ALTHOUGH the final rules of the Food Safety Modernization Act (FSMA), which was signed into law in January 2011, are a wait-and-see game, the adoption of hazard analysis and critical control point (HACCP) principles are mandated within this act, and feed manufacturers will be required to implement preventative control measures in future Food & Drug Administration regulations.
The increased demand for animal protein globally also increases the pressure on producing better-quality feed ingredients. Several countries mandate HACCP plans. Adopting voluntary feed HACCP programs now can not only prepare companies for future FDA regulations but also help them remain competitive in a global market.
With FSMA, FDA is modifying its federal regulatory focus from one of responding to contamination to preventing contamination. As a scientific system, applying HACCP throughout the entire feed manufacturing chain will ensure that products are processed as safely as possible for both animal and human health.
Feed manufacturing businesses that want to establish a HACCP program will need to complete five preliminary tasks and then apply seven HACCP principles.
The preliminary tasks to successfully develop a HACCP program start with assembling a team of individuals from the company who bring to the table a vast amount of knowledge and resources, including written materials and company food safety documents. It is important to establish a network of outside experts who are available during the process.
Dr. Tim Harman, professor at Texas A&M University, recommended that a HACCP team should consist of individuals with multidisciplinary expertise who represent the company's different departments and each have a specific knowledge about the process and the product.
"Individuals on the HACCP team must represent the diverse activities and cost centers of the feed manufacturing process because HACCP involves a systematic approach to controlling the manufacturing process," Harman said. "It is important to have individuals involved in production on the team."
The HACCP team will be responsible for developing and implementing the HACCP plan and also for appointing the HACCP coordinator. The person selected should possess technical skills to develop the science-based plan, in addition to being an excellent communicator and manager.
The next two steps for the team are describing the animal feed product, including the method of distribution and defining the normal expected use of the feed. A written list of ingredients and raw materials for each process and product must be completed.
After the preliminary written information is finished, a flow diagram must be constructed. According to Harman, the ideal flow diagram should provide a clear, simple outline of all steps involved in the process.
The team should verify the accuracy of the diagram by actually walking through the site and documenting any modifications that are necessary. Defining how returned or reworked products re-enter the process flow is often overlooked when the first diagram is created.
Those preliminary tasks prepare the team to embark on the HACCP principles, which are the most essential steps in writing a HACCP plan.
The first two principles — conduct a hazard analysis, and identify critical control points (CCPs) — are the fundamentals of the HACCP plan. The remaining principles are dependent on results of the hazard analysis. These application steps of the HACCP plan provide structure for implementation in the actual processing plant.
The seven HACCP principles are:
1. Conduct the hazard analysis by developing a list of both animal and human hazards that could cause injury or illness if not effectively controlled. Any action or activity that can prevent, eliminate or reduce a significant hazard must also be identified.
2. Detect CCPs for any potential hazard classified in the hazard analysis as causing illness or injury. If it is determined that an identified hazard cannot be controlled, then the process may need to be redesigned or the product reformulated.
3. For each CCP, critical limits (CLs) must be established to indicate whether the CCP is "in" or "out" of control. CLs must be science based and derived from regulatory standards, experimental results of validated studies, scientific literature and experts.
4. A planned structure for observation or measurements to assess whether a CCP is under control and to produce accurate documentation for future verification must be established.
5. In the event that a CL is violated, a list of corrective actions must be created. The corrective action plan should give operators options they can implement in a given situation and indicate the accurate way to document whether corrective action was taken.
6. It is important to determine the validity of the HACCP plan and if the system is operating according to the plan by establishing a verification process.
7. A clear procedure for recordkeeping must be instituted.
In addition to the five preliminary tasks and seven principles, the production of safe feed products requires the HACCP plan to be built on a solid foundation of prerequisites based on FDA's good manufacturing practices and the Codex Alimentarius International Food Standards.
The proper prerequisite program should also be well documented, including standard operating procedures and sanitary standard operating procedures.
Good sanitation is the most vital prerequisite program because it enhances product quality, reduces maintenance costs and contributes to operational efficiencies.
Management should make it a priority to train employees and verify that standard operating procedures are being performed correctly.
Do-it-yourself HACCP program planning can be overwhelming, but training is available through educational institutes such as Kansas State University, Texas A&M and the University of Nebraska-Lincoln.