Food Safety Standard

Prevention of Microbial Contamination in Spices During Processing and Storage

Actions can be taken at every step throughout the growing, harvesting, drying, transportation, and processing of spices to ensure that a clean, safe spice is ultimately delivered to the consumer. Development of supply chain approval and re-evaluation programs and adherence to GAPs, GMPs, and HACCP plans reduce the likelihood of microbial contamination throughout the supply chain. These programs also help reduce the introduction of filth, which, in turn, reduces risk for microbial contamination.

Supply Chain Approval and Re-evaluation Programs:

Spice manufacturers should establish robust supplier prerequisite programs to evaluate and approve suppliers. These programs may include audits of supplier facilities; periodic requalification that takes into consideration whether the supplier conducts microbiological monitoring of their process environment or uses validated microbial reduction techniques; and periodic raw material/ingredient testing upon receipt. A risk assessment should be applied to each raw material. Suppliers should provide necessary documentation on traceability of product and on their implementation and use of GAP, GMP and their own HACCP programs. A Certificate of Analysis should be obtained from the supplier that includes results of microbial testing, sample size analysed, and method and lab certification. These controls may be difficult to implement when materials are purchased from markets of collectors, and the burden of ensuring a pathogen-free spice falls on the domestic spice importer and/ or processor.

Good Manufacturing Practices (GMPs):

GMPs have been outlined elsewhere, including the FDA cGMP regulations 21 CFR 110 and the Codex general principles of food hygiene. Manufacturing facilities involved in the processing of spices should manage their operations following GMP guidelines. Sections focusing on worker hygiene, cleaning/sanitizing of physical facilities, utensils, and equipment; pest control; rubbish disposal; and the design and construction of plants and equipment to facilitate cleaning are particularly pertinent to reducing the risk of microbial contamination of spices.

FDA cGMP regulations 21 CFR 110 also address segregation of treated and untreated materials. FDA considers ready-to-cook foods those that have to be cooked according to the instructions on the package. These foods are low risk when consumers follow the cooking instructions as written. The directions are meant to raise the temperature of the food to a certain level for long enough to kill bacteria, including Salmonella. Ready-to-eat foods are processed foods that consumers are not expected to cook or bake. These foods pose a higher risk if they were made without a validated lethality step, a food processing step that kills Salmonella.

Sanitation standard operating procedures (SSOPs):

Each plant should adopt the eight-sanitation standard operating procedures (SSOPs) specified in 21 CFR 120.6. These are written instructions describing each sanitation procedure, how to properly complete the task, the frequency with which each procedure is performed, and the need to record the identity of the person(s) responsible for the implementation and maintenance of the SSOP. SSOPs should address:

Safety of the water that comes into contact with food or food contact surfaces
Condition and cleanliness of food contact surfaces, including utensils, gloves, and clothing
Prevention of cross contamination from insanitary objects to food, and from raw product to processed product
Maintenance of hand washing, hand sanitizing, and toilet facilities
Protection of food, food packaging material, and food contact surfaces from adulteration with lubricants, fuel, pesticides, cleaning compounds, sanitizing agents, condensate, and other chemical, physical, and biological contaminants
Proper labelling, storage, and use of toxic compounds
Control of employee health conditions that could result in the microbiological contamination of food, food packaging materials, and food contact surfaces
Exclusion of pests from the food plant

Hazard Analysis Critical Control Point (HACCP) Plans:

HACCP is a key tool to ensure food safety at all stages of the food chain. An effective HACCP study allows for the identification of specific hazard(s) (i.e., any biological, chemical, or physical property that adversely affects the safety of the food) and specifies measures for their control. A HACCP plan consists of the following seven basic principles

Principle 1: Conduct a hazard analysis:

Step 1: Identify the microbiological, chemical, and physical hazards to human health that may be introduced into the food product.

Step 2: Identify preventive measures that could be used to control the food safety hazard.

Principle 2: Identify Critical Control Points:

A Critical Control Point (CCP) is a step in a food production process at which control can be applied and, as a result, a food safety hazard can be prevented, eliminated, or reduced to acceptable levels. A decision tree is used at the steps where a hazard has been identified. It should be noted that a subsequent step in the process may be a more effective point at which to control a hazard and thus, may be the preferred CCP. Furthermore, more than one step in a process may be involved in controlling a hazard, and more than one hazard may be controlled by a specific control measure.

Principle 3: Establish Critical Limits for Each CCP:

Critical limits are the boundaries of safety for preventive measures put in place at CCPs. A critical limit will usually be a reading or observation such as temperature, time, or pH. A critical limit can be an upper limit where a set amount or level cannot be exceeded or a lower limit where a minimum amount is required to produce the safe effect.

Principle 4: Establish Monitoring Procedures:

Monitoring procedures are routine tasks (performed either by employee or mechanical means) that measure the process at a given CCP and create a record for future use. Continuous monitoring is preferred when it is possible. It is important that the person responsible for the CCP monitoring is given specific, documented, CCP training.

Principle 5: Establish Corrective Actions:

Establish corrective actions to be taken when monitoring shows that there is a deviation from a critical limit. Listed below are some questions that may help when developing corrective actions:

How will people be informed when the deviation occurs?
Who will be responsible for controlling the product that may have been affected by the deviation?
How will we decide what caused the deviation?
Who will be involved in deciding how to get the process back in control?
Who in the company needs to sign off on any modifications to plan?
Who will be responsible for keeping the records of things done in response to a deviation from a critical limit?

Principle 6: Establish Recordkeeping Procedures:

Record keeping is an essential feature of a HACCP plan.

Use simple understandable forms.
Make sure employees know exactly what is expected if they are responsible for making a record entry.
Make sure the records are signed and dated at the time a specific event occurs.

Principle 7: Establish Verification Procedures:

Verification procedures are needed to make sure the plan is working correctly.

There are three types of verification:

Validation, the initial phase in which the plan is tested and reviewed.
Ongoing verification, which ensures that the HACCP plan is working effectively on a day-to-day basis. Typically, verification includes management review and sign off.
Reassessment, an overall review of the plan that must be performed at least annually, or whenever any changes occur that could affect the hazard analysis or alter the HACCP plan.

HACCP reduces the risk of food safety hazards in finished products by identifying the potential risks in the process. Each spice manufacturer should develop product- and process-specific HACCP plans.

Benefits of use of HACCP:

Can be applied to receipt, decontamination (cleaning and microbial reduction), blending, packaging, storage, and distribution processes
Cost effective, preventative approach that reduces product losses
Approved by U.S. regulatory and international authorities as a means of controlling food borne illnesses
Compliments other quality control systems and prerequisite programs (e.g., GMPs)

Steps for assembling a HACCP team, with an emphasis on inclusion of members with different roles in the plant

Instructions for development of a process flow diagram examining

All the steps in the process where a hazard may exist
The potential for specific types of hazards at each step

Relevant product considerations

Use
Packaging
Shelf-life

Appropriate HACCP documentation

Product description
Process flow diagram

Discussion of potential chemical, physical, and biological hazards, including

Specific hazards (e.g., Salmonella, sharp objects)
Suggested controls for prevention of hazards
Methods for eradication of hazards

A checklist of considerations to ensure a thorough hazard analysis process. These include

Presence of “sensitive” ingredients
Physical characteristics of the food product and their ability to support pathogen growth
Existence and timing of a lethality step
Opportunities for post-processing contamination
Storage conditions and their likelihood of supporting microbial hazards
Facility design that allows separation of pre-processing and ready-to-eat foods
Ability of equipment to provide time/temperature control to meet critical limits
Sanitation and employee hygiene •

Examples of HACCP plans for