Last week’s seventh annual Food Safety Consortium brought together a variety of industry experts to discuss key topics around regulation, compliance, leadership, testing, foodborne illness, food defense and more. The following are just a few sound bytes from what we heard at the event. (Click on any photo to enlarge)
“The food system today, while it’s still impressive, it still has one Achilles heel—lack of traceability and transparency.” – Frank Yiannas, deputy commissioner for food policy & response, FDA. Read the full article on Yiannas’ keynote session
“A typical food company only has about 5% visibility into known supply chain threats.” – Ron Stakland, senior business development, FoodChain ID, Inc.
“For most of us, our supply chain is a big black hole. Why are we so fearful of technology? Is it the implementation itself? What if technology could help us solve some of those perennial problems? There are resources available to help us get there.” – ¬ Jeremy Schneider, business development director, food safety and quality assurance, Controlant
“The records tell the story of how well the facility is being managed. It’s the first thing the regulators are going to look at.” – Glenn Black, Ph.D., associate director for research, CFSAN, FDA, on validation considerations and regulations for processing technologies in the food industry
“We’ll see more robotics enter the food space.” – Gina Nicholson Kramer, executive director, Savour Food Safety International
“Changes are happening; you can choose to face it or ignore it. We’re at least 10 years behind on technology. Automation/technology is not a new term in aerospace, etc., but to us [the food industry], it is. We will get there.” – Melody Ge, head of compliance, Corvium, Inc., on how industry should prepare for the data-driven transformation occurring in the smarter era of food safety
It’s okay to risk and fail, but how are going to remediate that with your employee? The more learners practice in different scenarios, the less they rely on specific examples. [They] become more adept with dealing with decision making.” – Kathryn Birmingham, Ph.D., VP for research and development, ImEpik, on employee training
“As a contract lab with the vision of testing for foodborne viruses for about 10 years—it wasn’t until about three or four years ago that we had the test kits to turn that into a reality. We also didn’t have a reference method.” – Erin Crowley, chief scientific officer, Q Laboratories, on the viral landscape of testing in the food industry
“You have to be strong and you have to believe in yourself before you get into any situation—especially as a food safety professional.” – Al Baroudi, Ph.D., vice president of quality assurance and food safety at The Cheesecake Factory, on what it takes to earn respect as a food safety professional
“’See something, say something’ is likely not enough. We recommend that companies develop a formal detection program that includes management buy-in, HR and governance, and policy documents, formal training and an awareness program…While FDA focuses on the insider threat, we feel that using a broader mitigation approach works best.” – R. Spencer Lane, senior security advisor, Business Protection Specialists, Inc. on lessons learned from food defense intentional adulteration vulnerability assessments
“Food safety is a profession, a vocation, [and] a way of life.” – Bob Pudlock, president of Gulf Stream Search
“A new era of smarter food safety is coming,” said Frank Yiannas, FDA’s deputy commissioner of food policy and response, at the GFSI Conference 2019 in Nice, France. He went on to explain, “a smarter food safety is people-led, FSMA-based and technology-enabled.” Afterwards, Yiannas announced the need for a greater budget for the FDA to invest in modern food safety for 2020 and beyond.
Now the question is, when this new era comes, are you ready?
The food industry is relatively behind on technology compared to other industries, or even within our daily lives. Take a look at the cell phone you have now compared to what you had 10 years ago; it has come a long way with all of its handy and useful features. Why can’t the food industry also benefit from technology? Of course, every coin has two sides, but no one would deny that technology played a significant role in bringing the world closer and making it more efficient nowadays.
The scary part of change is that it’s hard to predict what and when they will come to us, however, they also force us think outside of the box. Instead of debating whether incorporating advanced technology into our daily operations makes sense, why don’t we take a look at our current processes in place and see where technology can truly help us? We now have the opportunity to take advantage of technology to enhance our food safety and quality culture at our own facility. Here are some thoughts to share.
1. Identify what can be automated in your current process with technology
Certain things just can’t be replaced by technology, such as risk assessment or hazard identification (at least for now). However, inventory, temperature checking, testing results recording, or anything executing a command from you or implementing a part of your SOPs can potentially be automated. Execution is also the part where the most error could occur, and technology can help improve accuracy and consistency. Identify those steps systematically and understand what data needs to be captured to help your food safety management system.
2. Work with your technology developer to build technical requirements
Explain to the technology developer exactly how you want the program to operate daily. List the operating steps along with responsibilities step-by-step, and identify what requirements are needed for each step. Translating the paper SOP to a computer program plays an important role in this transition. Not only does it set the foundation for your future daily operation, but it also ensures that the control parameter is not lost during the transition.
3. Keep the integrity of the food safety management system through verification and validation
Once processing steps are done by technology, it doesn’t mean that we no longer have to do anything. We need to verify and validate the technology with certain frequency to ensure the steps are controlled as intended. Confirming that the software or system is capturing the right data at the right time becomes key to ensure the integrity of control risks is not compromised.
4. Utilize “preventative maintenance” on all technology used on site
Just like all equipment, food safety technology needs a preventive maintenance schedule. Check whether it is properly functioning on a certain frequency based on the safety impact in your process flow and take actions proactively.
5. Learn from your own records
The time saved from traditional ways allows us to have more time for looking at control points and records received to identify areas for continuous improvement. There are many ways of studying the data with modeling and trend analysis based on your own facility situation. Either way, those records are your own supporting documents of any changes or modifications to your food safety management system, as well as strong support to your risk assessment for justifications.
Just like Yiannas said, a smarter food safety system is still FSMA based. The goal has never changed; we want to produce sustainable, safe and high-quality products to our consumers, whether we use traditional or advanced approaches. After all, we are utilizing technology as a modern way to help us enhance and simplify our food safety management system; the outcome from the automated technology is still controlled by us.
