Chemical Hazards: Their source and control

By Charles Starkey, PhD, Auburn University

This is the second article in a series that aims to assist renderers, their suppliers, and their customers better understand the complexities of potential contaminants in rendered products (the first, “Physical Hazards in Raw Material: Their source and control,” appeared in the June 2015 Render). The goal is for these articles to help renderers complete animal food safety plans, meet requirements in the new Food Safety Modernization Act (FSMA), and control potentially harmful hazards in rendered products.

Whenever discussing any food safety topic, it can be difficult to know exactly where to start so this discussion on chemical hazards in rendered products will begin with the raw material source and traverse the rendering process. While the information below may be second nature to many readers, hopefully it will help others to better understand potential hazards and good manufacturing practices that can minimize chemical contamination.

The origination of most contaminants renderers contend with comes from raw material suppliers. It is important to note that these contaminants are not intentionally introduced but occur because of accidental inclusion or, in some cases, poor training and understanding of the further use of raw materials. It is still uncertain at this time whether or not many raw material suppliers will have to follow the requirements of FSMA. With that said, it will still be the responsibility of the rendering and feed industries to reduce or eliminate the risks posed by potentially harmful contaminants. Within the FSMA regulation, feed ingredient suppliers and feed manufacturers will be required to maintain an approved supplier list.

Because of this obligation, renderers will need to develop an approved supplier program in which suppliers are provided detailed specifications, including that raw materials contain no unacceptable contaminants. Check that contractual agreements include these agreed-upon product specifications. In addition, work with suppliers to make certain they have all the training materials needed for their employees to understand the issues surrounding food safety regulations and what the raw materials are ultimately used for.

Here are some items to include in discussions with suppliers (both raw material and other ingredients): Does the supplier keep an up-to-date record of chemical use in their facility? Are the chemicals used according to Food and Drug Administration (FDA) food production regulations? Are suppliers aware that finished rendered products are regulated under FSMA, which requires renderers to accept only raw materials that will allow them to be compliant? Does the supplier have a hazard analysis and critical control point (HACCP) or FSMA plan in place for the raw material that includes a section on chemical hazards? Has a raw material specification document been developed?

The most beneficial step the rendering industry can take is to work with suppliers to make certain they understand the renderer’s needs and wishes regarding raw materials. The most important thing to realize in this effort is that the sharing of these messages and education programs can never, ever stop and must be ongoing with dedicated personnel. Employee turnover, among other issues, will require that suppliers be continually reminded to eliminate sources of contaminants. Moving forward, it will be necessary to work closely with suppliers and engage their assistance to make sure their raw material streams are treated in a similar fashion as their food product streams.

Supplier’s Role in Elimination of Chemical Contaminants
While many suppliers of raw materials will not have to submit to FDA inspections under the new FSMA regulation (i.e., grocers, butchers, farms, etc.), they will have to comply with this rule in order to supply renderers with material that is safe to use. Raw material suppliers should already have some sort of HACCP (if required) or food safety plan in place to validate best practices and the safety of their food products. It is really a simple matter to add the flow of their raw materials to this plan and ensure safety of these products as well.

All companies are required to control chemical use and have ready access of all chemical Safety Data Sheets (SDSs). There are some great programs like MSDS Online and others to help keep track of this information or to search for additional SDSs. When developing the supplier relationship and agreeing on specifications for the raw materials received, renderers should request copies of these plans and the corresponding SDSs. The manner in which these chemicals are used within the supplier’s facility must follow the rules set out by FDA for food contact, food contact surfaces, and non-food contact surfaces. This review of chemical usage by the supplier is important so no unwanted chemicals enter the raw material stream inadvertently. It is also important for renderers to employ personnel with a good working knowledge of the approved food chemicals and for those personnel to be able to offer alternative solutions to raw material suppliers. It is also imperative that renderers work with their suppliers to help them understand that raw materials cannot be collected unless only acceptable chemicals are used in the food production process. Remember that everyone must share in the liability and responsibility of producing safe animal foods.

Common Chemical Groups to Consider
There are many chemicals that may be used by both the supplier and rendering facility. Below are some chemical groups that need to be addressed.

Lubricants: It is preferable that renderers and raw material suppliers use food-grade lubricants in their facilities. These may be slightly more expensive, but these products have become more common and improved over the years. However non-food grade is sufficient provided the raw material and rendered product are not contaminated with the lubricant. Ideally, a closed processing system will ensure any lubricant does not contaminate the material.

