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Evaluating the Safety of Your Food Ingredient Supplier With New FDA Regulations in Mind

Wed, 02/11/2004 - 6:08am
James P. Hyland, Director of Environmental, Safety, & Health, Astaris LLC
** Click here to view the Feature in pdf format.**

Pending enforcement of new FDA food safety regulations has created new opportunities for food manufacturers to differentiate themselves from the competition. Those who can respond proactively rather than reactively to safety requirements can eclipse the competition in terms of efficiency, quality and brand integrity.

End products are only as safe as the ingredients from which they are made, so food manufacturers are increasingly turning their attention to the security practices of ingredient suppliers. In order to support brand security, it is critical that food manufacturers qualify the safety and security of commonly used ingredients. This can reduce contamination risks, simplify traceability, and increase confidence in the safety of their products.

 

What to Look for in Site Security From Your Food Ingredient Supplier

Effective site security at a food manufacturing plant ensures that anything entering and exiting the plant is safe. Food manufacturers should inquire with ingredient suppliers about their approach to strengthening areas of vulnerability, based on FDA's Guidance for Industry document.

 

Perimeter controls

Effective perimeter controls include the use of fencing or other appropriate perimeter deterrents. Food ingredient suppliers should minimize the number of entrances while maintaining safety standards for ingress and egress. Suppliers should also keep careful tabs on all access to the establishment, both by individuals and vehicles. Routine physical checks of perimeter controls by security personnel are also recommended.

 

Secure water supplies

Food ingredient suppliers should be able to confirm that their water sources are protected, including municipal systems, wells, and hydrants, and water storage and handling facilities. They should also be able to verify that their systems are equipped with internal backflow protection and other precautions to maintain the integrity of the water supply used for processing.

 

Secured facility entrances and exits

Locks, alarms, intrusion detection sensors, guards, and/or monitored video surveillance should be used by food ingredient suppliers to secure all possible entrances, including gates, doors, freight loading doors, windows, roof openings, hatches and vent openings.

 

Identification & access procedures

Suppliers can increase the safety of their facility by using positive identification and recognition systems, such as issuing photo ID badges with individual control numbers that are color coded by area of authorized access. Terminated employees, whether voluntarily or involuntarily, can be a source of risk. Therefore, identification badges should be collected immediately upon termination.

In addition to limiting employee access to areas necessary to their job function, ingredient suppliers should consider the use of other means, such as key cards or cipher locks to access restricted areas. The use of color-coded uniforms may be helpful in distinguishing those allowed to access sensitive areas. Key cards and cipher lock codes should be collected from terminated employees.

Employers can also consider preventing employees from bringing personal items into food handling areas as another way to minimize risks. Suppliers may also choose to establish policies for regular inspection of employee lockers, bags and vehicles when on company property.

 

Computer systems

Just as restricting access to certain areas of the facility is critical to ensuring good security, so is limiting access to computer process control systems and critical data systems. Passwords, firewalls and other security mechanisms provide the best protection against data system threats.

The ability to trace computer transactions is also critical to uncover the source of a threat. Suppliers should have adequate data back up systems to ensure product traceability in the event of sabotage.

 

What to Look for in In-Transit Security from Your Ingredient Supplier

To counter today's security threats, ingredient suppliers should establish an effective policy on sealing product transportation containers by using security-assurance seals on all direct truckload and bulk shipments to provide evidence of the security of the shipment. This system of security-assurance seals should apply not only to products bound for food manufacturers, but also to in-process materials being transported to warehouses and tollers.

The ingredient supplier needs to record seal numbers so food manufacturers, warehouses and tollers can verify/validate product integrity. Seals properly placed and recorded will reveal unauthorized access. If seal information is missing or inaccurate, food manufacturers should reject the delivery. Such sealing policies coincide with FDA's current views on appropriate measures that can be taken by food establishments to minimize the risks of tampering while products are in transit. Food manufacturers must also be careful to reconcile both printed lot code details, and the amount of product received with the amount ordered and listed on invoice and shipping documents.

In order for an in-transit security program to be effective, seals must be affixed to every opening into the container that can provide direct access to products.

