From the Other Side: Bio-Fuels Co-Products

by Matthew L. Gibson (Lee Enterprises Consulting, Inc./Biofuels Digest) ... Today I’m going to put on my “Food Production Hat” and share with you some thoughts about where your co-products ultimately end up: Food. What your downstream customers have to deal with. Hopefully, you can glean some nuggets to think about and start acting on.

First, let’s review the most significant events in American food production with respect to Food Safety.

...Federal Meat Inspection Act of 1906. Also, in 1906, the FDA was created through passage of the Pure Food and Drug Act.

E. coli O157:H7 outbreak in 1993 that sickened hundreds of people (and killed 4 children) in four states. ... Bill Marler, the attorney who prosecuted the case, is still actively pursuing “Food Litigation”.

Global Food Safety Initiative (GFSI)
The GFSI was created in 2000 by a group of industry cooperators who wanted to standardize food safety threshold schemes for manufacturers and farmers.

Food Safety Modernization Act (FSMA)
The FSMA was signed into law on January 04, 2011 and is considered the greatest expansion of scope and power in FDA’s history. Of particular note for bio-fuels producers is that “Livestock Feed” became legally defined as “Food”. ... Further, non-compliance can lead to penalties up to, and including, felony status.

10 Common “Food Safety Practices” not Commonly Employed at Bio-Fuels Facilities

1. GMPs – Good Manufacturing Practices: Yes – we follow GMPs for Feed. But, at the “Human Food” level, these are much more intense than for “Animal Feed”. Here are just a few examples. Prior to entering, or when working in, a food production area: (a) Employees must be clean and must wash their hands, (b) hair nets and beard nets must be worn, (c) no jewelry may be worn, (d) no food (lunches, drinks, etc.) may enter, (e) no tobacco, medications or even chewing gum. The list goes on and on (and on).

2. Process Tracking: Every single item (package or lot) of outbound product can be discretely tracked back to its individual lot of input material.

3. Bulk Transport – Seals: Every port on a bulk vessel is sealed and the seal identity is recorded and, usually, photographed. At destination, if a seal is missing (or incorrect), product may be rejected.

4. Bulk Transport – Sanitation: Every rail car or truck must be food-grade and must be cleaned or have a Food-Grade Wash Certificate prior to loading. All prior load information must be confirmed.

5. Facility Sanitation: This is huge. Facilities are, literally, kept as clean as a kitchen. ...

6. Food-grade Lubricants: All equipment must use food-grade lubricants and / or hydraulic fluids.

7. Certificate of Analysis: A complete COA is provided with each item – including microbial data (pathogens, molds, yeasts,).

8. Sanitary Bulk Loading: Finished product is maintained in a sanitary state all the way through loading. Bulk vessels are loaded indoors.

9. Positive Release (aka, Test & Hold): All items are tested for food-safety variables. Each load is placed on “hold” status until it has been positively released for receiving or shipping.

10. Access Control: Food facilities have strict access control to the food production area. There are even stricter controls to other areas such as analytical labs.

Consumers are requiring food manufacturers to reach farther and farther back up the food production chain to provide assurances of desirable practices. For example, many companies are now able to document certifiably sustainable farming practices for corn and soybeans. Some can, literally, identify the exact field from which products were harvested.

For bio-fuels producers, it’s not a matter of “if” more food safety compliance and documentation will be required; it’s a matter of “when”.

First, and foremost, make absolutely sure that you are in full compliance with all current FSMA and any state regulations. Define critical gaps and fill them. Again, we don’t need bad publicity.

Get certified by one of the industry-level food safety programs. There are a number of them commonly employed by the USA feed industry – available from GFSI as well as feed industry organizations. Create training opportunities for employees to become food safety certified.

Most importantly, food safety is driven from the top-down. Bio-fuels executives and managers must establish a culture that places equal value on food safety as environmental and personnel safety. READ MORE