Milling & Baking News - October 18, 2011 - 26

Regulatory Affairs 

Prepare for winter and the new year
BY ANNE GIESECKE

Cooler temperatures drive a variety of animal and insect pests to seek shelter indoors, but the sanitation department is on the front line to prevent their entry. The baker and snack manufacturer will need to be in compliance with a new rule. During September, the Environmental Protection Agency (E.P.A.) published a new list of approved rodenticide products (www.epa.gov and search “bait stations”). The bait stations are resistant to weather and to tampering and may be used indoors and outdoors (within 50 feet of buildings,

the food supply is safe by shifting the focus of federal regulators from responding to contamination to preventing it. Bakers and snack food manufacturers must evaluate risk in their plants and put in place systems to minimize the risk. Forward thinkers will take the opportunity to optimize their operations. As mentioned above, air flow though a plant is critical for product quality and may be a significant factor in allergen cross-contamination. As sanitation is doing a risk analysis to anticipate pest activity, the risk analysis and procedures put in

should consider the use of standards from the program Leadership in Energy and Environmental Design (LEED). These standards are for efficient use of energy, water and to minimize waste. Winter preparations to ensure supply of ingredients and materials as well as preparation of alternative delivery routes may be compatible with the awareness about traceability. Traceability of ingredients backward and product forward for the F.S.M.A. should include knowledge of the safety of the sources as well as the corporate responsibility standards and sustainability of the company. The integrity of the supplier and those supplied is integral to the costs of those operations. On the floor, audits are a concern. Industry efforts are being made to try and consolidate audits and the F.S.M.A. may help move that endeavor. The many parts of sustainability This column started out simply preparing for winter and ends deep into sustainability. Sustainability has three parts: economic, social and environmental. The F.S.M.A. is for preventing illness. The prevention of contamination from pests is basic to food safety. The point is that optimizing the operation is the bottom line. The names of the programs and activities are not as critical as the overall coordination of teams within the bakery or snack operation. The web has many sites for learning about what might work best in a particular situation. The AIB Internaional and even www.epa.gov all have resources that are accessible and may be tailored to particular operations. The U.S. E.P.A. Energy Star initiative by the American Bakers Association will provide some baseline information that may be helpful. Individual companies are also eligible to join Energy Star. Companies must coordinate activities to use employee talent effectively and use resources efficiently to show continuous improvement. So much to do, may the winter be mild. MBN

defined as structures that possess walls and a roof). The purpose of the rule is to protect children, domesticated animals, pets and wildlife. The entire property and buildings are subject to evaluation. These areas include the processing plant, garbage areas, storage structures, and vehicle maintenance building. The processing plant has challenges with structural integrity, at delivery and distribution areas, break and rest rooms. Winter adjustment for roof vents requires sanitation and engineering people to work together to seal roof gaps and adjust gravity dampers. A positive air pressure in the plant for sanitation and the avoidance of heat loss are important for appropriate air flow through the plant to ensure product quality. F.S.M.A. presents challenges Another new challenge is the implementation of the Food Safety Modernization Act (F.S.M.A.). The purpose of the F.S.M.A. is to ensure
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place may be documented to meet F.S.M.A. requirements. At the same time, production may critique allergen changeovers and cleaning requirements. Costs for energy and water are not expected to go down. F.S.M.A. implementation efforts may reveal opportunities to better use energy and water and to reduce waste. The reconfiguration of air compressors and the consideration of alternative refrigerant systems also may fit with the F.S.M.A. Air compressors should not leak and should not emit contaminated air. New refrigerant systems offer better temperature control to ensure food safety and product quality. The use of food grade lubricants, and the discontinued use of mineral and other petroleum oils, will make lubricant and oil management less subject to burdensome compliance requirements. Considering LEED for retroﬁts Any structural or machine retrofits

Anne Giesecke, Ph.D., is a contributing editor at Sosland Publishing Co.
bakingbusiness.com / world-grain.com

http://www.epa.gov http://www.epa.gov http://www.bakingbusiness.com http://www.world-grain.com

Milling & Baking News - October 18, 2011

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