There’s welcome news from packaging material converters that have received formal certification of HACCP-based food safety programs in their manufacturing facilities.
In previous columns, I have expressed disappointment in what I perceived as resistance or low priority on the part of some food packaging companies to integrate current, industry-recognized food packaging safety programs into their manufacturing and distribution operations. I made reference to multiple comments I had heard or viewed suggesting lack of understanding or clarity with expectations, risk level uncertainties, disconnects with the connection between food packaging and the latest Food Safety Modernization Act requirements and similar negative observations.
My comments represented frustration with what I perceived as a pushback from some in the packaging industry based on the perception that the hazard and safety controls and standards required for manufacturers and distributors of inedible packaging should not or need not be as urgent, broad or comprehensive as those required for implementation by manufacturers of edible products.
Now I am pleased to see that multiple packaging converters have successfully implemented HACCP-based (Hazard Analysis and Critical Control Point) food packaging safety programs in their manufacturing facilities, achieving formal certification of same. These accomplishments are particularly noteworthy and impressive, as the converters not only implemented basic prerequisite standards contained within recognized food safety programs, but took the process to a higher, more secure level by also integrating the HACCP process for identifying and controlling food hazards and conditions within their manufacturing processes.
Thus, these converters of food and packaging components are well positioned, within their categories, to provide safe and certified packaging components to their customers in the “post-FSMA era.” By incorporating the principles of HACCP or HARPC (Hazard Analysis and Risk-Based Preventive Controls) into their manufacturing and distribution processes, these companies send a clear message to suppliers and customers alike that their organizations understand, identify and control food safety and suitability risks.
Similarities in improvement and food safety programs
Most manufacturers are acquainted with the concepts of Six Sigma and Lean Manufacturing. By any name, these multiple-step quality and waste elimination programs have been embraced and implemented by the manufacturing community, which promises a level of uniformity and practicality to practitioners. When an individual achieves “Coach,” “Champion” or a related status level, that position of subject matter expertise follows the person to other locations and organizations. Similar concepts exist for HACCP and HARPC. Just as there are some differences between continuous quality improvement-related programs, food industry professionals will identify differences between HACCP and HARPC. I, though, consider the similarities. That is, they are both broadly intended to:
- Apply a team-based approach to analyze all aspects of an operation or process for physical, chemical or microbiological food safety risks or hazards;
- Identify and clarify possible or known hazards and consider actions or steps intended to effectively prevent, catch and control those hazards in advance of shipment;
- Trial methods considered at inception to represent effective practices or controls; and
- Monitor and evaluate data, then adjust and finally validate effectiveness in advance of final implementation.
Other similarities between “branded” quality and efficiency processes such as Total Quality Management (TQM), Six Sigma, Lean and HACCP or HARPC food safety programs include ownership, monitoring and continuous improvement components. These programs jointly value individual knowledge, experience and ownership in a facility or organization. Further, they conclude that these resources are aware, involved, in control (to some extent) or responsible for aspects of each process ultimately connected to quality, health and safety. Those resources have leadership and/or “teammate” potential, with the ability and willingness to continuously observe, communicate, contribute and facilitate improvement.
These programs are intended to shift from a culture of reaction to a process of proaction.
Not every process in a food packaging manufacturing or distribution process is in need of critical control; however, every process is in need of risk/hazard analysis. Following analysis, teams consider and document potential or actual risks and hazards, rate them for frequency and severity and assign a method of control or mitigation, which may be accomplished through implementation of standards specified within all recognized food safety programs (that is, prerequisite programs), the creation and execution of one or more customized control points, or another method which can be measured, documented and validated. HACCP and HARPC both require that the programs, processes and corresponding generated data be documented (archived), reviewed, validated for effectiveness and adjusted or customized as conditions and factors change. Proof of effectiveness and consistent performance exists in the evidence, visual, written and archived.
What this tells the industry and consumers
Packaging converters, manufacturers and distributors who maintain a certified HACCP or HARPC - based food safety program are notifying supply chain partners, clients and consumers that:
- As required under our food safety program, you must provide us with complete, comprehensive and satisfactory documentation to prove the safety and suitability of the products you ship us and that said products are legally compliant for the intended food use.
- Our facility sets quality thresholds for incoming materials and monitors properties which may affect the safety of the goods we convert.
- We evaluate our facility, its internal and supporting processes and the related environment for conditions known or thought to represent food safety hazards.
- We create written programs to control those hazards and train our employees to properly and consistently apply steps in the program.
- We evaluate reasonable, representative products and assess their physical, chemical and/or microbiological quality against written standards and specifications in order to identify andcontrol hazards in advance of shipment.
- We allow our program to be inspected at regular intervals by independent or external monitors or auditors to verify that we are meeting or exceeding food safety program standards as determined through written data and visual proof.
- We perform our food safety operations using a program that contains and embraces internationally and uniformly accepted standard principles of Hazard Analysis and Control.
Although there are no absolute guarantees that potentially hazardous products may slip past a facility’s hazard analysis and control program, supply chain partners and consumers alike should feel a level of confidence that members who operate under such certified programs are best positioned to prevent and react to hazardous events and demonstrate a commitment to responsible manufacture of safe products with independent oversight.
Congratulations to those facilities that have achieved certified food safety hazard analysis and control program status. To those organizations that are in the development phase, keep up the good work!
Gary Kestenbaum has 40 years’ experience in the food and packaging industries, 6 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. 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.