Food
Safety Management Systems II
A shrimp manufacturer
has been notified by their accredited contract laboratory that the level of
Enterobacteriaceae present in their final products has increased. Trend
analysis of the finished product data shows an increase from less than 102
cfu/g to 104 cfu/g over a period of four weeks.
Introduction
The reason why food safety management
system has been designed, is not only for monitoring the food industry to reach
operating standards (so that all food production industry to follow certain
production pathway). We all understand that the most important thing in the
food safety surveillance is aimed for the ultimate goal “safe food, better
business”. If something goes wrong in the food product line, the HACCP plan or HACCP-based
guidelines can be helpful.
For there are various kinds of food
products, different hazard plans for different food process. Even though the
formulas of the hazard plans are
similar to each other; it still emphasizes that one hazard
plan corresponds to one product line. For example, the processes of some kinds
of fishery products are similar, there still several processing steps (such as
sterilizing temperature, packaging and storage temperature), and their
shelf-life standards may not be exactly the same; due to these small
differences can derive more variations. So that’s why it is better suggested to
have one specific HACCP-based plan to one unique product line, it will help
decrease the number of control points and make the process smooth and safe.
Since there was little information
provided from the shrimp plant, enclosed with the blue plan and the data: “the
raw material is frozen raw prawns, sourced from an approved supplier. The raw
material specification demands levels of 100 Enterobacteriaceae or below”. With
regard to the information, the hypothesis of contamination by the raw material
is omitted. According to the information provided by the factory and the
laboratory, the prerequisite programs and ssop are
not suitable to apply into this situation.
Investigating
the source and reason for increase in the levels of Enterobacteriaceae:
Base upon the information provided from the accredited laboratory
of the shrimp plant, also, with reference to HACCP: Hazard Analysis and Critical Control Point Training Curriculum
Trainer’s Guide & CA/RCP 1-1969, Rev.4-2003. There are 8 aspects for the Seafood and fishery product CCP (which
HACCP as a basis for); it’s useful to start investigation in these 8 items.
When these 8 items are not handled properly, then food problems occur. Here are
the 8 items which need to be considered in the food plant:
1. Water safety (water source and protection from contamination by
cross connections).
2. Condition and cleanliness of food contact surfaces are
acceptable.
3. Prevention of cross contamination (includes training, employee
practices and facility).
4. Maintenance of hand washing, sanitation and toilet facilities.
5. Protection of food, food packaging and food contact surfaces from adulteration.
6. Labeling, storage and use of toxic compounds.
7. Employee health.
8. Pest control.
Though the points above are useful,
they can help finding the problem in the product line that ruins the final
product. But, after studied the blue plan of the plant, there are more doubts
have been found.
Identifying the
possible source for the contamination:
In order to find out the main cause of the increasing bacteria (Enterobacteriaceae) level, review the work flow of the shrimp processing should be needed. From the FDA website, relevant information (including
guidelines, work forms and hazard plans etc.) of fishery processing is listed
for people in the industry to reference. In this step, it is recommended to
have the plant checked by the third party specifications (Inspectors from
government officials, or certified system investigators). Since the check was
done by other professionals, they can discover the problems easier and they can
find out some parts that the plant staffs have neglected.
The first thing we need to know is the common progress of
ready-to-eat shrimp production. The trainer’s guide from the Seafood HACCP
Alliance for Education and Training has given an example for the common progress
of the cooked shrimp product:
Due to the work flow
of the shrimp processing, briefly describe the next six steps (thawing, size
grader, peeling, razor slide, tumbler/de-veiner, and conveyor/cull table cover)
which a rapid automated process designed to convert shell-on shrimp to a peeled
and de-veined product form.
Fresh raw shrimp are
commonly treated with sulfites to prevent the oxidation of shell pigments from
forming a quality defect known as “black spot.” Mention that the ABC Shrimp Co.
has quality and inventory control procedures for incoming product plus specific
specifications regarding sulfites for frozen shrimp.
From the summary of the shrimp product making process, we may know
that probably there is not only one reason for the increasing level of the Enterobacteriaceae, the consequence may
be derived from consolidated conditions. It may caused by not totally
eliminated the bacterial pathogens and then it takes chance to growth; or
decontaminated by other bacteria due to process, and both of these happened
during the process. Conditions that can cause the bacterial level increase, such
as cooking temperature, cooking time, water, equipment and the plant
environment; if more than one part of the process goes wrong, the probably of
forming hazards in the end product will be higher.
1.
