The USDA estimates that foodborne illnesses cost more than $15.6 billion each year. However, biological contamination isn’t the only risk to the safety and quality of food. Food safety can also be compromised by foreign objects at virtually any stage in the production process, from contaminants in raw materials to metal shavings from the wear of equipment on the line, and even from human error. While the risk of foreign object contamination may seem easy to avoid, in 2019 alone the USDA reported 34 food recalls, impacting 17 million pounds of food due to ‘extraneous material’ which can include metal, plastic and even glass.
When FSMA went into effect, the focus shifted to preventing food safety problems, necessitating that food processors implement preventive controls to shift the focus from recovery and quarantine to proactive risk mitigation. Food producers developed Hazard Analysis and Critical Control Point (HACCP) plans focused on identifying potential areas of risk and placement of appropriate inspection equipment at these key locations within the processing line.
Metal detection is the most common detection technology used to find ferrous, non-ferrous, and stainless steel foreign objects in food. In order to increase levels of food safety and better protect brand reputation, food processors need detection technologies that can find increasingly smaller metal foreign objects. Leading retailers are echoing that need and more often stipulate specific detection performance in their codes of practice, which processors must meet in order to sell them product.
As food processors face increased consumer demand and continued price-per-unit pressures, they must meet the challenges of greater throughput demands while concurrently driving out waste to ensure maximum operational efficiencies.
Challenges Inherent in Meat Metal Detection
While some food products are easier to inspect, such as dry, inert products like pasta or grains, metal foreign object detection in meat is particularly challenging. This is due to the high moisture and salt content common in ready-to-eat, frozen and processed, often spicy, meat products that have high “product effect.” Bloody whole muscle cuts can also create high product effect.
The conductive properties of meat can mimic a foreign object and cause metal detectors to incorrectly signal the presence of a physical contaminant even when it is nonexistent. Food metal detectors must be intelligent enough to ignore these signals and recognize them as product effect to avoid false rejection. Otherwise, they can signal metal when it is not present, thus rejecting good product and thereby increasing costs through scrap or re-work.
Equipping for Success
When evaluating metal detection technologies, food processors should request a product test, which allows the processor to see how various options perform for their application. The gold standard is for the food processor to send in samples of their product and provide information about the processing environment so that the companies under consideration can as closely as possible simulate the manufacturing environment. These tests are typically provided at no charge, but care should be taken upfront to fully understand the comprehensiveness of the testing methodologies and reporting.
Among the options to explore are new technologies such as multiscan metal detection, which enables meat processors to achieve a new level of food safety and quality. This technology utilizes five user-adjustable frequencies at once, essentially doing the work of five metal detectors back-to-back in the production line and yielding the highest probability of detecting metal foreign objects in food. When running, multiscan technology allows inspectors to view all the selected frequencies in real time and pull up a report of the last 20 rejects to see what caused them, allowing them to quickly make appropriate adjustments to the production line.
Such innovations are designed for ease of use and to meet even the most rigorous retailer codes of practice. Brands, their retail and wholesale customers, and consumers all benefit from carefully considered, application-specific, food safety inspection.
The food processing industry is necessarily highly regulated. Implementing the right food safety program needs to be a top priority to ensure consumer safety and brand protection. Innovative new approaches address these safety concerns for regulatory requirements and at the same time are designed to support increased productivity and operational efficiency.
If your food processing facility needs an expansion or update, construction can be a disruptive event. Throughout the process, a variety of food safety hazards can be present, potentially putting your products at risk. While the contractors you work with are skilled at their trade, protecting your brand is ultimately your responsibility.
Extra precautions are needed to minimize the food safety risks during construction, but by developing a thorough plan and following it diligently, you can keep your products, facility and employees safe.
Preparation: The Important First Steps for Safety
Having an established environmental plan before construction starts will make the construction process go smoothly and help maintain safety. If the plan your staff is following needs changes or improvements, make updates in advance of construction and be sure that your staff is up to speed before the project begins.
First, remove any equipment that can be moved from the construction zone and cover all electrical panels, open conduit and electrical outlets to minimize areas that might harbor dust or bacteria during construction.
