Food Safety Basics

untitled

What is food additives?

For centuries, ingredients have served useful functions in a variety of foods. There is the historical footprint of their application in our ancestors time for example use of salt to preserve meats and fish, added herbs and spices to improve the flavor of foods, preserved fruit with sugar, and pickled cucumbers in a vinegar solution. Today, these components are commonly known as food additives. As the day pass by, there is increased in consumer demand to enjoy a food that is flavorful, nutritious, safe, convenient, colorful, and of course affordable. In order to meet consumer demand, invention/ technology advances in food additives evolved over the period of time. As per Food safety act -2006 chapter -1 sections 3K- the term food additive means “any substance not normally consumed as a food by itself or used as a typical ingredient of the food, whether or not it has nutritive value, the intentional addition of which to food for a technological (including organoleptic) purpose in the manufacture, processing, preparation, treatment, packing, packaging, transport or holding of such food results, or may be reasonably expected to result (directly or indirectly), in it or its by-products becoming a component of or otherwise affecting the characteristics of such food but does not include “contaminants” or substances added to food for maintaining or improving nutritional qualities” . Today’s date, Food Safety Standard Authority of India (FSSAI) approved a list of over 500 ingredients. Some of the additives are manufactured from the natural sources such as corn, beets, and soybean, while some are artificial, man-made additives.  There are few myths among consumers about food additives application because they may see the long, unfamiliar names and think of them as complex & unsafe chemical compounds. In fact, every food we eat — whether a just pickled strawberry or a homemade cookie or noodle— is made up of chemical compounds that determine flavor, color, texture and nutrient value. All food additives are carefully regulated by food authorities in India and periodically check to review details are accurately labeled on food products. The purpose of this article is to provide basic information about food additives: Classification, importance and how they are regulated for safe use.

Classification of Food Additives:

Depends on the functionality of additive it is broadly classified as antimicrobial agents, preservative, antioxidants, artificial colors, artificial flavors enhancers, chelating agents, thickening agents, stylizing agents and much more.  In figure -1, depicted various kind of food additives.

untitled2

Figure: 1

 The importance of food additive: 

Though there are lots of controversy about the application of food additives, still food additives remain one of the indispensable components in our food products. Today’s date there are thousands of studies conducted throughout the world (JECFA, FDA, FSSAI and etc.,) and attested the overall safety of various additives. It is important to one should understand the use of additives within permissible levels of regulatory norms not going to cause a harmful effect.  As matter of fact, anything consumed in excessive amounts will be toxins, even if the substances are most familiar and in daily contact. Some of the major importance are a) maintain product quality and freshness b) provide nutrition c) aid in the processing and preparation of foods d) make foods appealing.

Regulation on food additives:

Safety Standard Authority of India has the regulatory norms for food additives, including monitoring of their safe use. Under Food Safety Standard authority of India – Product approval cell must review the safety of food additives before manufacturers and distributors can market them. FSSAI maintain a list of more than 500 ingredients, and many of these are found in our kitchen shelves (such as salts, sugar, baking soda, monosodium glutamate, and etc.).  Needless to say, food manufacturers must remain compliant with Food Safety Packing and labeling regulation and any deviation considers as an offense under the rules and regulation made thereunder.

Summary:

As stated earlier food additives have been used for centuries to preserve food, improve its taste and appearance, and provide a better mouth feel.  Recently, FSSAI encouraging a step to curb malnutrition through fortification, here once again the use of food additives have been extensively used. Today, food additives are strictly controlled by FSSAI in India for safety and are approved only after thorough testing and evaluation. FSSAI work closely with food industry peers and international regulatory agencies to ensure that substances added to food are safe for human consumption.

Shelf life study concept basic

belgian-consumers-confused-by-eu-shelf-life-labels_strict_xxl

Shelf life, most of us agree that it is one of important aspect when it comes to buying a food product from your local supermarket. But, most of us still wonder that what this term actually mean?  Shelf life is the period of time within which the food is safe to consume without considerable change in organoleptic (taste, texture, odor, appearance), microbial spoilage and chemical changes when it stored at an appropriate temperature condition.  This generally indicated on food label by either a best before date or a use by date or an expiry date.

