Nut Handling and Processing for Confectioners and Small Nut Roasters

1. Nut Handling and Processingfor Confectioners and Small Nut Roasters Sponsored by: Session 4: Role of Food Safety Programs in Assuring Safe Use of Nuts Tom Mackie, Food Safety Consultant to NCA Steve Calhoun, Food Safety Consultant to APC In partnership with:

2. Nut Handling & Processing for Confectioners and Small Nut Processors Role of Food Safety Programs in Assuring Safe Use of Nuts Steve Calhoun and Tom Mackie

3. Challenges for Nut and Confectionery Processors • Handling contaminated raw commodities • Old facilities with poor traffic flow • Poor equipment design making it difficult to clean and inspect • Lack of trained and dedicated resources • Use of contract and temporary labor pool • Reliance on co-manufacturers for critical process steps • Low level of technology for quality and food safety systems support • Change management to keep up with pressure for new product and new package development

4. Prerequisite Programs • Regulatory Proposals • PRP Overview • Facilities , Personnel , Equipment • Control of Raw Materials • Sanitation & Environmental Monitoring • Traceability and Recall • SSOPs and Process & Controls

5. PRP Implementation • Microbiological Control • Hazard Analysis • Chemical , Allergen & Physical Hazards • Documentation • Training • Verification • HACCP

6. Proposed Changes to Food Safety Regulations • Substantially increase regulatory burden, cost, and liability risks • Increase frequency of food facility inspections • Expanded access to company records and test results • Mandated food recalls • Written HACCP type plans • Enhanced Traceability requirements • Third party accreditation to food safety standards

7. PrerequisitePrograms • A range of programs that are necessary to set the stage for HACCP-based systems and to provide on-going support for these systems.

8. Prerequisite Programs Based on: • FDA current Good Manufacturing Practices (cGMPs) • USDA/FSIS sanitation regulations

9. Prerequisite Programs • Provide the basic environmental and operating conditions that are necessary for the production of safe, wholesome foods.

10. Facilities design Production equipment controls Cleaning & sanitation Chemical control Pest control Personal hygiene Training Supplier assurance Specifications Traceability & recall Examples of Common Prerequisite Programs

11. Examples of Prerequisite Programs • Consumer complaint management • Sanitation Standard Operating Procedures (SSOPs) • Environmental monitoring program

12. Facilities • Layout • Buildings, premises, equipment, and personnel movements • Segregation • Clean and unclean zones • Wet and dry zones • Air handling

13. Facilities • Separation of raw from processed including air flow • Special attention to roof • Master Sanitation Schedule • Use of dry cleaning procedure as routine for risk areas • Dry, Dry, Dry • Nut residue accumulation removed as timely as possible • Integrated pest control management

14. Personnel • Health and hygiene • Disease control and personal hygiene/dress code • Hygienic practices • Handling of materials • Movement in facility • Education and Training

15. Personnel Practices • Should apply equally to contract employees • Cross contamination prevention, limit traffic between raw nut and processed nut area

16. Poor employee practices may result in microbiological, physical or chemical contamination of foods.

17. Production Equipment • Sanitary design principles • Scheduled maintenance • Calibration, where applicable • Monitoring activities

18. Sanitary Design Figure 3-1. Ends of a horizontal screw conveyor – always a potential area of stagnant product build-up.

19. Sanitary Design Figure 3-2. A flat surface that can collect product (This should be eliminated or sloped).

20. Equipment • Cold storage equipment monitored • Raw Peanuts 1-5oC (34-41oF) • 55-70% Relative Humidity

21. Inbound Material Control • Documented Specifications • Certificates of Analysis / Conformance • Letters of Guaranty • Supplier approval program • Inbound material inspection • Material receiving procedures • Management of material storage

22. Supplier Assurance • Document a material management program for all ingredients and packaging • Conduct risk assessments for materials • Decide which materials present the greatest risk to the business • Determine how to audit suppliers • Build strong relationships to enable regular communication with suppliers

23. Supplier Audits • Who conducts the audits ? • Make sure the auditor is trained • Provide documentation of the audit • How frequently should a supplier be audited ? • Make sure the supplier is clear on all specifications and expectations • Follow up on all recommendations and required corrective actions • Assure the vendor provides timely notification of all changes to material , facilities , or process

24. Specifications • Spec.’s are documented , contractual requirements • All critical food safety parameters must be included • For nut materials these will include microbiological , aflatoxin and allergens • All special handling requirements need to be documented in the spec. • Assure spec.’s are controlled documents

25. Specification Categories Moisture Microbiological ; bacteria , molds Rodent or insect evidence Foreign Materials ; shell , twigs/wood, metal Chemicals ; aflatoxin , pesticides Allergens Sensory ; color , flavor Nut Quality ; size , broken pieces , damage

26. Microbiological Limits • USDA Commodity Micro Requirements for Peanut Butter

27. Material Receiving & Storage • Material receiving procedures such as checks for seals ; COAs and sampling • Dock space and material protection • Bulk unloading and handling equipment • Isolation of raw commodities • Control of allergen cross contact potential • Warehouse space and conditions • Handling of non-conforming materials

