A client was concerned when a labeling and packaging stage was called a critical control point on a hazard risk worksheet. The following actual recall notice illustrates why this stage is indeed critical and must be controlled.
The producer of a peanut butter chocolate cake recently issued a voluntary recall notice, stating the product had been mislabeled as a chocolate chip cake. The product label did not include an allergen, peanuts, as a key ingredient nor did it include an allergen warning about the use of peanuts. The same producer has another chocolate cake product which only uses chocolate chips as the key ingredient. The labels were apparently confused during the labeling and packaging stage of production.
Note: This blog uses food safety information to reinforce the importance of monitoring and corrective action. It is not intended as a recall or regulatory notice so those details are not included. It is an excellent practice to stay subscribed to recall information. The following FDA (Food and Drug Administration) website provides current recall information as well as industry guidance for handling recalls:
A good point to this story:
While this problem might have been prevented, the producer appears to have reacted quickly. There appears to be an excellent recall plan in place. The recall notice was voluntary. The producer located the problem through proactive monitoring (the phase of production is noted: labeled and packaging), notified regulatory, consignees, and consumers, and took action to prevent any further concerns. The use of lot numbers on the transformed products enabled the company to quickly locate the products. Product photos and contact information were provided in the recall notice. Retraining and stricter monitoring will hopefully prevent any recurrence.
Why is this phase a Critical Control Point? Defined.
A critical control point is defined as a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level. The labeling and packaging phase of production is the last step before the product is distributed. If the transformed product label is inaccurate, incomplete, or misplaced, there is no opportunity to take corrective actions, to reduce, prevent, or eliminate a hazard. Thus, monitoring is vital to ensure that this production phase goes both efficiently and effectively.
Here are some ideas to consider:
- Monitor Ingredient Deliveries: In addition to routine safety and sanitation concerns with deliveries, monitor supplies for accuracy and the evidence of allergens. It is possible some suppliers might change their sources without warning or a supply may no longer be regulated or approved.
- Environmental Contamination: Some kitchens may have a variety of different productions occurring simultaneously. Different recipes may be produced in the same location. Space and equipment might be shared, creating a potential for cross-contamination. Whenever possible, prevent the incidental intermixing of allergens: use separate production times and locations; verify cleaning and sanitizing of equipment and surfaces between tasks; during rush periods, consider the use of additional personnel to avoid mistakes.
- Obtain Prior Label Approval: It is tempting to avoid the delays of regulatory approval, as well as using input from industry contacts. The label is a legal document, however, so plan to get prior approval. Keep a written copy of this approval.
- Monitor Production and Labeling: The responsible person in charge, not production line personnel, must approve the final product prior to distribution, assuring proper lot numbers and an accurate and complete product label. A second observer might find areas of concern as well as reinforcing good production practices.