During our Monday, March 30 “Food Safety and COVID-19: What Businesses Need to Know” webinar, we discussed a number of regulatory updates and recommendations to ensure food safety and worker health. One of the practical scenarios reviewed by Earl Arnold, Manager, Food Defense/FSMA Operations, Quality Assurance, involved key considerations when increasing production.
Specifically, is your facility having longer production runs, but with fewer SKUs? Here are four key questions to ask of your team.
1. What about the ingredients we’re not using?
If you’re increasing production of standard product, but some specialized ingredients won’t be in production for a while and are in storage, they may be susceptible to pests. Per the FDA’s Current GMPs, Sec. 117.80 Processes and controls, section b, 1-4: “Raw materials and other ingredients must be inspected and segregated or otherwise handled as necessary to ascertain that they are clean and suitable for processing into food and must be stored under conditions that will protect against allergen cross-contact and against contamination and minimize deterioration… Raw materials, other ingredients, and rework susceptible to contamination with pests, undesirable microorganisms, or extraneous material must comply with applicable FDA regulations for natural or unavoidable defects if a manufacturer wishes to use the materials in manufacturing food.”
By adding those ingredients to an inspection schedule approximately every four weeks, you will take into account the lifecycle of most insects and limit the potential for an insect infestation in your facility.
2. Do we need changes to our cleaning, sanitation and inspection schedule?
While these activities may each be verified during your normal production schedule, increased production may prompt risks you haven’t considered. You should re-verify your production run to determine if any new risks are present.
Next, discuss your new run schedule with your chemical supplier. They may recommend different products that can assist with these changes and help reduce your risk of cross-contamination or cross-contact issues.
Further, review your cleaning procedures to determine if changes are necessary. This could include additional deep cleaning during shutdowns.
And finally, when you do make changes, train and educate everybody involved to make sure they are aware and understand what changes you’ve made and why. Additional inspections may also be necessary, providing assurance that you’re maintaining the production of safe food.
3. What is the impact of longer runs on traceability?
If production times are increased, more frequent lot changes of staple ingredients may be necessary. Consider reviewing this process and discussing it with employees, reminding them that changes in lots may be more frequent. You should also consider more frequent supervisor checks to ensure that these lot changes are being recorded.
4. Are our preventive maintenance schedules being interrupted?
Review upcoming production runs with your maintenance team. If changes to your schedule are warranted, develop a temporary maintenance schedule and document the need for that change in the schedule.
You will also want to make sure this schedule coincides with your sanitation activities, minimizing downtime.
If you need additional insight on key considerations when increasing production, or have other questions, please contact us at firstname.lastname@example.org.
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