Sept. 1, 2011
by Dan Malovany
A provision in the Food Safety Modernization Act (FSMA) waives small processors from certain requirements, and Baking & Snack
contributing editor Richard Stier doesn’t believe that should have been included. Little guys can make someone just as sick as a large operation, he noted. In fact, he pointed out that small processors and seasonal production of unpasteurized cider and apple juice drove passage of the juice Hazard Analysis Critical Control Points (HACCP) regulation almost 10 years ago.
Mr. Stier, a consulting food scientist with international experience in food safety, took a look at how things have evolved and where they might be going. Specifically, in a candid interview with Baking & Snack
, he discussed in length why third-party audits have proliferated because processors — both big and small —are trying to push the responsibility for food safety down the supply chain. Baking & Snack: How has the definition of HACCP evolved in recent years? What does it encompass now that it didn’t before? What are the new areas or critical control points in a bakery, snack operation or even facilities that produces pizza or burritos? Richard Stier:
HACCP has not changed significantly since it was conceived. The last major modification of HACCP principles was in 1997. At that time, Principle 6 (recordkeeping) and Principle 7 (verification) were flip-flopped, so recordkeeping became the last principle. These revisions also established the five preliminary steps. In addition, the system was now harmonized between Codex Alimentarius and the National Advisory Committee for Microbiological Criteria for Foods. The system and how it is managed has, however, both devolved and evolved.
The original Principle 1 read as follows: “Assess hazards and risks associated with growing, harvesting, raw materials and ingredients, processing, manufacturing, distribution, marketing, preparation and consumption of food.”
It is now expected that part of a HACCP plan will be a risk assessment on all ingredients, raw materials and packaging materials used in the operation. This is the devolution process. We have reverted to what was included in the first principle from 1989. This is, in fact, a very good idea. Understanding which materials used in a processing facility pose the highest risk allows the facility to better focus on those risks and to take steps to minimize said hazard. As an example, a processor may elect to purchase higher-priced seasonings and spices that have been treated to minimize potential microbiological issues.
HACCP’s greatest evolution has come in the area of validation — of both processes and systems such as cleaning and sanitizing. This is an arena in which many processors are very active at the moment. For many years, processors — especially bakers, snack food producers and others manufacturing cooked foods — assumed the cooking processes were a “kill step,” meaning the processes would effectively destroy microorganisms of public health significance. This is no longer the case.
Many operators are in the process of revalidating their thermal processes using bacterial challenge studies and/or thermocouples to monitor heating. One of the factors that have driven this work is that baked foods and snacks rely on their low water activity for stability. Bacteria tend to be more resistant to heat in products with lower water activity, so some have questioned whether the processes are effective. The pathogens will not grow in the finished product, but they may remain viable. And as an industry, we have learned to our dismay that some microorganisms of public health significance can make people sick at very low levels. How are companies, especially those that produce private label products or contract manufacture for the big players, responding differently since the rash of recalls? What new demands do their customers — including retailers, food service and co-pack customers — put on bakers?
“Rash” of recalls may be the wrong word; it implies there has been a huge jump in product recalls. The real issue seems to be that recalls receive much more publicity than they did in the past, especially those that have been linked to illnesses. Most recalls do not involve illnesses or injuries. The recall was initiated because of a potential problem, such as foreign materials, undeclared allergens or the recovery of a pathogen.
To check out recent recalls of products regulated by the FDA, visit www.fda.gov/safety/recalls
The numbers on the website do not imply that there is a rash or epidemic of recalls. In most cases, recall announcements will contain the following kind of language: “No illnesses have been reported in association with the recall. This precautionary recall notification is being issued due to an isolated instance in which one package of product yielded a positive result for Listeria monocytogenes in a random sample test collected and conducted by the Ohio Department of Agriculture.”
Or here is another example: “No other products are involved in this recall. No illnesses have been reported to date. This alert was initiated after the company’s own internal labeling review process identified that one ingredient used in the mix contained non-fat milk powder and the label did not reveal the presence of milk.”
These issues have really not affected how larger companies do business with their suppliers and/or contract packers. During the past few years, the goal of all processors, both large and small, has been to push safety back down the supply chain. They expect that their suppliers or contract packers will have the capabilities to produce safe and wholesome foods. This is one reason third-party audits have grown the way they have. In addition, it is one of the reasons that FSMA includes a provision that will mandate supplier verification. It is all part of reducing potential risks to your products, your brands and your company as a whole. What concerns do you have about the North American food safety system? What solutions are needed by the food industry? What lessons can they learn from progress made in some international food facilities?
Personally, I believe the North American food processing industry and its commitment to food safety is in excellent shape. Even the enactment of FSMA should not affect “good” operators as was alluded to when it was discussed earlier this year. The new law basically mandates what quality operators are already doing. This is especially true in the baking and snack industry.
I can’t see it having any major impacts on the way most processors are currently doing business. There will be more frequent inspections, which take time and create angst amongst the management team, but if a company currently meets the requirements of third-party audits, it should be able to handle anything that the FDA throws at it. Products of the baking and snack industry have not been a significant source for foodborne illness.
There will always be the occasional processor that is a bad apple and will create problems. Unfortunately, with food processing, the bad apples truly spoil the barrel. For every bad apple, there are a hundred or more good processors.
And can we learn from our overseas colleagues? That is debatable, especially in the wake of the sprout outbreak in Europe, which at last count has sickened more than 3,000 people and killed at least 30. One of my North American colleagues in the produce industry commented, “I wish that the Europeans had learned from our problems with spinach.”
As sad and expensive as each and every outbreak or recall is to the company involved, the hope is that the industry will learn from them. Pointing fingers and pontificating legislators do little to advance the cause of food safety, but understanding potential problems and learning from our mistakes certainly does. The world is not a zero-risk environment, but we in the food industry can and do take steps to minimize those risks to our customers, our products and our industry.