Stewart and Michael Parnell may not be household names in the celebrity sense, but ask the average quality professional who they are and it’s a safe bet that you will get the right answer. Not for their commitment to product quality, sadly, more that these two people are the face of one of the most egregious episodes in food safety history.
It’s been over 10 years since the multi-state peanut butter salmonella outbreak in 2008 and 2009 that killed nine and sickened over 700 people, leading to one of the largest recalls in U.S. history. Details of the investigation and criminal case tell a disturbing story of food safety gone awry, complete with fraud, lies to federal prosecutors and knowingly selling products that tested positive for contamination.
After weeks of investigative journalism by a number of recognized media outlets –the Washington Post and the Chicago Tribune, to name two – the Peanut Corporation of America (PCA) became synonymous with unsanitary conditions at various production facilities and a litany of U.S Food and Drug Administration (FDA) compliance violations. These included deceased animals in peanut-roasting areas, damaged buildings that were open to the elements and a cavalier attitude to the actual quality of shipped products.
The end result was a conviction of five company officials in 2015, which included the Parnell brothers, Mary Wilkerson (the quality assurance manager), the plant manager and the operations manager. All of these people were, according to court statements, aware of the problems at the PCA plants and played a major role in ignoring the risks to public health.
According to Food Safety Magazine, the U.S. Court of Appeals for the Eleventh Circuit will hear no more appeals in the case of the Parnell brothers, both former executives at the now-defunct PCA. At the time of writing, the pair are in federal prison facing decades of incarceration for their role in the biggest food safety conviction of all time.
Did these people commit crimes? According to the courts, yes. Does it look like they intended to cover them up and make money while doing so? Yes.
But if you rewind all the way back to what started the problem in the first place, you won’t find evil corporate villains with a twisted desire to sicken consumers. From day one, the quality issues came down to sanitation and pest control—and a complete and utter failure to follow hazard analysis critical control point (HACCP) principles.
With that in mind, let’s take a dive into what companies need to know (or should already know) about HACCP. And while this post gives a high-level overview of the basics of HACCP, it goes without saying that a systematic approach to food safety can help avoid recalls, public harm and even criminal penalties for company leaders.
What is HACCP?
According to the FDA website, HACCP is “a management system in which food safety is addressed through the analysis and control of biological, chemical and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.”
On a practical level, an effective HACCP system is designed to help companies prevent problems before they occur (as opposed to simply trying to detect problems after food has been produced). In other words, adopting a proactive rather than reactive attitude to food safety.
We should note that the FDA only mandates HACCP for juice and seafood processing, while the U.S. Department of Agriculture (USDA) requires HACCP for meat and poultry (which includes egg products). Any company can implement HACCP to reduce risk to consumers, however, and considering the daily headlines of food safety failures throughout the supply chain, it’s more than just a good idea.
HACCP can also help satisfy Food Safety Modernization Act (FSMA) requirements to establish systems for identifying hazards and implementing preventive controls. For those willing to go beyond compliance, a leadership-driven commitment to HACCP principles can help create a culture of quality where everyone takes ownership of food safety.
The Seven Principles of HACCP
The concept of HACCP is built around seven core principles or steps:
- Conduct a hazard analysis
- Identify critical control points (CCPs)
- Establish critical limits for each CCP
- Establish monitoring procedures
- Establish corrective actions
- Establish verification procedures
- Establish record-keeping procedures
More detailed guidance can be found in the FDA’s HACCP Principles & Application Guidelines, which manufacturers can use to get a greater understanding of what is required. This information also includes examples of flow diagrams, decision trees and federally mandated compliance requirements.
Prerequisite Programs: The Foundation of HACCP
The caveat is that addressing the seven principles of HACCP alone isn’t enough to ensure food safety. The FDA makes it abundantly clear that HACCP plans must be built on top of prerequisite programs (PRPs) that include Current Good Manufacturing Practices (CGMPs) and compliance with federal, state, local and international regulations.
In other words, PRPs cover the basic requirements for producing safe, high quality food. Examples of PRPs include:
- Sanitary design of manufacturing facilities
- Supplier quality management processes
- Specification and standard operating procedure (SOP) management
- Preventive maintenance scheduling for equipment
- Chemical and hazardous material control
- Lot coding to ensure traceability
And there’s more …
In addition to having prerequisite programs in place, the FDA outlines a number of preliminary steps within its guidelines for developing an HACCP plan. Before diving into or integrating the plan, organizations need to:
- Designate a multidisciplinary HACCP team with employees from engineering, production, sanitation, quality and microbiology
- Describe the food, including ingredients and processing methods, as well as distribution methods and temperature requirements
- Describe intended use and target consumers, whether that’s the public or a group such as infants
- Create a simple flow diagram covering all the steps in the manufacturing process
- Verify the flow diagram is accurate and complete via onsite review
- Ensure adequate employee training in HACCP principles and critical practices relevant to their role
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Food safety is always the priority
Getting the preliminary steps, PRPs and HACCP principles right requires a team effort, as well as the visibility and control to keep the plan on track. A flexible, workflow-based Food Safety Management System (FSMS) satisfies on both counts, giving manufacturers the tools they need to ensure food safety and protect their brand reputation.
Ultimately, no food and beverage company wants to have its processes laid bare in front of a national audience, especially if the product is both an ingredient and a stand-alone food. The Parnell brothers may be serving time for their peanut quality failures, but an effective HACCP process is a good way to ensure that companies don’t make the same mistakes in their own quality journey.
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