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.
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Explore This IssueFebruary/March 2019
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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.