Food safety being a shared responsibility of all supply chain participants in farm to fork continuum, is not always technical but also behavioural. Food service operators share equitable responsibility of ensuring safety of food in the supply chain. Every year, an estimated six hundred million people are sickened by contaminated food. Studies have documented poor management commitment and improper food handling practices as major causes of food safety failures in food service facilities. Food poisoning accusations have cost food service operators loss in consumer base, reputation damage and product liability litigations. Increase in number of food-borne illnesses and outbreaks have emphasized the need for stricter food safety interventions to protect public health. Therefore, the need of the hour necessitates food service leaders to establish food safety organizational culture as a food safety intervention to facilitate production and service of food in safe and sanitary environment and protect customers from food safety hazards. Food safety culture reflects organization's genuine commitment the food safety compliance and noticeable safe food handling behaviors, attitude and practices embedded in employees.
Model an Upstream Food Safety Cultural Framework
Well first of all, food service leaders must create an organizational structure that effectively manage organizational resources. Blend organizational vision for food safety compliance, performance benchmarks and key performance indicators to track and accomplish food safety goals. It is important to implement and document food safety management system that outlines the processes, instructions, procedures and reports required to ensure food safety. Food service leaders must develop competency model by determining factors that contribute to food safety failures through efficient root cause analysis, identifying key processes and team members and establishing clearly defined reporting structures. This will help in laying the groundwork for effective food safety leadership and communication. Put emphasis on standardizing processes and procedures (Time temperature requirements, cleaning and sanitation control, allergen control and employee hygiene- to name a few) to eliminate risk of deviations and implement a monitoring system to ensure reduction in possibility of food safety issues. It is worthwhile to invest in continuous improvement activities to achieve optimal levels of proficiency and viability in performance and processes. Emphasize on recruiting food safety focused employees and build their capabilities and competencies by determining training need. Create reward systems that encourage employees to consistently practice safe food handling behaviours. Long-term culture sustainability can only be achieved by evaluating current culture's effectiveness, identifying gaps and taking consistent corrective action.
Showcase Commitment Based Food Safety Leadership
Employee's values and opinion on food safety often differ from those of the organization. It is commonly seen that individuals with positional power demonstrate more safety-related behaviors in comparison to individuals down the hierarchical level. Main obstacles in implementing and maintaining food safety culture are casual behavioral approaches, practicing non-standard processes and poor managerial commitment and attitude towards food safety. Food service leaders must demonstrate strong leadership by committing to food safety compliance, allocating resources and communicating food safety expectations clearly throughout the organization. Build leadership at all levels by encouraging managers to oversee food safety processes and reinforce food safety behaviours. Emphasize the importance of being proactive about food safety and getting involved in training, inspections and other food safety related activities. This will help in strengthening employee commitment to food safety. Sanitary design criteria should be considered an essential prerequisite for food safety and integrated into the planning and design process. Sanitary design standards, a strategic consideration of premises and equipment facilitate maintaining hygienic environment that is essential to mitigate food safety risk. Providing sanitary working conditions demonstrate senior management's commitment to food safety culture and can help influence employee behavior and increase commitment to food safety.
Showcase Leadership Centered Towards Risk-Communication Approach
Effective communication and engagement is important for survival of food safety culture. It is important to know how concerned employees are about food safety and how aware they are of consequences of food safety failures. Employees must realize their role in food safety and their accountability to food safety failures. Food service leaders must effectively communicate why food safety is important and how food safety is one of the top organizational priorities.
Employees should be given clarity on work responsibilities, critical control points, food safety policy and conformance standards. They should have complete understanding on risk associated with food products, the possibility of a hazard arising in the event of a loss of control, and the seriousness of the resulting illness or accident in order for them to understand how their poor food handling practices may jeopardize public health safety. Positively influence employee attitude and behavior so that food safety remains at the forefront of their minds and they consider it as their social responsibility. Food safety culture cannot be integrated and ingrained in employees when the sole focus is just to meet minimum applicable statutory and regulatory compliance. It is vital to train employees in risk and hazard specific to their area of work. Developing employees through training and awareness programs on hygiene and sanitation, supply chain risk assessment, preventive measures, food safety, corrective process behaviors and regulatory conformity will drive food safety culture. Food service leaders must shift from competency model to capability model by empowering skills, driving accountability and creating collaborative teams. Empower employees to respond to food safety concerns when there is an occurrence of process deviation.