Food Safety Standard Authority of India (FSSAI) – lingo on shelf life:

According to FSSAI – Food Safety Standards (Packaging and Labelling) Regulation 2011 under section 2.2.2.10 all pre-packaged food products need to be mentioned the life of products by either a best before date or a use by date or expiry date.

Best Before date:

Reflects the length of a period a food can reasonably be expected to retain its best quality example: flavor, and taste.  This terminology generally used for a product which is longer shelf life more than three months example: Rice, Dried, and Frozen food.

Use by date 

Reflect the length of period food can reasonably be expected to be safe to consume when stored at an appropriate storage condition Example: Milk, Fresh poultry, and cooked meats.

Expiry date:

It pronounces similar meaning of use by date.  However, as per the FSSR 2011, on specific products such as “Aspartame, Infant food substitute, and Infant foods”.

Factor influencing the shelf life of a product:

What is the shelf life of my breakfast bread slices? Unfortunately, there is no straightforward answer to this question. Foods are perishable by nature. Upon storage for certain period of time, one or more quality attributes of a food may reach an undesirable state.  Therefore it is very important to control parameters influencing deterioration or spoilage. These factors are commonly known as the end of shelf life parameters (EOSL). However, there is a considerable difference in spoilage rate for a product to product. EOSL parameters can be broadly classified into two groups a) Microbial spoilage b) Non- Microbial spoilage

Microbial spoilage:

The growth of some of microorganism in food such bacteria,spoilage or food poisoning. The EOSL parameter determined by recommended Indian Food Safety regulation or guidance.

Non- microbial spoilage:

There is numerous way foods get deteriorated during the course of storage before it reaches to a consumer. Unlike to microbial spoilage, the results of deterioration not necessarily being harmful (food poisoning) but can certainly result in the foods no longer in an acceptable state. Some of the EOSLs are. I) Moisture gain or loss, II) Chemical change, III) light induced change, IV) temperature change, V) physical damage

Methodology:

There are two different test methods for conducting or determining a shelf life of product a) Direct method b) Indirect method

Direct method (Real time)

This is one of the commonly used methods. It involves storing the product under specific conditions for a period of time longer than expected shelf life and checking the product at regular intervals to see when it begins to spoil. As stated earlier procedure of the study is unique for each product

Indirect method (Accelerated)  

It allows for shelf life prediction without conducting full-fledged storage trial. It is very useful for the product has longer shelf life.  The two most common indirect method are a) accelerated shelf life studies b) predictive modelling.  The first indirect method (predictive modelling) uses information from a data base that predicts bacterial growth under preselected conditions which later used to calculate shelf life of a product.  The second indirect method (accelerated shelf life studies) involves intentionally increasing the product deterioration, through increasing the storage temperature.

 e407121499

The tool used in accelerated studies is “the rule of ten” or Q₁₀, which is the factor by which the rate of spoilage increases when the temperature is raised by 10⁰ C. It is calculated with the following equation.

Q₁₀ = (R2/ R1) ⁽10 / (T2-T1⁾⁾

Planning the shelf life study:

Shelf life study must be planned in order to give an answer to some important following question:

  • Which types analyses must be carried out?
  • How many analyses must be carried out?
  • How many samples need to withdraw per analytical point?
  • Which period is most appropriate to perform the study?

Responsibility of calculating a shelf life

Food business operator involved in packages and sells food that is required to be date marked is legally responsible for calculating. Along with shelf life on the food label, it is mandatory to mention storage instruction / appropriate storage condition to meet that shelf life. Generally, it is perceived that this the responsibility of the manufacturer, but it can also be re-packers, secondary processors, food retailer, and supermarkets.