If a seal is broken for legitimate reasons, such as a border crossing or weigh station, it is incumbent upon the food ingredient carrier to record the time, date, location, and reason for removal. The carrier is also responsible for resealing the vessel as soon as possible with a new seal number and recording the time, date and location of resealment.

Just as ingredient suppliers should ensure the use of registered seals on all deliveries, food manufacturers should reciprocate by resealing all returning vehicles and shipment containers to prevent tampering, or show evidence of it, while in transit in an empty state back to the supplier. Likewise, seal numbers should be documented on return paper work.

A currently unresolved issue involves appropriate security for less-than-truckload shipments of food ingredients to distributors and other customers. The applicable trade associations are actively evaluating this security issue. An acceptable means of ensuring safe material will be very important to both the food ingredient suppliers and the food manufacturers.

 

Question Your Supplier About Training

Watchful, trustworthy, and satisfied employees are a supplier's best line of defense against sabotage. Effective training programs can help nurture these qualities in employees, and teach them how to recognize suspicious behavior or occurrences.

To that end, supplier training programs should instruct employees on how to prevent, detect, and respond to tampering, criminal, or terrorist activity. Changes in packaging or processes can be a signal to employees to ask questions. Employees should be trained to recognize any unusual behavior by colleagues, and to report any questionable activity to their supervisor or security personnel. Part of a thorough assessment could include asking the supplier management about their training procedures, as well as assessing the attitudes of the site personnel regarding security.

 

How Complete are Your Food Ingredient Supplier's Records?

Although food ingredient suppliers will soon be required to create and maintain records of their raw material sources and of the direct recipients of their products, the detail and efficiency used by each supplier may be a source of differentiation. A supplier that has written record-keeping practices into its International Organization for Standardization (ISO) plan, and has been certified accordingly, should be able to respond quickly to FDA and food manufacturers' requests for documentation. Suppliers can also demonstrate this preparedness through routine external audits by their customers, or by other trade organizations, such as that offered by the National Food Processing Association (NFPA). Suppliers can also engage in internal audits to confirm the efficacy of their record-keeping capabilities.

 

Adapting to FDA's New Bioterrorism Legislation

The purpose of FDA's new bioterrorism legislation is to increase the safety of our nation's food supply. One stipulation that has the potential to change the landscape of the food and food ingredient import market is Sec. 307 of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002. This regulation requires that FDA be notified two to eight hours before the day the imported food will arrive at the U.S. border crossing or at the port of entry, depending on the mode of transportation. U.S. ingredient suppliers and food manufacturers should consider establishing back up domestic suppliers for critical ingredients in the event that imports are detained.

 

Recall Strategies

While FDA's Guidance for Industry document outlines numerous measures that food establishments can take to minimize food safety risks, suppliers can institute additional safety practices to augment those of FDA. The practice of staging mock recalls is an excellent example of how a supplier can be proactive about their recall strategy. By staging mock recalls, suppliers can ensure the preparedness of the person who will lead the recall, as well as the person assigned as a back up. Mock recalls also give suppliers the opportunity to make sure that customer contact lists are up-to-date, while providing real world experience in the disposal of recalled products.

Although FDA advises food businesses to establish procedures for dealing with recalls, it does not specify staging of mock recalls. This practice transcends typical procedures to ensure an effective and expedient recall in the event that one is needed.

 

Who's Supplying Your Supplier?

Your suppliers' products are only as safe as the source compounds that are supplied to them. It is important to know the procedures that your ingredient supplier is requesting of their supplier. Their shipping specifications should not only include measures to ensure the safety of deliveries to food manufacturers, but also deliveries to their own facilities.

 

Security as a Competitive Differentiator

Responsible food ingredient suppliers have always had good safety/security programs and are taking this opportunity to further enhance those programs to support the integrity of their products and the products of their customers, the food manufacturers. It is critical that all food ingredient suppliers provide at least the minimum safety/security required by the new regulations and existing guidelines for food safety. Food Manufacturers should assess the safety/security of its ingredient suppliers in determining which suppliers they want to use as an integral part of their overall safety and security program for their products.

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