Chapter 3: What Potential Food Ingredient Hazards Occur in Human Food
3.4 New Hazards in Food Manufacturing
No book or other reference can be comprehensive, nor should any such reference be used as an exhaustive listing of food ingredient–hazard pairs. Likewise, not all ingredients that may be used to produce human food can be completely covered in any one resource, and each should be researched against the most current regulatory and academic publications to ensure all hazards are considered. Because of the pace of technology and food production changes that occur in the food industry, it is important to establish a process to monitor the food ingredient-hazards list for each of your products to ensure new, previously unknown hazards (which may be the root cause of many outbreaks with unknown causes shown in Table 3.2) that become known do not now impact your product’s safety. For example, L. monocytogenes has long been recognized as a hazard in dairy products such as butter, cheese, and ice cream and in RTE deli meats and pork and poultry RTE products, but had not been considered a hazard with caramel apples (although they are made with raw produce, wooden sticks, and dairy ingredients). However, a deadly 2014 listeriosis outbreak that caused 36 illnesses and at least three deaths across the United States and Canada was attributed to caramel apples (Centers for Disease Control and Prevention, 2015a; Food and Drug Administration, 2015b).
Although caramel apples as the source of this outbreak seemed unlikely as neither apples (which are too acidic) nor caramel (with low water activity) normally support the growth of L. monocytogenes, subsequent research showed that significant growth of the outbreak strains of L. monocytogenes occurred when the wooden sticks were inserted into the apples, releasing juice and producing a new microenvironment where the bacterial pathogens could grow to hazardous levels to cause disease (Glass et al., 2015).
What Potential Food Ingredient Hazards Occur in Human Food Manufacturing? 53 The best place to review and confirm potential ingredient-related hazards in human foods is in Appendix 1 of FDA’s Draft Guidance for Industry: Hazard Analysis and Risk-Based Preventive Controls for Human Food (Food and Drug Administration, 2016). How can you stay abreast of new hazards that are not listed in this guidance when they are discov- ered? To best track new hazards to ensure each of your food ingredient–hazard pairs are up-to-date, monitor all CDC outbreak investigations, FDA recalls, and any FDA reports on new guidance documents to control foodborne disease risks.
In Chapter 4, we will discuss potential facility-related hazard pairs (facility and equip- ment related) as a final step in defining all known potential hazards of your products.
This information will then enable the hazard analysis of each product (Chapter 5) so that the preventive controls necessary to manage all potential hazards of each product can be defined (Chapter 6).
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