Raising the Bar with Hygienic Design: 3A and Showcasing our Next Generation Remco and Vikan Tools

Investing in a “hygienically designed” facility, equipment, or an itemized inventory is no longer just a buzzword for the food and beverages industries. Having surfaces that are easy to clean, inspect, and access have become definitive hallmarks for ensuring sanitary production of safe food by preventing or significantly minimizing key environmental hazards (such as pathogens, unique allergens, and deleterious foreign material) from contaminating food.   

Of course, design is considered an integral part of the material specifications that’s critical to assuring environmental and food sanitation. Last month, Remco attended the 3-A SSI’s 2021 Virtual Conference (a) where regulatory sanitarians, equipment manufacturers, food industry processors, academics, and professionals collectively deliberated on the “role of hygienic design in improving food safety plans.” Some topics of interest covered during the session were on: 

  • Pathogen control strategies  
  • Developing hygienic design training for the staff
  • Avoiding pitfalls in hygienic design 

The discussions and inputs by subject-matter experts clearly pointed out the stark limitations of legacy facility or equipment (b) when compared with the ideal choice of equipment that is hygienically designed. However, achieving the ideal is no mean task – for instance, 3-A takes a holistic approach to hygienic design by integrating: 

  1. Equipment design 
  2. Facility design
  3. Cleaning and sanitizing protocols
  4. Operational design and GMP procedures
  5. Quality and regulation focus 

In line with the recent development of new GFSI industry scopes (1), JI (for building constructors and equipment manufacturers) and JII (for building and equipment users), we should expect Certification Program Owners (i.e., developers of GFSI benchmarked standards such as BRC, SQF, and FSSC 22000) to include these hygienic design benchmarking requirements in their near-future program versions. However, besides just the capital assets such as building and equipment, hygienic design principles should also be considered for sanitation and material handling tools, since tools can also become vectors of contamination if improperly designed, constructed, or installed (2). 

Since 2015, Remco has offered Vikan’s line of Ultra-Safe Technology brushes and brooms. These hygienically designed tools are ideal for use in high-risk food processing areas, such as in a ready-to-eat facility. Each tool has a smooth surface, and most importantly, is free of significant contamination traps, making them easier to clean (3)Contact us to help you with the proper selection, installation, storage, care, and maintenance procedures for hygienically designed tools. To see our selection of tools meant specifically for hygiene-sensitive environments (including our squeegees, handles, and one-piece shovels), click here. 

Notes and References: 

(a) About 3-A Sanitation Standards Inc: As an independent organization, 3-A Sanitary Standards Inc. principally relies on the collaboration and consensus of regulatory sanitarians, equipment fabricators and food processors when developing voluntary standards and accepted practices for food processing systems. More information about 3-A SSI is available at: http://www.3-a.org/. 

(b) Legacy facility or equipment is usually a term given to outdated, obsolete, old, or over-used capital assets used at a site that were not originally constructed and installed with hygienic design principles in mind, hence they may create more maintenance and breakage problems in the medium- to long-run. 

(1) https://www.3-a.org/News-Events-Updates/News/ArtMID/122397/ArticleID/651/3-A-SSIEHEDG-Endorse-New-GFSI-Hygienic-Design-Benchmarking-Requirements 

(2) https://remcoproducts.com/how-to-keep-cleaning-tools-from-becoming-vectors-of-contamination/ 

(3) https://remcoproducts.com/ust-white-paper/ 

 

 

 

Celebrating FSMA’s 10th Anniversary: What have we achieved, and what’s to come in 2021?

blue workstation

Ten years ago, on January 4th, President Obama signed into law the Food Safety Modernization Act (FSMA). This act enables the FDA to better protect public health by focusing more on preventing food safety problems rather than simply reacting to them. Looking through a decade of U.S. regulatory challenges and achievements, so far, seven FSMA Final Rules and several guidelines have been published, and most food industries are already complying with the relevant requirements. Other FSMA compliance date deadlines to look out for are as follows:

FSMA Final Rule

Applicability

Compliance Date Deadline




Produce Safety

Other Produce – Small Farms (remaining water requirements)

Jan. 26, 2021

Other Produce – Very Small Farms (remaining water requirements)

Jan. 26, 2022

Small Farms – Non-sprout agricultural water requirements

Jan. 26, 2023

Very Small Farms – Non-sprout agricultural water requirements

Jan. 26, 2024

Intentional Adulteration

Very Small Businesses

July 26, 2021

 

For more current information on FSMA compliance requirements, visit the FDA’s website.

