This summer my wife, Janice, and I drove across Canada in our RV and stopped into numerous food technical centres on our way. Although all of the places we visited are doing well, they all commented that food processors in their province were in survival mode and reluctant to investment spend for the future. It’s in such times that executives find themselves having to make serious business decisions involving food safety that can put their company at risk, or, as the old cliché goes, places them “between a rock and a hard place.”
In tough times, food processors can find themselves working to the lowest common denominator, including doing some or all of the following:
• Working to the letter of the regulations and no more.
• Minimizing the number of samples taken and tests performed to cut costs.
• Testing until a good result is obtained and then releasing the product.
• Pushing equipment and personnel beyond limits of safety.
• Postponing capital projects designed to improve food safety.
• Looking for bargains on ingredients, packaging and distribution.
• Reformulating to lower costs at the expense of quality.
• Expanding tolerances on specifications to reduce the amount of “out-of-spec” product.
• Eliminating training on food safety.
• Replacing full-time production and QA/QC staff with part-time staff.
• Cutting back on sanitation programs.
• Cutting back on internal and supplier food safety audits.
It’s all part of the harsh commercial realities processors are now facing. But there are options for dealing with this situation.
The Letter of the Law
Food processors need to understand that Canadian Food Inspection Agency (CFIA) regulations may only be minimum requirements. The regulations assume that other variables are in control and that the processor will do everything necessary to mitigate a food safety hazard. A good (or bad) example is the old Listeria regulation.
Processors must be aware of all the risks inherent to the processes used and products manufactured. Processes and products that pose lower food safety risks, like raw foods that must be cooked, can be managed within CFIA guidelines. However, foods such as ready-to-eat meats require the processor to go beyond the minimum published standards to assure consistent food safety. For example, it’s essential to develop and implement validated product and environmental sampling programs that tell you that you may have a problem before the product is distributed.
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