Next, taking steps to separate the construction and production areas is crucial. Installing heavy gauge plastic sheeting or even temporary walls to isolate the construction area will help prevent cross-contamination. Any doors or wall openings on the temporary barriers should be sealed on both sides, and the gaps between the base of the barriers and the floor should be adequately sealed to keep the surrounding production areas safe. Do whatever is necessary to minimize organisms from traveling by air outside of the construction zone.
The HVAC and air handling system in the construction area should also be evaluated for cross-contamination potential. Be sure to close off or divert the airflow to prevent air movement from the construction zone to any production areas. In addition, make sure the system will be able to accommodate additional areas or space after construction is complete and make any upgrades if necessary. Thoroughly clean the HVAC system and filters before the construction process starts.
Similarly, evaluate any drains that are present in the construction zone for cross-contamination potential and take precautions to keep pathogens from passing from the construction area to the food production areas.
Make Contractors Part of Your Plan
While contractors might have years of experience in their trade, they don’t know your food safety plan. Schedule a formal food safety training session with the contractor and all members of the construction staff. Don’t allow anyone to work in the facility before completing the training. Determine which protective clothing contractors and their team will need, such as frocks, boot covers or hairnets, and provide a separate bag or place to store them during the construction process.
Designating a single entrance for contractors and construction staff will minimize confusion and avoid mistaken entries into prohibited areas. Educate them on the appropriate traffic flow as they arrive, enter the facility, and conduct their work. Their entrance should be separate from those used by office and food production employees. Have quat or alcohol hand and tool sanitizers stationed at the designated contractor entrance, and require them to sanitize any tools, materials or equipment before entering the facility. Emphasize that no mud or other debris should be tracked into the facility. Provide the necessary guidance and monitor the entrance area to prevent that from happening.
Construction staff and in-house food production staff should be separated at all times. To prevent cross-contamination, there shouldn’t be any direct paths from the construction area to the production area. No material from the construction area should ever be brought into the food production area. Contractors and construction staff should also be prohibited from using the break rooms or restrooms that are used by the facility employees. Because they won’t have access to other areas, temporary hand wash sinks may be needed for construction employees to follow frequent hand washing and sanitizing procedures.
Best Practices for Sanitation During Construction
Before demolishing and removing any walls during the construction process, apply a foam disinfectant at 800–1000 ppm without rinsing. If any equipment needs to be moved, or if there will be new equipment brought into the area, clean and disinfect it with quat at 800–1000 ppm without rinsing.
Quat should also be applied heavily on the floors around the designated construction team entrances. Foam or spray contractors’ walkways and the construction area floor every four hours at 800–1000 ppm. Allow contractors, forklifts, dollies or other wheeled carts to regularly travel through the disinfectant to keep their feet and wheels sanitized as they move throughout the construction area.
If your construction project involves new equipment installation, discuss the sanitation requirements and restrictions with a sanitation chemical provider before purchasing this equipment to ensure you have the right chemistry on hand. Any new equipment should be cleaned and sanitized, as well as the area where it will be installed, before bringing the equipment into the area. Make sure all the surfaces of the new equipment are compatible with your current cleaning chemistry and that the installation follows proper food safety guidelines. If necessary, upgrade your food safety process to accommodate the new equipment.
Transitioning from Construction to Safe Food Production
Once the construction project is complete, remove all construction materials, tools, debris, plastic sheeting and temporary walls. Seal any holes that might have occurred in the floors, walls and ceilings where equipment was moved, and repair or replace epoxy or other floor coverings. Inspect any forklifts or man lifts used during the construction, and clean and sanitize them.
Clean the HVAC and air handling system and return it to either its pre-construction settings or an updated configuration based on what the new area requires.
Continue cleaning everything in the construction area, from ceiling to floor, including lights, walls, drains, refrigeration units and all equipment following SSOPs. Note that different cleaning products containing solvents may be needed for the initial cleaning to remove cutting oil, welding flux residues, greases, and other elements from the construction process. Be sure to have those cleaning products on hand before you get to this step to avoid delays of a thorough sanitation process. Where necessary, passivate any stainless steel equipment.
