Food manufacturing

Industry hazards

According to the Bureau of Labor Statistics, food manufacturing has one of the highest incidences of injury and illness among all industries. Animal slaughtering plants have the highest incidence among all food manufacturing industries. About 34 percent of all food manufacturing workers are employed in plants that slaughter and process animals, 19 percent work in establishments that make bakery goods, and seafood product preparation and packaging accounts for only three percent of all jobs.

Many production jobs in food manufacturing involve repetitive, physically demanding work. Food manufacturing workers are highly susceptible to repetitive-strain injuries to their hands, wrists, and elbows. This type of injury is especially common in meat- and poultry-processing plants. Production workers often stand for long periods and may be required to lift heavy objects or use cutting, slicing, grinding, and other dangerous tools and machines.

To deal with difficult working conditions, ergonomic programs have been introduced to cut down on work-related accidents and injuries. In an effort to reduce occupational hazards, many plants have redesigned equipment, increased the use of job rotation, allowed longer or more frequent breaks, and implemented extensive training programs in safe work practices.

Because of the considerable mechanization in the industry, most food manufacturing plants are noisy, with limited opportunities for interaction among workers. In some highly automated plants, "hands-on" manual work has been replaced by computers and factory automation, resulting in less waste and higher productivity. While much of the basic production-such as trimming, chopping, and sorting-will remain labor intensive for many years to come, automation is increasingly being applied to various functions, including inventory management, product movement, and quality control issues such as packing and inspection.

Working conditions also depend on the type of food being processed. For example, some bakery employees work at night or on weekends and spend much of their shifts near ovens that can be uncomfortably hot. In contrast, workers in dairies and meat-processing plants typically work daylight hours and may experience cold and damp conditions. Some plants, such as those producing processed fruits and vegetables, operate on a seasonal basis, so workers are not guaranteed steady, year-round employment and occasionally travel from region to region seeking work. These plants are increasingly rare, however, as the industry continues to diversify and manufacturing plants produce alternative foods during otherwise inactive periods.

HACCP

Hazard Analysis and Critical Control Point (HACCP) is a preventive food safety management system that identifies, evaluates, and controls biological, chemical, and physical hazards that could occur in food production. HACCP is designed for use throughout the food supply chain, including processing, manufacturing, distribution, retail, and food preparation, to help ensure food is produced safely.

HACCP is based on the following seven principles:

• Principle 1: Conduct a Hazard Analysis. Identify and evaluate biological, chemical, and physical food safety hazards at each step of the production process (e.g., receiving, storage, processing, cooking, cooling) to determine which hazards must be controlled to prevent illness or injury.
• Principle 2: Determine the Critical Control Points (CCPs). Identify points, steps, or procedures in the process where control can be applied to prevent, eliminate, or reduce a food safety hazard to an acceptable level.
• Principle 3: Establish Critical Limits. Set measurable limits (such as time, temperature, pH, or concentration) for each CCP to ensure the hazard is controlled.
• Principle 4: Establish Monitoring Procedures. Define how and when CCPs will be monitored to ensure they remain within critical limits.
• Principle 5: Establish Corrective Actions. Develop procedures to follow when monitoring shows a CCP is not within its critical limit, including how to correct the issue and prevent recurrence.
• Principle 6: Establish Verification Procedures. Perform activities to confirm that the HACCP plan is effective and functioning as intended.
• Principle 7: Establish Recordkeeping and Documentation. Maintain records that demonstrate the HACCP system is being implemented and monitored according to the plan.

U.S. federal regulations, enforced by the Food and Drug Administration (FDA) and the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS), require Hazard Analysis and Critical Control Point (HACCP) systems for certain food sectors.

FDA mandates HACCP for seafood and juice processors, while USDA FSIS mandates HACCP for establishments producing meat, poultry, catfish, and egg products (liquid, frozen, or dried).

Environmental concerns

The food processing sector is affected by a number of major environmental statutes and regulations.

