When the Food Safety Modernization Act (FSMA) pivoted food safety practices from reactive to preventive, food manufacturers were tasked with quickly implementing comprehensive custom plans to address the hazards specific to their facilities and products. This included documenting and enacting preventive controls to mitigate risk.
Food safety plans are based on a thorough assessment of biological, chemical, and physical hazards. Once identified, manufacturers must address each hazard with a written preventive control and take additional steps to prevent the adulteration of food.
This blog from ImEPIK will look at preventive controls and a company’s obligation to establish a food safety plan to address known hazards.
Process controls cover a myriad of parameters in a food facility, such as cooking and cooling procedures necessary to kill pathogens or inhibit their growth or acidifying foods to do the same.
For example, a facility that produces foods with eggs must identify that ingredient as a food safety hazard due to the possibility of the presence of salmonella. The hazard analysis will deem that a preventive control is necessary, most likely cooking the item until it reaches a specified temperature required to kill pathogens.
According to FSMA, the preventive control addressing an identified hazard must set a critical limit, a maximum or minimum value (or combination of values) to which biological, chemical, or physical parameters must be controlled to significantly minimize or prevent a hazard.
By their very nature, food processing facilities provide ideal conditions for pathogens to thrive, with damp floors and drainage areas, warm temperature ranges that promote pathogen growth, and plenty of organic material to allow colonies to take hold.
Sanitation preventive controls address procedures, practices, and processes for:
- Cleaning food contact surfaces, from conveyors to sorters, and wash water systems;
- Preventing cross-contamination of food;
- Keeping employees from spreading unsanitary conditions to food or food packaging material; and
- Ensuring that steps in the manufacturing process, from raw ingredients to the finished product, don’t allow hazards to be passed down the line.
Foods that pose a possible threat to consumer safety bring to mind pathogens that spread foodborne illnesses (such as E. coli and salmonella). However, food recalls are issued far more often for the possible presence of allergens than pathogens, regardless of whether illnesses or adverse effects result from eating the food.
The Food Allergen Label and Consumer Protection Act of 2004 mandates that food manufacturers identify certain ingredients as allergens on food labels. These include:
- Crustacean shellfish
- Tree nuts
- Sesame (to be included starting Jan. 1, 2023)
Companies that process food containing allergens must guard against mistakenly adding them to a product that doesn’t list them as an ingredient. Salad companies, for example, have issued recalls after the incorrect ingredient/dressing pouch was packed into a salad kit. A recall can also happen if an allergen is intentionally included but is not listed on a label.
Manufacturers must have procedures that isolate and identify allergens from the time they enter a facility and track them throughout the manufacturing process. In addition, food safety plans, through current Good Manufacturing Practices, will identify allergens and detail cross-contact hazards in the facility.
Supply Chain Controls
Manufacturers must have a risk-based supply chain program if a hazard requires a preventive control applied in the supply chain. For example, companies should receive ingredients only from approved suppliers that have been vetted and demonstrated an ability to follow standards. Facilities that control their own hazards (or if a downstream handler, such as another processor, controls the hazard) do not need a supply-chain program.
ImEPIK, a Trusted Food Safety Partner
ImEPIK has designed a comprehensive 100% online training course that guides companies through the development and implementation of preventive controls and helps food company employees earn the designation or” Preventive Controls Qualified Individual,” or PCQI. PCQI Online covers the material in 10 modules, offers the course in English and Spanish, and you’ll receive your training certificate absolutely free (our competitors charge!).
The company’s PCQI training is also offered in an online course for Canadians to address the Safe Food for Canadians Act and Canadian Food Inspection Agency rules.
Contact ImEPIK today with any questions about our 100% self-paced training or to receive discounted team pricing.