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THE DEPARTMENT OF MARINE RESOURCES
Sanitation Controls
Procedures
[SCPs]
Workshop
7-8 July 2020
DMR Conference Room
Table of Contents
Day One
Definitions
General Concepts in Keeping Food Safe
Spotting Unsafe Conditions in the Home & Office
2
Table of Contents
Day Two
SCPs & GMPs
SOPs, SSOP VS. HACCP Documents
Spotting Unsafe Conditions in the Field
Field Visit
3
Sanitation and Keeping Food Safe
Proper sanitation is necessary to control potential
food safety hazards that might be associated with
the environment in which food is prepared as
well as preparation or cooking methods.
4
Sanitation and Keeping Food Safe
Keeping food safe is especially important to the following populations:
Elderly
Young children
Pregnant women
Those with compromised immune systems
5
Sanitation and Keeping Food Safe
Preventing Cross Contamination
Practicing Personal Hygiene
Cleaning and Sanitizing
Controlling Time and Temperature
Purchasing from Approved Reputable Suppliers
6
Sanitation and Keeping Food Safe
TCS Foods are those which require time and temperature controls to ensure safety
and avoid contamination.
Ready-to-Eat (RTE) Foods are those foods that are normally eaten in their raw state
or any other food, including a processed food, for which it is reasonably foreseeable
that the food will be eaten without further processing that would significantly
minimize biological hazards.
7
8
Sanitation and Keeping Food Safe
Cross-contamination refers to the transfer of biological or chemical contaminants to
food products from raw foods, food handlers, or the food handling environment.
Food Contact Surfaces are those that contact human food and those surfaces from
which drainage onto the food or onto surfaces that contact the food ordinarily occurs
during the normal course of operation
9
Biological
Viruses
Bacteria
Fungi
Parasites
Yeasts
Molds
Chemical
Allergens
Toxins
Pesticides
Sanitizing Agents
Physical
are extraneous and not
normally found in food
which may cause physical
injury.
Glass or metal fragments,
fish bones
10
Preventing Cross Contamination: Types of Hazards
Preventing Cross Contamination: Reducing Hazards
When choosing material or equipment, choose those that are smooth and durable to make
cleaning easier. Avoid wooden utensils or cutting boards. Choose stainless steel or silicone
Cleaning aids which retain water, such as sponges, wiping cloths and mops should be avoided
Using only food safe chemical cleaning aids
Keeping cleaning or maintenance chemicals stored away from food and food preparation
areas. Never store above food or food contact surfaces
Larger pieces of equipment should ideally be floor mounted to allow for cleaning underneath
11
12
13
14
Preventing Cross Contamination: Reducing Hazards
Separation of raw and cooked or ready-to-eat foods
Separation of the utensils used for each (i.e. using only red utensils for raw foods and green
utensils for ready-to-eat foods and keeping them physically separated when in use)
Separation of contaminated surfaces and ready-to-eat foods
Washing hands when switching from preparing raw or uncooked foods to handling ready-to-
eat, cooked food items
15
Controlling Cross Contamination: Pest Prevention
They are vectors of diseases foodborne illness
Pests can also aid in spreading contamination by
damaging food, supplies or food processing areas
themselves
16
Controlling Cross Contamination: Pest Prevention
Eliminate sources of food, water and shelter
Eliminate access to home and food handling
areas
Contract a licensed pest control operator
17
18
19
20
Practicing Personal Hygiene
Handwashing is an important part of
practicing personal hygiene
21
22
Practicing Personal Hygiene
Video https://youtu.be/IisgnbMfKvI
23
Practicing Personal Hygiene
24
Practicing Personal Hygiene: Additional Hand Care
Tips
Fingernails should be kept short, filed and clean
False fingernails should not be worn
Nail polish should not be worn
Cuts or wounds on the hands or wrist must be completely covered
with an impermeable cover before also putting on disposable gloves
25
Practicing Personal Hygiene: Using Gloves
Wash hands well before putting on gloves when starting a new task
Select the correct glove size
Avoid touching the glove as much as possible. Hold gloves by their edge
Check for rips or tears once on
Never blow into gloves or roll them to make them easier when putting on
Demo: https://www.youtube.com/watch?v=DzqmgUfEVoM
Practicing Personal Hygiene
Never handle ready to eat food with bare hands especially when
they are unwashed.
Avoid actions which can contaminate food such as wiping or
touching the nose, touching contaminated wounds or spitting
Never wash hands in sinks designated for food preparation,
dishwashing or utility services
26
Practicing Personal Hygiene
Tie hair back before preparing food. Consider beard restraints for containing facial hair.
Avoid false lashes, and other types of jewelry or hair accessories which could fall off and
pose a physical contaminant risk.
Remove aprons when leaving food prep areas.
Avoid wiping hands on apron.
27
28
29
30
Cleaning removes germs, dirt, and impurities from surfaces or objects. Cleaning works by using soap
(or detergent) and water to physically remove germs from surfaces. This process does not necessarily kill
germs, but by removing them, it lowers their numbers and the risk of spreading infection.
Disinfecting works by using chemicals to kill germs on surfaces or objects. This process does not
necessarily clean dirty surfaces or remove germs, but by killing germs on a surface after cleaning, it can
further lower the risk of spreading infection.
Sanitizing works by either cleaning or disinfecting surfaces or objects to lower the risk of spreading
infection by lowering the number of germs on surfaces or objects to a safe level, as judged by public
health standards or requirements.
Cleaning and Sanitizing
31
Cleaning and Sanitizing
Soaps are made from natural ingredients, such as plant oils
(coconut, vegetable, palm, pine) or acids derived from animal fat.
Detergents, on the other hand, are synthetic & contain man-made
derivatives
32
Cleaning and Sanitizing
Surfactant particles are made up of molecules that aid in cleaning by reducing water’s surface
tension and improving water’s ability to spread evenly. Surface tension is generated by water
molecules attraction to each other and prevents water alone from being able to wash away dirt
well.
The tail end attaches readily to fats (hydrophobic) tail and the hydrophilic head likes polar molecules
such as water.