Recognizing employees for safe food behaviors and practices is critical for boosting morale, improving engagement and strengthening food safety commitment. Posting posters and signs in the kitchen outlining food safety behaviours and practices is one major intervention to inspire staff and increase attention to food safety. Comprehensive involvement of quality control, purchasing and internal audit teams with food safety-focused responsibilities is principle to long term survival of food safety culture. Employees feel valued and have a sense of acceptance when they are educated, kept informed and recognized, resulting in increased employee engagement. Restaurant audit schemes consider food safety culture a key component in food performance management. Prevalence of an active safe food culture and employee’s knowledge on food safety hazards and practices could easily be evaluated in audits through observations and interviews. To be audit ready at all times, food service facilities must demonstrate success in the context of food safety related activities and strengthen food safety culture as part of continuous improvement.
The primary aim of establishing a food safety culture is to share common values and belief and eliminate behavior and procedure-based food safety risks. The culture must be integrated within organizational structure as a preventive measure. It should also be noted that implementation, monitoring and enforcement under dedicated leadership is pivotal for culture to grow. Once integrated and maintained, it benefits organization in form of improved governance, increased dedication, better cooperation and consistent compliance with operational processes and standards at all levels and by all team members. In view of legal obligations, food service leaders must strive to leverage behavioural change to improve food safety standards. As a matter of fact, customer may differ in food preferences but the pursuit of safe and wholesome food is universal.
Dhruv Kishore Bole
MBA - Hotel Management I CGSP I PCQI I HACCP I ISO 9001:2015 I FSSC 22000 V5 I Lean Six Sigma I cGMP I FPM I Revenue Management I Allergens I OHSMS I FOSTAC - FSSAI
Dhruv Kishore Bole is a hospitality and food safety specialist with qualifications in hotel management, food safety and quality management system. He has extensive experience spanning over twelve years in operational and training roles. His expertise centers on hospitality operation, food and beverage services and food safety. He has attended numerous workshops and conferences on customer service, leadership and food safety and quality and is certified by Food Safety and Standards Authority of India in food safety competencies. He is an empanelled trainer with Hero Mindmine and IL&FS Skills. He is a member of Quality Council of India and an instructor and proctor with ServSafe for India region.
- Apr 06 2021 06:11 AM
- by Simon
HACCP and Compressed Air
The new rules created by the FDA to fulfill FSMA require that manufacturers must conduct a Hazard Analysis (HA) as part of the revised current Good Manufacturing Practices (cGMP). Hazard Analysis serves to identify and inform Critical Control Points. Critical Control Points (CCP) are steps, stages, or points in a process where a failure of a standard operating procedure or equipment could lead to the contamination of product and resulting harm to consumers. Together, Hazard Analysis and Critical Control Points are referred to as HACCP. Each identified CCP must be monitored, and such monitoring must be documented. The HACCP process informs the frequency and tolerance of that monitoring. For example, if milk must be pasteurized to a temperature of 161 F, the step of the process that heats the milk is a Critical Control Point, and the functioning of the equipment and temperature achieved must be monitored and documented.
Often, Critical Control Points are less obvious. In the context of compressed air and gas, if a facility uses compressed air to cause a product to flip at a certain point, that compressed air is in direct contact with the food and becomes a potential source for contamination. Compressed air that is used to clean a surface that is used to prepare food has indirect contact with that food. Obviously, air or gas that is in direct contact food poses a more significant risk than gas that only indirectly contacts food, but both are still Critical Control Points.
