Tag Archives: compliance

Michael Koeris, Ph.D. and vice president of operations, Sample6, pathogen detection
FST Soapbox

The True Costs You Endure During a Food Recall

By Michael Koeris, Ph.D.
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Michael Koeris, Ph.D. and vice president of operations, Sample6, pathogen detection

When you think about the expense of a recall, you probably automatically focus on the costs to pull the affected product from shelves and reimburse customers. Yes, this can be an expensive undertaking. But the true, comprehensive cost of a recall involves immensely more than these obvious financial tolls. Do you fully understand the price to be paid when your organization is up against a food recall?

The recall process in the food manufacturing industry is a highly expensive one, averaging more than $10 million in costs to cover activities such as communicating the recall across the supply chain, retrieving and handling the recalled product, investigating the event and implementing corrective actions to prevent reoccurrence.

Of course, this average doesn’t address the possibility of litigation costs, decreased sales, reputational damage or brand crisis management, which can add up to millions—even billions— of dollars more. The public has become much more informed and aware of food safety events, and a single breach of trust could result in resounding losses to your brand. This makes it critical to understand the true costs you endure when faced with a food recall.

Immediate, Direct Costs

A recall can be a company-defining event. The vast majority of recalls are voluntary and a reflection of conscientious behavior by the retailers, wholesalers and producers, but that doesn’t mean you won’t incur serious expenses. The most obvious, immediate and direct ones include:

  • Pausing production to carry out recall response initiatives
  • Alerting necessary parties within and outside the organization, including regulatory agencies and relevant retailers
  • Managing the logistics of removing affected or mislabeled products
  • Examining the source of the recall, including issues with suppliers, equipment, processes or contamination prevention plans
  • Remediating the identified problems to prevent similar occurrences
  • Planning for expanded human resources to handle recall tasks in addition to routine operations

Again, these expenses could equate to millions of dollars from your bottom line, but the truth is they may be the most minor of your concerns in the face of a food recall.

Compliance Penalties

As you likely know by now, there’s a monumental shift happening in the regulatory arena. FSMA has enacted strict laws that place a greater emphasis on proactive and preventive approaches to food safety. In addition, the USDA has been focusing on strong enforcement of its guidelines for years.

For manufacturers, this means adjusting processes and procedures to comply with legal requirements for monitoring, testing, documentation, risk assessment and more. It is not enough for companies to have a plan for taking corrective action on contaminated products; they must also have a strong preventive plan in place to identify pathogens in the production environment before they affect the product and/or leave the facility. If your company undergoes an FDA or USDA audit or investigation that reveals noncompliance with government-mandated prevention efforts, you could be looking at significant consequences like criminal fines and forfeitures to the U.S. government.

FSMA laws and USDA regulations stipulate that depending on the nature of the violation, and whether the food is adulterated or misbranded, the FDA or USDA may consider regulatory actions, including:

  • Issuing advisory letters
  • Initiating court actions, such as seizure or injunction
  • Implementing administrative detention to gain control of adulterated or misbranded products
  • Mandating a recall of violative food
  • Suspending a facility’s food registration to prevent the shipment of food

Lawsuits and Litigation

According to the CDC, 48 million people get sick from foodborne illness each year, 128,000 are hospitalized and 3,000 die. If your organization is sued on the basis of a contaminated or unsafe product, you can expect to deal with attorney fees, court costs and settlements. In the worst cases, you may even need to pay damages to harmed consumers.

Yes, prosecutions are rare. But they are a reflection of a failure to protect consumers, as well as potential negligence or (in the rarest of cases) malicious intent. The financial effects of these reputational scars go well beyond obvious litigation expenses.

Lost Sales

Once a recall is ordered, a series of actions unfold that drastically impact your income. Manufacturers halt production, and retailers pull products from their shelves. Worse, a loss in consumer trust can initiate a long-lasting sales depression. Your customers want to know that the products they’re buying are safe. In response to a recall, they may change their purchasing, food preparation and consumption practices, or they may avoid the product for months or years after the recall has ended.

Insurance Impacts

Most food companies have recall insurance to protect their assets if a recall occurs. But, are you fully informed on what it means to work through a recall with your underwriter or how a recall affects your premiums? Is there a possibility of losing your insurance? It’s crucial to understand how your insurance is affected by a recall and what is contractually covered under your plan.

