherappropriate regulatory laws or guidelines were clearly assigned to the OperationsManager. This responsible person remains up to date on regulatory issues and hasobtained the required regulatory food security registration dated 11/0/03.2.COMA Food Safety Manual had been developed. This manual included workinstructions and/or job descriptions outlining the specific responsibilities of eachdepartment manager and employees, a Quality Policy signed by the CompanyPresident with a revision date of January 28, 2006, and written policies for theprograms listed in the AIB Consolidated Standards for Food Safety.3.APThis facility had established a multidisciplinary food safety committee toconduct monthly inspections of the entire plant. Inspections were generallyperformed by the Operations Manager and/or Janitorial/SanitationDirector. Documentation of the monthly inspections included identifieddeficiencies, specific assignments, and actual accomplishments. Inspectionsreviewed included January, 2008, February, 2008, and March, 2008.Follow-up inspections were done to ensure that the items were corrected. Inaddition, systems and procedures critical to product safety and quality wereaudited to ensure they were in place, appropriate, and complied with. Thisaudit was performed by the Quality Assurance Manager and OperationsManager annually, most recently on January 12, 2008, by the OperationsManager. Continued attention to items that had the potential to impactproduct zones was recommended. Items such as the paste room hoistmaintenance, cleaning and sealing gaps in vertical support beams, and openingredient containers in the peanut butter mixing area. (IMPROVEMENTNEEDED)4.COMThe facility appeared to maintain an adequate budget and support to maintain theproper and timely acquisition of appropriate tools, materials, equipment,monitoring devices, chemicals, and pest control materials.#19408-A-p.4

5.APA Master Cleaning Schedule (MCS) and a daily housekeeping schedule weredeveloped as a formalized, written plan and implemented in this facility. ThisMCS specified frequency and responsibility. Postcleaning evaluations wereconducted. The schedules were documented as current, and the conditionsobserved in the plant supported the documentation. The schedule included theoutside grounds, buildings, drains, and equipment. The schedule was reviewedperiodically to ensure that it was still applicable. Continued emphasis on cleaningthe edges around the peanut butter pour-up stations and the floor/wall junctionsand gaps in the paste room were needed.6.COMDetailed, written cleaning procedures were developed and on file for all cleaningtasks in the facility. These procedures included the chemicals, concentrations,tools, and disassembly instructions for equipment at the level needed to facilitatethe appropriate sanitation maintenance of the processing and packagingequipment, building areas, and outside grounds. Specific cleaning procedureswere developed to prevent cross-contamination amid allergen andnon-allergen-containing products.7.COMIncoming goods and ingredients received into the facility were inspectedaccording to established written procedures. The incoming goods were checkedfor damage, cleanliness, and pest activity. The receiving records included date ofreceipt, carrier, lot number, amount, seal numbers (when applicable), and productand vehicle conditions. Raw materials that contain allergens or are susceptible tomycotoxins, autolysis from temperature abuse, or pathogenic microorganismswere segregated and covered by a separate written procedure with appropriatedocumentation.8.COMBulk deliveries of liquid materials included a visual inspection both before andafter unloading. Verification was conducted that hatch and hose seals matchedthose listed on the bill of lading to ensure load integrity in transit. The findingswere documented.9.COMAppropriate specifications were on file for the raw materials, packagingmaterials, finished products, and intermediate/semiprocessed products. Thesespecifications were detailed to ensure compliance with relevant food safety andlegislative requirements. These specifications were periodically reviewed andformally agreed upon with relevant parties.10.COMCertificates of analysis and/or supplier guarantees for raw materials, foodpackaging, and finished products were maintained on file.#19408-A-p.5