So when the era comes, we all want to be ready for it.
Running an unvalidated program or product is like betting your life’s savings on a horse because you overheard a “surefire tip” outside the racetrack, or driving around without any mirrors.
To put it less dramatically: Skipping validation is asking for problems. But what does validation mean, how much is necessary, and what’s the best way to include it in your plans?
In order to start understanding validation, we must first break it down into two main categories: Product validation and process validation. From there, it’s important to look at whether something has been broadly validated for general use, and whether it has been narrowly validated for use in your specific situation. That last question is where people often struggle: How can we ensure this product or process is validated for use in the way that we plan to use it?
Validating an on-site allergen test kit requires a few different layers of research and testing. Taking the time to carefully design and vet a validation process may seem tedious, and it may require some additional up-front costs—but in the long run, it’s the only way to ensure you are spending your money on a test kit that works. And if you’re using an allergen test kit that doesn’t actually detect allergens in your facility—best-case scenario, you’re wasting money and time. Worst-case scenario, you’re headed straight for a recall and you won’t see it coming until your customers get sick.
If you are buying a test to determine the absence or presence of allergens in your facility (specific or general), you’ll likely ask the kit manufacturer if the test kit has been validated. This validation can come in many forms, most commonly:
Third party validation (eg., AOAC)
Internally produced validation documents or whitepapers
A product with more validation (third-party certifications, studies, whitepapers) isn’t necessarily better than a product with less. It may have simply been on the market longer or be produced by a company that allocates its funding differently. However, validation documents can be very comforting when reviewing a product, as they provide a starting point for your own research. When you are reviewing validation data, ask yourself a few questions:
Does this data cover products like mine?
Are the ingredients similar (raw meat, ice cream, spices, etc.)?
Are the preparation processes similar (heat, fermentation, etc.)?
Does this data cover an environment like mine?
Will the tests be run the same way in my facility as in the data?
Is the contamination being introduced in a way and amount that feels realistic to the risk factors I know about in my facility?
Does the data mention any complicating factors (and do I need to care about them)?
Are there ingredients known to cross-react or cause false negatives?
Are there processes known to change the LOD or cause false negatives?
If I am aware of limitations with other similar test kits, are those limitations addressed in the data for this test kit as well?
To give an example, let’s imagine you make premium ice cream and are reviewing allergen test kits that look for peanuts and almonds in product, in rinsewater and on surfaces. You’ll want to ask questions like:
How does the kit perform in a high-fat environment?
Does the validation data cover product, rinsewater and surfaces?
Are there ingredients in our facility that are called out as cross-reactive (or otherwise troublesome)?
Do our ingredients get exposed to temperatures, pH levels, or other processes that impact the LOD?
You might learn, for example, that one of the matrices tested in validation was ice cream. If so: Wonderful! That’s a vote of confidence and a great starting point. Or maybe you learn that the kit in question isn’t recommended for matrices that include an ingredient in your formulation. If so: That’s equally wonderful! Now you know you need a different solution. Or maybe the instructions on your current peanut test kit indicate that heavily roasted peanuts have a higher detection limit than raw peanuts, but this new test kit only has data for raw peanuts. If so: OK! You have more research to do, and that’s fine too.
In short: Pre-existing product validation data is a helpful starting point for determining whether or not an allergen test kit MIGHT work well in your facility—but it doesn’t eliminate the need for you to run your own internal validation study.
Once you’ve identified an allergen test kit that you want to use in your facility, you’ll want to prove that it can work to identify contamination in your specific environment. This is where a more narrowly tailored validation comes into play. Your test kit provider may have resources available to help you design an internal validation. Don’t be afraid to ask for help! A reputable test kit provider should care not just about making the sale, but also about making your food safer.
Before you even order a new test kit, you should have a good idea of how your validation process is going to work. It’s important to have both the study design and study outcome on file. Here are some possible additions for your internal validation study:
Validating that an allergen test kit can reliably prove your surfaces are clean of said allergen:
Test the surface prior to cleaning, after the allergen in question has been run. Do you see positive results? If not, then a negative result after cleaning is essentially meaningless.
Test the surface after cleaning. Do you see negative results? If not, it could mean a problem with your cleaning process—or a strange interference. Both require further research.
If your products encounter multiple surfaces (eg., stainless steel and also ceramic), test them all with before and after testing.
Validating that an allergen test kit can reliably prove your rinsewater is free of said allergen:
Test water from the beginning of the cleaning cycle as well as the end. Do you see a change in results, from positive to negative?
If you don’t ever see the allergen present in your rinsewater, you may want to “spike” a sample by adding a small amount of the product that contains the allergen into the rinsewater you’ve collected. Could it be that something in your cleaning protocol or some aspect of your matrix is affecting the detection limit?
Validating that an allergen test kit can reliably prove your ingredients or finished products are free of said allergen:
Test a product that you know contains the allergen but is otherwise similar. Keep in mind that some allergen test kits can be overloaded and can show false negatives if too much allergen is present in the sample—if you aren’t sure whether the test kit you are trialing has this limitation, ask your supplier. Do you see a positive?
Have you encountered batches of your product with accidental cross-contamination from the allergen in question? If so, and you have some of that batch archived, run a test on it. Would this kit have identified the problem?
Do you have a batch or lot of product that has been analyzed by a third-party lab? If so, do your results in-house match the lab’s results?
Run—or ask a lab to run—a spiked recovery. This is especially important if there is no pre-existing data on how the test kit works against your specific matrices.
Some test kit manufacturers can provide this service for you—you would simply need to send them the product, and they can add various amounts of allergen into the product and confirm that the test kit shows positive results.
