The Food and Drug Administration (F.D.A.) new regulations are for implementation of the Food Safety and Modernization Act (F.S.M.A.), which has a stated mission to prevent food safety problems not only address incidents. The Environmental Protection Agency (E.P.A.) has moved from end of pipe pollution solutions to regulations for the reduction of emissions. The Occupational Safety and Health Administration (O.S.H.A.) new regulations continue their stated mission to prevent accidents.
Eyes on efficiency
Federal agencies are attempting to be efficient as their budgets are cut. One way to be efficient is to maximize the use of personnel. Agencies have done this for some time, such as, the Memorandum of Understanding for inspections between the E.P.A. and O.S.H.A. Inspectors are cross-trained and can write citations for violations of the regulations of both agencies. A recent example is the agreement among the Centers for Disease Control and Prevention, the Agency for Toxic Substances and Disease Registry, and the U.S.D.A. Food Safety and Inspection Service. The quick identification of a health issue will allow the government to respond more quickly and more clearly identify the source of the problem. Companies will be held to a high standard.
If a company has not understood the prevention approach, the company’s economic viability is in question. Corporate plans and standard operating procedures should have moved far down the line of responsible care of food quality, environmental protection and worker safety.
Business as usual
In corporate language business as usual should now show an awareness of sustainable operations, continuous improvement, lean management, six-sigma, root cause analysis and other methods that may be used to strive to prevent problems.
Production, engineering and sanitation must work together for the control of the costs resulting from regulations. Typical examples of the failure of departmental cooperation are most common when new people are not properly trained. Some examples follow.
Changing the color or fruit of a frosting or filling may change the color of the waste water. If the color goes to the sewage treatment plant the bakery may be fined for not meeting the conditions of the wastewater permit. Adding a new oven, just after the permit for the existing oven has been renewed for $15,000, would start the permit process over and add substantial time and cost to the project. If a new boiler is being considered, an analysis should include whether one is really needed and the alternatives, the fuel that will be used and the size. The rules for boilers can be very burdensome.
Not training sanitation workers to take down and replace machine guards may result in a guard being left off, a worker injury and a government fine. When a recipe is changed and an allergen is added, failure to properly store the product or to sanitize the area may result in an expensive recall and intrusive government intervention.
Working through the supply chain
Companies are working through the entire supply chain to meet the goals of preventing accidents, making quality products, and reducing waste. Government programs encourage supply chain responsibility, but company customers are also significant drivers. Another trend to challenge operations is the consumer demand for variety and personalization of food products and packaging. The opportunity for a mistake is increasing; the margin for error is increasingly narrow.
The best companies look at the regulatory requirements before selecting a facility site. Land, air, water, transportation access, taxes and many other conditions will affect the economic viability of a facility; a county can be very, very different from an adjacent county.
The global nature of many businesses from equipment suppliers to bakers means that an awareness of international standards is important. The United States has developed regulations based on Canadian programs, initiatives by the European Union and Non-governmental Organizations (N.G.O.). Again, a commonality among the regulations is objective to prevent problems.
Facing internal challenges
Companies must be aware that agencies face their own internal challenges. For example, the E.P.A. has a rapidly changing and diminishing list of approved refrigerants; however, some of those refrigerants are not approved for the agency’s Energy Star program. The E.P.A. has failed to coordinate with the U.S. Department of Energy rules on these same energy and refrigerant changes. To survive, companies need a refrigeration audit and plan.
As difficult as it is for some companies to make the culture changes required by government regulations aimed at prevention, the regulations now are more predictable and therefore make long-term corporate planning more cost effective. People are the key to the company’s operation and training remains critical to continuous improvement and economic success.
