Baking&Snack - March 2013 - 112

Q&A: FOOD SAFETY

Additionally, the company needs
to make sure that all employees,
including clerical staff, understand
their roles in the event of an inspection. This is something that will
need to change when the FSMA enforcement rules are finalized.

What are the biggest pocketbook issues posed by FSMA?
Food processors will face potential
costs involving reinspections, recalls
and proper development nnd validation of preventive controls.
Let’s look at reinspection first. The
agency has already issued regulations that establish the costs for reinspection, which conveys the veiled
message to get it right the first time.
FDA’s guidance for fees can be found
at
www.fda.gov/Food/FoodSafety/
FSMA/ucm257982.htm. There are
no fees for an initial inspection, but
if there are issues, the agency will
come back, and it will cost the company. Fees include $221 per hour
for inspections requiring no foreign
travel and $289 per hour for projects
involving foreign inspection. So, the
cost for one 8-hour day for one domestic investigator is $1,768.
The second matter with potential hit to the pocketbook could be
developing and validating all preventive controls and critical control
points. The assumption in the industry has always been that if a food
is baked, fried or cooked, then it is
safe, but the salmonella outbreaks
from breakfast cereals were an eyeopener. Some bakers and snack
food processors are doing in-house
research to evaluate their current
processes. Are these cakes, pies,
snacks or cookies actually receiving
enough heat to kill microorganisms
of public health significance? The
validation work will determine if
this is a myth or not.
Validation will entail a great
deal of work for the industry.

Large operations have the people
and instrumentation to do this,
but it will be a challenge to smaller
operations. What large companies
do will remain their proprietary
data, unless they come to the realization that problems with small
companies can potentially impact
their business. Perhaps the baking
trade associations can fund the
research necessary to determine
methods, target organisms, surrogate organisms and the other
issues associated with validating
baking processes.

What equipment design
changes need to occur in
the next couple of years to
improve food safety?
What is needed — and what I
believe is already being done — is
that food process equipment manufacturers must make an even greater
commitment to sanitary design
of equipment and conveyors. The
10 Principles of Sanitary Design
established by the American Meat
Institute for ready-to-eat foods are
really applicable across the board.
These principles should be used
by all food equipment manufacturers. Because most food processing equipment is custom ordered
and built, food processors should
seriously consider working with
the
equipment
manufacturer
to make any modifications that
ensure the equipment is easier to
operate, clean and maintain. It
may add to the initial cost, but
the changes and benefits resulting from more efficient operations
could very well end up paying for
the equipment in short order.

What best practices should
facilities adopt to deal with
allergens and pathogens?
Allergen and pathogen control are
two distinct activities. Their only

real similarities are that both are
potential food hazards and that
good sanitation, especially cleaning
and sanitizing, can help minimize
potential problems.
First, let’s talk about cleaning.
When developing an effective cleaning program, the key is validation.
A validated program is one that is
proven effective at removing soil
from the surface. Once the cleaning
procedures have been validated, you
must implement programs to verify
that the work was done properly.
However, the real challenge in the
baking and snack industries is that
many operations cannot use water
for cleaning.
The real difference between the
two potential hazards is that allergen control is a function of the label,
whereas pathogens must be eliminated from or kept out of the food.
Because baked foods and snacks are
low in water activity (Aw), they generally will not support the growth
of pathogens. But if salmonella
or another pathogen gets into the
product, it could survive and cause
an illness, as with the salmonella
outbreaks attributed to puffed cereals and potato chips.

What is the best advice
you have ever given or
heard about for improving
food safety?
Never skimp on training and education. A commitment to properly
educating workforce and management is an investment in the future,
especially if you can make it seem
like a reward. For example, many
plant workers never get a chance
to get out of the plant on company
business. Getting people out to a
workshop education session, with
lunch included, at a local hotel or
business center can be perceived as
a day off or a bonus. This kind of
program builds goodwill.

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