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Getting the measure of critical control

16 April 2010

EXCLUSIVE At a time when the European dairy industry is still adjusting to a complex new regulatory regime, Neville Child of ABB says modern instruments and recording equipment can help operators meet their new obligations

EU regulation governing the safety of consumer products and foodstuffs has been tightened dramatically over the past five years. The food industry, in particular, has seen the implementation of a raft of new hygiene law introduced across Europe. Under this tighter regime food producers and distributors are under increased pressure to report any product safety issues, which may eventually lead to a product recall.

In the short term after implementation, many people involved in the food industry still remained confused about their responsibilities. Yet the principles on which all the new legislation builds essentially boil down to two points.

Fundamental principles
First, the regulations seek to apply a "farm-to-fork" approach to food safety, which demands transparency and traceability throughout the food chain. It also means that the regulations bring certain primary producers, such as dairy farmers, under food hygiene controls for the first time.

Second, the regulations rely heavily on the application of HACCP (Hazard Analysis Critical Control Points) to identify and control risks at every stage of production and distribution.

A lot of the initial confusion with the new laws revolved around the requirements for microbial testing, with some people (including certain environmental health officers) under the impression that a massively increased programme of testing was required. In fact, the latest advice from bodies including the UK's Food Standards Agency and the Chilled Food Association is that testing can never substitute for good hygiene practice and extra testing should only be needed where the HACCP controls have broken down.

This is good news for the dairy industry. The biggest operators will have been applying HACCP for years and for smaller producers, such as farm-based dairies, HACCP can often be implemented using largely no- or low-cost measures. However, dairy companies must be able to demonstrate to the authorities that their control and validation procedures are effective. And if something does go wrong, they must be able to go back and interrogate their records to trace the source of the problem.

Responding to risk: The latest control and monitoring equipment can help. Pasteurisation is an obvious Critical Control Point (CCP), so let's take that as an example. Until a couple of years ago, circular chart recorders were the standard across the dairy industry, but there are now several reasons why the technology is being superceded by videographic recorders.

For a start, the price of solid-state videographic recorder/controllers has fallen drastically to the point where they are the same price or even cheaper to buy up-front than their mechanical counterparts. Doing away with pens and paper also cuts the ongoing cost of consumables to zero, so any price advantage continues to grow throughout a videographic recorder's life.

The other big reason is data storage. Memory technology allows the new recorders to store millions of data points, both internally and to memory card, enabling years of data to be easily accessible.

Electronic storage also makes it easier to back up data onto a PC or other external storage device. Not only does this keep the data safer than a paper record, it also makes it easier to use the data in new ways. With paper charts, users are realistically only going to rummage through their historical data if there is a problem.

Electronic data storage is more accessible and easier to manipulate, enabling users to extract valuable trend information or calculate the energy per batch of milk production, for instance. In other words, videographic technology not only allows users to do the same things better, it opens up entirely new possibilities for process management.

Tamper-proof security
But all the data in the world is useless unless the regulator can be confident that it hasn't been tampered with. In the US, the dairy industry operates under the Food and Drug Administration's 21 CFR Part 11 regulations governing data security. While European dairies do not need to operate to the FDA's rules, the principle of farm-to-fork traceability that underpins the new European legislation means that users looking to provide tamper-proof data will benefit from recorders that comply with 21CFR Part 11. It's important to note, however, that simply getting the right devices is not sufficient to meet the US standard and guarantee security. It also depends on how they are installed and used.

Ideally, videographic recorders will combine hardware and software measures to maintain security.

For example, the hardware measures available with ABB's SM-Series include sealing the case with a lead seal, locking the memory card, and various systems of password access (including advanced features such as inactive user deletion). The recorders even feature the option of an internal switch to lock all settings unless the recorder is removed, opened and the switch is flicked - a manoeuvre which is easy to spot. On the software side, digital signatures ensure that data cannot be tampered with, while logging additional information, such as the time of any power failure or when the memory card was last removed, provide a complete picture of the process.

Finding solutions
Of course, this is just one way in which modern control and monitoring technology helps ensure that hygiene standards are met. There's more to keeping dairy products safe than keeping track of pasteurisation temperatures. Any risk assessment carried out to comply with HACCP is likely to throw up a number of issues that need addressing.

For example, how can a user prevent cross contamination if a heat exchanger develops a pinhole leak between the product and the heating/cooling medium? The answer is to use a booster pump control system, which ensures that the pressure on the product side is always higher than that on the side of the heating/cooling medium. Reputable control companies such as ABB routinely provide these kinds of solutions, and can advise on the most effective way to solve other such problems.

If in doubt, the best thing to do is to call an experienced supplier for advice. Whatever hygiene concerns a dairy may encounter, an instrument company with a long enough track record is bound to have come across them before.

The new legislative landscape is putting pressure on everyone as the food industry and regulators adjust to the new regime. Modern instrumentation can help control and record safety-critical processes more effectively. So if you're worried you may not be able to meet your new obligations, don't fret - ask for help.

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