Cleaning and sanitation: Always evaluate these chemicals to determine if they are safe to use. The supplier must take all possible steps to make sure the raw material flow is not contaminated with cleaning chemicals and sanitizers. This is an area that may be overlooked in some plans so make certain suppliers are aware of the issue.

Processing or treatments aids: These chemicals include processing aids that may be used for product, wastewater, or raw material treatment. It is important to know how and where such products are used and ensure they are not a source of contamination.

Pesticides, herbicides, and other-use chemicals: These must never be allowed to enter the raw material flow. Specific plans should be in place to assure that the supplier as well as the renderer control the use of these products so they do not make contact with food or raw materials. It is also important that any food contact surface where these chemicals may be applied is completely cleaned and drained to an alternative water treatment area.

Additional items like antimicrobials, pharmaceuticals, personal care products, and so on should also be discussed with the supplier to make sure that none of these products have a way of entering the raw material stream. It may be beneficial to test the water supply of both the rendering plant and the supplier to check that none of these chemicals are entering in that manner. At times there are contaminants that can be present in municipal or rural water systems that are not removed in their treatment process.

Rendering’s Role in Removing Chemical Contaminants
The following are some additional procedures to assist in eliminating potentially harmful chemical contaminants from the rendering process stream. This is not a complete list, but a few suggestions that can help.

When receiving raw materials at the facility, it is essential to evaluate the product prior to placing it into the process stream. Is every load delivered to your facility inspected? If not, be sure to inspect raw materials, when possible, prior to them being placed into a receiving bin or tank. While chemical contaminants can rarely be seen with the naked eye, the inspection process can catch chemical containers that may have accidentally entered the raw material.

The next decision is what to do if the load is contaminated. Should the load be rejected? (The best answer would be yes.) Is the raw material supplier notified? Are records kept and evaluated as to the frequency of adulterated products received from suppliers? Are these records shared in formal meetings with suppliers? It is always best to reject a chemically-contaminated load prior to receiving it into a facility.

Once the raw materials have been put into the process stream, it is then the obligation of the rendering facility to ensure no potentially harmful chemicals are present or introduced by the facility itself. The need to prevent the introduction of chemicals used in the rendering process itself cannot be stressed enough. Employees must be adequately trained on proper use of all chemicals and provided direction on when and where it is appropriate to use such chemicals.

The use of chemicals in and around the rendering facility must be closely monitored. Chemicals should be used only by properly trained personnel and stored outside the production areas in approved containers or chemical storage cabinets.

Use an additional testing procedure for chemical contaminants in finished products prior to shipment. Although this is something renderers have done for some time, it is still a good procedure to follow if and when possible.

Many individuals in upper management and operations may say, “We have heard and tried all of these before.” That may be the case, but what about newer employees? Do they understand the importance of the quality requirements of the finished product? Do they understand the general substance of new regulations? Has this sentiment been adequately expressed within and throughout the company? Everyone must be involved in any good quality system in order for it to work. If one person is not thinking about quality in their job, it could lead to contamination and possibly a recall situation that can get very expensive very quickly. It is understood that implementing more security measures can cost both money and time as well as make the process more difficult, but if the manufacturing of animal feed ingredients and other products was easy, then everyone would be in the business. Each rendering facility, and not others in the food/feed chain, is ultimately responsible for removing these contaminants prior to shipping finished products so implementing more standard procedures will ensure this is accomplished.

It will take the dedication of personnel, time, and money to control potentially harmful hazards. Along with it being required in new FSMA regulations, removing hazards is the right thing to do. There is never any reason to place humans or animals at risk from the feed ingredients manufactured in rendering facilities. The rendering industry has been and will continue to be a leader in ensuring safe ingredients for use in the animal food chain.

Charles Starkey received his bachelor of science and master of science degrees from Arkansas State University, and his PhD from Kansas State University. Previously, he worked with DSM Nutritional Products and Balchem as a nutrition and production management consultant. Starkey also was director of technical services at American Proteins Inc. responsible for quality assurance, quality control, regulatory, analytical services, and customer support and compliance. He is now an Assistant Professor in the Poultry Science Department at Auburn University.

June 2016 RENDER | back