“It's not just an opportunity to comply but to improve.” M&M Mars’ John Helferich discussed how the government’s new FSMA standards can motivate food and beverage manufacturers to up their game. Helferich discussed the Food Safety Modernization Act (FSMA) of 2011 and some opportunities he sees from his experience at Mars and from an academic point of view. This included control opportunities that have appeared because of FSMA and other development in the food safety landscape.
Food safety is really controlling of the presence of organisms, pathogens, allergens and foreign objects that can cause illness or death by ingestion. "They don't belong in food so we control them," said Helferich. "At the base, food safety is a control problem."
The CDC estimates there are approximately 3,000 deaths in the U.S. every year related to food safety illnesses, said Helferich. "That would be like having 20 commercial plane crashes a year," he said. "It's quite a large number. An even bigger impact is that about 128,000 people end up in the hospital and 46 million suffer an illness. That puts food about in the middle of safety performance alongside health care."
Food safety performance has not really improved in the past 15 years, so there are many opportunities to improve. Helferich talked about how controls can help make that improvement possible. The big deal is FSMA. The rules are finally set and large firms, with over 500 people, now have to be compliant with the human rules. Most big companies are, but with smaller companies, it's still an issue.
Reactive to proactive
In the past food safety was reactive: “Let's stop this outbreak after it happens,” Helferich said. With the new government regulations, it's more of a proactive mode. The food industry has been working on preventing these problems for years. “The government regulations are just catching up with us,” he said.
"A big change is the move from HACCP to HARPC,” said Helferich, noting the move from hazard analysis and critical control points to hazard analysis and risk-based preventive controls. "With HACCP the only thing controlled was the critical control point, but maintenance, sanitation and training were assumed to be OK. With HARPC, all these items require the same control. It's now about risk-based preventive controls. Prevent food safety issues from happening by training, proper operation and maintenance.”
It's a big change in philosophy and it now has force of law. "People are now getting charged for food safety violations,” said Helferich. “Stewart Parnell, a CEO, received a 28-year sentence for shipping bad peanut butter. The FDA and the Department of Justice are teaming up and going after people. The FSMA rules were rolled out September 2016. It's not just an opportunity to comply but to improve. Review your operations and look for what can be done better."
With this new FSMA standard, data collection is a big opportunity that controls people and Rockwell Automation can help with, said Helferich. "Collection of data off the floor, not just the temperature of the pasteurizer, but also training records and maintenance records," he said. "The data now needs to be collected and stored. Who's going to do that, and how do you use the data? We need two years of record=-keeping and the beginnings of a good track-and-trace system. Data in the food supply chain now needs to include intra-firm production records and inter-firm track and trace records. A problem from just a small ingredient supplier can effect a large amount of product. The data will need to tell what and where the ingredient went."
Making use of the data to improve food safety performance is a big opportunity for controls. Focus on getting the data and improving feedback to the operators and mangers and be sure to store data to support record-keeping requirements.
