Safety from the ground up
Aug. 7, 2012
by Dan Malovany
The Food Safety Modernization Act of 2010 (FSMA) mandates that all food processors conduct a hazard analysis of their operation and establish the necessary preventive measures. Some of the more cynical individuals have commented that the only reason that the words “preventive controls” were used was that FDA did not want to state that it was mandating Hazard Analysis Critical Control Points (HACCP) for the whole food industry. The bottom line, however, is that is what has been done with the exception of very small processors. Baking & Snack contributor Richard Stier, a consulting food scientist with international experience in food safety, offered his advice to readers as they work to ensure a safe food supply.
Baking & Snack: What should bakers and snack food producers do build a robust food safety management system?
Richard Stier: The easy answer is that bakers and snack food producers should follow the guidelines established in the Codex Food Hygiene document and the recommendations established by the National Advisory Committee for Microbiological Criteria for Foods in 1997 [see “Developing a HACCP plan” at the bottom of this page]. However, with establishment of ISO 22000 in 2005 and the increasing demand for processors to meet the criteria in one of the audit schemes approved by the Global Food Safety Initiative (GFSI), expectations are much greater.
In what ways are the expectations higher?
Among the expectations in ISO 22000 are an increased emphasis on hazard analysis, verification and validation, and the role of management. One message emphasized by most HACCP instructors when conducting workshops is the importance of the role of management. Their commitment to the food safety management system can make or break the program. In fact, management commitment should probably have been included as a preliminary step to the seven principles.
You have referred to ISO 22000 several times. What does it say about the role of management?
In Section 5, “Management Responsibility,” the standard specifically states that “Top management shall provide evidence of its commitment to the development and implementation of the food safety management system and to continually improving its effectiveness by:
- showing food safety is supported by the business objectives of the organization
- communicating to the organization the importance of meeting the requirements of this international standard, any statutory and regulatory requirements, as well as customer requirements relating to food safety
- establishing the food safety policy
- conducting management reviews
- ensuring the availability of resources.”
Each of these areas has specific requirements which are defined in the standard. Management is also responsible for developing programs for internal and external communication and for emergency preparedness.
Are any of the elements in the standard and the audit schemes new to bakers and snack food producers?
I would say yes. Management review as defined in these documents is really a new paradigm. Most processors have management meetings in which they meet with their management team, but this is not a management review. The HACCP plan reassessments are also not management reviews, although some operations consider them to be so.
The juice HACCP regulation in 120.11 (b) states that the “processor shall validate that the HACCP plan is adequate to control food hazards that are reasonably likely to occur; this validation shall occur at least once within 12 months after implementation and at least annually thereafter or whenever any changes in the process occur that could affect the hazard analysis or alter the HACCP plan in any way.” The management review would include this, but it is much more.
The best way to understand what is expected from the management review is to look at the standard. Management review should be a tool to assess the food safety management system and evaluate means for continuous improvement. Inputs for each review should include records and activities from previous management reviews, analysis of verification activities, the corrective action programs, new information that could affect food safety, customer feedback and consumer complaints, internal and external audits, and any other elements that make up the food safety management system.
Ideally, each member of the management team should have conducted an assessment of the company’s programs and activities, analyzed the data and prepared this for presentation at the meeting.
Developing a HACCP plan
- Preliminary Step 1: Assemble HACCP team
- Preliminary Step 2: Describe product
- Preliminary Step 3: Identify intended use
- Preliminary Step 4: Construct the flow diagram
- Preliminary Step 5: Verify flow diagram on site
- Principle 1: List all potential CCPs, conduct hazard analysis and determine control measures
- Principle 2: Determine CCPs
- Principle 3: Establish critical limits at each CCP
- Principle 4: Establish a monitoring system for each CCP
- Principle 5: Establish corrective actions for each deviation that may occur
- Principle 6: Establish verification procedures
- Principle 7: Establish record keeping and documentation
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.