Years ago as a consumer, I purchased a six-pack of chocolate chip cookies from a vending machine for an afternoon snack. My plan was to enjoy the cookies with a cup of coffee. As I started on the second cookie, I bit into a hard chocolate chip that wasn’t consistent with my expectations. However, with a second bite I almost broke a tooth. Upon inspection, I discovered it was not a chocolate chip but a ¼-inch mild steel threaded nut. Oops … a failure in foreign material control somewhere in the system. This was very disappointing to me as a consumer.
I have been amazed by my experiences with consumers in my professional life when they contact a company with remarkable stories of finding a wedding band, a diamond ring, rodent parts, glass, frog parts or even a gigantic metal bolt. Consumers just can’t make these things up; in fact, they are remarkably honest with their discoveries. For example, the gigantic bolt (6-inch-by-1-inch) was reported by the consumer to be in a pasta box. The size of the bolt was a tight fit inside the box. Upon investigation, it was discovered the consumer was totally correct, and the bolt’s home was found: the head of the pasta filler.
In the bolt’s case, the plant had an excellent metal detection control program. If it can miss a large bolt, however, what else could be missed? The obvious question was, “Were the hourly metal detection checks taken and documented?” They were. A more intuitive and appropriate question would have been, “What are the preventive controls to prevent foreign material contamination?” After all, a metal detector will only potentially alert of passing metal while other foreign materials are unchallenged by this technology.
Metal is a low percentage of foreign material complaints. Other contaminants like wood, glass, string, tape, insects, plastic, rubber gaskets, hair, gloves, pieces of poly liners, dissimilar products and others are not discoverable with a metal detector. Since these non-metallic items are most of the foreign material complaints, aggressive preventive controls should be applied to keep all foreign material from inclusion in food products.
A robust preventive control program looks at controls for all foreign material, not just metallic ones. This elevates the discussion of prevention vs. detection. Prevention must be the dominant focus with support from detection.
The Food Safety Modernization Act focuses on the prevention of unintentional contamination or cross contamination for food products, including foreign material.
Risks can be controlled through basic programs organized to follow existing food industry guidelines. Good Manufacturing Practices (GMPs) focus on personnel practices in a food processing facility. Preventive maintenance ensures that equipment and facilities are maintained optimally and monitored for performance. Sanitation programs monitor equipment for loose parts when disassembling and assembling equipment and tracking gaskets and equipment parts to ensure they are not left on product contact surfaces. Weekly physical GMP inspections can identify frayed conveyor belts, peeling paint, damaged equipment, misaligned belts and more.
These are just a few approaches that help discover and prevent a loose bolt or nut from incorporation into a chocolate chip cookie and eliminate a consumer complaint.
Joe Stout is a contributing editor for Baking & Snack and the founder of Commercial Food Sanitation, LLC