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Rework management –Crucial aspect of food safety
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Thursday, 04 August, 2022, 15 : 00 PM [IST]
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Arya Indani &Khushbu Shah
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Food rework practices can vary from one food business to another food business. The US Code of Federal Regulation, defines food rework as being clean, unadulterated food that has been removed from processing for reasons other than insanitary conditions or that has been successfully reconditioned by reprocessing and that is suitable for use as food.
Generally, Rework is applied to a nonconforming product. The primary objective is to bring the product into its full conformity in terms of its intended use, performance, safety, and compliance with regulatory requirements.
Therefore, rework can be readily used as long as it is handled under good manufacturing practices (GMP), in a sanitary manner that would ensure that the rework is free from any microbial, chemical, insect, and foreign material contamination, also is in compliance with traceabilityand regulatory requirements.Rework is usually a process of the following stages:
- Accepting the need and inputs for rework
- Planning and documenting the rework activities
- Reviewing and approving the rework activities
- Documenting the relevant training on the procedure
- Performing the rework
- Validating the result of rework and re-inspection.
Some Examples of reworking may include:
- Re-forming meat patties rejected for being broken, underweight or improperly breaded
- Reprocessing dough left over from the previous production
- Repacking cookies that were mislabelled
- Re-cleaning grains that did not meet specifications
- Reprocessing cooked sausage as pizza topping or sausage crumble
- Re-baking bread crumbs that will be used to coat other food products
- Incorporating sausage end trimmings from one batch into the production of a new batch
- Mixing production from one day into a batch from a different day
- Depending on the industry category, using food rework may be a daily activity. Regardless of the frequency, there should be a plan in place to manage rework.
Challenges of Rework: Rework occurrences adversely impact the performance aspects of the food manufacturing process e.g. with respect to costs, time, quality as well.
The Time required for Rework: When it comes to the quality of the bulk of items, a major factor in fixing the problems is time. Inspection, undoing the error and then fixing it will take time, hence the factor Time needs to be taken into consideration while performing Rework. Time will be excessive if the order quantity is relatively big, and if the product is a low-cost promotional item. In some cases, rework can be expensive if the value of an order is low.
The Possibility of Quality Defects: In terms of defective goods, the risks are even higher. It is important to consider the possible negative effects of fixing these defective goods. Product rework almost always requires additional product handling by the production staff. Product handling is often the cause of quality defects in the first place.
Other potential hazards resulting from Mishandling rework material may include the following:
- Presence of undeclared allergens due to cross-contamination — for example when a product containing a specific allergen is mixed with a product that does not contain the ingredient and labelling is not changed to acknowledge the fact.
- Contamination with pathogenic bacteria due to improper personal hygiene or product handling practices
- Growth of pathogenic bacteria due to temperature abuse — for example, rework material that requires refrigeration is left at room temperature overnight and used as an ingredient in the next day's production. Another example of rework mishandling would be to allow frozen rework to thaw at room temperature rather than at refrigeration temperature.
- Growth of pathogenic bacteria due to time abuse — for example, rework material stored for long period of time due to improper stock rotation
- Presence of undeclared restricted ingredients in the final product — for example, addition of cured meat to a fresh meat product, which should not contain curing agents
Besides these potential hazards, the addition of rework may affect the formulation of the product because it can modify the nutrient content of the final product. If there is a need to use rework, ensure that it does not affect the accuracy of the nutrition declarations.
Documentation and Verification of Reworked Products: Each rework activity or operation must be documented. Each non-conformity will have its own specific rework instruction based on its nature and root cause.To document the rework effectively, it is necessary to identify all types of documentation needed for the rework: work instructions, process flow diagrams, and checklists, traceability records, outward inward register, and specifications. After the completion of documentationof rework, it is essential that the reworked products must also be verified to ensure that they meet the applicable acceptance criteria and regulatory requirements.
It is essential to maintain documentation work and verification of reworked products.This aids in traceability of the reworked products, in case of issues or customer complaints.
Traceability of the Reworked Products: Traceability or product tracing is defined by the Codex Alimentarius Commission as “the ability to follow the movement of a food through specified stages of production, processing and distribution”. Traceability plays a pivotal role for the Reworked Products as it helps to trace the products forward and backward.
This is helpful during customer complaints. Also it helps to identify and trace the products internally and externally. Internal Traceability means tracing the product within the process flow in the company. External Traceability means tracing the product backward to the supplier and forward till the consumer.
Factors Affecting Shelf Life of Reworked Products: Shelf life is the time after production that the food remains safe to eat or the period food can be used while maintaining its quality. Shelf Life depends on following factors: Water Activity: Foods having high water activity have the chances of getting spoiled early. Rework of such foods having high water activity have higher chances of getting spoiled early as compared to the final finished product. Since rework has shorter shelf life they should be processed early. Before storing all the Rework material should be properly labelled and identified for ensuring food safety. They should be stored separately under suitable conditions depending upon the product.
