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Ensuring Regulatory Compliance for Flavor Companies

By: Patty Benson, SAFC
Posted: January 9, 2009, from the January 2009 issue of P&F magazine.

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Following an evaluation process that led to the reshuffling of activities both domestically and overseas, it was determined that an investment was need to upgrade packaging stations, install a controlled HVAC system, flooring, receiving docks and lighting, replacement windows and cooler, and other general facility maintenance.

Policy Upgrades

Using an existing ISO 9001:2000-certified quality management system as the backbone for our enhancements to meet food safety standards, representatives from the company’s quality assurance departments at each respective site led the policy upgrade project. Following evaluation, the standards identified that required improvement or further definition included our pest control policy, food sanitation policy and glass policy. Several lower-level procedures were also identified for revision, including the need to establish a food safety committee and an HACCP program.

Project “owners” were then assigned to develop or revise the identified policies and procedures, and timelines for approval were established. A cross-functional food safety committee was set up at each site, including personnel from quality assurance, quality control, operations, engineering and maintenance. The food safety committee developed the HACCP program at both sites that was responsible for identifying program concerns, driving improvement initiatives, and generally maintaining the ongoing food safety program.

Vendor Qualification

When the majority of one’s flavor and fragrance products are purchased from vendors, a robust vendor management system is key to certifying products as “food grade” and enabling timely delivery to customers at a competitive price. This requires that purchasing departments lead the vendor qualification improvement project. This team should develop a system that includes a comprehensive vendor questionnaire, a risk-based on-site vendor audit program, and a vendor performance measurement metric. Key to this process is ensuring that the vendors supplying products comply with applicable regulations and industry standards. Our company had strong vendor relationships in place and this, along with the purchasing team’s persistence in qualifying each vendor, was indispensable to this effort being successful. In the end, one’s program should certify that vendors have the capability to provide customers with the necessary documentation, including information and certification on genetically modified organisms (GMO), allergens, natural status, etc. In addition, a strong QC testing program must be in place to ensure that all product lots meet purity, identity and heavy metals requirements.

Personnel Practices To improve personnel responsibilities and training, job roles must be developed, training plans designed and training programs delivered. A key fundamental requirement to the success of any improvement plan is cultural change within the organization. Those new to the food industry environment must acclimatize themselves to the unique standards of cleanliness, documentation, and material control, which differ from the research chemical business. Acting under operations and quality assurance teams, an education program should be deployed. Of course, adding personnel with previous food manufacturing experience to the operations and quality assurance groups can bring best practices to facilities, emphasize the importance of compliance and enhance the cultural atmosphere.

Maintenance of the Improvement Program

AIB standards rely upon an ongoing internal audit program to maintain compliance and identify areas for further improvement. Individual site management should look for areas for improvement and address corrective actions through planning and implementation. In the case of SAFC, each site’s quality assurance team is responsible for maintenance of the internal audit program, though auditors from several areas participate using a cross-functional approach that allows numerous parties to evaluate areas and share new ideas and best practices. The food safety audit program is supplemented by an internal audit program carried out to maintain the ISO 9001:2000 certification held by each site. Auditors outside of the food safety committee perform these audits and are able to provide input based on general quality management systems.