FSA and EFSA food safety legislations, retailer codes of practice (COPs) and BRCGS standards can often leave food manufacturers unsure of the food safety systems required. Does the law insist on having a metal detector on your production line? If so, where? Will retailers still stock your product if they haven’t been inspected by X-ray? Does BRCGS need to grant approval confirming that your equipment is HACCP compliant and safe?
Phil Brown, Sales Director at Fortress Technology Europe shares his extensive expertise on navigating the minefield of food safety standards, who needs to authorise what, and where to find out more about the food safety audit process.
WHO SETS THE STANDARDS?
The Food Standards Agency (FSA) is responsible for providing the framework for all food legislations in the UK. While they work alongside local authorities to enforce food safety regulations, the entire supply chain plays a role in upholding food safety standards. However, as a food manufacturer, how do you ensure your meeting the right requirements? Especially when considering multiple retailer COPs and food safety certifications.
“Ultimately, the food safety standards enforced by the FSA outline the specific details of meeting the Codes of Practice set by retailers. The codes will tell you what you need to do in order meet their requirements, and the standards will tell you how to do it,” states Phil.
For example, the FSA necessitates the use and outlines the process of Hazard Analysis and Critical Control Point (HACCP) planning to ensure food safety standards are met. These standards don’t specify the use of metal detection equipment, but instead instruct food processors to conduct a comprehensive risk assessment of all potential food safety hazards. For the majority of food manufacturers, metal is the most likely physical contaminant risk and therefore warrants the implementation of a metal detector as a hazard control measure.
On the other hand, retailers may stipulate that a food manufacturer’s production line includes a metal detector, even specifying where the inspection system should be integrated. “With new food safety values emerging relating to transparency and traceability, retailer COPs are becoming increasingly stringent. Despite the FSA not requiring the use of X-ray inspection, many retailers are now stipulating X-ray inspection in order for them to sell your food product,” adds Phil. In some instances, this is a ‘cover all the bases’ approach, and through a better understanding of the risks may not be warranted.
FOOD SAFETY SEAL OF APPROVAL
For many, navigating these confusing and sometimes contradictory demands from governing bodies and retailers can be daunting. Especially given that badges offer a symbol of confidence.
Inevitably, food processors and contract packers will turn to trusted food safety mentors to ensure that they are meeting the government standards.
GFSI-recognised certifications can assure food processors that they are complying with both regional and international food safety laws, as well as meeting multiple retailer COPs. Founded in the early 2000s to restore trust after many food safety crises, the GFSI is an international industry body that compiles and harmonises existing food safety management requirements by setting stringent norms to establish a benchmark.
However, GFSI do not conduct food safety audits or certify food businesses. Instead, auditing and food safety certifications are managed by Certification Program Owners (CPOs) who meet the GFSI’s benchmarking requirements.
The brand recognition received when working with a chosen certification body will determine how widely accepted the food safety certification will be. The most highly regarded CPOs include BRCGS, IFS, FSSC 22000 and SQF. For food manufacturers and retailers alike, this recognition implies a ‘once certified, worldwide recognised’ message.
CERTIFICATION CREDIBILITY
Achieving certification through a globally recognised third party auditor may assist a food manufacturer to add legitimacy to their food safety program and establish credibility throughout their entire supply chain.
Although certification from GFSI auditing bodies isn’t essential from a regulatory point of view, some major retailers may insist upon it. Additionally, many retailers set their own auditing processes and extensive approval programs, as well as demanding GFSI-recognised CPO certification.
This presents processors with a double-edged dilemma. If certification helps you to retain a valuable retailer contract and the rewards are worth the investment, you may be justified in viewing this as a business necessity, suggests Phil.
UK retailers establish their own requirements and codes of practice for foreign object prevention and detection.
COP-COMPLIANT INSPECTION SYSTEMS
When looking for food inspection equipment, it is important to thoroughly examine your risks in line with HACCP standards. The severity and likelihood of a physical contaminant risk will then determine the appropriate control measures to implement. Most likely, a food processor will need some form of food inspection machinery. However, the detection sensitivity levels will depend on the specific food application and risks involved.
HACCP planning involves using control measures that prevent, eliminate or reduce a food safety hazard to an acceptable level. These are referred to as critical limits and are the maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled. The sensitivity level of an inspection system must therefore align with the contaminants critical limits.
To assure the highest level of food safety possible for their customers, UK retailers also establish their own requirements and codes of practice for foreign object prevention and detection. This includes prescribing the sensitivity levels expected from inspection machinery. For example, typical guidelines for the detection sensitivity of a metal detector with an aperture height of up to 50mm is 1mm for ferrous and non-ferrous metal and 1.5mm for stainless steel.
Some of the most stringent food safety requirements have been developed by the leading UK supermarkets. For example, food safety guidelines can specify the type of foreign object detection system to use, how it should be audited, what records must be kept, and what the desired sensitivity is for various size metal detector apertures. One leading retailer’s document also specifies when an X-ray system should be used instead of a metal detector.
Those that meet these well-regarded standards can generally enjoy the assurance that their food safety program is robust enough to meet the requirement of all major retailers. At the same time, providing the best possible brand protection.
Following an auditing checklist can help a processing facility to measure conformance against set standards.
SYMBOL OF CONFIDENCE
Enhancing food safety in supply chain management involves ensuring that all people, processes, and technologies are aligned. However, in the event of a food safety recall, it is the retailers responsibility to quickly remove the affected products from their shelves and inform their customers about the issue. Additionally, the FSA is responsible for investigating and taking action to prevent a recurrence of the threat, as well as communicating this food safety information to the public.
Given these responsibilities, the FSA and retailers are understandably strict on standards. “While a food recall has the possibility to damage a food manufacturer’s brand, ultimately, the responsibility of handling one falls on the retailers and the FSA’s shoulders,” Phil clarifies.
The most common question Fortress is asked when processors see the BRCGS badge on the side of a metal detector, X-ray or checkweigher, is “great, this must mean this machine is BRCGS-certified?” Given the statutory food safety minefield, it is of course a very valid question. Phil summarises: “The badge itself is a recognised symbol of confidence. It provides the assurance that all Fortress Technology inspection systems have all been manufactured in line with GFSI and HACCP standards. However, it is not certifying the placement of a specific machine on a specific food processing line. That can only be determined by each processor conducting a comprehensive HACCP risk assessment.”
Providing further clarification, Fortress Technology recently published a Food Equipment Audits Whitepaper. Download a free copy from https://fortresstechnology.co.uk/food-equipment-audits/.
