food industries, the establishing of a
HACCP systematic approach is highly
recommended, inasmuch as the new
FSMA requires that those plants receive
an inspection and certification for the
produced food products to enter the
U.S.
Implementing and maintaining prerequisite programs addresses existence
and effectiveness of prerequisites during
design and implementation of a
HACCP plan that must have SOPs,
maintain records and periodically verify
that the specifications are being met.
•
•
•
•
Raw materials and raw material
requirements
• Activities
• Conversion of raw materials into
products
Measurements
Outputs
Customers and their
requirements
• Products
• Other
• Key support units and responsibilities
top management commitment and as-
surance of economic support for these
programs do not exist, if the support is
not constantly reaffirmed and if funds
are eliminated because of “budgetary
reasons,” these programs will fail and ul-
timately affect product quality. n
In summary, exporting food industries can apply GMPs with management
commitment and proper support. Programs that must be implemented have
been mentioned above, and it is relevant
to reiterate that there are several ways to
attain “compliance with specifications.”
The inspection of food products at the
U.S. border by FDA and USDA is a fact,
and so is the inspection of the manufacturing plants in their countries of origin.
Therefore, compliance is expected, and
the production of safe and compliant
food with U.S. laws and regulations is a
must for all exporters. Additionally, if
Implementing HACCP
Innumerable books, magazine articles, experts, etc. indicate (show, train,
etc.) how to implement a HACCP program. Table 2 summarizes the most
common steps recommended. 3
Besides the adoption and implementation of HACCP systems and programs, experience has indicated that the
other deficiency most commonly found
in developing countries’ food industries
is proper record keeping. Production
records provide auditable proof that the
job was done. Specifications of raw and
packaging materials are essential to confirm the quality and amount of what has
been purchased. In-process and finished
product specifications and records allow
for product quality control. To maintain
the proper records, the existing regulations and standards must be followed.
Forms must be standardized and used.
The common use of pieces of paper
should not be allowed but should be discouraged as these and other records
must be used and properly handled for
auditing and recall purposes. Documentation provides a solid base for the quality management system.
Record keeping must be easy to manage, should provide the groundwork for
improvement and must be linked together to form a total company system;
to achieve this, employees need the
latest, most correct and appropriate documents to do their jobs. Most importantly, keep documents simple and easily
understandable.
For written documentation, one must
define the process:
• Input
• Suppliers
Herbert Weinstein, Ph.D., earned his
chemical engineering degree from the
Universidad Nacional Autonoma de
Mexico and his M.Sc. and Ph.D. in food
science and technology from the
Massachusetts Institute of Technology.
He can be contacted at
HERBWEIN@aol.com.
References
1. www.fda.gov/food/foodsafety/fsma/
default.htm.
2. www.fda.gov/Food/Guidance
ComplianceRegulatoryInformation/Current
GoodManufacturingPracticesCGMPs/ucm110
907.htm.
3. Pierson, M.S. and D.A. Corlett Jr., eds.
1992. HACCP — Principles and applications.
London: Chapman and Hall.
