Key Components of Food Safety Compliance
Eric Hansen
Food safety is a top concern for Food and Beverage companies and for a good reason. Not only does it help to ensure the safety of your consumers, but it also prevents severe consequences like hefty fines and irreparable damage to your company’s reputation. While each company is unique and thus must take its own tailored approach to compliance, there are a few industry best practices you can use as a starting point for designing more specific food safety programs. In this blog, we will cover the key components of Food Safety Compliance:
What Does Food Safety Compliance Mean?
What Are the Key Elements of Food Safety?
Food Safety Regulations & Standards
Examples of Food Safety Compliance Requirements
How to Effectively Manage Food Safety Compliance Requirements
What Does Food Safety Compliance Mean?
Food safety involves the procedures and regulations designed to prevent food supply contamination. This requires a robust approach due to the many links in the food supply chain and various processes food products undergo within a facility. For example, the preparation, handling, and storage of food must all include preventive measures to ensure safety.
While companies will have their own internal food safety programs specific to their products and processes, these plans are overseen by governing bodies such as the FDA and USDA. In addition, many process manufacturers have turned to Food Safety Software that supports the many unique needs of food safety compliance. Thus, food safety compliance is the act of complying with the standards that apply to a Food and Beverage facility.
What Are the Key Elements of Food Safety?
A comprehensive food safety program is built on an effective and thorough food safety plan. However, some companies may use a HACCP plan instead, which refers to “Hazard Analysis and Critical Control Points.” Here’s a closer look at the difference between HACCP and food safety plans and how both can promote food safety compliance:
HACCP Plans
HACCP plans are designed to preventively identify and address risks and hazards associated with specific foods or production processes required by the FDA for the juice and seafood industries. Their goal is to control the reasonably likely hazards, including microbiological, physical, and chemical risks. HACCP plans can be streamlined and standardized across facilities and departments with software that supports HACCP.
There are seven core principles of HACCP that together, promote ongoing food safety compliance:
1) Conduct a hazard analysis.
In this step, you must list the detailed steps involved in the processing and identify those in which significant hazards are likely to occur. Then, focus on the hazards that can be prevented, eliminated, or controlled through an effective HACCP plan.
2) Determine critical control points (CCPs).
CCPs are steps, points, or procedures at which actions can be taken to reduce a food safety risk. Some examples include:
Chilling
Thermal processing
Testing for metal contaminants
Testing for chemical residue
Establish critical limits.
Critical limits (CLs) are the minimum and/or maximum values to which physical, biological, or chemical, measures must be controlled to reduce or completely eliminate a hazard. These may include metrics such as weight, temperature, time, or other parameters controlled by regulatory standards.
3) Establish monitoring procedures.
Food safety teams must also establish and adopt monitoring procedures to measure CLs at each CCP in their process. The HACCP plan should also detail how the measurement will be taken and when and by whom.
4) Establish corrective actions.
When a deviation in CLs occurs, corrective actions are used to address and prevent hazards. This should include the identification and resolution of the issue itself as well as steps that will be taken to prevent it from happening in the future.
5) Establish verification procedures.
Verification activities determine the validity of the HACCP plan and ensure operations are running according to the plan. Food safety teams may use verification activities such as reviewing records, auditing CCPs, calibrating instruments, and testing products.
6) Establish record-keeping and documentation.
Recordkeeping is a key component of any HACCP plan. While records detail all the information about the plan for employees to reference, they can also be used as proof that food was made safely during audits. Documentation should include the plant’s hazard analysis, CCPs, CLs, monitoring system, corrective actions, recordkeeping procedures, and verification activities.
7) Food Safety Plans
While the FDA does not require HACCP plans for all food groups, any companies that fall under the FDA’s Food Safety Modernization Act (FSMA) must have a written food safety plan for compliance with the Human Food Rule. A food safety plan encompasses HACCP principles.
The FDA notes that a food safety plan “consists of the primary documents in a preventive controls food safety system that provides a systematic approach to the identification of food safety hazards that must be controlled to prevent or minimize the likelihood of foodborne illness or injury. It contains a collection of written documents that describe activities that ensure the safety of food during manufacturing, processing, packing, and holding.”
A food safety plan should include a hazard analysis, preventive controls, monitoring procedures, corrective actions, and verification procedures like a HACCP plan. The FDA also requires:
Documented records illustrating how the plant is implementing the food safety plan
A preventive controls qualified individual (PCQI) who designs or oversees the food safety plan
Signing and dating upon plan creation and every update made thereafter
Reassessment of the plan at a minimum of two-year intervals
Food Safety Regulations & Standards
To understand food safety compliance, it’s important to first look at the governing bodies. The FDA and USDA are two of the largest regulatory bodies overseeing food safety.
FDA
The FDA is the lead agency that oversees the processing of food post-harvest. Its role is to see that products are made and labeled properly and protect food safety and wholesomeness.
To contend with the enormous responsibility of promoting food safety and minimizing illnesses caused by foodborne diseases, FSMA was signed into law in 2011. FSMA applies to all food producers, including manufacturers, processors, packers, and distributors (except USDA-regulated meat, poultry, and egg producers). Over the next decade, several final rules were rolled out, including:
Preventive Controls for Human Food Rule
The core of FSMA requirements, the Preventive Controls Rule, focuses on problems that could lead to foodborne illnesses by applying risk-based preventive controls.
