Food safety compliance amid a complicated supply chain

However, as opportunity grows, the ongoing evolution of the global food safety regulatory environment may present many challenges to manufacturers that operate within highly complex supply chains. That’s particularly true in the United States, where many of the provisions of the Food Safety Modernization Act Act (FSMA) are still pending.

RTE products are not typically re-heated prior to serving, and some, such as sliced meats, have been linked to illnesses caused by foodborne pathogens. The US Department of Agriculture’s (USDA) Food Safety and Inspection Service (FSIS) has reported recalls of nearly a half-million pounds of RTE in 2012 because of the presence of Listeria monocytogenes​, thebacterium that causes listeriosis, or the listeria illness. 

In an effort to also reduce the number of food pathogen related recalls, the Food and Drug Administration (FDA) has proposed additional rules at proactively controlling the occurrence of potentially dangerous food-related illness.

As the FDA's increased regulatory oversight nears, RTE food manufacturers must carefully examine their processing operations to ensure they are in line with new standards. Using a combination of technologies and best practices will be crucial to prepared foods and RTE food product manufacturers.

Manufacturers of RTE foods looking to overcome food safety challenges can find the latest regulatory insights at PACK EXPO International 2014 (November 2-5; McCormick Place, Chicago). The event, owned and produced by PMMI, the Association for Packaging and Processing Technologies, will showcase a range of equipment and materials to improve food safety measures across the production line.

Safety first​

Reacting to high-profile foodborne illness outbreaks, the US FDA enacted the FSMA in 2011 to ensure the overall safety of the US food supply through proactive rather than reactive means. The law gives the FDA authority to mandate safety measures and regulate how food is processed.

Instead of reacting to food contamination outbreaks, the new law gives the FDA authority to put mandatory safety measures into place designed to prevent such events, regulating how food is processed.

The proposed rule change will require foreign and domestic companies that manufacture, process, or package food for human consumption in the US to develop formalized written food safety plans.

Similar to conventional Hazard Analysis and Critical Control Point (HACCP) plans, manufacturers must identify hazards and put protective controls into place. However, the new rule requires more stringent control measures for allergens and sanitation when determined by the initial hazard analysis, rather than focusing solely on critical control points.

The proposed rule also requires manufacturers to monitor, adjust plans as needed, verify and report on the overall effectiveness of the food safety plan. These plans will need to be available to the FDA, which will evaluate them and inspect facilities for compliance.

Preventing contamination​

A comprehensive food safety plan begins with combatting bacterial contamination at the food processing facility – usually through good sanitation practices and modern technological advancements. Recent innovations in processing and packaging systems can maintain the overall cleanliness of food manufacturing operations, ensuring regulatory compliance and product safety, while protecting a brand’s reputation.

Designed for Safety​

Because it comes into direct contact with the product, food packaging equipment is a key area of focus for any food safety program, and equipment design can factor heavily into an operation’s microbial controls. Packaging machinery is designed with safety in mind — minimizing exposed parts, wiring, slots and holes, for example, to reduce the number of areas where potentially harmful bacteria can thrive.

Original equipment manufacturers (OEMs) are also choosing their building materials with care. Stainless steel is often easier to clean than other materials, because it can stand up to extremely harsh chemical cleansers. However, some OEMs are offering high-tech antimicrobial coatings of bacteria-resistant materials such as enhanced polymers and select metals, to increase product safety. Automation is another effective option for improving product safety; by reducing opportunities for human error, automated solutions attack an all-too-common source of contamination.

Technological Advancements​

Technology has come a long way, allowing food manufacturers to take preventative measures other than extreme temperatures, which can negatively impact food quality. Non-thermal techniques, use UV light and ultrasound to sterilize food products without affecting product consistency or taste.

High-pressure processing (HPP) is another increasingly popular non-thermal method. HPP applies up to 87,000 pounds per square inch of pressure to eliminate potentially harmful microorganisms and is known to be effective against bacteria that can cause foodborne illness, such as pathogenic E. coli, Salmonella and Listeria monocytogenes​. HPP has been recognized by the  US Department of Agriculture Food Safety and Inspection Service (USDA-FSIS) as a mitigation step to reduce microbial activity in RTE meat products such as marinated meats, sliced ham, turkey and chicken cold cuts, and cured meat products.

Techniques for Success​

Implementing a robust food safety plan that takes advantage of the latest in technology is a step in the right direction, but without procedures and practices in place and followed, even the most ambitious plans have little chance of success. Employees are the driving force behind ensuring food safety and quality control rigorous training in proper sanitation and clean-up measures at all staff levels and functions can mean the difference between the success and failure of any food safety plan.

While the proposed FSMA regulations do not focus exclusively on critical control points, good sanitary design and material handling can still factor into preventative measures. For example, through strictly controlled zoning, a manufacturer can control when and where products come in contact with equipment or personnel – and that allows managers to focus their food safety efforts in the areas that need it most. A zone dedicated to mixing meat and spices prior to cooking, for example, would be of greater concern for food safety than a zone for palletizing finished products.

As the popularity of RTE and prepared foods products continues to rise, the FDA is paying particular attention to food safety, and will be implementing the FSMA to include stricter processing controls.

The increased regulatory requirements will force RTE manufacturers to take a close look at their entire operations, not just critical control points, to determine where food safety controls are needed.

Implementing comprehensive food safety plans that combine the latest in food processing technology with on-site best practices, will allow RTE manufacturers to comply with FDA standards, while increasing the overall safety of their products and ensuring the ongoing integrity of their brand.’