Good Manufacturing Practices will provide extra support to a HACCP & SSOP system; a functional Food Safety System will provide a safe and wholesome product.
If adequately designed and executed, an establishments “Food Safety System” will allow a safe and wholesome product to be produced prior to entering commerce. HACCP and SSOP provides a written program as to how the establishment will provide proper sanitation, product handling, and packing, while the GMP, or Good Manufacturing Practices, will back-up the HACCP and SSOP programs to further eliminate the possibility of any other contamination.
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Planning Good Manufacturing Practices – GMP Program
Good Manufacturing Practices basically include issues that are not covered in an establishment’s HACCP or SSOP program. GMPs provide establishment employees a “guideline” on potential food safety issues that could possibly be overlooked.
An establishment that is interested in developing a written Good Manufacturing Practices program should begin by monitoring common issues throughout the establishment. These issues could include: employee food handling, sick employees, establishment pest control, dry storage areas, properly dressed employees, etc…
When an establishment is planning to design a GMP program, it’s common practice to ask for outreach through their State Meat Inspection program, or the USDA FSIS Inspection program. Both the State Meat Inspection program and the USDA should provide In-plant Inspection Personnel or an EIAO (Enforcement Investigative Analysis Officer) to assist with the development of a properly designed GMP program.
Designing a GMP Program
When designing a GMP Program, the HACCP and SSOP programs must be closely reviewed to determine which areas and processes of these programs could be improved with “back-up” from a GMP program. Most commonly, high-risk products such as Ready-To-Eat (RTE) products and ground beef will greatly benefit from a GMP program. For example, in RTE and ground beef products, the GMP could include a back-up sanitation program to validate that employees are entering these processing areas only after properly sanitizing their boots, aprons, hands, and other equipment to help eliminate any cross contamination of bacterial organism.
Other issues to consider in the design of a GMP program could possibly include: employees wearing smocks and aprons outside the premises, food and drink within processing areas, tobacco use within the establishment, proper knife and scabbard sanitation and sterilizing, and cross-contamination from employees traveling from one processing room to another without sanitizing boots.
Documentation and Execution of Good Manufacturing Practices
Once the GMP program has been developed and provides written procedures of any potential contamination from issues not listed in the establishments HACCP or SSOP programs, proper execution of the GMP program should be monitored, and results of the monitoring should be fully documented. It is this documentation that provides evidence of the establishment’s execution of the GMP program.
Most commonly, the execution of the program is performed by following the written GMP program itself. The GMP program should include each area of the establishment along with what and how these areas will be monitored. Once the monitoring of each area has been completed, a GMP form (which should have been created upon completing the design of the GMP program) should be completed, dated, and signed by the responsible employee(s) who performs the actual monitoring of the program.
As with other programs such as HACCP and SSOP, the GMP monitoring log should be reviewed daily to validate that it has been properly completed and all areas of the establishment have been monitored. GMP programs are not required to be implemented in establishments, but these programs will provide extra support in an establishment’s Food Safety Program.
