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Dr Nigel Davies, Manufacturing and Technical DirectorWhy UK Malt Protects Your Brand – World Class Food SafetyFOOD SAFETY ASSURANCES TRACEABILITY: FARM TO CUSTOMER
STRUCTURE OF FOOD SAFETY CONTROL
• Food safety and assurance across all stages of processing• is the most important consumer requirement• Food safety is maintained by good traceability• In the UK since the Food Safety Act was introduced in• 1990 all food processing factories have targeted• improved hygiene levels• Implemented via legislation registration or best practise • Malting has become food factory orientated even though• malt undergoes further processing prior to consumption• Definition of consumer now incorporates both• human and animal feed.
Examples of pre-requisite control measures that form a basis for a HACCP protocolThis table lists some of the key pre-requisites that must be in place for a suitable HACCP system for malting. It demonstrates the foundation on which a HACCP study can build.
HACCP• Hazard Analysis and Critical Control Point (HACCP) is • the most common food safety system• Large food supermarkets require a higher standard• Large food supermarkets require a higher standard e.g.• British Retail Consortium Global Standard Food (BRC)
OUR QUALITY STANDARDS
ISO9001:2008 Quality Management System
ISO14001:2004 Environmental
Management System
ISO22000:2005 Food Safety System
Muntons Malt are “Assured UK Malt”
Suppliers
Organic Certification Feed Materials Assurance
BRC Global Standard – Food:Grade A
All products GM freeand TASCC assured
HACCP• HACCP – Hazard Analysis And Critical Control Points• Developed by NASA to make sure astronauts had negligible chance of getting ill when in space• Looks through the process or system to identify all the risks to food safety• Then looks at how they can be prevented.• If a preventative measure fails but the error can be corrected further along then that• control point is not critical• If a preventative measure fails and there is no possibility of correcting the error later in• the process it is a CRITICAL CONTROL POINT
Example three magnets (M) in a process line:• Case 1 – all magnets operational• Case 2 – magnet 2 fails, but process passes because the third magnet can remove metal• Case 3 fails because metal particles could get into the productMagnet 3 is the CRITICAL CONTROL POINT
HACCP: Critical control points
M
M
M
M
M
M
M
M
M
CONSUMER PASS
CONSUMER PASS
FAILCONSUMER
• A dedicated central compliance team is essential • Regular Good Manufacturing Practice (GMP)• audits required • Multi-disciplinary HACCP team• All staff trained by bespoke Food Safety & Hygiene course• Internal plant and personnel hygiene monitored by• dedicated compliance team member
GMP & HACCP BACKBONE OF ASSURANCE
EXAMPLES OF PRE-REQUISITE CONTROLS
• How a HACCP assessment is made• Conduct a hazard analysis: • – Draw up a process flow diagram • – Look at Physical, Chemical, Biological hazards• Determine the control points e.g. magnet, sieve, analysis• Establish limits for these controls e.g. analytical tolerance• or range, microbiological counts• Devise a system to monitor your controls e.g.• recording sheet and cross checks• Verify that the procedure is working e.g. review• contamination claims or test product to ensure absence• of a compound• Review the procedure at least annually to make sure• no risks have changed
Area for Control Method of Control
Grain intake and storage
Strict control of reception and storage of grain e.g. moisture.Strict terms and conditions for supply and supplier evaluation.Use assured grain suppliers. Due diligence sampling to assure controls effective
Must be of a high standard throughout the maltings e.g.different coloured brooms for areas with different risks: green for outside roadways and paths, blue for inside the plant and red for germination boxes. Keep cleaning of food and pedestrianareas separated.
No loose jewellery, watches, spectacles or anything else that could fall into the product / process.
Minimal glass allowed on site. All glass or brittle plastics must be on an audited register and risk assessed.
