Nut Handling and Processing for Confectioners and Small Nut Roasters

1
Nut Handling and Processingfor Confectioners and
Small Nut Roasters

• Session 4 Role of Food Safety Programs in
  Assuring Safe Use of Nuts
• Tom Mackie, Food Safety Consultant to NCA
• Steve Calhoun, Food Safety Consultant to APC

Sponsored by
In partnership with
2
Nut Handling Processing for Confectioners and
Small Nut Processors

• Role of Food Safety Programs in Assuring Safe Use
  of Nuts

Steve Calhoun and Tom Mackie
3
Challenges for Nut and Confectionery Processors

• Handling contaminated raw commodities
• Old facilities with poor traffic flow
• Poor equipment design making it difficult to
  clean and inspect
• Lack of trained and dedicated resources
• Use of contract and temporary labor pool
• Reliance on co-manufacturers for critical process
  steps
• Low level of technology for quality and food
  safety systems support
• Change management to keep up with pressure for
  new product and new package development

4
Prerequisite Programs

• Regulatory Proposals
• PRP Overview
• Facilities , Personnel , Equipment
• Control of Raw Materials
• Sanitation Environmental Monitoring
• Traceability and Recall
• SSOPs and Process Controls

5
PRP Implementation

• Microbiological Control
• Hazard Analysis
• Chemical , Allergen Physical Hazards
• Documentation
• Training
• Verification
• HACCP

6
Proposed Changes to Food Safety Regulations

• Substantially increase regulatory burden, cost,
  and liability risks
• Increase frequency of food facility inspections
• Expanded access to company records and test
  results
• Mandated food recalls
• Written HACCP type plans
• Enhanced Traceability requirements
• Third party accreditation to food safety
  standards

7
Prerequisite Programs

• A range of programs that are necessary to set the
  stage for HACCP-based systems and to provide
  on-going support for these systems.

8
Prerequisite Programs Based on

• FDA current Good Manufacturing Practices (cGMPs)
• USDA/FSIS sanitation regulations

9
Prerequisite Programs

• Provide the basic environmental and operating
  conditions that are necessary for the production
  of safe, wholesome foods.

10
Examples of Common Prerequisite Programs

• Personal hygiene
• Training
• Supplier assurance
• Specifications
• Traceability recall

• Facilities design
• Production equipment controls
• Cleaning sanitation
• Chemical control
• Pest control

11
Examples of Prerequisite Programs

• Consumer complaint management
• Sanitation Standard Operating Procedures (SSOPs)
• Environmental monitoring program

12
Facilities

• Layout
• Buildings, premises, equipment, and personnel
  movements
• Segregation
• Clean and unclean zones
• Wet and dry zones
• Air handling

13
Facilities

• Separation of raw from processed including air
  flow
• Special attention to roof
• Master Sanitation Schedule
• Use of dry cleaning procedure as routine for risk
  areas
• Dry, Dry, Dry
• Nut residue accumulation removed as timely as
  possible
• Integrated pest control management

14
Personnel

• Health and hygiene
• Disease control and personal hygiene/dress code
• Hygienic practices
• Handling of materials
• Movement in facility
• Education and Training

15
Personnel Practices

• Should apply equally to contract employees
• Cross contamination prevention, limit traffic
  between raw nut and processed nut area

16
Poor employee practices may result in
microbiological, physical or chemical
contamination of foods.
17
Production Equipment

• Sanitary design principles
• Scheduled maintenance
• Calibration, where applicable
• Monitoring activities

18
Sanitary Design
Figure 3-1. Ends of a horizontal screw conveyor
always a potential area of stagnant product
build-up.
19
Sanitary Design
Figure 3-2. A flat surface that can collect
product (This should be eliminated or sloped).
20
Equipment

• Cold storage equipment monitored
• Raw Peanuts 1-5oC (34-41oF)
• 55-70 Relative Humidity

21
Inbound Material Control

• Documented Specifications
• Certificates of Analysis / Conformance
• Letters of Guaranty
• Supplier approval program
• Inbound material inspection
• Material receiving procedures
• Management of material storage

22
Supplier Assurance

• Document a material management program for all
  ingredients and packaging
• Conduct risk assessments for materials
• Decide which materials present the greatest risk
  to the business
• Determine how to audit suppliers
• Build strong relationships to enable regular
  communication with suppliers