Cooking /
pasteurization temperature
As the
first reason, the cooking temperature or the cooking time has not reach the
safety level. Though they are less to happen, it still needs to take into
account. Mostly the ready-to-eat shrimps are processed by cooking (heat
processing) before it was packaged or put into container. And then the products
have to be pasteurized. Through the heating process and pasteurization can reduce
a large number of the bacterial pathogens, there still remains some resistant
pathogenic bacteria than cannot be eliminated through high temperature heating.
As it was shown in the factory plan, two cooking boilers
were found. Besides these, no other heating equipment or sterilization device
(such as UV light room for sterilization or other cold sterilization equipment)
were found in the factory plan.
So what is the adequate cooking temperature and time for the
shrimp that can kill most of the bacteria but will not affect the taste and the
texture of the shrimp? A study about the quality management programme based on
HACCP in cooked shrimp processing plant in Vietnam(2001), researcher has listed
out different temperature of cooking the shrimp will take different amount of
time for killing
the bacteria.
2.
Water that use in the
making process
Water safety is also an important part to the process. Whatever
the water is added as ingredient or using as an agent during the process (for
rinsing or cooling use), water still has a direct contact to the food product.
So if the quality of the water is not suitable for food processing, or
contaminated with some toxins or bacteria, will be cross-contaminate to the
food.
Suppose that may be the water for
washing and cooling process that contains the Enterobacteriaceae.
Since the Enterobacteriaceae is killed due to the high temperature cooking,
while using the cooling/ washing water that is not fit for the HACCP guideline
level. If the water contacts the food directly which contains the
Enterobacteriaceae may contaminate the food. The salmonella is not affected by
freezing among those Enterobacteriaceae (but the activity of E.coli will be reduced).
And one thing is that, there is no UV light room shown on the blueprint, it may
be reckoned that they did not use the UV light sterilization in the production
process. Thus, the probability that the shrimp is contaminated by the
salmonella is higher.
Water can be treated as a “food
ingredient/ agent” in the food processing. In the A Technical Guide to Food Hygiene provided by Macao Health Bureau, the
guideline suggested that if the water or ice being used in the food
processing or having direct contact with the food surface in food industries or
other food processing place, both the quality of water and ice should conform
to relative regulations stated in the Regulations on Water Supply and Drainage
of Macao. That means the quality of water is safe for people to drink.
The
microbiological and quality criteria for water that used in seafood processing:
In accordance with FDA's Good
Manufacturing Practices (GMP) regulations, 21CFR Part 110, all food process
water must be safe and suitable for its intended use. (Part 110.37(a)
Facilities, Water Supply: "The water supply shall be sufficient for the
operations intended and shall be derived from an adequate source." Part
110.80, (a)(1) Processes and Controls, Raw materials and other ingredients:
"...Water used for washing, rinsing, or conveying food shall be safe and
of adequate sanitary quality....")
In certain situations, "safe
and suitable" water may be water that is not of potable water quality but
is known to be sanitary and to pose no risk of chemical or biological
contamination to the food product. Any processor using such water, however,
must be able to demonstrate that the water is safe and suitable for the use.
3.
Condition, cleanliness and
function of
the equipment and machines :
For the equipment and the machines, since they will contact the food
directly. Those will be discussed in three
parts. In the washing/ cooling and grading/ peeling processes; those
utensils and equipment should be always keep clean and sterilized after use; if
they have been contaminated by the Enterobacteriaceae, it will cause the cross-contamination. And in the
packing part, the most likely to spread bacteria is a packaging machine.
The problem may be occurred in the freezer, when
dealing with the large batches of food in process, the equipment is needed to
fulfill the condition of cleanliness. If the freezer is not always cleaned and
checked whether there is ice cube or other foreign objects hide in the freezer, and that can become a good hiding place for the bacteria; also
the foreign bodies may affect the airflow distribution inside the freezer and
then the cooling effect was affected. Besides, if the flat packs of shrimp are
not cut in the same size or cut in different thickness, (as it was shown in the
fig) the packs will have a poor contact with the freezer plate (either too
thick to touch the freezing plate or too thin to make a gap with the freezer
plate); and the food packs are not freezing evenly and thoroughly. All the
reasons will lead to not freezing probably of the product and contamination of
bacteria.
4.
Distance between freezers
and plant room
The forth reason may cause the increasing of the bacteria is the
freezers are too close to the plant room, as the plant room produces lot of
heat, the one of the entrance is facing the space between the two freezers. Heat
spreads through convection and radiation may also affect the freezing process
of the food product and giving the chance for the bacteria to growth.
