The most publicized recalls of unsafe foods involve food-borne illnesses: salmonella, listeria, E. coli, C. perfringens, etc. caused by unsafe processing, storage or handling of foods. These are dangerous and frightening events–both for the public and the responsible companies that face damaging consequences–which is what leads to their being widely publicized.
Events that don’t make the evening television news but that can be equally damaging are the “other” food safety challenges: contamination by material inclusions such as metal, glass, plastic and bone that can cause serious injury if ingested, and labeling errors where the wrong label is applied to a package or labels carry incomplete or incorrect content listings.
While less dramatic and newsworthy, these events are also regulated by FSMA, and can cause equally serious injury, damage to the brand image of the responsible producer and can lead to costly personal injury lawsuits in addition to any penalties imposed by regulators.
The majority of contaminations take place during the processing of a food product. High-speed deboning of chicken, for example, can leave small bone fragments in the meat, small metal pieces can be separated from blades, screens and other metal processing equipment components and plastic bits can become detached from product handling equipment. Unless detected, these contaminants, often smaller than the human eye can easily see, will pass through processing and enter the marketplace.
Labeling errors, on the other hand, are primarily due to human error. The wrong incorrect label can be loaded onto a labeler on the packaging line, and occasionally a skewed label will wrinkle during application, causing an important ingredient to be obscured and unreadable.
According to the FDA, such labeling errors are the source of about 43% of product recalls.
Failing to disclose an allergen or other potentially harmful ingredient can lead to dire consequences both for the consumer who suffers from the result and the food processor who is responsible.
Detection as a preventive control
FSMA stresses prevention as the key to food safety assurance and requires written prevention plans and preventive controls that assure that foreseeable hazards are minimized or prevented. These rules apply to preventing contamination and label errors as well as to potential sources of foodborne illness. It is essential that you include controls that can detect and prevent these defects from entering the marketplace in your preventive plan.
Preventing in-process contamination events from happening is virtually impossible. High-speed operations by their very nature sacrifice precision for productivity; bone fragments will inevitably be left in boned meats and high speeds will inevitably cause equipment to wear and experience damage. Regular and thorough maintenance of equipment may reduce instances of metal and plastic contamination, but never eliminate them.
The best preventive controls that can adequately address these potential contamination and labeling challenges are X-ray and metal detection systems that detect physical contaminants––even minute fragments of bone, metal and plastic––and machine vision systems that detect skewed and wrinkled labels and compare labels with product codes to ensure proper labeling.