23
Supplier Audits

• Who conducts the audits ?
• Make sure the auditor is trained
• Provide documentation of the audit
• How frequently should a supplier be audited ?
• Make sure the supplier is clear on all
  specifications and expectations
• Follow up on all recommendations and required
  corrective actions
• Assure the vendor provides timely notification of
  all changes to material , facilities , or process
  

24
Specifications

• Spec.s are documented , contractual requirements
• All critical food safety parameters must be
  included
• For nut materials these will include
  microbiological , aflatoxin and allergens
• All special handling requirements need to be
  documented in the spec.
• Assure spec.s are controlled documents

25
Specification Categories

• Moisture
• Microbiological bacteria , molds
• Rodent or insect evidence
• Foreign Materials shell , twigs/wood, metal
• Chemicals aflatoxin , pesticides
• Allergens
• Sensory color , flavor
• Nut Quality size , broken pieces , damage

26
Microbiological Limits

• USDA Commodity Micro Requirements for Peanut
  Butter

Salmonella Negative
E. Coli lt3.6/g MPN
Coliform lt10/g MPN
Aerobic Plate Count lt10,000/g
Yeast lt100/g
Mold lt100/g
27
Material Receiving Storage

• Material receiving procedures such as checks for
  seals COAs and sampling
• Dock space and material protection
• Bulk unloading and handling equipment
• Isolation of raw commodities
• Control of allergen cross contact potential
• Warehouse space and conditions
• Handling of non-conforming materials

28
Nut Processors

• Crop sources
• Harvest conditions
• Storage conditions
• Shelf life impact
• Lab capabilities micro, chemical ,aflatoxin
• Allergen cross contact at shellers
• Intermediate handlers / co-processors

29
Confectioners

• Nut supplier locations
• Packaging used for nut ingredients
• Shipping and handling prior to delivery
• Receiving practices at your sites
• Product turnover during processing
• Intermediate products and rework

30
Environmental Sanitation

• Know the facility layout wet and dry areas
• Dedicated tools and cleaning equipment
• Lean manufacturing approach
• Control traffic patterns throughout the process
  facility raw product containment is critical
• Rely upon documented cleaning and sanitation
  schedules and procedures
• Use product contact surface sampling to verify
  sanitation effectiveness
• Use environmental swab testing for pathogens

31
Equipment Cleaning and Sanitation

• Dry cleaning in nut and confectionery processes
• Continuous operations and shut down periods
• Wet clean systems such as CIP and COP
• Focused wet cleaning of equipment
• Product build up and biofilms
• Access to clean and to inspect the job
• Application of sanitizers
• Swab tests and bioluminescence / ATP kits
• Impact of GMPs and personal hygiene

32
Environmental Swab Program

• Where and how to sample using sponges
• Frequency of swab sampling
• How to react to a positive pathogen result
• Control reporting and communications
• Confirm external lab credibility
• Expect programs to be implemented at suppliers
  and co-processors

33
Product Testing

• Product contact surface sampling protocols
• Raw materials monitoring
• Intermediate ingredients
• Rework
• Finished product composites
• Composite breakdowns
• Resampling and retesting
• Returned product and retained samples
• Strong hold management system

34
Traceability and Recall Program

• Crisis response plan and team
• Lot coding and records
• Distribution records
• Product disposition
• Mock recalls
• FDA regulation (21 CFR 1)
• Requires records identifying immediate previous
  source and immediate subsequent recipient

35
SanitationRegulatory Requirements

• FDA Current Good Manufacturing Practices (21
  CFR 110)
• SSOPs

36
SSOPs in FDA HACCP Regulations 21 CFR Parts 120
and 123

• 1) Water safety
• 2) Cleanliness of equipment, tools, product
  contact surfaces
• 3) Prevention of cross-contamination
• 4) Hand washing sanitizing, toilet facilities
• 5) Protection from chemical, biological and
  physical contaminants
• 6) Control of toxic compounds
• 7) Employee hygiene
• 8) Pest control

37
SSOPs in FDA HACCP Regulations 21 CFR Parts 120
and 123

• Implementation
• Monitoring sanitation activities in the key
  areas.
• Record-keeping
• Records must be kept to show the monitoring of
  activities and any corrections taken.

