By: Gordon Hayburn
It’s one of the grand ironies of our times that the proliferation of food safety standards has made people much more aware of food safety management requirements—and yet the issue of food recalls continues to be a serious cause for concern. A recall can be triggered by either an accidental event or intentional deliberate sabotage but, either way, reports suggest that food recalls can cost a company in excess of $10 million; factor in an untold amount of brand damage and the loss of consumer confidence—which might never be recaptured—and you have a potentially crippling situation on your hands. What’s a company to do? Here are six suggestions.
1. Complete a vulnerability assessment. A vulnerability assessment will identify areas of the site or parts of the process where there is an opportunity for malicious tampering to occur at the hands of disgruntled employees or people from outside the organization. Good staff training, appropriate security and ensuring supervisors and managers are aware of employee issues which may escalate to a problem are key here.
2. Implement a program of daily or weekly accuracy testing. Microbial issues arise from either under-processing or post-process contamination. Instrument calibration once or twice a year will not provide consistently reliable information. Companies operating close to the “critical limits” run the risk of not achieving the required process if there is an issue with the accuracy of the measuring equipment. It needs to be checked often.
3. Plan effectively and use correct segregation controls. Poor storage and handling practices are the most common cause of post-process contamination and this often links to poor workflow design and scheduling. Allergen contamination is generally the result of:
Failure to ensure that metal detector and weight reject bins are emptied as part of a changeover can lead to a food recall. These products might be checked in line with company requirements, e.g. passed through the detector three times and, if there is no issue, then allow them into the boxing and palletizing stage. Although the labels may be accurate, when a few rogue packs are discovered within a case or pallet, retailers are almost certainly going to pull the product from the shelves. They are not going to sort through pallets of product.
4. Improve checking procedures. During busy periods inspections might consist of just a quick visual check. It’s a good idea to replace complex forms with a procedure which requires the checker to sign the pack and circle all the points that were checked, including name, date/lot code etc. In fact, this simple approach could prevent the majority of food recalls experienced today.
5. Develop proactive controls to support visual and mechanical inspections. Another common cause of recalls relates to foreign bodies such as glass, metal and plastic or rubber materials which often come from machinery or the processing environment. Glass audits are very common at manufacturing sites, however they will only identify breakages retrospectively, with no way of accurately identifying the time of the breakage or the product which was being manufactured at that time. Auditors will often note that companies have identified breakages during the inspection, however it is uncommon to see any action taken on identifying potentially compromised product. The breakage itself is attended to, but investigations are often very cursory. This is not good enough.
6. Use detection equipment correctly. It’s always a good idea to get advice from the experts. This is not the same as using testing in accord with what “the man from the metal detector company” suggested. Companies must properly validate their metal detection process and understand the idiosyncrasies and limitations of their machines. Damaged machines and nuts and bolts from equipment can result in a recall that is disproportionate to the true risk to consumers, but the retailers will, quite correctly from their own brand protection point of view, insist that the product is removed from shelves. Proper maintenance and inspection, not just for cleanliness but to ensure all parts are replaced after work has been carried out, will significantly reduce this risk.
In reality, food recalls should be easily prevented but prevention requires companies to have a philosophy which revolves around “prevention is better than cure.” An overly complicated food safety management system, driven by form filling instead of active controls, will deliver a less reliable risk reduction strategy and this is in no-one’s interest.
About the Author
Gordon Hayburn is Vice President of Food Safety and Quality at Trophy Foods. He is a highly qualified and experienced professional with a reputation as a subject matter expert in the areas of food safety, food law and food science/technology and he has an extensive knowledge of current international regulations to ensure full compliance across all areas of operation.