Finally, test the environment. Collect a special set of swabs and monitor the results. Apply post-rinse sanitizer and then begin food production. Implement an enhanced environmental monitoring program in all areas disrupted by the construction until the data shows a return to the baseline levels. Revise your facility SSOPs in light of any changes based on the new construction.
Achieving Seamless Productivity
Expansion can mean new capabilities for your business, but lax food safety processes during construction can jeopardize the new opportunities your expansion brings. By having a strong plan in place, following it diligently, educating contractors on your plan, monitoring activity, and using effective sanitizing chemistry, you will be able to expand while protecting your brand and avoiding food safety issues.
Milk has enjoyed increasing popularity in China, however, the milk supply chain is still vulnerable to fraud throughout the country. Milk can be adulterated in variety of ways, from dilution with water to the addition of carbohydrate- or nitrogen-based and protein-rich adulterants as well as a variety of unapproved (sometimes hazardous) additives. This study used Fourier transform-infrared spectroscopy to determine fraud in 52 ultra-high-temperature commercial milk samples. Twenty-three percent of the samples turned out to be adulterated and some of the samples were even flagged for multiple issues.
Foodborne illnesses cost billions of dollars each year in the United States. A lack of standards can lead to severe consequences, including loss of customers, negative impact on brand reputation and employees missing work due to illness. As a result, safety is vital for any brand that is committed to high-quality food and maintaining a positive brand image.
Food safety management systems—the processes and procedures that companies set up to prevent contamination—are essential in reducing the risk of foodborne illness and ensuring the safest products possible.
By FDA regulation, most food processors must have HACCP as well as corrective actions/preventive action (CAPAs) plans in place. Even with the right safety guidelines, however, contamination or exposure to food hazards can still occur. The following are four ways to improve the quality of your food safety management system.
1. Conduct Regular Audits
Even if your business’s HACCP is highly effective in theory, it won’t prevent contamination unless actual practice lines up with documentation. Regular audits can ensure employee practice complies.
HACCPs are structured around identifying both potential food hazards and critical control points (CCPs) where your system has the opportunity to prevent, mitigate or eliminate a potential issue. Usually, this means storing food items or performing some biological, physical or chemical action to a target limit— like a specific temperature—to prevent or mitigate contamination.
For example, in the manufacturing of chicken products, cooking and hot-holding are critical control points at which the product needs to be heated to a certain temperature to eliminate or prevent potential hazards. Here, an audit would be a chance to ensure employees cooked and hot-held foods at the proper temperatures. If they aren’t, the food safety management team can make policy changes that ensure practice lines up with planning.
The audit process should be consistent and occur regularly. It should also cover every aspect of your HACCP strategy and place a particular focus on potential hazards and CCPs. These audits can be a way to uncover the strengths and weaknesses of your current HACCP strategy. Companies can use this information to build upon existing practices or demonstrate how procedures could be more effective.
2. Consider a CCP Monitoring System
You can use automated or digital systems to ensure that CCPs aren’t deviating from control limits. With the right sensors, it’s possible to ensure that food remains between target limits at each CCP. For example, automated sensors can quickly alert plant staff if the temperature of food in cold storage rises above a certain threshold, or if there is a deviation from a given CCP.
These alerts can help staff quickly respond to deviations, ensuring compliance, and reducing the risk of contamination by food hazards.
3. Review and Maintain Equipment
An thorough equipment program can be highly effective in reducing the risk of food contamination. To minimize risk, your plan should look at the equipment needed in your plant, as well as how it’s constructed and maintained. For example, choosing industry-standard or food-safe materials can help prevent contamination. Investing in the right kind of stainless steel can both improve operating costs and help reduce the risk of food exposed to hazards.
Preventive maintenance plans for food safety equipment can also reduce the risk of contamination by ensuring the proper functioning of site equipment.
4. Provide Employee Support and Encourage Buy-In
Training programs are an essential component of any HACCP. If your employees don’t know how to handle food properly or aren’t aware of HACCP documentation or the CCPs in the food processing pipeline, they won’t be able to execute the plan and prevent contamination.