If allowed on site it must be restricted to a defined area away from production
Hand washing or sanitising stations must be provided at entrances to food areas e.g. germination boxes
Chemicals must be food gradeCleaning schedules must be documented
Must be extremely thorough and any actions identified rectified immediately
Brief induction in food safety at reception to site
Basic hygiene rules are mandatory and staff are restricted from work if they or close family members are ill
TRACEABILITY LAWS• EU regulation 178/2002• US Bioterrorism Preparedness• and Response Act• Federal Food, Drug and• Cosmetic Act
REQUIREMENTS• Both physical tracing of• documents and food safety• awareness in supply chain• Protects up and down stream
Housekeeping
Jewellery
Glass
Smoking
Personal hygiene
Cleaning
Pest control
Visitors and contractors
Personnel hygiene
The HACCP risk assessment is carried out
by a multi-disciplinary team representing a
cross-section of the staff e.g. operators, engineers,
microbiologists and managers, and led by a certificated HACCP lead
auditor or equally qualified person.
• Mycotoxins from fungal growth on grain • INTAKE from Harvesting – DON, T2, HT2, ZEA• Grain storage on site – OTA• Control is via drying and moisture control and inoculum reduction in the supply chain
• Pesticide application • IN FIELD or POST HARVEST - use of non-approved materials or incorrectly applied• mixture (too concentrated, at wrong time, at wrong dilution)• Control is by using assured supplier, post harvest declaration and due diligence testing• of pesticide residues
• Glycosidic Nitrile• During steeping this compound can form and generate ethyl carbamate in distilled• products – a toxic chemical • Control is to use a low or zero GN barley variety
• NDMA (n dimethylamine)• KILNING: If air is high in Nitrous oxide (Nox) e.g. from direct fired heating or from• traffic fumes it can enter the kiln air intake and combine with amines in malt and• make a carcinogenic NDMA • Control: either use indirect firing and avoid lorries parking by intake or add sulphur• dioxide to the direct fired system
The team looks at every aspect of the malting
operation and establishes which points are critical
control points (CCP)
The best practice is to have a formal written
description of each CCP at the point where operators can see them. It describes what the CCP is, why it is needed and the impact if
the control fails.
MALTING CCP’S
• MAGB HACCP code is the basis• Grain sourced via auditable Farm•• Assurance Scheme• Risk based approach to sampling and screening• Supply-chain traceability / product recall• Effective Quality Management System• Effective control of factory environment• standards, product, process and personnel• External auditing
ASSURED UK MALT
“The resultsof this survey confirm thatUK malts are wholesome and comply with legal limits for contaminants.”
MONITORING RISKpositive PR statement
✓
FARM 1 STORE 1 DELIVERY 1
FARM 2 STORE 2 DELIVERY 2
FARM 3 STORE 3
BATCHD
STEEPINGBATCH D1
BATCH D1
BATCH D1
BATCH D1
GERMINATION
KILNING
DISPATCH
Must be able to trace every load of malt back to the barley used
Barley and Malt can only have certain tested and approved pesticides applied
Chemicals that are approved on the BBPA list have been shown to be food safe throughout the brewing process and by detailed chemical analysis. For these trials the application of the chemicals is at TWICE the normal levels to increase the certainty of safety when testing for residues. These chemicals are also checked against international databases on food safety. Only chemicals passing both process trials and with no detrimental entries in the food safety databases and in process trials are authorised to be included on the BBPA accepted list.
Only those demonstrated to have no effect on malting, brewing and human health are permitted
Approved list is published in the British Beer and Pub Association (BBPA) & Campden – BRi list
All post-harvest pesticide application must be declared on intake documentation
All barley is bought from approved suppliers e.g. Assured Combinable Crop Scheme (ACCS)
Samples taken for analysis by external accredited company to demonstrate ‘due diligence’
Standard covers:• Literature Requirements• Crop Protection• Seed / Seed Treatment• Fertiliser & Crop Nutrition• Crop Storage & Handling• Hygeine• Transport• Contractors• GM Crops / Materials• Complaints• Fuel Storage• Contaminants
• Operators assess barley at intake by smell as well as sight • Individuals can be assessed for their ability to detect a synthetic • mould aroma analog. This is unique to Muntons.
HOW DO WE ASSURE SAFETY?