5.
Package material and method of
the product
The product may be using the modified atmosphere (MAP) and vacuum
packing (for the picture of the end product was shown in the question). The
picture was obviously shown that the product was not totally vacuumed. Also, it
the blue plan we cannot be clearly told that what kind of packing machine was
used in the factory. So we can consider and guess form the package that the
food product may be using the MAP packing.
The package of the product includes the PE (polyethylene) trays
and the PE films. No information of leakage was found in the question. And that
can be considered as PRPs of the process. Thus, the main reason of the
increasing level of Enterobacteriaceae may not relevant to this.
6.
Maintenance of hand washing, sanitation
and toilet facilities, Prevention of cross contamination (includes training, employee
practices and facility)
Even these are the minor ones
that are always neglected. Personal hygiene, the sanitation of toilets is
important control point in the hazard control plans. Keep the notices of
“flushing after use”; “wash your hands” can alert staffs to do so. Conduct
workshops regularly so as to educate the staffs that the importance of hygiene;
standardize operation practice are the main points of safe processing.
7.
Employee health.
The staff health is similar to the
personal hygiene. If a staff carries infectious bacteria (the staff becomes a
vehicle of transmission), not only contaminated food in the processes, that
will let bacteria transmitted to the consumers through the medium of food
product, and resulting in foodborne illness or food poisoning.
8.
Pest control:
Pest is also a common vehicle of
bacteria and virus. Always keep the food plant free of pest is very
important.
Combining all of the conditions above and
evaluating of them, the most possible to cause the increase level of Enterobacteriaceae among those are the water and the freezer. Because the increase of
bacteria level was latest occurred issue, not happened in the former products;
so we can infer that there may be something goes wrong in the water source; and
secondly, since the freezers are early placed near the plant room, the cooling
effect has been affected by the heat released from the plant room early in the
beginning.
In
order to anticipate implementing and managing, controls will be taken as
follow:
Using the logic of the CCP decision tree, the condition of water, i.e. the bacteria levels of the water can be refined to an acceptable level; and the freezing temperature of the
freezer. The
probability of the hazards can be decreased by
regulating these two conditions; so definitely they were the critical control points (CCPs). These conditions can be improved by human, coordinate with
periodic testing data; the situation of the product line can be well monitored.
Cold storage of the product
Though we suspect that the
freezing process was altered by the heat from the plan room, we should remind
that the recommended temperature for cold storage of fish and fish products in
the UK is -30°C and this
temperature has also been adopted throughout Europe. The recommended
temperature of FAO is more flexible, due to the size, time and the species of
the fishery product.
And The International Institute of Refrigeration
recommends a storage temperature of -18°C for lean fish such as cod and haddock
and -24°C for fatty species such as herring and mackerel. The code also recommends
that for lean fish intended to be kept in cold storage for over a year, the
storage temperature should be -30°C. For their storage life can be longer with
the storage temperature lower than -30°C.
From the following table from FAO, it shows that the
cooked/peeled shrimp can be store from - 18°C to - 30°C, depends on how long
will the manufactures sell out their products or distribute to wholesalers.
To solve the problem of
poor ventilation and heats comes out from the engine room, it is suggested to cover some Insulating materials outside the plant room, and
convert exit to a bit far away from the freezers, so that the heat from the
plant room are not easily to affect the freezing process through convection and
radiation. Install
several exhaust fans and louvers in the engine room, which will also improve
releasing the heat to another side so not to affect the temperature of the cold
storage.
Table 16
Practical storage lives (PLS) of fish products
|
Product
|
Storage life in months
|
|
|
- 18°C
|
- 24°C
|
- 30°C
|
|
Fatty fish (glazed)
|
5
|
9
|
> 12
|
|
Lean fish (fillet)
|
9
|
12
|
24
|
|
Flatfish
|
10
|
18
|
> 24
|
|
Shrimp (cooked/peeled)
|
5
|
9
|
12
|
Review the efficacy of control systems
Though the water is not the
main ingredient of the food product, the water is a media which has direct contact
with the food; it should be focus on the water safety as it was basically
consider in the HACCP plan, if it was sure that something went wrong in the
water, use the ISO2000 to standardize.
DATA and records, which
can reflect the result of the efficacy of the control
Monitoring
the records is important, it can be easily to know the products were last
produced has exceeded the critical limit or not. Always the records show out
the clues of the deviations. Make both the critical limit deviation and
corrective action to be documented. These steps are useful for adopting
solutions and referencing when similar situation occurs. The establishment of
critical limits is one of the most important steps of the HACCP principles.