Some kit manufacturers or other suppliers can send you standards that have known quantities of allergen in them. You can mix these into your product and run tests, and confirm that you get positive results when expected.
You may want to simply do this on your own, by adding small quantities of the allergen into the sample and running tests. However, take care to be especially careful with your documentation in case questions arise down the line.
No matter how the spiked recovery is being run, consider these two factors:
Be sure you’re including what could be a realistic amount of contamination—if you’re concerned about catching 25ppm of allergen, loading up your sample with 2000ppm won’t necessarily help you prove anything.
The matrix of your allergen-containing foods is just as important as the matrix of your allergen-free foods. If your allergen has been fermented, roasted, pressurized, etc. —your spike needs to be processed in the same way. If you aren’t sure how to think about your matrices, this previous Allergen Alley postis a good starting place.
Once you’ve proven that the test kit in question can in fact show positive results when traces of allergen are present, you can confidently and comfortably incorporate it into your larger allergen control plan. If your matrices change, you’ll want to re-validate whatever’s new.
While it can be tempting to rely on a kit’s general validation, taking the extra step to validate your unique matrices is an essential part of a truly robust food safety plan. If you’re stumped for how to begin, contact your kit provider—after all, you share the same goals: Safe, allergen-free food for consumers who rely on you to keep themselves and their families healthy and well fed.
Manufacturing large volumes of food product that must be safe for human consumption with finite resources is, simply put, a demanding responsibility. For many food brands, having dedicated production lines is not always an option, so lines are often shared amongst a variety of food products. A potential problem arises when products containing allergenic foods are manufactured on the same equipment as other products, and those allergenic foods are not meant to be declared in the product label. As a result, residues of the first product manufactured may move to the next product. Known as direct cross-contact contamination, this issue can have a severe adverse impact on allergic consumers.
Cross-contact contamination can occur at various stages of production, but it’s direct food cross-contact in shared production lines that is often found as a particularly significant food safety hazard. Addressing cross-contact through effective cleaning procedures is one of the most critical allergen management activities in establishing preventive controls and minimizing the potential of unintentional presence of food allergens. Allergen cleaning validation enables food manufacturers to evaluate that their cleaning procedure is adequate when it comes to removing ingredients from direct food contact surfaces.
Cleaning validation consists of generating data to demonstrate that allergenic foods are removed from direct food contact areas to a pre-defined acceptable level. A basic cleaning validation design consists of determining the residual level or presence of allergenic food before cleaning (baseline), and then assessing the level of the allergenic food after cleaning.
If the cleaning procedure exists in several steps (i.e., more than one rinse or purge, as with dry cleaning) additional testing to assess the level of allergens between cleaning stages and in the final product can also be incorporated. It is important to remember that a single validation study may not be applicable for an entire site operation. Different production lines within a food production site may require an individualized validation analysis. This determination will depend on the cleaning process as well as the formulation of the products being manufactured.
There are five important considerations for establishing a successful validation study:
Set up a team and assign a leader to carry out the design of the validation. Involving relevant personnel with knowledge in the product formulation, manufacturing process, equipment design and cleaning and sanitation regimes may provide valuable insight to identify processes that should be included in the validation. It may also bring to light critical sampling points in the equipment that should be considered.
Determine the scope of the study. This is where you describe and justify which equipment, utensils, cleaning regime and production processes will be validated. It may be wise to group different processes or select the worst-case scenario. For example, you might choose to focus on food production equipment regarded as hard to clean or equipment that contains the highest concentration of the allergenic food.
Design a sampling plan. This is a critical prerequisite before starting a validation study. The plan should be clearly defined, with critical sampling points and locations prescribed to challenge the effectiveness of the cleaning regime and to find evidence of allergenic food presence. In both open equipment and equipment that will be dismantled as part of the cleaning regime, it is important to select sites where food can get trapped, as well as other sites that are hard to clean. Also consider other surfaces that can be a source of direct cross-contact like protective clothing and utensils. For clean-in-place (CIP) systems, wash water should be collected from the onset of cleaning and then at intervals leading up to the final rinse water. This helps to demonstrate that allergen food levels are diminishing, thereby validating the use of CIP analysis as a verification method. Note that it is important to consider that the sampling plan for the validation should also reflect the sampling plan that will be used during routine verification. Support from a statistician may facilitate the decision to define how many samples and type of samples (swabs, CIP or final product) should be collected for the validation and how many cleaning runs should be performed to demonstrate validity.
Select a method of analysis. Validation and verification involve the use of a specific method to detect allergenic foods. The selected method should be validated as well, an undertaking most often done by the commercial supplier. Then it should be verified by the food processor that the method is fit for purpose, such that the allergenic food will be recovered and detected under the conditions in which samples are routinely collected. This ensures there will not be interference due to the food itself or due to cleaning chemicals. There are a variety of different analytical methods; most are based in technologies designed to detect proteins. Enzyme-linked immunosorbent assays (ELISA) and immune-based lateral flow devices (LFDs) offer detection of specific protein targets (i.e., egg proteins, milk proteins, peanut proteins) and are ideal for a validation study. ELISA can provide quantitative data from pre-cleaning, at various intervals during the cleaning process, at post-cleaning and at final product, offering a measurable level of the allergenic food during the cleaning process. Rapid detection through LFDs also allows food processors to assess the presence or absence of a specific protein or group of proteins, but different from ELISA, the result is only qualitative. In either case, these rapid tests may be used for both validation and routine verification. In addition, there are non-specific tests that can detect total protein that may be selected for a cleaning validation study. These tests do not provide specific information about the allergen to be managed, and thus may be more suitable for routine verification. During a cleaning validation study, it is important to include the test that will be utilized for verification and ensure it is also fit for purpose and detects the allergenic food to an appropriate pre-defined sensitivity. This is particularly important if the test is different from the analytical method chosen for cleaning validation.
