Validation
ISO
22000 applies to all enterprises and organizations that directly has impact on the
food chain, including feed producers, primary product producers (farms,
fisheries, livestock producers), food manufacturers, retailers, restaurateurs
and caterers, cleaning / washing / sterilization / disinfection service
providers, transport and storage, as well as delivery services. In addition,
the standard also applies to enterprises and organizations that are indirectly
involved in the food chain, including equipment suppliers, cleaning agent and
sterilization and disinfectant suppliers, packaging material suppliers, and
suppliers of materials that come into contact with food products.
The
food safety management system needs to include the capacity to plan and
implement processes to verify the effectiveness of control measures, to
validate them and to improve itself.
The concepts of monitoring,
verification and validation can be confusing. ISO 22000 defines them as
follows.
Validation
(food safety)
– “obtaining evidence that the control measures managed by the HACCP plan and
by the operational PRPs are capable of being effective” – it is an assessment
prior to starting operations.
Verification –
“confirmation, through the provision of objective evidence, that specified
requirements have been fulfilled” – it is an assessment carried out during and
after operations.
Monitoring –
“conducting a planned sequence of observations or measurements to assess
whether control measures are operating as intended” – it is an activity
undertaken during operations.
The organization must validate the
effectiveness of its operational PRPs and CCPs prior to finalizing the food
safety management system, or whenever these control measures are changed.
Validation consists
of a combination of tools used to ensure the total food safety management
system is working to evaluate food safety data prior to release of the product
through either internal or external audits. The validation can be defined as “obtaining evidence that a control measures
or combination of control measures managed by the HACCP plan and by the operational
PRPs are capable of being effective, if properly implemented is capable of
controlling the hazard to specified outcome”.
Validation
asks whether the hazard analysis was complete and if the control measures are effective
“Are you doing the right thing”. The organization will validate that the selected control measures to
verify whether they are capable of controlling the food safety hazards and
control measures are effective and capable of ensuring control of the food safety hazards.
If this cannot be confirmed, modify and reassess.
Prior
to the implementation of your organization’s food safety management system,
each operational PRP and CCP must be validated to determine if it is capable of
achieving the intended control of the identified hazards. The control measures
or combinations of control measures must demonstrate that they are capable of
ensuring that the end products of the processes meet the defined acceptable
levels.
The organization has a responsibility
to make certain that their food safety management system is designed to produce
the desired controls, is operated as designed, and is updated as new
information is provided. This can become a complicated process.
The food safety management system
should be developed using sound scientific principles. The necessary
information for the system design can usually be obtained from colleges and
universities, government agencies or research branches, trade or industry
associations, consultants, or other parties that have expertise in the food
process and product.
Once you have designed your control
measures on paper, they must be validated. The validation process provides assurance
that the control measure or the combination of control measures will deliver
end products that are safe (i.e. within the acceptable levels required for each
identified hazard).
Validation usually includes activities
such as:
- Reference to validations carried out by others or historical knowledge;
- Experimental trials to mimic process conditions;
- Collection of biological, chemical and physical hazard data during normal operating conditions;
- Statistically designed surveys;
- Generally accepted industrial practices;
- Mathematical modeling;
If you are relying upon validations
carried out by others, then you should ensure that the conditions of your
application are consistent with those identified in the referenced validations.
Scaling up laboratory based
experimental trials in a pilot plant may be required to ensure that the trials
properly reflect actual processing variables and conditions. Intermediate
and/or finished product sampling and testing based on the use of statistical
sampling plans and validated testing methodology may be used.
Validations may be conducted by
external parties. Microbiological or analytical testing can be used effectively
to validate that a process is in control and that acceptable product is being
produced.
If additional control measures, new
technology or equipment, changes in the control measures, identification of new
or emerging hazards or their frequency of occurrence, or unexplained failures
of the system occur, re-validation of the system may be necessary.
Reassessment or Revalidation
The ISO 22000 food
safety system literature uses the term “revalidation” or “reassessment” in
regard to operational oversight. Most of the time, reassessment or revalidation refers to annual review
activities that must be conducted to ensure that the ISO 22000 food safety
system is operating as intended. In reality, a complete
revalidation similar to the design qualification, installation qualification
and operational qualification used in thermal processing protocols is rarely
done. A complete validation or revalidation study needs to be conducted only if
there are significant changes in processes, ingredients, products or equipment
that can affect the food safety of the product.
If a complete revalidation is not needed, the plant should conduct either an annual or a continual reassessment of its ISO 22000 food safety system. The objective of reassessment is to determine whether the ISO 22000 food safety system (basically the HACCP plan and the PRPs) is operating as intended.
The reassessment should help answer the following question: Is the ISO 22000 food safety system (HACCP plan and PRPs) adequate to control the identified food safety hazards? The reassessment should lead to identification of activities to improve the ISO 22000 food safety system. It can be used as input for other verification activities, including the internal audit and management review.
Validation of Metal Detectors (an example)
This needs to be done for each product type. The validation protocol might even require that the standards be inserted into the bag at different locations. Multiple tests—a minimum of 10—should be done at each location. The people doing the validation study must also confirm that the settings remain the same throughout the test. The result should be the determination of where to place the test wands during calibration checks in the course of normal production. The location needs to be the spot where the magnetometer receives the weakest signal. Isn’t that a lot of work? Yes, but a rigorous test protocol such as this will provide confidence that the system works properly.
