FDA stated issues with the Preventive Control Plan as well as with GMPs. With regard to the Food Safety Plant, while the hazard analysis considered pathogen contamination at the cutting and assembling processing steps. it determined that a preventive control was not necessary due to CGMPs/SSOPs and a prior wash step. However, "RTE fresh-cut produce is exposed to the environment during cutting and assembly and does not receive a lethal treatment or otherwise include a control measure (such as a formulation lethal to the pathogen) that would significantly minimize the pathogen. Thus, environmental pathogens are a hazard likely to occur in the absence of preventive controls (i.e., sanitation controls)."
One item stated in the Warning Letter was a bit surprising in that FDA seems to be suggesting a Supplier Preventive Control for the produce. The report stated that the company "did not establish supply-chain controls for pathogens such as L. monocytogenes, pathogenic E. coli, and Salmonella at the receiving step for incoming produce. [The] hazard analysis indicated that pathogens will be controlled at a later wash step. However, [the] produce wash does not effectively destroy pathogens on the whole produce, as indicated by an email on July 20, 2021, from a representative of [the] supplier of (b)(4) sanitizer, which is used in your produce wash." This may be difficult if the company is bringing in raw, unwashed produce.
The facility had a number of GMP issues which would exasperate the situation. Condensation, poor plumbing, inadequate cleaning of equipment (both contact and non-contact surfaces), and poor food handling practices.
https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/onofrios-fresh-cut-inc-618502-01102022
WARNING LETTER
Onofrio's Fresh Cut, Inc.
MARCS-CMS 618502 — JANUARY 10, 2022
https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/onofrios-fresh-cut-inc-618502-01102022
WARNING LETTER
Onofrio's Fresh Cut, Inc.
MARCS-CMS 618502 — JANUARY 10, 2022