In last month’s white paper, Managing cross-contamination and cross-contact across the food supply chain, TUV USA touched on cross-contact risks and controls for identity preserved foods. In this month’s newsletter, we are expanding the discussion by focusing on those elements of identity preservation (IP) systems aimed at preventing cross-contact, commingling, mislabeling, and false claims.
Generally speaking, IP systems reflect practices, which ensure the purity and integrity of a food commodity or product.* This includes organic, non-GMO and gluten-free production systems. At first glance, components of an IP system may seem adjunct to a food safety management system (FSMS) where the primary focus is the production of food, which ensures consumer safety. Rather, these systems are natural partners and should be aligned for maximum effectiveness as both build off of supply chain transparency (i.e., visibility across supply chain operations beyond tier-1 suppliers).
Increasing the transparency of your supply chain—and in turn, the transparency of your operation—can improve the identification of risks or threats, reduce response time for incidents and removal of product from the marketplace, enhance continuous improvement, increase regulatory compliance, and bolster consumer confidence. For effective food safety management and IP verification, visibility must extend beyond mere traceability and dive into operational practices of material and service suppliers to accurately assess risk to product safety and integrity. Maximize this visibility by co-evaluating food safety and IP risks; leverage visibility gained to develop effective and efficient supply chain controls that safeguard both food safety and the identity preserved status.
By: Ashley Smejkal & Lori Carlson
Core components of IP systems, which are also integral to food safety management and increase supply chain transparency, include risk assessment, supplier approval, segregation, sanitation, traceability, recordkeeping, and verification to ensure the validity of claims and integrity of value-added characteristics. Recordkeeping and traceability are cornerstones of IP systems to maintain chain of custody for IP claims but must be complemented by production controls—notably, the management of suppliers; distinctive identification and segregation of materials and product; and cleanliness of shared equipment, utensils, containers, and other food contact surfaces. Lastly, identity preserved foods should be verified through product testing, mass balance exercises, record review, audits, or other activities, which verify the authenticity of the product according to its claim.
Risks to IP integrity and food safety are distinctly different but are not mutually exclusive within the context of food production and handling systems. Accurate assessment of material risks—from both a food safety and integrity perspective—require visibility into the supplier’s operation and thus, reflect the importance of supplier approval and monitoring programs. Without this visibility—especially that gained through second-or third-party audits—it would be difficult to ascertain the potential for cross-contamination, cross-contact and commingling risks. These risks result from a breakdown in production and handling systems; where one element of a system fails (e.g., inadequate sanitation), multiple risks may be realized impacting both food safety and IP claims. By taking a holistic perspective in risk identification of materials, greater insight into production and handling operations can be achieved resulting in increased knowledge of supplier systems and therefore, an improved ability to more accurately identify and mitigate risks.
Resources - *Sundstrom, F.J., J. Williams, A. Van Deynze, K.J. Bradford. Identity Preservation of Agricultural Commodities. UC ANR. Publication 8077.
About the Authors
Lori Carlson provides independent technical writing, training and consultation services to the food and beverage industry. She has over a decade of experience in verification and validation, risk assessment, food safety and quality management systems, GFSI benchmarked schemes, regulatory compliance, and third party certification. Lori has authored numerous white papers, magazine articles and guidance documents and has contributed to the development of various food safety standards and food professional training courses for GFSI scheme owners and certification bodies. Contact the author through LinkedIn.
Ashley Smejkal supports TUV USA’s Food Division team as Project Coordinator ensuring excellence in client satisfaction for new and renewal certification audits.
Ashley has more than a decade of experience in customer service and sales within the food service industry. Additionally, she served in administrative and marketing positions for a start-up biotechnology company helping to launch new products in the medical device industry.