Everyone knows about Murphy’s Law: “Anything that can go wrong, will go wrong.” The more time one spends in the food industry, the more often one sees that this is true.
But one of the saddest things I see is when people adopt the attitude of one of the corollaries to Murphy’s Law: “There is never time to do it right, but there is always time to do it again.” When it comes to food safety, quality and sanitation, time should be the least of your considerations. Make the time to properly plot your course and actions. Don’t rush forward.
Ideally, food processors should develop, document and implement procedures that ensure that all proposed changes to operations or new programs should be evaluated in detail, which should include a risk assessment that addresses quality, safety, sanitation and potential benefits to the business (change management). Taking the time to conduct such assessments can save time, money and aggravation.
My sense is that everyone who has been in this industry for some time understands the aggravation element, especially when a project or program goes awry and things must be done over again. A proper evaluation of proposed changes upfront is also a key element supporting the doctrine that food quality, safety and sanitation programs should be viewed not as cost centers, but cost savings centers. This procedure should be documented and include details on who within the company will conduct the assessments. Ideally, this should be an interdisciplinary team, but with many smaller companies, the assessment will ultimately be in the hands of top management.
There are many areas in food and ingredient processing where a little extra effort and upfront expenditures can result in not only enhanced quality, safety and sanitation but significant cost savings down the road. Areas where this mantra applies may include, but need not be limited to, product development and formulation, building design and maintenance, equipment review and purchasing, microbiology programs and in-house monitoring. Let’s look at in-house product development. If your product development people formulate with allergens, the end result is that production must eventually manage those allergens and the products that contain allergens. This means that production scheduling must look at the allergens and that cleanups must be conducted during changeovers. And, those cleanup procedures should be properly validated to ensure that they are effective. Eliminate the allergens in the formulation, and production operations can be run more efficiently and effectively.
Since we are talking about allergens, another area that can be potentially save time and effort is when it comes to purchasing and use of natural and artificial flavors. If you are using a hazelnut flavor in a product, does that flavor really contain hazelnuts? Many of these flavors are extracts which are alcohol or glycol-based. If the flavor is labeled hazelnuts, but it can be clearly demonstrated that there is no residual allergen, the need for doing an allergen cleanup would disappear. Which is cheaper? Checking an incoming lot for the presence of an allergen or having to stop production to do a full allergen cleanup?
Another project that processors should consider is whether doing a challenge study or studies on your products is worth the time and effort. And, what kind of challenge study should be considered? If your products are high-acid/low pH, high brix, contain compounds that are antimicrobial or a combination of these characteristics, the products may be either bacteriostatic, meaning that they will not support the growth of pathogens or spoilage organisms, or bactericidal, which means the products themselves will be lethal to these microorganisms. If the product is bactericidal and production procedures are such that finished product characteristics remain constant, the end result will be a very safe product. There are many such products in the marketplace. Some examples are carbonated soft drinks, alcohol-based flavors, condiments, vinegar and soy sauce. The table that is included with this column shows the lethality of soy sauce with and without preservatives when inoculated with different pathogens. With each pathogen, the product completely inactivates them within 6 to 48 hours. This means even if the product does become contaminated in some way, the pathogen will not survive. This means the product is extremely safe.
There is also an added benefit to producing such products. The Preventive Controls regulation in 21 CFR Part 117.130 (c) (2) states the following:
“(ii) The hazard evaluation required by paragraph (c)(1)(I) of this section must include an evaluation of environmental pathogens whenever a ready-to-eat food is exposed to the environment prior to packaging and the packaged food does not receive a treatment or otherwise include a control measure (such as a formulation lethal to the pathogen) that would significantly minimize the pathogen.”
What this says is if food products are lethal to potential pathogens that have been identified through the risk assessment process and the company has established the necessary supporting data, environmental monitoring for pathogens for that product or products will not be necessary. Again, companies will need to do the math. A challenge study utilizing pathogens such as the soy sauce example can be expensive.
But weigh those costs against having data that clearly shows products are safe and eliminating the need and expenses of conducting environmental monitoring for pathogens, and the end result could be significant cost savings and a good night’s sleep for all. Some processors have even expanded challenge studies to include potential spoilage organisms. Doing this will add cost, but if a product is lethal to both potential pathogens and spoilage organisms, worries about safety and economic spoilage will be minimal.
If a processor determines that challenge studies are a good potential investment, take care when it comes to selecting the people who will do the work.
The more conservative and rigid the challenges, the greater the margins of safety with the results and the products. So, take your time when considering changes or improvements to operations. There is a great potential for not only ensuring safety and quality, but also for making changes in a way that saves time, money and headaches.