33
Cleaning and Sanitizing
34
Cleaning and Sanitizing
Most cleaning products today are
detergents. One of the biggest reasons for
this is the many conditions soap needs to
work well.
35
36
37
Cleaning and Sanitizing
Rubbing your hands together with the soap and water also physically
disrupts dirt and makes it easier to wash away.
https://www.britannica.com/video/179625/soap-dirt
38
Controlling Time and Temperature
Bacteria need FAT TOM to grow:
F-food T-time
A- acidity O-oxygen
T- temperature M-moisture
39
Controlling Time and Temperature
Temperature Danger Zone: 41°F (5°C) and 135°F (57°C).
Bacteria grows especially well between 70°F (21°C) - 125°F (52°C).
40
Controlling Time and Temperature
TCS foods must:
be held and stored at the correct temperature
be cooked well enough (or reheated) to kill pathogens
be cooled correctly
41
42
Purchasing From Approved Reputable Suppliers
Unless planning to cook them, fresh fruit should be free of bruises or
spots
Fresh seafood should have a mild scent or no scent at all. It should
not smell fishy, sour or ammonia-like
Fresh fish should have clear and shiny eyes, with firm flesh and bright
red gills, with no odor
Fresh conch meat is white to off white with tinges of pink or orange.
Leg movement should be evident when buying crabs or lobsters
43
44
45
Purchasing From Approved Reputable Suppliers
Ensure that seafood packaging is not torn, or open or crushed on
it’s edges
Avoid packaged meat with signs of frost or ice crystals
Frozen packaged meats should not be pliable.
46
47
Purchasing From Approved Reputable Suppliers
Approved, reputable suppliers have been inspected and are able to
produce the relevant records
Records such as processing records, inspection reports,
certificates and licenses should be available upon request
48
49
Thanks!
Any questions?
THE DEPARTMENT OF MARINE RESOURCES
Sanitation Control
Procedures
[SCPs]
DAY 2: SCPs & GMPs, SOPs, SSOP VS HACCP documents
Spotting Unsafe Conditions in the Field
51
Strong prerequisite programs are
necessary to ensure that
environmental and operational
conditions
are conducive to safe food processing
Prerequisite Programs
Good Manufacturing Practices (GMPs)
are the basis for determining if
processing methods are safe and
food is being processed under
sanitary conditions. They outline
the minimum standards that a
vessel needs to meet with respect
to the crew, the vessel, the
equipment, etc.
52
Sanitation Control Procedures (SCPs)
are used by food processing firms
to meet the requirements in the
GMPs. SCPs are an effective
means to control potential food
safety hazards that might be
associated with the processing
environment and with employee
practices.
SCPs and Hazards
HAZARD
A biological, chemical or physical agent that is reasonably
likely to cause illness or injury in the absence of appropriate
controls. [HINT: SCPs & GMPs 😉]
Hazards present unacceptable risk to the end consumer
53
54
Strong Prerequisite programs address
most biological hazards
55
SCPs
Address concerns before
seafood processing begins.
SCPs and SSOPs address
quality concerns with the
product
HACCP
Addresses concerns that
arise during seafood
processing which may
cause illness or injury
HACCP controls address
specific hazards in the
product and processing
steps.
56
HACCP VS SCPs
HACCP VS SCPs
57
Hand washing should be a general employee practice and is not
specifically related to any product or processing step.
Routine cleaning of food contact surfaces is likewise not specifically
related to a single product or a specific processing step.
Freezing the product after processing is considered a processing
step and should be addressed in the HACCP plan
58
HACCP or SCP?
Hazard Control Type of Control
Control
Program
Histamine Time and temperature controls for fish Product specific HACCP
Pathogen survival Time and temperature controls for smoking fish Processing step HACCP
Contamination with
pathogens
Washing hands before touching product Employee Practice SCP
Contamination with
pathogens
Limiting employee movement between raw and
cooked areas
Employee Practice SCP
Histamine Time and temperature controls for fish Product specific HACCP
Contamination with
pathogens
Cleaning and sanitizing food contact surfaces Plant environment
SCP
Chemical Contamination
Using only food grade grease
Plant environment SCP
59
Each licensed facility describes its
SCPs in a Sanitation Standard
Operating Procedures [SSOP]
document
THE DEPARTMENT OF MARINE RESOURCES
Standard Sanitation
Operation Procedures
[SSOP]
Twelve (12) Areas of Concern
61
Safety of water
Condition and cleanliness of food contact surfaces
Prevention of cross contamination
Maintenance of hand washing, hand sanitizing and toilet facilities
Protection from adulterants
Labeling, storage and use of toxic compounds
Employee health
Exclusion of pests
Disposal procedures for waste materials and debris
Responsibilities of outside contractors
Condition and cleanliness of vehicles used to transport product
Condition and cleanliness of raw material (packaging) storage areas.
SSOP Document
For each area of concern, a goal is stated. This field explains what
the procedures are expected to achieve.
The method describes the means in which a stated goal is met,
while the responsibility identifies who is responsible for executing
the procedures as well as the frequency in which they are to be
carried out
All records generated by the application of the SSOP should be
kept for at least two years
62
SSOP Document
Monitoring involves having a second party confirm that the task is being
completed as described in the SSOP. The monitor should record their
observations as they are observed.
Corrective Actions are pre-determined actions made when monitoring or
verification activities indicate that a stated goal is not being met.
Verification activities are all those that a company uses to prove that the
stated goal is being met. This field should also include who is responsible
for carrying out these activities and how often they are to be executed
63
Safety of Water
To ensure the safety of water used in processing
or manufacturing of ice
Key concerns:
Source and treatment of water that comes into contact with food or
food contact surfaces
Water used in the manufacture of ice
Cross connections between potable and non-potable water supplies
64
Safety of Water: Possible Controls
Have potable and non-potable outlets clearly
marked
Testing water quality regularly
65
Condition and Cleanliness of Food Contact Surfaces
To ensure the condition and cleanliness of food
contact surfaces, food process areas and
equipment.
