Tag Archives: verification

Earl Arnold, AIB International
FST Soapbox

HACCP is the Past, Present and a Building Block for the Future

By Earl Arnold
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Earl Arnold, AIB International

“Food safety plan” is a term often used in the food industry to define an operation’s plan to prevent or reduce potential food safety issues that can lead to a serious adverse health consequence or death to humans and animals to an acceptable level. However, depending on the facility, their customers, and or regulatory requirements, the definition and specific requirements for food safety plans can be very different. To ensure food safety, it’s important that the industry finds consensus in a plan that is vetted and has worked for decades.

One of the first true food safety plans was HACCP. Developed in 1959 for NASA with the assistance of the food industry, its goal was to ensure food produced for astronauts was safe and would not create illness or injury while they were in space. This type of food safety plan requires twelve steps, the first five of which are considered the preliminary tasks.

  1. Assemble a HACCP team
  2. Describe the finished product
  3. Define intended use and consumer
  4. Create process and flow diagram
  5. Verify process and flow diagrams

This is followed by the seven principles of HACCP.

  1. Conduct the hazard analysis
  2. Identify critical control points
  3. Establish critical limits
  4. Establish monitoring requirements
  5. Establish corrective actions for deviations
  6. Procedures for verification of the HACCP plan
  7. Record keeping documenting the HACCP system

HACCP is accompanied by several prerequisites that support the food safety plan, which can include a chemical control program, glass and brittle plastics program, Good Manufacturing Practices (GMPs), allergen control program, and many others. With these requirements and support, HACCP is the most utilized form of a food safety plan in the world.

When conducting the hazard analysis (the first principle of HACCP), facilities are required to assess all products and processing steps to identify known or potential biological, chemical and physical hazards. Once identified, if it is determined that the hazard has a likelihood of occurring and the severity of the hazard would be great, then facilities are required to implement Critical Control Points (CCP) to eliminate or significantly reduce that identified hazard. Once a CCP is implemented, it must be monitored, corrective actions developed if a deviation in the CCP is identified and each of these are required to be verified. Records then also need to be maintained to demonstrate the plan is being followed and that food safety issues are minimized and controlled.

HACCP is, for the most part, the standard food safety plan used to meet the Global Food Safety Initiative (GFSI) standards. This is utilized in various third-party audit and customer requirements such as FSSC 22000, SQF, BRC, IFS and others. These audit standards that many facilities use and comply with also require the development of a food safety management system, which includes a food safety plan.

Further, HACCP is often used to demonstrate that potential food safety issues are identified and addressed. FDA has adopted and requires a regulated HACCP plan for both 100% juice and seafood processing facilities. USDA also requires the regulated development of HACCP for meat processing and other types of facilities to minimize potential food safety issues.

For facilities required to register with the FDA—unless that facility is exempt or required to comply with regulated HACCP—there is a new type of food safety plan that is required. This type of plan builds upon HACCP principles and its steps but goes beyond what HACCP requires. Under 21 CFR 117, specific additions assist in identifying and controlling additional food safety hazards that are on the rise. This includes undeclared allergen recalls, which constituted 47% of recalls in the last reportable food registry report published by FDA.

Prior to developing this plan, FDA provided recommendations for preliminary steps that can be completed and are essential in development of a robust food safety plan but are not a regulatory requirement. The steps are very similar to the preliminary tasks required by HACCP, including the following:

  1. Assemble a food safety team
  2. Describe the product and its distribution
  3. Describe the intended use and consumers of the food
  4. Develop a flow diagram and describe the process
  5. Verify the flow diagram on-site

Their recommended plan also requires a number of additional steps, including:

  1. A written hazard analysis. Conducted by or overseen by a Preventive Controls Qualified Individual (PCQI). However, this hazard analysis requires assessing for any known or reasonably foreseeable biological, chemical, physical, radiological, or economically motivated adulteration (food fraud that historically leads to a food safety issue only). You may note that two additional hazards—radiological and EMA—have been added to what HACCP calls for in the assessment.
  2. Written preventive controls if significant hazards are identified. However, similar preventive controls are different than a CCP. There are potentially four types of preventive controls that may be utilized for potential hazards, including Process Preventive Controls (the same as CCP), Allergen Preventive Controls, Sanitation Preventive Controls, Supply Chain Preventive Controls and Others if identified.
  3. A written supply chain program if a Supply Chain Preventive Control is identified. This includes having an approved supplier program and verification process for that program.
  4. A written recall plan if a facility identified a Preventive Control.
  5. Written monitoring procedures for any identified Preventive Control that includes the frequency of the monitoring what is required to do and documenting that monitoring event.
  6. Written corrective actions for identified Preventive Controls in case of deviations during monitoring. Corrective actions must be documented if they occur.
  7. Written verification procedures as required. This could include how monitoring and corrective actions are verified, procedures themselves are verified, and calibration of equipment as required. Also required is training, including a Preventive Control Qualified Individual. Additional training is required for those individuals responsible for performing monitoring, implementing corrective actions, and verification of Preventive Controls. Further, all personnel need to have basic food safety training and all training needs to be documented.