Foreign Supplier Verification Programs (FSVP) Rule
As its name suggests, the FSVP Rule applies to importers of human and animal foods. Under this rule, importers must perform risk-based activities to ensure any food entering the U.S. meets FDA safety requirements.
Intentional Adulteration (IA) Rule
The objective of the IA Rule is to prevent purposeful acts against the food supply from causing widespread harm to public health.
FSMA 204
The Food Traceability Rule involves comprehensive product tracing, requiring manufacturers to monitor and document Critical Tracking Events (CTEs) and Key Data Elements (KDEs) within their facility and along their supply chain.
USDA
The Food Safety and Inspection Service (FSIS) of the USDA regulates the US’s commercial supply of meat, poultry, and egg products. Their goal is to ensure products are safe, wholesome, and labeled correctly.
There are several Food Safety Acts used to promote healthy, wholesome products, including:
Federal Meat Inspection Act
Poultry Products Inspection Act
Egg Products Inspection Act
Humane Methods of Livestock Slaughter Act
In addition to these agencies, state health and agriculture departments and EPA have jurisdiction over some aspects of food safety.
Examples of Food Safety Compliance Requirements
Your company’s food safety requirements may look different than the next. In fact, under FSMA, different facilities—even within the same company—require their own unique food safety plan. That’s because no two facilities are exactly alike, and each has its own specific risks that must be identified and mitigated.
While conducting a hazard analysis to identify potential risks is an extensive undertaking, here are some basic concerns to bear in mind:
Handling of raw materials: Your facility should have certain procedures in place to ensure the quality of materials and ingredients from their point of entry. Quality checks protect the food supply and your equipment, and any other food with which the materials come into contact.
Food contact surfaces: Rigorous and routine cleaning of equipment and surfaces that come into contact with food are crucial for any food manufacturing facility’s sanitation program.
Cross-contamination: While it’s simple in theory, cross-contamination continues to pose a considerable risk in food processing. Contamination can be spread through numerous entry points, including operators and production areas. To that end, your policies and procedures should thoroughly address bacterial and allergenic risks.
How to Effectively Manage Food Safety Compliance Requirements
1) Know Which Regulations Apply to You
Understanding which regulatory requirements apply to your company is the critical preliminary step to ensuring compliance specifications are being met. As mentioned above, different governing bodies are in place to ensure quality and safety in environments where food is handled, from farms to processing facilities. Your company may fall under the authority of one or more sets of regulations, but it’s important to know for sure. According to a survey conducted by SafetyChain and The Acheson Group, more than 10% of respondents were unsure as to whether their food and beverage company fell under FSMA.
2) Develop Procedures & Train Accordingly
Every food and beverage company must take a disciplined approach to ensure compliance with applicable regulations. Based on guidelines, companies should put their own preventive controls in place to monitor compliance specifications. For instance, companies under FSMA must develop a detailed Food Safety Plan outlining specific controls intended to mitigate potential risks. Data like temperature readings should be tracked, and it’s also important to develop strict procedures to prevent contamination and maintain cleanliness. Once these procedures are in place, companies should then provide thorough training for all employees, so everyone has a complete understanding of their role in maintaining food safety and quality.
Of course, food safety isn’t a “one-and-done” event but an ongoing activity. Once a comprehensive plan is developed, and staff members are trained, it must remain an everyday priority through the enactment of your protocols. Ideally, food safety compliance issues should be identified before they escalate.
While well-trained staff plays a significant role in the prevention of safety issues, technology can help, too. For instance, a fully digitized CAPA program can drive continuous improvement and support compliance with real-time operational data that tells you the story of what’s happening in your plant and why. With digital root cause analysis, you can pinpoint the circumstances that lead to CAPAs so you can address them promptly and prevent them from happening again. The system can leverage data from inputs such as sensors and help you uncover root causes through tools such as the 5 Whys or fishbone diagrams. It will also allow you to decrease your resolution time and ensure your CAPA program is being executed effectively.
3) Optimize Records Management
A final but important step in ensuring compliance is optimizing records management. Every critical piece of data from processes like task checklists to vendor approval must be properly documented and easily accessible. This will help you ensure your food safety and quality program requirements are being met every day while also keeping your company prepared for audits and inquiries. Moreover, comprehensive recordkeeping is essential for FSMA compliance.
Food safety compliance is clearly among the most extensive undertakings for Food and Beverage facilities to pursue. Fortunately, there are tools available to help. From FSMA’s Food Safety Plan Builder to technology such as SafetyChain’s CAPA, a streamlined way to perform root cause analysis and preventive and corrective actions, there are many solutions that can make your teams more effective in their roles.
About SafetyChain
SafetyChain is the #1 Digital Plant Management Platform that improves yield, maximizes productivity, and ensures compliance for process manufacturers. Trusted by over 2000 facilities, SafetyChain is the only enterprise platform uniting production, quality, safety, and supplier management.
