Due Diligence in Food Manufacturing
Food Manufacturers Must Maintain High Product Quality, And Prevent Litigation, Recalls and Customer Complaints
By Robert Rogers, senior advisor of food safety and regulations at Mettler-Toledo Product Inspection Group
In this day and age, it’s more important than ever for food manufacturers to ensure their products are safe, free from foreign material contamination and accurately labeled. Given our increasingly litigious culture, consumers can seize any opportunity to take legal action against a food processor if a product causes harm. Short of an expensive legal defense or recall associated with an unsafe or mislabeled product, even minor complaints can bring negative attention instantly and broadly via social media, causing serious damage to a brand’s reputation.
To minimize these risks, food manufacturers must maintain high product quality while also taking steps to prevent litigation, recalls and customer complaints. Thorough due diligence includes selecting suitable product inspection technology for the application, installing those systems at key points on the processing and/or packaging lines, maintaining proper operation of the systems and keeping necessary documentation. In this article, we’ll discuss ways to comply with food safety standards to protect consumers, partners and retailers as well as the food processor’s own brand and bottom line.
Food safety standards and requirements
There are many different food safety standards and requirements around the world. A food processor needs to consider the following to identify those that affect their business:
- Manufacturing location
- Export destinations
- Product type (e.g., cheese, meat, etc.) and package type
- To whom the product is being supplied (e.g., main street retailer, farmers’ market, etc.)
The Global Food Safety Initiative (GFSI) is a cornerstone for standards around the world. Launched in the year 2000 by a consortium of international retailers, today the GFSI reviews food safety standards and approves those that meet specific criteria. The foundation of all GFSI standards is based on Hazards Analysis Critical Control Points (HACCP) and Pre-Requisite Programs (PRP).
HACCP is a framework that identifies where hazards are most likely to occur and provides a structure to put procedures in place to monitor and control manufacturing processes to mitigate the risk of hazards. The organizations and bodies that provide GFSI-recognized schemes include the following:
- Brand Reputation Compliance Global Standard (BRCGS)
- Food Safety System Certification – FSSC 22000
- Safe Quality Food (SQF) Institute
Other GFSI-recognized schemes exist, but the three above comprise more than 90% of all adopted standards currently being worked.
In the U.S., the Food Safety Modernization Act (FSMA), which came into effect for most manufacturers in 2016 and continues to be developed, offers a food safety program based on Hazard Analysis Risk Based Preventative Controls (HARPC), instead of HACCP. Both HARPC and HACCP are focused on prevention but they differ considerably in execution. For example, unlike HACCP, HARPC includes planning for potential terrorist acts, intentional adulteration and food fraud, so a facility’s HARPC plan will include additional security such as visitor access and control.
It is worth noting that there are important distinctions between GFSI and FSMA. GFSI is a global standard, whereas FSMA is more U.S.-centric, focused on protecting the American consumer. Also, GFSI has more guidance-based documents and adopts a broad scope, while FSMA is a law.
Other food safety frameworks come from the International Featured Standards (IFS), the People’s Republic of China (PRC) Food Safety Law (2015), the Food Safety and Standards Act (FSS) 2006 India, the International Retailer Codes of Conduct, precision weighing from the Measuring Instruments Directive (MID) and a variety of nutrition labeling regulations, among others.
The risk of metal inadvertently finding its way into a food product is relatively high, since most food processing machines are made of metal and can easily shed a small piece whether the
machine fails or not. Other contaminants such as glass, plastic, rubber, bone and stone can also be present in food processing lines, perhaps from being scooped up by harvesting equipment prior to raw receiving or accidently introduced by line operators during the manufacturing process. Risks associated with other aspects of the product, such as incorrect product weight, fill level, labeling and the integrity of tamper-evident seals, can also be controlled to maintain the ideal product quality.
Due diligence with product inspection
To comply with any GFSI-recognized set of standards, food processors must integrate some form of contamination detection, which usually means installing metal detectors and/or x-ray inspection systems to detect and reject products containing foreign material contaminants from the production line. Other quality control technologies can help achieve compliance with other regulations such as the Measuring Instruments Directive (MID).
Product inspection technologies operating correctly and located at suitable Critical Control Points (CCPs) on processing and packaging lines help maintain high product quality. Adding real-time monitoring and record keeping of inspection activities helps prove that due diligence has been carried out.
Product inspection technologies
Metal detectors find metal contaminants such as ferrous, non-ferrous and stainless steel in bulk, free-flowing, pumped or packaged products. Metal detectors are often installed near the front of the line to inspect incoming product, at various in-process control points and near the end of the line after packages are sealed to inspect final product quality.
X-ray inspection systems detect differences in density to find a wide range of contaminants including glass shards, metal fragments, stone, bone, rubber, dense plastics and more in bulk, free-flowing or packaged products. X-ray systems can also perform a range of other in-line product and package checks such as counting components, verifying mass measurements, fill levels and seal inspection.
Checkweighers dynamically weigh every package on the line at high speeds to detect under- and overfilled products. Controlling under-fills helps food processors achieve compliance, and controlling over-fills helps reduce product giveaway. And data collected by a checkweigher can be used to calibrate the filler to improve yields.
Vision inspection equipment can verify label contents as well as packaging and label defects. By replacing less-effective random spot checks with a high speed, in-line vision inspection system, processors can find torn labels, ink smudging and non-readable codes while verifying allergen information is accurate and the correct labels are on the packages.
Combination systems perform multiple inspections such checkweighing combined with metal detection, X-ray, and/or vision inspection. The idea is to save floorspace while complying with multiple food safety and quality regulations within one system.
Any of these inspection systems can be equipped with a reject device to automatically remove contamination or an out-of-tolerance product or package from the production line. For even more security, processors can add reject confirmation software, a tunnel guard from the detector past the reject device and a lockable, password-controlled reject bin. Password protecting the inspection system ensures equipment settings are not incorrectly adjusted to help maintain proper operation.
Data management software can augment inspection systems to monitor all activities such as testing in real-time while documenting the information for later retrieval. Because test results cannot be falsified or altered without leaving evidence, data management software provides evidence for due diligence.
About the Author
Robert Rogers is the Senior Adviser of Food Safety and Regulations at Mettler-Toledo Product Inspection. Learn more at www.mt.com/pi.