Reference:

  • Principles and methodologies for the determination of shelf life in foods – Antonio Valero, Elena Carrasco, and Rosa M Garcia Gimeno
  • A guide of calculating the shelf life
  • The process of conducting a shelf life study

 

Taxing sugary drinks can reduce consumption, help beat obesity, diabetes -WHO

WHO urges global action to curtail consumption and health impacts of sugary drinks

Soda-tax in Mexico

In a new WHO report launched this week on World Obesity Day, expert findings show that taxing sugary drinks can lower consumption and reduce obesity, type 2 diabetes and tooth decay. Fiscal policies that lead to an at least 20% increase in the retail price of sugary drinks would result in proportional reductions in consumption of such products.

Click the link below for executive summary:

http://apps.who.int/iris/bitstream/10665/250303/1/WHO-NMH-PND-16.5-eng.pdf

HYGIENIC FACILITY STRUCTURE IS A FUNDAMENTAL REQUIREMENT FOR FOOD SAFETY

azam-mbagala-estim-construction-pbf_2764

In order to produce safe food manufacturer or food business operator adopt, follow, and sustain good manufacturing practices and HACCP to produce safe food for consumers. Did you know? The starting point or fundamental of food safety majorly resides at your facility. Yes, h Product contamination may occur not only at equipment level but also at the factory level. Therefore, design and construction of food processing and handling area in a hygienic way become an indispensable requirement. Hygienic design deals with details of hygienic design and construction of the physical structure and surrounding. An engineered design of food handling, processing, storage facilities and equipment to create a sanitary processing environment and to produce pure, uncontaminated, quality products consistently, reliably and economically (H.L.M. Lelieveld)

There is numerous consideration of design to be given when constructing a new grassroots or amending food processing facility to the great extent to control chemical, physical and microbiological hazard directly or indirectly. In generally the processing facility areas are differentiated into two broad categories i.e. external and internal.

EXTERNAL

Site Selection: Hygiene starts with location selection. Law says ideally food establishment need to be located away from pollution and produce disagreeable or obnoxious odours, fumes, chemical and biological emissions. For example, if the facility to process meat, poultry, vegetable oils (high-fat contents) then the site surrounding relatively odourless since fat is flavour carrier and will pick up odour cause off-flavour easily.

Water supply:

dc9a495a-d90d-47fe-9bbc16c3b82b3db8

The site should have adequate of a source of potable (human consumption) water throughout the year even for future expansion.

  • The incoming water line designed for adequate volume and pressure as desired.
  • If pressure not sufficient than storage tank and booster pumps would be required.
  • Water storage tank constructed in such a way to avoid the possibility biological contamination and enhance cleaning and sanitization.
  • An adequate supply of cold and hot water provision to be made available as desired to adhere good manufacturing practices.

Landscaping: Sanitary landscaping is one of important barrier controller of rodents and keeping dust to a minimum.

  • The processing facility surrounding area shall have grass free strip and lined up with a thick poly liner to keep weeds down and then filled pea gravel.
  • The walking area and driving area shall be surfaced with concrete, that has been effectively treated to minimize dust, facilitate maintenance
  • Tree around the plant is not recommended since they provide roosting and nesting spots for birds. If require trees, it is recommended to away from 30-40 feet.

Roof Area:  Roofs are the equally important area as like the processing area. However, it is often ignored when it comes to sanitary design. It can be a major source of contaminants, especially if they are constructed of un-cleanable material i.e. tarpaper gravel (H.L.M. Lelieveld). There could chance of vegetation formation ranging from bits of grass and weeds. Some of the parameter to be considered at the time of roof selection are:

  • Drainable and cleanable
  • Discourage water accumulation
  • Designed with downspouts to handle rain water.
  • All openings through the roof are curbed and flashed
  • The curb should extend 12 inches (0.3 m) or more above the finished roof
  • Do not place insulation on the inside of the curb wall, as it is difficult to clean and frequently becomes infested with insects
  • Roof penetrations for vents, intakes, oven vents, air-handling systems and some utilities must be sealed to prevent water leakage and subsequent interior air and surface

External lighting: Selecting and positioning appropriate light and location are essential in order to maintain the hygienic environment. As many of us know that light can be insect attractant, especially those that emit a high level of ultraviolet light. Where ever possible, it is suggested to the position about 30 feet (9 Meter away). Recommended light for the external area is high-pressure sodium lights, as they have a whiter light, low UV, and use less energy.

