According to USDA records, more than 20 million pounds of meat were recalled last year, and the U.S. government is expected to issue new food safety guidelines after a recent spike in meat and poultry recalls due to product contamination. These headlines reveal the alarming rate at which food companies are still experiencing costly recalls, even amid modernized food safety regulation and heightened oversight. These statistics are a strong reminder of the importance of following preventive food safety guidelines and taking a proactive rather than reactive approach to contamination challenges.
If you’re worried about whether your food safety plans are aligned with critical guidelines focused on prevention, here’s some expert insight on the factors you need to prioritize. Make sure your company is adopting these preventive food safety guidelines to mitigate the risk of expensive recalls and reputational damage.
1. Hazard/Risk Analysis and Prevention
The Food Safety Modernization Act (FSMA) focuses on early identification and prevention of food safety issues, which is clearly indicated in its preventive controls provision. As part of FSMA’s requirement to institute and follow a solid plan for HARPC (Hazard Analysis and Risk-based Preventive Controls), it is imperative to integrate the following aspects into your food safety plan:
- Sanitation procedures at food surface contact points
- Sanitation of utensils and equipment
- Staff hygiene training
- Environmental monitoring program (for pathogen controls)
- Food allergen control program
- Recall plan
- Current Good Manufacturing Practices (cGMPs)
- Supplier verification activities
An up-to-date HARPC is a fundamental component of preventing recalls. Unfortunately, most companies aren’t aware that they need to update this critical plan EVERY time something changes. Make sure that yours is consistently revised to reflect issues such as:
- Emergent employee and equipment sanitation hazards
- New ingredients that may pose allergen risks
- Ineffective control measures and preventive controls
- Actual versus documented production flow processes
- Changes to compliance requirements or industry standards
Assign a HARPC and food safety team that meets on a regular basis to assess problems, implement updates and protect your brand from recalls.
One of the many difficulties in implementing a truly preventive approach is maintaining complete, accurate and up-to-date records amid the challenges of limited resources and simultaneous focus on daily production goals. Paper-based and other manual forms of meeting preventive food safety guidelines render this objective nearly impossible.
But managing the necessary records and documentation doesn’t have to be a highly complex undertaking. A cloud-based software solution that integrates all data and workflows via a centralized database allows you to unlock food safety and compliance insights, maintain document control, avoid the costs of extra manpower, facilitate company-wide compliance contributions and eliminate points of risk, error, inefficiency and miscommunication. A dynamic platform can put valuable insight and data at your fingertips to make planning and implementation more intelligent and thorough.
2. Established Safety Standards
FSMA’s Final Rule on Produce Safety went into effect in January of 2016, establishing for the first time science-based minimum standards for the safe growing, harvesting, packing and holding of fruits and vegetables grown for human consumption. The rule’s key requirements address:
- Agricultural water
- Biological soil amendments
- Domesticated and wild animals
- Worker training, health, and hygiene
- Equipment, tools, and buildings
The responsibility of protecting consumers from contamination falls, in large part, on the shoulders of the farms that grow, harvest, pack and hold produce, but overall accountability and risk don’t end there.
It is necessary for manufacturers to ensure organization-wide alignment on preventive policies and procedures, including those that mitigate food safety hazards all along their supply chain. A valuable software like CONTROL-PRO enables both farms and production companies to keep segmented aspects of food safety and compliance organized and efficient. It keeps everyone focused on operating in accordance with established food safety standards and preventive guidelines.
3. Risk Mitigation for Adulteration
The Final Rule for Mitigation Strategies to Protect Food Against Intentional Adulteration is aimed at preventing intentional wide-scale harm to public health, including acts of terrorism targeting the food supply. While not likely to occur, these acts could cause illness, death or economic disruption of the food supply without proper mitigation strategies. Rather than targeting specific foods or hazards, this rule requires risk-reducing strategies for processes in both domestic and foreign companies that are required to register with the FDA as food facilities under the Federal Food, Drug, and Cosmetic Act.
Each facility is required to prepare and implement a written food defense plan that identifies:
- Vulnerabilities and actionable process steps for each type of food manufactured, processed, packed or held at the food facility
- Mitigation strategies at each actionable process step to provide assurances that vulnerabilities will be minimized or prevented
- Procedures for food defense monitoring, corrective actions, and verification, including training to ensure that personnel assigned to the vulnerable areas receive appropriate training, as well as thoroughly maintained records of all data and activities
A reanalysis is required every three years or when certain criteria are met, including mitigation strategies that are determined to be improperly implemented. And just as with critical safety standards, there must be alignment among all members of the organization when it comes to the steps taken to mitigate risk.
4. Supplier Verification
Food safety in your operations is impacted by any hazards your suppliers may be introducing as a result of improper handling and sanitation procedures. If you’re not taking the necessary actions to ensure that your suppliers are preventing these hazards, you can’t be sure that your own product won’t be affected. Therefore, insight and transparency are paramount at every touchpoint along the way.
The Final Rule on Foreign Supplier Verification Programs (FSVP) requires that importers perform certain risk-based activities to verify that food imported into the United States has been produced in a manner that meets applicable U.S. safety standards. Under FSMA rulings, importers are legally bound to the following responsibilities:
- Determining known or reasonably foreseeable hazards with each food
- Evaluating the risk posed by food, based on the hazard analysis, and the foreign supplier’s performance
- Using that evaluation and the supplier’s performance to approve suppliers and determine appropriate supplier verification activities
- Conducting and documenting supplier verification activities
- Conducting and documenting corrective actions
- Establishing and following written procedures for supplier verification
- Developing, maintaining and following a foreign supplier verification program for each food brought into the United States and the foreign supplier of that food
With a controlled process to regularly assess your food suppliers, you reap the benefit of greater visibility into potential food safety risks. Visibility is key to prevention. It enables you and your team to identify issues before you have a major recall on your hands.
The bottom line is that a preventive approach to food safety cannot truly be achieved without standardized, documented, shareable and automated processes in place to safeguard against contamination and the onset of foodborne illness. To effectively ensure that your organization is maintaining all of these important food safety guidelines and truly minimizing the risk of food recalls, it’s best to adopt tools and tactics that keep every plant, person and process fully aligned. Avoid the high costs of recall investigation, remediation, customer management, logistics and brand perception by taking the necessary steps to uphold the highest standards of prevention in food safety.
Interested in accessing additional guides to keep your brand strong, minimize your organization’s recall risk and elevate your reputation for quality? Get your free Food Recall Prevention Kit.