Brand Deterioration

Recalls are happening more frequently today than ever before, for reasons including stricter compliance regulations and supercharged government testing regimes using novel technologies like next-generation sequencing. This increased focus on testing by the government has led to a greater discovery rate of contamination, which is a good thing for the public. It means that improvements will be made to yield an even safer food production environment.

Nonetheless, recalls are alarming to your customers, and the last thing you want to risk is their trust in your brand. At the end of the day, your brand is your primary asset. It is a representation of who you are and how you do business. When recalls happen, customers lose faith in your brand, which comes with a hefty price tag for your company. If your brand deteriorates due to consumer mistrust, you’re risking business failure.

Unfortunately for the food industry, stories exposing scandals are a proven way to catch the public’s eye. Therefore, any news of a recall receives immediate and aggressive media coverage from both traditional and social media platforms. In the event of a recall, publicity is inevitable, and it’s an expense that spans every aspect from public relations management to eroded sales.

Prop 65 label

California Proposition 65 To Impact Food Labels

By Nick Recht
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Prop 65 label

The fast-approaching August 30th deadline for California’s Proposition 65 has food manufacturers of all sizes working to make sure affected labels comply with the new labeling requirements. According to the California Office of Environmental Health Hazard Assessment (OEHHA), Proposition 65:

“…requires businesses to provide warnings to Californians about significant exposures to chemicals that cause cancer, birth defects or other reproductive harm. These chemicals can be in the products that Californians purchase, in their homes or workplaces, or that are released into the environment. By requiring that this information be provided, Proposition 65 enables Californians to make informed decisions about their exposures to these chemicals.”

Proposition 65, also known as the Safe Drinking Water and Toxic Enforcement Act, is intended to help better equip Californians to make informed decisions about the products they purchase. The OEHHA is responsible for determining which chemicals meet the legal and scientific requirements for inclusion on the Proposition 65 list, a list which has grown to more than 900 chemicals since it was originally published in 1987.

The new law will be enforced by the California Attorney General’s Office as well as any district attorney or city attorney for cities whose population exceeds 750,000. Individuals acting in the public’s interest may also seek to enforce Proposition 65 by filing a lawsuit against companies alleged to be in violation. Companies that are found to be in violation may be fined as high as $2,500 per violation per day.

To ensure compliance with the new law, food manufacturers must reference the list of included chemicals to determine which of their products, if any, are impacted. Manufacturers must then provide “clear and reasonable warnings” that chemicals used in the production of their goods or products sold in California are known to cause cancer, birth defects and/or other reproductive harm. The ruling impacts goods sold in California as well as those sold via catalog or the internet.

Proposition 65 underscores the importance of an agile labeling environment for food manufacturers, particularly as it relates to their ability to adjust labels prior to compliance deadlines. It also implores manufacturers to look to automation to reduce the room for human error. For example, labeling software can be leveraged to create a table look up so if an impacted ingredient is included in a product and printed on a label, the required warning statement is also automatically included on the label.

Leveraging a database connection to apply such warnings can help businesses mitigate risk, as failing to include a required warning could result in fines, business disruption and lost revenue. It is also important to note that compliance with Proposition 65 will require food manufacturers to stay up to date on changes, as new chemicals may be added and/or revisions to law may continue to occur. Food retailers must also stay abreast of labeling changes required by Proposition 65 to ensure the products they sell are in compliance. Learn more about Proposition 65 at the OEHHA’s official website: https://www.p65warnings.ca.gov.

Prop 65 label
Label design products can help a company add a warning statement to a current label. Image courtesy of TEKLYNX.
Question mark

Return of FSMA IQ Test: Part IV

By Food Safety Tech Staff
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Question mark

Two years ago, Food Safety Tech published a series of six FSMA IQ tests to “test” industry’s knowledge about FSMA. It seemed appropriate, as at that point in time, folks still had a lot of unanswered questions. Now that we have a couple of years under our belt, how much to we know? We will publish each section of the test every week for the next six weeks. Then at this year’s Food Safety Consortium, the creators of the test–Bill Bremer, principal of food safety compliance at Kestrel Management, LLC and his team–will compare 2016 vs. 2018 during an interactive session. And if you have questions or comments on any of the elements brought up in the IQ test, please include them comments section below the test, so Bremer’s team can address them either live on our site or during the Consortium session.

