Food safety déjà vu
Jan. 15, 2013
Anyone who was working in or observing the U.S. meat processing industry in 1996 must have experienced a sense of déjà vu on Jan. 4 when the Food and Drug Administration issued its proposed rules to require food processors to develop and implement food safety prevention plans that follow the model of hazard analysis and critical control points (HACCP) plans. Meat processors, which are regulated mainly by the U.S. Department of Agriculture, went through the development, implementation and management of a regulatory-based HACCP program. This makes the meat industry an excellent resource for food and beverage manufacturers that now are attempting to comply with the F.D.A.’s pending regulations.
That similarities will appear between the F.D.A.’s program and the U.S.D.A.’s effort is undeniable. The principles that guide the development of HACCP plans do not change based on the product produced. It should also be noted the official leading the development of F.D.A.’s regulations played an integral role in the U.S.D.A. program.
Michael Taylor was the acting undersecretary of food safety for the U.S.D.A. in 1996, playing the key role in the development of the meat and poultry industry’s food safety regulations. Today, Mr. Taylor is the F.D.A.’s deputy commissioner for foods and veterinary medicine, and he once again finds himself at the nexus of events that will reshape how food and beverage manufacturers approach food safety. One hopes Mr. Taylor has taken to heart the lessons he learned when he was working with the U.S.D.A.
The mid-1990s were a difficult time for the meat processing sector. It was only a few years after four children from the Pacific Northwest died after consuming E. coli O157:H7-tainted hamburgers from a fast-food restaurant. Little was known about the E. coli O157:H7 pathogen and the illnesses it caused. It was simply referred to as “hamburger disease.” The fall-out from the children’s deaths led the U.S.D.A. to develop and implement its HACCP regulations.
A key lesson to be taken from the meat industry’s experiences is that differences exist between traditional HACCP and HACCP programs that are developed and implemented to comply with government regulations. At its core, HACCP is a program that requires manufacturers to review their operations, identify where hazards are likely to occur, develop controls to ensure the hazards are prevented, create a documentation and records retention program to track whether the controls are working properly, and develop contingency plans if a control fails. It is a form of continuous improvement that may be customized to individual manufacturing processes.
What made HACCP challenging for meat processors and likely will make it challenging for all food processors is the regulatory environment under which the programs will be implemented and managed. While the prevention concept is flexible, the F.D.A. is going to have its own set of biases about what constitutes a hazard in a specific manufacturing process and what type of documentation is appropriate to ensure compliance. While food companies are going to want to develop plans that fit their current quality control programs and corporate culture, they must also pay close attention to the guidance documents provided by the F.D.A. that will be a part of the final regulations.
The good news for food and beverage processors is that resources available at the university level and in the private sector are of great value in helping both large and small companies comply with the new regulations. These service providers have learned from past experiences and should help ensure a smooth transition to the F.D.A.’s new food safety standards.