In 2013, the FDA introduced new standards to ensure the public health of perishable food products that are being shipped, tracked and delivered. While the end result improves public safety and health, these standards present challenges for food distributors to ensure they have FDA-compliant processes, plans and technologies in place to avoid product recalls and fines.
Under these standards, the FDA can invoke a mandatory recall on a distributor’s product, and restrict the company from distributing if it isn’t following the regulatory guidelines. The FDA has the authority to request manufacturing, processing, packing and distribution records at any time. It is critical, therefore, that food distributors implement a comprehensive, written food safety plan that includes documentation of product shipping information, sanitation guidelines and the steps to follow in case a recall were to occur.
This article identifies the items that need to be part of a written food safety plan, and provides the resources food companies need to ensure compliance with food safety regulations.
Traceability and Lot Tracking
Food companies need to have complete visibility and control into the goods it is receiving, shipping, and storing — this includes knowledge into inventory management, product/service layout, staff, bins and purchasing. As products are delivered, automated systems should match specific items to purchase orders to verify that correct products are being received. As part of this, employees need to enter lot information and shelf life dates at this point in the process to ensure that items are not used in production or shipped to a customer until it’s passed the required quality tests.
Lot tracking helps food companies locate raw ingredients that distributors use in production, and ensures the quality of finished products that will be delivered to customers. Implementation of a Warehouse Management System (WMS), for example, allows distributors to ensure the accuracy of lot tracking and the organization of product services including receiving, inventory management and product/service layout.
The documentation of sanitation procedures and food allergen controls is an important component to a food safety plan. In addition to maintaining clean food processing equipment, food production facilities must document the processes and schedules of equipment cleaning and sanitation. Cross contamination is the most common sanitation issue and can occur when products come into contact with unsanitary equipment, contamination from the environment and the mixture of pasteurized and raw materials.
Distributors must also be cognizant of international products that are purchased and received, and subsequently delivered to their facilities. Not only is the FDA implementing product recall capabilities, but it also closely monitors the quality of products delivered from abroad into the U.S. Distributors should ensure that the retailers from which they order have obtained a Safe Quality Food (SQF) certification. SQF certifications ensure the safety and quality of products being obtained, and are recognized globally as a consistent and trustworthy program.
A distributor’s written food safety plan should include a detailed recall strategy, in the event a recall occurs. For the sake of public health, it is vital that distributors have the ability to remove items from the market as quickly as possible. Proactively planning for a hypothetical recall reduces a distributor’s liabilities, while a non-existent program could have serious and expensive consequences.
Recall plans can be broken down into a number of different steps, and can be integrated into other parts of an organization’s food safety plan. These recall strategy steps should incorporate everything from the team that will be at the forefront of a potential recall — to traceability documentation of items involved, to shipping and receiving records. Total product recalls can be detrimental to a distributor’s business, and depending on the size of the company, the experience can either serve as a valuable learning experience or total, company-wide shutdown.
Written food safety plans are essential to operational success and help avoid product recalls for companies. While the FDA is cracking down on food safety regulations, this is an opportunity for distributors to discover the technologies and processes that help in the tracking and documentation of food safety.
Don’t risk a product recall or facility shutdown. Take a step back and determine the products that are going in and out of your warehouse, and the implications they have on public safety. A well devised, written plan can help with that.
About Ira Dannenberg, Vice President of R&D — Food Division
As Vice President of R&D — Food Division, Dannenberg is responsible for all development and updates to the VAI Food Package. Dannenberg heads a team of programmers who deploy food industry customer implementations, from initial surveys and business studies, to the installation of the software and subsequent follow-up as needed.
It is critical for food distributors to implement a comprehensive, written food safety plan that includes documentation of product shipping information, sanitation guidelines and the steps to follow in the event that a recall takes place.