While the term “food safety plan” is used widely, it’s important that operations don’t just use the term, but enact a plan that is vetted, proven to work, and encompasses the principles of HACCP. Doing so will help ensure that their facility is producing foods that customers and consumers will know is safe.

James Davis, OSI Group
FST Soapbox

Applying Food Plant Sanitation Best Practices to Facility Janitorial Programs

By James T. Davis
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James Davis, OSI Group

The COVID-19 pandemic propelled food processors to scrutinize various aspects of their existing employee hygiene and environmental safety programs in an effort to protect facility workers’ health. Implementation of measures such as social distancing, illness screening, workspace barriers, additional personal protective equipment (PPE) and enhanced cleaning measures have aided the industry in reducing employee sickness and unplanned shutdowns.1 Of these actions, effective cleaning protocols in non-production areas, under the scope of facility janitorial programs, have been brought to heightened attention as a critical preventative measure for surface contamination of SARS-CoV-2.1 Through incorporation of the fundamental principles of sanitation programs utilized for food production zones, processors can elevate the effectiveness of their janitorial cleaning programs in non-production areas.

Scope of Janitorial Program

Food processing facilities should evaluate, using a risk-based assessment, all non-production areas that employees occupy on a routine basis, for inclusion into the janitorial cleaning program. Examples of areas that are routinely subject to high employee traffic and regular congregation include, but are not limited to, locker rooms, restrooms, break rooms, cafeterias, hallways, conference rooms and offices.

Additionally, specific surfaces within each of the identified non-production areas for inclusion into the program should also be evaluated in the risk-based assessment. Surfaces within these identified areas that are frequently touched, and present a greater likelihood of contamination to employees, would be considered higher-risk, and thus, command more focus during routine janitorial cleaning activities. Examples of such surfaces may include the following: Door handles, tables, desks, chairs, toilet and faucet handles, vending machines, phones, computers and other electronic devices.

Janitorial Best-Practice Examples

Sanitation Standard Operating Procedures
Sanitation standard operating procedures (SSOPs), or written cleaning instructions, should be developed for all janitorial cleaning tasks of selected employee and welfare areas, in a similar manner as those for production area equipment and infrastructure. These documents should contain pertinent information to effectively perform the desired janitorial tasks, such as the following: The individual(s) responsible for the task, appropriate chemicals, personal protective equipment (PPE) and other safety measures, frequency of cleaning, steps of cleaning execution and verification measures.

Chemical Selection & Use
Selection of chemicals for cleaning of employee and welfare areas is critically important in ensuring biological agents are effectively removed from surfaces during janitorial activities. Much like in production areas, the facility janitorial cleaning program should utilize an appropriate detergent suitable for removing residual surface soils as a base of the program. Inadequate removal of soils, such as grease or food debris in break rooms, will inhibit the effective removal of adverse biological agents.2 Additionally, the program should include an application of sanitizer or disinfectant to the target surface effective in neutralizing SARS-CoV-2.3

Cleaning Process & Frequency
An effective cleaning process for routine janitorial tasks can be modeled after the established Seven Steps of Sanitation commonly utilized in food production zones.4 Typical steps in this process applicable for janitorial cleaning should include: area preparation and dry cleaning, wiping surfaces with fresh water, application and wiping with detergent, removal of detergent with fresh water wiping, inspection verification activities and application of sanitizer or disinfectant to target surfaces for required dwell time (subsequent wiping of chemical after dwell time may be required). The frequency of cleaning and additional sanitizing activities should be validated and take into consideration times of employees breaks, level of non-production area occupancy and extent of employee contact with higher-risk surfaces. Additionally, individuals who performed the required cleaning tasks should ensure appropriate PPE is worn, not only to protect from chemicals utilized, but from biological agents that may be present on surfaces.

Master Sanitation Schedule
A master sanitation schedule, or MSS, encompassing janitorial cleaning activities that occur on a non-daily basis should be maintained either separately, or included in an existing sanitation schedule.

Sanitation, misting
Misting frequently touched surfaces with an additional disinfectant chemical approved to inactivate SARS-Cov-2. Image courtesy of OSI Group.

Examples of non-routine janitorial tasks may include:

  • Emptying and cleaning of personnel storage lockers
  • Cleaning of difficult-to-access surfaces for daily cleaning, such as ceilings, walls and around vending machines
  • Misting of frequently touched surfaces, or entire rooms, with an additional disinfectant chemical approved to inactivate SARS-Cov-2

The appropriate frequencies of these non-routine tasks should be validated through a risk-based assessment and continually verified to ensure effectiveness.

Employee Training
All employees who are required to perform routine and non-routine janitorial tasks should be fully trained and records maintained. This should not only include adequate training knowledge of required practices and documentation, but also chemical selection and handling specific to janitorial activities. Retention of knowledge should be verified and included in existing facility training programs. Routine auditing of the cleaning practices by facility personnel will ensure continued acceptable outcomes of the program.

