Top 10 Ingredients of a Total Food Protection Program
A mere 10 years ago, the title "food safety director" didn't exist in the majority of food manufacturing, foodservice and retail companies. Responsibilities for food safety efforts often were spread out among various personnel in different departments, many of whom held a variety of titles indicating the emerging importance of the food safety function in the business. The monikers HACCP Manager, Food Safety Specialist and Zone Food Safety Manager, among others, could be applied to more than one person in more than one department within any given company. As food companies began to observe the enormous costs of food safety failure, the industry began a concerted effort to centralize the food safety function, spurring the creation of a new, dedicated discipline in its own right.
Today, the food safety department enjoys the same level of visibility in the corporate structure as research and development (R&D), quality assurance (QA), marketing, purchasing and finance. The fact that food safety aims and considerations factor into every aspect of today's food business requires the constant assessment and development of strategies to identify and manage food safety risk throughout the entire manufacturing process. This is a tall order for the food safety professional who knows that the implementation of a Hazard Analysis and Critical Control Point (HACCP) program alone does not a food safety system make.
The recipe for success in attaining a comprehensive food protection system involves fully integrating five fundamental food safety programs and five ancillary strategies into the company's operations. With these top 10 ingredients in the mix, the food safety professional will achieve greater protection for the company's brands, reputation, consumers and earnings.
1. Current Good Manufacturing Practices (cGMPs)
The guidance found in 21 CFR 110, "Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food," is considered the most fundamental of all food safety programs. The GMP regulations set forth criteria for complying with provisions of the Federal Food, Drug, and Cosmetic Act, which requires that all human foods be free from adulteration. The guidance lays the groundwork for the production and preparation of safe and wholesome food in several general areas, including provisions for personal hygiene and dress codes, sanitary operations, sanitary facilities and controls, buildings and facilities, equipment and utensils, process and production controls, and warehousing and distribution.
"The importance of GMPs relative to a comprehensive food safety system is clear," states Paul Hall, Ph.D., Director of Microbiology and Food Safety, Kraft Foods North America. "We consider GMPs one of the prerequisite programs to HACCP. If you don't have a sound GMP program in place on your plant manufacturing floor, you're not going to have an effective HACCP program."
While the regulation presents good detail on the specific areas that need to be covered, it does not necessarily in all cases provide direction on how to achieve compliance. It is up to each individual company to select and implement the specific approach and technologies to satisfy the basic criteria. Recently, the U.S. Food and Drug Administration indicated that the agency may seek to refine the language of the GMP regulations. The original regulations were developed based on water testing data, and as a result, tend to focus on turn-of-the-century concerns, mainly the control of filth. By refining the language of the guidance, the agency hopes to incorporate provisions for more recent food safety hazards such as the more newly emerged microbiological contaminants of the last decade.
In the meantime, the most important element of effective implementation of GMPs, says Hall, is the ongoing training of plant employees. "I think that the training aspect of GMP implementation is absolutely essential to the success of the program. The food company has got to have very good initial training of plant floor employees. You also must have a good mechanism in place for documenting your training and for checking that these employees have a good understanding of the GMPs, including how these affect their specific job, their specific line, their specific plant manufacturing environment, and their specific responsibilities. The key is to retrain employees on an ongoing basis to ensure that understanding.
"When you have procedures in place to ensure GMP compliance over time--whether that is ensuring that line supervisors are properly trained on an ongoing basis and have a good understanding of GMP compliance for their particular areas in the plant, or whether that is verification through an independent audit function, for example--and you are documenting that you are, in fact, doing what you say you are doing relative to GMPs, other food safety programs in the company will be strengthened."
2. Sanitation
"Sanitation is a cornerstone to a company's food safety program," says Mike Cramer, V.P. of Food Safety and Quality Assurance with Specialty Brands, Inc. "It is difficult, if not impossible, to prepare safe product without a clean facility."
Cleaning and sanitizing are the two essential elements that comprise a food sanitation program, and both must be performed in tandem in order to successfully achieve food safety and quality assurance goals. Cleaning is defined as the use of mechanical agitation and detergents to remove visible soil, biofilms and other residuals from the surfaces of equipment, floors, walls, etc. Sanitizing is the application of chemicals or chemical treatments to remove any remaining bacteria or residuals that cannot be seen with the naked eye.
