Why food safety?
We can explain the urgency and motivation for food safety management systems (FSMS) very easily! It is a matter of life and death. We need food manufacturers, as well as regulatory authorities, to plan and regulate the food safety of food products consumed.
As discussed in the previous article, titled “Food Safety from Farm to Fork”, we define food safety as the concept that food will not cause harm to the consumer when it is prepared and/or eaten according to its intended use (ISO22000:2005 international standard for FSMS). We plan for the financial side of our business, the possible human relation hazards and so forth, so why do we not also plan the management of risks relating to the food safety of the final product which the consumer will enjoy?
Safe production of food requires knowledge of foodborne pathogens, chemical toxins, food quality, labelling and food safety education. In some cases, the current South African system of food safety regulation is not prepared for managing food safety incidents effectively. The state departments are generally understaffed and untrained for the rapid changes required to manage food safety, especially when it comes to emerging pathogens and toxins, not to mention the lack of availability of state owned laboratories, which can significantly contribute to the safety of the product which lands on the end consumer’s plate.
Results of food safety
The result of a well implemented FSMS will be to supply a safe product to the end consumer. Other advantages will also come into play e.g. less rejects on raw materials on arrival which will increase productivity, less reworks on line which will add to the bottom-line of the company, less waste of packaging material for example due to less reworks, less returns due to product that stay within specification for the length of the shelf life. On top of that, there is the joy and pride of providing the consumer with a safe product.
Who is responsible for food safety?
Section 5 of ISO22000:2005 as well as the HACCP standard SANS10330:2007, are both very clear that highest level of management is responsible for the development, implementation and maintenance of the FSMS. The British Retail Consortium also emphasizes the fact.
A management representative has to be appointed by top management in order to report back at agreed intervals on the status of the FSMS. This representative then in turn has to appoint a HACCP or food safety team which will be responsible for the compilation, implementation, maintenance and review of the FSMS.
When to start with food safety?
The best time to start off the FSMS is NOW, if you have not started it already.
The best way to start is to compile the hazard analyses before production of food products start. Unfortunatel, in the majority of cases this is not done. But do NOT delay this matter any further - it is advisable to start (even if it on a small scale e.g. with one product line) with training in food safety as the starting point.
How to implement food safety
Once the food safety team is appointed and the necessary training has been performed, you can begin with a hazard analysis. The HACCP standard can be used as guideline. However there is more, the team has to obtain all relevant legislation, regulations and standards which are applicable to the end product, manufacturing process and facility. These have to be studied and the team members have to be fully aware of the contents.
Step One:
At first start with defining the product produced. All food safety matters important to the product have to be described, including the microbiological standard for the final product, the chemical parameters e.g. pH, storage temperatures required, the type of packaging used. This will help determine the oxygen availability for micro-organism growth as well as specific parameters which are important and which can affect the quality of the final product. The team must also consider the intended use of the product and possible abuse by the consumer.
Step Two:
Follow up with documentation of the production process. List the steps based on the decisions regarding the purchasing of raw materials, the distribution of the final product, to the first point of delivery in the form of a flow diagram. Make sure to include all processing parameters which are implemented. The product flow should then be indicated on a floor plan. Include the flow of staff and services on this plan (e.g. water, waste removal) in order to identify possible cross-flows which can pose a risk to the end product.
Step Three:
Brain storm each step to identify the hazards which might occur. Do not exclude any possible hazards.
Hazards to be considered can be classified as follows:
1. Microbiological hazards e.g. possible faecal contamination which took place at farming operations before raw materials arrive at the processing plant, cross contamination from food handlers, micro-organisms which might be an inherent risk to the product, micro-organisms which was reported to cause food borne illnesses in these category of products.
2. Physical hazards e.g. wood chips from pallets, flaking paint from walls and ceiling, metal from machinery, pips from the original fruit used.
3. Chemical hazards e.g. contamination with cleaning chemical residues, hazardous chemical contamination during transportation, inherent chemical compounds of the raw materials used.
4. Allergen hazards can be classed with or separated from chemical hazards. Remember, this is not limited to just the top eight allergens i.e. egg, cow’s milk, crustaceous and molluscs, fish, peanuts and tree nuts, significant cereals (gluten containing) as well as the presence there of in any raw materials used shall be taken into consideration. The Labelling and Advertising R146 of 2012 also stipulates that uncommon allergens should lso be identified, and possibilities of cross contamination identified and managed.
It is important to be specific when considering a hazard. Do not list the hazard as “microbial” for example without detail the organisms which pose a risk.
Step Four:
Now you need to determine and rate the possibilities of occurrence (i.e. the likelihood) of the specific hazards in the specific production facility. The history and occurrence which were researched to determine the likelihood must now be available in written format. The significance of the listed hazards (the extent to which the hazard will cause food borne illnesses when the consumer enjoys the final product) must also be recorded. The rating of both the likelihood and significance will be done according to a pre-determined standard. The combined effect of the likelihood and significance will then in turn be used to decide whether the hazard pose a significant risk.
Step Five:
The control measures which will manage the possible occurrence of the hazard during the manufacturing process need to be decided upon and listed as such. Control measures can include but are not limited to:
1. Temperature control e.g. chilling within a certain period of time to prevent microbiological growth and the survival of bacterial spores.
2. Cooking and similar heat treatment to a temperature of minimum 72°C for minimum 2 minutes which will kill the majority of pathogenic organisms.
3. Pasteurisation or sterilisation where product temperature was increased and maintained for a certain period of time and then chilled down within a specified period. This might include specific packaging methods e.g. metal cans, Tetrapak used for UHT milk.
4. Personnel hygiene management to limit possible contamination of hazards from staff to product e.g. by wearing suitable protective clothing, or hand washing verified by hand swabs.
5. Managing of the building controlling possible contamination from the structure, air and the likes e.g. flaking paint, impervious wall surfaces, openings in structure which can let birds and rodents in.
These 5 steps should be followed even in the smallest and simplest of processes. This is the crux of safe food. These principles are not reserved for large companies only nor those with sophisticated systems – this is BASIC. If you aren’t doing this you aren’t adequately considering food safety at all.
When a manufacturing company implements a HACCP system (either in line with ISO2200:2005 or SABS10330:2007) the identification of critical control points (CCP) must be done. When ISO22000:2005 is implemented, operational pre requisite programs (OPRP) must be identified as well. These are controls for specific hazards to be able ensure an acceptable level of that hazard is achieved.
In conclusion
This quote from Kathy Means, Vice president of Government and Public Affairs at the Pproduce Manufacturers Association USA, highlights the necessity of a well implemented FSMS: “The reality is that pathogens simply do not respect the size and type of operation”.
Can anyone afford not to have a food safety management system in place?
Author
Rika Le Roux Kemp
