What are Physical Hazards?
Physical hazards consist of any extraneous foreign substance in food. They can be present in the final product due to contaminated raw materials, poorly designed or poorly maintained equipment and facilities, improper hygiene practices, and poor implementation or failure to observe proper standard operating procedures.
Effect of Physical Hazards
Physical hazards can cause damage to teeth and lacerations to the mouth, tongue, throat, stomach, and intestine. They may otherwise be aesthetically unpleasant.
Aesthetically unpleasant substances may include small insects, insect parts, rodent hair, human hair, and filth. These are likely to cause “mental anguish” but not any physical injury. Substances likely to cause physical injury include stones, glass, and metal. The FDA has established guidelines for the acceptable length of hard or sharp substances in food in its Compliance Policy Guide (CPG) Sec 555.425 on “Foods-Adulteration involving hard or sharp foreign objects”. According to the guide, ready-to-eat or minimally processed foods are subject to seizure or import detention if they contain hard or sharp objects having a length of 7 mm to 25 mm.
Hard or sharp substances that are natural components of food such as bones in seafood and shells in nuts are not subject to the above rule since customers are generally aware that they may be present and therefore look out for them. However, products with labels indicating that the substance has been removed is of greater concern. For example, if the label says “boneless fish” or “pitted olives”, consumers will not be expecting the presence of the removed substance and will therefore be at risk of injury. Therefore, the presence of bones and pits exceeding the FDA’s established “defect action level” would render the product as “adulterated”.
Control of Physical Hazards
Physical hazards can be controlled in several of your prerequisite programs as well as in your HACCP plan. Examples of prerequisite programs where they can be controlled include supplier control, equipment, facility, cleaning and sanitation, and personal hygiene.
Prerequisite Programs Control
Supplier Control: Purchase your raw materials only from approved suppliers. Inspect raw materials upon receipt and store them separately from finished or partially processed materials. You can request letters of guarantee from suppliers to provide assurance that your raw materials are free from or within the limits of acceptable physical hazards. Request certificates of analysis as appropriate to confirm that concentrations of foreign materials such as insect parts and other non-food materials in the shipment are within acceptable limits.
Equipment: Install and maintain equipment used for sorting and cleaning raw materials. These equipment may include flumes, water sprayers, bottle washers, color graders, sieve separators, and aspirators. Check their settings at the start and end of operation and at established frequencies throughout production to make sure that they are working properly. Equipment involving metal-to-metal contact or those that contain parts that can break or become loose should be visually inspected at appropriate frequencies and after jams, to check for metal shavings, missing parts or breaks.
Facility: Design your facility to allow for proper cleaning and maintenance. For example, walls should be smooth, cleanable and free from peeling paint or chipping surface. Overhead structures should be free from cobwebs, rust, dust and any material that could fall into the food. Uncovered lighting may break and contaminate food, so make sure that they are covered with a shatterproof shield. Physical barriers should be installed at entrances such as doors, strip curtains and air curtains to prevent entry of pests, dust and movement of other physical hazards from raw material handling areas into areas where food is being processed.
Cleaning and Sanitation: Follow your sanitation standard operating procedures (SSOP) to ensure that your equipment and facility are properly cleaned and sanitized before processing. When equipment maintenance is done prior to operating equipment, make sure that all tools and loose hardware are removed from the area. Negligence in this responsibility can result in significant damage to expensive equipment.
Personal Hygiene: Train employees in the practice of good personal hygiene, including proper hand washing and wearing of personal protective gears. Remember that no jewelry, including tongue rings should be worn in the facility. Wedding bands may be allowed but they must be plain and should be covered with a glove when handling food. Bandaids used should be brightly colored so that they can be easily detected if they fall off. Do not allow any meal, drink or snack to be brought into the processing or changing areas. Instead, provide your employees a designated area in the facility for eating and drinking.
HACCP Control
HACCP control of physical hazards may take the form of visual inspection or instrumentation. Two common hazards that are controlled in the HACCP plan are glass and metal. The presence of glass on or near the equipment or in containers can be inspected visually for cracks and fragments by:
- Examination of pallets and cases of empty jars
- Examination of area where glass jars are inverted and cleaned in preparation for filling
- Examination of the filling area
- Examination of the filled glass containers
The visual checks should be done by properly trained personnel at the start of each day, periodically throughout the operation, at the end of each shift, and whenever there is an equipment malfunction that resulted or could have resulted in breakage.
X-ray detection may be used to detect and remove food and packages containing glass fragments. However, an appropriate personnel should check the machine at least once daily to verify that it is working properly. Whenever glass fragments are detected, you must stop the operation and remove the fragments from the equipment and surrounding area. The source of the fragments must be located and adjustments made to prevent breakage in the future. Products containing glass should be discarded. In case you discover that the machine was not working for a given time, resulting in products passing without proper evaluation, you should hold the affected products and make sure to pass them though a properly functioning x-ray machine before allowing them to leave your facility.
Metal fragments may also be monitored and controlled by visual inspection or instrumentation using a metal detector. Visual inspections should be done at the start, end, and throughout the operation, as well as when jams are encountered. During visual inspections, the operator should look for signs of equipment damage or missing parts. If damage or missing parts is observed, the operator should stop the line, adjust the equipment, and hold all products since the last acceptable visual check. Destroy rejected products, or you may divert them for non-food use. To ensure proper calibration of your metal detector, you should challenge the machine with standard sensitivity test wands before start up and periodically throughout the operation.
Reference: FDA Guidance Regulation (UCM252440) – Metal Inclusion
