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ferent animals.
CryoGas: Thank you Terry and Sal for sharing your knowledge of food safety regulations and their
impact on the food and beverage business with our readers.
The Compressed Gas Association (CGA) standard and update their carbon dioxide tion is much more stringent for Beverage
(cganet.com) is responsible for some of the specification to reflect today’s market place Grade. While some of these differences are
confusion around Food and Beverage Grades reality, which is that CGA Grade I/ISBT small they have been shown to be highly
in our industry with their standards. For Guideline is the appropriate and only important. This is because Beverage Grade’s
example, CGA Grade H for carbon dioxide is acceptable specification for Beverage Grade tighter analytical specifications are an evolu-
called “Food Grade,” and conforms to the carbon dioxide. The same issue will have to tion of customer requirements derived from
Food Chemical Codex (FCC) analytical spec- be dealt with for the Beverage Grade nitro- actual testing on the effect of carbon dioxide
ifications for that product. CGA Grade I for gen specification once it is finally released contaminants on product quality performed
carbon dioxide is called “Beverage Grade” by ISBT. by the beverage industry. The results of these
and conforms to the International Society of There are significant differences in the tests concluded that the contaminant levels
Beverage Technologists (ISBT) analytical carbon dioxide product quality specifications acceptable in Food Grade product can cause
guidelines. The confusing part comes from between Food and Beverage Grades. For significant problems, such as inducing unde-
the same CGA publication which also states example, the analytical specification for sired tastes or odors, when used to carbonate
that Grade H is acceptable to carbonate bev- Food Grade CO2 has a minimum purity of high quality beverages.
erages, which effectively creates two Bever- 99.5 percent, and includes testing mainly for
age Grades. common/traditional CO2 contaminants. On
While the gas industry appears to be con- the other hand, the analytical specification Like medical gases the pedigree for Food
Product Pedigrees
fused about which grade of CO2 to use for for Beverage Grade stipulates a minimum and Beverage Grade products starts at the
beverages, the major beverage firms have purity of 99.9 percent and includes a broader bulk supplier. Firms selling Food Grade
made it quite clear they now only accept range of contaminant tests. Even more gases, under Federal law, must have, at a
Grade I for use in carbonating their prod- important, for most of the contaminants the minimum, a documented “Food Grade”
ucts. It is time for CGA to eliminate this dual two grades share in common the specifica- pedigree back to the bulk supplier. Like-
covering HARPC in more detail in a future Once FSMA takes full effect, every food February 2014, the FDA introduced a new
article in CryoGas International.) facility in America will be required under Food Defense rule requiring firms to address
The whole HARPC process begins, ends, Federal Law to conduct and document a intentional sources of contamination in their
and is guided at each of the seven steps by HACCP risk assessment. When conducting risk assessment. This means firms must con-
a focus on hazard and risk identification and that assessment firms must consider physi- sider the potential for a third party seeking to
management. The tool for assessing risk cal, chemical, biological, and radiological intentionally introduce a food safety hazard
favored by the FDA is HACCP, which sources of food safety contamination (risks). or contaminant into their product and how
stands for Hazard Analysis of Critical Con- The risk assessment must also assess points the firm can best detect and defend against
trol Points. We predict HACCP is yet in the manufacturing process where food that issue.
another acronym that distributors in the safety risks can be introduced or become
food business should expect to become inti- concentrated. Finally a risk assessment will
mately familiar with over the course of the determine the process points where Food Using the output of risk assessment, firms
Food Safety Plans
next few years. Safety hazards can be eliminated or con- will be required to create a food safety plan.
trolled to an acceptable level. In just the last The term food safety plan is somewhat of an
few months the FDA has added to the list of acronym itself. Food safety plans will outline
food safety risks that must be considered. In the relevant hazards and risks and spell out
See “Changes Coming to the Food Supply
Chain,” CryoGas, May 2013, p. 40.
the framework for addressing them. The plan the company to conduct these reviews. The changes to the HARPC plan must be approved
will outline the firm’s detailed approach to FDA is establishing regulations setting out by the QI and plans need to be reviewed and
assessing and controlling identified risks and minimum educational and experience require- reapproved every three years at a minimum.
hazards. The plan also will incorporate the ments that a QI must possess in order to con-
mandated food safety prerequisite programs duct these reviews and grant plan approval. QI
for compliance with the various FSMA criteria is expected to be a blend of training The new language of food and its associated
Be Prepared
requirements, such as product traceability, and experience in HACCP execution, knowl- acronym’s will soon be part of the day-to-
recall, employee training, process documen- edge of Food Safety Regulations, and experi- day dialogue in the gases industry. Teaching
tation, etc. For many distributors already in ence in food safety auditing combined with a the industry and our customers the differ-
the gas business, elements of their food safety background in the food industry. The FDA has ence between Food Grade and Beverage
plan might resemble sections of their medical made it very clear in the FSMA language they Grade — and how to recognize that differ-
gas manual, such as product lot numbering. do not expect smaller firms to have the capa- ence — is vital to preserving our industry’s
Other elements, such as the risk assessment bility to create their own QI. They also antici- well-deserved reputation for safety in the
output and the actual food safety plan will be pate some firms may not be willing to invest public interest. Our industry needs to make
items new and unique to those firms. the necessary time, effort, and money to train a sure going forward that the term “Safety”
Medical gas manufacturers and firms with QI to meet their criteria. As a result, the FDA also includes “Food Safety” when referring
an ISO certification will already be familiar built into FSMA the ability for smaller firms to to Food and Beverage Grade gases. B&R is
with managing and approving procedures for use a third party as their Qualified Individual already well ahead of the curve in FSMA
their business. Under FSMA, the FDA takes to do reviews and approvals for them. In fact, compliance and is prepared to assist your
this process to a whole new level. Every food this is very likely the FDA’s preferred company learn this new food safety lan-
safety plan must be reviewed and approved by approach for small- to medium-sized firms. In guage. For questions on food safety, medical
a Qualified Individual (QI), which is yet all likelihood most firms will end up forming a or industrial gases, or bulk systems at
another new acronym in the Food Safety lexi- long-term relationship with their QI, as, in healthcare facilities give us a call or drop us
con. QI cannot be just anyone designated by addition to the initial plan approval, any a line. n
Bob Yeoman is President and CEO of B&R Compliance Associates LLC (Lehigh Valley, PA), a consulting firm specializing in
medical gases, safety management, and other regulatory compliance management issues relating to the compressed gas industry.
He can be reached at (610) 868-7183; Email bob.yeoman@brcompliance.com.