Establish acceptance criteria. Proteins from allergenic foods may cause an adverse reaction at very low levels. To date, there are very few regions in the world in which threshold or permitted levels for allergens in food are established. Each individual food manufacturer should define a criterion to establish when a surface is clean from allergens after routine cleaning. The limits that are set up should be practical but also measurable and verifiable, thus it is important to define a level with knowledge of the sampling and analytical method selected. The sensitivity of the analytical methods currently available may be used as a criterion to verify that levels of an allergen are under control if they fall below the limit of detection of the analytical method.
Once a cleaning regime has been validated and documented, routine allergen cleaning verification should be performed as part of a monitoring program to demonstrate that the cleaning process in place is effective and that the risk of direct cross-contact is consequently being controlled. The validation should be repeated at defined intervals, often once a year. However, it is expected that a cleaning verification will be performed after each production run and cleaning procedure in order to reflect that the validated cleaning process is still effective. Cleaning verification, along with other allergen management activities, strengthens implemented food safety programs and helps to protect consumers.
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).
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 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.
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.
Our industry is in a perpetual food safety discussion. We are constantly mulling over the finer points of hazards, risk, preventive controls, training, sanitation, and regulations. Validation is also a key component of the food safety dialog. Here we will explore common themes industry professionals discuss in regard to validation in this era of food safety.
In any good conversation, terms must be set and semantics agreed upon. It is helpful to start off with a simplistic definition of validation and verification that can be applied across industries and applications. We often return to these reductive definitions throughout conversations to recalibrate and ensure that all parties are on the same page.
Validation: Are we using the correct system / method?
Verification: Are we using the system / method correctly?
From there, we narrow our focus. Using the FSMA backdrop, from the FDA’s “Draft Guidance for Industry: Control of Listeria monocytogenes in Ready-To-Eat Foods” we find the following definitions:
Validation: Obtaining and evaluating scientific and technical evidence that a control measure, combination of control measures, or the food safety plan as a whole, when properly implemented, is capable of effectively controlling the identified hazards.
Verification: The application of methods, procedures, tests and other evaluations, in addition to monitoring, to determine whether a control measure or combination of control measures is or has been operating as intended and to establish the validity of the food safety plan.
Validation and Verification: Semantics Matter.
Definitions for validation and verification are available from various standards organizations and regulatory bodies. What is most important, however, is that in this conversation there is a clear distinction between validation and verification—both in activities and objectives. These are not interchangeable terms. Further, validation and verification can be discussed from two general perspectives in the food safety landscape. Process validation addresses manufacturing activities and controls to prevent product hazard and contamination. Method validation addresses the analytical methods used to verify the physical, chemical or microbiological properties of a product.
Our industry is comprised of a variety of categorical segments. Each segment faces unique processing challenges, risks and requirements that must be addressed in the validation and verification conversation.
Some segments, such as the dairy industry, have long standing processes in place that have a robust scientific backbone and leave little room for guesswork, experimentation or modification. “Milk processes were validated years ago and are part of the Pasteurized Milk Ordinance (PMO). The science is there,” states Janet Raddatz, vice president of quality & food safety systems at Sargento Foods, Inc. ” It is well established that when you pasteurize the product for the time and temperature that has been validated, then you simply verify the pasteurizer is working to the validated specifications.”
However, process validation challenges arise when novel applications, ingredients and processes are employed. Even in an established industry, reformulations of products such as sauces and dressings require fresh validation perspective and risk assessment. “You must assess the risk anytime there is a change. Properties such as pH, salt and water are critical variables to the safety and microbial stability of a product. Novel processing techniques aimed at ‘all natural’ or ‘minimal processing’ consumer demands should also be challenged.” Raddatz suggests conducting a full assessment to identify potential areas of risk. A challenge study may also be a critical piece to validate that a certain process or formulation is appropriate.
To help the food industry understand, design and apply good validation and verification practices, the Institute for Food Safety and Health (IFSH) published “Validation and Verification: A Practical, Industry-driven Framework Developed to Support the Requirement of the Food Safety Modernization Act (FSMA) of 2011.” This insightful document provides various definitions, guidance, practical advice, and offers several Dos and Don’ts on validation and verification activities.
Divide validation and verification into separate tasks
Think of validation as your scientific evidence and proof the system controls the hazards
Use science-based information to support the initial validation
Use management to participate in validation development and operations of verification
Use lessons from “near-misses” and corrections to adjust and improve the food safety system
Confuse the activities of verification with those of routine monitoring
Rely on literature or studies that are unlike your process/ product to prove controls are valid
Conduct audit processes and then not review the results
Perform corrective actions without determining if a system change may be needed to fix the problem
Forget, reanalysis is done every three years or sooner if new information or problems suggest
Analytical methods used to verify a validated food process must also be validated for the specific product and conditions under which they will be conducted. For example, a manufacturer that has their laboratory test a product for Salmonella to verify that a kill step in the manufacturing process worked, must ensure that the method the laboratory uses is both validated for that product and has been verified as appropriate for use in that laboratory. Three general considerations should be discussed with the laboratory:
Is the method validated for the product (matrix)?
Often, the method will carry several matrix validations that were previously conducted by the diagnostic provider, an industry organization or as a reference method.
If the matrix to be tested is not validated the laboratory should conduct a validation study before proceeding.
Has the laboratory verified this method on the product (matrix)?
The laboratory should demonstrate that they can indeed perform the validated method appropriately.
Verification activities typically involve a matrix specific spiked recovery.
Are there any modifications made to the validated method?
