Is it a Risk? Is it a Hazard? What's the Difference?

As I talk to people about FSMA and other food safety regulations, I am constantly asked the difference  between a risks and hazards.

As FSMA comes into effect there is going to be a lot more emphasis on systems that put in prevention programs..."

Under the proposal, each owner, operator or agent in charge of a facility (those required to register with FDA under Section 415 of the FD&C Act), with certain exceptions, would be required to comply with the hazard analysis and risk-based preventive controls. The preventive controls are science- and risk-based in that the rule would require controls only where necessary to prevent hazards to public health and exempt certain facilities from requirements or modify requirements for certain low-risk activities. Second, they are flexible in that firms could develop preventive controls that fit their products and operations, as long as they are adequate to significantly minimize or prevent all food safety hazards that are reasonably likely to occur."

Risks are the big picture.  From 3000 feet in the air, places like FSIS look at the public health impacts of various risks.  The FDA has also identified a lot of different risks in the food chain.

• Food from unsafe sources
• Inadequate cooking
• Improper holding time and temperature
• Poor personal hygiene

The FDA has identified 5 interventions, outlined in the Food Code, that inspectors look at during assessments of plants to ascertain the level of management control over those risks.

• Demonstration of Knowledge
• Implementation of Employee Health Policies
• Hands as a Vehicle of Contamination
• Time/Temperature Relationships
• Consumer Advisory

Essentially if a plant can show that the food safety systems use the interventions to mitigate risk, the FDA deems the food fit to eat. Many scientists over many years and with a lot of money investigated just where in plants food risks come from and came up with that list.


So using the FDA Food Code risks, we can identify some hazards.  For example

Risk: Food from unsafe sources (for example, leafy greens that are picked in unsanitary conditions) 
Hazard: E. coli
Intervention: Approved supplier program can make this not reasonably likely to occur (remember, critical control points control hazards, pre-req programs make hazards NRLTO).  This would be a knowledge based intervention

Risk: Inadequate cooking (let's take eggs) 

Hazard: Salmonella 
Intervention: Cooking shell eggs to 145F for 15 seconds, or to 160 if they are with other foods.  This is an example of a critical control point. There's going to be nothing else after the cooking step that would kill salmonella.  This would be a time/temperature intervention.  A consumer advisory intervention would be telling consumers that eating undercooked eggs can make them sick.

Risk: Improper holding time and temperature (for example, cooked veggies in a sauce in a buffet)
Hazard: Staph aureus intoxication
Intervention:  This one actually needs several.  First, a time/temperature intervention of keeping hot foods hot and out of the staph danger zone, this would be a critical control.  Second, employee health policies need to emphasize not handling food with open cuts, need a pre-req program that complies with GMPs here.  And third, understanding how hands are a vehicle for contamination and emphasizing hand washing, again a pre-req program on personal hygiene.

As FSMA comes into affect, FDA regulated entities are going to have to catch up to USDA regulated entities.  Written food safety plans that take scientifically developed risks and delineate the hazards that come out of those risks will be required.  DQM is set to help small growers and processors cope with the coming onslaught.  Call today for your free phone consultation and ask for Dr. P.  90-907-7798

Charcuterie For the Small Processor

DQM spent the weekend at the New England Meat Conference.  It was a fantastic gathering of entrepreneurs, producers, processors, chefs, meat cutters and just about anyone else working to create the New England market for local meats.

And if there was one over riding interest after "isn't this cool?  All the people I know and like are in one place!!" it was charcuterie.

From a food safety perspective, charcuterie is challenging.  But hey!  Let's break it down!  Food safety challenges are what we do here at DQM!  The following is by no means an exhaustive list, but, it is a good start.

First- figure out what you want to make.  And don't just say sausage.  Do you want to make Spanish sausage?  Mexican?  Polish? The more specific you define your product the easier it is going to be.  You need a recipe.  Even if it is your grandmother's that you used to make in the basement, you need to know what and how much is going into the product

Second- Understand what process steps are.  When you write a HACCP plan, you need to have a process flow diagram.  And your commercial charcuterie production needs to have one full of excruciating detail.  You are going to get inspected on how well you adhere to this flow, and if you don't, there can be huge consequences.  Make sure your process flow diagram starts with Receiving Meat.

Third- Once you understand what you are making and how, then start thinking about the whole food safety plan including pre-req programs, the HACCP plan itself, training, and what avenue of inspections are available.

Putting a delicious and safe charcuterie product in the marketplace is absolutely possible.  However, it takes attention to detail, and frankly, is tough to do without some help.  When you are ready to take that step, give DQM a call, and we will be right there with you to put your wonderful product into the marketplace!

Developing a HACCP

As America's food system becomes more professionalized and distribution channels widen, small producers and plants have an opportunity to move into new markets.  Consumers are looking for safe, wholesome food, and entrepreneurs are stepping up to provide new products, or put an new twist on established products.

Food however, exists in a regulatory framework.  If you want to make money selling food, someone is going to regulate you.  And whomever that someone is, you are going to have to satisfy them that your food safety plan is adequate to the task of keeping your product safe and wholesome.

Enter HACCP.  Back in the dawn of the food safety movement as it currently exists, some smart folks figured out that testing final product for pathogens was a really expensive, and not terribly effective way of keeping food safe.  So, they came up with a scheme called HACCP.  Hazard Analysis for Critical Control Points.  HACCP plans were first implemented in a regulated way at the FDA with seafood and juice.  Then the USDA adopted HACCP planning for its plants, and no one has ever looked back.

But HACCP is more than just a process diagram.  It is a way of thinking and planning on how to keep your product safe starting before it even comes to your loading dock.  HACCP allows your food safety team to manage your production process to keep the plant and people healthy.  And therein lies one of the keys to HACCP, and to food safety in general: teamwork.  From top to bottom in the company, people must be on board with creating safe food.  The executives must understand how safe food contributes to the bottom line (how expensive would a recall be??) and the line workers must know why the SOPs are there, why and how to follow them.  Food safety isn't just a checkoff list (though, those help a ton).  It is a thought process and corporate culture.

If you are interested in a piece on how to write a HACCP plan, drop me a line at michele<at>dirigoqualitymeats<dot>com.

Welcome to DQM!

Ahhh, a new business and a bright shiny new blog page.  Both are a world of possibility.

This blog will focus on the core competency of Dirigo Quality Systems; helping producers (farmers, livestock growers, dairies) and processors create safe wholesome food to improve and grow their presence in the market place.

Who is the target audience?  Small producers who wish to professionalize their farming systems.  Medium size producers who recognize that safe food means business security and ultimately growth.

So stay tuned!  Like us on FaceBook, subscribe to the blog via email below, and tell your friends to come visit.