Key concerns:
Design, workmanship, maintenance, and materials used for food
contact surfaces
Routine scheduled cleaning and sanitizing of food contact surfaces
including gloves and outer garments
66
Condition and Cleanliness of Food Contact Surfaces: Possible
Controls
67
Clean food contact surfaces with an approved
cleaning and sanitizing agent
68
Condition and Cleanliness of Food Contact Surfaces: Possible
Controls
69
70
71
2-22.
Cleaning aids which retain water, such as sponges,
wiping cloths and mops should not be used for routine
cleaning in processing plants.
Prevention of Cross Contamination
To prevent cross-contamination from insanitary objects to
food, food-packing materials and other food contact
surfaces including utensils, gloves & outer garments and
raw product to cooked product or ready to eat products
Key concerns:
Employee hygiene practices
Employee food handling practices
Plant design and layout
72
Prevention of Cross Contamination: Possible Controls
Physical separation of raw and ready to-eat
products
Employing color coded utensils for different
food products or for use in different areas
Providing adequate employee training
73
Maintenance of Hand Washing, Hand Sanitizing and Toilet Facilities
To support a necessary hand washing program to
prevent the spread of filth and potential
pathogenic organisms about the processing area
or to foods
Key concerns:
Maintenance and location of hand washing, hand sanitizing, and toilet
facilities
Maintenance of adequate sewage disposal system
74
Maintenance of Hand Washing, Hand Sanitizing and Toilet Facilities:
Possible Control Procedures
Regular checking and restocking of facilities by
staff
75
Protection from Adulterants
To ensure that the food, food packaging material
and food contact surfaces are protected from
microbiological, chemical and physical
contaminants such as lubricants, fuel, pesticides,
cleaning compounds, sanitizing agents,
condensate and floor splash
Key concerns:
Protection of food, food contact surfaces, and food packaging material
from contaminants.
76
Protection from Adulterants: Possible Control Procedures
Ensuring that condensate does not
accidentally drip onto foods
77
Labeling, Storage and Use of Toxic Compounds
To ensure that the labelling, storage and use of toxic
compounds are adequate to protect food from
contamination
Key concerns:
Labeling, proper storage and use of toxic compounds are adequate to protect food from
contamination.
Containers show the name of the chemical compounds or solutions.
Containers show the instruction for the proper use of the contents.
Access to storage areas is limited.
Food grade and non-food grade chemicals are segregated.
Toxic compounds are kept away from food equipment, utensils and other food contact items.
78
Labeling, Storage and Use of Toxic Compounds: Possible Control
Procedures
Discarding improperly labelled containers
Restricting access to storage areas
79
Employee Health
The primary goal of monitoring employee health is to
control conditions that could result in the microbiological
contamination of food, food packaging materials, and food
contact surfaces
Key concerns:
The controls necessary to ensure that employee health conditions do not cause food contamination
The management of persons who are diagnosed with or have symptoms of an illness, wound or other
affliction that could be a source of microbial contamination.
Be aware of conditions that that might cause contamination
80
Employee Health: Possible Controls
Relocate sick employees to other areas until
their illness has passed
Ensure that staff are properly trained in safe
food handling
81
Exclusion of Pests
To ensure that pests are excluded from the plant
to the extent possible and to ensure that
procedures to prevent infestation are followed.
Key concerns:
Foodborne illnesses that may be passed on by pests are numerous.
Pests must not be present in the food processing facility.
Flies and cockroaches may transmit salmonella, staphylococcus, etc.
Rodents are sources of salmonella and parasites.
Birds are hosts for a variety of pathogens such as salmonella and listeria.
Shelters and attractants need to be eliminated.
82
Exclusion of Pests: Possible Controls
Installing air curtains
Hanging fly paper
Contracting a commercial exterminator
83
84
Disposal Procedures for Waste Materials and Debris
To implement proper disposal procedures for
waste materials and debris
Key Concerns:
Suitable provisions must be made for the removal and storage of waste
Waste must not be allowed to accumulate in food handling, food storage and
other working areas and the adjoining environment
Waste storage areas must be kept appropriately clean
That waste of any kind must not come into contact with food.
How and how often it is disposed of.
Disposal Procedures for Waste Materials and Debris: Possible
Controls
Discard waste daily
Keep garbage receptacles covered
85
Responsibilities of Outside Contractors
To ensure that the responsibilities of outside
contractors are documented and detailed
Key Concerns:
Are there persons or companies outside of the processing plant or freezer vessel
who have been hired to perform any of the activities related to the sanitation
program?
How and by whom, the outside contractors are monitored
How the performance of the contractor is monitored
86
Responsibilities of Outside Contractors: Possible Controls
Keep records of the contract and all reciepts
following service by the outside contractor
Inspect after work has been completed
87
Condition and Cleanliness of Vehicles Used to Transport Product
To ensure that the condition and cleanliness of
vehicles used to transport product.
Key Concerns:
Food must be adequately protected from contaminants (including dust and fumes) during
transport.
The type of containers required depends on the nature and the conditions under which it has
to be transported.
Containers should not contaminate the food.
Containers should be easily and effectively cleaned.
Frozen product should not be allowed to thaw during transport.
Vehicles should be inspected by the processor prior to loading to ensure that they are free
from contamination and suitable for the transportation of food.
There should be a program in place to demonstrate the adequacy of cleaning and sanitizing.
88
Condition and Cleanliness of Vehicles Used to Transport Product:
Possible Controls
Sanitize vehicles before and after transporting
product
89
Condition and Cleanliness of Raw Material (Packaging) and Storage
Areas
To ensure the condition and cleanliness of raw
material (packaging) storage areas
Key concerns:
protected from various microbiological, chemical and physical contaminants,
such as lubricants, fuel, pesticides, cleaning compounds and sanitizing agents.
90
Condition and Cleanliness of Raw Material (Packaging) Storage
Areas: Possible Controls
Rotate raw material on a first in first out basis
Clean and sanitize storage area periodically
Store materials on shelves at least 6in. off the
floor and 6in. away from the ceiling
Wrap packaging in plastic
91
92
Thanks!
