Manufacturing and selling food to the masses is serious business. Its all fun and game to think about the media attention the fame and glory at the trade shows and the fun times but are you thinking about your food safety plan and the processes you must have in place in order to comply with FDA regulations? Big co-packers do, smaller start up companies often forget about these pesky details!
Every year 48 million (1 in 6) people get sick, 128,000 are hospitalized and 3,000 die. Our food supply system has become quite complex with ingredients and major food components being imported from all over the world. Even if you have a handle on your own food safety procedures, do you know what all your suppliers are up to? Have you visited their plants in China and Germany or wherever else your supply comes from? Just because your ingredient came from a broker here in the USA, doesn’t mean that the food came from here.
The Food Safety Modernization Act (FSMA) are the new FDA rules for food safety. It was signed into law on Jan 4 2011 and the goal is to protect our public health by strengthening our food safety system. Scientifically based standards must be implemented from farm to table to fork to mouth! Everyone is and will be impacted by the act- from farmers to importers, to foreign countries to start up food companies making energy bars out of a commercial kitchen in the east bay! No one is immune to bacteria!
The major components of FSMA are similar to your company HACCP Plan (do you have one of those—if not, you should!) Every food establishment should evaluate the hazards in their system, figure out how they will control it and prevent it, how they will monitor it, correct errors, verify those corrections and of course keep track of it all. All food making facilities should have – at the bare minimum- a sanitation program, a training process for employees, GMP (good manufacturing practices) in place, a allergen program, a recall emergency plan and a supplier verification program. This includes commercial kitchens that are being used to make retail products.
The FDA is going to start cracking down—as they should! There will be more plant inspections and if anything in your facility is amiss, the FDA can now issue a mandatory recall (in the past it was all voluntary- now the FDA can force you to shut down) There will be more heavy monitoring at the borders to ensure that imported foods coming into the US are following their own similar safety plans.
The FDA is doing what they can to assist but you, the food maker, cannot rely on their program alone. Food makers have to have their own strict plans in place, it is your responsibility to ensure that you are well versed in all regulations and are following them.
How can you learn more about these regulations? You can start off by reading the FDA code of federal regulations. Its available for free and on-line ! You can specifically read about the FSM Act You can sign up for HACCP certification courses all over the U.S.
Private label co packers often have teams of food safety staff ensuring that all regulations are being followed. If you choose to work with a co packer don’t be shy about asking to see their HACCP plan and pre requisite programs. While the co packer holds the ultimate liability on the safety of your product, you still own the reputation. Do you want to be on the 6 PM news as the latest company to have killed 23 people in the Midwest?!
If you choose to make the food yourself via a commercial kitchen then you own the liability. Before you being to produce and sell make sure you speak with the health department about the specific safety concerns related to your product and understand all the requirements on managing that safety. Even if you are not meat or juice, you should still learn HACCP and set up a plan in your kitchen. HACCP is a great way to get a handle on your food safety process.
Taking SAFESERVE, the 30 minute online course- is not enough to ensure you are producing safe food. The day long classes that reenforce hand washing is also not enough. And knowing that TDZ (temperature danger zone) is also not enough. You need allergen programs, recall programs and a way to monitor your safety plan. Supplier verification does not mean knowing which stall you bought your kale from last week- it means knowing where that farm is, visiting it and knowing they are not washing it in dirty dish water.
Food safety is a shared responsibility. You, the FDA and your co packer.
See, making food ain’t so simple after all–!!
I would like to thank the city of Hayward, CA for proving a free workshop last week on FSMA. The speaker Nikoo Arashteh did a great job of summarizing the latest information. You can learn more about her services via linked in https://www.linkedin.com/pub/nikoo-arasteh/3/ba0/2b0 The seminar inspired me to write this piece and I have used information directly from the presentation!
Seminar Here http://yournextep.com/presentations.a5w
For more musings on food safety, food science, development and research chefs check out my website The Intrepid Culinologist