During our Monday, March 30 “Food Safety and COVID-19: What Businesses Need to Know” webinar, we discussed a number of regulatory updates and recommendations to ensure food safety and worker health. One of the practical scenarios reviewed by Earl Arnold, Manager, Food Defense/FSMA Operations, Quality Assurance, involved key considerations when increasing production.
Specifically, is your facility having longer production runs, but with fewer SKUs? Here are four key questions to ask of your team.
1. What about the ingredients we’re not using?
If you’re increasing production of standard product, but some specialized ingredients won’t be in production for a while and are in storage, they may be susceptible to pests. Per the FDA’s Current GMPs, Sec. 117.80 Processes and controls, section b, 1-4: “Raw materials and other ingredients must be inspected and segregated or otherwise handled as necessary to ascertain that they are clean and suitable for processing into food and must be stored under conditions that will protect against allergen cross-contact and against contamination and minimize deterioration… Raw materials, other ingredients, and rework susceptible to contamination with pests, undesirable microorganisms, or extraneous material must comply with applicable FDA regulations for natural or unavoidable defects if a manufacturer wishes to use the materials in manufacturing food.”
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