Any questions?
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DMR SCP Workshop 070720 - Day 1 and Day 2

  • 1. THE DEPARTMENT OF MARINE RESOURCES Sanitation Controls Procedures [SCPs] Workshop 7-8 July 2020 DMR Conference Room
  • 2. Table of Contents Day One Definitions General Concepts in Keeping Food Safe Spotting Unsafe Conditions in the Home & Office 2
  • 3. Table of Contents Day Two SCPs & GMPs SOPs, SSOP VS. HACCP Documents Spotting Unsafe Conditions in the Field Field Visit 3
  • 4. Sanitation and Keeping Food Safe Proper sanitation is necessary to control potential food safety hazards that might be associated with the environment in which food is prepared as well as preparation or cooking methods. 4
  • 5. Sanitation and Keeping Food Safe Keeping food safe is especially important to the following populations: Elderly Young children Pregnant women Those with compromised immune systems 5
  • 6. Sanitation and Keeping Food Safe Preventing Cross Contamination Practicing Personal Hygiene Cleaning and Sanitizing Controlling Time and Temperature Purchasing from Approved Reputable Suppliers 6
  • 7. Sanitation and Keeping Food Safe TCS Foods are those which require time and temperature controls to ensure safety and avoid contamination. Ready-to-Eat (RTE) Foods are those foods that are normally eaten in their raw state or any other food, including a processed food, for which it is reasonably foreseeable that the food will be eaten without further processing that would significantly minimize biological hazards. 7
  • 8. 8
  • 9. Sanitation and Keeping Food Safe Cross-contamination refers to the transfer of biological or chemical contaminants to food products from raw foods, food handlers, or the food handling environment. Food Contact Surfaces are those that contact human food and those surfaces from which drainage onto the food or onto surfaces that contact the food ordinarily occurs during the normal course of operation 9
  • 10. Biological Viruses Bacteria Fungi Parasites Yeasts Molds Chemical Allergens Toxins Pesticides Sanitizing Agents Physical are extraneous and not normally found in food which may cause physical injury. Glass or metal fragments, fish bones 10 Preventing Cross Contamination: Types of Hazards
  • 11. Preventing Cross Contamination: Reducing Hazards When choosing material or equipment, choose those that are smooth and durable to make cleaning easier. Avoid wooden utensils or cutting boards. Choose stainless steel or silicone Cleaning aids which retain water, such as sponges, wiping cloths and mops should be avoided Using only food safe chemical cleaning aids Keeping cleaning or maintenance chemicals stored away from food and food preparation areas. Never store above food or food contact surfaces Larger pieces of equipment should ideally be floor mounted to allow for cleaning underneath 11
  • 12. 12
  • 13. 13
  • 14. 14
  • 15. Preventing Cross Contamination: Reducing Hazards Separation of raw and cooked or ready-to-eat foods Separation of the utensils used for each (i.e. using only red utensils for raw foods and green utensils for ready-to-eat foods and keeping them physically separated when in use) Separation of contaminated surfaces and ready-to-eat foods Washing hands when switching from preparing raw or uncooked foods to handling ready-to- eat, cooked food items 15
  • 16. Controlling Cross Contamination: Pest Prevention They are vectors of diseases foodborne illness Pests can also aid in spreading contamination by damaging food, supplies or food processing areas themselves 16
  • 17. Controlling Cross Contamination: Pest Prevention Eliminate sources of food, water and shelter Eliminate access to home and food handling areas Contract a licensed pest control operator 17
  • 18. 18
  • 19. 19
  • 20. 20
  • 21. Practicing Personal Hygiene Handwashing is an important part of practicing personal hygiene 21
  • 22. 22 Practicing Personal Hygiene Video https://youtu.be/IisgnbMfKvI
  • 24. 24 Practicing Personal Hygiene: Additional Hand Care Tips Fingernails should be kept short, filed and clean False fingernails should not be worn Nail polish should not be worn Cuts or wounds on the hands or wrist must be completely covered with an impermeable cover before also putting on disposable gloves
  • 25. 25 Practicing Personal Hygiene: Using Gloves Wash hands well before putting on gloves when starting a new task Select the correct glove size Avoid touching the glove as much as possible. Hold gloves by their edge Check for rips or tears once on Never blow into gloves or roll them to make them easier when putting on Demo: https://www.youtube.com/watch?v=DzqmgUfEVoM
  • 26. Practicing Personal Hygiene Never handle ready to eat food with bare hands especially when they are unwashed. Avoid actions which can contaminate food such as wiping or touching the nose, touching contaminated wounds or spitting Never wash hands in sinks designated for food preparation, dishwashing or utility services 26
  • 27. Practicing Personal Hygiene Tie hair back before preparing food. Consider beard restraints for containing facial hair. Avoid false lashes, and other types of jewelry or hair accessories which could fall off and pose a physical contaminant risk. Remove aprons when leaving food prep areas. Avoid wiping hands on apron. 27
  • 28. 28
  • 29. 29
  • 30. 30 Cleaning removes germs, dirt, and impurities from surfaces or objects. Cleaning works by using soap (or detergent) and water to physically remove germs from surfaces. This process does not necessarily kill germs, but by removing them, it lowers their numbers and the risk of spreading infection. Disinfecting works by using chemicals to kill germs on surfaces or objects. This process does not necessarily clean dirty surfaces or remove germs, but by killing germs on a surface after cleaning, it can further lower the risk of spreading infection. Sanitizing works by either cleaning or disinfecting surfaces or objects to lower the risk of spreading infection by lowering the number of germs on surfaces or objects to a safe level, as judged by public health standards or requirements. Cleaning and Sanitizing
  • 31. 31
  • 32. Cleaning and Sanitizing Soaps are made from natural ingredients, such as plant oils (coconut, vegetable, palm, pine) or acids derived from animal fat. Detergents, on the other hand, are synthetic & contain man-made derivatives 32
  • 33. Cleaning and Sanitizing Surfactant particles are made up of molecules that aid in cleaning by reducing water’s surface tension and improving water’s ability to spread evenly. Surface tension is generated by water molecules attraction to each other and prevents water alone from being able to wash away dirt well. The tail end attaches readily to fats (hydrophobic) tail and the hydrophilic head likes polar molecules such as water. 33
  • 35. Cleaning and Sanitizing Most cleaning products today are detergents. One of the biggest reasons for this is the many conditions soap needs to work well. 35
  • 36. 36
  • 37. 37
