On April 28, 2011, the FDA gave notice that it had updated and implemented guidance standards for fish that “support and complement FDA’s regulations for the safe and sanitary processing and importing of fish and fishery products using hazard analysis and critical control point (HACCP) methods.” According to the Federal Register, the FDA implemented the new standards immediately, without public comment, to promote consumer safety and “provide important recommendations for conducting a hazard analysis and implementing a HACCP plan.”
A .pdf copy of the guide can be downloaded here.
The 476-page document provides an organized and comprehensive overview of how to identify potential hazards, determine whether they are significant, identify critical control points to reduce the hazard, and develop a control strategy (which includes setting critical limits, establishing monitoring procedures, establishing corrective action protocols, record-keeping, and verification procedures).
The March 2011 Deloitte Consumer Food Safety Survey confirms that customers are aware of food safety issues, and they are willing to pay more for safer food products. Food processors, distributors, and retailers may all benefit from this trend by developing and implementing food safety risk management plans.
Customers are Aware of Food Safety Issues
According to the Deloitte survey, 73 percent of consumers are “more concerned than they were five years ago about the food [they] eat,” an increase of eight percentage points over 2010 figures. The top five food safety concerns include ingredient safety, toxins and chemicals in packaging materials, and contracting a food-borne illness. About 91 percent of consumers think the number of food recalls has stayed the same or increased since the prior year.
Consumers Concerned about Safety of Fresh and Imported Foods
Consumers generally reported the greatest safety concerns about fresh foods, such as meat, fish and seafood, and fruits and vegetables. Fresh food producers, distributors, and retailers may benefit from developing, implementing, and regularly updating their cold chain risk management and HACCP plans to maintain and improve food safety to minimize the risk of food-borne illness and food recalls (as well as the risks of litigation and lost brand value).
Consumers Hold Manufacturers and Retailers Accountable for Food Recalls
More than three-fourths of those surveyed told Deloitte that they hold manufacturers responsible for communicating food recall information. A majority expect that retailers will also notify them about food recalls. Critically, almost 20 percent of consumers reported they would buy “somewhat more expensive” products that included traceability information, compared to lower-priced products without it. These data highlight the need for food growers and manufacturers, distributors, and retailers to adopt and implement food recall risk management plans before a problem arises to meet your customers’ rising food safety demands. (You will be able to read more about food recall risk management plans in my upcoming July 2011 publication).
On March 26, the makers of Toxic Waste candy recalled their “Toxic Waste® Short Circuits™ Bubble Gum” for excessive lead content. This is the second Toxic Waste candy product recalled in 2011 for excessive lead levels.
The gum was distributed between January 4, 2011 and March 18, 2011. This raises the question of the extent to which the recalled product may already have been consumed. Time is of the essence for food recalls, and managing a food recall is easier for both the manfacturer and consumer when a product is recalled sooner than later.
As with the January 2011 recall of the company”s “nuclear sludge” candy, the recalled candy at issue here was imported. Although non-chocolate candy accounted for only 7.3 percent of FDA food import violations from 1998 to 2004, it is difficult to find specific data regarding the scope of these violations. However, the FDA provides information about how it monitors and regulates food importation. Additionally, while candy manufacturers are not at this time required to develop and implement HACCP plans, companies may want to consider doing so sooner than later to manage their risk of food recalls.
What is a “Cold Chain?”
A cold chain is just a supply chain that maintains a constant cold temperature. This helps ensure product safety and stability.
What are Some Critical Cold Chain Risks?
The effort required to identify and minimize cold chain risks (and verify your efforts to do so) depends in part on whether your ingredient sources and final product distribution are local, regional, national, and/or international. A cold chain export logistics system may include 39 or more steps and 21 or more potential cold chain failure points. The greater the number of variables, the greater the risk of cold chain failure.
Risks to the supply chain during domestic transportation include training employees to load products properly into refrigerated trailers to maintain the consistent desired temperature, such as 45 degrees F for shell eggs.
Why is Cold Chain Risk Management Important?
If you cannot document that you have maintained temperature security for your perishable products, you might unintentionally sell spoiled food to your customers. This presents organoleptic concerns as well as health risks, because pathogenic bacteria may not be detectable by taste or smell.
How Can My Company Manage Cold Chain Risks?
Your company can apply HACCP principles to manage its cold chain to identify risks, mitigate them, and maintain optimum product quality and safety. This includes keeping good records of your compliance by, e.g., using integrated time and temperature recording devices to monitor cold cargo.
The FDA provides a wide variety of free forms to document compliance for a number of types of regulated food processors, both at the production plant and in transit.
Developing, implementing, and verifying effective written Hazard Analysis and Critical Control Point (HACCP) plans can seem like a daunting task for startup and small-scale food processing companies. (The FDA Food Safety Modernization Act requires food processing companies to do so.) Climb this hill one step at a time, and you may realize that it is not so hard after all. The Food Safety Inspection Service (FSIS) of the USDA offers guidance and free information to help small and very small companies increase food safety by validating, verifying, and documenting their HACCP risk management plans. Several universities and other organizations publish guidelines for how processing companies can develop HACCP SOPs. Sample HACCP SOPs are also available for restaurants and foodservice companies.