28. Nut Processors • Crop sources • Harvest conditions • Storage conditions • Shelf life impact • Lab capabilities ; micro, chemical ,aflatoxin • Allergen cross contact at shellers • Intermediate handlers / co-processors

29. Confectioners • Nut supplier locations • Packaging used for nut ingredients • Shipping and handling prior to delivery • Receiving practices at your sites • Product turnover during processing • Intermediate products and rework

30. Environmental Sanitation • Know the facility layout ; wet and dry areas • Dedicated tools and cleaning equipment • Lean manufacturing approach • Control traffic patterns throughout the process facility ; raw product containment is critical • Rely upon documented cleaning and sanitation schedules and procedures • Use product contact surface sampling to verify sanitation effectiveness • Use environmental swab testing for pathogens

31. Equipment Cleaning and Sanitation • Dry cleaning in nut and confectionery processes • Continuous operations and shut down periods • Wet clean systems such as CIP and COP • Focused wet cleaning of equipment • Product build – up and biofilms • Access to clean and to inspect the job • Application of sanitizers • Swab tests and bioluminescence / ATP kits • Impact of GMPs and personal hygiene

32. Environmental Swab Program • Where and how to sample using sponges • Frequency of swab sampling • How to react to a positive pathogen result • Control reporting and communications • Confirm external lab credibility • Expect programs to be implemented at suppliers and co-processors

33. Product Testing • Product contact surface sampling protocols • Raw materials monitoring • Intermediate ingredients • Rework • Finished product composites • Composite breakdowns • Resampling and retesting • Returned product and retained samples • Strong hold management system

34. Traceability and Recall Program • Crisis response plan and team • Lot coding and records • Distribution records • Product disposition • Mock recalls • FDA regulation (21 CFR 1) • Requires records identifying immediate previous source and immediate subsequent recipient

35. SanitationRegulatory Requirements • FDA – Current Good Manufacturing Practices (21 CFR 110) • SSOPs

36. SSOPs • Should identify daily pre-op procedures • Should identify daily operational procedures • Should be signed and dated • Establishment should initiate corrective and preventative actions • Daily records should be maintained

37. Process and Controls • Validate kill step • Do not use same equipment (conveyors, containers, etc.) for unprocessed and processed, including blanched nuts • Process disruptions – remove product • Control nut dust and other nut debris • Assure nut foreign material removed

38. Process and Controls • If a processed product sample tests positive for Salmonella, the tested lot is considered adulterated and should not be released into commerce • Positive lots may be reprocessed , but ONLY when run through a VALIDATED process • It is critical to review adjacent lots to confirm a clean break between a positive lot and one or more lots designated as clear to release

39. Process and Controls • Purging contaminated peanut butter lines with hot oil • Validate procedure • Recent study suggests it takes 42+/- 8 minutes at 90oC (194oF) for a 5 log reduction of Salmonella for a mixture of three outbreak-associated S. Tennessee strains in peanut butter (Doyle, May , 2009) • 49±12 min were needed to inactivate a composite of other Salmonella isolates

40. Process and Controls • Traceability • Finished product traceable to raw material lots used • Consideration should be given for a routine clean break for bulk or continuous nut and nut butter operations

41. Microbiological Control GMA Guidance Document • Prevention • Hygiene Practices and Control • Hygiene Design of Buildings and Equipment • Moisture Control, Minimizing growth, Dry & Wet Cleaning Practices • Raw Material Programs • Validation of Control • Verification of Controls & Corrective Actions www.gmaonline.org/science/SalmonellaControlGuidance.pdf

42. Chemical and Physical Hazards • Aflatoxin and other Mycotoxins • Pesticide Residues • Heavy Metals • Unintended Food Allergens • Foreign Materials

43. Proper implementation of prerequisite programs simplifies the development of a HACCP Plan.

44. Prerequisite Programs Should Be : • Well-documented with written SOPs • Adhered to by all employees • Reviewed and revised as needed • Effective in accomplishing objectives

45. Establishing Prerequisite Programs • Documentation • What procedures should be performed? • At what frequency? • Who has responsibility? • What actions should be taken if: • a procedure is not performed as required? • there is an unexpected outcome?

46. Establishing Prerequisite Programs • Employee training • Continuing education • Important to understand and follow assigned tasks • Provide time and materials for training • Verify by reviewing performance

47. Verification of Prerequisite Programs • Periodic review of the SOPs and audit reports to ensure that the programs are operating in a manner that should not require a change in the hazard analysis or HACCP plan.

48. Establishing Prerequisite Programs Verification • Is the SOP performed in the manner intended? • Is the procedure monitored? • Are appropriate records kept? • Is there an independent audit? • Are programs revised as necessary?

49. Establishing Prerequisite Programs • Resources • Are the proper tools/equipment available? • Are appropriate personnel available to perform the task effectively? • Are systems adequate for monitoring and storing data?

50. Prerequisite Program or HACCP?