Take Part III here.

Create your own user feedback survey

Question mark

Return of FSMA IQ Test: Part II

By Food Safety Tech Staff
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Question mark

Two years ago, Food Safety Tech published a series of six FSMA IQ tests to “test” industry’s knowledge about FSMA. It seemed appropriate, as at that point in time, folks still had a lot of unanswered questions. Now that we have a couple of years under our belt, how much to we know? We will publish each section of the test every week for the next six weeks. Then at this year’s Food Safety Consortium, the creators of the test–Bill Bremer, principal of food safety compliance at Kestrel Management, LLC and his team–will compare 2016 vs. 2018 during an interactive session. And if you have questions or comments on any of the elements brought up in the IQ test, please include them comments section below the test, so Bremer’s team can address them either live on our site or during the Consortium session.

Take Part I here. 

Create your own user feedback survey

2018 Food Safety Supply Chain Conference, Blockchain

Beyond Supply Chain Trends: Blockchain, FSMA, Food Fraud, Audits and More

By Maria Fontanazza
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2018 Food Safety Supply Chain Conference, Blockchain
Rick Biros, Priya Rathnam, and Andrew Seaborn, 2018 Food Safety Supply Chain Conference
Priya Rathnam (middle) pictured with Rick Biros, president of Innovative Publishing (left) and Andrew Seaborn Supervisory Consumer Safety Officer, Division of Import Operations, ORA, FDA

How well do you know your suppliers? Can you trust your supplier’s suppliers? What kind of technology are you using to assess and ensure your suppliers are in compliance with regulatory requirements? These are common questions food companies must ask themselves on a regular basis. These and more were addressed at the 2018 Food Safety Supply Chain Conference, held last week at USP in Rockville, MD. Stay tuned for coverage of the event in upcoming articles. In the meantime, here are some top insights shared by FDA and others in industry.

“We’ve issued a limited number of warning letters (two), and they were due to really egregious issues. Where there were previously warning letters issued, we’re seeing a lot more ‘regulatory meetings’.” – Priya Rathnam, Supervisory Consumer Safety Officer, CFSAN, on FDA’s enforcement this fiscal year.

Criteria for FSMA auditors also includes the “soft skills”, aka ISO 19011, auditor personal attributes. –Josh Grauso, Senior Manager, Food Safety & Quality System Audits, UL

Fabien Robert, Nestle 2018 Food Safety Supply Chain Conference
Food fraud costs the industry up to $15 billion annually. – Fabien Robert, Ph.D., Director, Nestle Zone America

It’s concerning that so many QA managers (and other pros) today don’t know extent of risk assessment they need to carry out. – Chris Domenico, Safefood360, Territory Manager for North America

“Blockchain is more than a buzzword at the moment.”- Simon Batters, Vice President of Technology Solutions, Lloyd’s Register

2018 Food Safety Supply Chain Conference, Blockchain
A dynamic panel about blockchain, led by Darin Detwiler, Director: Regulatory Affairs of Food and Food Industry, Northeastern University featured (left to right) Kathy Wybourn, Director, Food Safety Solutions, DNV Business Assurance; Simon Batters,Vice President of Technology Solutions, Lloyd’s Register and Melanie Nuce, Senior Vice President, Corporate Development & Innovation, GS1 US.

Sometimes food safety doesn’t win; sometimes you need the business acumen to show that implementing supply chain efficiencies will create the win. – Gina Kramer, Executive Director, Savour Food Safety International

Bryan Cohn, 2018 Food Safety Supply Chain Conference
Building a robust & smart supply chain = reduce food miles, shrink carbon footprint, and save food waste to increase revenue/acre. – Bryan Cohn, Vice President of Operations, Seal the Seasons

The FSMA Sanitary transportation rule is not as straightforward as you think. We need more training. – Cathy Crawford, President, HACCP Consulting Group

Steven Burton, Icicle Technologies
FST Soapbox

Automation Is Happening—Don’t Miss The Boat

By Steven Burton
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Steven Burton, Icicle Technologies

Successful businesses move fast. They stay ahead of their competition by keeping their eye on the newest and most innovative emerging technologies. Failure to embrace the newest, fastest means of production and communication allows other businesses to muscle ahead of slow-to-change competitors, especially in the food industry. This is why embracing automation—even if it requires a commitment from you and your whole organization — is absolutely necessary for every food company.

