On Jan. 4, President Barack Obama signed the Food Safety Modernization Act into law, requiring all facilities registered with the FDA under the Bioterrorism Act to develop a written food/feed safety plan that evaluates hazards and details procedures to control those hazards so they do not cause adulteration or misbranding of product.
The regulation applies to all commercial grain elevators, feed mills, feed ingredient manufacturers, grain processors, millers and exporters, as well as foreign facilities that ship agricultural products, feed and feed ingredients intended for consumption in the United States.
One way to ensure compliance with the law’s written food/feed safety plan requirement is to implement a HACCP (Hazard Analysis and Critical Control Point) plan. While the FSMA does not mandate facilities use HACCP, David Fairfield, director of feed services for the National Grain and Feed Association, says applying HACCP principles within a feed manufacturing setting provides an excellent opportunity to evaluate operations, identify potential hazards and eliminate or minimize those hazards.
HACCP was originally designed to replace finished product testing by entities such as Pillsbury Co. and the U.S. Government. The program was even put into place at NASA to ensure the safety of food for astronauts.
Developing a HACCP plan takes time, dedication from management and staff, and an acute understanding of all the raw materials and processes used at the facility. Breaking HACCP into “Preparation,” “The Seven Principles” and “Implementation” is an effective way to learn about the plan and determine how best to utilize the information in your facility.
As is the case with any new program launched in the workplace, there is preliminary work required before it can be implemented. Before starting a HACCP plan, these steps must be completed:
1. Choose a HACCP coordinator and team
In some cases, the best candidate for this important position is clear. A company may select a quality control manager, corporate food safety director or operations manager. But if a company determines its staff doesn’t have enough expertise, management can seek an outside specialist or consultants for additional help.
2. Provide HACCP team with education and training
If a company chooses to train its own employees rather than hire a consultant or other outside help, education is necessary.
“There is a variety of resources available,” says Keith Epperson, vice president of manufacturing and training, American Feed Industry Association. “There is a short course offered each spring and fall at Kansas State University that is co-sponsored by AFIA and NGFA, and the Northern Crop Institute holds its own HACCP training courses.”
NGFA also organizes a HACCP for the feed industry distance learning program, which is available to members at any time through its website.
3. Create and use process flow diagrams
A process flow diagram is a basic diagram that serves as a visual of how a product or a process flows from start to finish (Figure 1).
Fairfield, the instructor of the NGFA’s Model Feed Quality Assurance distance learning program, including its HACCP elements, says viewing a verbal picture of how a process flows, or how material flows through equipment, aids in identifying where potential hazards might be introduced.
Creating these documents is an integral step if utilizing HACCP is a company objective.
“Process flow diagrams are a fundamental HACCP requirement,” says Fairfield. “If you want to meet the criteria, you’ve got to create these process flow diagrams. They may, in some cases, be very specific, and very general in other cases. But it will help during the risk assessment step to identify where potential hazards may enter the scene.”
4. Develop prerequisite programs
According to Fairfield, this area can be a source of confusion for students in his HACCP training course. He clarifies that prerequisite programs are simply the written procedures and policies a firm has in place to meet regulatory requirements and ensure either the quality or the safety of the products they produce.