  • 38. Cleaning and Sanitizing Rubbing your hands together with the soap and water also physically disrupts dirt and makes it easier to wash away. https://www.britannica.com/video/179625/soap-dirt 38
  • 39. Controlling Time and Temperature Bacteria need FAT TOM to grow: F-food T-time A- acidity O-oxygen T- temperature M-moisture 39
  • 40. Controlling Time and Temperature Temperature Danger Zone: 41°F (5°C) and 135°F (57°C). Bacteria grows especially well between 70°F (21°C) - 125°F (52°C). 40
  • 41. Controlling Time and Temperature TCS foods must: be held and stored at the correct temperature be cooked well enough (or reheated) to kill pathogens be cooled correctly 41
  • 42. 42 Purchasing From Approved Reputable Suppliers Unless planning to cook them, fresh fruit should be free of bruises or spots Fresh seafood should have a mild scent or no scent at all. It should not smell fishy, sour or ammonia-like Fresh fish should have clear and shiny eyes, with firm flesh and bright red gills, with no odor Fresh conch meat is white to off white with tinges of pink or orange. Leg movement should be evident when buying crabs or lobsters
  • 43. 43
  • 44. 44
  • 45. 45
  • 46. Purchasing From Approved Reputable Suppliers Ensure that seafood packaging is not torn, or open or crushed on it’s edges Avoid packaged meat with signs of frost or ice crystals Frozen packaged meats should not be pliable. 46
  • 47. 47
  • 48. Purchasing From Approved Reputable Suppliers Approved, reputable suppliers have been inspected and are able to produce the relevant records Records such as processing records, inspection reports, certificates and licenses should be available upon request 48
  • 50. THE DEPARTMENT OF MARINE RESOURCES Sanitation Control Procedures [SCPs] DAY 2: SCPs & GMPs, SOPs, SSOP VS HACCP documents Spotting Unsafe Conditions in the Field
  • 51. 51 Strong prerequisite programs are necessary to ensure that environmental and operational conditions are conducive to safe food processing
  • 52. Prerequisite Programs Good Manufacturing Practices (GMPs) are the basis for determining if processing methods are safe and food is being processed under sanitary conditions. They outline the minimum standards that a vessel needs to meet with respect to the crew, the vessel, the equipment, etc. 52 Sanitation Control Procedures (SCPs) are used by food processing firms to meet the requirements in the GMPs. SCPs are an effective means to control potential food safety hazards that might be associated with the processing environment and with employee practices.
  • 53. SCPs and Hazards HAZARD A biological, chemical or physical agent that is reasonably likely to cause illness or injury in the absence of appropriate controls. [HINT: SCPs & GMPs 😉] Hazards present unacceptable risk to the end consumer 53
  • 54. 54 Strong Prerequisite programs address most biological hazards
  • 55. 55
  • 56. SCPs Address concerns before seafood processing begins. SCPs and SSOPs address quality concerns with the product HACCP Addresses concerns that arise during seafood processing which may cause illness or injury HACCP controls address specific hazards in the product and processing steps. 56 HACCP VS SCPs
  • 57. HACCP VS SCPs 57 Hand washing should be a general employee practice and is not specifically related to any product or processing step. Routine cleaning of food contact surfaces is likewise not specifically related to a single product or a specific processing step. Freezing the product after processing is considered a processing step and should be addressed in the HACCP plan
  • 58. 58 HACCP or SCP? Hazard Control Type of Control Control Program Histamine Time and temperature controls for fish Product specific HACCP Pathogen survival Time and temperature controls for smoking fish Processing step HACCP Contamination with pathogens Washing hands before touching product Employee Practice SCP Contamination with pathogens Limiting employee movement between raw and cooked areas Employee Practice SCP Histamine Time and temperature controls for fish Product specific HACCP Contamination with pathogens Cleaning and sanitizing food contact surfaces Plant environment SCP Chemical Contamination Using only food grade grease Plant environment SCP
  • 59. 59 Each licensed facility describes its SCPs in a Sanitation Standard Operating Procedures [SSOP] document
  • 60. THE DEPARTMENT OF MARINE RESOURCES Standard Sanitation Operation Procedures [SSOP]
  • 61. Twelve (12) Areas of Concern 61 Safety of water Condition and cleanliness of food contact surfaces Prevention of cross contamination Maintenance of hand washing, hand sanitizing and toilet facilities Protection from adulterants Labeling, storage and use of toxic compounds Employee health Exclusion of pests Disposal procedures for waste materials and debris Responsibilities of outside contractors Condition and cleanliness of vehicles used to transport product Condition and cleanliness of raw material (packaging) storage areas.
  • 62. SSOP Document For each area of concern, a goal is stated. This field explains what the procedures are expected to achieve. The method describes the means in which a stated goal is met, while the responsibility identifies who is responsible for executing the procedures as well as the frequency in which they are to be carried out All records generated by the application of the SSOP should be kept for at least two years 62
  • 63. SSOP Document Monitoring involves having a second party confirm that the task is being completed as described in the SSOP. The monitor should record their observations as they are observed. Corrective Actions are pre-determined actions made when monitoring or verification activities indicate that a stated goal is not being met. Verification activities are all those that a company uses to prove that the stated goal is being met. This field should also include who is responsible for carrying out these activities and how often they are to be executed 63
  • 64. Safety of Water To ensure the safety of water used in processing or manufacturing of ice Key concerns: Source and treatment of water that comes into contact with food or food contact surfaces Water used in the manufacture of ice Cross connections between potable and non-potable water supplies 64
  • 65. Safety of Water: Possible Controls Have potable and non-potable outlets clearly marked Testing water quality regularly 65
  • 66. Condition and Cleanliness of Food Contact Surfaces To ensure the condition and cleanliness of food contact surfaces, food process areas and equipment. Key concerns: Design, workmanship, maintenance, and materials used for food contact surfaces Routine scheduled cleaning and sanitizing of food contact surfaces including gloves and outer garments 66
  • 67. Condition and Cleanliness of Food Contact Surfaces: Possible Controls 67 Clean food contact surfaces with an approved cleaning and sanitizing agent
  • 68. 68
  • 69. Condition and Cleanliness of Food Contact Surfaces: Possible Controls 69
  • 70. 70
  • 71. 71 2-22. Cleaning aids which retain water, such as sponges, wiping cloths and mops should not be used for routine cleaning in processing plants.
