Food Safety: Self Preservation
August 1, 2010
by Richard F. Stier
One of the essential elements for a baker’s or a snack food producer’s quality plan is its vendor quality program. The importance of such endeavors cannot be overemphasized, especially in light of recent issues with contaminated or adulterated ingredients. Whether the ingredient is peanut butter, hydrolyzed vegetable protein (HVP) or black and red pepper, when a food component causes illnesses and deaths, not to mention negative impact to a processor’s business, immediate corrective action must take place.
The peanut recall cost manufacturers of peanut butter as well as baking and snack companies tens of millions of dollars in recalled product. This does not include the reputation lost on brands as well as the plant cleanups and reinspections.
As this article is being prepared, there are two ongoing issues with ingredients with HVP and black and red pepper. Both were found to be contaminated with salmonella. The HVP issue has already caused one potato chip manufacturer to recall product because the contaminated ingredient was used in the spice blend. The contaminated pepper has been linked to more than 250 illness in more than 40 states.
Whether a vendor quality program would have detected these problems remains to be seen. However, the role of a vendor quality program is to minimize the potential of such an occurrence. Note that the goal is to minimize the potential. Guarantee that such a problem won’t occur is impossible.
Vendor quality programs are for all sizes of processors. The extent of the program depends on the company, its resources, the ingredients purchased and the complexity of its operations. These programs have many potential benefits, including reduced testing of incoming materials and shortened lead time for receipt of materials. They can decrease on-site ingredients inventory and promote the ability to adopt just-in-time inventory control. These programs refocus the emphasis from testing and inspection to management of quality. They also force the operator to do more focused testing, which leads to more consistent quality ingredients and to enhanced operational efficiencies. With these programs come improved product quality and safety and, ultimately, enhanced protection of consumers, brand names and company.
ELEMENTS OF SUCCESS.
Oftentimes, small companies neglect vendor quality programs simply because they have been working with their suppliers for many years. This longtime experience with a company provides a sense of adequate security. This may not be the best route to follow, however, especially since so many ingredients are now sourced not only from overseas but also from third-world nations.
The first step to ensure success of a vendor quality program is management support. Management needs to provide all necessary resources to ensure the program is developed, documented, implemented and maintained over time.
Vendor Quality Team — Companies should create a multidisciplinary vendor quality team. The team should consist of one or more persons from quality, production, purchasing and R&D departments. For larger companies, bringing in people from engineering, warehousing, finance or other groups also may be valuable. It is up to this group to develop the programs and ensure that the programs are properly documented and the persons responsible for maintaining them on a day-to-day basis have been properly trained to do the necessary tasks. And of course, that training must be documented.
If companies purchase a significant quantity of overseas materials, they should look for an agent or a “champion” in that country or region of the world. That agent’s job would be to ensure that the materials or ingredients purchased meet internal quality and safety standards. This is not something that small companies can easily do, but multinationals often use resources from their operations in the region. However, small operations may be able to work together or work through a trade association.
Evaluation of Raw Material, Ingredient or Packaging — Before spending the time evaluating a vendor, a processor needs to determine whether the vendor’s material will function in their products or processes. The R&D or packaging department should get product samples and specification sheets. The department then needs to do test packs to ensure the material will work. Ideally, this work can be done at the bench or in the pilot lab. It also is essential that several different lots be evaluated. This is especially important if material such as fruit or vegetable purees is organic.
Vendor Questionnaire — A company must also establish basic criteria for potential vendors. Such criteria should include both technical and financial considerations and must be documented and available as a reference for companies wanting to partner with the bakery or domestic supplier. A summarized questionnaire can be sent to potential vendors as well. This will clearly define a company’s requirements and serve as a preliminary screening tool. Potential vendors that fail to fill out the document can be eliminated immediately. Those that have significant gaps can be eliminated or asked to address the issues prior to moving forward.
The development and use of a good questionnaire is something that even small companies can do. It is also a smart idea to send it on to longtime suppliers to see how they react. If they ignore it, remind them that it is part of doing business with you. The questionnaire also presents an opportunity to evaluate whether companies are changing from year to year.
Verifying the Questionnaire — One essential question on the questionnaire is whether vendors have been subjected to a third-party audit and, if so, to send a copy of the audit along with the completed form. Smaller companies may wish to compare the audit to the questionnaire, whereas larger companies usually elect to visit the potential vendor themselves.
Many large corporations have developed their own audits that are either done by in-house employees or third-party companies. These audits look at management commitment, quality systems, food safety, allergen control, sanitation, personal hygiene, physical plant, pest management, water systems, chemical handling, and shipping and receiving. Other areas of investigation include recalls and traceability procedures, training and education, and food defense.
