On January 4, 2011, President Barack Obama scored what many consider to be a huge step toward assuring the quality of our nation's food supply when he signed the U.S. Food and Drug Administration (FDA) Food Safety Modernization Act (FSMA) into law. Initiated as a response to a slew of foodborne illnesses reported in the decade before, the legislation endowed the FDA with a number of new powers, all intended to help the administration better prevent potential contamination. The current focus is on prevention instead of retroactive reaction, and with that comes regular inspections. How can food manufacturing facilities ensure they're staying on top of the ever-changing landscape of food safety regulations? Whether you're searching for guidelines to use during an in-house audit or you're preparing for an inspection led by an external team, here is a list of programs, procedures and documentation you should have in place to safeguard success.
Always Follow HACCP
Your facility should already have a Hazard Analysis and Critical Control Points (HACCP) system in place. Reviewing those checkpoints and ensuring compliance will go a long way toward meeting the FDA's standards. HACCP organizes procedures concerned with the potential biological, chemical and physical hazards involved in the many steps of food production. Having a checklist in place that is adhered to each day is absolutely essential. Use this time to find weak points, identify any areas of noncompliance and update your HACCP plan to include any new additions to your plant or packing facility.
Cleanliness is the most important step in preventing contamination, and this process begins at hiring. Training programs should include sections that concentrate on sanitation standards, and these lessons should be reinforced via written guidelines in a training manual accessible by employees at all times. The sanitation schedule should be part of a continuous record that documents who, where, what and how––all the necessary information to prove who did the cleaning, what equipment was cleaned, what chemicals were used to clean it and the methods employed. This log serves a dual purpose. Not only is it proof that steps aren't being skipped, it also helps during an audit as proof that you have such guidelines in place. A log can also be considered a great starting point, should improvements be recommended.
The evolving world of FDA regulations is hard to stay on top of, but ignorance is never an excuse—neither to consumers nor to the government regulatory bodies charged with checking up on your business. Are you familiar with the fine print associated with maintaining filtration systems? Do you know if your Safe Quality Food Standard Certification is up to date? What about your Good Manufacturing Practice (GMP) standards? It's impossible for one person to know everything, but one company absolutely has to. Use audit preparation as an opportunity to fill in any potential blanks and bring your team up to speed.
Review Your GMP and Quality Assurance (QA)
While you're reviewing those regulations, two in particular warrant extra focus. GMP is the minimum standard of practice your facility must achieve in order to assure your output doesn't put the public at risk. Likewise, QA procedures give you a step-by-step way to analyze current procedures, find errors, take corrective action and keep evidence of each action to aid in future inspections. A QA process will also come in handy when reevaluating best practices or if you contract with an outside team for a review. Review, reassess, regulate, record –– these are four ways to embrace food safety governance and take control over your brand and overall output while respecting the consumers — be they wholesale or retail.
While government regulations and legislation like FSMA can initially seem daunting, all the tools are in place to ensure compliance and a successful audit. By being hands-on during the pre-inspection process and reviewing how your company makes, transports and handles its products, you can market the safest product possible.
Jeff Maree is the product specialist at Eaton Filtration Online.