  • 72. Prevention of Cross Contamination To prevent cross-contamination from insanitary objects to food, food-packing materials and other food contact surfaces including utensils, gloves & outer garments and raw product to cooked product or ready to eat products Key concerns: Employee hygiene practices Employee food handling practices Plant design and layout 72
  • 73. Prevention of Cross Contamination: Possible Controls Physical separation of raw and ready to-eat products Employing color coded utensils for different food products or for use in different areas Providing adequate employee training 73
  • 74. Maintenance of Hand Washing, Hand Sanitizing and Toilet Facilities To support a necessary hand washing program to prevent the spread of filth and potential pathogenic organisms about the processing area or to foods Key concerns: Maintenance and location of hand washing, hand sanitizing, and toilet facilities Maintenance of adequate sewage disposal system 74
  • 75. Maintenance of Hand Washing, Hand Sanitizing and Toilet Facilities: Possible Control Procedures Regular checking and restocking of facilities by staff 75
  • 76. Protection from Adulterants To ensure that the food, food packaging material and food contact surfaces are protected from microbiological, chemical and physical contaminants such as lubricants, fuel, pesticides, cleaning compounds, sanitizing agents, condensate and floor splash Key concerns: Protection of food, food contact surfaces, and food packaging material from contaminants. 76
  • 77. Protection from Adulterants: Possible Control Procedures Ensuring that condensate does not accidentally drip onto foods 77
  • 78. Labeling, Storage and Use of Toxic Compounds To ensure that the labelling, storage and use of toxic compounds are adequate to protect food from contamination Key concerns: Labeling, proper storage and use of toxic compounds are adequate to protect food from contamination. Containers show the name of the chemical compounds or solutions. Containers show the instruction for the proper use of the contents. Access to storage areas is limited. Food grade and non-food grade chemicals are segregated. Toxic compounds are kept away from food equipment, utensils and other food contact items. 78
  • 79. Labeling, Storage and Use of Toxic Compounds: Possible Control Procedures Discarding improperly labelled containers Restricting access to storage areas 79
  • 80. Employee Health The primary goal of monitoring employee health is to control conditions that could result in the microbiological contamination of food, food packaging materials, and food contact surfaces Key concerns: The controls necessary to ensure that employee health conditions do not cause food contamination The management of persons who are diagnosed with or have symptoms of an illness, wound or other affliction that could be a source of microbial contamination. Be aware of conditions that that might cause contamination 80
  • 81. Employee Health: Possible Controls Relocate sick employees to other areas until their illness has passed Ensure that staff are properly trained in safe food handling 81
  • 82. Exclusion of Pests To ensure that pests are excluded from the plant to the extent possible and to ensure that procedures to prevent infestation are followed. Key concerns: Foodborne illnesses that may be passed on by pests are numerous. Pests must not be present in the food processing facility. Flies and cockroaches may transmit salmonella, staphylococcus, etc. Rodents are sources of salmonella and parasites. Birds are hosts for a variety of pathogens such as salmonella and listeria. Shelters and attractants need to be eliminated. 82
  • 83. Exclusion of Pests: Possible Controls Installing air curtains Hanging fly paper Contracting a commercial exterminator 83
  • 84. 84 Disposal Procedures for Waste Materials and Debris To implement proper disposal procedures for waste materials and debris Key Concerns: Suitable provisions must be made for the removal and storage of waste Waste must not be allowed to accumulate in food handling, food storage and other working areas and the adjoining environment Waste storage areas must be kept appropriately clean That waste of any kind must not come into contact with food. How and how often it is disposed of.
