Reasonable debate over the value of HACCP (hazard analysis critical control points) planning by food and beverage processors ended in the last century. Whether by government edict or customer insistence, most food manufacturers are being challenged to formulate documented procedures that validate their food safety efforts.
The question today is, how well is that HACCP plan integrated into plant automation systems?
Ever since the HACCP bandwagon started rolling in the mid-1990s, plant managers have been grousing about the record-keeping aspects. "A paper chase," many have fumed. The obvious solution is to automate as much of the data collection and reporting functions as possible, but opportunities are limited by the flexibility of existing systems, company culture and other factors.
Pride in professionalism has prompted some processors to embrace HACCP. "It's the continuous improvement loop," explains Brad Hagan, director of brewery operations at Latrobe Brewing Co. in Latrobe, Pa., which became the first North American brewery to achieve HACCP certification earlier this year. Latrobe, which produces Rolling Rock beer, is a unit of the Labatt Division of Interbrew, the world's sixth largest brewery.
"We always felt we had a good food safety program, but it was internal and had never been tested against a standard," says Hagan. "Nobody mandates this for the brewing industry. But we have a quilt of breweries all over the world, and we need an internal mechanism to bring them all up to a uniform standard. HACCP is it."
While brewers have used sensors, controls and other automation technology for decades, automation of HACCP has not been a slam-dunk. Some aspects of the HACCP plan have been integrated into automation systems in Latrobe, but manual logging likely will be part of the execution for some time. "Operators are not necessarily computer literate," explains Jessica Hudale, the plant's HACCP coordinator, making paper-and-pen the data-capture tool of necessity for some reports.
Long, winding road
HACCP is a continuous improvement process, and automating its elements is more likely to occur in increments than in one sweep. No one in the food industry has been at it longer than HACCP pioneer Pillsbury, and even that organization continues to make refinements.Not long ago before its acquisition by General Mills, Pillsbury executed an integration project that tied together HACCP data collection with SPC and QES (quality execution system) programs. Until Pillsbury integrated the data collection requirements of HACCP and QA, operators often were "back-filling" data, Robert Zeigenfuse of Advanced Automation Associates (AAA) told the JCS Food Forum last year. "At the first plant we audited, only three of 11 people had ever logged an out-of-compliance situation," Zeigenfuse said. The situation is all too common in food plants, and in those cases HACCP is short-circuited as an effective tool to identify deficiencies and correct them.
By making quality CCPs complementary to HACCP, the company created a means for continuous improvement and "empowered operators to be proactive" by making them privy to the quality outcomes from line adjustments, he said. At Pillsbury, no additional staff was necessary.
The only added staff at Latrobe and seven other Labatt breweries has been the HACCP coordinators at each facility. "We needed a HACCP champion at each brewery to drive the program and make sure the plant took complete ownership," according to Terry Dowhanick, quality assurance and product integrity manager for Labatt. Heads of IT, packaging, engineering and other departments composed the team that drafted each brewery's plan.
HACCP development coincided with customization of Latrobe's computerized maintenance management system (CMMS). "The timing was excellent," Dowhanick says. "We were able to expand the schedule to include HACCP plan objectives where required and also designate specific maintenance processes under the HACCP umbrella for auditing purposes." Those include sanitation programs.
Electronic records are created by the plant's empty bottle inspection (EBI) system and the filler flush system, one of the CCPs. If a bottle bursts at the filler, sensors activate a water flush at the filler head, and all bottles are rejected for several rounds. HACCP-required follow-ups to those incidents have helped boost system performance. Likewise, a fill-detect system that rejects bottles that are not properly filled has been made more reliable because false positives are identified and investigated, leading to system improvements.
Conversion from paper-based to electronic data-capture is happening in increments, Hagan says. In the meantime, hazard analysis is uncovering quality issues that previously were not addressed. Says Hudale: "There were many systems in place before, but we weren't documenting issues thoroughly or at all. This made us more aware of safety issues."
Off-site data managers
Maintaining the cold chain is probably the key in reducing Listeriosis in ready-to-eat meats and other foods, the FDA's October risk assessment report on food-borne pathogens suggests. The conclusion isn't lost on USDA inspectors, who likely will be paying much closer attention to recorded temperatures from slaughter through distribution.In slaughter operations, workers routinely gather carcass temperature samples in coolers to determine the time it takes to lower the temperature of sides of beef below 40°F. It's a labor-intensive, error-prone exercise that Booker Packing Co. in Booker, Texas, decided it could do without. The company recently converted to wireless probes that record HACCP data and relay them via RF to a host computer. Real-time data then is encrypted and relayed via the Internet to a service bureau that maintains the records in 21 CFR 11-compliant form. Supervisors can access and view the data from any location, and if readings at any sensor drift beyond the set point, a series of escalating alarms demanding a response are sent.