All method modifications should be validated and verified. Additionally, modification should be noted on the laboratory report or Certificate of Analysis issued.
Method modifications may include time and temperature alterations, media changes and sample preparation factors.
AOAC International is an organization that certifies the validation of methods to a specific prescribed standard. “Diagnostic companies seek AOAC approval, which entails rigorous validation protocol with the selected matrices,” says Ronald Johnson Ph.D., president of AOAC International and associate director of validation for bioMérieux, describes the importance of commercial standardization. “The AOAC validation scheme ensures that the method is robust, rugged, inclusive and exclusive, stable and meets the sensitivity presented.” Standards such as these provide confidence to the user that the method is fit-for-purpose, a critical first step in method selection.
While many diagnostic companies will perform standardized validation as described above, how a laboratory validates and verifies a method is incredibly nuanced in the food industry. Currently, there is no standardized approach to study design and execution. Even ISO 17025 accredited laboratories are only required to have a validation and verification protocol—there is no dictation about what that protocol should look like.
“Currently, there is a lot of variation in the industry around [method] validation,” says Patrick Bird, microbiology R&D laboratory supervisor at Q Laboratories. Bird is a method validation expert who is on the U.S. ISO TAG TC34/SC9 working group 3 for the new ISO validation and verification standards, including ISO/DIS 16140-4 guidelines, “Microbiology of the food chain – Method Validation – Part 4: Protocol for single-laboratory (in-house) method validation.”
“Variables such as number of replicates, spike levels, and even acceptance criteria vary widely from lab to lab—both in manufacturing laboratories and contract testing laboratories. We hope the ISO guidelines will standardize that, ” says Bird. He goes on to discuss the importance of good laboratory stewardship in the industry. “While some look at validations as a proprietary or competitive advantage, the testing industry must realize that without standardization, poor validation and verification practices by a few can tarnish the great science done by the many, and ultimately jeopardize the safety of our food supply.” He stresses the importance of quality operations and open communications with laboratories, whether in house or third party. “Now that validation is highlighted as a required area in FSMA Preventive Controls, more and more companies are paying attention to the methods and associated validation/verification data their labs can provide.”
The previous article discussed the various decontamination options available to eliminate Listeria. It was explained why the physical properties of gaseous chlorine dioxide make it so effective. This article focuses on one company’s use of chlorine dioxide gas decontamination for both contamination response and for preventive control.
The summer of 2015 saw multiple ice cream manufacturers affected by Listeria monocytogenes. The ice cream facility detailed in this article never had a supply outage, but ceased production for a short amount of time in order to investigate and correct their contamination. After a plant-wide review of procedures, workflows, equipment design and product testing, multiple corrective actions were put into place to eliminate Listeria from the facility and help prevent it from returning. One such corrective action was to decontaminate the production area and cold storage rooms using chlorine dioxide gas. This process took place after the rest of the corrective actions, so as to decontaminate the entire facility immediately before production was set to resume.
The initial decontamination was in response to the Listeria monocytogenes found at various locations throughout the facility. A food safety investigation and microbiological review took place to find the source of the contamination within the facility in order to create a corrective action plan in place. Listeria was found in a number of locations including the dairy brick flooring that ran throughout the production area. A decision was made to replace the flooring, among other equipment upgrades and procedural changes in order to provide a safer food manufacturing environment once production resumed. Once the lengthy repair and upgrade list was completed, the chlorine dioxide gas decontamination was initiated.
The facility in question was approximately 620,000 cubic feet in volume, spanning multiple rooms as well as a tank alley located on a different floor. The timeline to complete the decontamination was 2.5 days. The first half-day consisted of safety training, a plant orientation tour, a meeting with plant supervisors, and the unpacking of equipment. The second day involved the setup of all equipment, which included chlorine dioxide gas generators, air distribution blowers, and a chlorine dioxide gas concentration monitor. Gas injection tubing was run from the chlorine dioxide gas generators throughout the facility to approximately 30 locations within the production area. The injection points were selected to aid its natural gaseous distribution by placing them apart from one another. Gas sample tubing was run to various points throughout the facility in locations away from the injection locations to sample gas concentrations furthest away from injection points where concentrations would be higher. Sample locations were also placed in locations known to be positive for Listeria monocytogenes to provide a more complete record of treatment for those locations. In total, 14 sample locations were selected between plant supervisors and the decontamination team. Throughout the entire decontamination, the gas concentration monitor would be used to continuously pull samples from those locations to monitor the concentration of chlorine dioxide gas and ensure that the proper dosage is reached.
As a final means of process control, 61 biological indicators were brought to validate that the decontamination process was effective at achieving a 6-log sporicidal reduction. 60 would be placed at various challenging locations within the facility, while one would be randomly selected to act as a positive control that would not be exposed to chlorine dioxide gas. Biological indicators provide a reliable method to validate decontamination, as they are produced in a laboratory to be highly consistent and contain more than a million bacterial spores impregnated on a paper substrate and wrapped in a Tyvek pouch. Bacterial spores are considered to be the hardest microorganism to kill, so validating that the process was able to kill all million spores on the biological indicator in effect also proves the process was able to eliminate Listeria from surfaces. The biological indicators were placed at locations known to be positive for Listeria, as well as other hard-to-reach locations such as the interior of production equipment, underneath equipment and inside some piping systems.
In order to prepare the facility for decontamination, all doors, air handling systems, and penetrations into the space were sealed off to keep the gas within the production area. After a safety sweep for personnel, the decontamination was performed to eliminate Listeria from all locations within the production area.
By Douglas Marshall, Ph.D., Gregory Siragusa No Comments
The use of genomics tools are valuable additions to companies seeking to meet and exceed validation and verification requirements for FSMA compliance (21 CFR 117.3). In this installment of Food Genomics, we present reasons why microbiome analyses are powerful tools for FSMA requirements currently and certainly in the future.
