The FSSAI has published a food industry guide to implement GMP/ GHP requirements for Edible oil and fats. This Guidance Document on Food Safety Management System (FSMS) is prepared with the intent to provide implementation guidance to food business especially small and medium businesses involved in manufacturing, packing, storage and transportation of edible vegetable oils and fats. Edible vegetable oils and fats form an essential part of the modern diet. They are an energy source and provide the diet with many beneficial micronutrients. India’s annual per capita consumption has shown a steadily increasing trend from 4 kg in the1970s to 10.2 kg in the late 1990s to current levels of 17kgs.
This document contains practical approaches which a business should adopt to ensure critical food safety throughout the supply chain. The use of this guidance is voluntary and FBOs may comply with the requirement of the regulation according to other established best practices also. It is important to train food handlers appropriately to implement good manufacturing practices (GMP) and good hygiene practices (GHP) to ensure food safety. This guidance is for all FBOs in the entire or any part of the edible oil supply chain. The major activities comprise in the supply chain are
- Pre-processing (seed storage /crushing / expeller oil /solvent extracted crude oil)
- Manufacturing and packing
- Storage/warehousing and transportation of packed/bulk edible vegetable oils and fats
Since all these activities happen in various stages they might not happen in the same establishment. Based on their position in the supply chain FBOs can use the guidance document as per their operations in the oil industry. The various types of Edible vegetable oils & fats covered under the document are:
- Raw/ Crude edible vegetable oils
- Refined edible Vegetable oils
- Blended edible Vegetable oils
- Hydrogenated Vegetable fats
- Bakery Fats and Margarines
Implementation Guidelines for Establishments – Design Facilities
Location and surroundings of the establishment must be such as to prevent risk to food safety and following should be kept in mind
- Located away from polluting industries and adequate measure taken to protect the manufacturing unit from environmental hazards
- Boundaries must be clearly identified and enclosed to prevent theft and entry of dogs, cats and stray animals
- The building premises must be surrounded by well-maintained grass and greenery. Roads, yards and parking areas must be free of accumulated garbage and pest activity.
- All activities must be compartmentalised to prevent cross contamination and residential area must not have direct access to food premises.
- Manufacturing plant must be located away from flood prone areas or the height of the manufacturing plant must be elevated to prevent risk due to flooding.
Construction Design and Layout
Plant internal layout should be designed, constructed and maintained in such a way to facilitate good hygiene and manufacturing practices. It must be designed for
- logical flow of materials, products and personnel
- raw area is segregated from processing area
- allow for inward and outward movement of vehicles
- conveyors and openings for transfer of materials must minimise cross contamination
The guidelines have detailed requirements for
- Internal Structures like walls, ceilings, floors, windows and doors are
- Equipment, containers and food contact surfaces
- Design of oil containing tanks
- Water supply facilities
- Drainage and waste disposal
- Personnel Hygiene Facilities
- Lighting and intensity of lights has been outlined according to functional areas
- Storage facilities
- Air circulation and ventilation
- Compressed Air and Other Gases
- Boiler/ Water treatment chemicals
Control of Operations
Control of operation is necessary to produce safe food which is fit for human consumption and is free from contamination and/or cross contamination by:
- Developed and validated methods of manufacturing and handling of food items throughout procurement, storage, processing, packaging, warehousing
- Designing, implementing, monitoring and reviewing effective control systems
- Seeds/oils/process aids/ food additives consignments should be procured from approved suppliers and wherever applicable FSSAI licensed/registered FBO
- Raw material or ingredient known to contain chemical, physical or microbiological contaminants and adulterants must not accepted if they cannot be reduced to acceptable levels by sorting or processing
- Procedures must be in place to inspect and sort before processing and to meet specification through certificate of analysis, visual inspection, laboratory testing, review of label for allergens, etc.
- Source of raw materials and ingredients to be recorded for traceability,
- Food grade certificates must for food ingredients and processing aids
- All bulk tankers/ containers receipt shall be checked for seal integrity / previous cargo / fitness checklist at the time of receipt
- Raw materials (oil seeds/ crude oil) are received according to the storage and processing capacity of the oil processing plant.
- The incoming vehicles that bring the oil seeds should be checked for cleanliness and hygiene
The following have detailed guidelines but some of the highlights are as follows
- Storage of raw materials and packaging materials including storage of non-confirming rework / rejected / recalled stocks and proper labelling and sealing of storage tanks to prevent contamination
- Food processing including pre-processing and drawing of flow diagram, SOP for process changeover, critical parameters records like temperature and prevention of contamination including hygienic handling. Table with check points to be used during oil processing has been formulated
- Food Packaging design and materials shall provide protection from contamination, damage and accommodate required labelling as laid down under the FSS Act &Regulations there under. Only Food grade, non-toxic material to be used and packaging materials like aluminium, tin and plastic shall conform to BIS standards as mentioned under the FSS Regulations. Re-usable containers are properly cleaned and sanitized, repaired or replaced, as appropriate.