38
SSOPs

• Should identify daily pre-op procedures
• Should identify daily operational procedures
• Should be signed and dated
• Establishment should initiate corrective and
  preventative actions
• Daily records should be maintained

39
Process and Controls

• Validate kill step
• Do not use same equipment (conveyors, containers,
  etc.) for unprocessed and processed, including
  blanched nuts
• Process disruptions remove product
• Control nut dust and other nut debris
• Assure nut foreign material removed

40
Process and Controls

• If a processed product sample tests positive for
  Salmonella, the tested lot is considered
  adulterated and should not be released into
  commerce
• Positive lots may be reprocessed , but ONLY when
  run through a VALIDATED process
• It is critical to review adjacent lots to confirm
  a clean break between a positive lot and one or
  more lots designated as clear to release

41
Process and Controls

• Purging contaminated peanut butter lines with hot
  oil
• Validate procedure
• Recent study suggests it takes 42/- 8 minutes at
  90oC (194oF) for a 5 log reduction of Salmonella
  for a mixture of three outbreak-associated S.
  Tennessee strains in peanut butter (Doyle, May ,
  2009)
• 4912 min were needed to inactivate a composite
  of other Salmonella isolates

42
Process and Controls

• Traceability
• Finished product traceable to raw material lots
  used
• Consideration should be given for a routine clean
  break for bulk or continuous nut and nut butter
  operations

43
Microbiological Control GMA Guidance Document

• Prevention
• Hygiene Practices and Control
• Hygiene Design of Buildings and Equipment
• Moisture Control, Minimizing growth, Dry Wet
  Cleaning Practices
• Raw Material Programs
• Validation of Control
• Verification of Controls Corrective Actions
• www.gmaonline.org/science/SalmonellaControlGuidanc
  e.pdf

44
Chemical and Physical Hazards

• Aflatoxin and other Mycotoxins
• Pesticide Residues
• Heavy Metals
• Unintended Food Allergens
• Foreign Materials

45
Proper implementation of prerequisite programs
simplifies the development of a HACCP Plan.
46
Prerequisite Programs Should Be

• Well-documented with written SOPs
• Adhered to by all employees
• Reviewed and revised as needed
• Effective in accomplishing objectives

47
Establishing Prerequisite Programs

• Documentation
• What procedures should be performed?
• At what frequency?
• Who has responsibility?
• What actions should be taken if
• a procedure is not performed as required?
• there is an unexpected outcome?

48
Establishing Prerequisite Programs

• Employee training
• Continuing education
• Important to understand and follow assigned tasks
• Provide time and materials for training
• Verify by reviewing performance

49
Verification of Prerequisite Programs

• Periodic review of the SOPs and audit reports to
  ensure that the programs are operating in a
  manner that should not require a change in the
  hazard analysis or HACCP plan.

50
Establishing Prerequisite Programs

• Verification
• Is the SOP performed in the manner intended?
• Is the procedure monitored?
• Are appropriate records kept?
• Is there an independent audit?
• Are programs revised as necessary?

51
Establishing Prerequisite Programs

• Resources
• Are the proper tools/equipment available?
• Are appropriate personnel available to perform
  the task effectively?
• Are systems adequate for monitoring and storing
  data?

52
Prerequisite Program or HACCP?
Prerequisite Programs HACCP Plans
Deal indirectly with food safety issues Deal solely with food safety issues
Cross multiple product lines Specific to product line
Failures seldom result in food safety hazards Deviations must be considered potential food safety hazards
53
Prerequisite Program or HACCP?

• Depending upon the results of the hazard analysis
  and identification of control measures, some
  activities normally addressed in prerequisite
  programs may be included in the HACCP plan.

54
Summary

• Understand all legal and regulatory requirements
  for nut handling processing
• Know the important PRPs that form the foundation
  for food safety and HACCP
• Regularly train the employees that are
  accountable for program implementation
• Verify all food safety programs perform to
  protect customers and consumers

55
Questions?

• For QAs and Food Nut Safety Resource Guide
• http//www.ecandy.com/Content.aspx?ContentID7134