The June 2012 passage of the FDA’s Food Safety Modernization Act, or FSMA, will soon require preventive controls for companies that manufacture, process, pack, or hold human food. These companies will be required to have written plans that identify hazards, specify the steps that will be put in place to minimize or prevent those hazards, identify monitoring procedures, record monitoring results, and specify what actions will be taken to correct problems that arise. These actions were initiated to prevent problems that can cause foodborne illness, but a frequent risk in the food industry is the presence of foreign material from ingredients, processing equipment, and the environment. Although the proposed rule aligns well with Hazard Analysis and Critical Control Points (HACCP), it differs in that preventive controls may be required at points other than at critical control points, and critical limits would not be required for all preventive controls.
To establish the correct preventive measures and develop a successful program that withstands FDA scrutiny, food quality employees need specialized materials analysis training that enables them to characterize and identify raw material and processing contaminants and their sources.
Specialized Materials Analysis
The presence of foreign material from ingredients, processing equipment, and the environment is a frequent risk in the food industry. Foreign material can be a risk in and of itself, or it can be the source of foodborne illness (microbiological contamination), and can provide clues to the source of contamination. Well-trained quality employees can easily compare suspect contaminants to reference samples from the manufacturing process and eliminate or confirm suspects based on appearance. This type of training can also be advantageous when addressing customer complaints for foreign matter contamination; successful identification of foreign matter is instrumental in determining the validity of complaints and developing the corrective actions needed.
Courses on materials identification can train food quality professionals to identify the specific hazards for their facility or industry so they can ensure that preventive controls are appropriate for the risk and not over-engineered. For example, incompatible gasket materials commonly cause contamination in the food processing industry. Identifying the offending material so it can then be replaced with a more compatible material is a simple step and is an easier solution than installing filters or screens downstream and implementing routine QC checks of those controls.
Food quality employees regularly attend microscopy courses at Hooke College of Applied Sciences (HCAS) with the goal of becoming proficient in the identification of food contaminants, in particular, contamination from extraneous materials and particles.
Learning to use specialized equipment such as research-grade microscopes can be challenging, especially if the microscope brand or model used in the classroom differs from the equipment at your workplace. HCAS has found that using a blended learning approach—one that augments classroom training with distance learning from the student’s lab—is an advantageous approach for students.
A study by the U.S. Department of Education’s Office of Planning, Evaluation and Policy Development’s Policy and Program Studies Service recognized that blended learning produced a larger advantage in learning outcome relative to purely face-to-face instruction than did purely online instruction. This study focused mainly on post-secondary and adult learners.
At HCAS, blended learning begins with pre-course online content consisting of both narrated learning modules and fully functional virtual microscopes. The narrated modules are 25 to 35 minutes long. The microscope simulations offer virtual versions of the instruments used during the course, allowing students to review the parts of the microscope, build the microscope from its virtual parts, and engage all of the microscope parts, simulating the microscope’s function.
The hands-on portions of the courses are taught as three-day or four-and-a-half-day sessions, which follow a traditional classroom format. Each student has access to a microscope during class and is expected to successfully complete a variety of tasks related to the lecture material presented in the course. Tasks include hands-on practice, laboratory exercises, identifications of unknowns, and competency checks. Students are required to have 100% attendance during the course, participate in class, complete a student evaluation form, and complete a pre-course and post-course knowledge and skills assessment form.
Each course is primarily taught by HCAS faculty, who are all members of McCrone Associates’ technical staff. McCrone Associates is a microscopy laboratory, pioneering innovative particle identification and materials analysis methods. All instructors currently work in laboratories where they use the techniques they teach to the students.
Techniques learned during training can be basic, such as the use of the stereomicroscope or polarized light microscope to get a better view of contaminants for basic characterization purposes. Is the contaminant glass, metal, or plastic? Does the material look corroded or thermally degraded? This will narrow down the detective work needed and allow the investigator to collect the appropriate reference materials from the manufacturing process to compare against the unknown sample. A contamination source can possibly be identified without definitively naming the components of the offending material. The techniques can be complex, such as the use of Fourier transform infrared spectroscopy (FTIR) to identify thermally degraded sugar or starch compounds, or the use of scanning electron microscopy (SEM) to determine the type of metal.
After the classroom portion of the course, students login to access a live, online, instructor-led session, where they discuss unknown samples that were sent to their labs by the instructor. Post-course sessions offer students an opportunity to put into practice the skills learned during the course, while using the equipment available to them at their facilities. Sessions allow participants with little experience to build confidence, while those with more experience can share insight with their less experienced colleagues. During this final web-based portion of the course, students begin the process of self-directed learning and inquiry, reinforcing the acquired concepts and skills learned earlier in the pre-course modules and in the classroom. The post-course environment encourages the exchange of ideas, such as alternative techniques and approaches used for identifying the unknowns. In addition, students are encouraged to analyze samples brought from their workplace during the hands-on portion of the class.
It’s important to receive training from an International Association for Continuing Education and Training (IACET) Authorized Provider. Organizations like HCAS offer CEUs for its programs that qualify under the American National Standards Institute (ANSI)/IACET Standard, which is widely recognized as the standard of good practice internationally. The requirements set forth by IACET create transparency in course structure, enabling learners to know who is teaching their course, the instructor’s experience level, the type of equipment to be used in class, and the expected student learning outcomes upon completion of each course.
When choosing a training provider, choose a materials analysis course that trains quality professionals not only within a specialized academic environment, but also with an online component to be carried out in the student’s own laboratory with materials specific to their industry. Ask questions to determine the instructor’s experience level, the age and type of equipment being used in the classroom, the types of learning resources available, and the material expected to be learned upon completion of the course. Ensure your training choices have sufficient credibility to withstand regulatory scrutiny.
Zona is the dean of Hooke College of Applied Sciences, Westmont, Ill. Murley is the quality manager at McCrone Associates, Westmont, Ill.