Depending on the context of the discussion, reference to “grain quality” can allude to a number of diverse attributes. From moisture content to density, the variables dictating the perception of quality typically hinge on the specifications outlined in a customer contract and, ultimately, how the commodity will be consumed. Aside from the physical and intrinsic grain characteristics, quality in terms of sanitation is expected to meet the standards outlined by the U.S. government. Increased scrutiny of the processes and quality of commodities entering the food supply has taken center stage under the Food Safety Modernization Act (FSMA).
FSMA mandates all companies up and down the food supply chain adopt a proactive, preventive approach to food safety by outlining intervention strategies against potential foodborne contamination. Feed mills and grain elevators are especially affected by FSMA legislation because they provide foodstuffs for both human and animal consumption.
“Grain handlers are part of the food system,” asserts Dr. Charles Hurburgh, professor with Iowa State University’s Department of Agricultural and Biosystems Engineering. “This is a new concept in the bulk commodity world because, traditionally, most wouldn’t think they would be part of the food safety world.”
Dr. Angela Shaw, assistant professor of food science and human nutrition, Iowa State University, explains the implications of FSMA are assumed to be wide reaching: “Every company in the food chain is required to do a better job assessing where incidents may occur, preventing the occurrence and establishing mechanisms to respond should an outbreak take place.”
While the final version of the law has yet to be released, the industry is expected to have these preventive controls in place by July. Facilities must register with the Food and Drug Administration (FDA), the agency that will be heading up site inspections and enforcing the law, as a food facility every other year starting in 2012.
“Companies must be registered if they are to participate in the food system — all processors including ethanol — have to register,” Hurburgh explains. “And if you’ve registered before, you have to reregister to validate your registration. Registration will act as the gatekeeper the FDA uses to say whether you can or cannot be in business because of safety issues. If the FDA suspends your registration, you can’t operate.”
The FSMA requires every registered U.S. food facility to create a food safety program outlining the hazards and the preventive controls used to mitigate the risk of foodborne contamination.
According to the FDA’s Access Data site, the status of FSMA Section 103(a), Hazard Analysis and Risk-Based Preventive Controls, is waiting on an FDA and USDA report of the food processing sector and information on foodborne illness to be submitted to Congress on July 3, 2012: “The study will provide information to be used in making decisions about the application of the preventive controls regulations to small businesses so that public health is still protected.”
Since the law is unlikely to change little if at all — and its expectations are clearly stated — companies are advised to get ahead of complying with Section 103 by developing a Food Safety Plan.
Creating a Food Safety Plan
If your company has yet to develop a Food Safety Plan, Iowa State University–Extension and Outreach has developed a guideline to aid grain facilities in the process. Guided by the belief that the goals of a regulatory agency and industry must align to successfully foster a food safety culture, Iowa State University reached out to the FDA to develop a checklist of critical control points that need to be addressed by a food safety plan. Headed by Shaw and Connie Hardy, program specialist with the Iowa State University Extension Value-added Agriculture Program, the “Risk-Based Food Safety Plan Checklist for Grain Facilities” is an effort to establish uniformity across the industry regarding the new regulations.