The battle is still far from being won – allergen labeling and management remains the top cited cause for product recalls, and contamination by Listeria monocytogenes and Salmonella continue to be the leading causes of foodborne illness outbreaks. These trends indicate that regulatory agencies, industry stakeholders, and allied groups should continue to make a concerted effort in providing safe and wholesome food to consumers. In light of increased hospitalizations during the ongoing pandemic, controlling for allergens and contaminants are even more critical as we face an already strained healthcare system. 

This year should see significant activities centered around strengthening industry requirements toward FSMA compliance. The following are some of the recent developments to potentially keep track of:

  1. Collaboration and Integration within Agencies: Expect more open communication among North American regulatory agencies such as the FDA, FSIS, and the CFIA and stakeholders. One such collaborative initiative that has been spearheaded by these organizations is on Salmonella reduction efforts in meat, poultry, and produce to meet Healthy People 2030 global targets. 
  2. Digitization of Food Safety Processes and Systems: To meet increasing record-keeping requirements, industries will make a greater effort to move away from physical paperwork and towards digitization and the use of AI and Data analytics technologies. Companies should be able to take advantage of real-time, block-chain, or predictive capabilities to help in hazard prevention, but these systems must also meet the 21 CFR 11 requirements on electronic record-keeping.
  3. Preparing for a New Era of Smarter Food Safety: The FDA’s Blueprint was launched in July last year as the agency’s masterplan towards creating a more digital, traceable, safer, and FSMA-based food network system that should help bend the curve of foodborne illnesses in the U.S. We should expect more developments for this initiative in 2021.
  4. Traceability as a Preventive Approach: The ability to trace and track the source of foodborne illnesses to be able to better prevent future outbreaks has become one of the FDA’s priorities. This year we look forward to the finalization of FSMA’s proposed Rule for Food Traceability, which should mandate additional record-keeping requirements for certain high-risk foods.
  5. Enhanced Focus on Sanitation Controls: With sanitation being elevated to one of the hazard analysis risk-based preventive controls, there should be an increased industry focus toward an integrated sanitation approach. Such an approach should also include the selection, cleaning, storage, and maintenance of cleaning tools, as such equipment can also become vectors of contamination in a food plant.

For more updates on the FDA’s Viewpoint on FSMA progress and the path forward, visit the FDA’s website.

References:

Focus on FSMA: Looking Forward to a Year of Produce Safety Improvements

Produce safety changes in 2020

According to the World Health Organization, low consumption of fresh fruits and vegetables has been shown to be a significant risk factor potentially contributing to cancer, heart disease, and strokes around the globe. Indeed, nutrition experts have recommended a minimum individual daily intake of 400 g of various fresh produce commodities.1 However, eating fresh fruits and vegetables isn’t without risk, as there are minimal processing steps (such as washing, cutting, and packing) even when they’re not just eaten raw. This can and does increase the chances of produce cross-contamination that may result in foodborne illnesses.

Last year, in 2019, a significant number of disease outbreaks and recalls were linked to the produce sector. Some of the key food safety incidents that made headlines were on:

  • Multi-state coli O157:H7 outbreak associated with romaine lettuce from Salinas growing region in California, that led to about 138 reported illnesses and 72 hospitalizations;
  • Nationwide recall of Ready-to-eat (RTE) vegetable products from various retail outlets due to potential risk of Listeria monocytogenes found in produce sourced from a common supplier;
  • Outbreak of Salmonella Uganda infections (reported in nine U.S. States) linked to whole, fresh papayas imported from a Mexican farm.

Not surprisingly, the U.S. is currently a net importer of fresh produce.2 Just over half of the fresh fruit and almost a third of fresh vegetables consumed by the American public are imported from other countries such as Mexico, Chile, and Canada. The risks to food and produce safety are greatly aggravated if suppliers do not have adequate preventive food safety controls in place. Thus, it became imperative for the U.S. federal government to enact the 2011 Food Safety Modernization Act (FSMA), which basically provides the FDA with a proactive authority to regulate the way foods are sourced or grown, harvested, processed, stored, and transported for interstate or international commerce.3

In 2020, we should expect stakeholders to build upon the existing regulatory framework or initiatives in order to foster better Produce Safety improvements, and with a collaborative objective of providing safe and wholesome food to the public. Some of the key things coming in this arena are as follows:

1. Produce Safety Rule compliance date for very small farms is nearing:

The FSMA Final Rule on Produce Safety was published on January 26, 2016, with the aim of providing minimum food safety standards for growing, harvesting, packing and holding of fruits and vegetables.4 Most of the compliance deadlines have passed, but then the compliance date for the very small produce farms (other than sprouts – which has a separate compliance date) shall be January 27, 2020.