While training programs are crucial, they don’t necessarily guarantee compliance. Common pitfalls exist that can discourage employees from following the plan. To encourage employee buy-in, training should begin by discussing the importance of food safety and the potential risks of contamination.
The training should also be robust enough that employees feel confident when executing the HACCP. Training staff should be sure to provide visual demonstrations and opportunities for employees to practice before they become responsible for food safety. Tests or evaluations both during and after training can be useful tools in determining how well your employees understand your business’s HACCP strategy. Regular follow-ups on training can also ensure compliance and reduce the risk of contamination.
Improving Food Safety Management Systems
For any business that works with food, safety programs are essential in ensuring the safest and highest quality product possible. Existing food safety management systems can often improve with the right methods. For example, automated monitoring systems can reduce the risk of deviating from CCP limits. Employee training and regular audits can also ensure that a plant’s food safety practices line up with the documented plan.
The plant-based meat market is anticipated to be worth more than $320 millionin the next five years, according to a report released last summer by Global Market Insights. As the popularity of meat-alternative products continues to rise, new challenges are being introduced to supply chain management. Joe Scioscia, vice president of sales at VAI explains some of these hurdles and proposes how technology can help.
Food Safety Tech: Is the growing popularity of plant-based foods introducing hazards or challenges to the supply chain?
Joe Scioscia: The growing popularity of plant-based foods has presented a new set of challenges for the supply chain, especially considering many of these organic items are being introduced by traditionally non-organic retailers. Impossible Foods received FDA approval for its plant-based burger in 2019, showing just how new the plant-based movement is to the industry.
Obviously, the organic supply chain and produce suppliers have long followed regulations for handling produce, such as temperature controls, cargo tracking, and supply and demand planning software, so the produce could be tracked from farm to table and in the case of a recall, be traced back to the source. But for meat alternatives that are combining multiple plant-based ingredients, organizations in the supply chain who are handling these products
have new food safety concerns. Considerations on how to store and process meat alternatives, how to treat each ingredient in the product and, most importantly, how to determine temperature controls or the source of contamination are all discussions the food industry is currently having.
FST: How are plant-based foods changing the dynamic of the supply chain from a food safety perspective?
Scioscia: The food supply chain has changed dramatically in recent years to become more complex, with food items traveling farther than ever before, containing more ingredients and required to follow stricter regulations. Many of the changes to the supply chain are for the better—organic and plant-based alternatives offer health benefits for consumers and are a move towards a more sustainable future. But the reality is that the supply chain isn’t quite there yet. Suppliers, retailers and producers at every part of the supply chain need to work together to ensure transparency and food safety compliance—including for plant-based products. Foodborne illnesses are still a real threat to the safety of consumers, and these same consumers are demanding transparency into the source of their food and sustainable practices from brands. All of these considerations are what’s making this next era of the food industry more complicated than ever before.
Because food safety compliance is always top of mind in the food industry to keep consumers safe, this new and complex supply chain has required companies to rely heavily on technology solutions to ensure plant-based products are equally as safe to consume as non-organic alternatives. These same solutions are also helping supply chains become more transparent for customers and streamline food processes to build a more sustainable future.
FST: What technologies can food companies and retailers use to better manage the supply chain risk while supporting the increased consumer demand for meat alternatives?
Scioscia: Utilizing a centralized software system is one tool many food suppliers and distributors can use to better visualize, trace and process products in the supply chain—including for plant-based alternatives. Having access to a central platform for business data to track assets and ensure food safety regulations are being met allows for companies to optimize processes and cut unnecessary costs along the way.
Heading into 2020, many organizations in the food supply chain are also looking at new applications like IoT, automation, and blockchain as ways to curb food safety issues. The FDA has taken steps to pilot blockchain and AI programs to better track drugs and food products, in conjunction with major food brands and technology companies. Other organizations are following suit with their own programs and many are looking at these solutions to improve their food tracking efforts. It’s clear technology has the most potential to make it easier on the industry to comply with food safety regulations while meeting customer demands for plant-based alternatives and organic options—all the while building a sustainable supply chain for the future.
