Using Color-Coding for Food Safety and Organization

Lately, I’ve been doing a lot of consulting with food processors to build and improve color-coding systems in their facilities. Color-coding can be approached in a variety of ways and works well with a number of related programs. One such program is a lean manufacturing practice called 5S, which I encountered often in a previous position working in the steel industry.

I’m starting to see 5S used more often in food processing. Although I am not an expert in this system developed by the Japanese, I do know that the 5 S’s are Sort, Set in Order, Shine, Standardize, and Sustain. The aim is to eliminate waste, keep workspaces organized, and develop procedures that are consistently easy to follow. I can see why this set of guidelines is appealing to food processors. An organized processing facility is agreeable with inspection authorities, because it demonstrates that a food safety procedure is defined and in practice.

Color-coding for food safety

Color-coding is also commonly applied in conjunction with written food safety plans and HACCP programs to further enhance food safety. The purpose of HACCP and the CGMP regulations laid out in 21 CFR 110 is to identify and control hazards that could potentially impact the safety of food. Cleaning and food contact tools can potentially transfer hazards like pathogens and allergens throughout the facility, so it may be important to keep certain tools in designated areas. Color-coding supports this objective by clearly identifying where tools belong or what task they are designated to perform.
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CGMPs and HACCP: The Dukes of Hazards

In the past couple of blog entries, we’ve covered CGMPs or Current food Good Manufacturing Practices. These are procedures and standards set forth by the FDA to help assure safe, quality, consumable food.

salmonella biohazard food safety riskIn this article, we’ll be covering the different types of hazards that can occur in food processing, and also the controls that can be put in place to reduce the risk of those hazards. Many CGMPs exist to control these hazards, so naturally CGMPs can be used to support a HACCP plan.

So what constitutes a hazard? There are basically three types: biological, physical and chemical.

Let’s start with biological hazards. The Centers for Disease Control (CDC) has determined four levels of biohazards starting with Level One which includes bacteria and other microorganisms that can transmit from one person to another via contact or through the air like E. Coli. Each level is more hazardous than the previous, leading to Level Four which includes the most severe strains such as Ebola virus and Marburg virus.

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The Birth of Food Safety, the FDA and CGMPs

Remco Products Inc.

Lately, we’ve been talking about Current food Good Manufacturing Practices—CGMPs for short—because they are the set of regulations that apply to just about every food processor not regulated by the USDA. CGMPs have also been getting quite a bit of press lately since we may see an update as a result of FSMA. We released an earlier blog article and a white paper on the topic for those who want to learn more.

But did you know that many of the regulations that guide the production of today’s food were largely spawned by the works of investigative journalists? These journalists were referred to as “muckrakers,” and they exposed government and business corruption.

food safety and 1900s meatpackingOne of the most well-known of these journalists was Upton Sinclair, who spent seven weeks working undercover in the Chicago meatpacking district on a research mission to expose the injustices and hazardous working conditions faced by meat industry workers. In Sinclair’s novel, The Jungle, his vivid descriptions of the unsanitary practices of the meatpacking industry captured the attention of the American public and President Theodore Roosevelt.

After reading The Jungle, Roosevelt sent a pair of advisors to assess the truthfulness of the novel’s depictions—and their report swayed the President to believe that Sinclair had provided an accurate representation. Shortly after Sinclair’s works became widespread, the Pure Food and Drugs Act and the Meat Inspection Act were passed in 1906. The passage of these regulations marked a turning point in federal food safety and was the beginning of what we know today as the FDA.

Although Sinclair had hoped that his accounts would improve working conditions for America’s poor laborers, he ended up making a huge and lasting impact on food safety. He was later quoted as saying, “I aimed for the public’s heart, and by accident hit it in the stomach.”

The early regulations were more specific about the standards for pharmaceuticals and accurate product labeling, and policies regarding food were much more ambiguous. Over the next 30 years, gaps in the protections provided to consumers by these regulations were exposed by a new generation of investigative journalists. In 1938, President Franklin D. Roosevelt signed the Food, Drug, and Cosmetic Act, received enthusiastically by an American public that had witnessed one too many food and drug safety disasters. This was the first law that mandated legally enforceable food standards, and CGMPs for food were officially established later on in 1969.

No one can deny that we have come a long, long way for food safety since the days written about by Upton Sinclair. But we may soon see another era of modernization of our food safety regulations. Do you think that the updates proposed by FSMA go far enough in preventing the production of unsafe foods? Are there holes in today’s laws you think should be considered? Tell us your thoughts.

Five Types of GMPs for Food Processing

Assuring quality of a manufactured product requires certain procedures and standards. In many industries, these procedures and standards are often referred to as Good Manufacturing Practices, or GMPs. The Food and Drug Administration (FDA) outlines Current food Good Manufacturing Practices, or CGMPs, in Title 21 of the Code of Federal Regulations, Part 110 (21 CFR 110).

The FDA provides CGMPs to assure that food processors maintain sanitary conditions that minimize the risk of contamination by “hazardous” materials. We’ll cover what the FDA considers hazards in a future blog entry. But for now, we’ll focus on CGMPs.

So what aspects of a food processing operation should be controlled and monitored to assure they conform to CGMPs? Through working with food processors, we’ve found that just about every aspect of a food processing operation might come under scrutiny during an inspection — from the personal hygiene of the workers in the plant, to the equipment used to make the food products, to the processing facility itself.

