During my time working in the food industry, I’ve noticed that HACCP system verification and validation activities are rarely given the attention they deserve. Facilities typically meet the minimum regulatory requirements and do little beyond that. How does your company stack up? Have you implemented a variety of periodic verification activities to supplement routine verification measures in your facility? If not, it may be time to give HACCP verification and validation another look. Continue Reading

Major developments in the Food Safety Modernization Act (FSMA) have given the FDA new authority under the law. If the FDA decides to conduct a swabathon at your facility, you should expect a minimum of 100 to 300 swabs to be taken and a team of several investigators to conduct the swabathon. Based on the type of swabathon, you may also be required to hold production in your facility. This need is based on several factors, but, in particular, the zones that will be tested.

The FDA’s goal is to find pathogen isolates of Salmonella and or Listeria monocytogenes in and around the processing environment. As an outcome, the FDA will subsequently perform Whole Genome Sequencing (WGS) on these Listeria monocytogenes isolates for their database. The FDA is now swabbing Zone 4 specifically for this purpose, with a WGS analysis of Salmonella expected to follow. The FDA’s zone focus will differ based on the environment and the specific pathogen they are seeking out. For Listeria monocytogenes, you can expect the FDA to begin sampling no sooner than 4 hours into production. Continue Reading

For over 20 years, the food industry has been steadfast in our view of the role of sanitation in classical Hazard Analysis Critical Control Point (HACCP) programs. Our experience with meat and poultry HACCP by way of the International HACCP Alliance and what came later with Global Food Safety Initiative (GFSI) HACCP requirements solidified the supportive role of sanitation as a food safety prerequisite program. We have managed sanitation as a separate prerequisite program, and then used these programs to eliminate the need for sanitation critical control points. However, compliance with the Preventive Controls Rule for Human Food (PCHF) as part of the Food Safety Modernization Act requires a different approach in how we manage sanitation procedures that directly addresses a food safety hazard identified in the hazard analysis. Continue Reading

Using Hazard Analysis Critical Control Point (HACCP) principles to manage food safety in the dairy industry is not a new concept. Most dairy manufacturers have already implemented HACCP as a process to manage food safety in addition to regulatory requirements.

Although the FDA Preventive Controls for Human Food Rule is not required for Grade A dairies until September 2018, customers and retailers continue to require their suppliers to have an effective and operational HACCP Plan in place that is overseen by a trained individual. Additionally, Global Food Safety Initiative (GFSI) schemes such as Safe Quality Food Institute (SQF) and British Retail Consortium (BRC) also require HACCP implementation overseen by a trained individual. Finally, global organizations, such as The Food and Agricultural Organization of the United Nations (FAO), continue to recognize HACCP (Codex HACCP) as a system which identifies, evaluates and controls hazards which are significant for food safety.  Continue Reading

If you are subject to the final rule, Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food (PCHF rule), then you should be aware of FDA’s new recommendations for controlling Listeria monocytogenes in ready-to-eat (RTE) foods. Manufacturers, processors, packers and holders of RTE foods will benefit from an understanding of the strategies and recommendations described within the new draft guidance.

Released this month, the draft guidance sheds light on the agency’s thinking regarding effective strategies for controlling L. monocytogenes in RTE foods, including identifying the risks associated with raw materials and ingredients, listericidal process control, environmental monitoring, product testing, and the analysis of verification data trends. Continue Reading

Required under both the FDA and USDA-FSIS regulations, the Hazard Analysis is arguably the most important component of any food manufacturer’s food safety system. Unless identification of CCPs or Preventive Controls is based on a scientifically sound, properly-supported hazard analysis, hazards may not be adequately controlled. Since microbial hazards often represent the greatest potential food safety risk for food products, it’s critical to understand the microbiological profile of ingredients. This requires both general knowledge of hazards applicable to a particular ingredient and specific information on the ingredients sourced from your suppliers. Continue Reading

Due to its presence in the Food Safety Modernization Act (FSMA) and prevalence in Global Food Safety Initiative (GFSI) schemes, Hazard Analysis and Critical Control (HACCP) programs are very much vogue these days in the food industry.

Under FSMA’s preventive controls rule for human food, facilities that manufacture, process, pack or hold human are charged with implementing a written food safety plan focused on controlling hazards. In nearly every GFSI certification scheme, including Safe Quality Food (SQF) and BRC, companies seeking accreditation to a particular Code are required to have validated and verified HACCP plans. Continue Reading

The food industry has evolved from locally grown and consumed products to national and international operations. The globalization of food production and trade has raised the potential of food safety issues to an international level. The food industry has done a remarkable job ensuring food safety not only at the national level, but also at the international level.

As part of this effort, food companies — many times under regulatory guidelines — are required to validate their operations for safe and quality foods. Process validation studies determine the ability of a specific Critical Control Point (CCP) of a HACCP plan to achieve desired food safety objectives.  Continue Reading