Understanding 3-A SSI’s new General Requirements standard
In an earlier column, we described the origin of the new 3-A SSI standard, “ANSI/3-A 00-00-2014, 3-A Sanitary Standards for General Requirements.” The new General Requirements standard was released on Sept. 8, 2014 following approval by the American National Standards Institute as an American National Standard.
The new standard covers the sanitary design, materials of construction and fabrication techniques for dairy and for other food and beverage equipment used to handle, process and package consumable products where a high degree of sanitation is required.
What exactly is in this document? Why is it critical to the goal of food safety in the dairy industry and across other sectors of the market for hygienic equipment? Let’s start with the second question.
The Food Safety Modernization Act (FSMA) established a new construct for documenting the elimination or reduction of risks to food for all parts of the food processing industry.
The FDA is currently developing rules in seven key areas to fulfill FSMA requirements. The Preventive Controls for Human Food rules will require food processors to maintain written plans for monitoring, verification and corrective action in a range of areas, including supplier management, allergen controls, process controls, GMP program oversight, product traceability, recall plans and intentional contamination or food defense. The final rules for Preventive Controls are not anticipated until late 2015; the actual compliance for processors under the new rule will likely begin in late 2016.
A number of schemes designed to help processors show compliance with the anticipated new rule now receive regular publicity in a variety of food publications. Some of the leading schemes or voluntary codes benchmarked under the Global Food Safety Initiatives (GFSI) include Safe Quality Foods, British Retail Consortium, ISO/Food Safety System Certification 22000 and others.
It will be the responsibility of the processors to know and understand the risk profile of the products they make as well as the appropriate equipment and the cleaning/sanitizing techniques necessary for such equipment. A deficiency or weakness at any level — whether in the compliance guides or in the resources employed to demonstrate the achievement of the objectives — will jeopardize reaching the goal of food safety in the processing system.
The new General Requirements standard was developed to address a long-standing need of 3-A SSI to modernize its system for managing an inventory of more than 80 3-A Sanitary Standards and 3-A Accepted Practices. The new standard covers common elements across this large and complex inventory of documents, including the sanitary design, materials of construction and fabrication techniques used to handle, process and package consumable products where a high degree of sanitation is required. The General Requirements will serve as a normative reference for all 3-A Sanitary Standards and 3-A Accepted Practices and extensive work lies ahead for 3-A SSI to transition all these documents to the newly revised criteria.
The voluntary codes cited above are quite extensive. Some address the entire food processing “envelope,” including elements of the facility site plan, and virtually all include some requirements for the safety of food processing equipment/systems. However, requirements are very general in regard to equipment, and only make general statements like “the equipment is to be designed and constructed to minimize food safety risks” or “not pose a contamination risk to food product.”
As for equipment choices available to the processor, design makes the difference. Cleanability must be designed into the equipment and systems. This feature cannot be added later. In order to clean process equipment, the equipment must first be cleanable.
The General Requirements standard addresses the features affecting cleanability, including materials and surface finishes, radii on wetted surfaces, drainability, cleaning methods and chemistry plus the ability to expose surfaces to cleaning solutions. These specific benchmark hygienic design criteria in the General Requirements provide an indispensable compliance resource for processors and equipment fabricators to use to help meet the requirements of various third-party auditing schemes and the anticipated Preventive Controls final rules.
Where the safety of food matters, so does the integrity of hygienic design criteria. The General Requirements standard is available for use on a voluntary basis.