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.
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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.