Nut Handling and Processing
for Confectioners and Small Nut Roasters
Session 4: Role of Food Safety Programs in Assuring Safe Use of Nuts
Tom Mackie, Food Safety Consultant to NCA
Steve Calhoun, Food Safety Consultant to APC
Sponsored by:
In partnership with:
Nut Handling & Processing for
Confectioners and Small Nut Processors
Role of Food Safety Programs
in Assuring Safe Use of Nuts
Steve Calhoun
and
Tom Mackie
Challenges for Nut and
Confectionery Processors
• Handling contaminated raw commodities
• Old facilities with poor traffic flow
• Poor equipment design making it difficult to clean and
inspect
• Lack of trained and dedicated resources
• Use of contract and temporary labor pool
• Reliance on co-manufacturers for critical process steps
• Low level of technology for quality and food safety
systems support
• Change management to keep up with pressure for new
product and new package development
Prerequisite Programs
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Regulatory Proposals
PRP Overview
Facilities , Personnel , Equipment
Control of Raw Materials
Sanitation & Environmental Monitoring
Traceability and Recall
SSOPs and Process & Controls
PRP Implementation
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Microbiological Control
Hazard Analysis
Chemical , Allergen & Physical Hazards
Documentation
Training
Verification
HACCP
Proposed Changes to Food
Safety Regulations
• Substantially increase regulatory burden, cost,
and liability risks
• Increase frequency of food facility inspections
• Expanded access to company records and test
results
• Mandated food recalls
• Written HACCP type plans
• Enhanced Traceability requirements
• Third party accreditation to food safety
standards
Prerequisite Programs
A range of programs that are necessary
to set the stage for HACCP-based
systems and to provide on-going
support for these systems.
Prerequisite Programs Based on:
• FDA current Good Manufacturing
Practices (cGMPs)
• USDA/FSIS sanitation regulations
Prerequisite Programs
Provide the basic environmental and
operating conditions that are
necessary for the production of safe,
wholesome foods.
Examples of Common Prerequisite
Programs
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• Facilities design
• Production equipment •
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controls
• Cleaning & sanitation
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• Chemical control
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• Pest control
Personal hygiene
Training
Supplier
assurance
Specifications
Traceability &
recall
Examples of Prerequisite
Programs
• Consumer complaint management
• Sanitation Standard Operating
Procedures (SSOPs)
• Environmental monitoring program
Facilities
• Layout
– Buildings, premises, equipment, and
personnel movements
• Segregation
– Clean and unclean zones
– Wet and dry zones
– Air handling
Facilities
• Separation of raw from processed including air
flow
• Special attention to roof
• Master Sanitation Schedule
• Use of dry cleaning procedure as routine for risk
areas
• Dry, Dry, Dry
• Nut residue accumulation removed as timely as
possible
• Integrated pest control management
Personnel
• Health and hygiene
– Disease control and personal hygiene/dress
code
• Hygienic practices
– Handling of materials
– Movement in facility
• Education and Training
Personnel Practices
• Should apply equally to contract
employees
• Cross contamination prevention, limit
traffic between raw nut and processed nut
area
Poor employee practices
may result in
microbiological, physical or
chemical contamination
of foods.
Production Equipment
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Sanitary design principles
Scheduled maintenance
Calibration, where applicable
Monitoring activities
Sanitary Design
Figure 3-1. Ends of a horizontal screw conveyor – always a
potential area of stagnant
product build-up.
Sanitary Design
Figure 3-2. A flat surface that can collect product (This should be eliminated or sloped).
Equipment
• Cold storage equipment monitored
– Raw Peanuts 1-5oC (34-41oF)
– 55-70% Relative Humidity
Inbound Material Control
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Documented Specifications
Certificates of Analysis / Conformance
Letters of Guaranty
Supplier approval program
Inbound material inspection
Material receiving procedures
Management of material storage
Supplier Assurance
• Document a material management
program for all ingredients and packaging
• Conduct risk assessments for materials
• Decide which materials present the
greatest risk to the business
• Determine how to audit suppliers
• Build strong relationships to enable regular
communication with suppliers
Supplier Audits
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Who conducts the audits ?
Make sure the auditor is trained
Provide documentation of the audit
How frequently should a supplier be audited ?
Make sure the supplier is clear on all
specifications and expectations
• Follow up on all recommendations and required
corrective actions
• Assure the vendor provides timely notification of
all changes to material , facilities , or process
Specifications
• Spec.’s are documented , contractual
requirements
• All critical food safety parameters must be
included
• For nut materials these will include
microbiological , aflatoxin and allergens
• All special handling requirements need to be
documented in the spec.