- Rework & control of non-conforming products need to be labelled, stored and handled to maintain safety, quality, traceability and regulatory compliance and records maintained
- Food transportation, warehousing and distribution – Only FSSAI registered transporters and clean vehicles shall be used for oil transportation. Tankers, containers, rail wagons, trucks used to transport crude or refined oils and fats and packed products shall be inspected for proper servicing and cleaning. All edible oil and fats must be carried under intact unbreakable sealed conditions and minimize food spoilage during transportation.
- Loading and Unloading procedures have been given including temperature of oil being transferred from storage tanks, shore and ship tanks.
- Warehousing of final oil product must be 18” away from walls preferably stocks to be kept on pellets and should not be stored directly on floor.
- Food Traceability and recall
- Quality Control
ESTABLISHMENT – MAINTENANCE AND SANITATION
- Cleaning and sanitation sanitizing programmes to be established according to set recommendations to ensure equipment and environment are maintained in a hygienic condition to prevent contamination of food, such as from metal shards, flaking plaster, food debris and chemicals and records of the same shall be maintained. Master sanitation schedule must be maintained.
- Maintenance: Preventive maintenance of equipment and machinery shall be carried out regularly as per the instructions of the manufacturer.
- Pest Control Systems to be in good repair and condition and a person nominated to manage pest control activities. FSSAI has also recommended a pest control 4D method given in a table
- Waste disposal management
Establishment – Personal Hygiene
- Health status of food handlers: they undergo a medical examination by a registered medical practitioner annually to ensure that they are free from any infectious and other communicable diseases like jaundice, tuberculosis, sore throat etc. and injuries like boils and cuts or discharge from ear, nose and eyes.
- They must maintain personal hygiene and have covers for hair, beards, moustaches, perspiration, etc. and finger nails clean and clipped so they cannot contaminate the product.
- Recommendations have been provided with every instance of hand washing requirements
- Visitor control: FBOs should implement and display visitor control policy
Product information and consumer awareness
Guidelines have been provided for
- Product information and labelling
- Consumer awareness and complaint handling
TRAINING & MANAGEMENT
- Awareness and responsibilities: so personnel are aware of their role and responsibility and handling of strong chemicals or potentially hazardous substances
- Training programmes
- Instruction and supervision
- Refresher training
- Management & supervision: The FBO management shall lead establishment of Food safety management systems in their premises.
AUDIT AND DOCUMENTATION
Self-evaluation and review
FBOs must conduct self-evaluation to review the effectiveness of the food safety system they have implemented at least once a year through internal and external audits or other mechanisms and make recommended improvements.
Documentation and records
Following records shall be maintained by the FBO:
- Incoming materials checks – raw materials, ingredients, packaging materials.
- Inspection and testing
- Operational controls such as temperature, pressure, time etc.
- Product recall and traceability
- Cleaning and sanitation
- Pest control
- medical examination and health status
- Complaints and customer feedback
- Corrective and preventive actions
- Self-evaluation results
Implementing Hazard Analysis and Critical Control Point (HACCP) is crucial for any food manufacturing process. A HACCP plan is required to be in place before initiating the HACCP system. A HACCP plan consists of 5 initial steps and 7 major HACCP principles.
STEP 1 Assemble HACCP Team
STEP 2 Describe the products
STEP 3 Document intended use of product
STEP 4 Construct process flow diagram
STEP 5 Onsite confirmation of flow diagram
PRINCIPLE 1 Identify hazards (conduct hazard analysis)
PRINCIPLE 2 Identify Critical Control Points (CCP)
PRINCIPLE 3 Establish critical limits for each CCP
PRINCIPLE 4 Establish Monitoring actions
PRINCIPLE 5 Establish corrective action
PRINCIPLE 6 Establish verification process
PRINCIPLE 7 Establish record keeping procedures
(The steps and the principles have been explained in minute detail under “Application of HACCP System)
- The requirements for Sanitation Standard Operating Procedures (SSOPs) along with Good Manufacturing Practices (GMPs) & Good Hygiene Practices should be considered as prerequisite for HACCP.
- Risk assessment is a critical step in a HACCP plan.
Hazard Analysis and Critical Control Point (HACCP) decision trees are tools that can be used to help you decide whether a hazard control point is a critical control point (CCP) or not. A CCP is a step at which control can be applied. It is vital that you determine the correct CCPs to ensure that food is managed effectively and safely. The number of CCPs in a process will depend on how complex the process is and how many hazards are present. The Decision Tree has been demonstrated through a flow diagram.
HACCP plan has been given as samples for
- Kachi Ghani Mustard oil
- Refined Vegetable Oil
- Hydrogenated Vegetable fat (vanaspati)
These include detailed
- Process flow diagram
- Hazard Analysis and Identification
- HACCP Implementation Plan
The checklist has the date, FBO name, Food Safety officer and representative, FBO license number and address. Audit questions along with score about
- Design and facilities
- Control of operations
- Maintenance and sanitation
- Personal hygiene
- Training & Complaint Handling
A grading between
85-90 is compliance exemplar (grade A+)
80-84 is compliance satisfactory (grade A)
60-79 is Needs Improvement (grade B)
Less than 60 – Non-compliance (no grade)