11.COMA Hazard Analysis Critical Control Point (HACCP) program had been developedand implemented for all processes and process lines. The program included thefollowing components: Description of the products manufactured and hazardsinherent to them, determined through risk assessment; Identification of criticalcontrol points (CCP) and critical limits; Procedures to control the CCPs;Determination of the monitoring frequency for the CCPs and designation of theperson(s) responsible for testing; Established and documented deviationprocedures; Written verification program, with proper documentation;Documentation of procedures, records of conformance, and corrective actions.This facility had evaluated the processes and procedures and determined that nocritical control points were present in the operation. The designated monitoringcontrol points (MCPs) were specified and described. The most recent programreassessment had been performed by the Operations Manager on January 12,2008.12.COMThe company had established written employee and Good ManufacturingPractices (GMPs) policies. Specific written procedures were on file for providingfood safety training to all personnel, including temporary personnel andcontractors. Employees also attended monthly food safety meetings that revieweddifferent aspects of food safety and GMPs. Records of training completion fornew employees and annual refresher training documentation were maintained forall personnel. The most recent employee meeting was held on 03/05/08. Itemscovered included AIB, GMP, hand sanitation, spillage and clean-up. The annualemployee training was held in January and February, 2008.13.COMA written program for evaluating consumer complaints was established at thislocation. This program included the rapid dissemination of complaint informationto all departments responsible for implementing the food safety program.Complaint information was used, where appropriate, to avoid recurrence andimplement ongoing improvements to product safety, legality, and quality.Actions appropriate to the seriousness and frequency of the problems identifiedappeared to be carried out promptly and effectively.14.COMA written recall program was on file. All finished products were coded. Producttraceability was accomplished through the recording of raw material lot numberson production records, and included source identification for work in progressand rework. Distribution records were maintained to identify the initial point ofdistribution to facilitate segregation and recall of specific lots. The recall programwas tested every six months with appropriate documentation maintained on file.The most recent mock recall was done on January 15, 2008. The incomingpeanut lot number tracked was 14675 received on October 18, 2007, from aknown supplier. The peanut lot number was used in a number of manufacturedproducts, manufacturing codes for 7 items were provided. The mock recall wascompleted in two hours and 15 minutes with 100 % effectiveness documented. #19408-A-p.6

15.COMWritten procedures were in place to control nonconforming product, includingwork in progress, finished product, and returned goods. Corrective actions equalto the seriousness of the risk appeared to be taken. Records were kept of thecorrective actions and disposition of the product. The disposition records accountfor the total quantity of the nonconforming material produced.16.COMA written policy on how to handle regulatory and third party inspections was onfile. These procedures included the person(s) delegated to accompany allinspectors and company policies regarding photographs, records, and samples.The most recent regulatory inspection was done by the Georgia Department ofAgriculture, Consumer Protection Division, on December 14, 2007. Noviolations were noted.17.COMA written program to evaluate and select suppliers of goods and services thataffect product quality and food safety had been implemented. An approved list ofthese suppliers was maintained. An approved list of these suppliers datedDecember 29, 2005, was maintained.18.APA written policy stating that no glass or brittle plastics were to be used in thefacility, except where absolutely necessary, was in place. Included in the policywas a procedure on how to handle any glass breakage in the facility. A list of allessential glass had been developed and was audited on a routine frequency toensure that any accidental breakage was found and addressed. The most recentaudit was done on March 1, 2008. One deficiency was observed during thisaudit. Additional attention to cracked light covers was recommended.19.COMA formal preventive maintenance program and work order system was in use toprioritize the elements of identified structural, equipment, or utensil maintenanceproblems that could cause food adulteration. The program listed the equipmentand frequency of the work required to keep the equipment and facility wellmaintained and in good order. A program to ensure that the safety and legality ofproduct were not jeopardized during maintenance operations was implemented atthis facility.20.COMThis operation had established a formalized program for the control of bacteria,yeast, and mold as required. Records of laboratory analysis and/or environmentalsampling were maintained. Environmental samples were sent to an approved,outside laboratory for testing. Finished product testing was determined bycustomer requirements and could include total plate count, coliforms, E. coli,Salmonella, and Staphylococcus aureus. All microbiological testing would beperformed by an approved, outside laboratory. The on-site laboratory wasmaintained in such a manner as not to jeopardize the safety of product.#19408-A-p.7

21.COMA formalized pest control program was established with written proceduresoutlining the requirements of the program to reduce the potential for productcontamination from pest activity or use of materials and/or procedures designedto control pest activity.22.COMFacility management contracted the McCall Services, Inc., Company to provideweekly pest control services for the exterior of the facility and the interior rodentcontrol program. Also, McCall Services, Inc., provided weekly service for theinterior insect light traps. A copy of the service agreement that included materialsto be used, methods, and precautions was maintained on file. Copies of thecurrent Georgia State Department of Agriculture license with an expiration dateof 06/30/09, liability insurance with expiration date of 08/01/08, and currentapplicator's license with an expiration date of 06/30/09 were maintained on file.In addition, Adams Pest Control was contracted to perform week