| Perhaps you’ve heard of the non-reciprocal wine and sewage principle. I’m not sure where it originated, but it states that if you add a cup of wine to a barrel of sewage, you still get a barrel of sewage. No brainer, right? Well, consider the flip side. If you add a cup of sewage to a barrel of wine, you also get nothing more than a barrel of sewage. In other words, a small amount of contamination goes a long way.
The premise of this principle also applies within the food manufacturing industry. If you were to add uncontaminated food to garbage, you would just get more garbage, and if you add garbage to food… well, you get it. The term garbage can encompass an endless variety of contaminants, such as broken glass, metal shavings, nuts, bolts, plastic fibers, grease, broken machine parts, errant human body parts, and on and on. Although the FDA does allow for certain levels of natural contaminants, like insect parts and rodent hairs, consumers are never pleased when undesirable elements enter their food supply. It could even be dangerous. When design engineers create food processing machinery and production lines, they must be on the lookout for potential risks of contamination hazards. They must also provide a quick means of mitigation, before contaminants can enter into commercial production. A systematic approach provides the best means of addressing these needs, allowing for a pre-emptive method to ensure food safety. Checklists and procedural policy set in place for these reasons will enable design engineers to identify, assess, and control risks before they turn into hazards. This is where Hazard Analysis Critical Control Point (HACCP) planning comes in. To address these needs, the FDA has set up the HACCP (pronounced, “hass-up”) system, defined as “…a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.” HACCP is the outgrowth of FDA current Good Manufacturing Practices (cGMP), which are set out in the Code of Federal Regulations pertaining to commercial food processors and manufacturers, Title 21, Part 110, entitled, “current Good Manufacturing Practice in Manufacturing, Packing or Holding Human Food.” Every commercial food processor, regardless of size, must implement a cGMP/HACCP quality assurance program to comply with these regulations. HACCP is a proactive strategy where hazards are identified, assessed, and then control measures developed to prevent, reduce, or eliminate potential hazards. A key element of HACCP involves prevention of food contamination during all phases of manufacturing, and way before the finished food product undergoes quality inspection. This strategy extends into the food manufacturing equipment and production line design process as well. Next time we’ll continue our look at HACCP and how its seven principles are used by design engineers to prevent food product contamination.
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Tags: cGMP, current good manufacturing practices, design engineer, engineering expert witness, FDA, food contamination hazard, food processing machinery, food product contamination, food production line, forensic engineer, HACCP, hazard analysis critical control point, quality assurance program, quality inspection, risk analysis
