Bakeries Rise to Food Safety and Defense Challenges
By An interview with Lee Sanders, American Bakers Association
Now that the Atkins diet craze is finally receding, Americans are once again embracing bread and other baked goods that they have always loved. After several years of declining sales, bread sales were up 1.2% and rolls and buns were up 4.3% in 2005 according to reports from Information Resources, a provider of enterprise market information solutions and services based in Chicago, IL.
This boom in sales is further bolstered by the new food pyramid from the Department of Health and Human Services (HHS) and the U.S. Department of Agriculture (USDA), which features the grain category as its largest segment, encouraging consumers to eat at least five ounces of grain products every day. And these grains don’t just come from bread. Grain-based bakery items include snack cakes, energy bars, cookies, crackers, rolls, donuts, pastries, pie/pastry/pizza crusts, cakes and muffins, and fortified breakfast cereals, giving bakery manufacturers a broad range of food categories to tap into.
Bakery sales have always been a retail powerhouse. The average American eats 53 pounds of bread, 119 pounds of cereal and 14 pounds of pasta each year—and about 35,000 cookies in his or her lifetime. That translates into billions of dollars in revenue for bakers.
The worldwide market for bakery products is now greater that $300 billion, according to Sosland Publishing of Kansas City, MO. In the U.S. the bakery market includes $18.9 billion in-store, $13.9 billion retail and $14.9 billion foodservice baking markets.
However, maintaining a wholesale bakery to support the demand for multiple baked product lines and retail markets is not easy, as it requires the knowledge of bakery management and the maintenance of hygienic conditions for the production of bakery foodstuffs. If sanitation processes, allergen control programs and bioterrorism defense strategies aren’t well defined and constantly adhered to, the bakery and its many brands can be at risk.
Fortunately, bakers have long relied on the American Bakers Association (ABA) for guidance on everything from training on good sanitation and biodefense planning to lobbying support on issues such as The National Uniformity Act and public concerns over acrylamide.
Lee Sanders, senior vice president, government relations and public affairs for the ABA, is a strong voice within the organization, who works tirelessly to support the needs of its members and consumers. The ABA is the Washington, DC-based trade association that has been the voice of the wholesale baking industry since 1897 (americanbakers.org). ABA represents approximately 85% of the wholesale bakeries in the U.S., as well as their suppliers. Through the association, member baking and allied companies are closely integrated and work together to achieve goals and solve industry challenges to strengthen the baking industry.
Along with working at the ABA, Sanders is the principal staff liaison for the Food Technical Regulatory Affairs Committee (FTRAC) and Legal Committee and is the principal liaison with the Grain Foods Foundation and Wheat Foods Council. She serves as the leader of ABA’s government relations team and is the key lobbyist for all FDA and USDA related issues advising the industry on members on critical international, federal and state level issues of both a legislative and regulatory nature.
Outside the office, Sanders serves as chairman of the Milling and Baking Division of the AACC International; chairman of the American Society of Baking’s (ASB) Scientific Advisory Committee; as a member of the American Institute of Baking’s (AIB) Scientific Advisory Committee; and as Secretary-Treasurer of the Society of Bakery Women.
Sanders recently met with Food Safety Magazine to discuss the key food safety and regulatory issues that bakery operations face today. She discussed what baking facilities need to manage their risks and meet tightening standards and shared what ABA is doing to help bakers achieve these goals.
FSM: What are the biggest food safety issues for baking facilities, and how should operators address them?
Sanders: There are many food safety issues with which bakers are concerned, including food defense, allergen control and sanitation programs, and criteria for shelf-stability, to name just a few.
In this new age of food defense awareness, bakers must be vigilant when they are sourcing ingredients and must factor in traceability systems under the new Bioterrorism Act regulations. They also need to think about developing a plant security program, which includes a thorough means of screening new employees and visitors to the plant.
Bakers have always been proactive when it comes to handling allergens in their plants. Good cleaning and sanitation practices to remove allergen residues from equipment and the food production environment is always at the top of the list. Strategizing on new plant equipment that incorporate sanitary design principles and improved, effective cleaning methods for existing equipment are key priorities. In general, the most important tools in an effective sanitation program are: identifying best practices for cleaning tasks; training of your sanitation staff to adhere to the best practice; inspecting all areas of your bakery on at least a monthly frequency to effectively identify issues and to take corrective actions; and establishing and keeping an effective and up-to-date master sanitation schedule that tracks cleaning tasks and established frequency.