Guarantee Growth and Compliance with the Internet of Things

The innovation at the forefront of automation technology is the Internet of Things (IoT): Multiple devices interconnected to monitor, communicate and control in real time. Today, a farmer can monitor a crop located in Australia from North America. Ingredients from anywhere in the world can be brought together in a matter of days and distributed just as quickly. Agricultural robots that reduce the risk of contamination and food safety expectations have risen as a result. As exciting as it is to be a part of a constantly innovating food industry, it’s also becoming more challenging to keep up and adapt.

It’s also becoming more necessary. Regulatory agencies are working to keep pace with technological innovations. The standards of food safety—more global than ever—have grown in complexity and will continue to grow as improved, real-time monitoring of products and facilities extends into every type and size of food production company. Properly planned and applied food safety programs are vital to ensuring that globally sourced ingredients and production facilities adhere to regulations to avoid the consequences of failed audits and expensive recalls.

Even for those on top of their regulatory requirements, IoT and other automation technologies are friends, not foes. Automation means that preparation for audits and inspections is reduced to bare minimum, eliminating the need for binders, spreadsheets and months of prep work. Furthermore, one of the greatest challenges of today’s food chain is ensuring not only your own compliance, but the compliance of your vendors. Dealing with hundreds or thousands of incoming ingredients and other materials at any given time is a massive undertaking, let alone dealing with vendor certifications. Integrated, automated systems for food production management streamlines processes and communication and reduces the risk of error and recall throughout the supply chain.

Don’t Be Paralyzed by the F-word: Fear

It is clear to see that staying competitive and staying in business in an interconnected world is possible only if the newest technology is embraced. Why are some companies reluctant to adapt, even when they know it is crucial to a successful future?

Some fear that their managers and employees may not adapt, that their functioning programs already in place may be interrupted, and that ever-present fear of a price tag.

To alleviate these fears and embrace the power of the future, it is vital that the company’s new automation and IoT utilize a software that is:

  • User-friendly so that employees, new or existing, can hit the ground running
  • Capable of building upon an existing food safety program and continue its success
  • Able to improve existing food safety programs to ensure updated compliance
  • Cost-effective and a good business decision when compared to the cost of manpower and recalls

One of the most common reasons a company chooses not to implement a new technology concerns the last point: Cost. To maximize the benefit of automation and IoT, expenses like laptops, tablets and phones are advisable in addition to software. The cost of the software itself when there is a paper or spreadsheet system that is working may seem unnecessary—after all, why buy a telephone when the telegrams are working just fine? In the high-speed world we now live in, a low-speed business approach is fatal.

There is good news when it comes to automation adoption: In response to the growing need for technology and the reluctance of companies to take on the expense, new incentives are being put in place in order support businesses and keep a country’s economy competitive. For example, the U.S. Tax Cuts and Job Act of 2017 allow write-offs of new automation technology in the first year of purchase, vastly reducing the initial cost impact of implementing automation technologies. Many state and provincial governments provide grants for updating technology to improve safety and traceability.

Automation Will Feed the World

Technology and automation in agriculture and food production make a company competitive, but it is also an unavoidable requirement going forward. Looking at the big picture, it’s also necessary to meet the demands of a booming global population. Food is, in many ways, the most essential industry to human life.

In The Future of Food: Food Production, Innovation, and Technology, authors David B. Schmidt and Kimberly Reed say it clearly:

“Each U.S. farmer feeds more people worldwide than ever before, at 155 people per farmer. In 1960, that number was 25.8 people. By 2050, the same farmer will need to feed 232 people… With finite resources, it will take innovation and a variety of technologies to meet the world’s food demand. This includes using new technologies. At every step of the journey from farm to fork, technology is helping us produce a safe, abundant, sustainable, and nutritious food supply.”

