Implementing Supplier Controls
Food safety is a chain-wide responsibility and in our industry, this supply chain extends to all of the components and ingredients of our products. Often we may focus on only the fruit or vegetable that our company supplies, but it is imperative for suppliers to ensure all their inputs are safe. Suppliers must be able to demonstrate their adherence to their food safety programs, including any components “down the chain” from them.
If your company is producing a blended salad, for example, that includes iceberg lettuce, carrot slices, croutons, chopped almonds and a salad dressing in a bag, then you have at least eight suppliers that you need to “qualify” as having produced those ingredients safely. In other words, you need to know that the romaine, carrots, croutons, almonds and salad dressing were produced by a supplier with a verified food safety program. You also want to be sure the manufacturer of the packaging materials, the cartons and the pallets follow written food safety programs. With that in mind, I’d like to share some considerations to be taken into account when looking to ensure raw materials and ingredients are safe for their intended use.
The first area to consider when looking at a supplier’s food safety exposure is to ensure they employ a risk-based food safety program. Processors that rely on growers to provide raw agricultural commodities need to be sure that these growers employ GAPs based on sound risk assessments specific to the crops they provide. Similarly, processors that use custom processed ingredients, such as ingredients in salads, need to account for the safe production, shipment and storage of those products prior to use.
This philosophy also extends to other materials that contact the food. For example, sanitizers should be verified for content and strength. Film manufacturers, carton producers and other packaging suppliers where the materials contact food also need to follow risk-based food safety programs to ensure these materials do not provide a cross-contamination risk. It is entirely appropriate to ask your suppliers to provide documentation that demonstrates their commitment to food safety and for you to schedule visits to their facilities to see for yourself that these food safety programs are in place every day.
The level of control required needs to be risk-based and take into consideration the intended use of the product. For example, sterile packing cartons should not be required for produce that is field packed as that product will likely be washed by consumers prior to consumption. However, it is a reasonable expectation that the carton be manufactured and stored prior to use so that it does not become an unexpected risk to the safety of the produce. On the other end of the spectrum, it should be expected that a custom sliced carrot ingredient in a bagged salad should be produced and packaged according to the provider’s HACCP-based food safety program and shipped and stored prior to use to maintain its food safety integrity.
Many processors have written suppliers’ programs that include their expectations for food safety and verification for adherence to supplier food safety programs. Some conduct their own audits and may also require third-party audits. Often processors will provide food safety training to valued suppliers to help them comply with food safety requirements. It is important to note that supplier food safety programs should extend to being able to demonstrate where any specific food ingredient came from. Being able to trace the source and identify specific lots of ingredients can be vital to limiting the scope of finished product recalls when safety problems are discovered.
Numerous firms have an internal supplier approval program and lot tracking system with clearly defined coding. Indeed, “supplier approval” programs are commonly part of any good food safety auditing scheme today. However, these supplier approval programs should extend beyond simple “letters of guarantee.” There should be a comprehensive, risk-based supplier sourcing program that can be verified and documented via on-site visits and/or third-party audits.
I encourage companies to develop and adopt supplier verification programs to help ensure the safety of produce. As always, these programs must be based on science and account for the factors raised in this section. Though many processors and packers do already have documented supplier verification programs, this is another area where our industry has a chance to shine in our dedication to the best food safety programs possible. Let me know your comments and questions on this topic by contacting me at AskDrBob@pma.