2. Supplier traceability challenges should make industry adopt smarter food safety technologies:

To enable a faster foodborne outbreak response in the interest of public health, more reliable information, better processes and updated technologies will be required by industry to track the source and destinations of contaminated produce. According to Frank Yiannas, the FDA deputy commissioner for food safety, facilitating the adoption of newer traceability technologies (such as blockchain) in the produce sector will usher in a New Era of Smarter Food Safety that is people-led, FSMA-based, and technology enabled.5

3. Sanitation and hygiene will become a greater produce sector focus:

There will be an enhanced requirement to strengthen the foundation of Good Agricultural Practices and the key risk-based sanitation programs on farms that should help prevent microbial contamination of the marketable produce, associated food recalls, and foodborne disease outbreaks. Examples of these practices include ensuring worker health and hygiene; overall plant sanitation and cleaning; organizing growing, harvesting, packing, and holding activities; ensuring the proper quality of agricultural water and soil amendments; and properly maintaining equipment, tools, and buildings. Moreover, it has been generally estimated that poor sanitary conditions at a plant or site is responsible for at least one-third of North American food recalls, and a lot of direct and indirect expenses could be avoided through proper sanitation strategies.6

Remco can help the food industry, as a well as the produce sector, with the right selection, storage, care and maintenance criteria for sanitation and material handling implements that are required for a sanitary and more hygienic food production environment. More information about our tools are available at https://remcoproducts.com/products/.

 

Selected References:

(1) WHO: Global Strategy on Diet, Physical Activity and Health – https://www.who.int/dietphysicalactivity/fruit/index1.html

(2) The U.S. Trade Situation for Fruit and Vegetable Products – https://fas.org/sgp/crs/misc/RL34468.pdf

(3) FDA Food Safety Modernization Act – https://www.fda.gov/food/guidance-regulation-food-and-dietary-supplements/food-safety-modernization-act-fsma

(4) FSMA Final Rule On Produce Safety – https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-final-rule-produce-safety

(5) New Era of Smarter Food Safety – https://www.fda.gov/food/food-industry/new-era-smarter-food-safety

(6) Evaluating FDA Food Recalls with Sanitation as a Root Cause – https://www.vikan.com/media/8428/2019_iafp-poster_amitmkheradia-us.pdf

How is HARPC Different From HACCP?

How is HARPC Different From HACCP

HACCP and HARPC share more than just four letters. They’re both food safety standards based on prevention, but they do differ on execution. Their differences and their similarities aren’t as important as the way they fit together for most food processors, though. A HARPC plan shouldn’t be considered as a replacement, but as a necessary upgrade to the conventional HACCP plan. Understanding how the systems fit together is the first step toward implementing both.

HACCP

HARPC

(1) Is the preventative approach based on a standard, guideline or a set of laws?
Based on a guideline recommended by CODEX and NACMCF Based on FSMA act and principally, the Final Rule for Preventive Controls for Human Food
(2) What food safety risks are considered using the preventative approach?
Conventional – Biological, Chemical, and Physical Beyond the conventional risks for actual and potential food safety hazards
(3) What is the goal of the preventative approach?
To prevent, eliminate (or) reduce hazards to a safe level (in that priority) Preventive controls that prevent or significantly minimize “known or reasonably foreseeable” risks
(4) Who is primarily responsible for the development and maintenance of the preventive plan?
Primarily, a competent HACCP coordinator with assistance from multidisciplinary team Trained Preventive Controls Qualified Individual (PCQI) as described in the FSMA Act
(5) At what frequency is the preventive plan being reviewed by the facility?
At least once a year, or when required At least once in 3 years, or when required
(6) The plan is mandatory for what type of establishments?
For FDA and USDA mandated establishments, or when required for certification purposes For all establishments along the food supply chain that serve U.S. consumers, unless exempted
(7) The plan is excluded or exempted for what type of establishments?
Unless mandated or required for certification, HACCP is voluntary, and GMPs are mandatory Exemption list is provided by FDA, but this does not exempt facilities from following at least CGMPs
(8) Who is the interested party here? For whom is the plan for?
Stakeholders: auditors, inspectors, and customers The FDA
(9) What is the documented approach for making the preventive plan?
12 Steps of HACCP (includes 7 Principles) 7 Steps of Developing a HARPC Plan

HARPC as an Upgrade to HACCP

HACCP, or Hazard Analysis Critical Control Points, is already widely used due to requirements from retailers, auditing standards, and inspectors, though the USDA and the FDA only mandate it for meat, seafood, and juice products. As a global standard conceptualized the 1960s, HACCP has been continually developed and updated. HACCP requires a multi-disciplinary team for implementation and follows prescriptive steps.

Continue reading “How is HARPC Different From HACCP?”