Common utilizations of compressed air or gas that are in direct contact with food include drying, sorting, freezing, moving, carbonating, culturing, inert packaging, and modified atmosphere packaging. Some examples of indirect contact of compressed air or gas with product include cleaning of surfaces, packaging manipulation and pneumatically driven equipment. Each of these represent a Critical Control Point.
Contamination of Compressed Air
Depending on the compressed air or gas system, contamination can take several forms and have multiple sources. Common contaminants of compressed air or gas include solid particulates, oil vapors and aerosols, water vapor or aerosol, and viable microbial contamination. Particulates are commonly a consequence of friction within the system. They can originate from unions, valves, seals, and other fittings, as well as the moving parts of the compressor itself. They may also be a consequence of the ambient air the compressor intakes for the system. Oil vapors and aerosols are commonly a consequence of compressor pump oil, but may also originate from cleaning materials, solvents, and contamination of the ambient air the compressor intakes. Water vapor and aerosol originate from the ambient air used by the compressor. Microbial contamination is ubiquitous, and may be present in the ambient air, on the equipment at the time of install, or contamination at the point of use. Microbial contamination is also more common in the higher humidity segments of a compressor system, such as receiver tanks and condensate traps.
These contaminants are removed at various stages throughout the compressor system by subsystems such as pre-filtration, condensate traps, driers, and midstream and point-of-use filters. When applying the HACCP process to a compressed air or gas system, the Critical Control Points are most commonly the point-of-use filters, as well as the condition of the point-of-use itself. As such, a risk analysis for each point of use should be performed to identify Critical Control Points. The risk analysis will also inform the monitoring criteria for each CCP, and a monitoring plan can then be developed. Once the monitoring plan is established and documented, records of monitoring the CCP according to the monitoring plan must be maintained. A summary of the FDA guidance for filtration, as well as guidance or compliance requirements from other regulatory bodies can be found here. Some best practices guidelines for microbial contamination can be found here.
Testing your compressed air and gas:
Many different options exist for testing a compressed air or gas system exist. These range from expensive in-line instrumentation to relatively cheap single use detector tubes and impactors. However, testing a system in-house opens a whole range of liability and potential hang-ups. Furthermore, any testing done will require quality control and calibration of the testing apparatus.
Accredited laboratories offer a measure of confidence and simplicity at cost-effective prices to help ensure continuing FSMA compliance. Accreditation to ISO 17025 guarantees appropriate handling and analysis of test items and ensures accuracy and consistency. Trace Analytics ups the ante by providing education and resources to allow operators to make intelligent and confident decisions regarding the scope and criteria for monitoring of their compressed air and gas CCPs. Our analysis reports provide easily referenced documentation of monitoring. Training resources are provided to ensure our customer’s ability to fulfill FSMA training and competency requirements. Our HACCP trained customer service team and long experience in the compressed gas industry are powerful tools for our customers, regardless of whether they are new to HACCP, or seasoned veterans.
Matthew DeVay has over 10 years of experience in Quality Assurance and chemical testing. As the Quality Assurance Director for Trace Analytics, LLC, he oversees and directs compressed air analysis and has helped countless customers successfully troubleshoot compressed air systems. He is a member of the Medical Gas Professional Healthcare Organization, and an expert in GC and GC/MS analysis.
Trace Analytics is an A2LA accredited laboratory specializing in compressed air and gas testing for food and beverage manufacturing facilities. Using ISO 8573 sampling and analytical methods, their laboratory tests for particles (0.5-5 microns), water, oil aerosol, oil vapor, and microbial contaminants found in compressed air. For over 29 years, they’ve upheld the highest industry standards of health and safety, delivering uncompromising quality worldwide in accordance with ISO, SQF, BRC, and FDA requirements.