INTERNAL

Appropriate layout: Interior of the food processing facility must be designed hygienically so that the flow of material, people, air, and waste can proceed in the right directions. Some of the important for the appropriate layouts are:

The flow of material needs to be in one direction. Logically it shall follow the sequence of operation i.e. receiving raw material …… and finally dispatch finished products.

  • Barrier or separation to be created between clean and unclean area
  • Workflow needs to be smooth and to extent possibly straight with minimal crisscrossing
  • Flow of food waste and discarded material shall be in the opposite direction
  • To extent possible designed to minimize non-essential personal traffic from passing through the processing and packing area.

Floor: The floor is the most important part of food processing area. Needless to say, it is the most abused part in food processing area such as chemical, water, dust, cleaners, sanitizers, acid, lubricant, food particles, dropped equipment, tools pallet dragging, temperature, hot water or cooking oil foot traffic, forklift and pallet jack traffic. Therefore floor shall be selected considering all above to withstand all kind of abuse i.e. durable, smooth and easy to clean.

  • Monolithic coating at processing and production area – seen as good flooring material
  • Floors should be sloped toward drains and provided with curbed wall floor junctions, with the curbs having a 30-degree slope to prevent accumulation of water, dust or soil.
  • Concrete flooring is not recommended for high-care production areas, because it can spill and absorb water and nutrients, allowing microbial growth below the surface.
  • Wall – floor junctions to have a smooth rounded finish for ease of cleaning.

Walls: Wall requirements greatly vary depends on the location i.e. external and internal. Requirement of external walls are:

  • Water, rodent and insect proof
  • Light density or cinder blocks not recommended as they are porous and encourage pest / insect infestation / harbourage.
  • All wall penetration for wiring, plumbing, ventilation, and utility pipes shall be framed and sealed with metal or galvanized hardware cloth to withstand rodent gnawing

Interior Wall:

  • Inside surface of the wall should be water resistant, smooth, and washable.
  • Should not have ledges to collect dust and debris.
  • Wall plates should be sealed to prevent insect entry and dust accumulation
  • The edges of walls, especially at the base, are to be protected with sanitary bumpers or coved curbs to prevent the walls from chipping since chipped walls are bacteria and insect breeding places.
  • Crevices at wall-ceiling junctions are to be eliminated to prevent insect or rodent harborage.
  • Protective barriers recommended for areas where there is a high chance for potential for damage ( example Wall guards, Bollards )
  • In wet areas blocks or tiles should be constructed using stacked bond rather than the running bond method to avoid moisture observation.
  • Wall in a facility shall be designed without windows in processing, packing and storage area.

Ceiling: It is often neglected from sanitary design and construction perspective. Improperly constructed ceiling become a room for condensation, contamination, and eventually, increase the chance of food hazard incident.  Some of the requirements of ceiling are:

  • Should easy to clean, smooth and non-absorbent
  • Good reflector of light
  • Dropped ceilings are to be avoided in manufacturing areas
  • Horizontal beams, pipes, and similar items are to be avoided over exposed products areas and food contact surfaces.
  • Ceiling crevices are to be eliminated between pipes, supports hangers, etc. by caulking

Drain: Did you know? Floor drain proved to be the source of Listeria in food processing facility unless correctly designed, installed, and maintained, and continually cleaned and sanitized (H.L.M. Lelieveld). They basic performance expected from the drains are

  • Drained floor
  • No pounding or standing of water in product floor
  • Designed to carry the maximum anticipated load to prevent any problem of flooding at your premises
  • Adequate control measures should be in place to prevent insects and rodents from entering the processing area from drains.
  • Drain channels shall be at least 15 cm from the floor and drainage channels should not place alongside walls
  • P -traps to be used that create a water­ lock that keeps sewer gases out of the plant.
  • Drain Channel Material –Stainless Steel can bear high temperatures, and it proves excellent in acid resistance. More importantly, it is anti-bacterial which is required for food processing facilities.
  • Drain should be accessible for cleaning and application of sanitizer on routine basis
  • Square bottom trench drains not recommended due to maintenance difficulty
  • The grates constructed on the drain to withstand foot traffic and any other equipment movement.

