Food Protection Trends - June 2009 - 350

Common Industry Practices ❏ create a list of “Salmonellasensitive” ingredients, with an emphasis on those that are used without a further inactivation step in the finished product. table 4 shows a list of “Salmonellasensitive” ingredients commonly used in low-moisture products. – Sensitive ingredients should be held under adequate hygiene conditions to avoid recontamination. Where feasible, sensitive ingredients should be stored in a segregated area. – before sensitive ingredients are brought into the pSca, procedures should be in place to minimize cross contamination from packaging materials or containers used to transport bulk ingredients. For example, removal of the outer layer of multiple-layer bags prior to bringing the bags into the pSca may be employed. ❏ obtain sensitive ingredients from an approved supplier. an approved supplier is one that can provide a high degree of assurance that Salmonella is not likely to occur in the ingredient because appropriate process controls have been implemented. establish a supplier approval program to ensure the adequacy of the supplier’s food safety programs. the approval program should include components such as the following: – conduct an initial comprehensive audit of a supplier’s food safety program. – use common practices outlined in the seven elements of this guidance where applicable as a basis for supplier approval. industry practices from the gma’s Food Supply chain handbook (44) can also be applied as appropriate. – evaluate the supplier’s food safety program for areas that include, but are not limited to, the following: • A pathogen environmental monitoring program • Sanitation practices • Raw materials/ingredients storage • A finished product hold and release testing program • Traceability • Process validation • A corrective action plan if positive Salmonella results are found, and an evalua- tion of the potential significance for other products or ingredients manufactured in the processing facility or on the line being evaluated – grant supplier approval that is specific to an individual facility or processing line. – conduct supplier requalification at a frequency based on risk. consider that the supplier’s history may not be a guarantee of future product safety and quality. – develop guidelines for adding and removing a supplier from the approval list based on the adequacy of its food safety program and its compliance to the program. – provide the supplier with ingredient specifications and ensure that the supplier is in agreement with the requirements. The specification should be lot-specific and include a requirement that the lot be Salmonella-negative. a complete microbiological criterion (sampling plan, methodology, etc.) should be defined. ICMSF or FDA BAM sampling plans (3, 4, 48) are commonly used as part of a criterion. Samples taken should be as representative as possible of the entire production lot. ❏ develop a program for testing and using sensitive ingredients to be added to products without a lethality step or ingredients added after the lethality step. this is particularly important for situations involving new or unknown suppliers or where confidence in the supplier’s Salmonella control program is lacking. the program should include components such as the following: – Wherever possible, obtain a Certificate of Analysis (COA) from the supplier that includes results of Salmonella testing and sample size analyzed. – implement a hold and release testing program for coa verification or for ingredients that were obtained without a coa. – use approved testing labs (inhouse or external). laboratory approval should evaluate the ability of the laboratory to conduct Salmonella tests for the food(s) of interest. it may be of value to conduct this evaluation as an on-site laboratory audit. the laboratory must follow good laboratory practices, which ideally should include proficiency testing (e.g., for Salmonella testing). laboratories may or may not be certified (e.g., ISO 17025). these considerations should also be extended to the supplier’s laboratory to ensure their coa results for sensitive ingredients are reliable. – use the Fda bam or an icmSF sampling plan (e.g., cases 10–15), depending on the ingredient and the robustness of the supplier’s food safety program. the frequency of sampling may vary, e.g., once every lot (such as for a new ingredient from a new and unknown supplier), once every 6 lots, or less frequently, depending on the supplier. – make clear in the program that if a product sample tests positive for Salmonella, the tested lot is considered adulterated and it should not be released into commerce. it is important to note that retesting should not be conducted for the purpose of negating the initial test results (49, 66; see further discussion in element 7). conduct an evaluation of risk for Salmonella contamination to determine disposition of adjacent lots. ❏ Wherever possible, source an entire lot and strongly discourage being supplied with a split lot that has been distributed to multiple customers or multiple manufacturing plants. (this has the potential for one company’s verification test to implicate another company’s products.) ❏ all materials being tested for Salmonella should remain under manufacturer’s control and be released for use only after acceptable test results are received. SuMMARY And ConCLuSIonS although Salmonella outbreaks from low-moisture products are relatively rare, they often impact large numbers of people. human illnesses have been attributed to the handling of contaminated dry pet foods, as well as the consumption of a wide variety of contaminated lowmoisture products. control of Salmonella in low-moisture foods presents numerous challenges to manufacturers. the heat resistance of the organism can be 350 FOOD PROTECTION TRENDS | JUNE 2009

Food Protection Trends - June 2009

Table of Contents for the Digital Edition of Food Protection Trends - June 2009