  • 85. Disposal Procedures for Waste Materials and Debris: Possible Controls Discard waste daily Keep garbage receptacles covered 85
  • 86. Responsibilities of Outside Contractors To ensure that the responsibilities of outside contractors are documented and detailed Key Concerns: Are there persons or companies outside of the processing plant or freezer vessel who have been hired to perform any of the activities related to the sanitation program? How and by whom, the outside contractors are monitored How the performance of the contractor is monitored 86
  • 87. Responsibilities of Outside Contractors: Possible Controls Keep records of the contract and all reciepts following service by the outside contractor Inspect after work has been completed 87
  • 88. Condition and Cleanliness of Vehicles Used to Transport Product To ensure that the condition and cleanliness of vehicles used to transport product. Key Concerns: Food must be adequately protected from contaminants (including dust and fumes) during transport. The type of containers required depends on the nature and the conditions under which it has to be transported. Containers should not contaminate the food. Containers should be easily and effectively cleaned. Frozen product should not be allowed to thaw during transport. Vehicles should be inspected by the processor prior to loading to ensure that they are free from contamination and suitable for the transportation of food. There should be a program in place to demonstrate the adequacy of cleaning and sanitizing. 88
  • 89. Condition and Cleanliness of Vehicles Used to Transport Product: Possible Controls Sanitize vehicles before and after transporting product 89
  • 90. Condition and Cleanliness of Raw Material (Packaging) and Storage Areas To ensure the condition and cleanliness of raw material (packaging) storage areas Key concerns: protected from various microbiological, chemical and physical contaminants, such as lubricants, fuel, pesticides, cleaning compounds and sanitizing agents. 90
  • 91. Condition and Cleanliness of Raw Material (Packaging) Storage Areas: Possible Controls Rotate raw material on a first in first out basis Clean and sanitize storage area periodically Store materials on shelves at least 6in. off the floor and 6in. away from the ceiling Wrap packaging in plastic 91
  • 93. Presentation design This presentation uses the following typographies: Titles: Averia Libre Body copy: Work Sans Download for free at: https://www.1001fonts.com/averia-libre-font.html https://www.fontsquirrel.com/fonts/work-sans You don’t need to keep this slide in your presentation. It’s only here to serve you as a design guide if you need to create new slides or download the fonts to edit the presentation in PowerPoint® 93
  • 94. SlidesCarnival icons are editable shapes. This means that you can: Resize them without losing quality. Change fill color and opacity. Change line color, width and style. Isn’t that nice? :) Examples: 94 Find more icons at slidescarnival.com/extra- free-resources-icons-and-maps
  • 96. ✋👆👉👍👤👦👧👨👩👪💃🏃💑❤😂😉 😋😒😭👶😸🐟🍒🍔💣📌📖🔨🎃🎈🎨🏈 🏰🌏🔌🔑 and many more... 😉 96 You can also use any emoji as an icon! And of course it resizes without losing quality. How? Follow Google instructions https://twitter.com/googledocs/status/730087240156643328

Editor's Notes

  1. Sanitation is necessary in order to avoid illness or physical injury that could be caused by food safety hazards I will give a more in-depth explanation of hazards shortly, but whether they are associated with the environment in which food is prepared, the way in which food is prepared or the food handler themselves, sanitation controls help keep food safe
  2. Keeping food safe has obvious implications for public health, but even more so to the following populations: Compromised immune system: recent organ transplant, cancer patients, etc. They are more susceptible to contracting foodborne illnesses and also more likely suffer from additional health complications as a result of the illness than someone with a more robust immune system
  3. 5 Main Ways to Keep Food Sanitary, they involve:
  4. Foodborne illness often results when TCS foods are left at a temperature that is ideal for the growth of pathogens for too long. Ask for examples of TCS and RTE Foods. Foods that are both TCS and RTE: conch salad, coleslaw, potato salad,
  5. The most common way in which cross-contamination occurs is when pathogenic bacteria or viruses are transferred to ready-to-eat foods Ask for examples of Food Contact Surfaces: utensils, knives, tables, cutting boards, conveyor belts, ice makers, ice storage bins, gloves, aprons NOT the floor, NOT the wall
  6. 10AM As promised, I will explain Types of Hazards more. There are 3 kinds. Some consider biotoxins as a chemical hazard while some consider it as a biological contaminant. HACCP considers biotoxins to be chemical hazards. Fish bones could also be considered as a physical hazard because they can cause physical injury. Imagine if you went to the Fry and ordered conch fritters, and your mouth got cut because a piece of the fin was cooked in with the fritters. The fin (operculum) is considered a physical hazard even though it is a part of the conch, it is not normally consumed, especially in that dish
  7. RE the environment: The advantage in choosing smooth materials is that they are easier to clean and they have no grooves in which bacteria can shelter and grow. The advantage in choosing a durable material is that they won’t break apart and produce physical hazards, or become worn and once again create grooves which are harder to clean and can shelter pathogens. Normally stay away from wooden cutting boards because knife grooves are easily formed over long-time use, but this one came equipped Avoid cleaning aids which hold absorb longer because they take longer to dry and so support microbial growth very well, especially well in a warm environment like your kitchen. They are also hard to clean
  8. Normally stay away from wooden cutting boards because knife grooves are easily formed over long-time use, but this one came equipped
  9. RE preparation methods Separation of raw and cooked/RTE foods Never store raw meat above ready to eat food or food contact surfaces
  10. Also address cross contamination by excluding pests from your area. Directly spread disease because they are carriers Damaging food, supplies and FPA and encouraging contamination by destroying fruit skin, esp. fruit flies leaving it more vulnerable to microbial contamination allowing exposure, possible contamination by dust, etc. Economic damage because you must replace supplies, equipment
  11. Don’t make them comfortable. Deny pests sources food, water and shelter by: Keeping garbage receptacles covered and taking out garbage regularly Store food properly and clean up food spills or messes quickly to eliminate reliable sources of food or water Prevent access to home/office/building by: Using and maintaining screens and vents, checking and repairing cracks in walls, windows, etc. will eliminate opportunities for pests to access to shelter or food handling areas e.g. kitchens or cafeterias. Using traps, repellants, or baits also helps prevent access to home or office. Check packages incoming deliveries to ensure that you are not bringing pests into the home or office. Refuse shipments if pests or other signs (e.g. legs, wings) of pests are present If all else fails, It may become necessary to hire a commercial pest control operator. Infestations are notoriously hard to judge because once even minimal signs of pest activity appear, the population has been well established. Some businesses contract with pest control operators to proactively keep pests out. E.g. FSTL on Gladstone Road is regularly visited by Tropical Exterminators
  12. 10:30 Questions? Short 3 minute break
  13. 10:33
  14. Now that we’ve discussed how to wash hands …tell me when you should wash your hands
  15. How do long, ragged or false nails present a hazard? Hard to keep clean and may hold pathogens, may rip gloves, exposing bare hands, may rip gloves and cause physical contaminants (torn glove bits), may chip and present a physical contaminant. Why should nail polish not be worn? May chip and fragments may end up in food Obscures dirt
  16. Because it will cause cross contamination
  17. Handling RTE foods with bare hands is only acceptable when the food will be added to a dish that will be cooked to eliminate pathogens
  18. Remove aprons so as not to expose them to contamination, Don’t wipe hands because aprons because they are presumably soiled and aprons are a food contact surface
  19. Now we will move on to Cleaning and Sanitizing
  20. 11:00 AM Cleaning doesn’t necessarily ‘disinfected’, but rather that surface dirt/grease has been removed Disinfected doesn’t necessarily imply ‘clean’ or that surface dirt has been removed. As a point of interest, some literature distinguishes disinfecting from sanitizing as the killing of microbes, those microbes are not necessarily of public health concern. Sanitizing works by either cleaning or disinfecting to lower the amount of pathogens on a surface or an object. By definition, pathogens are of public health concern. E.g. E. coli as a pathogen as opposed to Sacromyces cervisea which doesn’t cause infection (used to ferment beer).