Documentation

Completion of all janitorial cleaning activities should be documented and records maintained following similar practices for sanitation in production areas. As a best practice, documentation, such as checklists, should be made visible to employees who utilize the welfare areas as a means to convey facility hygiene practices and ease potential health concerns.

Validation & Verification of Cleaning Effectiveness
To ensure an established janitorial cleaning program for non-production areas is effective in achieving appropriate hygiene outcomes, the facility must validate and routinely verify the process. Validating the effectiveness of janitorial programs can be undertaken in much the same manner as performed for the traditional sanitation process in food production zones. A combination of visual inspection, environmental sampling and other methods should be utilized both during the validation and subsequent routine verification process. Specific to the COVID-19 pandemic, several contract laboratories offer surface environmental testing for SARS-CoV-2 (via RT-qPCR) that should be incorporated into janitorial validation and verification protocols.2,5 Routine absence of the virus will assist in demonstrating effectiveness of the facility janitorial cleaning program.

Conclusion

With the increased scrutiny of employee welfare during the COVID-19 pandemic, maintaining effective facility hygiene remains a critical goal of food processing facilities. Through incorporation of current sanitation best practices utilized in food production zones, facilities can elevate the outcomes of their janitorial cleaning programs, ensuring effective hygiene.

References

  1. North American Meat Institute. (November 12, 2020). Significant Events and Progress Involving the Meat and Poultry Industry during the COVID-19 Pandemic.
  2. American Society for Microbiology. (October 8, 2020). Detecting SARS-CoV-2 in the Environment.
  3. United States Environmental Protection Agency. (November 25, 2020). List N: Disinfectants for Coronavirus (COVID-19).
  4. International Association of Food Protection. (December 7, 2017). Cleaning, Sanitizing and the Seven Steps of Sanitation [Webinar].
  5.  IEH Laboratories & Consulting Group. (December 2020). SARS CoV-2 Environmental Monitoring.
Food Safety Consortium

2020 FSC Episode 6 Preview: Sanitation Issues

By Food Safety Tech Staff
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Food Safety Consortium

The integration of sanitation is a critical part of the food manufacturing process. This week’s episode of the 2020 Food Safety Consortium Virtual Conference Series will focus on effective approaches, best practices and lessons learned. The following are some highlights:

  • Sanitation Methods, Day-to-Day Operations and Applying It to a Pandemic (Now and Future Outbreaks), with Elise Forward, Forward Food Solutions; David Shelep, Paramount Sciences; and Bill Leverich, Microbiologics, Inc.
  • The Critical Nature of a Good Environmental Program: The Story Behind Sabra’s Recall, Experience with the FDA, and Environmental Monitoring Journey, with Rob Mommsen, Sabra Dipping Company
  • Surrogates & Emerging Applications: Their Role in Validation, Verification and Compliance, with Laure Pujol, Ph.D. and Vidya Ananth, Novolyze
  • Tech Talks from Sterilex and Romer Labs

The event begins at 12 pm ET. Haven’t registered? Follow this link to the 2020 Food Safety Consortium Virtual Conference Series, which provides access to 14 episodes of critical industry insights from leading subject matter experts! We look forward to your joining us virtually.

Checklist

2020 FSC Episode 3 Wrap: Does Your Company Have a COVID Czar?

By Maria Fontanazza
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Checklist

Navigating the murky waters that COVID-19 presents has been no easy task for food companies. Being part of America’s critical infrastructure has meant that adapting to the pandemic has been unavoidable, and the industry has directly taken on the challenges to ensure the nation has a reliable food supply. But what about the frontline workers, their safety and how this ties into operational continuity as a whole? During last week’s episode of the 2020 Food Safety Consortium Virtual Conference Series, an expert panel discussed the practices that food companies have put in place during the pandemic and offered advice on managing the entire scope of COVID-19 challenges including screening employees and preventing infection transmission, safeguarding workers and the facility, administrative and engineering controls, education and training, and risk management.

“No doubt that it is a concert of controls and interventions that have allowed our industry to effectively combat this over the past several months,” said Sanjay Gummalla, senior vice president of scientific affairs at the American Frozen Foods Institute. “By and large, the industry has taken charge of this situation in a way that could not have been predicted.” Gummalla was joined by Trish Wester, founder of the Association for Food Safety Auditing Professionals and Melanie Neumann, executive vice president and general counsel for Matrix Sciences International.

First up, the COVID Czar—what is it and does your company have one? According to Neumann, this is a designated person, located both within a production facility as well as at the corporate location, who manages the bulk of the requirements and precautions that companies should be undertaking to address the pandemic. “We’re not trained in people safety—we’re trained in food safety,” said Neumann. “And it’s a lot to ask, especially on top of having to manage food safety.”