It took centuries for the writing of letters to be replaced by telegrams. It took only 130 years from the invention of telegrams to the use of email. A farmer with a shovel is now a robot, with the agricultural robot market expected to increase by more than fivefold to $12.8 billion over six years. 94% of packaging operations use robotic technology today. A recent survey found that half of food companies interviewed plan to increase their use of automation in the next two years.

Where will food production be in 2020? And where will your company be in that near future?

Randy Fields, Repositrak
FST Soapbox

Technology’s Role In The Future Of Food Safety

By Randy Fields
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Randy Fields, Repositrak

As we have all read in the media, when a food safety emergency occurs, a company’s reputation stands to take a significant hit that may be unrecoverable. This phenomenon isn’t going away soon, nor are compliance requirements that pose a threat to the personal freedom of executives. If these aren’t enough reasons to get busy automating your food safety programs, read on.

Learn more about the future of food safety and technology at this year’s Food Safety Consortium, November 12–16 in Schaumburg, IL

The trends toward social and health-related product claims, like organic, the ‘free-froms’ and locally-grown, have had the impact of adding dozens if not hundreds of new suppliers to a retailer’s procurement list. And, it’s important to note, that these generally smaller suppliers are just now approaching their compliance deadlines for FSMA, and if they are very small, still have another year. New trends appear every year, and they will compound the challenge for retailers and wholesalers of knowing exactly who all of their suppliers are, which in turn will worsen compliance issues.

Our studies show that at least 12% of documents that certify organic, ‘free-froms’ and other product label claims have some level of discrepancy or inaccuracy making them invalid, and rendering the systems that rely on vendor self-disclosure near useless. With sales expected to skyrocket within these categories during the next few years, companies need to leverage technology to protect the supply chain, and consider having the system hold purchase orders generated for vendors who are not compliant with requirements.

An alternative is to have the system add a compliance fee to the purchase order that escalates over time or swiftly replace suppliers if they are not willing or not able to comply. That also speeds compliance as news travels quickly if there is a hard-hitting consequence for non-compliance. Either way, it’s important to be able to substantiate any claims to the consumer, since if those assertions are deemed unreliable, retailers and their suppliers risk a breach in consumer confidence and will suffer economically when shoppers turn away from them at the shelf.

And while retailers and wholesalers have begun to turn the Titanic on regulatory and business compliance, they need to continue to diligently find the risks in their supply chain, working even more aggressively to automate their current food safety and quality programs using new technology and procedures. Otherwise, their reputation and their existence are in jeopardy.

Cloud-based compliance management solutions that help retailers, wholesalers and suppliers meet the new food safety requirements can be configured to manage documentation requirements by supplier type vs. requiring the same documents from all suppliers. These systems also go beyond just storing digital copies of documents, and actually manage any form of compliance by reading inside the document to confirm it meets requirements. The benefits of these compliance management tools extend to streamlining new vendor approvals, which can save time and enable the redeployment of resources to more productive business-building activities.

Make no mistake: business and regulatory compliance will continue to be a focal point in the future. This includes addressing potential safety, certification and quality challenges throughout the extended supply chain as nearly one-third of all recalls are due to ingredient suppliers. We believe that in less than three years, retailers will require supply chain visibility from the shelf all the way back to “dirt”. It’s been proven too risky not to have that kind of visibility for ultimately everyone’s customer – the consumer. And now technology companies are on the hook to deliver it.

FoodSafetyTech's Food Safety Training Calendar

FoodSafetyTech Introduces The Food Safety Training Calendar

By Food Safety Tech Staff
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FoodSafetyTech's Food Safety Training Calendar

FoodSafetyTech introduces the industry’s only Food Safety Training Calendar. This calendar is a comprehensive, user-friendly tool that will become invaluable for food industry professionals searching for training courses.

“The calendar is searchable by region, date and category,” says Rick Biros, President of Innovative Publishing Group. “Our primary reason to bring this to the marketplace is to help companies with the daunting task of finding training courses that meet specific criteria, such as the location, topic or timing.”

Calendar categories include:

  • Food Fraud & Food Defense
  • FSMA | PCQI | FSPCA | FSVP
  • GFSI Standards (BRC, FSSC 22000, SQF)
  • General Food Safety
  • Food Science
  • ISO Standards
  • Good Manufacturing Practices
  • HACCP | HARPC
  • Retail & Hospitality
  • Sanitation | Hygiene | Cleaning

Visit the calendar today at www.foodsafetytech.com/trainingcalendar.