Enforcement
of the critical control points of the product
The
flaws of the product occurred due to the human negligence. But the error was
discovered by the monitoring system (the accredited
contract laboratory of the food factory). So in this situation, strengthen the testing of the critical limits is the modifying
action to the CCP (bacteria level in the water). Thus, as mentioned above, the
ISO2000 water standard can
fully cover the control point of water safety. If the budget of regulating the
quality of the process is not much, then try to change to use the drinkable
water throughout the process.
Establish
a recordkeeping system.
According to the Fish and Fishery Products Hazards and Controls Guidance, fishery industries are recommended to keep records as it was
necessary. It is important to document the monitoring of the critical factors
of the brining or pickling process, as established by a study (e.g., a
processing record showing the results of the brine or acid strength and
temperature, brine or acid to fish ratio, size and species of fish, time of
brining or pickling); or record of determinations of the finished product water
phase salt, pH, or water activity.
Besides,
it’s important to remember that all corrective action records shall include the
following:
-
Product
identification (e.g., product description, amount of product on hold).
-
Description
of the critical limit deviation.
-
Corrective
action taken and final disposition of the affected product. This is a critical
learning objective. Take the time to make sure students understand proper
disposition of suspect product. This is a teachable moment and good time to
encourage class participation.
-
Date
and time of the correction.
-
Signature
or initials of the individual responsible for taking the corrective action.
The advantage
if using Corrective action procedures is that it can ensure that unsafe product does not reach the end user and the
problem that caused the critical limit deviation is corrected.
Enforcement of the prerequisite programs such as the SSOP (Sanitation
Standard Operating Procedures) After all, the prerequisite programs can be introduced into the process again for a new evaluation and
development of critical control points.
Conclusion
When monitoring shows that a critical
limit deviation has occurred, corrective actions should be taken for both short
term and long term fixes for process deviations. Reference to the effect of the
operating procedures of the HACCP relatively perfect, even if the production
line is a problem in a timely manner according to the guidelines to identify
the problems, safe practice guidelines to solve the situation, In addition, the
industry training is also an important part of the surveillance programme. From the study of S Suwanrangsi
(2000), concluded the implementation of a HACCP-based system and compliance
with HACCP-based regulations can help improve the product safety level,
decrease in total quality costs and increase in product quality. It still a
long road to regulate all the food enterprises with HACCP-based system and
HACCP audit, as the writer said those are essential management functions in
modern context of the fishery and other kinds of food industries.
References
COLD STORES. (1994) Freezing and refrigerated
storage in fisheries FAO Corporate
Document Repository.
Available at: http://www.fao.org/docrep/003/V3630E/v3630e08.htm
FDA
- Seafood HACCP -Including
Fish and Fishery Products Hazards and Controls Guidance and FDA's Evaluation of
the Seafood HACCP Program 2004/2005
Available at: http://www.fda.gov/food/foodsafety/hazardanalysiscriticalcontrolpointshaccp/default.htm
FISHERY
FOOD FDA Q&A
Available at: http://www.fda.gov/Food/FoodSafety/HazardAnalysisCriticalControlPointsHACCP/SeafoodHACCP/ucm194434.htm#IX
Freshwater
Fish Processing and Equipment in Small Plants. (1996) FAO Corporate Document Repository.
Available at: http://www.fao.org/docrep/w0495e/w0495E04.htm
H.M. Lupin, M.A. Parin et al. (2010). Economics in
fish processing plants. Southern Regional Centre, National Institute of
Industrial Technology (INTI), Scientific Research Commission of Buenos Aires
Province (CIC), Marcelo T. de Alvear, 1168 Mar del Plata, Argentina
Available at: http://www.flavorfood.com.br/artigos/aplicacoes_haccp/HACCP%20economics%20in%20fish%20processing%20plants0001.pdf
National Seafood HACCP Alliance for Training and
Education
Available at: http://seafood.ucdavis.edu/haccp/ha.htm
QUALITY
ASPECTS ASSOCIATED WITH SEAFOOD. (1994) Assurance of seafood quality FAO Corporate Document
Repository.
Sirilak Suwanrangsi (2000). HACCP implementation in
the Thai fisheries industry. Fish Inspection and Quality Control Division,
Department of Fisheries, Bangkok, Thailand.
Available at: http://www.thaiscience.info/Article%20for%20ThaiScience/Article/1/Ts-1%20haccp%20implementation%20in%20the%20thai%20fisheries%20industry.pdf
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