We are beginning a new year, which often means it’s time for New Year’s Resolutions. For individuals, this often entails things like exercise regularly, lose 10 pounds, or get something fixed around the house. For food, beverage, and ingredient processors, the new year may involve implementation of new programs based on the previous year’s performance. Allow me to present 10 points (or resolutions) that might be considered as part of continually improving your food quality, safety, and sanitation programs.
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Explore this issueFebruary/March 2019
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1. A Commitment from Management
Management commitment is an essential element for ensuring the production of high quality, safe, and wholesome foods. Personally, I always felt it should have been included as one of the preliminary steps to Hazard Analysis and Critical Control Points (HACCP) as highlighted in the Codex HACCP document and those mandating the adoption of HACCP for seafood and juice. Management responsibility was also a key element of the ISO 22000:2005 standard and remains so in the updated 22000:2018 standard. All food, beverage, and ingredient processors should seriously consider incorporating the communication element into their food safety management system. Far too many operations do not establish formal, documented protocols for communication.
The importance of management taking an active and all-encompassing role in a food safety program may be demonstrated by looking at what happened to the top guy at Peanut Corp. of America. He is now behind bars for what may be the remainder of his life.
It is very obvious when management has a positive attitude toward food safety. That attitude echoes through the company as employees at all levels buy off on food safety. These operations are a pleasure to work with and the term “food safety culture” is simply part of everyday life, whether they call it that or not.
2. Welcome Third-Party Audits
Most operators are not overly thrilled about third-party audits. Many years ago, the National Food Processors Association safety audit was supposed to be the be-all and end-all for audits—an audit that would satisfy everyone. Today, the Global Food Safety Initiative (GFSI) audits are supposed to fill that role, yet many buyers do their own audits, so operators might end up having 10 or more audits over the course of a year.
Audits may be distasteful to some, but they should be treated as a learning tool and a means of improving operations. When I perform audits and am asked the question, “What do I need to pass?” my sense is that the company is not quite clear on the concept. Audits are supposed to be a check on how an operation is performing, that is, “Do you do what you say and say what you do?” Ideally, the auditor needs to look at what the company is doing and have the knowledge and experience to determine whether that is effective. Hopefully, your auditor is not simply filling out a checklist but digging down and looking at whether programs are both comprehensive and effective. Auditors are not supposed to consult, but there is nothing wrong with picking their brains when on site. The auditor may have observed things elsewhere that can benefit you.
3. Appoint a Document Control Officer
With the emphasis on documentation in the GFSI audit schemes, ISO 22000, and the Preventive Controls for Human Food regulation in the U.S., documentation is an absolute must to pass audits and ensure regulatory compliance. Documentation must include procedures, work instructions, and development of forms for record maintenance. The company must develop the protocols, properly document them utilizing a standard format, implement the protocols including proper use of any recordkeeping forms, and maintain programs—that is, make sure the system is working.
An integral part of implementation is training and education: making sure the persons responsible for doing a task know how to do it. The company must document each of these two elements. Development and implementation are the responsibility of the different operating groups within the company, but someone needs to manage all the necessary documents, and that person should be a document control officer. This individual must ensure documents are prepared using a standard format, that they are signed off by developers when they are newly developed or revised, that they are distributed to the proper individuals, and that old documents and forms are collected and destroyed. The document control officer does not necessarily have to be part of the quality group, but they must have computer skills and understand organization. If you don’t already have a document control officer, consider establishing such a position.
4. Use Your Data
It bothers me to see companies with piles of data that have simply sat in file cabinets and collected dust. Data need to be compiled and turned into useable information that can aid in making decisions.
In today’s food industry, buyers often mandate that each lot of ingredients, raw materials, or finished goods they receive be accompanied by a Certificate of Analysis (COA). The data generated when preparing a COA may be utilized in the food safety management system as a verification activity. It should also be compiled electronically so the company can easily look at how products perform historically. If you are one of those operations that has piles of data sitting in old file cabinets, consider doing something with them. Hire someone who can compile the information and then follow your recordkeeping mandate to get rid of anything that should be disposed of.
5. Read Labels During Production
The most common cause of allergen recalls is the use of the wrong label or package. You would think processors would get the message that putting the right label on a package is an absolute necessity. Recalls cost money, time, and can damage a company’s reputation.
According to Amy Philpott, senior director, Watson & Green, LLC, “A 2011 joint industry study by the Food Marketing Institute and Grocery Manufacturers Association estimated the average cost of a recall for food companies to be $10 million in direct costs, plus brand damage and lost sales. Although this is old data, it still seems to be the most commonly referenced in the food industry.”
Philpott also observes that recall costs depend on a wide range of variables.
So, processors, I urge you to develop, document, and implement programs to ensure the right label on the right package. Look at the different scanning technologies; develop and implement programs to verify that new labels match the masters when they arrive; do what you can to minimize the potential that the wrong label is applied by clearly segregating labels in storage and when used; and make sure any old or discontinued labels are destroyed so they cannot possibly be used.
6. Risk-Based Sanitation Programs
Properly developed and implemented sanitation is one of the best means the food industry has for ensuring the production of safe food. Obviously, FDA believes sanitation to be important as it has specifically defined it as one of the preventive controls within the Preventive Controls for Human Food regulation. Sanitation preventive controls will be required for many ready-to-eat products and for products containing food allergens.