"Before," says plant engineer Walter Smith, "we had to walk up, insert the probe in the carcass and write down the temperature. Now, we insert a probe at the beginning and get live, automatic readings of the entire process. We don't even have to watch the computer screen. The system alerts us if there is a problem, and we can take corrective action immediately."
The sensors and support system are from FreshLoc Technologies, a Dallas-based firm that has been involved in wireless temperature monitoring for 15 years. "We're monitoring sites in Australia and Tasmania," as well as U.S. facilities operated by H.E. Butt Grocery, Fresh Del Monte and other firms, according to Dick Fettig, one of FreshLoc's founders.
FreshLoc's new HACCP sensor is equipped with enough RAM to record data for up to 48 hours in the event of a power interruption at the plant. Being able to validate temperatures during a power loss could mean the difference between a widescale recall and an isolated event, says Fettig.
The core-product probe is a new twist for FreshLoc, which primarily has monitored temperatures in refrigerated trailers and warehouses with freezers, coolers and ambient-temperature zones. The probes, which measure one inch in diameter, can be applied to cook processes, as well. One company has begun using the system to monitor cooked meat control points, Fettig says.
"No data can be changed from outside our firewall, and every measurement is immediately encrypted and captured by us," he adds. "If there's a temperature spike to 40° or 50° in a freezer, we send out alarms that escalate until there is a response. Now the plant must take an action, and that response is captured and logged by us."
Hard-copy reports are printed for inspectors who insist on them, though "there's more integrity to the electronic records," Fettig points out. Problems can occur, however, when processors fail to amend their original HACCP plans to reflect a switch to automated HACCP record keeping. For example, one meat processor specified that an operator would read and record temperatures. If the HACCP plan was not amended to specify electronic monitoring, inspectors would find the plant out of compliance, despite the superiority of the automated system.
Integrating temperature records with other HACCP data shouldn't be difficult, Fettig maintains, saying, "We're SQL, a very open database that can be very easily exported and integrated." But the market is plagued with "pseudo databases," AAA's Zeigenfuse cautioned, and manufacturers need to be certain that their HACCP and plant-wide systems employ "commercial grade" SQL servers and Oracle databases that can handle the enormous record requirements over time.
Data muscle machines
Adding to database demands are issues such as product traceability. Implementation of the Bioterrorism Act of 2002 will force processors to maintain records that trace every action and operator input from raw materials through finished-goods distribution. Some of the data points duplicate HACCP information gathering, though the level of detail far exceeds HACCP requirements. A business-wide ERP system is almost a requirement, and that necessitates an extremely robust database."It's not just a matter of having this massive database in case USDA comes calling, it's how do you maintain a system that lets you optimize operations," says Scot McLeod, vice president of Atlanta-based ERP provider Ross Systems Inc. "We're headed in the direction where systems like Ross's iRenaissance becomes the database of record for the company."
Users of iRenaissance include Atlanta's Naturally Fresh Inc. and Vancouver-based Premium Brands, two mid-market firms that have pursued aggressive growth-through-acquisition strategies. Standardized processes and procedures are critical for these firms, whether for order processing, data collection or HACCP compliance, and the ERP system helps achieve those goals. "The audit trail begins with raw material inventorying," says McLeod. "As products move into production, QC checks are inputted, operator actions are tracked, maintenance and sanitation procedures are recorded and, when products get to packaging, all the records are tied to the specific product."
Electronic record keeping of all procedures and validation steps is the best way to eliminate costly paper-based errors and develop process-improvement programs, either for safety enhancement or production efficiency.
"Most of our clients to date have relied on paper-based systems, and that necessarily introduces human error," says Paul Moylan, industry market lead-food at Rockwell Automation in Cleveland. Rockwell recently added Web-supported links to standard operating procedures, equipment maintenance manuals and other documentation to eProcedure, Rockwell's ERP solution.
"The two most common errors in operating procedures are people in the plant forgetting to sign or date a procedure," whether it relates to SOPs or HACCP, Moylan says.
While data collection will never be enjoyable, it can be made relatively painless. Automating the process to the extent possible and giving operators a sense of how HACCP improves operations helps ease the pain.
For more information:
Robert Zeigenfuse, Advanced Automation Associates,
610-458-8700
Richard Fettig, Freshloc Technologies Inc.,
972-759-0111, ext. 102
Scot McLeod, Ross Systems Inc.,
770-351-9600
Paul Moylan, Rockwell Automation,
919-465-1741