Almost everybody loves chocolate, an ancient, basic, almost universal and primal source of pleasure. “The story of chocolate beings with cocoa trees that grew wild in the tropical rainforests of the Amazon basin and other areas in Central and South America for thousands of years… Christopher Columbus is said to have brought the first cocoa beans back to Europe from his fourth visit to the New World” between 1502 and 1504.1
Unfortunately, the production of chocolate and chocolate products today is as complex as any other global food product with supply chains that reach from one end of the world to the other. The complexity of the supply chain and production, along with the universal demand for the finished product, exposes chocolate to increasing pressure from numerous hazards, both unintentional and intentional. For example, we know that more than 70% of cocoa production takes place in West African countries, particularly the Ivory Coast and Ghana. These regions are politically unstable, and production is frequently disrupted by fighting. While production has started to expand into more stable regions, it has not yet become diversified enough to normalize the supply. About 17% of production takes place in the Americas (primarily South America) and 9% from Asia and Oceania.2
In today’s world of global commerce these pressures are not unique to chocolate. Food quality and safety experts should be armed with tools and innovations that can help them examine specific hazards and fraud pertaining to chocolate and chocolate products. In fact, the global nature of the chocolate market, requires fast reflexes that protect brand integrity and dynamic quality processes supported by informed decisions. Digital tools have become a necessity when a fast interpretation of dynamic data is needed. If a food organization is going to effectively protect the public’s health, protect their brand and comply with various governmental regulations and non-governmental standards such as GFSI, horizon scanning, along with the use of food safety intelligent digital tools, needs to be incorporated into food company’s core FSQA program.
This article pulls information from a recent industry report about chocolate products that presents an examination of the specific hazards and fraud pertaining to chocolate and chocolate products along with ways to utilize this information.
Cocoa and chocolate products rely on high quality ingredients and raw materials, strict supplier partnership schemes and conformity to clearly defined quality and safety standards. During the past 10 years there have been a significant number of food safety incidents associated with chocolate products. The presence of Salmonella enterica, Listeria monocytogenes, allergens and foreign materials in cocoa/chocolate products have been reported on a global scale. Today, information on food safety incidents and potential risks is quickly and widely available by way of the internet. However, because the pertinent data is frequently siloed, food safety professionals are unable to take full advantage of it.
Top Emerging Hazards: Chocolate Products (2013-2018)
Publicly available data, from sources such as European Union RASFF, Australian Competition and Consumer Commission, UK Food Standards Agency, FDA, Food Standards Australia New Zealand (FSANZ), shows a significant increase in identified food safety incidents for cocoa/chocolate products from 2013 to 2018. For this same time period, the top emerging hazards that were identified for chocolate products were the following:
Foreign bodies: 13.83%
Food additives & flavorings: 4.26%
Other hazards: 2.66%
By using such information to identify critical food safety protection trends, which we define to include food safety (unintentional adulteration) and food fraud (intentional adulteration, inclusive of authenticity/intentional misrepresentation) we can better construct our food protection systems to focus on the areas that present the greatest threats to public health, brand protection and compliance.
A Data Driven Approach
Monitoring Incoming Raw Materials
Assessment and identification of potential food protection issues, including food safety and fraud, at the stage of incoming raw materials is of vital importance for food manufacturers. Knowledge of the associated risks and vulnerabilities allows for timely actions and appropriate measures that may ultimately prevent an incident from occurring.
Specifically, the efficient utilization of global food safety and fraud information should allow for:
Identification of prevalent, increasing and/or emerging risks and vulnerabilities associated with raw materials
Comparative evaluation of the risk profile for different raw materials’ origins
Critical evaluation and risk-based selection of raw materials’ suppliers
A comprehensive risk assessment must start with the consideration of the identified food safety incidents of the raw material, which include the inherent characteristics of the raw material. Next, the origin-related risks must be taken into account and then the supplier-related risks must be examined. The full risk assessment is driven by the appropriate food safety data, its analysis and application of risk assessment scientific models on top of the data.
