Food Safety Magazine, August/September 2008

extremely foolish. Operating in this mode creates undue risk for the business enterprise and diminishes the level of protection afforded to the ultimate consumer. If a business has developed a stable supply history to justify not evaluating the product for contaminants, so be it; unfortunately, change is inevitable. New product introductions, various cost savings initiatives and unforeseen external influences can definitely undermine the aforementioned ideal steady state.

Prior to moving forward with sampling activities, it is crucially important that every quality and food safety professional have a basic understanding of product sampling and the statistical pitfalls associated with the use of the resulting data. As I was once told by a colleague who commented on a book proposal of mine, “Remember that every bite is a 100% inspection!” Performing statistical sampling to ensure

that products are free from physical hazards is not the concept that I wish to enforce here because that outcome does not logically exist. Using well-designed sampling plans and organizing the resultant data for trend analysis can help producers better understand their contamination burden and flag the organization when significant differences are present. The typical “tribal” sampling plans that have been passed down from

Prioritizing Risk

The organization must be prepared to protect itself from excess risk present within such a scenario. Prioritization of risk mitigation activities must be performed according to an established model, not just group think or gut feel. Conducting focused risk assessments can aid the processor in identifying the gaps present in their own supply chain. For both financial and business continuity purposes, it is best to evaluate ingredients and subcomponent blends early in the value chain. Figure 1 displays the incremental costs incurred when sampling activities, culling inspections and/or other product actions are taken at later stages of the product lifecycle. If there is any doubt, you certainly want to catch a problem early. Typically consulting your HACCP plan or a pre-existing failure mode and effects analysis (FMEA) will be a logical primary step. Having a healthy dialog with the supplier at this point is another recommended practice. Voice your concerns to the supplier; if only a superficial conversation can be had with flippant responses, then maybe engaging with their trade references will provide valuable information on past failures and noted gaps.

Now that a risk profile has been developed, the next phase is to sort the ingredients/sourced components by potential. If after this step is completed you find that your process already has multiple documented redundant interventions in place to either flag or mitigate the contaminants of concern, then further evaluation of the ingredient is not necessarily a priority. If unforeseen risk or other basis for further concern is noted, then product evaluation is most likely warranted.

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