Some of the takeaways during the discussion include:

  • Administrative controls that must be managed: Appropriate cleaning, disinfection and sanitation; PPE; employee hygiene; shift management; and surveillance mechanisms
  • PPE: “It’s really clear now that face masks and coverings are critical in managing source control—it prevents the spread and protects other employees,” said Gummalla. “All employees wearing masks present the highest level of protection.” When the attendees were polled about whether face coverings are mandatory where they work, 91% answered ‘yes’.
  • Engineering controls within facility: Physical distancing measures such as plexiglass barriers, six-foot distance markings, traffic movement, limited employees, and hand sanitizer stations. “Engineering controls in a facility involve isolation from the virus,” said Gummalla. “In this case, controlling [and] reducing the exposure to the virus without relying on specific worker behavior. This is where facilities have implemented a great amount of thoughtful intervention, probably at a high capital cost as well.” Companies should also consider airflow management, which can involving bringing in an outside professional with expertise in negative and positive air pressure, advised Wester.
  • Verification activities and enterprise risk management: Neumann emphasized the importance of documentation as well as advising companies to apply a maturity model (similar to a food safety culture maturity model) to a COVID control program. The goal is to ensure that employees are following certain behaviors when no one is watching. “We want to be able to go from ‘told’ to ‘habit’,” she said.
  • Education and training: Using posters, infographics, brochures and videos, all of which are multilingual, to help emphasize that responsibility lies with every employee. “It is important to recognize the transmission is predominately is person to person,” said Gummalla. Do you have a daily huddle? Neumann suggests having a regular dialogue with employees about COVID.
  • The future, 2021 and beyond: Does your company have a contingency, preparedness or recovery plan? “The next six months are going to be critical; in many parts of the world, the worse is not over yet,” said Gummalla. “There will be a lot more innovation in our industry, and communication will be at the heart of all of this.”

As part of a special offering, Episode 3 has been made available for viewing on demand for free. Register to view the on-demand recording.

Manuel Orozco, AIB International
FST Soapbox

Detecting Foreign Material Will Protect Your Customers and Brand

By Manuel Orozco
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Manuel Orozco, AIB International

During the production process, physical hazards can contaminate food products, making them unfit for human consumption. According to the USDA’s Food Safety and Inspection Service (FSIS), the leading cause of food recalls is foreign material contamination. This includes 20 of the top 50, and three of the top five, largest food recalls issued in 2019.

As methods for detecting foreign materials in food have improved over time, you might think that associated recalls should be declining. To the contrary, USDA FSIS and FDA recalls due to foreign material seem to be increasing. During the entire calendar year of 2018, 28 of the 382 food recalls (7.3%) in the USDA’s recall case archive were for foreign material contamination. Through 2019, this figure increased to approximately 50 of the 337 food recalls (14.8%). Each of these recalls may have had a significant negative impact on those brands and their customers, which makes foreign material detection a crucial component of any food safety system.

The FDA notes, “hard or sharp foreign materials found in food may cause traumatic injury, including laceration and perforation of tissues of the mouth, tongue, throat, stomach and intestine, as well as damage to the teeth and gums”. Metal, plastic and glass are by far the most common types of foreign materials. There are many ways foreign materials can be introduced into a product, including raw materials, employee error, maintenance and cleaning procedures, and equipment malfunction or breakage during the manufacturing and packaging processes.

The increasing use of automation and machinery to perform tasks that were once done by hand are likely driving increases in foreign matter contamination. In addition, improved manufacturer capabilities to detect particles in food could be triggering these recalls, as most of the recalls have been voluntary by the manufacturer.

To prevent foreign material recalls, it is key to first prevent foreign materials in food production facilities. A proper food safety/ HACCP plan should be introduced to prevent these contaminants from ending up in the finished food product through prevention, detection and investigation.
Food manufacturers also have a variety of options when it comes to the detection of foreign objects from entering food on production lines. In addition to metal detectors, x-ray systems, optical sorting and camera-based systems, novel methods such as infrared multi-wavelength imaging and nuclear magnetic resonance are in development to resolve the problem of detection of similar foreign materials in a complex background. Such systems are commonly identified as CCPs (Critical Control Points)/preventive controls within our food safety plans.

But what factors should you focus on when deciding between different inspection systems? Product type, flow characteristics, particle size, density and blended components are important factors in foreign material detection. Typically, food manufacturers use metal and/or x-ray inspection for foreign material detection in food production as their CCP/preventive control. While both technologies are commonly used, there are reasons why x-ray inspection is becoming more popular. Foreign objects can vary in size and material, so a detection method like an x-ray that is based on density often provides the best performance.

Regardless of which detection system you choose, keep in mind that FSMA gives FDA the power to scientifically evaluate food safety programs and preventive controls implemented in a food production facility, so validation and verification are crucial elements of any detection system.

It is also important to remember that a key element of any validation system is the equipment validation process. This process ensures that your equipment operates properly and is appropriate for its intended use. This process consists of three steps: Installation qualification, operational qualification and performance qualification.

