In January, FDA published the first of the Food Safety Modernization Act (FSMA) proposed rules, including those on Preventive Controls (FSMA Section 103) and Standards for Produce Safety (Section 105). Both are expected to significantly impact the industry and elicit a great deal of feedback during the comment periods. In this issue’s Legislative Update (pg. 12), Dr. David Acheson, formerly of the FDA, discusses the two proposed rules in detail, and provides an overview of the key points of the rules, which is included on page 14.
Preventive food safety is, in fact, a core focus of FSMA, with verification and documentation as key components. Throughout the year, we will continue to bring you related news, updates, analyses, and expert recommendations on the rules as they roll out. Additionally, as in the following articles and those throughout the issue, we will continue to feature general ideas for preventive food safety that you can apply in your facility today.
In these articles, the preventive focus is on sanitation management and controlling cross contamination in areas that may not always be top of mind.
A key component of preventive controls is protecting against cross contamination, particularly in relation to separation of raw, processed, and finished product; allergenic and non-allergenic foods; or even simply between food and sanitation chemicals or waste.
This is important because, as explained by Michelle Williams, Remco Products marketing specialist, “Pathogens and allergens are easily transported in and on any person or piece of equipment in an area where these substances are present, unless properly cleaned and sanitized. The presence of a tool that has come in contact with raw food could potentially contaminate the processed area with a biological pathogen, essentially negating all other efforts to control the pathogen to that critical point.”
One way of ensuring such separation is by utilizing color to distinguish between areas, tools used in specific areas or food-specific processes, and even worker authorization in separate areas. As Mark Clute, quality control manager for Turtle Mountain natural foods, writes in Food Industry Quality Control Systems, “Color coding of the containers or tools used for these materials provides immediate feedback that a potential contamination situation might be happening.”
Clute defines this as part of a loose-materials program, which is developed by the company first identifying the needed areas for separation. “These should be evaluated based on possible cross contamination from physical, chemical, microbial, and allergen viewpoints,” Clute said. Once identified, colors are assigned to the designated areas, and tools and containers should be replaced to fit the color scheme.
Many companies do use at least some color-coded tools, with the primary purpose being sanitation controls, such as differentiating between raw meats and fresh produce, said Laura Wissman, director of marketing and sales for The Safety Knife Company. “The ultimate goal for having color coding is using the tools in different parts of the plant for sanitary purposes.”
Color coding also is beneficial because it is universally understood, even if a language barrier exists, Williams said. “It assists in preventing cross contamination between critical control points for allergens, biological pathogens, and any other material or substance in a plant that needs to be segregated. By having a designated set of tools for each critical zone in a food processing setup, plant staff can mitigate the risk of transferring allergens and pathogens to controlled areas.”
The use of color-coded tools can also help with inventory control, Wissman said. Including metal-detectable properties in the tools helps to ensure detection should a tool itself, or part thereof, accidentally get into product, and its color can help trace it back to the source.
Another emerging use of color coding is the separation of cleaning and sanitizing chemicals to prevent the undesirable chemical reactions and help workers understand if a certain chemical is not to be used in a specific zone or on certain equipment, Williams said.
Many in the industry would like to see an industry standard for color coding, such as Bobby Love, director of global quality assurance for Phillips Foods, who said, “I had hoped that industry or academia would suggest a color assignment chart for allergen color coding for the food industry as a whole, but a proprietary program can still suit the needs of an individual processor, as long as it is consistent.” (Supply Chain Management, QA Nov/Dec 2012)
Although there is no such standard, black has received some universal acceptance for floor and drain areas, Williams said, adding that other common color designations are red in raw or unprocessed areas, and blue or green in processed areas.
Once colors are designated, signs should be posted in conspicuous places where employees can refer to them during daily operations, and employees should be trained, Clute said, explaining that due to the potentially devastating effects of cross contamination, “every employee should be trained in what the color-coding scheme is, how it is implemented in the plant, and the potential consequences of not following it.”
Although his book was published in 2009, well before the passage of FSMA, Clute notes written documentation as the final, and an important, step in the program. This includes the documentation of each employee’s training, a copy of which is kept in the employee’s file, as well as a program document, which, he said, “should be signed and placed in the Quality Control Manual with a copy of the training verification and color scheme.”