In 2000, BGC Manufacturing's Southwest Dairy plant developed a hazards analysis and critical control points (HACCP) plan with help from a consultant. Plant managers at the time had no idea the plan would ultimately assist the company in meeting the requirements of a sweeping new package of food safety laws. But when those new mandates began taking effect in January of last year, BGC's voluntary efforts from 11 years earlier paid big dividends.
"HACCP is an integral part of the day-to-day life of our food manufacturing plants and has permeated the entire manufacturing process from start to finish," says Brian Miller, quality assurance manager at BGC. "We are very confident that our HACCP plans are current and adequate."
Miller oversees quality assurance for six manufacturing plants in the unit owned by Brookshire Grocery Co. (www.brookshires.com), Tyler, Texas. The plants, located on two sites in Tyler, produce milk, cream, ice cream and yogurt, plus cut fruits and vegetables, bakery products, beverages and ice. They serve 151 company-owned stores in eastern Texas, Louisiana and Arkansas.
Like all other food manufacturers in the U.S., Brookshire is still unsure of what the ramifications of the 2011 Food Safety Modernization Act (FSMA) ultimately will be. At press time, FDA was behind schedule on detailing final rules on portions of the act. However, like a large majority of the dairy processors in the country, BGC is fairly sure its HACCP plan addresses much of the same hazard identification issues that will be stipulated in the most pertinent sections of FSMA.
"FSMA mandates that all food companies follow HACCP," says Clay Detlefsen, vice president of regulatory affairs at the International Dairy Foods Association (www.idfa.org), Washington. "It does not use that language anywhere, but that's what it does."
IDFA, a membership and lobbying organization representing dairy processors, spearheaded dairy's voluntary adoption of HACCP over the past 12 years. HACCP is required for seafood and fresh juice companies, but dairies — which operate largely under an older, more specific Pasteurized Milk Ordinance (PMO) -- escaped HACCP requirement.
Lids on ice cream cartons are checked at a Brookshire Grocery Co. dairy plant. Brookshire is one of many dairies that voluntarily adopted HACCP, putting them in a solid position for final regulations of the Food Safety Modernization Act.
Still, dairy's voluntary adoption made sense for a couple of reasons. To begin with, a good number of dairy plants also package orange juice. More importantly, many of their customers were asking for HACCP plans, says Tedd Wittenbrink, vice president of audit services at Randolph Associates Inc. (www.randolphconsulting.com), Birmingham, Ala. Randolph conducts training and audits and provides lab analytics for dairy processors and ice cream manufacturers around the globe.
"In most cases, HACCP was customer-driven. There were customers [major grocery and foodservice retailers] who wanted dairies to have something in place," says Wittenbrink. "You need to have some type of hazard analysis."
The dairy industry's voluntary HACCP participation has been strong, says Jon Gardner, another vice president at IDFA. His work is focused largely on the HACCP program. "Somewhere around 90 percent have a plan, or have gone through the process," he says. "And all dairy businesses identify their hazards."
Randolph is the firm that helped BGC and other dairy companies develop their HACCP plans. It works in concert with IDFA, providing fee-based training, audit and consulting services to many processors that are IDFA members. In the 1990s, the dairy industry underwent a period of rapid consolidation leaving a mixed playing field that remains today, Wittenbrink says.
"Anymore, you have two basic kinds of dairy operations in the U.S. from a business standpoint: the corporations and the smaller, independent family-owned businesses. For the most part, the corporations are going to be in great shape. They have had HACCP for years, primarily to satisfy customers."
Many of the smaller companies have adopted HACCP, but those who have not may have to scramble.
"They are the ones that may be struggling a little more with what they will need to do to comply with FSMA," Wittenbrink adds. "In many cases they have not developed a hazard identification plan, so they will need to do something. The easiest way to prepare for FSMA really is to develop a HACCP plan. Sooner or later their customers will want it anyway. More and more customers want HACCP and GFSI (Global Food Safely Initiative) certification."
An additional benefit to HACCP is that it moves some of the FDA oversight requirements of the PMO from the realm of regular inspections to a report-and-audit scenario.
While HACCP covers much of what is mandated in FSMA, particularly with regard to the act's hazard identification section, it does not cover everything. On its website, FDA summarizes the scope of the entire act in a few sentences before outlining it in more detail:
About 48 million people (one in six Americans) get sick, 128,000 are hospitalized, and 3,000 die each year from foodborne diseases, according to recent data from the Centers for Disease Control and Prevention. This is a significant public health burden that is largely preventable. The FDA Food Safety Modernization Act (FSMA), signed into law by President Obama on Jan. 4, 2011, enables FDA to better protect public health by strengthening the food safety system.