Installation qualification is the first step of the equipment validation process, designed to ensure that the instrument is properly installed, in a suitable environment free from interference. This process takes into consideration the necessary electrical requirements such as voltage and frequency ratings, as well as other factors related with the environment, such as temperature and humidity. These requirements are generally established by the manufacturer and can be found within the installation manual.

The second step is operational qualification. This ensures that the equipment will operate according to its technical specification. In order to achieve this, the general functions of the equipment must be tested within the specified range limits. Therefore, this step focuses on the overall functionality of the instrument.

The third and last step is the performance qualification, which is focused on providing documented evidence through specific tests that the instrument will performs according to the routine specifications. These requirements could be established by internal and industry standards.

Following these three steps will allow you to provide documented evidence that the equipment will perform adequately within the work environment and for the intended process. After completion of the equipment validation process, monitoring and verification procedures must be established to guarantee the correct operation of the instrument, as well procedures to address deviations and recordkeeping. This will help you effectively control the hazards identified within our operation.

There can be massive consequences if products contaminated with foreign material are purchased and consumed by the public. That’s why the development and implementation of a strong food safety/ HACCP plan, coupled with the selection and validation of your detection equipment, are so important. These steps are each key elements in protecting your customers and your brand.

FST Soapbox

A Digital Approach to Environmental Monitoring: Let’s Get Proactive!

By David Hatch
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Technology and automation for safety and surveillance have already impacted nearly every industry in the world. For example, in the United States and many other developed regions, we have just lived through the transformation to electronic health records within the healthcare industry. Prior to that, we lived through the digital transformation of all of our banking information to an online banking platform—now the norm across the world.

However, the food and beverage industry is still learning how technology can improve their organizations. The food safety segment of this market is particularly in need of a digital transformation, as the risk associated with foodborne illness is potentially catastrophic to food companies, and moreso, to the end consumers who are impacted by preventable pathogenic outbreaks.

Along with regulation advancements, such as the timed roll-out of FSMA, the industry continues to work towards a more effective approach to food safety. But most regulations, and advancements in the industry are pointed toward a reactive stance to food safety issues, rather than a preventive stance. For example, although traceability is important in leading investigations to the source and taking remediation steps sooner, a more proactive approach to prevention should be considered when investing in food safety programs.

This is where the importance of an automated environmental monitoring program comes in. To be proactive requires a commitment to embracing data and digital technology. Knowing where to start to effectively pivot your digital approach can be a challenge.

Understanding the following thought process can help you to recognize areas of potential improvement and growth within your environmental monitoring program.

  • Define Your Business Objectives. Ask how profitability and production uptime is connected to food safety issues.
  • Verify Suppliers. Establish protocols for incoming product from external suppliers and validate their food safety performance and ability to maintain a clean facility.
  • Modernize Your Environmental Monitoring Program (EMP). Are you able to confirm that your EMP is being executed consistently? Across all facilities?
  • Understand Data Exhaust. See how your organization’s valuable data can be used to identify trends and accelerate root cause analysis that impact decision-making processes.

Define Your Business Objectives

Food companies large and small are being challenged to implement required processes and procedures to meet the demands of FSMA, and ultimately achieve a more proactive and preventative food safety stance. Transformation in this arena, led by government regulation, and enhanced by standards certification requirements, has highlighted the responsibility of suppliers and manufacturers to protect consumers.

Many organizations are not aware that a single failure in their food safety program could actually be the most devastating profitability risk that the organization faces today. When your organization is focused on production uptime and profitability, it can be easy to overlook the details involved in maintaining a strong food safety program. In reality, though, food safety and profitability are inextricably linked due to the risk of production interruptions that can be caused by safety issues.

Whenever a food recall occurs, it has the potential to start the dominoes falling, with major implications regarding costs, reputational damage, compliance penalties, supply chain interruption, and sales declines. Worse yet, these impacts can last for years after the actual event. By delaying both the importance of recognizing the seriousness of this risk as well as taking necessary steps to prevent it, your organization’s reputation could be on the line.

Unfortunately, planning is often sacrificed when managers fail to implement the proper technological solutions. Fulfilling fundamental documentation requirements involves a smart, automated approach. This is the best way to optimize recall prevention. By incorporating an automated EMP process, a supplier management system, and other FSMA Preventive Controls measures, suppliers ultimately improve the strength of the entire chain for their partners, consumers and themselves.

There are many other facets to food safety, but the EMP is where inspectors and auditors will look to see the indicators of contamination and the efficacy of your sanitation controls. Therefore, it is critical that your organization exhibit not only that you are on top of things and are following your EMP procedures consistently, but that you can analyze and pinpoint issues as they arise, and that you have a track record of corrective actions in response to those issues. This, in-turn, allows you to see where your business objectives are most at-risk.

Regardless of which specific food industry segment your company operates in, or which governing body it reports to, it’s essential to stay informed and compliant with changing regulations in order to reduce the risk of experiencing a recall. In a strategic operational role, intelligent environmental monitoring allows companies to not only proactively work to avoid public health issues, but is vital to retaining a consistent bottom line.

