Food Safety Analysis, LLC


Ingredient, Product & Sanitation Testing

Database Entry & Management

A food manufacturer often has complex testing needs that involves the use of outside laboratories. Most of these analyses involve following various standard testing methodologies. However, there are often many different ways and therefore different methods to achieve what appears to be the same end. Different methods sometimes give different results. Some laboratories are able to provide a clear and unbiased exploration of these matters and guide their client to what is best for the client. Other laboratories will seek to maximize their own efficiencies by settling upon one method and then selling that method to all comers for all reasons. That is why it may be to a company's advantage to have a knowledgable consultant interact with an outside laboratory or locate new laboratories.

Methods are developed by various groups concerned with such matters. A large part of the work is method validation, which takes considerable time but is of great value to the user of a given method. Technology, however, has a way of marching forward. An examination of the scientific, technical and patent literature will often turn up methodologies that are cheaper, faster and better than the older, standard methods. A business must constantly evaluate the methodologies upon which that business depends. A good example of this may be the testing for Salmonella in foods. The FDA has long published its own "Bacteriologic Analysis Manual" (FDA-BAM). Their standard method involves sequential incubations on several different media with side tests along the way. This method takes more or less a week to complete and involves considerable "hands-on" effort, which makes it expensive. An overnight incubation in an enrichment medium followed by use of a specific, commercially available molecular biology probe may well be a far better alternative.

It is one thing to decide upon the testing that is required and quite another to have the results of that testing readily available, as the need for inspection of your company's testing schema arises. Paper records have a way of getting lost, misfiled or damaged. An electronic copy in a database of such records is a far better way to go. Redundant electronic copies are easy to make and are presumably already being made as part of your company's file backup routine. If one or more outside laboratories are already being used for testing, the chances are that each laboratory uses its own reporting format. The use of a consultant to evaluate methods, oversee outside testing, ensure that analytical sensitivity of each test is adequate for the purpose and then to compile the results into an easily searchable database lends professional credibility to your company at the same time it may actually save your company money. Once a testing and reporting scheme has been established, designated of your employees may be trained (remotely or on site) in some or all of the duties involved thereby saving the company additional money.

Sanitation testing is often taken to imply the demonstration of a kind of "hyper-cleanliness" and "semi-sterility" of materials in contact with food. This is all well and good, however, it is nowhere near enough in a regulatory environment that places its reliance upon a company's HACCP plan rather than repeated testing of final product. In order to provide a cogent hazard analysis, one must know the hazards that are in the plant to begin with. This is done by testing. One needs to know, for example, the arsenic, lead, cadmium, nickel, chromium (VI) and pesticide content of untreated incoming water. If incoming water shows the occasional or systemic presence of identifiable hazards then a treatment regimen must be devised to reduce such hazards to a nonhazardous level. The same goes for microbial contaminants. The microbial content of the plant air needs to be measured and the identification of at least the major groups of microbiota resident in your plant must be known. The same is true of walls, ceilings, drains, machinery, packaging materials, etc. Once the type of hazards present and their incidence is known, plans may be made to eliminate such occurrence. On the other hand, if potential hazards have been systematically sought but not found, then the HACCP plan need not plan interventions for a hazard that isn't there (although spot-checking to ensure the continued absence of such hazard should be done at regular intervals).

If your company already has the kind of deep technical expertise needed to decide among methodologies and work through the intricacies of their deployment on or off your site, then you are fortunate. If not, then your company would be well advised to get the job done on a consultative basis so that your company can move ahead with its business plan and not get mouse-trapped by technical, analytic or regulatory compliance issues. Your company can buy as little or as much help as needed without the necessity of hiring an expensive technical person.

Copyright © 2012 by M. Mychajlonka, Ph. D.