Recall in the first installment of Food Genomics we defined a microbiome as the community of microorganisms that inhabit a particular environment or sample. For example, a food plant’s microbiome includes all the microorganisms that colonize a plant’s surfaces and internal passages. This can be a targeted (amplicon sequencing-based) or a metagenome (whole shotgun metagenome-based) microbiome. Microbiome analysis can be carried out on processing plant environmental samples, raw ingredients, during shelf life or challenge studies, and in cases of overt spoilage.
As a refresher of FSMA requirements, here is a brief overview. Validation activities include obtaining and evaluating scientific and technical evidence that a control measure, combination of control measures, or the food safety plan as a whole, when properly implemented, is capable of effectively controlling the identified microbial hazards. In other words, can the food safety plan, when implemented, actually control the identified hazards? Verification activities include the application of methods, procedures, tests and other evaluations, in addition to monitoring, to determine whether a control measure or combination of control measures is or has been operating as intended, and to establish the validity of the food safety plan. Verification ensures that the controls in the food safety plan are actually being properly implemented in a way to control the hazards.
Validation establishes the scientific basis for food safety plan process preventive controls. Some examples include using scientific principles and data such as routine indicator microbiology, using expert opinions, conducting in-plant observations or tests, and challenging the process at the limits of its operating controls by conducting challenge studies. FSMA-required validation frequency first includes before the food safety plan is implemented (ideally), within the first 90 calendar days of production, or within a reasonable timeframe with written justification by the preventive controls qualified individual. Additional validation efforts must occur when a change in control measure(s) could impact efficacy or when reanalysis indicates the need.
FSMA requirements stipulate that validation is not required for food allergen preventive controls, sanitation preventive controls, supply-chain program, or recall plan effectiveness. Other preventive controls also may not require validation with written justification. Despite the lack of regulatory expectation, prudent processors may wish to validate these controls in the course of developing their food safety plan. For example, validating sanitation-related controls for pathogen and allergen controls of complex equipment and for how long a processing line can run between cleaning are obvious needs.
There are many routine verification activities expected of FSMA-compliant companies. For process verification, validation of effectiveness, checking equipment calibration, records review, and targeted sampling and testing are examples. Food allergen control verification includes label review and visual inspection of equipment; however, prudent manufacturers using equipment for both allergen-containing and allergen-free foods should consider targeted sampling and testing for allergens. Sanitation verification includes visual inspection of equipment, with environmental monitoring as needed for RTE foods exposed to the environment after processing and before packaging. Supply-chain verification should include second- and third-party audits and targeted sampling and testing. Additional verification activities include system verification, food safety plan reanalysis, third-party audits and internal audits.
Verification procedures should be designed to demonstrate that the food safety plan is consistently being implemented as written. Such procedures are required as appropriate to the food, facility and nature of the preventive control, and can include calibration of process monitoring and verification instruments, and targeted product and environmental monitoring testing.
Most recently we have seen an increase in foodborne illness outbreaks from Listeria to Salmonella to Norovirus to E.coli, many of which are a result of post-lethal contamination of processed foods. This is often a direct result of a gap in the sanitation programs that were in place at the processing facilities. Every facility should conduct a sanitation gap analysis on an annual basis. In order to receive unbiased feedback, this activity is best performed by a third party that is not a chemical provider.
Join Gina Kramer at the Listeria Detection & Control Workshop, May 31–June 1 in St. Paul, MN | LEARN MOREDeveloping and implementing a sound environmental hygiene program at a food processing facility is essential to its success in producing safe food for consumer consumption. There are fundamental basics of sanitation that every plant must follow in developing a strong program. The fundamental basics include: Developing sanitation standard operating procedures (SSOPs) for; Floors and drains, walls, ceilings, equipment and utensils, and employees. SSOPs must also contain perimeter control, foot traffic control into food preparation areas, zoning, and environmental sampling procedures.
When developing SSOPs, using the proper risk reduction formula will lead to sanitation success. To determine the best risk reduction formula, I sought the advice of sanitation expert, Jeff Mitchell, vice president of food safety at Chemstar. Before working for Chemstar, Mitchell was the Command Food Safety Officer for the United States Department of Defense (DOD). Serving more than 20 years for the DOD has given him the opportunity to visit thousands of processing facilities all over the world, seeing the best and the worst, and assisting in finding the root cause of contamination issues and negative environmental sampling results. In this article, I share Mitchell’s risk reduction formula for sanitation success and how to use the formula to build a solid and successful sanitation program.
“An understanding of the difference between transient and persistent (or resident) pathogens is a key part in the foundational science of sanitation solutions,” explained Mitchell as we discussed the details of the risk reduction formula. Transient pathogens are those that are introduced to the processing facility from the external environment. Entrance occurs from deliveries on transportation vehicles and pallets, food, and non-food products and its packaging, employees and visitors, pests and rodents, along with leaks in the roof or improper cleaning of drains, which are known reservoirs.
“Persistent pathogens are those pathogens that establish residency within the processing facility. Most bacteria will aggregate within a biofilm, allowing them to live in communities. A biofilm is a survival mode for the bacteria; it protects it from sanitizer penetration. The biofilm layers actually masks it from sampling detection. You could swab a surface or an area and not get a positive pathogen test result, because the biofilm is masking it,” Mitchell stated. He continued to explain that most contamination risks are likely from established populations. Four things need to exist for resident populations to form: Pathogen introduction, water, trace organics and niche area for attachment and growth. Food processing facilities should be most concerned about these populations, as they’re being traced to many recent outbreaks and recalls.