While a Hazard Analysis and Critical Control Points (HACCP) program is not required for bakeries, many bakery operations find that it is a good food safety model to follow and do so voluntarily. A pilot study performed by FDA in conjunction with industry concluded that metal detection was the only critical control point (CCP) in the baking process. All other important control points can be covered by a suitable prerequisite program, such as Good Manufacturing Practices (GMPs). Along those lines, other food safety related programs found in bakery operations will likely include allergen and process control programs, and good consumer food safety inquiry/complaint programs.
Bakers must take special care when it comes to ingredient packaging materials and conveyors. Plant operators must be careful when cutting ingredient bags so as not to create loose pieces, and conveyors must often be inspected to observe for wear and cracks. Care must be taken with wooden pallets to make sure that neither the pallet nor the product packaging on the pallet is damaged during transport.
Bakers also focus on criteria for establishing shelf stability for both ingredients that go into the ultimate final products and finished products. While bakery products with lower water activity, such as breads and cereals, are less at risk for shelf life related risks, bakery products that have high water activity, such as pumpkin pie, or products with non-traditional ingredients, such as cheese bread, can have problems if they are not handled properly.
FSM: The ABA has been working on a protocol for pumpkin pie handling. Why is that important?
Sanders: One of the long-term projects ABA is working on is a guidance document for shelf stable pumpkin pie. This issue arose in Arkansas where officials wanted a way to easily demonstrate whether pumpkin pies are shelf stable. Because the pies are usually only sold around Thanksgiving and often displayed outside of refrigerated cases there were questions about the appropriate handling.
In 2005, ABA’s Shelf Stable Bakery Product Subcommittee, chaired by Valerie Wayland, regulatory manager of Flowers Foods, made exceptional progress and finalized the voluntary industry protocol, which included a scientific review by Dr. Daniel Y.C. Fung of Kansas State University. As a result of this meaningful, additional documentation and the efforts made by the subcommittee, the Voluntary Protocol was published as an American Institute of Baking Technical Bulletin in May 2005 and is the subject of a technical paper at the AACC International Milling and Baking Spring Technical Conference, therefore making the protocol ready for use during the 2005 pie season.
The objective of the protocol is to define the product and process criteria that a manufacturer may use to establish that its pumpkin pie product meets the requirements of the Model Food Code and is safe for distribution and retail display without refrigeration. The manufacturer must maintain and demonstrate compliance with all applicable GMP requirements in the manufacture of the pumpkin pie product.
We hope to be able to use the guidance for pumpkin pie as a template for other products in the future that may need similar research, although as the FDA looks at revisiting the definition of potentially hazardous foods (PHFs), we may need to revisit our own protocol to comply with that.
FSM: Can you go into more detail about food defense issues for the baking industry? For example, when the ABA held an interactive food security training session with the Institute of Food Technologists, what key issues were covered?
Sanders: In June of 2005, ABA worked with the Institute of Food Technologists and had a day of interactive training with their Food Defense Training Team lead by Dr. Frank Busta, Director, National Center for Food Protection and Defense, Homeland Security Center for Excellence, University of Minnesota. The day-long session included a vulnerability exercise; agent and product assessment; defense planning; prevention activities and risk communalizations. It was an eye-opening experience for the membership and assisted ABA in prioritizing defense planning goals.
To follow up on that dialogue, ABA’s Food Technical Regulatory Affairs Committee held a joint session with the ABA Energy and Environmental Health Committee in September of 2005 to further discuss food defense issues and how increased security requirements can be used to improve operations and control costs. For example, when you have a traceability program you have much greater control over inventory and a higher level of accountability that enables you to use ingredients more efficiently and avoid overstocking and waste. It can also be a tremendous cost-savings during a recall because you can respond more quickly, target smaller amounts of product for the recall and avoid potentially damaging media coverage.
FSM: In December, the U.S. Food & Drug Administration (FDA) released the “New Guidance on Unintentional Cross Contact of Allergens: Newly Revised Question and Answer Document Provides New Guidance for Food Industry.” What specific elements of this document, and of the allergen labeling law are important to the baking industry?