During hazard analysis, the processor must determine whether there are hazards that require sanitation preventive controls. Ideally, the processor will then develop, document, and implement the necessary programs to ensure the hazards determined to require a preventive control are in fact controlled. The operator should then validate the cleaning and sanitation protocols and ensure the validated program is followed. Validation is not required in the regulation, but it is a best practice.
Processors should take a close look at each cleaning and sanitizing procedure they develop. This would encompass all equipment, utensils, floors, walls, ceilings, drains, overheads, and more. They should also conduct a risk assessment on each procedure to make a clear determination not only whether that area poses a risk, but also whether the procedures that have been established are adequate to control the risk.
7. Validate Processes and Products
Validation is defined as obtaining evidence that the elements of the HACCP plan are effective. The Preventive Controls for Human Food regulation mandates all process preventive controls, that is, the critical control points from HACCP, be validated. The GFSI audit schemes, especially FSSC 22000, which is based on ISO 22000, mandate that prerequisite programs used to control hazards must be validated. In reality, this can pose a challenge since some controls simply don’t lend themselves to being easily validated.
Food processors should also take a close look at their products to determine whether they are bacteriostatic (inhibitory to pathogens) or bactericidal (lethal to pathogens). There are a wide variety of products on the market such as carbonated soft drinks, soy sauce, syrups, and condiments that are lethal to pathogenic bacteria. If a company allocates resources to conduct a challenge study that shows their products are lethal to pathogens, they should not only sleep easier knowing their products are safe, but they would not have to do environmental monitoring since the Preventive Controls regulation in 21 CFR Part 117.130(c)(2) states the following:
(ii) The hazard evaluation required by paragraph (c)(1)(i) of this section must include an evaluation of environmental pathogens whenever a ready-to-eat food is exposed to the environment prior to packaging and the packaged food does not receive a treatment or otherwise include a control measure (such as a formulation lethal to the pathogen) that would significantly minimize the pathogen.
8. Get Back to the Basics of Food Microbiology
Sometimes I wonder whether the food industry has forgotten the basics from food microbiology 101. The rapid methods and new tools for testing and analysis are extremely powerful additions to the food safety toolbox, but our goal is to produce safe, wholesome, and high-quality foods. This should be accomplished through formulation, and there are ingredients and processes that, when utilized properly, can create products that may be inhibitory and/or lethal to pathogens.
One product characteristic often ignored and definitely under-utilized is total acidity. Processors and regulators have become overly infatuated with pH and seem to forget that some foods have greater buffering capacity. Mayonnaise is routinely blamed for outbreaks associated with products like chicken or egg salad, but it is not the mayonnaise that is the culprit. Mayonnaise has a very high total acidity, which makes it a very safe product. Don’t forget to look at the ingredients and finished product characteristics and relate those how pathogens and spoilage organisms may be inhibited.
9. 5S Adoption
5S may be defined as a program to reduce operational steps and improve the overall cleanliness of a work area, making it safer and more productive. This definition can be expanded to say that development and implementation of the program can also enhance overall food safety and quality. If one wishes to summarize the 5S program, it can be described simply as “Everything has a place and everything in its place.” The program was first developed in Japan with the five “S”s as seiri, seiton, seiso, seiketsu, and shitsuke. These translate to sort, set location, shine and sweep, standardize, and sustain.
I encourage processors to consider the 5S method. It can, as noted above, enhance food safety, quality, and sanitation simply by better organizing overall operations. Companies that have implemented the program are generally amazed when they discover how much junk they got rid of with the first step of “sort.” This frees up space in the warehouses, production area, and other locations. Think about it: How much stuff do you have in your facility that simply collects dust? Employees in the shop never want to get rid of things as they “might” use it someday. If you ask how long something has been here, you’ll often get an answer like, “Before I joined the company, which was 10 years ago.”
10. Educate, Educate, Educate
A company can never devote too many resources toward educating its workforce. Education starts as soon as a worker joins the company. He or she will undergo an orientation that should address food safety, sanitation, allergen control, personal hygiene, food defense, worker safety, and other topics. Workers need to be trained on each task they perform, and those sessions must be properly documented. It is not simply a question of making sure that a person knows how to do a task properly; it is, unfortunately, also a liability issue. To ensure foods are safe, workers must follow the documented procedures, so training must be based on those procedures. Refresher sessions are recommended on a yearly basis.
Part of the education process is addressing the potential worker safety issues and making sure they understand that phase of the job. Are they handling chemicals? Then they must be taught about safe chemical handling and proper use of personal protective equipment. This needs to be documented. If a worker is injured on the job as a result of a chemical, the company will be liable for the injuries. If there is no record that the person was properly trained, then the company can be deemed negligent and may pay penalties.
It is imperative that training materials be applicable to the job and the plant. Utilize group exercises, take pictures of operations in the facility so it is more germane to the tasks at hand, and encourage participation. Make the learning enjoyable. Many workers look at training as a pleasant break from their day-to-day job, so consider this aspect in developing and scheduling educational programs.
Another potential benefit of such programs is they may help a company keep its workers. With reduced turnover, a company has a stronger and more knowledgeable workforce and educational costs may be reduced since it takes more time and effort to work with a new employee.
If you’re already doing some or all of these, I say “Bravo!” If not, there’s no time like the present to get started. Good luck in 2019!