GENEVA, N.Y. — Farmers processing their own goods — or others’ goods — need to better understand the Food Safety Modernization Act.
A recent workshop presented by Cornell AgriTech on FSMA helped participants better understand the regulations that went into effect in late 2018. The Northeast Center to Advance Food Safety, USDA and National Institute of Food and Agriculture supported the workshop.
Bruno Xavier, senior Extension associate and process authority with Cornell Food Venture Center, led the workshop. He said that food preservation should “extend the life of a food product by avoiding spoilage and safety concerns from microbial and quality challenges.”
To do so, processors need to “eliminate, exclude or inhibit the growth of microorganisms and control conditions that compromise food quality,” he added.
He offered dry spice mixes as an example of a product that’s naturally safe and stable; however pickles are naturally stable but may become unsafe.
Processors need to pay attention to physical hazards, such as metal pieces falling into a vat; chemical hazards, such as cleaning agents; and biological hazards, such as pathogens like E. coli in greens or salmonella in peanuts.
“Everyone is required to have a food safety plan,” Xavier said. “Keep records of your production no matter what you are making.”
The food safety plan is officially called Hazard Analysis Critical Control Points, or HACCP. Prior to FSMA, a food safety plan was already required for juice, seafood and meat. It’s now also accepted for dairy products.
“If you’re already doing this, package it into your FSMA package,” Xavier advised.
It’s especially important to document food safety if a recall happens. Xavier said that processors must actually obtain all the recalled items, not just tell stores to throw them out. Processors should keep detailed documents about how the company sourced and handled the ingredients, produced the product and distributed them. This can aid in proving the processor’s good faith effort in making a quality product, help in revising the processing plan to correct any shortcomings, and also obtain the recalled items from points of sale.
Xavier explained the principles of HACCP:
• Conduct a hazard analysis.
• Determine the critical control points.
• Establish critical limits.
• Establish monitored procedures.
• Establish corrective actions.
• Establish verification procedures.
• Establish recordkeeping and documentation procedures.
“If you do all the above and don’t keep records, it was all wasted,” Xavier said.
He also said that the biggest source of hazards are the environment, ingredients and people. Controlling environmental hazards includes scheduling the cleaning of equipment: who, when, how and what. Employees should receive adequate training on these procedures and farmers need to document that the training happened.
Farmers also need to maintain and inspect their facility, materials and equipment and employ pest control measures as needed.
Xavier said that cross-contamination can cause issues, such as sharing a single sink for defrosting frozen goods and preparing food. Or using the same area for raw and uncooked foods.
“Most problems happen at this point,” Xavier said. “Make sure employees take the day off when they’re sick. It’s very hard to enforce. Have contingency plans like sick days.”
Employees also require training on personal hygiene, such as washing their hands before handling any ingredients and using gloves as required.
Xavier said that another source of problems is how food is handled. Following the correct protocols for temperature, formulation and water activity, and preservation will result in safe, stable food. That can depend upon the type of food processed.
“Sterilization kills anything relative to spoilage and stabilization,” Xavier said. “Pasteurization kills pathogens.”
Sterilization occurs at 180 to 280 degrees F, whereas pasteurization is between 145 and 195 degrees F. The latter may be more appropriate to items like milk and eggs when the processor wants to preserve the state of the items.
Unlike in home canning, commercial food processors are encouraged to hot pack canned goods to help create vacuum pressure in glass jars and eliminate the air in the packaging that would otherwise contribute to spoilage.
Processors interested in dehydration need to take special care to reach the specified temperature within the first 30 minutes of processing. Xavier said otherwise, “the hot, dry air goes through the veggies and it can reduce the temperature when there is still moisture inside.”
Processors should use monitoring equipment to ensure their processes are using the correct temperature. They should also have their equipment tested periodically to ensure that it’s working correctly. Xavier said that Cornell AgriTech can help processors test their batches using equipment such as a water activity monitor for $25. This piece of equipment ordinarily costs between $2,000 and $3,000.
Allergen control represents another big area of concern for processors.
“You have to have very good controls,” Xavier said.
Otherwise, consumers can become quite ill and some could even die.
Allergen control begins with source ingredients and making sure that they have no chance of cross-contamination with common allergens like peanuts or tree nuts. Some countries have more lax laws about allergen labeling. The onus lies on the processor to confirm the ingredients’ purity.
Processors also must verify that they thoroughly clean equipment between batches of food without allergens and those with them and document that the cleaning happened.
“If you’re storing goods in the same room, put allergens on the bottom shelf so gravity works with you,” Xavier said.
Use separate clean-up tools in case of a spill.
Labeling should clearly state what the item contains in both the ingredients list and the allergen list. Xavier isn’t a fan of tacking on “may contain” to labels.
“People realize you say this because you’re not doing your job right,” he said. “Don’t do this.”
He anticipates that this phrase may be dropped from food labels eventually.
Overall, processors “need to know what you’re doing to answer the question why your product is safe,” Xavier said.