As a food processor, attention to food safety is essential. Clean, sanitized processing facilities need to be maintained and monitored – including by ensuring product safety through a Hazard Analysis Critical Control Points (HAACP) based food safety system; putting product recall procedures in place; and knowing when to inform health authorities of incidents. Section 6 provides an overview of Good Manufacturing Practises (GMPs) and the basic elements of a HACCP plan and a food safety management system.
The Food & Beverage Processing in Manitoba Reference Manual (Third Edition, 2017) contains a sufficiently detailed discussion of GMPs to allow entrepreneurs to develop a suitable food safety program for a start-up application. There is also a comprehensive discussion of food safety management systems and a summary of the Global Food Safety Initiative (GFSI) and all of the Food Safety Schemes that are approved under GFSI. GFSI standards are rapidly becoming the standards for food certification. The US food safety requirements for Canadian exporters are discussed as well. A list of several resource sites and interpretation documents is included in the Reference Manual.
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Food Safety Systems
Consumers, the food industry and public health agencies drive the need for food safety. Food processors have an obligation to ensure they produce the safest food possible.
Good food hygiene is essential for food companies in order to make or sell food that is safe to eat. Food hygiene is the conditions and measures necessary to ensure the safety of food from production to consumption. Food can become contaminated at any point during slaughtering or harvesting, processing, storage, distribution, transportation and preparation.
Lack of adequate food hygiene can lead to foodborne diseases and death of the consumer. Mishandling and/or misuse can make even the safest ingredients unsafe. To produce safe food, processors must follow specific steps and procedures throughout the entire production process.
For each company producing food, the requirements for food safety will differ based on the type of business, product or commodity being produced and where the product is being sold. Generally, however, the requirements and components of a food safety system can be divided into the following levels of assurance:
- Activities required by legislation (See Section 5 Regulations Governing the Food Industry)
- Good Manufacturing Practices (GMPs) also called Prerequisite Programs (PRPs)
- Hazard Analysis Critical Control Points (HACCP)
Developing a successful food safety system requires a solid understanding of:
- Food safety system requirements and food safety principles
- Hazards associated with the products being produced
- Controls required to prevent and manage hazards
- Regulatory requirements
Having a properly implemented and maintained food safety system is important for government recognition, as well as for customers, suppliers, insurance companies or anyone else with an interest in a facility. Having these programs is a way to show due diligence if the need ever arises. Due diligence refers to all the actions that a company can reasonably be expected to take to prevent harm to the customer. A company can demonstrate their due diligence by doing everything that they can reasonably do to prevent hazards in the product. GMPs and HACCP are two things that a company can reasonably be expected to have in place to protect their customers. Due diligence implies actions are taken before an incident. These actions are voluntary, but without them, a company could be considered negligent because they did not do everything they could.
Good Manufacturing Practices (gmp) Prerequisite programs
GMPs and Prerequisite Programs provide a foundation for an effective HACCP system. They are often facility-wide programs rather than product or process specific. The programs deal with the good housekeeping concerns of a facility, whereas HACCP manages specific process hazards. GMPs can reduce the likelihood of certain hazards or may prevent a food safety hazard from occurring.
The following are all considered GMP or Prerequisite Programs:
- Premises / Environment
- Receiving, Storage and Shipping
- Supplier Assurance
- Equipment, Maintenance and Calibration
- Sanitation
- Pest Control
- Traceability and Recall
- Allergen Control
- Personnel Practices
- Training
The NPD Process Model described on the following pages is a business tool that outlines how each of these four functional areas (Tracks) must be dealt with at each Stage in the NPD process. It will work for all businesses, but will be particularly helpful for entrepreneurs and startup businesses.
Premises / Environment
The Premises typically consists of the interior and exterior of the building, and includes the surrounding areas that are not directly connected to food production and storage areas. The environment in and outside a facility, can impact the safety of a product. The facility surroundings can harbor pests that could enter the facility. External contaminants e.g. dust and chemicals can also enter the facility. All aspects of the interior environment of a facility, including the construction, layout, equipment, air, temperature and utilities are potential sources of product contamination. A well designed Premises program will ensure that product is protected from external contaminants and that the facility interior does not present hazards.
Receiving, Storage and Shipping
Food safety starts before food, ingredients, processing aids and packaging materials enter the facility and continues after the finished product leaves the facility.
