This month’s column underscores the fact that identifying, analyzing, and understanding the risks associated with producing safely packaged foods is a daunting task. It’s best to approach this task with the assumption that what you don’t know or don’t control will eventually hurt customers, your company and you!
Last month’s column, 3 examples of aligning food safety risk and packaging safety, provided examples of food packaging safety risks and explained why stakeholders and end users are driven to maintain supply chain safety . This month we begin to focus on risk identification and prioritization. Identifying, analyzing, and understanding risk can be a daunting task. I suggest beginning with the basics: Assume that what you don’t know and/or don’t control will eventually hurt you! Let’s continue our checklist:
Risk assessment, priority and control #1A: Incoming materials evaluation list
Whether you purchase raw materials, intermediate goods, or finished ready-to-ship products, the professionals in charge of regulatory affairs and food safety need to have a full understanding of and confidence that every item coming in the door of the facility and/or passing through external and contract facilities, is suitable for its intended purpose and safe for consumer use, as defined by law and best industry practices.
The best way to begin with this task is to create a process map for each facility and then list items that flow inside that facility, which may include equipment and supplies, vehicles, raw materials, intermediate materials, chemicals, lubricants, ingredients and people.
Technically speaking, every item has a risk of being contaminated, unsuitable or causing same. It is up to the risk assessor to identify each item and assess the type of risk (e.g. chemical, physical, biological, or all of the above), the extent of the risk (mild, moderate or serious risk to human safety) and the likelihood of occurrence if not controlled (low, medium or high). Each item on the list should be grouped by category, where used, stored, handled and processed. Once the list is complete, the risk assessor(s) can then determine what they know (and don’t know) and control (or not) regarding each item.
The principles for application of this process are very similar no matter the phase of the business you support: whether you are a manufacturer, shipper or end user of equipment, the principles apply. Some key questions may include, determining whether materials are compliant with food regulations, customer’s specifications and procurement contract stipulations, and identifying and mitigating risks. The equipment design, materials, packaging, lubricants, protective materials and related all need to be assessed as the equipment is fabricated, acceptance tested, shipped, received, intaken, sanitized, installed and tested in or near food or food materials production facilities.
Once a satisfactory form is created to perform the “end-to-end” risk analysis of each item, it will become more of a checklist formality and less of an interpretive exercise.
In Part 2 of this column that will be available next week, we’ll assess Risk Assessment, Priority and Control for Incoming Materials Risk Mitigation and for Incoming Materials Documentation and Testing.
Gary Kestenbaum has 40 years’ experience in the food and packaging industries, six as a supplier with National Starch, 18 as a product developer with General/Kraft Foods and 15 as a packaging engineer and developer with Kraft. In his current position as Senior Food Packaging Safety Consultant with EHA Consulting Group, Kestenbaum provides guidance on packaging safety and suitability-related projects for raw material manufacturers, converters and associated supporting professionals. He can be reached at [email protected] or 410-484-9133. The website is www.ehagroup.com.