Food Safety & Foodborne Illness Expert Article
Contamination of food products with bacteria, such as Salmonella, Escherichia coli, Listeria, or other germs is known to be a cause of public outbreaks of illness with potentially severe consequences for children, the elderly, and immune-compromised individuals. Nearly all food for human consumption is processed in some way, from pre-packaged meals to meat and produce. This article discusses safety management systems for food processing facilities as they relate to litigation and insurance claims.
What regulations and requirements are there for food processing?
A food processing facility should know to have a robust Food Safety Plan in place to address the safety of food products made at the facility. The Food Safety Plan for each individual facility should be specifically designed to address all potential hazards associated with every facet of production. This Food Safety Plan includes suppliers, processors, sanitation, and many other factors that impact the safety of the food products.
For the processing of food, the benchmark food safety management system used in the food industry is known as HACCP (Hazard Analysis and Critical Control Points). HACCP is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.
When a particular facility develops its HACCP Plan, that plan needs to be tailored to encompass the hazards associated with the processing of the types(s) of foods processed at the facility. A thorough Hazard Analysis (HA) must be completed to identify the specific food safety hazards inherent to the products processed at the facility.
Once these hazards are identified, then points in the process are established where it is possible to control, mitigate, or prevent the associated risk(s) of exposure to these identified hazards. These are known as Critical Control Points (CCP). At these points, limits or targets are established, which are known as Critical Control Limits. Examples of these types of limits include, but are not limited to:
- Time
- Temperatures
- Microbiological testing results
- Equipment settings for food safety devices
HACCP is part of a Food Safety Plan that also addresses potential hazards imposed by suppliers, sanitation practices, or any other factors that could impact food safety.
All food products processed in the United States are regulated by the FDA (Food and Drug Administration) and/or the USDA (United States Department of Agriculture). Generally, meat and poultry are regulated by the USDA, and all other food categories are regulated by the FDA. Food Safety Plans, including HACCP systems, are mandated by regulations that are issued by both agencies.
Components of a Food Safety Plan
In addition to the HACCP Plan, and depending upon the hazards that have been identified at a facility, a food safety plan, or program could include, but is not limited to the following:
Presence and Effectiveness of Microbiological Environmental Monitoring Program (EMP)
The role of an EMP in a food facility is to provide the guidelines necessary for monitoring for the presence of microbiological organisms such as bacteria (and other pathogens), within the environment of the facility. The purpose of the EMP can be preventive in that it outlines the processes for detecting the presence of a pathogen before product contamination occurs. This also includes determining sanitation program effectiveness.
In a food safety case, one of many aspects a Food Safety expert would analyze includes how an EMP program is written and whether it is being implemented effectively.
- Other questions include whether there is ongoing monitoring of the program by the facility management in charge of food safety.
- Is documentation provided and is it consistent with industry guidelines?
- Are corrective actions identified when deficiencies are found?
- How are the corrective actions documented, and does the documentation conform to guidelines and standards of care?
Employee Guidelines for Personal and Food Facilities Hygiene
- Are there written guidelines within the facility regarding proper employee hygiene for food facilities?
- Are proper handwashing techniques being followed? How is this documented?
- Is there a standard for employee and clothing cleanliness?
- Is there a sanitary footwear program in place or use of footbaths containing sanitation chemicals with routinely monitored chemical concentrations and replenishment?
- Is there ongoing monitoring by facility management to ensure that these guidelines are being followed? Is there documentation that this monitoring is occurring?
Written Sanitation Programs
The monitoring of sanitation program effectiveness is tied directly to the EMP discussed above.
- Is there a written, effective sanitation program in place for the facility that is appropriate for the type of microbiological hazards inherent to the types of products being processed at the facility in any given area?
- Is the program effectiveness being monitored?
- Is the program effectiveness and any corrective actions documented?
Importation of Food Products
If a food facility imports ingredients or products from other countries, they must have an effective Foreign Supplier Verification Program (FSVP) in place.
- Is the FSVP sufficient to identify the hazards unique to the foreign country?
- What safety protocols are in place to ensure the safety of food they are using that has been manufactured outside of the United States?
- Is the documentation of these processes up to industry standards?
Foodborne Illness
Expert Witness Investigations
Food Safety experts at Robson Forensic routinely analyze case data to determine whether written Food Safety Plans and HACCP programs are appropriate for the hazards associated with the product from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product in the case. Experts would also verify that documented programs are being followed and monitored for effectiveness by regular “internal audit” programs. Such investigations also include whether the internal audit findings and associated corrective actions (if needed) took place in an efficient and expeditious manner. Finally, the analysis would also include assessing the presence of effective, regular employee training programs and the records documenting this training.
This approach enables our experts to determine whether the food safety program was reasonable and proper with respect to the anticipated hazards, and whether such programs were properly implemented by facility management to effectively mitigate or prevent these hazards.
For more information, submit an inquiry or call 800.813.6736.
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