Gary Ades on Food Safety: Key Issues For Prerequisite Programs

Looking at food safety as a pyramid (see Figure 1), we see that prerequisite programs are key to success. Without them, developing and implementing HACCP plans and subsequent continuous improvement programs would be difficult, if not impossible. In this article, I will provide a list of programs that Technical Food Information Spectrum, Inc. (TfiS) considers possible/potential prerequisite programs. For each of these programs, I will identify key issues of concern that we have found over the course of conducting numerous facility inspections and consulting with groups across the food supply chain. In subsequent articles, other TFiS team members or myself, will discuss each of these prerequisite programs in detail.

Prerequisite Programs Include:

• Supplier/Vendor Selection and Approval
  
• Good Manufacturing Practices (GMPs) and/or Good Agricultural Practices (GAPs)
  
• Receiving/Shipping Protocols
  
• Product/Ingredient Specifications
  
• Hold/Release Protocols
  
• Sanitation
  
• Preventive Maintenance
  
• Equipment Selection
  
• Pest Control
  
• Allergen Controls
  
• Training
  
• Environmental Monitoring
  
• Prevention of Foreign Objects
  
• Product Tracking
  
• Warehousing
  
• Glass Policy
  
• Calibration
  
• Recall

Supplier/Vendor Selection and Approval

• Assure that proper food safety information is gathered
  
• Utilize audits
  
• Do not select just because a well known company uses them and therefore "they must be good"
  
• Have a means for rejecting them

Good Manufacturing Practices (GMPs) and/or Good Agricultural Practices (GAPs)

• Know what is contained in these guidelines
  
• Use them as a guide to develop Standard Operating Procedures (SOPs) and audit instruments for internal audits and supplier or co-packer audits
  
• Good employee practices are essential, especially handwashing

Receiving/Shipping Protocols

• Provide Receivers and Shippers with the proper training and tools to do their job. This includes items such as flashlights, calibrated thermometers, black lights, etc.
  
• Develop simple documents for recording findings
  
• Provide guidance and support for rejecting carriers and/or items

Product/Ingredient Specifications

• Keep them current
  
• Make them realistic-remember, you are usually paying for tests done by suppliers either as an add on or as part of the cost of the product

Hold/Release Protocols

• Develop documentation that requires the recording of the results of all of the activities
  
• Establish an area for product that is on Hold
  
• Establish a limited group of individuals that can release product that is on Hold

Sanitation

• Remember that this is key to all food safety issues
  
• Understand the difference between cleaning and sanitizing
  
• Keep hose nozzles off of the floor
  
• Hang up brooms and squeegees (no wooden handles or straw brooms)
  
• Measure and record the concentrations of sanitizers

Preventive Maintenance

• Have a written program
  
• Train maintenance personnel regarding cleanliness and cross contamination
  
• Keep tools clean
  
• Conduct activities in a manner that does not contaminate in-process product

Equipment Selection

• Make sure it can be cleaned

Pest Control

• Assure that the Pest Control Operators (PCO) license is current
  
• Pest Control company should be insured and provide the customer with a current insurance policy naming the customer as the certificate holder
  
• Insist on comprehensive reports when they visit the premises; use reports to trend activities
  
• Insect control devices can be a source of contamination. Select the location for their use carefully.

Allergen Controls

• Know what items are considered to be allergens
  
• Conduct an allergen review of ingredients and the operation
  
• Develop protocols to eliminate cross contamination with allergens
  
• Check labels for proper identification of allergens

Training

• Train new workers and current workers regarding food safety issues
  
• Reinforce training regularly (15 minute sessions on a topic)
  
• Be aware of language and literacy issues

Environmental Monitoring

• Don't forget water, ice and air quality
  
• Have a plan for corrective actions

Prevention of Foreign Objects

• Metal detection is important. Use ferrous, non-ferrous and stainless steel standards.
  
• Remove or repair damaged pallets
  
• Document programs such as filters, strainers, magnets, etc.

Product Tracking

• Be able to track finished products and ingredients. Don't forget packaging materials.

Warehousing

• Practice inventory control
  
• Practice Good Housekeeping
  
• Watch conditions so pest control is not negatively impacted
  
• Maintain temperature and humidity controls

Glass Policy

• Have a written policy
  
• Dock inspection lights, forklift lights, etc. should be shatterproof or shielded
  
• A glass map is an excellent tool

Calibration

• Calibrate thermometers against a recognized standard or ice water or boiling water depending upon the temperature ranges for which they will be used
  
• Identify each thermometer with a unique designation (number)
  
• Keep scales calibrated
  
• Record all calibration activities

Recall

• Have a program in place
  
• Conduct mock recalls at least twice per year, once using the finished product and once using an ingredient that is used in a wide variety of finished products. Document the results.
  
• Have ways to contact essential personnel during non-business hours
  
• Take emergency numbers home with you

In future weeks we will discuss each of the prerequisite areas in more detail. Other members of the TFiS team will be contributing to this activity.

Gary Ades, Ph.D, is president of Technical Food Information Spectrum, Inc. (TFiS), a leading food safety and quality consulting firm. Dr. Ades is a professional food scientist and consultant with over 25 years of experience in the food industry. For more information, contact Dr. Ades at 800.248.8347 or via E-mail at tfis@ix.netcom.com.