If your organization is interested in listing courses in the calendar, please contact Marc Spector at 516-270-5344 or mspector@innovativepublishing.net.

Bill Bremer is Principal, Food Safety Compliance at Kestrel Management LLC
FST Soapbox

FSMA Checklist: Sanitary Transportation of Human and Animal Food Rule

By Bill Bremer
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Bill Bremer is Principal, Food Safety Compliance at Kestrel Management LLC

The FSMA rule on Sanitary Transportation of Human and Animal Food is now final, advancing FDA’s efforts to protect foods from farm to table by keeping them safe from contamination during transportation. Sanitary Transportation is one of seven foundational rules proposed under FSMA since January 2011 to create a modern, risk-based framework for food safety. The goal of this rule is to prevent practices during transportation that create food safety risks, such as failure to properly refrigerate food, inadequate cleaning of vehicles between loads, and failure to properly protect food.

How much do you know about the Sanitary Transportation Rule? Test your smarts by taking the FSMA IQ Test hereSpecifically, the Sanitary Transportation rule establishes requirements for vehicles and transportation equipment, transportation operations, records, training, and waivers. It applies to shippers, receivers, loaders and carriers who transport food in the United States by motor or rail vehicles. Additionally, it impacts shippers in other countries who ship food to the United States directly by motor or rail vehicle (from Canada or Mexico) or by ship or air, and arrange for the transfer of the intact container onto a motor or rail vehicle for transportation within the United States, if that food will be consumed or distributed in the United States. These requirements took effect April 2017 for shippers, carriers and receivers subject to the rule.

As the FSMA rules move to enforcement status, food companies must prepare to best respond to requirements and to develop programs for compliance, including Sanitary Transportation. This requires companies to document specific verification steps to satisfy regulations and meet food safety transportation requirements.

Self-Diagnostic Assessment Tool
The following self-diagnostic assessment tool can help organizations better determine their current state of planning when it comes to implementing and managing Sanitary Transportation Requirements. To complete your own assessment, review and compare your programs to the questions in Table I.

FSMA Sanitary Transportation rule
Table I. Kestrel Management’s self-diagnostic tool can help a company assess its Sanitary Transportation of Human and Animal Foods programs, as required under FSMA compliance.

Get Compliance-Ready

Companies must have the appropriate systems in place to comply with FSMA Sanitary Transportation of Human and Animal Food requirements or face possible willful non-conformance, which can include fines and criminal penalties under FDA enforcement. The questions in Table I will help companies identify areas to consider regarding their Sanitary Transportation programs. Kestrel can also help answer questions, provide input on solutions, discuss how to better manage all your food safety requirements, and change “No” responses into “Yes” responses that promote best practices for FSMA and food safety compliance.

Robert Rogers
FST Soapbox

Validating Your Foreign Material Inspection System

By Robert Rogers
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Robert Rogers

The Food Safety Modernization Act (FSMA) requires that food manufacturing and processing companies identify potential hazards within their production systems and then:

  • Put in place preventive controls to address those hazards,
  • Monitor those preventive controls to ensure their effectiveness &
  • Provide documentation proving compliance with these requirements.

There are also requirements for each company to develop and establish its own plan identifying potential food safety hazards and preventive controls to counter them, and to establish the monitoring procedures that will verify the efficacy and reliability of the preventive controls.

Validating, verifying and monitoring the performance of the systems that ensure that only safe food enters the market enables food manufacturers and processors to meet the specific regulatory standards mandated by the countries where they operate and sell. This enables them to avoid product recalls that are costly and that severely damage brand identity. But these processes, in addition to satisfying regulators, also play a valuable part in protecting the companies from potential liability lawsuits, which can often be even more damaging.

The preventive controls most often used to effectively deal with such identified hazards are inspection systems (checkweighers and metal detection, X-ray and machine vision inspection systems) that quickly and efficiently detect non-standard and contaminated products and defective packaging and reject them from production lines before they can enter the marketplace. The performance of these systems must be validated, verified and monitored on an ongoing basis to ensure that they are performing as intended.