Heating Ventilation Air conditioning System: Did you know?  Sara Lee hot dog Listeria incident (USEPA, 2003) occurred due to airborne contamination. Maintaining clean and appropriate air pressure becomes very important. Air flow within a facility should flow from clean to dirty area. The thumb rule for food processing areas is a minimum 6±12 air turns per hours i.e. the volume of air in the room is changed 6±12 times per hour. A sensitive area like final processing area and packing highest filtered air pressure should be used. The ideal HVAC system:

  • Cools and heats
  • Humidifiers
  • Filter for clean air
  • Not from contaminated source
  • Pressurizes the room
  • Keeps ductwork out of the room.

The facility should have air tester to determine the microbial load of air entering into the facility. An air tester is even more important at ready to eat product handling facility 

Lighting:

h400mh

Sufficient amount of lighting is important in food processing or handling facility in view of safety, cleaning, sanitization, employee comfortability and related operations. Few criteria are:

  • Without causing glare
  • Preference should be given to lighting mounted on ceilings rather than on walls
  • Formation of shadows to such an extent as to cause eye-strain or the risk of accident to any worker
  • Either the light fixtures have an unbreakable cover or shatter proof bulbs
  • Low UV emissions light should be considered in processing area to avoid fly attraction.

In general Metal halide lamps are widely used in food processing area due to intensities and distribution capability. USDA generally suggested range of lighting has been reproduced below:

Food Processing Type Lighting area Illuminance (FC)
Meat General 30
Freezer 30
Dry storage 30
Inspection 50
QC Inspection 50
Others 30
Poultry Traditional inspection 50
NELS /SIS/NTI Inspection 200
Pre – and Post-chill inspection 200
Re-inspection 200
QC Control 200
Others 30

Source: LEDs Magazine

Storage: Sufficient facilities to store raw material, packaging material, immediate products, finished product, chemical and etc., Basic expectations are:

  • Separate storage area for raw , intermediate , and finished products, including chilled, frozen, packaging,  cleaning chemical, equipment, and etc.,
  • Access to material storage area should be controlled
  • Cold stores to extent possible equipped with an automatic temperature control system to alert technical personnel when the temperature rises above the desired
  • Floors in these areas capable of withstanding frequent cleaning, equipment movement.
  • To extent possible racks to be made of chemical / corrosion resistant.
  • Designed to enable stock rotation (FIFO) and batch traceability.

Personal facilities: Hand wash station, Rest Room, locker room, and break room should be designed with sanitation in mind. Did you know?  Nearly around 25 % of foodborne outbreaks can be avoidable if adequate hand washing were accomplished (H.L.M. Lelieveld). Some of the important criteria are:

  • Toilet areas are vented outside of the plant  by exhaust fan
  • Katsuyama (1993) stated that the minimum air flows 35 cubic feet of air per minute for each of the water closet or urinal
  • Negative air pressure needs to be maintained at locker and restroom
  • Recommended to use maze design so nothing has to be touched going in and out of the room.
  • Should not open directly in food processing area
  • Floor, Wall, Ceiling shall be in a match with another part of the facility.
  • Hand wash sink should wall hung and water activated with knee , thigh or sensor
  • Food operated no longer recommended due to perceived cleaning difficulties on undersides of petals.
    • Adequate supply of cold and hot water to exercise hygienic practices

Reference:

The handbook of hygienic control in the food industry –edited by H.L.M. Lelieveld

 

Birds: Always an unnoticed pest threat in food industry

 

pigeon_png3426

As a manufacturer or food business operator, we also know typical pests that create the critical problem in our operations such as ants, cockroaches, flies, mice and rats.   You may find various pest control operators offers a different set of solutions for these pest problems.  However, there is the serious forthcoming threat that many manufacturer or food business operator face these days where solutions and answers are harder to come by – birds.