Validation of Control Measures to Inactivate Salmonella
When a lethality
step is needed to inactivate Salmonella in a low-moisture product or ingredient,
the processing parameters used should be adequate to inactivate the level of
the organism likely to be present. According to the National Advisory Committee
on Microbiological Criteria for Foods (NACMCF), validation encompasses
collecting and evaluating scientific data and technical information to
demonstrate that the control measures and associated critical limits at the
lethality step, when followed, will result in a safe product (NACMCF, 1998). In
addition, it is necessary to demonstrate that the chosen control measure and
critical limits can be applied in production at a critical control point. Validation
of lethality steps for low-moisture foods involves determining an appropriate
log reduction for Salmonella, determining the critical limits in the process
required to achieve the reduction, and confirming the process equipment
consistently delivers the critical limit parameters in the operation (NACMCF,
1998; Scott et al., 2006).
In general, NACMCF’s
definition for pasteurization (NACMCF, 2006) can be used to guide the
determination of an appropriate level of log reduction. With respect to a
low-moisture product, NACMCF’s definition translates into applying any process,
treatment, or combination thereof, to reduce the most resistant Salmonella
serotype “to a level that is not likely to present a public health risk under
normal conditions of distribution and storage.” NACMCF also indicated that a
control measure aimed at inactivating the target pathogen does not protect the
consumer if the product is subsequently recontaminated during manufacturing.
The effective approach to prevent recontamination is through good hygiene practices
verified by environmental monitoring to ensure that recontamination is not
likely to occur.
The level of
reduction required will depend on the potential levels of Salmonella, if
present, in the raw ingredients. Efforts have been made to set an appropriate
level of log reduction for a specific low-moisture product based on a risk
assessment. For example, a risk assessment (Danyluk et al., 2006) conducted to
assess the risk of salmonellosis from almond consumption was used to determine
that a 4-log reduction of Salmonella in raw almonds is adequate to ensure
safety of the finished product (AMS, 2007). In some instances, historical knowledge
is used as the basis for validation (Scott, 2005).
For example,
pasteurization at 72 °C for 15 sec is considered adequate to inactivate
expected levels of vegetative pathogens of concern in raw milk. These
parameters may be used as the critical limits or the basis to establish other
process parameters as critical limits at the lethality step to inactivate Salmonella
in the fluid milk ingredient for a dried milk product; preventing
recontamination after pasteurization during drying and subsequent handling
would be essential to protect the finished dried product from recontamination.
Both industry guidelines (Froning et al., 2002) and FSIS regulations in 9 CFR
590.575 (CFR, 2008a) set parameters for the pasteurization of dried egg white,
which include heating the product in a closed container to at least 130 °F (54.4
°C) for 7 days or longer until Salmonella is no longer detected (As a practical
matter, the egg industry routinely uses a more severe heat treatment in order
to eliminate the avian influenza virus as well as Salmonella). However, after
pasteurization during drying and subsequent handling would be essential to protect
the finished dried product from recontamination.
Both thermal and
non-thermal control measures can be used for Salmonella inactivation to achieve
the target log reduction. Various processing steps (e.g., cooking, frying,
roasting, baking, heat extruding, fumigation) may be used to inactivate
Salmonella in a low-moisture product. Thermal processing is the most commonly
used control measure to inactivate Salmonella.
For example, the
Almond Board of California’s Technical Expert Review Panel (ABC TERP)
determined that oil roasting at or above 260 °F (126.7 °C) for 2 min will
result in a 5-log reduction of Salmonella on the surface of whole almonds (ABC,
2007). The ABC TERP also provided minimum time and temperature combinations
required for blanching processes to deliver a 4 or 5-log reduction of
Salmonella on almonds (ABC, 2007). These parameters were determined based on
heat resistance data for Salmonella Enteritidis PT 30 as the target organism.
It is useful to
review available scientific data for the processing method of interest, including
high temperature short time or low temperature long time when desirable for
maintaining product quality. In order to assure appropriate validation, it is
also necessary to evaluate scientific and processing equipment data and
information specific to the processing technology under consideration. A
process authority should be consulted where necessary.
For example, the ABC
TERP, which consists of experienced microbiologists and processing experts,
evaluates the adequacy of various treatments to inactivate Salmonella in raw almonds
and develops guidelines for validating individual processes, including
propylene oxide (PPO) treatment for raw almond kernels, PPO treatment for
in-shell almonds, blanching, oil roasting, dry roasting and other processes
that may be proprietary (ABC, 2007).
Validation testing
can be carried out using Salmonella (appropriate strains), using a surrogate organism
that has been validated for the product and process under consideration, or
using a non-microbial method such as an enzyme that has been validated for use
in such applications. When the time and temperature profiles of a process can
be mimicked in the laboratory (e.g., oil roasting); a challenge study with
appropriate Salmonella strains can be conducted in the laboratory to validate
the process (Larkin, 2008). This approach has been used to validate a dry-air
roasting process for peanuts, where a lab-scale roaster was used to mimic the
actual processing times and temperatures and the process was found adequate to
deliver a 4-log reduction of several Salmonella strains (Tuncan, 2008).
Reference:
http://graphics8.nytimes.com/packages/pdf/business/20090515_moss_ingredients/SalmonellaControlGuidance.pdf
http://fskntraining.org/sites/default/files/coca-colaFS09/ISO_08_English.pdf
http://www2.shimadzu.com/applications/lcms/Shimadzu_TechReport_Vol13_LCMS.pdf
http://www.foodsafetymagazine.com/magazine-archive1/augustseptember-2014/a-new-paradigm-for-validation-verification-and-monitoring/
http://www.fsis.usda.gov/OPPDE/rdad/FSISDirectives/5100.2/Meat_and_Poultry_Hazards_Controls_Guide_10042005.pdf