The FDA outlines CGMPs in five subparts:

1. General Provisions

— Do you know the terminology that should be used in describing CGMPs? This first section provides guidelines. It also explains when to use “shall” versus “should” in differentiating between when compliance is necessary (“shall”) and when procedures and practices are directly related to unsanitary conditions as specified in Section 402(4)(a) (“should”). It also delineates plant and employee responsibilities with regard to personal hygiene. Food safety education is addressed as well as the need for supervisory personnel to ensure compliance.

2. Building and Facilities

— How should a facility be designed and maintained to help assure food safety? In this section, CGMPs are outlined for the maintenance of the grounds, including litter control, waste removal and treatment, and grounds maintenance and drainage. Plants should be designed and built to reduce the potential for contamination. Sanitary operations, facilities, and controls are also outlined.

3. Equipment

— This section provides requirements and expectations for the design, construction, and maintenance of equipment and utensils to ensure sanitary conditions. But did you know it also includes an automatic control for regulating temperature or an alarm system to alert employees to significant change in temperature? Other requirements are general and intended to prevent contamination from any source.

4. Process and Controls

— How should a food processing facility keep sanitary conditions in check? This section of CGMPs addresses general sanitation and controls necessary to ensure that food is suitable for human consumption. It addresses the monitoring of physical factors (critical control points or CCPs), such as time, temperature, humidity, pH, flow rate, and acidification. Warehouse and distribution requirements are also included, requiring finished foods to be stored and distributed under conditions that protect against physical, chemical and microbial contamination. The container must also be protected from deterioration. This section also outlines very general requirements for warehousing and distribution.

5. Defect Action Levels

— There may be unsanitary circumstances that are simply inescapable. So how does the FDA address this? This last part allows the FDA to define maximum defect action levels (DALs) for a defect that is natural or unavoidable even when foods are produced under CGMPs (as covered in the sections above). These defects are not hazardous to health at low levels and include rodent filth, insects or mold. Those exceeding maximum DALs will be considered in violation.

We continue to appreciate the diligence our food processing customers demonstrate in following CGMPs to assure high-quality food products. What are your facility’s CGMPs, and how do you verify that your operation is in compliance? As you have gained experience in the industry, are there any types of required controls that surprised you? What other aspects of food processing do you think should be controlled that aren’t currently covered in regulations? We’d love to hear more about the policies and procedures that have been successful for you. And to learn more about food safety practices and CGMPs for food processing, check out our white paper, Understanding GMPs in Food Processing.

Five Things You Maybe Didn’t Know About HACCP

If you work in food processing, chances are you’re probably familiar with the concept of a Hazard Analysis Critical Control Point or HACCP. Here’s a little about what we’ve learned about HACCP.

HACCP food safety sample verificationAs part of a HACCP Plan, a Hazard Analysis identifies “Critical Control Points” or CCPs — those points, steps or procedures in food manufacturing process at which control can be applied and as a result, a food safety hazard can be prevented, eliminated or reduced to an acceptable level. With CCPs identified, a HACCP Plan provides a series of procedures to control the process and sensitive points in the food chain, with the ultimate goal of producing foods that are safe for consumers’ health.

HACCP is a part of the Food Safety and Modernization Act (FSMA) proposed by the Federal Drug Administration (FDA) in 2011. While FSMA is fairly new, did you know the concept of HACCP has actually been around for some time? Here is the answer to that question along with some other interesting things about HACCP that many people may not be aware of.

1. HACCP is not a new system.

HACCP is a concept that’s been around since the 1960s. It was developed by the Pillsbury Company, the US Army Laboratories and NASA to help produce safe food for space missions. Today, HACCP is a recognized international standard for safe food production. It is endorsed by the Food and Agricultural Organization (FAO), the World Health Organization (WHO), and in the United States by the National Advisory Committee on Microbiological Criteria for Foods (NACMCF).

2. Not every hazard is a CCP.

As part of putting together a HACCP Plan, there’s a thought-process or Decision Matrix one can use to review each step in a food workflow process and determine the likelihood of hazards that could occur. Once a hazard is identified, then it is evaluated whether or not it is a CCP. Going through this evaluation, one will soon discover that not every hazard is a CCP. If a control measure is already in place to address the hazard, then chances are the hazard is not a CCP.

3. It takes a team to put together a HACCP Plan.

Through our experiences working with food processors, we’ve seen that some of the best HACCP Plans are the result of a team effort by the key individuals responsible for food safety within a food processing operation. The team may include managers from quality assurance, plant operations, engineering, maintenance, sanitation, and shipping & receiving. In addition, it’s often advised that someone who works on the line, such as a Line Supervisor and/or Machine Operator, provide input to the HACCP Plan to help assure alignment with day-to-day operations.

4. One person should be responsible for the HACCP Plan.

While it often takes a team to put together a well-structured HACCP Plan, we’ve also observed that maintaining the plan should ideally be the responsibility of just one person within a food processing organization. That person is usually the HACCP Coordinator. However, if there is no HACCP Coordinator, then the responsibility often falls to the Quality Manager, or even the company’s CEO.

5. Review the HACCP Plan regularly.

In a perfect world, anytime something changes within a food process, then the HACCP Coordinator should review the HACCP Plan and update it accordingly. At the very least, it’s suggested that a HACCP Plan be reviewed every 3 to 6 months.

How does your food processing facility deal with HACCP? If you have any additional tips or observations about putting together and maintaining a successful HACCP Plan, we’d love to hear them.