Focusing on prevention
How to comply with FSMA regulations.
BakingBusiness.com, June 12, 2012
by Lucy Sutton
POWER Engineers

With the Food and Drug Administration currently working on news rules and regulations as part of the Food Safety Modernization Act (FSMA), which President Obama signed into law in January 2011, companies should already be considering preventive controls to reduce potential contamination of foods.

Baking & Snack Contributing Editor Joe Stout, founder and CEO of Commercial Food Sanitation LLC, Libertyville, IL, has more than 35 years of experience in quality and sanitation. He offers his advice to bakeries and snack manufacturers as they prepare for these preventive controls

Baking & Snack: What are the most vital food safety challenges for the baking and snack industries in 2012 and why?

Joe Stout: Food safety challenges abound in the baking and snack sector. I would say several distinct areas of concern raise these to the challenge level. The first would be allergen management. This is a challenge from a few perspectives. First, being able to get the labels to match what is in the package. It sounds simple, but line speeds, formulation complexity and confusion in label generation — such as common appearance of labels for allergens and non-allergens, mixed labels coming from suppliers, and cross contamination from line to line — can all impact this challenge.

Getting this right takes planning and perfect execution. During the past five quarters, the majority of the food industry’s recalls were because of allergens rather than a specific pathogen. We need to do a better job with this.

The second challenge is with pathogens. Just because a product tests negative for a pathogen doesn’t mean it would be considered acceptable. It also needs to be manufactured and stored in a sanitary environment — where pathogen presence is fully controlled — to be in regulatory compliance with Food Drug and Cosmetic Act 402 A. The act states, “A food shall be deemed to be adulterated if it has been prepared, packed or held under insanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health.”

Finally, the third challenge I see is to generate the necessary documentation — hazard analysis and associated preventive controls — expected under FSMA. This could be a challenge for companies with less developed documentation.

How does sanitary design relate to the new prevention provisions in FSMA?

The FSMA linkages between sanitary design and food safety are not well delineated. However, because regulatory agencies will have access to review food safety records and environmental monitoring results, if problems are continually evident in a food plant or an industry, it will lead to the root cause, which may be poorly designed equipment or facilities.

What sort of changes in culture do companies have to make to address the heightened awareness of food safety today?

Significant documentation will be required to meet the anticipated FSMA regulations. Many companies have begun to prepare for this with hazard analysis, preventive plans and sanitation standard operating procedures (SSOPs) development. Some companies have formed teams at the corporate level to organize this work across their organization. However, few companies have addressed the culture issue.

Documentation systems are important, but even more critical is to establish a culture of food safety at the corporate level and deep within the plant culture. A company needs to be assured all employees are trained and educated in food safety and troubleshooting the procedures they are using. We need an army of food industry employees who are dedicated and consistently focused on following procedures and documenting them as their work is completed. President Obama’s signature on FSMA does not automatically make this happen. It is up to all of us in the industry to get this right. Consumers are counting on us.

What else do processors need to know?

A signature, even by the president of the US, does not cause an industry to change quickly. Most companies are working on documentation and their food safety plans, which are core to meet the expectations of FSMA. Although documentation is important, it is also critical to focus on changing the culture in plants and companies to engage the hearts and minds of all employees. All of the documents on Hazard Analysis Critical Control Points (HACCP), sanitation, allergens, pest control or environmental monitoring will be worthless unless employees are engaged and passionate about their job requirements to make safe food. Without the right culture, FSMA will be a paperwork exercise that will increase regulatory actions against the industry without improving food safety statistics.

This story is sponsored by POWER Engineers, which has one of the most comprehensive teams of engineers and specialists serving the baking and snack industry. As an extension of its clients' engineering teams, the company provides program management, integrated solutions and full facility design for the baking and snack industry. Learn more at www.powereng.com/food.