How Preventive Controls Go Beyond Traditional HACCP:

If you’re familiar with the processing of juice, seafood, meat, or poultry, HACCP is the risk-based preventive food safety system you know and love. And although historically not required, many other types of food commodities have used HACCP, either to satisfy customer requirements or to achieve a third-party certification. I have heard many people express the notion that “well I have a HACCP plan, so I’m good”. But in reading the regulation (21 CFR Part 117), I think there is more to it than just considering the biological, chemical and physical hazards associated with the product and the process. 

Traditionally, HACCP is taught as being built upon other programs such as sanitation, hygiene, and good manufacturing practices. These other programs are sometimes described as the base of the pyramid and the HACCP plan being the peak of the pyramid. In my understanding of the new regulation, the HACCP (or preventive controls) portion of the overall food safety plan is more like one of many pillars that supports the whole building. I think it’s an important distinction because sometimes a complete focus on HACCP causes some of the other programs to lose priority. We get focused on maintaining the required paperwork but lose sight of the basics like pest control or cleaning. 

It’s interesting to note that in 117.126(a)(2), the food safety plan must be prepared (or its preparation overseen) by a so-called qualified individual, who can demonstrate through experience and education that they have the knowledge to do so. If we look at 117.126(b), this section details contents of the food safety plan.

I recognize here that the hazard analysis must be written. This is in contrast to seafood, where the hazard analysis is not required to be written. And I like this addition because it shows the thought process behind the selection of the hazards. It goes on to list that the plan must also include written preventive controls, a written supply chain program, a recall plan, monitoring and implementation procedures, written corrective actions, verification procedures, and records requirements for the aforementioned items. 

So far, a lot of similarities with traditional HACCP. Even the hazard analysis section is pretty standard. But when we get to 117.135(a)(2), there is a subset of controls that may be incorporated into the preventive controls plan. Here we see:
•    Process Controls (cooking, refrigerating, blanching, acidifying)
•    Food Allergen Controls (labeling, separating, scheduling)
•    Sanitation Controls (cleaning of food contact surfaces and utensils)
•    Supply Chain Controls (supplier approval, third party audits, testing)
•    Recall Plan (not a preventive control, but important nonetheless)
•    Other Controls (specific training or practices relevant to a particular food or process)

Just from this short analysis of 2 sub sections in subpart C of 21 CFR 117, I think there are some additional things to think about that go beyond just thinking about the hazards associated with the product. We can’t just slap together a HACCP plan. We need to look at how sanitation, supply chain, allergens, and the process affect the safety of the food and if it’s critical. If determined to be critical, then it needs to be monitored, documented, and verified. Then we must go a step further and seek out what those “other controls” are. There is no template or one size fits all approach. It takes an incredible amount of critical thinking, team work, and research. It will be interesting to see the creative ways food safety scientists come up with the proper controls necessary to address these hazards and how they fit into compliance with the regulation. 

5 Reasons Why You Should Invest in Digital Temperature Monitoring

There are many valid reasons why it’s important to invest in smart temperature technologies that will protect your customers, your business, and make your operation more efficient. Traditional monitoring has involved taking a reading periodically with an indicating thermometer or relying on a temperature recording chart (also known as “temp wheels”). While “temp wheels” have been standard issue for many years, they can be difficult to read, there’s labor involved in replacing them, and they’re prone to error. The following are some reasons why you should consider installing digital temperature monitoring devices:
 

Reason #1: Food Safety

Among all external microbiological growth factors, temperature remains one of the most critical to food safety. Yes, we all know the mantra – “keep hot foods hot and cold foods cold”. A simple rule that’s applied across the board. But in practice we have to be specific about monitoring and recording those temperatures. It’s not enough to say the cooler works. What about temperature fluctuations during different seasons or defrost cycles? This data needs to be captured as it can provide valuable insight into how well the process is actually being controlled. Under FSMA, any step determined to be a preventive control must be monitored and records must be kept. 

Reason #2: Food Quality

Depending on the type of food, temperature plays an important role in maintaining quality. It’s generally accepted in the food industry that the lower temperature you store a food, even a food not requiring refrigeration, the longer the shelf life of those products. When we talk about shelf life, we’re specifically talking about those quality factors that impact the eating experience, such as texture, taste, mouth feel, color, odor, etc. Although this may not apply to finished products, some manufacturers choose to refrigerate or freeze ingredients to extend the shelf life. A longer shelf life means less wasted product and makes for a more efficient operation. Unknown deviations in temperature could affect product quality.

Reason #3: Overall Efficiency

With digital cloud-based thermometers, there is no need to constantly replace and calibrate temperate wheels. There’s also no need to have an employee go around taking ambient temperatures with an indicating thermometer and recording it. They can focus on higher priority functions such as ensuring employee practices are adhered or that products are being made to specification. The data can also be accessed from anywhere with the additions of smartphone apps. There is also no need to scan paperwork into an existing electronic system. Saving time for your quality and food safety staff equates to saving money and preventing costly mistakes.

Reason #4: Easy Access to Records

If you a large facility who is subjected to several audits per year (or even per month), you want to have fast and easy access to temperature monitoring records. You may have the federal, state, and local government to deal with plus third party audits, customer audits, and Kosher inspections. Having electronic records gets you the information faster and more efficiently, ensuring a smooth audit. This also means the inspector isn’t waiting around and you don’t have to go digging for paperwork.

 
Reason #5: Prevent “Dry-labbing”

So-called “dry-labbing” is the practice of filling in data on a form that was not actually observed or performed. Generally we trust our employees working in food safety to do a thorough and accurate job when filling out monitoring records. But the food industry moves insanely fast. Production seems to never stop all the while you are trying to put fires out all over the place. It’s hectic and stressful. However, as busy as people get, we never want them to be in a position where they think that since the cooler has been 40°F for the past 30 days in a row that it will be the same today. This may lead an employee, for whatever reason to write down 40°F when the temperature wasn’t actually taken. This can lead to a systematic failure. Digital temperature monitoring can prevent such a failure if properly implemented.