Water Quality: Must be potable with no pathogensEquipment: control of presence of glass or brittle plastic near open production areas(so can’t fall in)Cleaning: with food safe chemicalsMachinery: uses food safe lubricants and greasesPersonnel: cannot wear jewellery, must wear hairnets and overalls with no external pockets; operators and visitors screened for disease and excluded if infectiousAccess is controlled by coded locks. Allergens such as nuts not allowed in production areas. Prevention of pest ingress e.g. insects, birds, rodentsProcess aids: must be food approvedAir quality: Nox must be low and final malt measured for NDMA (n- dimethyl amine: safe level is 5ppb, most maltings operate at around 1ppb: formed if NOx high and combines with amino acids in malt)
ALL staff on site trained in basic food safety and hygiene
Secondary metabolites produced by Fungi if not treated properly during growing or harvesting or if not stored properly after harvest and which if not kept below strictly controlled safe levels of temperature and moisture can be dangerous to health.
Which Fungi create them?Aspergillus / Penicillium / Fusarium
They can arise in:poorly treated grain in the field / poorly stored barley ormalt in storage
• Rapid test kits are used during intake to check for mycotoxins• Initial checks made at harvest time fo seasonal risk assessment• Checks also done on stored grain• Historically UK has had very low levels of mycotoxin
Sampling frequency based on risk modelling
Then back to the farm
Must be able to track pesticide applications
If a container used must be able to trace back to the container itself and the batch of container liners used
Must do a test recall annually
Within 2 hours
DELIVERY 3
BATCHA
BATCHB
BATCHC
CUSTOMER12345....................
SUPPLY CHAIN TRACEABILITY
TESTED ANNUALLY TO PROVE IT WORKS!
How fast can we do it?
Serious problem
identified
Samples traced back to
barley at intake
All dispatches to customers from
same batch identified,
remainder of batch quarantined before
3.00pm 3.30pm 5.00pm
TRACEABILITY – A MUST
TRACEABILITY AND ANALYSIS
✓
• All transport that is used to transport malt or• co-products must be fit to carry a food material• Applies to the inside and outside of the vehicle• Only certain materials are allowed to be carried in• the vehicle• Specific materials excluded e.g. fish, coal• Record must be kept of last 3 loads• Can gain certification of transportation via• TASCC – the Trade Association Scheme for• Combinable Crops
TRANSPORTATION
DUE DILIGENCE
Not acceptable as a business risk to assume that the barley being supplied is food safe
Samples are taken according to schedules designed to reflect the risk to health of pesticide, mycotoxin and heavy metal residues
All samples must be below the legal Maximum Residue Limit
We test for Pesticides, Mycotoxins and Heavy Metals
TRACEABILITY AND PESTICIDES
INTAKE
INTAKE SENSORY ANALYSIS
CONTROL OF MYCOTOXINS
FURTHER FOOD SAFETY CONTROLS
GRAIN ASSURANCE SCHEMES
HOW CAN MALT AND MALT PRODUCTS BE CONTAMINATED?
SAFETY CHECKSWhat are our operators looking for?
Container liner
StonesGlass
Wood
PaintCleaning fluids
Hair
RustBacteria
(low risk unlessSalmonella)
Yeasts(unlikely)
Moulds(Main issueis Fusarium)
Mouse Dropping
PHYSICAL MICROBIAL
Mould /Pink GrainsAdmixture
StonesErgot
Rodent droppingsPre-germinated grain
Insect damageBroken Grain
0
15
12%
25
20
Ap
pro
xim
ate
Mo
istu
re C
on
ten
t (%
)
What are safe storage conditions for Malting BarleyTemperature (ºC)
Fusarium
Penicillium
Aspergillus
ThermophilicFungi
-10 0 10 20 30 40 50 60 70
Many maltings exceed minimum frequency of standard spot checks
UK Malt is the safest in the World
THE BBPA APPROVED PESTICIDE LIST IS ULTRA-SAFE!
Coloured areas show conditions
that favour fungi that could generate
Mycotoxins
Muntons store barley well inside the safe zone
Operators must maintain good sensory ability to make intake decisions.
WHAT ARE MYCOTOXINS?
RESEARCH &DEVELOPMENT
Source: “Food safety review of UK cereal grainfor use in malting, milling and animal feed” – HGCA