Using food safety intelligent digital tools to analyze almost 400 unique, chocolate product related food safety incidents around the globe provides us with important, useful insights about cocoa as a raw material, as a raw material from a specific origin and as a raw material being provided by specific suppliers. The graph below represents the results of the analysis illustrating the trend of incidents reported between 2002 and 2018. It can be observed that after a significant rise between 2009 and 2010, the number of incidents approximately doubled and remained at that level for the rest of the evaluated period (i.e., from 2010 to 2018), compared to the period from 2002 to 2005.
By further analyzing the data stemming from the 400 food safety incidents and breaking them down into more defined hazards, for incoming raw materials, we can clearly see that chemical hazards represent the major hazard category for cocoa.
Organoleptic aspects: 5.93%
Other Hazards: 4.38%
Foreign bodies: 2.06%
Food additives and flavorings: .77%
Food contact materials: .52%
Using the appropriate analytical tools, someone can drill down into the data and identify the specific incidents within the different hazard categories. For example, within the “chemical hazard” category specific hazards such as organophosphates, neonicotinoids, pyrethroids and organochlorines were identified.
Comparative Evaluation of Risk Profiles for Different Origins of Raw Materials
The main regions of origin for cocoa globally are Africa, Asia and South America. After collecting and analyzing all relevant data from recalls and border rejections and the frequency of pertinent incidents, we can accurately identify the top hazards for cocoa by region.
The top five specific hazards for the regions under discussion are listed in Table I.
Poor or insufficient controls
Table I. Top Five Hazards By Region
After the first level of analysis, a further interpretation of the data using the appropriate data intelligence tools can help to reach to very specific information on the nature of the incidents. This provides additional detail that is helpful in understanding how the regional risk profiles compare. For example, the prevalence of chemical contamination, as either industrial contaminants or pesticides, has been a commonly observed pattern for all three of the regions in Table I. However, beyond the general hazard category level, there are also different trends with regard to specific hazards for the three different regions. One such example is the increased presence of mold in cocoa beans coming from Africa.
The primary hazard categories for cocoa, as a raw ingredient were identified and a comparison among the primary hazards for cocoa by region (origin-specific) should take place. The next step in a data-powered supplier assessment workflow would be to incorporate our use of global food safety data in evaluating the suppliers of the raw materials.
The Role of Global Food Safety Data
This article has been focused on chocolate products but has only touched the surface in terms of the information available in the complete report, which also includes specific information about key raw materials. Let’s also be clear, that the techniques and tools used to generate this information are applicable to all food products and ingredients. As we strive to produce food safely in the 21st Century and beyond, we must adapt our methods or be left behind.
The regulatory environment the food industry must operate in has never been more intense. The threats to an organization’s brand have never been greater. This is not going to change. What must change is the way in which food companies confront these challenges.
Global food safety data can contribute to the establishment of an adaptive food safety/QA process that will provide time savings and improve a quality team’s efficiency and performance.
Based on the continuous analysis of food recalls and rejections by key national and international food authorities, a food safety / quality assurance manager could establish an adaptive supplier verification process and risk assessment process by utilizing the knowledge provided by such data. In that way, QA, procurement, food safety and quality departments can be empowered with critical supplier data that will inform the internal procedures for incoming materials and ingredients (e.g., raw materials, packaging materials) and allow for adaptive laboratory testing routines and compliance protocols. Moreover, food safety systems can become adaptive, enabling quality assurance and safety professionals to quickly update points of critical control when needed, and intervene in important stages of the chocolate manufacturing process.
The legal cannabis-infused products industry is growing with impressive and predictable rapidity. But because the rollout of new regulations occurs in an awkward and piecemeal fashion, with stark differences from one state to another, and sometimes even one county to another, uncertainty reigns.1 Many entrepreneurs are diving headlong into the nascent industry, hoping to take advantage of an uncertain regulatory environment where government audits and inspections are rare. These business owners will see quality assurance and product safety as burdens—costs to be avoided to the greatest extent possible.
I have seen this time and time again, even in the comparatively well-regulated food industry, and it is always a mistake.
