We know that everyone is blogging about FSMA — For example “Preventive Measures for Human Foods” has been discussed in many different forums.
I do not think that this regulation really brings anything new to the industry as far as food safety processes are concerned. Basically food companies should have been doing these “incremental” elements before.
The interesting thing about this specific regulation is that the food safety program should be performance based e.g. number of deviations per CCP/PRP and are they being reduced, reduction in Recall events, reduction in Held Stock, reduction in Rework, and reduction in food safety related customer complaints. How is performance actually being measured? Is there visibility to the actual metric data? Can the performance data be easily extracted to determine whether or not the program is getting better or worse?
As far as customer complaints, how would an auditor know if the complaint information is being used to reassess the food safety program? Would the auditor review the performance tracking procedure, monthly reports, corrective action plans, the revision history of the food safety program or potentially the retesting of finished goods based upon the new program requirements?
Would the auditor be allowed to see/review the customer complaints? Customer Complaints are extremely confidential information to the majority of food processing companies. An interesting question to ask would be “What is my root cause, corrective action, and closure percentage for food safety complaints? What products or product group has the highest incidence of food safety complaints?
Visibility of complaint information to public could open up the company to governmental audits or customer legal action. But this visibility also will trigger enhancements in food safety program either through staffing or equipment. Would make the cost benefit question much easier to answer for food companies.
For example, the universal usage of on line x ray equipment to detect and reject product with foreign material and then the usage of the rejection data to enhance food safety programs would significantly reduce the incidence of physical hazards. A one week trial with a X Ray unit on line could be an eye opening experience. X ray units are widely used by the baby food industry especially to detect glass from the containers.
Or more thought, could go into the investigation of chemical hazards — product tastes “funny” or like a “chemical” type of complaints. The issue with chemical type complaints is what do you test for and how do you pay for it? Would you do organoleptic checks? “Does that smell funny to you?” What chemicals would you put in a specification? Could you afford to test for a vast listing of chemicals on every product. Auditing against the controlled chemical listing in your factory and GMP adherence helps, but what about your 1000 suppliers and the trucks that the product is delivered in — how much rigor is in your process?
Honestly, we could go on all day with the one more thought but food safety improvement is all about knowledge, execution and management support.
What do you think?