Needless say like rodents and insect pests, birds pose through their droppings, and feathers.

Preventing birds from getting into manufacturing or food-handling area are imperative in view of public or consumer health, as matter of fact the mere presence of birds could lead audit failure, shutdowns, loss of customer, and significant revenue loss. In addition, birds can cause structural and hygiene issue not only that building covered with bird and dropping send a signal to other about perceptions of cleanliness and hygiene.

Though there are a number of effective techniques available to deter birds. It is very important that the pest control operators has knowledge of local laws and regulations and their safety requirements.

Listed below are some of effective bird control systems:

Exclusion:

Though the method is very traditional, it still remains the most effective among others. Using a variety of material like netting, sheet metal, screening and strip doors you can keep birds from accessing areas of your manufacturing or handling area.

netting

Roosting Modification:

Often bird roost and perch on ledges, beams, over signs, dock shelter, and even signs. By adding mechanical controls to these areas, such as anti-roosting wire, spike system, and wire deterrent, you can force birds to relocate to another area.

downloadwire

 

Behaviour modification:

By altering environment on roosting and perching area, you can trigger bird’s safety and security and scare them to away from the locations. The tools used to make these modification are Ultrasonic / harassment tools, electrified track system, tactile (gel coating) / taste and smell repellents.

Trapping:

Though the only methodology provides a temporary solution, this method is a humane means of relocating bothersome birds.

Hazing and turf: 

(Methyl Anthranilate – MA- naturally occurring compound in grapes and citrus fruits). The chemical need to applied over affected area at a specified interval to deter the bird from your facility

 

Food safety program to provide much-needed training in wake of new food safety rules

48452952 - packaging dry goods

Each year one in six Americans become sick from consuming contaminated foods or beverages. That’s according to the Centers for Disease Control and Prevention, which also reports that annually 48 million people in the United States get sick from a foodborne illness. Of those, 128,000 people are hospitalized and 3,000 die. To prevent these outbreaks, new regulations have been put in place to reduce foodborne illness through preventative measures.

While the regulations went into effect in 2015, many in the food industry are unprepared to comply with the new rules, which require detailed food safety plans, said Michael and Charlie Kalish, twin brothers who have a consulting business that assists in developing food safety plans. To help address the need for training, the brothers will be leading a food safety workshop in partnership with UC San Diego Extension.

Cheese-makers by trade, the brothers gained valuable knowledge about food safety principles and new ways of approaching manufacturing and holding food while working on farms, manufacturing facilities and warehouses in Europe and the United States. Working as consultants to local creameries, they realized there was a need for more food safety training.

“When we started consulting, the opportunities that were popping up were food safety related,” said Michael. “Businesses really needed help developing food safety plans. What has made us successful is our ability to identify an opportunity. We gave it a shot and it has just exploded.”

In 2015, the Food and Drug Administration published the final rule for the Food Safety Modernization Act, requiring facilities that manufacture, process, pack or hold food for consumption in the United States, be required to have a Preventative Controls Qualified Individual (PCQI). The new rules are considered the most sweeping reform of food safety laws in more than 70 years.

“The paradigm shift is not only going toward inspecting on good manufacturing practices but also looking for a documented food safety plan,” Michael said. “Now we are seeing not just inspection, but an audit. That’s one of the biggest changes.”

The FDA estimates that the new regulations will affect more than 83,000 food facilities requiring them to institute a number of new safety requirements as well as keep detailed records of their compliance.

The brothers recognized the growing need for highly knowledgeable professionals who could develop food safety plans for businesses of all sizes.

“Food safety regulation can be extremely convoluted, which is why there is a real need for professionals who specialize in food safety – someone who takes the time to read the fine print and gives these businesses what they need to make informed decisions,” said Michael.

