Process Controls
Process controls are very formal ways to closely monitor, control, and record manufacturing processes that are defined as critical (in HACCP, these are the critical control points). Mistakes are usually prevented and corrected quickly if they do occur. In rendering, it is critical that sufficient temperatures are attained, so cooking would be addressed with a process control at any rendering plant. Cooking times and temperatures should be closely monitored, controlled, and recorded. Some plants, depending on their raw materials, may have additional process controls for things such as size of grind.
Best Management Practices
GMPs are basic procedures done by a rendering, food, or feed establishment so that products are clean and safe (GMPs are sometimes called prerequisite programs in HACCP). GMPs are generally less strict than process controls and are used to control factors done in conjunction with manufacturing processes that do not need constant process control. Some firms may address something like sanitation with a GMP while others may address it with a process control. The important thing is to get it done right. Many plants use GMPs to address these items:
• Product flow and traffic control to minimize cross-contamination from raw to cooked materials;
• Raw material inspection;
• Preventive maintenance and calibration schedules and documentation;
• Procedures and schedule for cleaning and sanitation of equipment;
• Employee training on cleaning and sanitation procedures, personal safety, and their role in safe feed;
• Procedures to assure the segregation and proper use of chemicals in the plant;
• Receiving, storage, loading, and shipping;
• Traceability and recall plans; and
• Pest control.
Program Credibility
Most rendering plant managers know what they are doing and they indeed produce safe, high quality products. But, it’s one thing to know you are doing a good job and saying so, and another thing to have everybody believe it. It’s also not possible for customers to know that two claims of processing excellence are equivalent without documentation. An integral part of the Code of Practice is the independent third-party audit. This is verification that the plant has a plan, has a strategy to minimize risk from hazards, and is doing what they say they are doing.
The auditors are individuals under contract with the Facilities Certification Institute. Most are retired from the feed industry in which they served in capacities such as quality control. They are trained to do audits for the American Feed Industry Association Safe Feed/Safe Food program, but more importantly, they are specially trained on the rendering industry and the Code of Practice. Representatives of National Renderers Association member companies and myself spent an entire day discussing each point of the program and the expectations of the auditors.
Why Not Just Call it a HACCP Plan?
HACCP plans and the associated training programs are excellent. The concept of customizing a plan for a particular situation works very well as a voluntary approach. HACCP originated in the 1950s to ensure the safety of food for astronauts during space flights where getting food poisoning would be a disaster. In 1996, the U.S. Department of Agriculture (USDA) established a detailed pathogen reduction HACCP program under the Food Safety and Inspection Service to regulate the production of raw meat products by large-scale facilities.
The marriage of a voluntary self-motivated risk-based program with the rigid regulatory atmosphere of meat and poultry inspection has been a rocky one. Only recently, in 2007, is USDA testing a risk-based approach to inspection for meat and poultry – 11 years after embracing HACCP. Having regulatory authority layered over HACCP has led to many problems such as meat inspectors unnecessarily telling plants how to do things in a prescriptive manner. Renderers chose to avoid any confusion with USDA’s regulatory version of HACCP by naming the program Code of Practice, while recognizing that it is a HACCP-like program. The industry accepts the flexibility and problem-solving nature of HACCP but not the regulatory application of it.
The problem with a regulatory or mandatory program is that it often assumes regulators or inspectors know how to run grinders, cookers, presses, and process control. They don’t. The flexibility and self-motivation are critical. The marketplace will offer sufficient pressure on renderers to move ahead with raising the level of sophistication in manufacturing practices. As fish and shrimp producers demand traceability of ingredients, as feed manufacturers track the origin and quality of incoming products, and as feed safety becomes integrated with food safety, customers of rendered products will start seeking out renderers certified in the Code of Practice.
Finding a Certified Renderer
There are currently 36 plants certified, as listed below and on APPI’s Web site at www.animalprotein.org, with dozens more plants to be certified in the near future.
American Proteins, Inc.
Hanceville Div., Pet Food
Hanceville Div., Feed Grade
Cargill Meat Solutions
Beardstown, IL
Dodge City, KS
Friona, TX
Ottumwa, IA
Central Bi-Products
Long Prairie, MN
Redwood Falls, MN
Darling International, Inc.
Denver, CO
Mason City, IL
South Omaha, NE
Darling-National, LLC
Berlin, WI
Wichita, KS
Farmland Foods
Monmouth, IL
Hormel Foods
Austin, MN
Fremont, NE
Mendota Agri-Products
Mendota, IL
National Beef Packing Co., LP
Liberal, KS
National Beef California, LP
Brawley, CA
John Morrell Animal Feeds
Sioux City, IA
John Morrell and Company
Sioux City, IA
Sioux Falls, SD
National Beef Packing Company
Dodge City, KS
Packerland Packing Company
Green Bay, WI
Sanimax, LLC
Green Bay, WI
South St. Paul, MN
Smithfield Packing Company
Smithfield, VA
Tar Heel, NC
Tyson Foods, Inc. - River Valley Animal Foods
Clarksville, AR
Harmony, NC
Robards, KY
Scranton, AR
Sedalia, MO
Temperanceville, VA
Texarkana, AR
Tyson Foods, Inc. - Specialty Products Division
Sequin, TX
Tech Topics - April 2007 Render