In his experience, Mitchell shared that sanitation efforts should focus on areas within the processing facility where moisture and nutrients are collected; both are needed for biofilm formation. Disruption of these niche areas containing biofilm can result in direct (food contact) and indirect (non-food contact) contamination if the biofilm is not completely penetrated or removed. This can occur through active and passive dispersal of pathogens. Active dispersal refers to mechanisms that are initiated by the bacteria themselves where they naturally eject from the biofilm and land on other surfaces. Passive dispersal refers to biofilm cell detachment that is mediated by external forces that shear the biofilm, causing it to move and further spread. This can be caused through fluid shear, abrasion and/or vibration due to power washing, equipment vibration, or deep cleaning/scrubbing that does not penetrate and remove all the aggregate layers of biofilm. In other words, the biofilm and pathogens are just smeared around the facility like cleaning a mirror with a greasy wiping cloth.
Chemistry and Application
The cleaning matrix must be considered to properly remove soils that house both transient and persistent pathogens. This is done by combining proper cleaning and sanitizing agent concentration (PPM), adequate exposure time, proper temperature and mechanical action (agitation) or good old elbow grease. If there is a decrease in one area of the matrix, then an increase in the other areas needs to be made as an accommodation to the cleaning process. My years working in industry have taught me that the most expensive quadrant of the cleaning matrix is agitation, because it requires manual labor. Reduction of labor is one of the first ways companies build in efficiencies to increase profit margins. That means a solution must be built that focuses on temperature, concentration and proper contact time to produce the sanitation results necessary to prevent persistent pathogens from establishing residency within processing facilities.
Temperature should be regulated by the type of soils that need to be removed. High fat soils need a higher temperature of about 140⁰ F. However, when removing high protein soils, the temperature needs to be reduced so that the protein is not baked onto the surface. Baked proteins that are not removed become nutrients for bacteria to aggregate and reside. High temperature is does not work in every food processing plant, Jeff explained.
Proper balance of detergent and sanitizer is necessary to remove and destroy both transient and persistent pathogens. The detergent needs to be the right formulation and contact time to break down soils and biofilms with application of the right concentration and contact time of sanitizer to kill the exposed pathogens. Without the right balance in place it can create the perfect storm for spread and contamination within the processing facility.
Do your homework. Research is the most valuable tool when validating the effectiveness of a cleaning process. Private research is good but not the only form of validation on which to base a business decision. I have found that peer reviewed published research is best to use in validating all quadrants of the cleaning matrix. Academic research based on sound science that has practical application results is worth the investment to make sound business decisions.
Many products have been developed to penetrate and destroy the biofilm layers that bacteria aggregate. Again, do your homework. Choose a product that also provides a pathogen kill once the biofilm has been penetrated. I cannot stress enough to make sure that the SSOPs follow the manufacturer’s validated processes and the sanitation team follows the SSOPs’ directions.
Applying the desired solution requires dividing the processing facility into zones to designate specific sanitation requirements. This will assist in the development of specific SSOPs that apply the right solution in the right zone throughout the site.
Mitchell also gave great advice about cleaning tools and cleaning chemical basics. He explained that a facility should color code the cleaning tools according to zone and only use them in the designated zone area. This prevents cross contamination from occurring, because cleaning tools can be vehicles of contamination transfer. Utilize foam detergents and foam sanitizers as they are more forgiving and increase contact time, and sanitation crew can see where they have applied the chemicals. Use the Ross-Miles foam test for stability: Foam should last more than three minutes before breaking and turning into a liquid solution that runs down the drain, costing a site money and opening up the potential for introducing pathogens into production rooms.
Mitchell advised the development of sanitation procedures that focus on daily thorough cleaning of everything from the knees down in Zones 1-3. “You want to knock everything down and keep it down. The objective is to keep bacterial creep from occurring,” he said. “Creep is where bacteria are moved by processes like water spray, splash and aerosolization, causing the bacteria to move from one area (it usually develops on the floor) to then move up walls and the legs of equipment, etc.— eventually causing contamination of food during food production and packaging.” Obviously, all food contact surfaces in Zone 1 need to have specialized SSOPs according to the equipment, food processing shifts per day, and type of foods that are being processed.
Mitchell stressed that perimeter and foot traffic control entry programs should incorporate a good foam sanitizer that stands up to the Ross-Miles test with optimal duration of five minutes. The distribution of the foam should cover a large enough area that the employees’ foot path and equipment must travel through the foam to achieve contact to control transient pathogen entrance into Zones 1–3. Concentration levels of these areas should be at least double what the food contact area strength is for effectiveness of log kill needed for control.
Environmental monitoring procedures should follow the zoning process set up for sanitation. “Swabbing for Adenosine Triphosphate (ATP) and/or Aerobic plate count (APC) are tools that can be used to help identify biofilm locations. One thing to note is that the bacteria located under the biofilm are in a modified dormant state requiring less energy and making less ATP available for detection. With that said, ATP and APC swabbing are still both viable tools to use in sanitation verification,” said Mitchell. If you only test for general risk pathogens in your facility you may receive false negatives due to biofilm masking the pathogen from showing up as a positive in environmental testing. Utilizing both general pathogen, ATP and APC in concert, is the best combination in a facility’s environmental monitoring program. The goal is to seek and find then destroy and verify.
I recently discovered a great biofilm visual detection test from Realzyme that is wonderful to use to verify whether the sanitation system in place is working. It can also differentiate between protein build-up and biofilm formation. In my professional opinion, this visual detection test is essential to incorporate in a robust environmental testing system.
Safe Food: The End Product
Our responsibility as food safety/quality professionals is to provide the safest, most delicious food for our customers to enjoy. To ensure safe food in our end product, we need to develop a robust sanitation and environmental testing program that follows the risk reduction formula (Foundational Science + Chemistry & Application + Validation = Solution) and conduct an annual sanitation gap analysis by a third-party expert for continuous improvements.
