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Food Safety And Plant Sanitation

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Crisis Management/Recall. HACCP. Prerequisite Programs. Say what you do ... Peter Pan Peanut Butter. Leaky roof and/or faulty sprinkler were sources of water ... – PowerPoint PPT presentation

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Title: Food Safety And Plant Sanitation


1
Food Safety And Plant Sanitation
  • Must have a risk based food safety system in
    place
  • Programs should be aimed at anticipating and
    preventing issues

2
Key Messages
  • The U.S. food supply is one of the safest in the
    world
  • Recent outbreaks have caused loss of consumer
    confidence in food safety
  • Legislative interest in food safety is high
  • Increasing amount of imported foods adds
    complexity
  • Changes in agencies, consumers and media
    highlight the need for a new approach to food
    protection
  • Industry must place greater emphasis on prevention

3
New Challenges
  • FDA faces increasing challenges and risks the
    nations food system
  • Changes in consumer expectations
  • Changes in farming, manufacturing and processing
  • Shifting demographics
  • Increased globalization
  • Terrorism

4
Regulatory ChangesWhat has/is Changing ?
  • Decade of significant regulatory change
  • New Authorities
  • New Regulations
  • New collaboration between Agencies,
  • States and between governments
  • IT upgrade amplifying communication speed

5
Priorities of the FDA
  • Modernization of the Food Safety Systems
  • Imports
  • Food Defense
  • Enhancing and Up-grading Information Technology

6
Recent/Future FDA Modernization Changes
  • FALCPA Implementation
  • Revising GMPs first comment round completed
  • Food Protection Plan
  • Focus on best practice for fruits and vegetables
  • Animal Feed Registration

7
Imports
  • Melamine Issue
  • Rising number of imports

8
Complexity of the Supply Chain
106 U.S. Hatcheries
Feed
Canadian Fish Feed Manufacturer
2 China Suppliers
Aquaculture Farms (2)
Poultry Farms
Slaughter House
Ingredients Meals
Feed Mill
Feed
3 Feed Ingredient Manufacturers
Hog Farms
Scraps
Scraps
5 U.S. Importers
Offal/Meat/Bone Meal
Ingredients Meals
14 Pet Food Manufacturers
5 Rendering Plants
Scraps
Pet Food
9
New Food Protection Plan
  • Introduced November 2007
  • Combines
  • Information Technology
  • Science
  • Identify potential hazards before they have
    an impact

10
Current Regulatory/Legislative
  • Increased emphasis on security and focus on food
    safety
  • Detection of food safety is increasing in
    sophistication IT is facilitating rapid
    communication and actions
  • Food safety has become a political issue with
    continuous media attention

11
Food Security/Defense vs. Food Safety
  • Not synonymous with food safety
  • Food security/defense serves as the umbrella
    under which food safety operates
  • Food Security
  • protection of food products from
    intentional
  • adulteration
  • Food Safety
  • protection of food products from
    unintentional
  • contamination

12
Food Security/Defense vs.. Food Safety
  • Differentiation based upon
  • the intentional vs.. the accidental
  • the diabolical intent vs.. the chance
    occurrence
  • the deliberate vs.. the unplanned
  • the sporadic vs.. the on-going

13
IT Infrastructure Enhancements
  • More and better detection capability and expanded
    use of epidemiology data for decision making
  • Lab Response Networks
  • FERN Food Emergency Response

  • Network
  • Pulse Net Laboratory based system
  • Food Net Agency based system for data
    capture
  • Border Front
  • ACE .
  • Automated Commercial Environment
  • OASIS Operational Administrative System
    for Import
  • Support
  • LRN

14
Government Conclusions
  • Profile on Food Safety is Increasing
  • Ag and Food Supply Chain more complex with an
    Increased Focus on Food Defense and Food Safety
  • More and Faster Pace of Food Legislation and
    Regulations
  • Detection of Food Safety Failure is Increasing in
    Sophistication IT is Facilitating Rapid
    Communication and Actions
  • Science-based subordinated to precautionary,
    emotion-based decisions

15
IndustryWhats Changed/Changing
  • New legislation and regulations have been or are
    being enacted
  • Enhanced information technology tools directly
    impact industry
  • Product life cycle increasingly important
  • Not all risk are created equal
  • Domestic and Imported products
  • Effective partnerships are essential

16
Current Industry Needs
  • Prerequisite programs that are foundationally
    sound
  • Use of a Risk based Approach to Food Safety
  • Be proactive. Prevent what we can, minimize the
    impact of what occurs
  • Anticipate and integrate new requirements

17
Prerequisite Programs
  • Good Agricultural Practices
  • Good Manufacturing Practices
  • Standard Operating Procedures
  • Standard Sanitation Operating Procedures
  • Training
  • Documentation
  • Quality Programs
  • Allergens
  • Labeling
  • Microbiological
  • Crisis Management/Recall
  • HACCP