Along these lines, there is a growing interest in the mandating that ingredient suppliers pass an audit approved as part of the Global Food Safety Initiative (GFSI). This initiative was supported by a consortium of major market chains from around the world that wanted to better ensure the quality, safety and ethical practices of their vendors. GFSI has approved several industry standards to meet this need. These include the British Retail Consortium (BRC), International Food Safety (IFS), Safe Quality Foods (SQF) and the Dutch HACCP program. It has recently acknowledged that companies with ISO 22000, “Food safety management systems — Requirements for any organization in the food chain,” have satisfactory programs. This is known as FSSC22000. This program is fairly new to the US, so it has yet to be seen whether being certified as compliant with one of these programs will satisfy the on-site audit requirements of buyers.
Adverse Findings — How a potential vendor responds to adverse findings noted in the questionnaire, discovered during third-party audits or observed when a member of the buyer’s team is in-plant should weigh heavily in whether the relationship moves forward. All adverse findings must be addressed prior to initiating the partnership. Potential suppliers must respond in writing to all issues with a corrective action plan and verify that they addressed any adverse findings. If possible, have them send before and after pictures to show that the work has been done.
TAKING THE NEXT STEP.
Once the buyer is satisfied with the product and systems in place to ensure quality and safety, both parties should then sign an agreement to work together. The contractual agreement includes delivery requirements, Certificates of Analysis (COAs) and other documentation intended to ensure quality and safety on an ongoing basis.
Ongoing Quality — Once companies enter into a purchasing partnership, the buyer must take steps to ensure the ongoing quality of purchased materials. One requirement that most companies ask of their suppliers is a letter of continuing guarantee. This letter should indicate the products are manufactured in a facility that adheres to the US Food and Drug Administration requirements and should assure the products will meet established specifications and will be replaced if they fail to meet established requirements. If it’s a food-contact packaging material, the letter also must state that the material has been approved for food contact and cite the appropriate section of the regulation.
This is also an area where the vendor quality or food safety team needs to step up. One group should conduct a risk assessment of every ingredient, packaging material and raw material. The team must look at the source, how the ingredient will be used, its importance to the operation, how much is used and any history pertaining to that ingredient. Requirements for COAs and whether they need verification will be the assessment’s end result. For example, if a baker uses a minor ingredient with no associated health risks in only one product, the team may decide that there no need for the vendor to provide a COA. On the other hand, if the facility uses a sensitive ingredient such as liquid egg, the team would insist the vendor provide a COA with each lot, and the quality group must verify that COA on a regular schedule.
Part of the vendor quality program must address how COAs are handled. Do you want them to accompany each delivery? Can the supplier send a copy in advance via fax or electronically? A big issue is, what happens if a delivery is made, and there is no accompanying COA? There are usually two options: reject the load, or accept it and place it on hold until the COA arrives. A company usually only has to send one load back to “send the message” to the supplier.
Each company must decide how COAs will be received, handled and reviewed. Who gets the COA if they are sent in ahead of time? How do they communicate with the warehouse to confirm receipt? A company does not want to have a COA sit in someone’s in-box while a delivery is made and rejected. It is a good idea to ensure that backups exist for receiving. And receipt is only part of the equation. Someone must review each COA to ensure that the analyses on that lot meet established standards.
Performance Evaluations — The vendor quality program should include a means to evaluate each supplier. Such a program should include technical considerations (quality upon delivery, performance in production, etc), on-time delivery, audit performance and any other factors deemed necessary to properly monitor and evaluate performance. Performance monitoring is one reason to have a multidisciplinary vendor quality team.
Documentation — Each area needs to be documented. Procedures must describe how each element shall be carried out and who is responsible for the element. They also must describe the role for each member of the vendor quality team. Finally, if the program features elements where there may be deviations or problems, the procedures for that section must include corrective actions.
ASSURING THE EFFECT.
If a company devotes the time and resources to build a vendor quality program, will it be effective? The answer is, not always. That’s not what processors want to hear; however, the chances of failure are probably very low, assuming the company is following a good program.
Making the program work takes time, effort, commitment and flexibility. And in this case, flexibility means changing to meet an evolving environment and world. Thanks to the recent problems, processors now routinely test ingredients such as peanut butter and spice blends.
The vendor quality team needs to meet regularly not only to do its jobs but also to look at the program as a whole. Continuous improvement is the way to ensure a functional program that evolves to meet new challenges as they appear