Verify Suppliers

Earlier this year, the FDA heralded what they call a “New Era of Smarter Food Safety”. As technology becomes increasingly accessible, more and more companies are investigating how technology can be used to harness and control the growing complexity of supply chain implications.

The challenge of making sure your organization is doing its due diligence to prevent recalls is further complicated when incorporating outside suppliers. For example, 15% of the United State’s overall food supply is imported from more than 200 other countries, according to the FDA. Making sure the product coming into a facility is also meeting your standards is vital to preventing pathogens from entering your supply chain either through containers, people, or the incoming product itself.

The complexity grows exponentially when we contemplate what this means for tracking food safety across a supply chain of this scope. Generally suppliers are asked to provide verification for the cleanliness of the product they are bringing into your facility. However, by going a step further and establishing test points for the product when it comes in, you will be better equipped to catch pathogens before they can enter into your own supply chain and potentially contaminate other products. While you may already have a good relationship with your suppliers, being able to independently verify the safety of their products and that their own processes are working, creates a mutually beneficial relationship.

Modernize Your Environmental Monitoring Program

Food experts at the World Health Organization headquarters in Geneva discussed the critical nature of ensuring food safety across geographic boundaries, as it is an issue that affects everyone. Incidents of pathogen outbreaks around the world have a direct impact on the health of global citizens, with one in 10 people falling ill due to food contamination.

A traditional EMP allows organizations to continuously verify that their sanitation programs are working by scheduling testing, monitoring results for any signs of pathogens, and maintaining compliance with regulatory bodies. Historically, this type of program is documented in spreadsheets and three-ring binders, but today the acceptance of new tools being offered by vendors and labs are expanding offerings to modernize the monitoring process.

Food safety professionals, many of whom are trained microbiologists, should have better tools at their disposal than spreadsheets that force them to manually sift through data. All regulatory bodies in the food industry have guidelines when it comes to where, what, and when you should be testing in your facilities. Ensuring that this is happening is a basic requirement for meeting regulatory mandates.

By choosing an automated EMP, FSQA teams are able to schedule testing plans including randomization and test point coverage rules, see what testing is being performed when, and obtain all testing data in one system for ease of access before or during an audit. This offers an “always-on” source of audit data and more importantly, trending and root-cause analysis capabilities to find and define actions to remediate recurring problems.

Further, an automated EMP that is integrated with your food safety plan allows you to set up workflows and automatically notify appropriate team members according to your organization’s policies. Each remediation step can be recorded and time stamped as the corrective action moves towards completion.

Understand Data Exhaust

A dominant theme pushed forward by FSMA is the need to document all aspects of your food safety plan, from the written outline to the records indicating proper implementation. Today’s manufacturers face a time of heightened regulation, and with stricter enforcement comes greater requirements for documentation. Automated EMPs not only provide your organization insight into what is happening within your facilities for documentation, it also gives time back to your FSQA team who, instead of spending their days with three ring binders, can analyze and investigate recurring issues in your facility to look for new, innovative ways for the organization to maintain a high standard of quality.

However, effective testing also means reading, understanding and responding to results. It is not enough to simply meet the required volume and frequency of environmental testing metrics. You need to use the resulting information to effect change and improvements by lowering the likeliness of pathogens, allergens and contaminants from entering the food supply chain. The more data collected, the more it leads to true understandings. What testing might show is just the symptoms of the problem—not the root cause of a far bigger problem. As more data is available, it becomes more valuable through the insights that can be gained through trend analysis. This, in turn, moves the conversation to higher levels within the organization who care about ensuring productivity and reducing avoidable risk.

Incorporating your lab into the equation is essential. Find a lab partner that offers an automated testing program that is integrated with their LIMS. Your organization will then be in a better position to ensure results are being responded to in an appropriate time frame.

There are many diagnostic tools in use today, both in-plant and at the lab. Each of these tools generates “data exhaust” in the form of a diagnostic result. But are your data streams being integrated and analyzed to find correlations and potential cause/effect relationships? Or does your ATP device simply record its data to a dedicated laptop or spreadsheet?

Testing, combined with an automated EMP, can allow you to combine data from various diagnostic systems (on-premise or from your lab partner) to identify trends and therefore a more holistic path to remediation. For this to occur, data must be accessible, aggregated and actionable, which an automated EMP achieves.

Forward-thinking companies and facility managers are leveraging valuable software solutions to improve processes, protect reputations, minimize inefficiencies, and simplify multifaceted compliance and audit tasks. Over the next three to five years, numerous organizations will reduce their risk of food recalls by combining their EMPs with analytics capabilities to reduce food risk and improve quality using diagnostic solutions and data assets. This change will be arduous, as all digital transformations in other industries have shown. But, in the end, they have shown the value and long-term success that the food industry now needs to experience.

