Food Safety Verification Requirements and Risks

We have had several discussions in this blog regarding the FSMA and the Preventive Controls Rule and its intent to give U.S. Food and Drug Administration (FDA) the authority to require that companies build food safety preventative controls into their processes. There are five requirements of verification that are proposed by the FDA that should be noted in your food safety plan.

Let’s take a look at the types of risks that are a concern and are being addressed by the proposed rule verification requirements. It is important to think about these in the context of the food safety plan. Do you know all the reasonably foreseeable physical hazards? Have you identified and controlled the significant hazards? The proposed rule is a holistic approach to food safety. In the case of foreign materials there are many steps in the process that a manufacturer can understand and potentially control or reduce food safety risks by applying prerequisite programs and preventive controls. This article will introduce some possible inputs to the process that could introduce foreign materials into product.

These inputs are not an exhaustive list. They are to provide context for the examples on foreign material control and demonstrate the types of questions and situations that a facility should consider when performing a hazard analysis around foreign materials.

Supplier Risk

It is helpful to ask, “What are the foreign material risks from the supply chain?” The risks can either be an inherent risk of the ingredient such as bone in chicken, or poor supplier history, such as plastic glove pieces in a product. Understanding this risk can help the manufacturer require the right controls at the supplier to prevent occurrence for example, X-ray detectors for bones, and potentially supplier disqualification with a repeated poor performer.

In-Process Risk

Another step in the process of foreign material control is to understand the risk in the manufacturing facility. One good way to do this is to develop a robust process flow chart. The proposed rule does not require a flow chart, but we recommend the development of one. A robust flow chart will identify all the inputs, steps and outputs of the process. (HACCP regulations for meat and poultry, seafood and juice require the development of a flow chart.) The qualified individual and the food safety or HACCP team can review the flow chart and identify all points where there may be a risk of physical hazards.

Risks for physical foreign materials can come from equipment and personnel, for example:

Metal: grinding metal such as blenders, agitators, gear boxes, etc. Metal can be accidentally introduced from loose equipment pieces, like nuts and bolts.
Plastic: pieces from worn equipment, gloves and, other personal protective equipment, plastic bags, plastic pallets, etc.
Wood: worn broken pallets, etc.
Glass: broken glass jars, light bulbs, etc.

Foreign Material Detection Systems

Detecting physical contaminants in food, such as metal, glass, stone, plastic and bone is like trying to find a needle in a haystack, especially when the contaminant may be as small as 1 mm in diameter. Accurate and reliable metal detectors and X-ray detection systems provide the highest sensitivity to help find metallic and non-metallic substances in packaged food.

Some metal detectors offer performance verification system technology that automatically measures and compares to expected values to help detect potential problems. The system can also keep electronic or paper records that can be managed for traceability. A performance verification system can help you achieve the highest possible food safety standards. In addition, it’s just as important to ensure your metal detection and x-ray equipment are detecting accurately and consistently. To ensure they are working properly, test the system, protect the equipment, check the process, educate the workers, and maintain the equipment on an ongoing basis.

For more details on verification, risks, and food safety solutions, read the entire White Paper written in cooperation with The Acheson Group: Verification: Can Your Food Safety Plan Meet the Rigors of FSMA’s Proposed Preventive Controls?