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The FDA food code is a strong proponent for “Active Managerial Control (AMC)”. AMC is essentially that the person-charge actively manages food safety controls in his or her operation.
AMC consists of three parts:
Chances are if you observe a restaurant, grocery store, manufacturer or foodservice operator using AMC, you’ll see staff using paper checklists or logs to monitor the food safety of their operations.
One solution to this is a digital or electronic food safety management (eFS) system or eAMC (electronic Active Managerial Control). The goal of an electronic (or computerized) food safety system is to get food safety data into an electronic form. At the very minimal end, the data is captured as static data or simply a PDF or photo of a paper form. At the opposite end, the data is captured into a database that permits data analysis and reporting.
For example, temperature sensors can be placed in all of an operator’s cold holding equipment. The sensors report the cold holding temperature 24/7/365 in real time. The eAMC system is programed only to notify management IF and WHEN a temperature deviation occurs. If the system is working effectively, there is no time and effort expended by management until a deviation occurs.
The eAMC system is often a computer based software program that can be programmed to perform many different tasks. Policies can be stored for retrieval in a few “clicks”. Corrective actions can be attached for access only when needed.
Another AMC requirement is training of staff. With constant turn-over, and other staff issues, this can become a paperwork nightmare. An eAMS system can provide on-demand training videos and assessments. Training videos can be linked to processes, ingredients, and equipment. Imagine that each standard operating procedure (SOP) had both a written text form and a video demonstration.
The internet of things can extend to the food safety world. First, the internet of things (IoT) is network of computer devises that connect together to transfer data. The data transfer can occur without human intervention. How can that help retail-foodservice food safety? Let’s recap the five major risk factors for foodborne illness as described by FDA in the Food Code.
Gingerbug: A mixture of sugar, shaved ginger, and water is allowed to naturally ferment via wild yeasts and usually lactic acid bacteria.
Shrubs: not the green vegetation things, but actually vinegar based beverage. It is a high-acid beverage and quite safe.
Trotters: Pigs Feet
Shiokara: Japanese traditional fermented fish viscera – requires ≥ 10% salt for safety. The result is VERY pungent.
Casu Marzu: maggot infested cheese from Italy.
Molecular gastronomy combines artistic culinary experiences and passion with the scientific and technical foundations of food science. Freeze-drying various foods is one of the methods currently being explored by these cutting edge chefs. Another is the rotary evaporation (concentration) of food essences.
The rotovap can be used for two purposes: 1) concentrate non-volatile components in a mixture (e.g, concentrating flavors from a blood orange by removing the water), and 2) to extract the volatile aroma and flavor molecules from mixtures gently (e.g., extracting the desired flavors from a blend of alcohol, herbs, and fruit without heating the mixture up). The key to understanding any distillation is to remember that it is a separation. Sugars, acids, colors, and most bitter compounds are separated from aromas, alcohols, water, and small flavor molecules, etc.
Is this a “Special Process”? Are there food safety concerns?
Is this a “Special Process”? This question would hinge on the evaporation process itself. Are PHFs subjected to conditions that could permit growth of pathogens? If yes. Then, yes, its a special process. What food safety concerns are there? Basically it is a temperature danger zone question. If 42-134F for more than 2 hours, an operator would need to demonstrate why their specific process is safe. Any legal concerns? Yes. It is not permitted in the USA to distill alcohol. The government fears it will not gets its taxes. It is permitted to have a small rotovap. Some Chefs feel that if they use alcohol that has been purchased (tax paid), then they are meeting the spirit of the law.
Is this a “special process” under the Food Code? Yes. A PHF (TCS) food is being freeze dried to be non-PHF (non-TCS).
The technology and equipment for freeze drying has improved to the point that small operators and even some home preservers can join in. Pictured is a line of freeze dryers from Harvest-Right (look them up on your own). From a food safety standpoint, this “special process” is low risk. Foods MUST be frozen first. Then the water is removed by sublimation (solid direct to a gas) inside the machine. The machine also maintains the freezing temperature, so time to dry is not important. The loss of flexibility or pliability indicates food dryness. A dry, crunchy, food item is likely to have a water activity close to 0.3, well below the 0.85 pathogen cut off level.
Molecular gastronomy combines artistic culinary experiences and passion with the scientific and technical foundations of food science. Freeze-drying various foods is one of the methods currently being explored by these cutting edge chefs.
Special Process Meats Bringing the farm to the fork (microgreens, etc) Molecular Gastronomy The digital revolution !! Online courses available NOW Retail-foodservice processes of concern Special Processes (non-meat) Special Process Auditing
Special Process Meats
Bringing the farm to the fork (microgreens, etc)
The digital revolution !!
Online courses available NOW
Retail-foodservice processes of concern
Special Processes (non-meat)
Special Process Auditing
The concepts of verification and validation leave most beginner food safety professionals confused. On top of that there are two different aspects to verification and validation. The first is related to specific food safety procedures (CCPs, GMPs, SOPs, etc) and the second is a global view. Is the entire food safety system working?
• Monitoring: Are the operations being done as intended? (present)
• Verification: Was the work done according to the food safety plan? (past)
• Validation: Are the plan criteria (e.g. critical limits) based on science?
• Monitoring: Is the entire operation being observed and assessed? (present)
• Verification: Is all of the work done according to the food safety plan? (past)
• Validation: Is the plan as a whole effective? (past and future)
FSMA Preventive Controls requires that Process Control CCP critical limits be validated by referencing the science or safe harbor (federal performance standard). No other Preventive Control programs REQUIRE validation. This includes allergens. The FDA has not set threshold levels of allergen residuals. On the global level, FSMA PC requires an effectiveness check (a) at the documentation stage, (b) just after the roll-out stage, and then (c) every three years.
Opposite to FSMA PC, most GFSI schema based on ISO 22000 and PAS 220 standards require formal validation of CCPs and operational prerequisite programs (oPRPs). In addition, cleaning and sanitizing programs must also be validated. Organizations must properly design, document, implement and maintain prerequisite programs, even if the standard does not specify a validation requirement for this part of the food safety system.