FSMA and the coffee roaster

The Food Safety Modernization Act

What Your Company Needs to Do – Now!

By Mike Ebert

Coffee production, specifically roasting, has long fallen under the radar when it comes to food safety concerns at manufacturing facilities. This is true for the government agencies that regulate and inspect such facilities, and for the coffee roasters who operate them.

Introducing the FSMA

On Jan. 4, 2011, President Obama signed into law the Food Safety Modernization Act (FSMA). This new law is designed to ensure that the food supply in the United States is safe by shifting focus from responding to problems that have already occurred to preventing problems in the first place.

The FSMA is the first major piece of federal legislation to address food safety since 1938. Some facts that drove this decision:

?      About 48 million Americans become sick every year from food-related issues.

?      Of these, 128,000 require hospitalization to treat food-related illnesses, and 3,000 die.

?      Infants, children and older individuals are more susceptible to food-borne illnesses.

?      With increasing globalization, 12 percent of the food we consume is imported from other countries.

?      There could be a risk of terrorism-related food tampering.

?      The importance of preventing contamination and health risks throughout our food chain is a key risk management strategy.

What does this mean for the roaster?

You must treat coffee as the food product it is. The FDA considers anything that you put into your mouth and swallow, a food product. All food products have potential to cause harm, no matter how low the risk.

Begin by registering your company

As a coffee roaster, your company must register as stated above. Simply visit FDA website (www.fda.gov) and follow the links to register. Food facility registration helps the FDA determine the location and source of a potential bioterrorism incident or an outbreak of food-borne illness, and allows the agency to notify entities and consumers who may be affected in a timely manner.

Good Manufacturing Practices in Place (GMP’s)

21 CFR 110 Good Manufacturing Practices were developed as a guideline to ensure and promote sanitary practices, sanitary design and sanitary facilities within a process system. They consist of:

?      110.10 Personal Hygiene

?      110.20 Plant and Grounds

?      110.35 Sanitary Operations

?      110.37 Sanitary Facilities and Controls

?      110.40 Equipment and Utensils

?      110.80 Process Controls

?      110.93 Warehouse and Distribution

Consider these the foundation of a food safe environment. Without standard operating procedures in place to cover these areas, you cannot continue with a written food safety plan.

Hazard analysis and critical control points (HACCP)

This is a systematic preventive approach to food safety from biological, chemical and physical hazards in production processes that can cause the finished product to be unsafe. Bottom line: HACCP details the prevention of hazards rather than finished product inspection. It will follow your product—in this case coffee—through the roasting plant, from receiving all the way through to shipping to your customer. It focuses on the hazards that are unique to your product. The concerns for a seafood processor will be different than those of a coffee roasting company.

Recalls

The main question to address here is, can you get ALL your product back if there is a problem? Your written food safety plan must include a procedure detailing what you will do in the event of a recall. However, this is only part of what they are looking for; you must have procedures in place that show you “listen” for potential problems. Reviewing customer service phone log, paying attention to coffee industry hazards, open door policy for all employees to report potential problems, etc.

The problem for roasters is how to set up a recall procedure. For starters, you should create a protocol for tracking product complaints from customers, as well as identifying potential trends these complaints might show. The FDA’s focus, however, is not on quality issues but on potential health issues. To understand this further, lets start with how the FDA classifies recalls, based on severity:

·     Class 1: Likely to cause severe illness or death

·     Class 2: Likely to cause illness

·     Class 3: Likely to cause “unpleasantness” but not much more

A qualified plan writer

Your plan must be written by a qualified individual, though what constitutes a qualified individual is not well-defined in the law. Technically, a qualified individual has successfully completed training in the development and application of risk-based preventive controls or is otherwise qualified through job experience to develop and apply a food safety system. This person becomes the official record keeper, assuring that all plan documentation is completed and maintained properly and available for review.

Owner and management participation

One of the most important aspects of a written food safety plan is the role of owners and top executives. They can’t simply put someone else in charge of it. They must be active in the plan development and implementation, and have full understanding of the laws and their roles, and be able to assure the company is in compliance.

It’s also important to understand that this is not something you do once and forget about. The plan must be reviewed and updated every three years—and any time you discover a control or procedure is not effective. Inspectors will want to see that your plan is a living, breathing document, regularly discussed and reviewed by the entire company.

The bottom line

No matter what your size, you should take this seriously. Coffee roasting is a low risk product, we roast and brew at high temps, run it through a filter, etc. For me, the reasons are simple, they make you a better business.

But remember on things – don’t eat the elephant. The creation of a well written food safety program takes time and a ton of documentation. In addition, as stated above, it’s a process that is never complete.

My advice for the roaster starting from scratch?

Educate your yourself and team on all facets of food safety; GMP’s, HACCP, Recalls, Supply verification, internal audits and GFSI food safety schemes.

Start with a focus on GMP’s – these are the foundation you build a food safety program on. Learn how to document these, how to assure they are being followed, etc.

Once you feel your GMP’s are in place and working, educate your team a bit more, with a focus on writing your first HACCP plan.

In conclusion

Most of us want a clean plant, sanitary operations, etc. But often we focus on things that are not important, or trying to do too much. Having a base education in food safety and a good program in place allows you to focus on the areas that are important. In addition, if and when you are inspected, you are ahead of the game, and know what to expect.

Perhaps the biggest benefit is the knowledge that your company is compliant, and when that big potential customer comes a calling, and they require a written food safety plan in place, you can confidently say yes!