Critical elements of an effective sanitation program include selection and training of sanitors, personnel safety, sanitary equipment design, sufficient quantity of hot water, knowledge of chemical interactions with food plant soils and proper cleaning techniques. Integral to this process is pre-operational and operational sanitation auditing. Sanitation records will include clear and thorough documentation of organoleptic findings, corrective actions when deviations are found and implementation of preventive measures to avoid repetitive deficiencies.
Notes Cramer, "Sanitation programs that include all of these elements will help companies meet their food safety obligations while providing products that conform to quality requirements in an economic manner."
Further, says John Butts, Ph.D., V.P., Research with Land O'Frost, company management must not allow the passing of pre-operational inspection to be the primary success measure of the sanitation department. Today, companies can attain a higher level of confidence by refocusing their efforts on the critical factors of the sanitation process.
"We use critical factors as a component in defining how thermal process controls, such as canning, aseptic processing and similar processes, actually function," says Butts. "We use critical factors to develop and identify components of critical control points. We can apply the concept of critical factors to the sanitation process, where we are managing various components through good execution of GMPs.
"An example of a critical factor in the sanitation process is the degree of disassembly of the equipment, which is critical to environmental pathogen control. Other critical factors include the thoroughness of sanitizer application and flood sanitization. These are just a few examples of the elements that we need to clearly define and effectively communicate to our employees to improve the effectiveness of our sanitation programs."
3. Regulatory Compliance
All foods are regulated in part or in whole by myriad federal, state and local government agencies. An effective regulatory compliance program ensures that the food company is adhering to national regulations and legislation, state and local rules and any applicable international standards related to the production of foods fit for human consumption. The federal system alone is comprised of 35 different laws and involves 12 different agencies, six of which have major roles in carrying out food safety and quality assurance activities. The recent implementation of several new federal rules and the need to keep current on relevant state and local public health and food safety standards makes it more critical than ever that the regulatory compliance program is streamlined and integrated into the total food protection program.
The critical elements of the regulatory compliance program include training; record keeping and documentation; plant registration and process filing; process authority, inspection readiness and recall procedures; inspection and testing protocols; and auditing. Taken together, these elements provide an enhanced framework for managing each of the applicable regulations that apply to a particular manufacturing operation.
Tony LoBue, owner of Scotts Food Products, a Paramount, CA-based manufacturer of specialty sauces, marinades and seasonings, states that the key to a workable regulatory compliance program is employee education. "We take the county health department, state and applicable federal rules and give them to the plant manager, the production manager and line supervisors. We go through all of these materials to make sure they have a basic grasp of all the applicable rules and regulations pertaining to food safety. When an inspector arrives at the plant, we want our personnel to be well-versed in this area.
"At the end of the day, it is critical that the food processor's documentation--of the product formulations and your actual processing systems, of sanitation efforts and GMP compliance--is available in such a way as to show evidence of your company's compliance with food safety rules and regulations."
4. Quality Control
The quality control (QC) program consists of measures and procedures pertaining to physical, chemical or organoleptic attributes of food products to ensure the cost-effective production of uniform and consistent products. A typical QC program involves establishing product performance criteria and supplier specifications, setting critical limits and instituting product- and process-specific controls that are applied at the point of production in a particular processing environment.
In terms of food safety, the basic elements of today's QC programs serve as a way for food processors to achieve both quality assurance and safety requirements. With the advent of new in-process intervention technologies that reduce the incidence of microbiological, chemical and physical contaminants, improved processing equipment design and placement within facilities, and automated data monitoring systems, processors are better positioned to ensure a higher degree of confidence that products are produced, packaged, distributed and reach consumers in the highest quality and safest state possible.
As William Sperber, Ph.D., Corporate Microbiologist with Cargill, Inc., has stated, "Quality control must be built into the system. Operators cannot assure the safety (which they are required to do by law) and quality (which is what sells their product) of products by simply testing finished product. Operators are realizing that it is more efficient and economical to build quality programs into the system, and are many have adopted quality programs in which on- or at-line quality monitoring and control play a crucial role. Without control, monitoring operations are a waste of time. Without control, operators might as well revert to the old belief that quality can be inspected into the product. The key to monitoring and control is to collect samples or evaluate the process and make corrections in "real time." Making corrections to a process that has begun to go "out-of-control" saves both time and money, since a substandard product must be destroyed, reworked or sold at a loss."