Links and Resources:
Trace Analytics Resources
- The Seven Principles of HACCP Application: Compressed Air Systems - https://www.airchecklab.com/manufacturing/the-seven-principles-of-haccp-application-compressed-air-systems/
- HACCP and Compressed Air Testing - https://www.airchecklab.com/news/haccp-and-compressed-air-testing/
- Compressed Air System Risk Assessment: Do I Need to Test? - https://www.airchecklab.com/food/compressed-air-system-risk-assessment-do-i-need-to-test/
- Sampling Plans for GFDI-Required Compressed Air Monitoring - https://www.airchecklab.com/manufacturing/sampling-plans-for-gfsi-required-compressed-air-monitoring/
- Food Safety Management Systems: Who Regulates Compressed Air? - https://www.airchecklab.com/food/food-safety-management-systems-who-regulates-compressed-air/
- Our Compressed Air – Food Grade Air in Manufacturing - https://www.airchecklab.com/services/manufacturing-iso-8573-1/food-grade-air/
- FSMA - https://www.fda.gov/Food/GuidanceRegulation/FSMA/
- FSMA – Final Rule for Preventative Controls for Human Food https://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334115.htm
- Lists “Upcoming Compliance Dates”
- Managing Food Safety: A Manual for the Voluntary Use of HACCP Principles for Operators of Food Service and Retail Establishments - https://www.fda.gov/Food/GuidanceRegulation/HACCP/ucm2006811.htm
- DSMA Preventative Standards - https://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm256826.htm
- Preventative controls plan is required
- CFR- Code of Federal Regulations Title 21 (references compressed air) https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=111.27
- FSMA Guidance Documents - https://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm253380.htm#guidance
- Micro - https://www.fda.gov/food/guidanceregulation/ucm064458.htm
- HACCP – GMPs – Parker reference - https://www.foodengineeringmag.com/ext/resources/WhitePapers/Compressed-Air-for-Food-GMPs.pdf
- Compressed Air GMPs for GFDI Food Safety Compliance – Parker CABP article - https://www.airbestpractices.com/standards/food-grade-air/compressed-air-gmps-gfsi-food-safety-compliance
- Jun 29 2020 06:01 PM
- by Simon
Understanding the Differences
There are some fundamental differences between HACCP principles and the HARPC requirements, a couple of the most controversial may be that the Preventive Control Rule does not recognize CCPs, or mention the use of a process flow diagram.
The rule also does not specifically state that a scope, including product description, intended use and intended user is required. The rule however, does imply that these elements would be needed, as the inherent hazards from the raw materials and finished product need to be included, plus those around the intended use.
When producing a system that complies to both sets of standards, CCPs, a process flow diagram, a scope, product description and details of the intended use and user are still going to be required.
Tackling the Contradiction in the Systems
There is one fundamental contradiction in the methodology of the two systems, which is all based on how likelihood is assessed.
Both systems require significance of the hazards to be determined, based on a risk assessment of severity and likelihood. The assessment of severity is aligned in HACCP and HARPC and does not pose a problem. The problem arises when the hazards are assessed for likelihood, as shown below:
HACCP: severity is assessed with the current controls taken into account
HARPC: severity is assessed in the absence of any controls
This small change, has massive implications.
In a typical HACCP system, we would include all the hazards that you could possible think of – so that all possible eventualities are covered. If we continue this approach into a HARPC system, and then assess these hazards in the absence of any controls, the number of significant hazards produced would be huge. More importantly, they would not be truly focused on the key food safety risks.
Therefore, when thinking about the hazards that should be included in a HARPC system, using the mind-set of less is more is the right way to go. Pertinent hazards should not be missed, but a structured approach of pin-pointing which hazards should be included is essential.
In my new book ‘Combine Your HACCP & HARPC Plan’ I have included a whole section about how this can be achieved, called the Hazard Extraction Stage. It uses some the elements of HACCP that we are used to, so it’s familiar, but utilizes them effectively to extract the really pertinent hazards for the specific product and process being assessed.
So What About the CCPs?
Once the hazard analysis has been carried out, using severity and likelihood (without the controls being taken into account) to determine significance, all significant food safety hazards must have a preventive control assigned.
In any combined HACCP and HARPC system, CCPs are still going to an essential element. Once the preventive controls have been established, we need to determine which of these preventive controls actually need to be CCPs.
