No One Wants A Recall: Plan, Implement and Audit Effective Food Safety Practices
September 20, 2019
By Don Hodapp
Business Development Director, Facilities Division, POWER Engineers
All manufacturers of consumable products should be concerned about the possibility of a recall. With the 24/7 news cycle and omnipresence of social media, recalls of contaminated products are under the harsh spotlight of public scrutiny. The theory of “there’s no such thing as bad publicity” does not extend to the food manufacturing industry – a recall can result in severe impacts to a manufacturer’s brand, revenue, and the health of consumers.
The risk factors for a recall include human error, food safety monitoring process failures, non-compliance with internal segregation and sanitation procedures, or not catching tainted ingredients in the supply chain. While the causes are complex, proactive preventative actions are quite often common-sense. When these steps are implemented correctly, and audited and adhered to, they do work.
Risk factor: Pathogens
Pathogen contamination can occur when disease-causing bacteria, spores or microorganisms are present in a food product. To minimize this risk factor:
- Properly implement and monitor the “kill step” to eliminate harmful bacteria.
- Ensure control checks are conducted with redundancy.
- Utilize technology and historian data in controlled environments.
- Clean thoroughly to remove all remnants and residues, and secure infrastructure to prevent leaks or buildup of mold, spores, bacteria or other potential contaminants.
Risk factor: Cross contamination
When raw and ready-to-eat areas are not properly separated, potential allergens or contaminants can be introduced into the product. To minimize this risk factor:
- Set up isolation zones and segregate HVAC systems to prevent contamination via vents, walkways and foot traffic patterns.
- Make it simple for employees to sanitize hands/feet and change smocks, gloves and hairnets when they are transitioning from pre-kill step areas into ready-to-eat areas.
- Segregate material flows between pre-kill step and ready-to-eat areas (e.g., forklifts, pallet jacks, maintenance personnel, etc.).
- Visit the plants where your ingredients come from to ensure sanitary standards are being met across the supply chain.
Risk factor: Foreign objects
Accidents happen – when there are equipment/machinery breakdowns or if employees improperly dispose of tools, gloves, hairnets or other objects, it can contaminate the supply chain. To minimize this risk factor:
- Scan for metal, glass, wood, and foreign objects with metal detectors and x-rays; require your ingredient suppliers to do the same.
- Secure overhead equipment and update or monitor aging machinery for broken parts.
- Have a process in place that is ready to find the foreign object and ensure complete removal from the line flow, if it does happen.
- Integrate maintenance and sanitation when repairing affected equipment.
How to create a controls philosophy
Advance planning is the best protection against food safety risk factors. Develop a written description of your production process with an emphasis on how it should be operated and controlled – this is known as a “controls philosophy.”
- Develop a detailed step-by-step plan for what will be done to correct a process if things go wrong.
- Formalize a plan and write down the specific actions that must be taken to regain control of the process. Be sure to detail the who, what, when, where, why and how for each step of the plan.
- Regularly communicate this formal plan to employees; even the best safety plan is ineffective if nobody knows what it is.
- Collect, evaluate and use historian data to set up controls philosophies for how the processes will change if an incident happens, or when conditions are altered.
- Conduct regular inspections to ensure all controls philosophies in your facility are being adhered to and implemented correctly.
- Monitor any failures, implement corrective actions immediately, document what happened, and always audit, audit, then audit again for compliance.
Reducing your risk of a recall does not need to be complex or expensive, and it will not decrease efficiency. Preparation, strategic planning and forethought, regular communication, written documentation, and subtle improvements to what you are already doing will go a long way towards keeping your product, consumers, and reputation safe.
About the Author
As a food industry veteran, Don has been there, done that, and seen it all: from working on the plant floor, to managing facility operations, to his current role of working hand-in-glove with global manufacturers as an engineering consultant. He understands the complexities of the food industry – the unpredictable nature of ingredients, the unique characteristics of each product, and the importance of uncomplicated sanitation processes. Don finds solutions that meet the requirements for clients’ products and operations while keeping in mind acceptable best practices.
Do you have a question for Don? You can contact him via email at firstname.lastname@example.org.