Food Safety Summit Rewind: Product Inspection Solutions for FSMA Preparedness with METTLER TOLEDO's Jennifer Ball and Robert Rogers

At May's Food Safety Summit, METTLER TOLEDO's Jennifer Ball delivered a presentation titled Product Inspection Solutions for FSMA Preparedness. Food Manufacturing recently had the opportunity to correspond with Ball and MT''s Robert Rogers to discuss the top takeaways from the presentation.

During May's Food Safety Summit at the Donald E. Stephens Convention Center in Rosemont, Illinois, Food Manufacturing had the opportunity to attend several of the Solutions Stage presentations offered at the 18th annual event.

One of those presentations β€” Product Inspection Solutions for FSMA Preparedness β€” was delivered by METTLER TOLEDO Food Safety Specialist Jennifer Ball. According to the Food Safety Summit program, the presentation was designed to "provide an understanding of metal detection and X-ray process controls to meet the requirements of the FSMA."

Food Manufacturing had the opportunity to correspond with Ball and METTLER TOLEDO Senior Advisor of Food Safety & Regulations Robert Rogers after the Food Safety Summit and asked them to provide their top takeaways from the presentation. The following is their written response outlining the key aspects of the presentation:

Requirements of FSMA: A facility subject to the final rule must establish and implement a food safety system that includes a hazard analysis and risk-based preventative controls. This is to identify and evaluate known or reasonably foreseeable hazards for each type of food manufactured, processed, packed or stored at the facility to determine hazards requiring preventive controls. To prevent adulteration, the facility must identify and implement preventive controls to assure the identified hazards requiring these controls will be significantly minimized or prevented. The rule establishes requirements for a written food safety plan, hazard analysis, preventative controls, monitoring, corrective actions and corrections, verification, supply-chain program, recall plan and associated records.

HACCP requirements are considered the core of food safety management programs. Controlling hazards throughout the process is the goal rather than relying only on finished product inspections. Inspecting throughout the process reduces waste and results in easier root cause analysis, so that proper corrective actions can be implemented to prevent reoccurrence.

Hazard Analysis Risk-Based Preventative Controls (HARPC) is similar to HACCP on the surface, but having a HACCP plan does not mean you'll comply with HARPC requirements under FSMA. HARPC covers products encompassed under the FDA's jurisdiction with an exception to seafood and juice since they are covered under HACCP. HARPC includes hazard identification, preventive controls for process/food allergens/sanitation, supply-chain controls, recall plan, oversight and management of preventive controls (monitoring, corrective actions, corrections, and verification).

Metal Detection: Metal detectors work on a conductive principle where the presence of a conductive signal initiates the detection. Metal detectors are used to inspect both bulk unpackaged products along with packaged products in paper, cardboard, poly films and metalized films. Heavy aluminum foil packaged products are challenging due to the conductive nature of the aluminum foil. These products are often inspected with X-ray inspection for improved detection capability. 

Several factors effect metal detectors sensitivity such as metal detector aperture size, position of metal in aperture, types of metal, orientation, electrical interference, and product temperature. It is important to properly test your metal detector assuring the test pieces (ferrous, non-ferrous, and stainless steel) pass through the center of the aperture, since it is the furthest area from the receiving coils, rendering it the least sensitive area. The most rigorous test is performed by placing three test packs onto the line one after the other. The first test pack will have a test piece at the leading edge, the second test pack will have a test piece in the center, and the third test pack will have a test piece at the trailing edge. An alternative method would be placing the contaminated packs every other pack. This is to simulate a worst case scenario, and to test the memory reset function of the metal detector and reject device. Testing is successful when all contaminated test packs have been detected and rejected and all good packs have successfully passed. 

X-Ray: X-ray inspection systems' detection is based on density making them ideal for inspecting products packaged in conductive materials. In regards to foreign material detection, X-rays have the ability of detecting various metal types, bone, stone, glass and high density plastics. 

X-rays have the ability to do more than just contamination detection. The ability to count objects ensures there are no missing components to the package. Sometimes there are parts of the package that, if included in the inspection, could adversely affect detection capability. An example would be removing the metal bread tie and ignoring it so that the sensitivity algorithm can be maximized for improved detection capability. 

Other Things to Consider: Automatic reject systems, secure reject bins and reject confirmation can aid in minimizing human error when dealing with non-conforming product and should be considered to be aligned with industry best practices.  

Also, keeping records is mandatory regardless if they are manual or electronic. To an auditor: if it wasn't documented, it didn't happen. Not only does proper documentation save you in the time of an audit, but it also helps track your operational efficiencies and identify trends for continuous improvement. 


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