• Assure spec.’s are controlled documents
Specification Categories
Moisture
Microbiological ; bacteria , molds
Rodent or insect evidence
Foreign Materials ; shell , twigs/wood, metal
Chemicals ; aflatoxin , pesticides
Allergens
Sensory ; color , flavor
Nut Quality ; size , broken pieces , damage
Microbiological Limits
• USDA Commodity Micro Requirements for
Peanut Butter
Salmonella
E. Coli
Coliform
Aerobic Plate Count
Yeast
Mold
Negative
<3.6/g MPN
<10/g MPN
<10,000/g
<100/g
<100/g
Material Receiving & Storage
• Material receiving procedures such as
checks for seals ; COAs and sampling
• Dock space and material protection
• Bulk unloading and handling equipment
• Isolation of raw commodities
• Control of allergen cross contact potential
• Warehouse space and conditions
• Handling of non-conforming materials
Nut Processors
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Crop sources
Harvest conditions
Storage conditions
Shelf life impact
Lab capabilities ; micro, chemical ,aflatoxin
Allergen cross contact at shellers
Intermediate handlers / co-processors
Confectioners
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Nut supplier locations
Packaging used for nut ingredients
Shipping and handling prior to delivery
Receiving practices at your sites
Product turnover during processing
Intermediate products and rework
Environmental Sanitation
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Know the facility layout ; wet and dry areas
Dedicated tools and cleaning equipment
Lean manufacturing approach
Control traffic patterns throughout the process
facility ; raw product containment is critical
• Rely upon documented cleaning and sanitation
schedules and procedures
• Use product contact surface sampling to verify
sanitation effectiveness
• Use environmental swab testing for pathogens
Equipment Cleaning and
Sanitation
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Dry cleaning in nut and confectionery processes
Continuous operations and shut down periods
Wet clean systems such as CIP and COP
Focused wet cleaning of equipment
Product build – up and biofilms
Access to clean and to inspect the job
Application of sanitizers
Swab tests and bioluminescence / ATP kits
Impact of GMPs and personal hygiene
Environmental Swab Program
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Where and how to sample using sponges
Frequency of swab sampling
How to react to a positive pathogen result
Control reporting and communications
Confirm external lab credibility
Expect programs to be implemented at
suppliers and co-processors
Product Testing
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Product contact surface sampling protocols
Raw materials monitoring
Intermediate ingredients
Rework
Finished product composites
Composite breakdowns
Resampling and retesting
Returned product and retained samples
Strong hold management system
Traceability and Recall Program
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Crisis response plan and team
Lot coding and records
Distribution records
Product disposition
Mock recalls
FDA regulation (21 CFR 1)
– Requires records identifying immediate previous
source and immediate subsequent recipient
Sanitation
Regulatory Requirements
• FDA – Current Good Manufacturing
Practices (21 CFR 110)
• SSOPs
SSOPs
• Should identify daily pre-op procedures
• Should identify daily operational
procedures
• Should be signed and dated
• Establishment should initiate corrective
and preventative actions
• Daily records should be maintained
Process and Controls
• Validate kill step
• Do not use same equipment (conveyors,
containers, etc.) for unprocessed and
processed, including blanched nuts
• Process disruptions – remove product
• Control nut dust and other nut debris
• Assure nut foreign material removed
Process and Controls
• If a processed product sample tests positive
for Salmonella, the tested lot is considered
adulterated and should not be released into
commerce
• Positive lots may be reprocessed , but ONLY
when run through a VALIDATED process
• It is critical to review adjacent lots to confirm
a clean break between a positive lot and one
or more lots designated as clear to release
Process and Controls
• Purging contaminated peanut butter lines
with hot oil
– Validate procedure
– Recent study suggests it takes 42+/- 8
minutes at 90oC (194oF) for a 5 log reduction
of Salmonella for a mixture of three outbreakassociated S. Tennessee strains in peanut
butter (Doyle, May , 2009)
– 49±12 min were needed to inactivate a
composite of other Salmonella isolates
Process and Controls
• Traceability
– Finished product traceable to raw material lots
used
– Consideration should be given for a routine
clean break for bulk or continuous nut and nut
butter operations
Microbiological Control
GMA Guidance Document
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Prevention
Hygiene Practices and Control
Hygiene Design of Buildings and Equipment
Moisture Control, Minimizing growth, Dry & Wet Cleaning
Practices
• Raw Material Programs
• Validation of Control
• Verification of Controls & Corrective Actions
www.gmaonline.org/science/SalmonellaControlGuidance.pdf
Chemical and Physical
Hazards
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Aflatoxin and other Mycotoxins
Pesticide Residues
Heavy Metals
Unintended Food Allergens
Foreign Materials
Proper implementation of
prerequisite programs
simplifies the development of
a HACCP Plan.
Prerequisite Programs
Should Be :
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Well-documented with written SOPs
Adhered to by all employees
Reviewed and revised as needed
Effective in accomplishing objectives
Establishing Prerequisite
Programs
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Documentation
– What procedures should be performed?
– At what frequency?
– Who has responsibility?
– What actions should be taken if:
• a procedure is not performed as required?
• there is an unexpected outcome?
Establishing Prerequisite
Programs
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Employee training
– Continuing education
– Important to understand and follow
assigned tasks
– Provide time and materials for training
– Verify by reviewing performance
Verification of Prerequisite
Programs
Periodic review of the SOPs and audit
reports to ensure that the programs are
operating in a manner that should not
require a change in the hazard analysis or
HACCP plan.
Establishing Prerequisite
Programs
Verification
– Is the SOP performed in the manner
intended?
– Is the procedure monitored?
– Are appropriate records kept?
– Is there an independent audit?
– Are programs revised as necessary?
Establishing Prerequisite
Programs
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Resources
– Are the proper tools/equipment
available?
– Are appropriate personnel available
to perform the task effectively?
– Are systems adequate for monitoring
and storing data?
Prerequisite Program or
HACCP?
Prerequisite Programs
HACCP Plans
Deal indirectly with
food safety issues
Deal solely with
food safety issues
Cross multiple product
lines
Specific to product & line
Failures seldom result in
food safety hazards
Deviations must be
considered potential food
safety hazards
Prerequisite Program or
HACCP?
Depending upon the results of the hazard
analysis and identification of control
measures, some activities normally
addressed in prerequisite programs may
be included in the HACCP plan.
Summary
• Understand all legal and regulatory
requirements for nut handling &
processing
• Know the important PRPs that form the
foundation for food safety and HACCP
• Regularly train the employees that are
accountable for program implementation
• Verify all food safety programs perform to
protect customers and consumers
Questions?
For Q&As and Food & Nut Safety Resource Guide:
http://www.ecandy.com/Content.aspx?ContentID=7134