  21. The most relevant way for me to explain cleaning vs. sanitizing is using conch. Conch slime is naturally found on fresh conch meat, but washing it away is extremely important since the slime typically carries a pathogenic organism. There’s a prize for anyone who can tell me the name of the organism found in conch slime.
  22. Both contain compounds called surface active agents or surfactants
  23. When a detergent or soap is added to water, the interaction between the water molecules is weakened. There isn't as much surface tension which helps soaps and detergents form a link with and attach to dirt and grease, break it up and let water wash it away. Soap and detergent molecules are polar meaning that they are positively charged at one end and negatively charged at the other end.
  24. Most cleaning products today are detergents. One of the biggest reasons for this is the way soap reacts with water. While detergents are free-rinsing (meaning they don’t leave a residue), soap needs a clear water wash after application or it will leave a film. Hard water is the enemy of soap. In hard water conditions, soaps form scum. Soap scum affects more than just cleanliness; it can deteriorate fabrics and eventually ruin clothing or other surfaces. Conversely, detergents can work in any level of water hardness since they react less to the many minerals in hard water. Finally, soaps need warm water to work at all. Detergents, on the other hand, can be built to perform well in any water temperature. This versatility enables detergents to be used in everything from shampoo to laundry liquid to hand cleansers and stain removers.
  25. Most cleaning products today are detergents. One of the biggest reasons for this is the way soap reacts with water. While detergents are free-rinsing (meaning they don’t leave a residue), soap needs a clear water wash after application or it will leave a film. Hard water is the enemy of soap. In hard water conditions, soaps form scum instead of producing a lather. Soap scum affects more than just cleanliness; it can deteriorate fabrics and eventually ruin clothing or other surfaces. Conversely, detergents can work in any level of water hardness since they react less to the many minerals in hard water. Finally, soaps need warm water to work at all. Detergents, on the other hand, can be built to perform well in any water temperature. This versatility enables detergents to be used in everything from shampoo to laundry liquid to hand cleansers and stain removers.
  26. Most cleaning products today are detergents. One of the biggest reasons for this is the way soap reacts with water. While detergents are free-rinsing (meaning they don’t leave a residue), soap needs a clear water wash after application or it will leave a film. Hard water is the enemy of soap. In hard water conditions, soaps form scum. Soap scum affects more than just cleanliness; it can deteriorate fabrics and eventually ruin clothing or other surfaces. Conversely, detergents can work in any level of water hardness since they react less to the many minerals in hard water. Finally, soaps need warm water to work at all. Detergents, on the other hand, can be built to perform well in any water temperature. This versatility enables detergents to be used in everything from shampoo to laundry liquid to hand cleansers and stain removers.
  27. However, the easiest of these parameters to control would be time and temperature If you remember, moisture is a big reason why sponges shouldn’t be used in your kitchen
  28. 11:30 AM Keep food safe by holding food outside of the range and/or by controlling the amount of time the food spends in this range: ideally, food should be refrigerated within TWO hours. Keep hot foods hot (over 140°F) and cold foods cold (40°F or under)
  29. LET FOOD COOL before refrigerating: When freshly prepared soup is immediately placed in the fridge, it will cool quickly and unevenly. The pot of soup functions almost as a frozen pond; where the top or outermost layers of soup cools quickest and insulates the soup in the middle of the pot. The soup in the middle of the pot therefore ends up spending a longer time in the temperature danger zone in which pathogens can grow and go on to cause illness. Fried Rice Syndrome: Leftover fried rice is a primary culprit, but other starchy dishes can be affected as well. After the rice is boiled, it is often left at room temperature for more than two hours to cool before frying it with other ingredients. Cooling the rice ensures that the finished fried rice won't get clumpy or become soggy after stir frying, however, it is often not reheated enough during this process to get rid of the toxins the bacteria have already produced. 
  30. 12PM FINALLY, controlling cross contamination, time and temperature, practicing personal hygiene, and cleaning and sanitizing would all be for naught if we were working with poor quality product in the first place. Let’s discuss… What other considerations can you think of when deciding to buy from a roadside vendor, in particular? Is the fish/seafood stored in coolers? Is ice available? Crabs and lobsters in particular, spoil quickly after death and must be immediately placed on ice Are they exposed to the environment? Absence of shelter means meat is open to flies, dust, etc. Is the vendor located near open sources of contamination e.g. standing water, open garbage receptacles or unchecked vegetation? Are vendors wearing gloves and masks? Are they changing between tasks? Do they eat or drink while serving or preparing food? What kinds of utensils are they using to handle or serve food?
  31. Fresh fish should have clear and shiny eyes, with firm flesh and bright red gills, with no odor
  32. Leg movement should be evident when buying crabs or lobsters
  33. Fresh conch meat is white to off white with tinges of pink or orange.
  34. Frost, ice crystals indicate the packaged has been in storage for a long time, or may mean the package was thawed and refrozen
  35. By law, processing plants and factory vessels must keep records on hand for a minimum of two years
  36. 10:15AM 10-15 minute group guessing activity
  37. 10 minutes to regroup
  38. 10:30 AM
  39. Goal: This field explains what the procedure is expected to achieve
  40. Monitoring: Produces a sanitation record of some sort. Corrective actions:
  41. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  42. Discuss corrective actions
  43. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  44. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  45. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  46. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  47. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Discuss examples you've seen in the field.
  48. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  49. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  50. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  51. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  52. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  53. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  54. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  55. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  56. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  57. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  58. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  59. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  60. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  61. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  62. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  63. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  64. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  65. Why is it important to address this in the SSOP? What controls can be applied to manage this area of concern? Include limits set by regulatory bodies where available. Describe an example you've seen in the field.
  66. 11:30-1: Geneva Visit