Hazard Prevention is of Prime Importance in Food Safety

“WASHINGTON, June 20, 2019 – C&S Wholesale Grocers, located in Westfield, Mass. is recalling an undetermined amount of ready-to-eat and not-ready-to-eat meat and poultry products due to temperature abuse during transport, which may have resulted in the growth of spoilage organisms or pathogens, the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) announced today. Temperature abuse may result in the growth of the proliferation of Staphylococcus aureus, Shiga-toxin producing E. coli, Listeria monocytogenes and Salmonella. Here is yet another case of recall. Just imagine the cost of producing all that meat and now the cost of recalling it and the loss of reputation along with loss of huge money.(Source: https://www.fsis.usda.gov/wps/portal/fsis/topics/recalls-and-public-health-alerts/recall-case-archive/archive/2019/recall-070-2019-release?permalink=1561083720

Is this avoidable? Of course, this is avoidable! Certification to FSSC 22000:2018 is the solution to such recalls. FSSC 22000:2018 is the discipline incorporated in any facility with the simplified documentation system from Quality Systems Enhancement Inc. serves as a simple, easy to follow and easily implementable system which is insensitive to failure when implemented fully.

FSSC22000 is a Food Safety Management System (FSMS) recognized by Global Food Safety Initiative (GFSI) which includes international food safety requirements covered in ISO 22000:2018 and Good manufacturing practices mandated by FDA and reproduced in TS 22002-X (X relates to the section of TS 22002 to be chosen by respective sector in Food chain).

ISO 22000:2018 stipulates enforcement of Hazard Analysis Critical Control Points(HACCP) in the entire food chain or Hazard Analysis Risk-Based Preventive Controls. (HARPC)
FDA has directed that all facilities should incorporate HARPC in its final rule issued in Sept’2015.

“This rule, which became final in September 2015, requires food facilities to have a food safety plan in place that includes an analysis of hazards and risk-based preventive controls to minimize or prevent the identified hazards.” The last extension for compliance has expired in Sept’2018. Now s manufacturing, storing packaging must comply.

Compliance dates are staggered, based on the size of the business, with separate dates for the requirements of the supply chain program. Training, education, and technical assistance are available for those covered by this rule.

Compliance Dates as per final rule of FSMA
September 18, 2017: Small businesses (businesses with fewer than 500 full-time equivalent employees)

September 17, 2018: Very small businesses (businesses averaging less than $1 million per year (adjusted for inflation) in annual sales of human food plus the market value of human food manufactured, processed, packed, or held without sale)

September 17, 2018: Facilities subject to the Pasteurized Milk Ordinance (for their Grade “A” milk and milk products; compliance date was extended to allow time for changes to the PMO to incorporate the requirements of this preventive controls rule)

*All other businesses (also known as “large” businesses) were required to comply, on September 19, 2016. (Source: https://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334115.htm)”

Hazard is defined as the Physical, Chemical, Biological or Radioactive contamination in food which is likely to cause damage to the health of humans or animals consuming the food. HACCP or HARPC is the Plan to eliminate such hazards in the entire food chain.

The plan is applicable from the agricultural produce stage to final retail stores within the reach of consumer. Critical Control Points are the stages in food chain where this contamination is likely to occur. Plan is to prevent an occurrence of contamination. In other words, the plan is made applicable to entire food chain. This also includes all modes of transport from produce stage to final retail.

Hazard prevention plan HACCP/HARPC also considers the allergen control and required precautions to be taken as a part of good manufacturing practices. ISO 22000:2018 details the requirements of employee health practices, safety precautions to be followed by employees in the entire food chain. Entry and exit points, prevention of deliberate contamination as an act of terrorism and safe passages while being transported. The standard ISO 22000:2018 mandates mock recall drills to be conducted by manufacturing firms in order that employees are aware of the hardship caused by recalls and the steps to be taken in case a recall becomes inevitable.

ISO 22000:2018 has been aligned to ISO 9001:2015 there by incorporating all essential features required for a quality management system by embedding them in to ISO 22000:2018. The standard also emphasizes the need for formulating a Food Safety Policy by the management and giving a strategic direction to implement, with risk identification and mitigation at all processes involved in the facility. It also Stresses the need for evaluation of performance and prevention of nonconformities.  Certification is simple. Documentation can be made very simple and easy to implement. It is time to get your certification and the time is now.

With the advent of internet explosion, the world has become small, in the terms that mobility of people and goods has increased, and the requirements of consumers have become global. It has forced food markets to become global and make varieties of food being available in all markets. The advantage of incorporating Food Safety Management System (FSMS) based on ISO 22000:2018 is that it is an internationally recognized standard. Following safe food practices based on international standards requirements such as ISO 22000:2018 makes consumers feel safe about the food they consume. Thus, making the certification as a powerful marketing tool to expand your business to international markets with confidence.

In addition to ISO 22000:2018 there are few more additional requirements of FSSC 22000:2018 which must be met before certification they are:

  1. Management of services
  2. Product labelling
  3. Food defense Threat assessment
  4. Control measures
  5. Food Fraud prevention
  6. Vulnerability assessment
  7. Control measures
  8. Plan
  9. Logo use
  10. Environmental monitoring
  11. Formulation of products
  12. Management of natural resources

Hazard Prevention in Packaging Industry:

Is hazard prevention necessary in a packaging industry where there is no direct contact with food? The answer is yes. This is because hazards in packaging industry could be inadvertent. Following could be some major areas as to how there could be hazards which potentially cause contamination in a packaging industry:

  1. Ink penetration to inside the carton or box
  2. Glue contamination inside panels of the box
  3. Excessive glue from the manufacturing joint
  4. Grease contamination from machine processing inside of the carton or box
  5. Contamination related to chemicals used as cleaning agents
  6. Accumulation of dust in storage area
  7. Possible contact with cleaning agents
  8. Potential contamination caused by pests or bird droppings
  9. Accidental contact with allergen materials during transportation

10.Contact with material handling equipment which are infested such as infested pallets or grease from Fork lifts and hand trolleys.

There could be several such areas which need attention by packaging industry

AEC Difference:  Audit Expertise Comptable LLC. (AEC) is a premier Consulting, Auditing and Training firm. AEC can help facilities achieve their certifications to any of ISO standards, sector specific standards. Among food safety standards AEC caters to certifications in FSSC 22000:2018, SQF Edition 8, IFS, BRC 8, and AIB. QSE has a10 step disciplined path which is insensitive to failure. AEC’s approach to management systems is through, data driven, evidence based, simplified, single level system which can withstand the scrutiny of any auditor and is a very simple format which is very easy to follow and maintain. The documentation is aimed at being a powerful administrative tool, to evoke continual improvement in the management of the facility instead of being a hogwash to auditors.

What can AEC do for you in a packaging industry or any other Industry?

  • AEC can assist your organization from Concept to Certification in all aspects
  • AEC can train select staff for Food Safety Team, Food Safety Team Leader. HACCP and HARPC Practitioner or SQF Practitioner or to become Preventive Control Qualified Individuals.
  • AEC can create entire documentation required for obtaining and sustaining certification
  • AEC can conduct Internal audits more through than certification audits
  • In short AEC is your answer all works related to food safety certification for any industry any standard

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