Recalls due to the presence of “Potential Foreign Material” are an ongoing issue in the food industry, with one of the most impactful ones being the 2018 recall of 3,000 pounds of frozen chicken due to pieces of blue and clear plastic in the chicken’s breading, particularly as this was followed by 13 million pounds of FSIS-regulated product recalled in the first half of 2019 for foreign material. The numbers led to a key focus on foreign object control, including the issuance of the FSIS Guideline for Industry Response to Customer Complaints, electronic consumer complaint form, and Consumer Complaint Monitoring System in 2020.
While the increased focus from FSIS likely had some effect on reporting of foreign objects, it continues to be a leading cause of recalls, particularly for USDA-regulated foods. This summer alone, foreign object recalls included both FDA and USDA foods and both manufacturer- and retail-prepared foods, from pen pieces in ice cream to rocks in cookies and plastic in meats. Not only can such fragments pose significant risks to consumers’ health, but they are also considered to be adulterations in food, so they need to be a key component of food safety policies and practices.
Foreign material presence can occur due to a variety of reasons throughout the food chain, from supplier issues to equipment failures to packaging or food prep errors. So, a facility’s foreign materials control program needs to include strict measures that focus on one’s particular risk, with regular reassessment and improvement, from supply to finished product. Within your own facility, food safety culture, as noted below, is an important part of the mitigation strategy. Workers who feel empowered to take action when they see the threat of foreign material getting into a product can really help reduce risks.
- Your supply chain can introduce significant foreign material risk to your own process and the finished product, particularly when a raw material is further processed by a supplier. Assessing your controls should start with your supplier approval process (e.g., does it include components such as foreign material control requirements, defect levels allowed, etc.?); include specifications for high-risk suppliers; and provide regular review of both supplier and co-manufacturer programs.
- Internal manufacturing risks (of both plant and retail processing) can be mitigated by ensuring the facility and equipment are in good condition and all sanitation programs are followed. Failing equipment can be a primary source of risk, so regular inspection is essential. Additionally, the facility should regularly reassess its control strategies, taking into account any manufacturing or equipment changes; identify potential foreign material sources and their controls; and examine and calibrate devices used for foreign object control (e.g., metal detectors, sieves, X-ray equipment, etc.).
- The facility’s sanitation program is also integral to foreign object control, both as a control itself and in supplementing controls. That is, having a thorough sanitation program helps to remove potential foreign object risk, and enables preventive maintenance by ensuring equipment is inspected for wear and tear as it is cleaned. Having a tools and parts accountability program is also helpful in reducing the risk of foreign material in finished product.
- The strength of the facility’s food safety culture can also be a strong determinant of risk, with a mature culture one of the most effective ways to migrate from a reactive to a preventive approach to addressing conditions that can result in foreign material in finished product, by anticipating and preventing those occurrences.
While the application of practices is the most essential aspect of foreign object control, it is also critical that the requirements be in writing, practices documented, and records monitored. Monitoring and analyzing practices and trends enables you to target and correct potential problem areas before they cause an issue. Forming a foreign material committee, that meets at least quarterly and conducts semi-annual inspections, can be a good way to keep the focus on these controls and develop corrective actions where needed.
Other preventive actions can include regular “plant walks” with the QA and plant managers conducting a full walk through, specifically to detect any foreign object potential; using only metal-detectable utensils and small equipment (including pens, zip ties, earplugs, etc.) that are metal detectable; ensuring all containers (such as totes, etc.) are in good condition with no cracks or missing pieces; having colored utensils, bags gloves, aprons, etc., to help enable detection; keeping wood out of production areas; and having foreign object detection equipment as CCPs.
Another important tool to mitigate the risk of foreign material is a robust preventive maintenance program. Such a program should check equipment for signs of failure and check filters and sieves on a regular basis to ensure they are intact. Discovering a break in a sieve with lost metal components is a bad day; but when you find out that the last time that sieve was checked was two months prior, your day just got a whole lot worse.
While keeping foreign material out of food is the primary focus, effective use of metal detectors, magnets, X-ray equipment or optical sorters can all help mitigate risk. Such equipment needs to be validated and then verified on a regular basis.
Because of the serious risk of consumer harm from foreign objects in food, thorough control programs are critical – and are required by regulation. But there are times that an object can slip through even the most stringent program. When that happens and you have to recall product, you may want to take a page from the book of the retailer who went twice the extra mile to make it up to customers, stating, “Customers who purchased the affected products should not consume it and may return it to their local [brand] store for a refund equal to double the purchase price in accordance with Food Lion’s “Double Your Money Back Guarantee.”‘