These terms–validation, verification and monitoring–are often used interchangeably, creating confusion within organizations and across industries because people interpret and use these terms in different ways. In fact, each term identifies a distinct process that has a clear purpose and role to play at different points throughout the equipment lifecycle. It is important to understand the purpose of each process to make sure that validation, verification and routine performance monitoring tests are performed to comply with regulatory requirements, particularly where the equipment is designated as a Critical Control Point (CCP).

Validation

The fundamental act of “validation,” when applied to inspection systems that are part of a food manufacturing or processing production line, is conducting an objective, data-based confirmation that the system does what it was designed, manufactured and installed to do. The International Featured Standards (IFS) organization defines validation as “confirmation through the provision of objective evidences, that the requirements for the specific intended use or application have been fulfilled.” In 2008, the Codex Alimentarius Commission defined validation as, “Obtaining evidence that a control measure or combination of control measures, if properly implemented, is capable of controlling the hazard to a specified outcome.” An important part of the validation procedure is the production of detailed data that demonstrates to line managers and to regulators that the system is operating as designed.

The manufacturer of each inspection system will validate its performance before delivery, testing it with generic products and packaging similar to what the customer will be producing. But that is only the beginning of the validation process. Onsite, that same system needs to be validated when inspecting the specific products that the production line where it will operate will be processing and/or packaging. This is ideally done at the time the system is originally installed in a production line, and then becomes one element of a complete program of validation, periodic verification and ongoing monitoring that will keep the system operating as intended and ensure that products are adequately and accurately inspected, and that accurate records of those inspections are kept.

It is critical for producers to remember, however, that the original onsite validation relates only to the specific products tested at the time. As new or additional sizes of products are developed and run on the production line, or packaging (including labeling) changes, the system will need to be re-validated for each change.

Verification

Verification is the process of periodically confirming that the inspection equipment continues to be as effective as when it was first validated. The verification process uses standard, established tests to determine whether the inspection system is still under control and continuing to operate as originally demonstrated. This verification process is conducted periodically at regular intervals to provide evidence-based confirmation that the system continues to be effective as specified. Formal performance verification is typically an annual process, to support audit requirements. It should continue throughout the productive life of the system.

Both validation of an installed system and periodic verification of operating systems can be conducted either internally by the end-user, or by the supplier of the equipment. Validation and verification services are often included as part of equipment purchase contracts.

Monitoring

Routine performance monitoring, as distinct from periodic verification, consists of a series of frequent, regular performance checks, during production, completed to determine whether processes are under control and to confirm that there has not been a significant change in the system’s performance level since the last successful test. The monitoring frequency may be as often as every two hours, depending on company standards, industry standards and/or retailer codes of practice.

If the monitoring process finds that a particular device is out of specification, all product that has passed through the production line since the last successful routine performance-monitoring event must be considered suspect and re-inspected.

In many cases, it is line operators that conduct online performance monitoring. However, many of today’s more sophisticated product inspection systems incorporate built-in performance monitoring software that automates this process and alerts operators when deviations occur. This valuable software feature removes any human error factor from the monitoring activity to help ensure that inspection processes are still being performed properly. It also provides documentation that will guide the end-user company’s QA groups in their continuous improvement efforts, and that will also be a valuable asset in the event of an inspection visit from regulators.

Routine performance monitoring can also have a direct impact on the production line’s OEE. Installing a system with built-in condition monitoring capability that automatically detects when the system may need correction and communicates that information directly to line operators reduces the frequency needed for verification testing, maximizing the line’s production uptime.

Reliance on the experts

Finally, food manufacturers and processors should remember that, while they are knowledgeable experts regarding their products, it is their equipment suppliers that are the experts on the capabilities and qualification procedures of their equipment. That expertise makes them the best source of reliable recommendations on questions from the most effective inspection equipment type for specific product needs, where to place that equipment on the production line for optimum results and how to validate, verify and monitor its performance.

Relying on these experts to conduct onsite validation and to advise on conducting periodic verification and ongoing performance monitoring can reduce both the time needed for the original onsite validation time and that needed for verification and ongoing monitoring procedures, increasing productivity.

Companies can also rely on these experts to be knowledgeable on the most current food safety regulations and the technology that affect equipment validation. It is critical for their success that they stay current on those topics, and sharing that knowledge is a valuable part of their service.