Mitigating the risk completely, however, is impossible. Therefore, the CFIA has also developed Guidelines for the General Cleanliness of Food—an Overview, which provides maximum limits for the amount of foreign matter in some foods. Two examples include an allowance for magnetic metal particle size and presence in chocolate and pits or pit fragments in pitted dates. This is a valuable resource for determining acceptable amounts of foreign materials in food and can guide both your HACCP program and your response to customer complaints.
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Finished Product and Intended Use. Hazards commonly associated with a food product are often overlooked. For example, if you are producing spaghetti sauce packaged in glass jars, your company has an elevated risk for glass complaints and should have good processes in place to control glass and respond to glass complaints. However, if your finished product is grated cheese, you are also at an elevated risk for glass complaints because your product is often served with spaghetti sauce. If the glass from the jar is eaten with the cheese, your company could receive the complaint. In this case, your company should recognize this risk and have a procedure to handle these complaints. This extra risk assessment is invaluable to determining what type of customer complaints a manufacturer may expect and how the company can direct its investigations accordingly.
Controlling Foreign Material
A HACCP plan is the foundation of effective foreign material control as it identifies the raw materials and process steps where contamination is likely to occur. Using the HACCP risk assessment, as well as industry standards, guidelines, regulations, and scientific studies, the facility can identify the steps in the process where foreign material control is needed. At the manufacturing level, devices commonly used to control foreign material include metal detection, X-ray, optical sorting equipment, mechanical sorting equipment (sieves, screens, filters, and magnets), bone separators, and visual inspection. Farm processing may include destoners, gravity tables, air separation, and visual inspection. This list is not exhaustive, and the devices needed in each facility will depend on the product being made and the manufacturing process.
Once you have identified the required devices, a strong program to control foreign material is necessary. Components of this program include standard operating procedures for activities, corrective action procedures for any deviations that occur, and employee training. Also essential for critical control points is the validation of the system.
When possible, customer complaints should be handled through the customer service department of the organization. These professionals will mitigate the risk from an upset customer, particularly if the consumer was harmed by the foreign material. First, determine if there has been an injury or illness associated with the incident. In this case, advise the consumer to contact a physician or seek medical treatment immediately. The usual consumer and product information should be documented, e.g. lot code or best before date, brand, package size, etc. Second, if the consumer mentions contacting the local or federal public health authority, encourage doing so. This transparency on your part will help to alleviate the consumer’s fears and provides an independent, credible authority to supply information to the consumer. If the customer is particularly difficult, provide this information directly so that a recognized authority can be involved as quickly as possible.
Also, request the object from the customer. While consumers may not want to release it directly to the facility, they will likely release it to a government authority for testing, which is another benefit of involving the government as soon as possible. Once the object has been retrieved from the customer, the investigation can continue. Access to a forensic laboratory is useful to help determine if the material was from your process (e.g. glass baked into bread) or from the consumer’s kitchen (e.g. rock salt that looks like glass).