So, to do this we need to have a way of determining them. The typical CCP decision tree is no longer applicable, because if we used it, we would end up with most, if not all of our preventive controls becoming CCPs.
We don’t want to go back to the time when we had loads of CCPs and we lost sight of what process steps are really critical to food safety.
To enable us to establish which of the preventive controls need to be ‘raised up’ to become CCPs, we need to understand the difference between a preventive control and a CCP.
The definitions can be broken down, so just the really key points from them remain. Then they can be compared side-by-side, so the distinction between them is clear.
The definitions are shown below:
Preventive controls prevent or significantly minimize the hazard
CCPs eliminate or reduce the hazard to an acceptable level
A preventive control is something that either prevents a hazard from occurring, or stops accidental contamination from reaching the customer.
A CCP as something that eliminates or reduces inherent contamination in the product.
So, to establish whether each preventive control should actually be a CCP, we need to ask if that preventive control eliminates or reduces the hazard to an acceptable level. Or, is the hazard an inherent contamination risk, and which the process step eliminates or reduces to an acceptable level. If it does, then it is a CCP.
By asking the right question of each of the preventive controls, the CCPs can be determined and they can still be focused on the really critical food safety risks.
If you’d like to learn more about the book ‘Combine Your HACCP & HARPC Plan’, please go to http://www.techni-k.co.uk/HARPC_Book
I’d also be happy to answer any questions you have on HARPC, if you would like to add them to the comments below.
Kassy Marsh is the author of Combine Your HACCP & HARPC Plan, step-by-step. Kassy started her career in the food manufacturing industry in 1998 and has developed an exceptional ability to implement simple and practical solutions, which can be effectively implemented into the factory environment. She is well known for her best practice risk assessments and specializes in food safety principles.
In 2015 she co-authored the book ‘Assessing Threat Vulnerability for Food Defence. This pioneering methodology is now one of the leading risk assessment tools in use for the assessment of food threats.
To meet the increasing demand for a methodology to assess food integrity, in early 2016 Kassy developed and co-authored her second publication ‘Assessing Error Vulnerability for Food Integrity’. This system is now used by a leading UK retailer as a training tool for their supply base.
Since starting her own consultancy business in 2012, she has become well regarded in the field of food safety risk assessment for her ability to provide simple, practical and easily understood step-by-step solutions.
Kassy can be contacted at www.techni-k.co.uk
- Jun 29 2020 06:10 PM
- by Simon
The HACCP Plan is a document which is based upon the principles of HACCP and which delineates the procedures to be followed. The HACCP System is the result of the implementation of the HACCP Plan thru the creation of the HACCP team: a multidisciplinary group of members who are responsible for developing, implementing and maintaining the system.
The production of safe food products entail that the HACCP plan and HACCP system are built upon a solid base of prerequisite programs. Prerequisite programs are procedures that concentrate on operational conditions providing the cornerstone for the HACCP system.
The most important point is that each section of the food chain supply management must provide the conditions necessary to defend food while it is under their control. Prerequisite programs originated from food regulations and intended food industry organizations accomplish this through the proverbial prerequisite implementation of the Good Manufacturing Practice (GMP) regulations enforced by the US Food and Drug Administration (FDA), under Section 501(B) of the 1938 Food, Drug, and Cosmetic Act (21 USCS § 351). The regulations use the phrase "current good manufacturing practices" (cGMP) or as usual name GMPs; GMPs were established to help define for the food industry the minimal sanitary conditions for processing safe food products. They include such areas as personal hygiene, operational practices, cleaning and sanitation, water safety, foreign material control, and sanitary design.
These conditions and practices (cGMPs) are now considered to be prerequisite to the development and implementation of effective HACCP plans. Prerequisite programs provide the essential environmental and operating conditions that are necessary for the production of safe food. Many of the conditions and practices are specified in federal, state and local regulations and guidelines.