Michael and Charlie Kalish became two of the country’s first and youngest Food Safety Preventative Controls Alliance (FSPCA) lead Instructors and are now educating businesses around the country on how to comply with new federal regulations. They are partnering with UC San Diego Extension to put on a two-and-half day workshop from September 28 to September 30, 2016. This training, which the Food Safety Preventative Controls Alliance developed, is the only standardized curriculum that the FDA recognizes for the new Preventive Controls for Human Food rule. Attendees who successfully complete the course will meet the requirements to be considered a preventive controls qualified individual, also known as a PCQI.

The workshop will benefit employees from a wide diversity of food businesses of all sizes across the supply chain, including manufacturers, warehouses, distributors and retailers/restaurants. Since 2007, national job postings for food safety experts increased more than 300 percent.

Because of that, the Kalish twins said there are not just more job opportunities but also there’s good money to be made. As it stands now, demand is outstripping supply when it comes to food facilities being able to find well-trained quality assurance professionals who can implement the Food Safety Modernization Act’s new rules.

“I think the industry, as far as food safety experts are concerned, could really use a lot more competent people who are eager to learn,” said Charlie. “Training is critical and learning how to apply food safety principles is the first thing you need to do.”

To find out more about UC San Diego Extension’s food-safety workshop, visithttp://extension.ucsd.edu/foodsafety.

Top 5 HACCP Reassessment Mistakes

Whether your USDA plant operates under HACCP principles or you’re an FDA plant preparing to implement a food safety plan under FSMA, avoiding food safety pitfalls should always be a top priority. By maintaining control over major food risks, the industry assures consumers that food products are as safe as current science, technology, and regulatory environments allow.
However, no matter how careful we are, mistakes can and do happen. To help minimize risk, I’ve highlighted five deficiencies auditors frequently encounter when reviewing HACCP plan reassessments.


 

1. Inaccurate Flow Diagrams

All manufacturing process steps must coincide with the written flow diagram. Remember to consider the product re-work flow and addition points, product repacking, and contact points in the process where water and/or gasses such as CO2 and N2 are added.  As a best practice, I recommend verifying the flow diagram among team members to be sure all the process steps are represented.

2. Incomplete Hazard Analysis

Some hazard analyses are simply cookie-cutter versions declaring “no hazards identified” or just listing “pathogens” as a hazard.  When performing your hazard analysis, make sure to consider the appropriate raw material hazards and identify the specific pathogen of concern. When assessing any potential hazards in your manufacturing process, be sure to review your hold/foreign material log and maintenance logs when trying  to determine your level of risk.

  1. Inadequate Decision Making Documents and Scientific Data

Facilities must justify the frequency of their monitoring procedures if the product is not being monitored 100% of the time. You will need to justify your frequencies as written in the HACCP plan.

Best practices include:

Be sure scientific references used as supporting documentation in validation of your plant’s HACCP Plan are relevant to the products being produced. Reference your scientific/technical documents within the body of your Hazard Analysis, or include footnotes.

4. Inadequate Direct Observation

It’s important to conduct direct observations of employees performing each monitoring procedure. Observations can quickly identify any procedural issues and key training opportunities. Direct observation of monitoring activities is a verification procedure listed in 9 CFR 417.4(a) (2), and find they are often overlooked or are not completed with the frequency outlined in the HACCP plan.

5. Ineffective Corrective Actions

Often we run across training and retraining as a corrective action, but if you have to retrain the same person 3 to 4 times on a task, you may want to look at putting a more accountable person in that position. Corrective actions should include a thorough root cause analysis performed by productive, knowledgeable, and contributing team members with the goal of solving the problem the first time.


IN SHORT

By diligently seeking to address these five areas and eliminating them as possible deficiencies, you’ll help to ensure that auditors will be that much less likely to find fault with your HACCP plan reassessments.

Source : http://blog.alchemysystems.com/top-5-haccp-reassessment-mistakes?utm_content=39249268&utm_medium=social&utm_source=linkedin