(Editor’s Note: This is an online-only article attributed to the August/September 2018 issue.)
As compliance dates continue to roll out this year for the FDA Food Safety Modernization Act and updated current Good Manufacturing Practices, food processors are thinking digitally and a little out of the box to ensure requirements are met. Companies large and small are coming up with new practices and utilizing new tools to ensure requirements are met as effectively, efficiently, and easily as possible, and they are starting at the critical first step–the moment ingredients hit the loading dock.
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When it comes to inventory brought into food production facilities and warehouses, the FDA specifies (21CFR117.80, section b): “Raw materials and other ingredients must be inspected and segregated or otherwise handled as necessary to ascertain that they are clean and suitable for processing into food and must be stored under conditions that will protect against allergen cross-contact and against contamination and minimize deterioration.” Proper intake of these raw materials and meticulous recordkeeping are critical first steps in meeting requirements for food traceability.
Culture and Training
Having qualified and well-trained employees is crucial and companies must also go beyond that, according to Cheriene Griffith, operations manager for Chevoo, Healdsburg, Calif., a producer of gourmet marinated goat cheese and a Navy veteran with 10 years of experience with food safety. “First, it is an overall culture at the facility that focuses on food safety, and that is the hardest challenge to overcome. Employees need to believe that there is a reason to store items in a certain way and understand why as well,” Griffith says. “If an item is received, inspected, labeled, and stored properly, a majority of cross-contamination issues can be avoided.”
What a Picture is Worth
Providing employees with the right tools and taking uncertainty out of the equation helps ensure accuracy from the start. Effective tools can range from low-tech solutions to modern enterprise resource planning (ERP) systems that are cloud-based and mobile. “I have seen some plants use not only different colored labels but also a graphic of the allergen on the label so it was very clear if that item was stored in the wrong place,” Griffith says.
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While processors have used photos to document products being shipped from the facility left in good condition in the event of damage claims, using photography to document incoming raw materials also can be useful. “People need to look outside the box because the rules are changing so fast. With written documents it’s easy for errors to happen, but a photo will accurately show the lot code, how much it is, the condition of the packaging, and whether it is intact or not,” she says. “It’s a lot easier when the inspector asks to see your receiving and shipping inspections to have a catalog of beautiful photos rather than a box of paper reports.”
In the Cloud
When it comes to foreign suppliers, it can be more of a challenge to get information in a timely manner, particularly when the difference in time zones is significant. Purely cloud-based document sharing services are growing in popularity and address one aspect of the issue, but they don’t always integrate well or share data with other systems. Efforts to digitize data relating to the food supply chain is an important step in creating modern food safety systems and is the precursor to implementation of blockchain or other technology for centralized information sharing.
Smaller food companies, whose compliance dates are in mid-September this year, often use spreadsheets—which are simply a digital form of paper recordkeeping—to try to keep track of ingredients from multiple suppliers for traceability, cost, and inventory management. However, the complexities of keeping track of ingredients—after the slicing, dicing, and blending of processing and shipment of finished product sent to different customers—are formidable.
“It is important to keep track of ingredient lot codes in storage for recall and traceability purposes,” Griffith says. “There are ERP systems that are robust enough to track exactly where an item is from storage to usage, which makes it very organized and clear what production should be using. Some ERP systems can use barcodes, which production enters when they input an ingredient, and if a wrong ingredient is used, it will flag as incorrect. The batch can be discarded before it is produced, and a recall is avoided.”