Receiving is the entry point for all products coming into the facility. If incoming ingredients and other materials don’t meet food safety standards they can bring contamination. If these ingredients and materials are not handled properly they can contaminate the finished product. Contamination can occur during transportation, if the vehicle is not suitable for transporting food, is not clean, kept in good repair or kept at the proper temperature. Vehicles can also cause physical contamination of products and food contact materials from dust and foreign material, chemical contamination from previous loads or biological contamination from improperly cleaned areas that can cause microbial growth. A robust handling and storage program also ensures that chemicals, allergens, waste and defective product are handled and stored to prevent cross-contamination with food, ingredients, processing aids and packaging materials.
Supplier Assurance
The safety and quality of the final food product is ultimately dependent on not only the ingredients themselves but also on the best practices of the ingredient supplier. Sourcing ingredients from approved suppliers is therefore a key program when it comes to ensuring the safety of the finished product. Food from unsafe sources is one of the most common causes of foodborne illness and product recalls. A strong Supplier Assurance program involves knowing the risks associated with incoming ingredients, a supplier approval process, standards and specifications for incoming materials and ongoing evaluation or assessment of supplier’s and their performance.
Equipment, Maintenance and Calibration
An effective equipment, preventive maintenance and calibration program ensures all equipment that could impact food safety works as intended and does not create food safety hazards. These programs help ensure that biological, chemical and physical hazards are controlled. It can also save time and money by reducing unscheduled downtime and unexpected repairs. A comprehensive equipment program considers equipment design and construction, how the equipment is placed/located in the facility, how the equipment is operated, and how it is maintained.
Sanitation
Sanitation plays a very important role in producing safe food. There are many sources of contamination, including residue from food, dirt and chemicals. Contamination can also be caused by allergens that are not effectively cleaned from food contact surfaces. Sanitation programs must clearly address all areas of the facility that receive, store, process or pack food, ingredients, processing aids or packaging materials. Cleaning programs and manufacturing operations must be integrated and coordinated. Therefore, selecting an appropriate time for cleaning is essential if both these goals are to be achieved.
Pest Control
Pests are insects, rodents, birds and other animals that can contaminate food, spread disease and threaten public health. Pests are known to cause biological, physical and chemical contamination. Pests can contaminate ingredients, packaging and finished products. The goal of the preventive pest program is to identify hazards that could occur so that controls can be put into place. Preventive pest management systems include a number of activities such as employee awareness, waste management, building repair and maintenance. They also include biological and mechanical controls. By using all of these, pests can be managed without depending on chemicals that might create chemical hazards. Pesticides should only be used as a last resort.
Traceability and Recall
A recall program facilitates the recall of finished product from the marketplace in the event that food safety is compromised. An effective program facilitates not only recall of finished product, but also the necessary tracing back through a process to ingredients, processing aids and packaging materials at all stages of production, processing and distribution. Every food processor is responsible for the implementation of a recall and traceability program and the verification of its effectiveness. Recall and traceability programs ensure that all suspect products are accounted for and controlled to prevent or minimize food borne illness and injury to consumers.
Traceability is the ability to verify the history, location, or application of an item by means of documented recorded identification. The ability to quickly and effectively recall affected or potentially affected product from customers and consumers is in the best interests of a company. Not only will this help to limit the extent of consumer exposure to a possible health hazard, but the speed of responding to a recall can also play an important part in restoring and maintaining a brand's reputation in the long run.
Allergen Control
If a facility produces or carries products that contain allergens, specific instructions need to be developed for transporting and using them throughout the facility, storing, dispensing and handling the allergens to ensure that non-allergen product is not contaminated. An Allergen Control Plan is a critical component in a company’s food safety program. A company must do everything within its power to ensure allergenic foods and ingredients do not find their way into products for which they are not intended. The Allergen Control Plan is a company’s written document regarding the storage, handling, processing, packaging, and identification of allergenic foods and ingredients.
Each country has a list of recognized or priority allergens that must be identified and controlled within the food production facility. In Canada, Health Canada recognizes the following allergens:
- Eggs
- Milk
- Mustard
- Peanuts
- Seafood (fish, crustaceans, shellfish)
- Sesame
- Soy
- Sulphites (greater than 10ppm)
- Tree Nuts (e.g. almonds, brazil nuts, cashews, hazelnuts, macadamia nuts, pecans, pine nuts, pistachios, walnuts)
- Wheat
Personnel Practices
A facility’s personnel, visitors and contractors are a common source of biological, chemical or physical contamination. They can affect food, ingredients, packaging materials, processing aids and food contact surfaces and play a major role in the production of safe food.