18
Prerequisite Programs
  • Say what you do
  • Do what you say
  • Validate
  • Verify
  • Document

19
Good Agricultural Practices
  • Food Safety Starts Here
  • Work with Growers
  • External Agencies

20
Standard Operating Procedures
  • Written and Documented
  • Proper training is essential
  • Responsibility and Accountability

21
Standard Sanitation Operating Procedures
  • Must be comprehensive and written
  • Sanitation by design for the plant and equipment
  • Pre operational controls
  • Hygiene practices
  • Documentation and Recordkeeping
  • Trust but Verify

22
Good Manufacturing Practices
  • Code of Federal Regulations 21 CFR 110
  • Provide the MINIMUM requirements
  • Review and Enforce/Upgrade where possible

23
Training
  • Management Commitment
  • Managers, Supervisors, Employees
  • Refresher Training

24
Documentation
  • Substantiates Quality Programs
  • Written procedures to control all documents
  • Review

25
Quality Programs Allergens
  • Update company Policies/Procedures
  • Dedicated Product Systems
  • Scheduling, Separation, Sanitation
  • Training/Education
  • Documentation
  • Labeling

26
Prevalence and severity of Tree Nuts
27
Industry Initiatives
  • Use of test kits to verify cleaning
    effectiveness
  • Voluntary recalls when mistakes are made
  • Food Allergy network Special alert Mailing
  • Allied Trade and Regulatory Associations

28
Quality Programs Labeling
  • Consumer Concerns
  • Industry Quandary
  • FDA

29
Advisory Label Examples
  • May contain nuts
  • Contains nuts
  • Contains traces of nuts
  • May contain the occasional nut
  • Manufactured on equipment that processes nuts
  • Manufactured in a facility that processes nuts
  • May contain soy flour, whey, peanuts, and tree
    nuts
  • May contain (Listings of Nuts)

30
Impact of Over Labeling
  • Food Allergic Consumers
  • Angry, frustrated, and scared
  • Restricted food choices become more restricted
  • Their lives will be controlled by our ability to
    get closer and closer to zero

31
Quality Programs Microbiological
  • Recent findings have necessitated re-evaluation
    of programs
  • Emphasis placed on Environmental Monitoring
  • SSOPs
  • GMPs

32
Background - Salmonella in RTE foods
Notable cases of food-borne salmonellosis
linked to low moisture products
Cross contamination from environment
Ingredient contamination
33
Most Recently
  • 3 outbreaks of Salmonella in past year
  • Low moisture ready-to-eat (RTE) foods
    contaminated by either the environment or
    ingredient
  • Cadburys Chocolate
  • Leaky waste water pipe above product zone
  • Peter Pan Peanut Butter
  • Leaky roof and/or faulty sprinkler were sources
    of water
  • Dormant transient pathogen now able to grow and
    become an established pathogen site and
    contaminate product
  • Roberts American Gourmet Veggie Bootie Snack Mix
  • Source of Salmonella appears to be seasoning blend

34
Industry Need
  • Re-assess your hazard assumptions
  • Re-assess your risk exposure
  • Do you have all the right programs in
    place?
  • Do you have to do more of anything?
  • Do you have to do anything differently?

35
Crisis Management
  • Comprehensive Program
  • Accountabilities
  • Action
  • Communication
  • Decision Making
  • Recalls
  • Traceability
  • Documentation

36
Traceability
  • Lot Coding
  • Rework/Work In Progress
  • Records
  • Mock Recalls

37
HACCP
  • Risk based systematic approach to hazard
    identification, assessment and control
  • Biological
  • Pathogens
  • Chemical
  • Poisons, Pesticides, Toxic cleaning
    chemicals or
  • any other compounds that could cause
    injury or death
  • Physical
  • Magnets, Sifters, Screens, Metal
    Detectors

38
Sanitation
  • Organizational Effectiveness
  • Measurement
  • Planning
  • Preventative Predictive Sanitation
  • Training

39
Industry Conclusions
  • Review Prerequisite Quality Programs
  • Industry will place more emphasis on Programs and
    Documentation
  • Train
  • Share Best Practices There is no competition
  • when it comes to food safety!
  • Be proactive. Prevent what you can, minimize the
    impact of what occurs

40
Concluding Remarks
  • New century of interconnectedness and
    collaboration
  • Globalization will present new issues and
    increase exposure to old
  • Prevention, early detection and communication
    will serve us all well
  • Train
  • Be Proactive

41
Thanks
  • Sara Geisert, General Mills Regulatory
  • Dr. Tom Trautman, General Mills Toxicology
  • Kevin Farnum, General Mills Sanitation/Food Safety
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