Apply these steps to protect your food, protect your brand and protect your customers so that they Savor Safe Food in every bite!
Although commonly overlooked, microbiological method validation studies are the linchpins of entire quality programs, and method validations done without rigor are crippling our industry’s ability to truly ensure the quality and safety of foods on a daily basis.
Food quality managers, it is time we discussed the critical importance of validation studies in the quality lab. Although commonly overlooked, microbiological method validation studies are the linchpins of entire quality programs, and method validations done without rigor are crippling our industry’s ability to truly ensure the quality and safety of foods on a daily basis. This article discusses the purpose and importance of microbiological method validation studies and why the food industry should insist on validation study designs of maximum rigor and validity.
What is a microbiological method, and what exactly is a validation study?
A microbiological method, for the purposes of this discussion, is any microbiology test or assay used in the food industry. It may be a test for indicator organisms such as Coliforms or yeast and mold, pathogens such as Salmonella or E. coli O157, or toxins secreted by microorganisms such as Staphylococcal enterotoxin.
A validation study is a one-time study that food safety risk managers complete in order to assure themselves that a new microbiological method produces accurate results that will enable them to effectively measure and manage food safety risk. A validation study is conducted in the actual lab where testing will be performed, with current laboratory analysts, with the specific formulations of foods that are tested regularly.
Food industry regulators and certifying bodies such as SQF expect food producers to use microbiological test methods that are proven fit for use on specific foods. If we are to draw inferences about the fitness of a new test method on specific foods, then we must study how that new test method compares to an accepted reference method, or “gold standard” method. Reference methods are those written in the Food and Drug Administration’s Bacteriological Analytical Manual, the United States Department of Agriculture’s Microbiological Laboratory Guidebook, or ISO methods. Regulators and experts agree that these methods represent the standard to which all other tests should measure up. Methods certified by the Association of Analytical Communities (AOAC) are not considered reference methods and must be validated as fit for use on foods that are appreciably different from the matrices studied. Likewise, AOAC Performance Tested Method (PTM) and Official Methods of Analysis (OMA) certificates are not substitutes for internal validation studies in any given food plant.
In my experience working with quality labs across the United States, I have seen several different validation study designs used to evaluate alternative, more rapid and cost-effective microbiological methods. Some common validation study designs are shown in Table 1. Multiple alternative tests are available, however an internal validation study is needed regardless of the test kit manufacturer. Rarely does a validation study include a comparison to agar plates, which are required for almost every microbiological reference method. Material costs, labor costs, and emergency situations typically prohibit food labs from conducting a rigorous validation study that can speak to the performance of a new method in relation to the current gold standard.
Table 1: Scientific Questions Inherent in Food Microbiology Method Validation Study Designs
Validation Study Design
Inherent Scientific Question
Does Study Explain Performance of New Test?
Test positive or spiked samples side by side on reference method and the new test
Does the test perform comparably to the reference method on my food?
Test positive or spiked samples on the new test
Regardless of accuracy, can the test detect certain or specific bacteria in my food?
No, but may be useful to understand workflow
Test any samples side by side on current AOAC certified method and new test
How do the new test’s results compare to my current AOAC certified method on my food?
No, but may be useful to understand workflow
Test any positive or negative samples on the new test
Will the new test’s workflow improve my lab’s efficiency?
No, but may be useful to understand workflow
This table presents several validation study designs common in the food industry and the scientific questions that are addressed by each design.
It is in the best interests of food producers and the public’s health to conduct rigorous validation studies that give food safety risk managers good information to make correct risk management decisions. In theory, some percentage of unsolved epidemiological foodborne illness clusters must be due to incorrect risk management decisions that allowed contaminated products to reach the market. At the same time, some percentage of all food lot rejections and recalls must be made incorrectly. A portion of these events must be related to food matrix interference that yielded incorrect microbiological results and caused the wrong risk management decision. As they say, “Garbage in, garbage out.”
In addition, including a comparison to agar reference methods in your microbiological method validation study is critical, as it reduces your chances of making an incorrect risk management decision.
Look at things this way: Plants certified with a GFSI accredited quality scheme have already put in effort to ensure analytical equipment such as thermometers and scales are calibrated. Similarly, validating microbiological methods against a reference method is equally if not more important. Finished product microbiology results inform decisions made every day that affect your profits and losses, and those results are likely a primary metric you use to study the effectiveness of your prerequisite programs and preventative controls.
Consider a quality lab that is using an alternative microbiological method that has not been rigorously validated with the plant’s specific foods. Unknown to the lab, the test results every day are twice as variable as the reference agar method and are frequently inaccurate relative to the plant’s product specifications. A rigorous method validation would demonstrate that results on the current method vary widely, while the same samples are consistent with a reference method. This well-intentioned plant is unknowingly making incorrect risk management decisions not just multiple times per year, but multiple times per week, either accidentally releasing contaminated product, reworking product that is acceptable, or disposing of perfectly good product. For the millions of dollars the food producer invests in prerequisite programs, preventative controls, quality personnel, and testing, the plant is unable to optimize their food safety risk management simply due to an unknown and overlooked incompatibility of the microbiological method with the plant’s product.
In my estimation, the costs of rigorously validating a microbiological method on all of your food products outweigh the potential hidden costs that could result from method incompatibility. The business case justifying the costs of a validation study are strong and compelling. And learning how to apply current microbiological methods specific to your foods is not as hard as you might think, considering the large host of test manufacturers, third-party labs, consultants, food safety extensions, and industry groups available to regularly provide study design education and services.
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