In addition to the requirements specified in regulations, food industry sectors often adopt policies and procedures that are specific to their own operations. HACCP plans are reduced in scope, being limited to ensuring safe food for human consumption. Critical Control Points (CCPs) are normally used to address significant food hazards, but even this varies from one industry sector to another. In one industry segment, a certain prerequisite may be of minor importance, while in another the same prerequisite may be essential to ensuring food safety.
The existence and efficiency of prerequisite programs should be assessed during the design and implementation of each HACCP plan. All prerequisite programs should be documented and recurrently audited internally or externally by a third party auditor. Prerequisite programs are established and managed separately from the HACCP plan.
In order to select the most suitable prerequisite programs, food industries must consider the following: their type of organization and their own unique circumstances; the capabilities of their suppliers and service providers; customer needs and expectations; statutory and regulatory requirements; and good practices in their segment of the food chain, including all relevant standards and guidelines.
Variety of Prerequisite Programs
Different categories have been developed for prerequisite food safety programs. From a regulatory HACCP perspective, six prerequisite programs should be implemented: good manufacturing practices, pest control, trace and recall, chemical control, cleaning and sanitation, and customer complaints.
Sperber W.H., et al., describes eight prerequisite program categories: raw material controls, facilities, sanitation, training, production equipment, production controls, storage and distribution, and product controls.
The National Advisory Committee on Microbiological Criteria for Foods (NACMCF) provides impartial, scientific advice to federal food safety agencies and establishes eleven prerequisite programs: facilities, supplier control, specifications, production equipment, cleaning and sanitation, personal hygiene, training, chemical control, storage / shipping & receiving, traceability & recall, and pest control.
The International Organization for Standardization (ISO) specifies detailed requirements to be specifically considered in relation to ISO 22000:2005, 7.2.3 in its standard ISO/TS 22002-1:2009: a) construction and layout of buildings and associated utilities; b) layout of premises, including workspace and employee facilities; c) supplies of air, water, energy, and other utilities; d) supporting services, including waste and sewage disposal; e) suitability of equipment and its accessibility for cleaning, maintenance and preventive maintenance; f) management of purchased materials; g) measures for the prevention of cross-contamination; h) cleaning and sanitizing; i) pest control; j) personnel hygiene. k) Other aspects as appropriate. In addition, ISO/TS 22002-1:2009 adds other aspects which are considered relevant to food manufacturing operations: 1) rework; 2) product recall procedures; 3) warehousing; 4) product information and consumer awareness; 5) food defence, biovigilance, and bioterrorism.
It does not matter the variety or number of prerequisite programs necessary to implement to assure the production of safe food in the food chain supply; most importantly it is how management properly implements the CORNERSTONE OF HACCP within the facility.
U.S. Food and Drug Administration ( FDA ) . Managing Food Safety: HACCP Principles, HACCP & Managerial Control of Risk Factors. Retrieved August 20, 2013, from http://www.fda.gov/F...lFoodProtection /ManagingFoodSafetyHACCPPrinciples/default.html.
Sperber, W.H. et al., “THE ROLE OF PREREQUISITE PROGRAMS IN MANAGING A HACCP SYSTEM”, in Dairy, Food, and Environmental Sanitation 1998, vol. 18, no7, pp. 418-423
U.S. Food and Drug Administration ( FDA ). Hazard Analysis and Critical Control Point Principles and Application Guidelines, Adopted August 14, 1997, NATIONAL ADVISORY COMMITTEE ON MICROBIOLOGICAL CRITERIA FOR FOODS. Retrieved August 18, 2013, from http://www.fda.gov/F...nes/default.htm
ISO (International Organization for Standardization), ISO 22000 - Food safety management. Retrieved August 19, 2013, from http://www.iso.org/i...ds/iso22000.htm
Martin W. Torres: ASQ HACCP Auditor, SQF Auditor High Risk, BRC Auditor and SQF Consultant High Risk.
B.S. Industrial Engineering, B.S. Food Science. MBA-Quality. M.S. Food Safety. Member: ASQ Chicago, ASQ Division Food, Drug and Cosmetic.
- Jun 29 2020 06:46 PM
- by Simon