AFSAP

FDA Issues First Import Alert for FSVP Non Compliance

By Trish Wester
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AFSAP

The Import Alert for FSVP noncompliance is applicable to any human and animal food subject to the FSVP regulation, and allows FDA to detain imported foods at the port of entry under the protocol for Detention Without Physical Examination (DWPE). DWPE is a standard enforcement tool for FDA.

July 31, 2019: FDA issued Import Alert #99-41, the first Import Alert based on noncompliance with the Foreign Supplier Verification Program (FSVP) regulation.
The FSVP Import Alert contains the following reason for the alert and the relevant charge.

Reason

“Section 805 of the FD&C Act (21 U.S.C. 384a) requires each importer of food to perform risk-based foreign supplier verification activities for the purpose of verifying that the food imported by the importer is produced in compliance with the requirements of section 418 (21 U.S.C. 350g) (regarding hazard analysis and risk-based preventive controls) or section 419 (21 U.S.C 350h)(regarding standards for produce safety) of the FD&C Act, as appropriate; and that the food is not adulterated under section 402 or misbranded under section 403(w).” – FDA

Charge

“The article is subject to refusal of admission pursuant to section 801(a)(3) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) in that it appears that the importer (as defined in section 805 of the FD&C Act) is in violation of section 805.” – FDA

Join Trish Wester for the closing plenary 2019 Food Safety Consortium panel discussion FDA Presentation on The Third-Party Certification Program | Thursday, October 3, 2019“Import alerts inform the FDA’s field staff and the public that the agency has enough evidence to allow for Detention Without Physical Examination (DWPE) of products that appear to be in violation of the FDA’s laws and regulations. These violations could be related to the product, manufacturer, shipper and/or other information,” states FDA on its webpage about import alerts.

A Trend of Increased Import Enforcement?

FDA enforcement actions in this area have recently seen a dramatic increase. Only one alert was posted in the first quarter, and less than 10 food-related alerts were posted prior to June. July 2019 saw eight food alerts, including one on radionuclides and the FSVP. FDA posted more than 30 food-related import alerts in August, and September is on a similar pace currently showing 21 food-related alerts, indicating this may be an ongoing focus for the agency.

The information in this update is provided by AFSAP, the Association for Food Safety Auditing Professionals. Please contact Patricia Wester @ trish@pawesta.com if you have any questions regarding DWPE, or to request a complete copy of the alert.

Melody Ge, Corvium
FST Soapbox

Changes in the Food Safety Industry: Face Them or Ignore Them?

By Melody Ge
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Melody Ge, Corvium

“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.

Gabriela Lopez, 3M Food Safety
Allergen Alley

Method Acting: Comparing Different Analytical Methods for Allergen Testing and Verification

By Gabriela Lopez-Velasco, Ph.D.
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Gabriela Lopez, 3M Food Safety

Every day, food industries around the world work to comply with the food labeling directives and regulations in place to inform consumers about specific ingredients added to finished products. Of course, special attention has been placed on ensuring that product packaging clearly declares the presence of food allergens including milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soy, sesame and mustard. (Additional food allergens may also be included in other regions.)

But labeling only covers the ingredients deliberately added to foods and beverages. In reality, food manufacturers have two jobs when it comes to serving the needs of their allergic consumers:

  1. Fully understand and clearly declare the intentional presence of allergenic foods
  2. Prevent the unintended presence of allergenic foods into their product

Almost half of food recalls are the result of undeclared allergens, and often these at-fault allergens were not only undeclared but unintended. Given such, the unintended presence of allergenic foods is something that must be carefully considered when establishing an allergen control plan for a food processing facility.

How? It starts with a risk assessment process that evaluates the likelihood of unintentionally present allergens that could originate from raw materials, cross-contact contamination in equipment or tools, transport and more. Once the risks are identified, risk management strategies should then be established to control allergens in the processing plant environment.
It is necessary to validate these risk management strategies or procedures in order to demonstrate their effectiveness. After validation, those strategies or procedures should then be periodically verified to show that the allergen control plan in place is continually effective.

In several of these verification procedures it may be necessary to utilize an analytical test to determine the presence or absence of an allergenic food or to quantify its level, if present. Indeed, selecting an appropriate method to assess the presence or the level of an allergenic food is vitally important, as the information provided by the selected method will inform crucial decisions about the safety of an ingredient, equipment or product that is to be released for commercialization.

A cursory review of available methods can be daunting. There are several emerging methods and technologies for this application, including mass spectroscopy, surface plasmon resonance, biosensors and polymerase chain reaction (PCR). Each of these methods have made advancements, and some of them are already commercialized for food testing applications. However, for practical means, we will discuss those methods that are most commonly used in the food industry.

In general, there are two types of analytical methods used to determine the presence of allergenic foods: Specific and non-specific methods.

Specific tests

Specific methods can detect target proteins in foods that contain the allergenic portion of the food sample. These include immunoassays, in which specific antibodies can recognize and bind to target proteins. The format of these assays can be quantitative, such as an enzyme-linked immunosorbent assay (ELISA) that may help determine the concentration of target proteins in a food sample. Or they can be qualitative, such as a lateral flow device, which within a few minutes and with minimum sample preparation can display whether a target protein is or is not present. (Note: Some commercial formats of ELISA are also designed to obtain a qualitative result.)