If you find yourself thinking about quality assurance or food safety as a prohibitive cost, annoyance or distraction, I encourage you to change your thinking on this issue. The most successful businesses realize that product safety and quality assurance are inextricably linked with profitability. They are best thought of not as distractions, but as critical elements of an efficient and optimized process. Proper QA and safety are not costs, they are value.
Food safety and quality assurance should be seen as important elements of the process that you undertake to enforce the high standards and consistency that will win you repeat customers. The fact that they guard against costly recalls or satisfy meddlesome auditors is only a bonus. Realizing this will make your business smarter, faster and more profitable.
Learn more about the science, technology, regulatory compliance and quality management issues surrounding cannabis at the Food Labs / Cannabis Labs Conference | June 2–4, 2020If today you cannot clearly communicate your product standards to your employees and to your customers, then you have some work to do. That’s because quality assurance always begins with precise product specifications. (A good definition of “quality” is “conformance to specifications.”) How can you assess quality if you don’t have a definitive standard with which to evaluate it? My consulting firm works with food businesses both small and large, and this is where we begin every relationship. You might be surprised how often even a well-established business has a difficult time naming and describing every one of its products, let alone articulating objective standards for them.
This may be doubly difficult for fledgling businesses in the cannabis world. Because the market is so new, there are fewer agreed-upon standards to fall back on.
When we help businesses create specifications, we always look at the relevant regulations while keeping in mind customer expectations. In cannabis, the regulations just aren’t as comprehensive as they are for conventional food and agriculture. Laws and guidelines are still in flux, and different third-party standards are still competing for market dominance. Different states have entirely different standards, and don’t even agree, for example, whether cannabis edibles should be considered pharmaceuticals or food. To some extent, it’s the wild west of regulation, and as long as the federal government remains reluctant to impose national guidelines, it’s likely to remain so.
The wild west may be a good place for the unscrupulous, but it’s not good for business owners that care about the health of their customers and the long-term health of their brand. Don’t take advantage of confusing quality and safety standards by doing the least possible to get by. At some point there will be a scandal in this country when a novel cannabis product makes dozens of customers sick, or worse. You don’t want it to be yours.
With cannabis-infused products, there is a unique additional factor at play: The strength of THC and other psychoactive compounds. Again, there are few agreed-upon standards for potency testing, and relatively little oversight of the laboratories themselves. This allows labs to get sloppy, and even creates an incentive for them to return inflated THC counts; at the very least, results may hugely differ from one lab to another even for identical products.2 Some labs are ISO 17025 accredited, and some are not. Using an unaccredited laboratory may prevent your efforts to create consistent and homogeneous products.
Even in comparatively well-regulated states, such as Colorado, it is ultimately your responsibility to create products that are safe and consistent. And in the states where the politicians haven’t even figured out which department is regulating cannabis products, your standards should be tougher than whatever is officially required.
And so we look to the more established world of conventional food and agriculture as a guide for the best practices in the cannabis industry.
The most constructive way to look at food safety, and the way your (eventual) auditors and regulators will view it, is to look at your product and process from the perspective of the potential hazards.
Some day, when regulation finally gets sorted out, you are likely to be asked to implement a Hazard Analysis and Critical Control Points (HACCP) safety system. HACCP framework recognizes three broad categories of hazards:
Physical hazards: Foreign material that is large enough to cause harm, such as glass or metal fragments.
Chemical hazards: Pesticides and herbicides, heavy metals, solvents and cleaning solutions.
Biological hazards: The pathogens that cause foodborne illness in your customers, such as E. coli, and other biological hazards, such as mycotoxins from molds.
All of these hazards are highly relevant to cannabis-infused product businesses.
The HACCP framework asks us to consider what steps in our process offer us the chance to definitively and objectively eliminate the risk of relevant hazards. In a cannabis cookie, for example, this might be a cooking step, a baking process that kills the Salmonella that could be lurking in your flour, eggs, chocolate or (just as likely!) the cannabis extracts themselves.
A good HACCP system is merely the capstone resting atop a larger foundational system of safety programs, including standard operating procedures, good manufacturing practices, and good agricultural practices. It’s important to use these agreed-upon practices and procedures in your own facility and to ensure that your suppliers and shippers are doing the same. Does your cultivator have a culture of safety and professionalism? Do they understand their own risks of hazards?