Sanders: Historically, ABA and its members have always been proactive when it comes to allergen labeling of bakery products. In 2000, ABA developed the ABA Allergen Usage Guideline that provides guidance on how to handle allergens, storage and staff training in any type of bakery. With the implementation of the Food Allergen Labeling and Consumer Protection Act (FALCPA), ABA is now revising that previous document for the membership. FDA’s Dec. 14, 2005 updated guidance on unintentional cross-contact of allergens provided our members much needed guidance on cross-contact of grains, such as wheat, soy and corn, for both bakers and millers who were not sure how to proceed with labeling.
ABA members worked diligently to comply with the deadline for FALCPA, and ABA provided guidance on the new law and its legal ramifications to support them in this process. For example, in June 2006, ABA dedicated a full day of training and dialogue to this topic. We had experts from various perspectives come in and educate the membership and participate in interactive dialogue in key areas. Experts who participated in the allergen workshop included Dr. Steve Taylor, University of Nebraska, Institute of Agriculture & Natural Resources, Food Allergy Research and Resource Program (FARRP), who talked about cutting-edge allergen research and compliance issues; Anne Munoz-Furlong, president of the Food Allergy and Anaphylaxis Network (FAAN), who discussed her organization’s work and reaction of consumers to FALCPA and encouraged broader joint communications efforts between FAAN and ABA to benefit consumers; and Kathleen Crossman, chair, Flavor and Extract Manufacturers Association (FEMA) Flavor Labeling Committee, who discussed how that association’s members are approaching the new law. Kevin Farnum from General Mills also discussed dry cleaning procedures, which are utilized by bakers.
FSM: You recently wrote a letter to all of the ABA members urging them to support the National Uniformity for Food Act of 2005. What does this act do?
Sanders: The National Uniformity for Food Act, H.R. 4187/S. 3128, provides for a national, uniform food safety standards and warning label requirements. The legislation would amend the Food, Drug and Cosmetic Act to create a uniform, national system that not only recognizes the role of state and local governments on the regulation of food products, but also integrates them into the national system. The bill would allow consumers in all 50 states to be protected equally.
Wholesale bakeries often have complex regional and national distribution chains that reach into many states, therefore uniformity is critical. The National Uniformity for Food Act of 2005 is a top priority for the American Bakers Association and its members. ABA has productively used its active grassroots lobbying network of members to educate Congress on this issue and to urge their support. Additionally, ABA has lobbied on Capitol Hill and with key state attorney generals on the importance of this legislation.
The National Uniformity Act is commonsense legislation that will help consumers make educated decisions for themselves and their families in an ever-changing and confusing food labeling environment. Consumers deserve a single standard, and this legislation will allow states and the FDA to work together collaboratively in establishing food safety policies that will educate and benefit, not confuse, consumers.
FSM: Recently, ABA commented to California’s Office of Environmental Health Hazard Assessment (OEHHA) with bakery specific concerns on proposals regarding acrylamide. What is the ABA’s position?
Sanders: As you may know, California OEHHA withdrew its previous proposals to add a new subsection providing an Alternative Risk Level (ARL) for chemical acrylamide in breads and cereals for concentration of less than 200 ppb. ABA participated in the Food Industry Coalition, as well as developed and submitted bakery-specific comments on the issue. ABA is anxiously awaiting the new California proposal.
ABA strongly supports a cooking exemption from any warning requirements. It believes food that would not be subject to Proposition 65 in its raw form should not be regulated under the act solely because it is cooked or heated. Such traditional methods of food preparation have been occurring since the discovery of fire, and people have safely consumed cooked and heated foods for thousands of years. A cooking exemption would be consistent with the purposes of Proposition 65, national dietary guidance and science-based public health considerations.
Currently, there is no science out there that shows we need to change our diets because of acrylamide in baked goods; however, we are looking into ways to make baked products with lower levels of acrylamide.
FSM: How will the baked goods industry be impacted if an acrylamide warning label is approved?
Sanders: ABA has a substantial interest in this proposed rulemaking because it would affect potential warning requirements regarding acrylamide for nearly all baked goods. Although, because acrylamide is present in so many products I’m not sure how effective such a label would be, and it could diminish the overall significance of Proposition 65 warnings, particularly when consumers will feel compelled to ignore the warnings and go ahead and purchase such staple goods as bread and cereal. The warning would be on everything and I don’t think average consumers would respond to it.
If an acrylamide label were to be made a requirement for bakery products, we would focus our effort on finding ways to lower levels in products, although we need to see what continuing science comes out on this subject before we proceed.