To date, ELISA assays have become a method of choice for detection and quantification of proteins from food allergens by regulatory entities and inspection agencies. For the food industry, ELISA can also be used to test raw ingredients and final food products. In addition, ELISA is a valuable analytical tool to determine the concentration of proteins from allergenic foods during a cleaning validation process, as some commercial assay suppliers offer methods to determine the concentration of target proteins from swabs utilized to collect environmental samples, clean-in-place (CIP) final rinse water or purge materials utilized during dry cleaning.

ELISA methods often require the use of laboratory equipment and technical skills to be implemented. Rapid-specific methods such as immunoassays with a lateral flow format also allow detection of target specific proteins. Given their minimal sample preparation and short time-to-result, they are valuable tools for cleaning validation and routine cleaning verification, with the advantage of having a similar sensitivity to the lowest limit of quantification of an ELISA assay.

The use of a specific rapid immunoassay provides a presence/absence result that determines whether equipment, surfaces or utensils have been cleaned to a point where proteins from allergenic foods are indiscernible at a certain limit of detection. Thus, equipment can be used to process a product that should not contain a food allergen. Some commercial rapid immunoassays offer protocols to use this type of test in raw materials and final product. This allows food producers to analyze foods and ingredients for the absence of a food allergen with minimum laboratory infrastructure and enables in-house testing of this type of sample. This feature may be a useful rapid verification tool to analyze final product that has been processed shortly after the first production run following an equipment cleaning.

Non-Specific Tests

While non-specific testing isn’t typically the best option for a cleaning validation study, these tests may be used for routine cleaning verification. Examples of non-specific tests include total protein or ATP tests.

Tests that determine total protein are often based on a colorimetric reaction. For example, commercial products utilize a swab format that, after being used to survey a defined area, is placed in a solution that will result in a color change if protein is detected. The rationale is that if protein is not detected, it may be assumed that proteins from allergenic foods were removed during cleaning. However, when total protein is utilized for routine verification, it is important to consider that the sensitivity of protein swabs may differ from the sensitivity of specific immunoassays. Consequently, highly sensitive protein swabs should be selected when feasible.

ATP swab tests are also commonly utilized by the food industry as a non-specific tool for hygiene monitoring and cleaning verification. However, the correlation between ATP and protein is not always consistent. Because the ATP present in living somatic cells varies with the food type, ATP should not be considered as a direct marker to assess the removal of allergenic food residues after cleaning. Instead, an analytical test designed for the detection of proteins should be used alongside ATP swabs to assess hygiene and to assess removal of allergenic foods.

Factors for Using One Test Versus Another

For routine testing, the choice of using a specific or a non-specific analytical method will depend on various factors including the type of product, the number of allergenic ingredients utilized for one production line, whether a quantitative result is required for a particular sample or final product, and, possibly, the budget that is available for testing. In any case, it is important that when performing a cleaning validation study, the method used for routine testing also be included to demonstrate that it will effectively reflect the presence of an allergenic food residue.

Specific rapid methods for verification are preferable because they enable direct monitoring of the undesirable presence of allergenic foods. For example, they can be utilized in conjunction with a non-specific protein swab and, based on the sampling plan, specific tests can then be used periodically (weekly) for sites identified as high-risk because they may be harder to clean than other surfaces. In addition, non-specific protein swabs can be used after every production changeover for all sites previously defined in a sampling plan. These and any other scenarios should be discussed while developing an allergen control plan, and the advantages and risks of selecting any method(s) should be evaluated.

As with all analytical methods, commercial suppliers will perform validation of the methods they offer to ensure the method is suitable for testing a particular analyte. However, given the great diversity of food products, different sanitizers and chemicals used in the food industry, and the various processes to which a food is subjected during manufacturing, it is unlikely that commercial methods have been exhaustively tested. Thus, it is always important to ensure that the method is fit-for-purpose and to verify that it will recover or detect the allergen residues of interest at a defined level.

Food Safety Supply Chain panel 2017

Registration Open for 4th Food Safety Supply Chain Conference

By Food Safety Tech Staff
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Food Safety Supply Chain panel 2017

Do you trust your suppliers? What about your supplier’s suppliers? Strengthening the links within your supply chain can be a challenging task, but it is necessary with FDA, and FSMA, recognizing the risk that exists.

Key topics, including vulnerabilities, inspections & audits, traceability, supplier verification, transportation, and recalls will be addressed at the 4th Food Safety Supply Chain conference from June 12–13 in Rockville, MD. The event will be held at the U.S. Pharmacopeial Convention.

This year’s agenda will be posted by March 1. In the meantime, the following are some topics covered at last year’s event:

Industry Experts Weigh in on Supply Chain Issues

Import Safe Food, Stay Out of Trouble with FDA