HACCP offers a rigorous perspective with which to look at a process, and to examine all of the places where it can go wrong. The safety system ultimately holds everything together because of its emphasis on scrupulous documentation. Every important step is written down, every time, and is always double-checked by a supervisor. It sounds like a lot of paperwork, but it is better viewed as an opportunity to enforce consistency and precision.
When you thoroughly document your process you’ll create a safer product, run a more efficient business, and make more money.
Given this fact, you may need to look up as well as down. Did you know that a rodent’s teeth is strong enough to gnaw through cinderblock? Or that they are smart enough to memorize floor plans and solve puzzles, enabling them to find multiple entrances into a facility? Did you know that a female mouse starts reproducing at only six weeks of age and can have up to 180 babies a year? That means there are 180 opportunities per mouse in your facility or home to reproduce, contaminate, and damage your products and property.
Rodent trivia can range from fun and interesting to downright shocking. The fact of the matter is that rodents are strong, agile and smart animals. The intelligence of rats is often ranked among some of the smartest in the animal kingdom. Since rodents can carry over 35 different diseases that are harmful to humans, it is a good reminder for those in food safety that these small skilled creatures require vigilance in order to keep them from spreading pathogens across your facility.
Food processing is a multi-trillion dollar industry that encompasses facilities such as bakeries, meat and poultry plants, bottling lines, dairies, canneries and breweries. For all of these food processing plants a commercial flooring system is essential for maintaining a hygienic environment. Few areas of a plant provide as much opportunity for the spread of bacteria, mold, fungi and dust as the floor. Hazardous materials from a contaminated floor can easily be spread from worker’s shoes and mobile equipment. Food processing plants present a unique set of challenges that require careful consideration of floor properties and installation.
Food processing plants floors are subjected to constant, high concentrations of salt, alkaline and oil compounds that substantially degrade the floor and thereby risk food contamination and facility shutdown. These compounds can come from common food production by-products like oils, fats, dairy products, sugar solutions, blood, and natural acids or from harsh cleaners and disinfectants. Even with frequent and thorough cleaning these substances can—and will—result in microbial growth and the spread of bacteria in untreated concrete or poorly installed resinous flooring.
Cleaning floors is an essential part of maintaining food processing operations to keep up with government standards. A proper floor coating is a necessity for dealing with the vigorous, harsh cleaning procedures that typically include very hot water and aggressive cleaning chemicals. Depending on the exposure to corrosive, temperature and moisture conditions a thin film coating may suffice; however, in most cases, a thick, durable floor coating is needed to endure the cleaning operations. If too thin of a coating is used the repeated barrage of high pressure, high-temperature hot water and steam will strip the floor coating. Only an experienced flooring professional can determine the proper floor coating for a facility.
In addition to the properties of the floor coating, proper installation is essential for maintaining a hygienic, safe facility. If a floor is not seamless even the best floor coatings are vulnerable to germ buildup within gaps and cracks. To prevent harmful substance accumulation, a seamless coving transition from the floor to the wall is needed. Not only does that make the floors unsanitary, but it also can spread to other parts of the facility, equipment and product. Coving also aids in the cleaning process by allowing for hosing around the sides and corners of the room where germ buildup is most common.
An often-overlooked—yet critical—aspect of floor installation is having the proper pitch to promote water drainage. Having pools of water is not only dangerous for workers but for product safety. Such an examples of this issue is the Listeria outbreak at cantaloupe producer Jensen Farms, which led to 33 fatalities, 143 hospitalized victims, and ultimately, the end of their business. In the 2011 FDA released a report that focused on “Factors Potentially Contributing to the Contamination of Fresh, Whole Cantaloupe Implicated in the Multi-State Listeria monocytogenes Foodborne Illness Outbreak”. The conclusion was reached that the leading cause of Listeria spreading was due to a poorly constructed packing facility floor that was difficult to clean and allowed water to pool. The best way to prevent a similar situation at your plant is to make sure you get an experienced flooring expert, who understands your facility’s needs, to choose a floor with the right properties and to properly install it.
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