Are your controls an exercise or a principle?

This article is intended to present different perspectives and considerations on the prevention of foodborne disease adulterations in food products.

As the recent PCA peanut paste fiasco demonstrated, no amount of advice or suggestion can improve operations owned or run by managers that either do not understand or trivialize the importance of food safety. When food safety is nothing more than an exercise to generate fraudulent documents to feign due diligence, disaster is assured.

For organizations truly focused on brand protection, prevention is the prom-ised land. Documentation is secondary to their ongoing actions, as it is only through effort applied to the line that prevention happens.

The goal of HACCP is prevention. The HACCP document requirements, their data and commentary are there only to convince the reader that all reasonable action was taken to reduce risk.

HACCP teams and risk managers have come to understand that the world of prevention is in fact cast onto a steep and slippery slope. The only way to hold one’s place is through daily effort of applying “the plan” to the process, one shift at a time, day in and day out.

In addition, risk assessment is key to HACCP and once performed, must be tuned and retuned given available resources. If resources are scant, then focus must be applied to risk communication to get stakeholders to increase those resources essential to enable targeted intervention and prevention.

There are hundreds of pathogens and thousands of serotypes which are implicated in foodborne disease outbreaks and The Centers for Disease Control and Prevention (CDC) has identified three primary target pathogens for food safety programs:

• E. Coli 0157:H7
• Listeria monocytogenes
• Salmonella

Each has shared the media spotlight in recent past. Each has killed and maimed innocent, trusting consumers.

It has been said that food safety program results hit a plateau a few years ago. In order to improve our position, we must challenge the premise of many of our assumptions and change the way we think. The peanut paste contamination at PCA exposed several major gaps in our food safety systems, and they exist at every level including management, State and Federal government, and private third parties.

Salmonella contamination, in partic-ular, has received much recent media exposure. Salmonella bacteria reside in the intestines of most animals, and is particularly likely to be found in and on the eggs and feces of birds and reptiles. Thus, food processing plants need to improve their vigilance and have an active program to inspect for and prevent birds and small reptiles from finding their way into food and ingredient stores.

Your facility design should include strategies to ensure against any openings through which these small, unwanted mobile disease factories can enter, particularly plants which are in older structures which can sag or settle, and have openings caused by storm damage or wear and tear. If someone is not looking for openings on a regular basis, an invasion may be imminent.

Plant management may be tempted to believe that when they have a third-party pest control operator, they need not consider pests in their prerequisite programs (PRP). It is also apparent that some oper-ators think that by hiring a third-party audit firm, they are somehow relieved of some burden for their food safety. Both of these are false assumptions. Rather, surveillance for evidence of such pests is everyone’s job, and there needs to be more discussion about their exclusion.

Third-party audits do nothing for prevention unless they identify an unacceptable risk and management responds to the notification in a reasonable manner. Keep in mind that the intent of an audit is to “sell” potential customer(s) on the safety story the food plant has created. This is not the same as saying the goal of the audit is to improve the existing HACCP plan or surveillance against PRP gaps or failures.

Thus, we need to challenge our assumptions and think differently to improve our systems.

We do this by asking challenging ques-tions, such as:

1. How do we reduce the likelihood that birds and reptiles can get near or above our food products?
2. How can we sanitize things that we do not know are clean?
3. How do we know “it is clean” and ready to be sanitized, when we have no analytical measure for “clean”?
4. How do we remove feces that are likely to be on produce leaves?
5. What intervention options are effective and, of those choices, which are practical given our risk and resource assessments?

When HACCP and its prerequisite programs are recognized as the path to prevention, then the question is no longer, “Is HACCP too complicated and/or expensive?”

Instead, the question becomes, “What can I do to improve my HACCP program and its surveillance today?”