Preventive Controls for Food Safety Recall Triggers
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Food Manufactures and consumers suffer from recalls on a regular basis. Recalls can be prevented or minimized by identifying recall triggers and by implementing food safety protocols.
The preventive control (PC) approach considers recall triggers to be those high-risk hazards which require preventive measures. They can be biological, chemical, physical or economically motivated hazards. Based on the type of hazard, different PCs may be required.
To detect and apply proper management for hazards requiring PCs, a detailed hazard analysis and risk assessment must be applied. Each necessary PC detected through hazard analysis must be managed through monitoring, corrective action/correction, verification and record keeping. The four main preventive controls to prevent recall triggers are Process PC, Sanitation PC, Allergen PC and Supplier PC.
Process Preventive Controls
We can consider Process PCs as Critical Control Points or CCPs from the HACCP approach, where a process step or a procedure is utilized to control a hazard requiring a PC. For example to control biological hazards, process steps such as heat treatments or refrigeration are used. Chemical hazards can be controlled through Formulation Process Controls, optical sorters for detecting mycotoxin and bar code scanners for allergen declaration accuracy. Whereas metal detectors and X-Ray scanners would be applicable for physical hazards.
Sanitation Preventive Controls
Sanitation PC can be compared to sanitation Good Manufacturing Practices or GMPs. GMPs are considered the foundation of any food safety plan. Under sanitation GMPs, all items in the plant must be listed on the sanitation schedule for regular cleaning with a specific frequency. Some of these items are considered high-risk sanitation points where extra focus is required to prevent recalls. This may be due to potential cross-contamination and/or allergen cross-contact issues. As an example, sanitation verification of a ladder would require a GMP approach, whereas sanitation verification of a shared packing table exposed to multiple allergens would require a Sanitation PC because of the greater vulnerability and potential for a recall.
There are three high-risk sanitation points that require extra assurance and would most likely require Sanitation PCs. 1- when RTE is exposed to the environment after the kill step and prior to packaging. 2- when there is a risk of cross-contamination between raw ingredients and processed products. 3-when allergen cleaning is needed prior to switching to allergen free or product containing different allergens.
Allergen Preventive Controls
Allergen PCs are required to prevent labelling errors and allergen cross-contact. For allergen labeling, we need to ensure the correct labeling is printed and applied. This requires the label to be printed according to the product formula and for the correct label to be applied to the matching product. To avoid cross-contact when multiple allergens are handled, the use of various prevention techniques such as scheduling, run sequencing, and the use of dedicated utensils are common. In cases where dedicated utensils or equipment are not possible, choosing Sanitation PC to clean shared utensils would be a more robust approach.
Supplier Preventive Controls
If during hazard analysis, we identify a high-risk hazard linked to an incoming ingredient that can only be controlled by the supplier, Supplier PC would be necessary. While all ingredients are approved and controlled under GMPs, a more consistent approach regarding high-risk ingredients should be applied as a Preventive Control. To verify supplier compliance, an on-site audit would be required especially when it comes to serious hazards.
A food safety point person should know these four main preventive controls and be able to apply consistent control measures around recall triggers. You will learn the underlying principles of a preventive controls approach and learn how to apply them effectively during the Live-Virtual PCQI course.
or more information please visit:
Sonia Akbarzadeh, MSc, Eng.
FIC Principal Food Safety Trainer
FSPCA Lead Instructor