Getting your plant ready for the proposed FDA Hazard and Risk-Based Preventative Control (HARPC) regulations as well as the FDA provision that aims to revise the current Good Manufacturing Practices (cGMPS) should be a priority for food processors. These two rules will bring food plant sanitation to a new level. Plants will have to develop written food safety plans, maintain strict documentation and implement controls to prevent dangerous processing conditions. Plants will have to prove, document and demonstrate their sanitation procedures.
While this will not be a cheap process for many plants, according to an article in Food Engineering Magazine, the FDA has estimated $1,000 to $25,000 depending on the facility; the process will hopefully change the economic burden and public health costs that come along with food sanitation issues such as food borne illnesses. The FDA hopes that eventually these rules will help save $2 billion dollars a year. The cost to plants will include effective employee training, spending to create and implement a food safety plan if one did not exist, auditing and monitoring food suppliers, and investments in equipment, documentation systems, and technology.
The article suggests five ways that plants can be proactive and by evaluating and developing sanitation controls that will get their plant FSMA (Food Safety Modernization Act) ready.
1.) Reset the mindset: Resetting the mindset at a corporate level by making the business case for food safety. They will see the cost associated with this, but must keep in mind that in the long run this may save them money.
2.) Lay a strong sanitation foundation: Conduct an extremely thorough hazard analysis of your plant. Identifying any hazards, no matter how small they will have a direct impact on your safety plan.
3.) Incorporate sanitary equipment and facility design principles: Hard to clean equipment may need to be replaced by new equipment and the flow inside of a plant may need to be considered. The cost of making these changes may be great, but will be effective in the long run.
4.) Make sanitation training a priority: While it is unclear how the proposed rules will specifically call for certifications and education, it is clear that the people who identify failures and contamination will need to ““provide a level of competency necessary for production of clean and safe food.” Food handlers and supervisors will also need training in technique and principles.
5.) No more lip service: Validate and Verify: Continuous monitoring of the system will be required. Validation that the system is working correctly will be required and will be code.
David Dixon, president, David C. Dixon, LLC says that facilities and equipment should be able to be cleaned to a microbiological level. He says, “FSMA does not directly address the concerns of the facility designer, the plant engineer or the equipment specifier. It does not direct you to take swabs of your condenser coils. It does not require you to repair your failing floor coating. It is up to the food processors to decide how best to achieve that,” Dixon continues. “Don’t wait to see what FSMA might eventually have to say about such specifics. Get started now. FMSA eventually will be the tool available to punish you if you do not.”
It is predicted that these new rules won’t go into effect for over a year so food processors should consider this and start preparing now. One area that should be examined is the safety flooring. SlipNOT® slip resistant flooring products are used in food processing plants throughout the world. SlipNOT® products test the same as untreated diamond plates for microbial and bacteriological testing, and are registered as a National Sanitation Foundation approved product for use in the food industry. The flooring can be incorporated into catwalks, drain covers, stair treads and crossovers among countless other customized applications.
Bricher, Julie Larson. “Top Five Ways to Get Your Plant Sanitation FSMA-Ready.” April 9, 2013. April 19, 2013. <http://www.foodengineeringmag.com/articles/90492-top-five-ways-to-get-your-plant-sanitation-fsma-ready>