Salt& Sugar Content: Foods having high salt and sugar content have longer shelf life. Rework derived from such foods also have comparatively longer shelf life. This rework material can be reused for formulating other products. Eg: Remaining bottles of different types of pickles can be mixed to make mix pickle. Rework after cutting the brownie which has high sugar content can be processed again to form another finished goods. However, it is important to check the quality parameters before processing the product further. Also storage conditions need to be maintained according to the product till the time it is processed.
Moisture Content: Foods having high moisture content have low shelf life, Rework material derived from such foods also have shorter shelf life. Hence it needs to be taken care of till the time the rework is processed. The rework matter should be stored at ambient temperature and under suitable storage conditions. Rework derived from foods having low moisture content are stable when stored under suitable storage conditions also have longer shelf life as compared to rework derived from high moisture content foods.
It is crucial to label properly, and store and process the reworked foods separately in order to maintain safety of the food products. This also helps to reduce the chance of cross contamination and in allergen management.
Food Safety Aspects of Rework:
When handling rework, the following points should be taken into consideration: - Identify the rework material: Identification should be done appropriately for all the products including reworked products. Tags could be applied with product identification information, which may include name of the product, lot code and date of production. Also color-coded containers can be used to identify rework material.
- Store rework in a way that prevents contamination with potential food hazards and growth of micro-organisms.
- Store rework in an appropriate environment that prevents or minimizes food spoilage. For example, meat rework must be stored in a temperature-controlled environment at four degrees Celsius or less to prevent or limit the growth of microorganisms.
- Follow general good storage practices.For example:
- Store rework materials off the floor and away from walls to minimize contamination
- Cover and protect rework materials
- Use clean containers
- Ensure storage room is adequate for storing food products (ex: avoid pest access, permit maintenance and cleaning)
- Establish the maximum storage time for the rework material. For example, for meat products, the Food Safety and Inspection Service of the United States Department of Agriculture (USDA), recommends using rework meat only from the immediately preceding lot or shift and only within 24 hours of that shift.
- Put controls in place to prevent storing rework material for long periods. For example, the amount and type of rework should be recorded in the production record. This serves as a reminder to use the material when work resumes.
- Prevent cross-contamination with allergens. Inappropriate use of rework materials may result in the presence of undeclared ingredients in final products. This may trigger allergic reactions in some people who are sensitive to a specific ingredient or product. To prevent cross contamination with potential allergens not listed on their labels following could be done:
- Specify designated uses for rework materials. For example, use rework materials only with products that already have the same ingredients.
- Identify ingredients and ensure that rework containing different ingredients is not used in those products
- Establish the maximum amount of rework material allowable in a product to control the effect of rework on the final formulation. The amount of rework added should not alter the nutrition content or the ingredient listing of the product. Depending on the type of product, adding too much rework material could affect the validity of the nutrition facts panel. It could also affect the quality and shelf life of the final product.
- Develop a rework tracking system to be able to identify the final products containing rework materials. A rework tracking system will be necessary if a food product is recalled because it or any of its ingredients is identified as a health risk. If a food product is suspected of presenting a potential hazard to the public, there would be need to identify all of its raw materials and ingredients, including rework materials.
To keep track of the rework material:- Develop a recording system for rework that includes the time, quantity and processing step it was collected from, the original lot or batch number/code and the code of the lot or batch it was added to
- Record the use of rework material from a specific lot code/batch or production date in daily production record
- Train the staff. Make sure to communicate with the staff regarding all the instructions and procedures on the use of rework and the risks associated with the mishandling of rework material. Post a copy of those procedures at the plant in local language, if necessary.
- Monitor the use of rework. To ensure rework material is used and handled properly do the following :
- Confirm that rework material is properly identified
- Confirm that rework material is stored under conditions that protect the safety of products (ex: correct temperature)
- Observe employees handling rework to ensure they follow proper procedures
- Maintain appropriate records for all the processes.
- Monitor rework tracking system by reviewing records
- Allergen Management in Rework:For Management of Allergens in rework, the entire staff should be aware of what allergens are, identification of allergens. Trainings should be provided for Allergen management including allergens derived from rework also.Rework that contains allergens should be stored in sturdy containers with secure covers in designated, clearly marked areas. The rework should be appropriately labelled with all food allergens specifically highlighted, and properly inventoried and accounted for during storage and when used, to prevent or minimise the potential for incorporation into the wrong product. Also, displaying the rework poster will encourage the staff to be aware of the ingredients they work with and to prevent accidental contamination of the production lines.
(Indani is a food professional; Shah is director at ASK SafeFoodz Solutions Private Limited)
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