Protecting Product Post-Production

It can be natural to think that once a finished product has left the manufacturer’s property, it is out of its purview. But that can be significantly detrimental to both the consumer and the manufacturer’s brand should a food safety, quality, or defense issue arise. Additionally, as Safe Quality Food Institute Vice President of Technical Affairs LeAnn Chuboff said, “All food businesses have a legal and commercial responsibility to supply safe food and comply with food regulatory requirements in the country of manufacture and the country of sale if it’s known.”

With FSMA having expanded FDA oversight throughout the supply chain, those regulations have carried an impact beyond processing to include distributors, transporters, and some retailers, i.e., anyone who “holds manufacture, process, pack, or hold food for consumption in the US.”

With respect to FSMA, said NSF International Lead Auditor Steve Hoffman, “The greatest direct effect for distributors and transporters is probably the preventive control and sanitary transport requirements.” In response, he said, distributors seem to have increased the number of food safety plans, such as FSMA Preventive Controls, FDA Seafood HACCP, and USDA HACCP, to meet regulatory requirements, with the main impact of FSMA being the identification and management of the preventive controls similar to the way CCPs were handled prior to FSMA. For transporters, significant effects have been upgrades in temperature controls and records, including evidence of compliant temperatures in loading and transportation, he said.

Going beyond regulation to help ensure their products reach the customer as intended, many processors are implementing a food safety management system to demonstrate compliance not only with food safety regulations, but with the requirements of their supply chain through to retail, QSR, or commercial customer, Chuboff said.

Following are some key elements to consider to ensure that distribution is not a weak link in your supply chain.

GOOD DISTRIBUTION PRACTICES. Just as many retailers require that their suppliers follow GFSI standards, so too can it benefit you to select distributors who implement the standards in their practices. While the details of certification requirements for good distribution practices vary slightly depending on the GFSI standard and certification program owner (CPO – previously called “schemes”), each requires compliance with all applicable regulatory requirements, Hoffman said. “Generally, GFSI standards correspond closely with U.S. regulatory requirements but include some prescriptive requirements that go beyond the more general wording of the regulatory standards,” he added.

Additionally, Chuboff said, food safety practices also will differ depending on the food safety risk to the product or process, so the codes were designed to meet the individual requirements of each industry sector.

DISTRIBUTOR REQUIREMENTS. “We often encourage risk mitigation,” Chuboff said. “The distributor must recognize inherent product risk and have procedures and practices in place to minimize the risk.” These include, but are not limited to, the cleanliness of storage areas, racking, and vehicles; adequate temperature and atmosphere control, if applicable; stock control; pest management; and loading and unloading practices.

“Above all, distributor management need to understand the food safety risks and controls and provide proactive leadership, encouragement, and direction to site staff,” she said.

Regardless of whether or not GFSI is required, distributors should be required to implement a HACCP/Preventive Controls program covering all its products and processes, Hoffman said. A few key elements that should be contained in the plan include:

• An effective temperature control system, both in storage and in transit. Systems for continuous temperature recording during transit are becoming more common.
• Systems to prevent cross-contamination during storage and transport, especially if any product is exposed.
• Security, food defense, and food fraud programs.
• An effective traceability and recall process in case of a food safety issue.

Some standards also require finished product specifications to be approved by the commercial customer, along with the requirement to review product quality and service specifications with the customer to maintain the ability to meet those specifications.

DISTRIBUTOR PROVISIONS. In turn, your distributor should be able to expect you to provide clear and well-defined product identification upon receipt, especially that of accurate identification of lot codes on the product and records for each delivery; records or evidence that may be required for product safety (e.g., transit temperature records, proper tagging and identification of shellfish, etc.); and accurate, on-time deliveries.

The distributor should also be able to expect product that is not only safe on receipt but is in a condition that will maintain its safety, integrity, and quality through the supply chain to the retailer or consumer if stored and handled correctly, Chuboff said. Along with temperature requirements, this can include primary and secondary packaging protection, as well as the inherent strength of the product to withstand transport and pallet stacking.

To enable this, she said, “The distributor must establish an open and honest relationship with food producers, so that they are aware of the requirements of the distributor and that product and service specifications are agreed.”

Additionally, a commitment by the distributor to a globally recognized food safety management system, such as GFSI, demonstrates that commitment and enables the distributor to establish that connection with their suppliers (i.e., food processors) through their approved supplier program.

RETAIL SAFETY. To ensure the integrity of the product is maintained through the supply chain to the final consumer — including product safety and quality, package integrity, and labelling — processors must establish specifications with their supply chain partners, by which they listen and respond to feedback from the market to reduce incidents, loss, and waste, Chuboff explained.

“Food safety certification is not about maintenance, it is about improvement,” she said. Management systems require continuous review of the processor’s operations; implemented controls, and compliance; and the identification and correction of deviations. By doing so, she said, “Over time, the management system is improved to further mitigate the safety and quality risk.”

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Above all, though, it is the commitment of site and senior management to use standards as a tool to drive business improvement, which can result in improved safety and quality, reductions in waste and loss, and business cost savings.

PRODUCT TAMPERING. In addition to general food safety and quality protection, food processors need to take steps to prevent product tampering between manufacturing and the consumer. Thus, in addition to use of tamper-evident packaging, Hoffman said that procedures should include oversight and control of the distribution chain, and requirements for on-site delivery inspection and facility distribution security.

Elaborating on that point, Chuboff said, “Product tampering is an issue that cannot be resolved simply by implementing tamper-proof or tamper-evident packaging, which can result in over-packaging and be counter-productive by reducing product access for the consumer.” Product is better protected by maintaining security and control over storage and handling of raw materials, work in progress, and finished product at all stages of the supply chain. This, she said, is achieved through controlled access to production and storage areas, effective stock control, product identification at all stages, and fair but effective management of labor hire and supervision. With the risk of a deliberate act of sabotage in the interface between the various points in the supply chain, in particular transport and distribution, vehicles used for product transfer should be secured from tampering using a seal or other acceptable device or system.

CUSTOMER COMPLAINTS. The procedures for handling and investigating the cause and resolution of complaints from commercial customers, consumers and authorities, are a key component of food safety, Chuboff said. Trends in customer feedback data need to be investigated and analyzed so appropriate corrective action can be taken to prevent recurrence. “It is one of the performance indicators that can drive continuous improvement in the processors management system,” she said.

Also seeing the use of trending and pareto analysis of complaints as important, Hoffman said, “Product and service complaints can contain clues to potential problems. Potential underlying issues should always be considered.”

IN SUMMARY. With all this, what are the key things food manufacturers should do to help ensure the safety and quality of their products through to the consumer? Although the factors that affect the safety of product vary greatly with the type of product, Hoffman said, “In general, the use of distributors that have effective implementation of detailed, validated food safety plans, continuous improvement programs, and employee involvement is advised.”

Businesses should have product specifications in place that are agreed with their supply chain customers and that maintain the safety, integrity, and quality of the product through the supply chain to the final consumer, Chuboff advised.

It also is important to understand the food safety hazards inherent in their products and processes; have an effective food safety management system (e.g., HACCP) in place to manage the hazards and mitigate the risks; and respond to issues, concerns, or complaints from commercial customers and consumers about product safety, integrity, and quality; and take preventive action to prevent recurrence.

“A failure of any product safety programs can have serious consequences,” Hoffman said. “But for me the most effective thing is a culture of continuous improvement that includes constant, aggressive challenges to the status quo and elimination of complacency.”

The author is Editor of QA magazine. She can be reached at llupo@gie.net.