Good personal hygiene is a necessary line of defense in the fight against product contamination. This means understanding how microorganisms contaminate food products, the effect microorganisms can have on food products and how to prevent contamination. Personnel health and hygiene policies are critical to any successful food safety program. A written personnel practices program will include policies to reduce potential hazards and minimize contamination risks. A hygiene or personnel practices program outlines a company’s food safety responsibilities, and includes:
- Hand washing and sanitizing
- Protective clothing (including uniforms, footwear, gloves, hair restraints (hairnets and beard nets), etc.
- Personal cleanliness
- Personal behavior
- Illnesses and injuries
Training
Employee training is essential when implementing and maintaining an effective food safety program. A training program ensures employees understand and follow a company’s policies and procedures. Everyone from production line employees, temporary employees, supervisors and management need to be trained.
All plant employees require training on personnel practices before they work on the production floor. This includes training in personal hygiene practices, food handling skills, and hygienic routines. These ensure that the food, premises, and equipment are clean and well maintained.
Employees also require technical training, including the skills and knowledge needed for more specific food handling practices. These include receiving ingredients and supplies, monitoring critical control points (CCPs), sanitation of equipment, formulations (measuring of controlled ingredients, development of new products), packaging, machine operation and monitoring procedures.
Hazard Analysis Critical Control Points (HACCP)
HACCP is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.
The HACCP approach focuses on preventing potential problems through monitoring and controlling each step of the manufacturing process. HACCP applies science-based controls from raw materials to finished product distribution. It uses seven standardized principles:
Principle 1. Conduct a hazard analysis to identify hazards associated with the food and measures to control those hazards. Hazards could be biological (e.g. pathogens), chemical (e.g. toxins) or physical (e.g. metal fragments).
Principle 2. Identify the critical control points (CCPs). These are points of the process at which the hazard can be significantly reduced or eliminated (e.g. cooking).
Principle 3. Establish critical limits for each CCP. A critical limit is the criterion that must be met to ensure food safety in a product (e.g. minimum cooking temperature and time to ensure elimination of pathogens).
Principle 4. Establish CCP monitoring procedures to ensure each CCP stays within its critical limits.
Principle 5. Establish corrective actions to be implemented if the CCP is not within the established limits.
Principle 6. Establish verification procedures to confirm that the HACCP plan is operating effectively and accordingly to written procedures.
Principle 7. Establish record-keeping and documentation procedures that demonstrate that HACCP is working properly.
HACCP plans are designed to prevent, eliminate or reduce to an acceptable level potential biological, chemical and physical food safety hazards, including those caused by cross-contamination. They are designed to control hazards directly related to the finished product, ingredients or process steps, which are not controlled by GMPs or Prerequisite Programs.
Depending on the type of food business, HACCP may be a requirement for a company to be able to become registered (e.g. for federally registered meat plants, HACCP is a requirement). Regardless of the regulatory requirements, implementing and maintaining a HACCP system can be one of the best ways to assure the safety of your products for a business and its consumers.
Food Safety Management Systems
A food safety system is comprised of managerial and administrative structures and processes to facilitate the food safety program's design and delivery, ongoing maintenance, evaluation and continual improvement. A comprehensive food safety management system is critical to the success of the food and beverage business. Beyond basic food regulations and acceptable workplace practice, a company needs contingency plans for potential crises such as product recalls or foodborne illness outbreaks.
A food safety management system is more than a HACCP plan. It is an all-inclusive system that branches out into all prerequisite programs, contract service providers, vendor approval, allergen management programs, food defense programs, etc. A food safety management system is a company’s program strategy for maintaining and executing a food safety program to encompass and adhere to internal and external standards, regulations and requirements.
In addition to HACCP Plans and Prerequisite Programs, there are several other components that can make up a food safety management system, including:
- Management Commitment
- Document Control
- Corrective and Preventive Actions
- Food Defense
- Internal Auditing
The NPD Process Model described on the following pages is a business tool that outlines how each of these four functional areas (Tracks) must be dealt with at each Stage in the NPD process. It will work for all businesses, but will be particularly helpful for entrepreneurs and startup businesses.
Global food safety initiative (GFSI)
GFSI is a collaborative organization that brings together retail, manufacturing and food service representatives, as well as international organizations, governments, academia and service providers to the global food industry. GFSI benchmarks (reviews and approves) existing food standards against specific food safety criteria and looks to ensure these standards have the same core requirements. GFSI standards cover all facets of the food industry. Many food businesses are required to operate food safety to one of the approved schemes by large retail or foodservice customers that want this extra level of assurance from their suppliers.
GFSI Website: http://www.mygfsi.com/