Water

The discharge of wastewater from a food processing facility generally will be covered by the federal Clean Water Act (CWA). Generally, federal regulations target three types of industrial discharges. Industrial wastewater discharges from food processing facilities probably fall into one of these categories:

Direct discharges which include any wastewater from an industrial facility (e.g., untreated, unpolluted wastewater or treated process wastewater) that is discharged straight to surface waters (e.g., ponds, lakes, oceans, streams, and wetlands). Storm water discharges also are considered a type of direct discharge.

Indirect discharges which include any wastewater from an industrial facility that is discharged to a publicly owned treatment works (POTW), which subsequently discharges to a surface water.

Land application of industrial wastewater discharges. Land application discharges include any wastewater from an industrial facility that is discharged to land to either condition the soil or to fertilize crops or other vegetation grown in the soil.

Facilities that store petroleum and nonpetroleum oils (e.g., vegetable oils and animal fats) must follow Oil Pollution Prevention Regulations, also known as the Spill Prevention, Control and Countermeasures (SPCC) Regulation.

Water used in food processing operations must meet EPA's safe drinking water requirements.

Air

Although total air emissions by the food processing industry typically are less than other manufacturing industries, some sources may emit sufficient air pollution to be regulated under CAA.

NAAQS for Criteria Pollutants May Affect Food Processing Industries in the following ways:

SO2, NOx, and PM result from the combustion of fossil fuels (e.g., industrial boilers,). Some significant sources of particulate emissions result mainly from solids handling, solid size reduction, cleaning, roasting, drying, and cooking (e.g., PM10 results from flour, sugar, and other dry ingredients). Some of the particulates are dusts, but others are produced by the condensation of vapors ranging in the low-micrometer or submicrometer particle-size.

VOC emissions may result from fryers (e.g., doughnuts, french fries), direct use of ethanol, by-products of yeast fermentation (ethanol), and from lubricating oils for machinery.

Your food processing facility may be emitting air pollutants (i.e., criteria, HAPs) from both process and ancillary operations, such as refrigeration and steam generation.

Food processors may be subject to risk management planning requirements if they have one or more of the identified substances onsite above the threshold quantity. If you have more than a threshold quantity of any of the regulated substances in a single process, you are required to comply with the regulation (40 CFR 68). In terms of this regulation, process means "manufacturing, storing, distributing, handling, or using" a regulated substance in any other way. Ammonia, chlorine, and propane are some of the regulated substances commonly used by food processing facilities.

Your food processing facility may be subject to requirements of the stratospheric ozone protection program if you have motor vehicle air conditioners, certain appliances (air conditioners, refrigerators, and freezers), and industrial process refrigeration units that use CFCs and other class I and class II substances.

Toxic substance control

Drugs, cosmetics, foods, food additives, pesticides, and nuclear materials are exempt from TSCA and are subject to control under other federal statutes (e.g., foods and food additives are under the purview of the Federal Food, Drug and Cosmetics Act (FFDCA) administered by the FDA. In order for a food or food additive to be exempt, however, it must meet the definition contained in the FFDCA (21 USC 321 et seq.), or related statutes such as the Poultry Products Inspection Act and the Federal Meat Inspection Act. If the food or food additive does not meet the definition, the substance may then be regulated under TSCA and is subject to all the requirements of TSCA including testing, premanufacture notice, reporting and recordkeeping, export notification, and import certification.

Additional TSCA requirements may apply to facilities that manage substances such as asbestos, chlorofluorocarbons (CFCs), and polychlorinated biphenyls (PCBs).

Pesticides

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) primarily regulates the manufacture and registration of pesticides (40 CFR 152 and 156), but important requirements also exist for pesticide users. Food processors must comply with all FIFRA requirements relating to these activities.

Under this program, the term "pesticides" includes herbicides, insecticides, and rodenticides.

Emergency planning and community right to know

If your food processing facility, no matter how small, has any of the extremely hazardous substances ( EHSs) in amounts equal to or in excess of certain minimum amounts (called threshold planning quantities [TPQs]), you must participate in emergency planning activities. EHSs typically found at food processing facilities include ammonia (for refrigeration), chlorine (for disinfection), and nitric and sulfuric acids (for cleaning).

Hazardous chemical inventory and reporting provisions require you to inventory the hazardous chemicals present onsite at your facility in amounts equal to or in excess of TPQs.

Form R reporting requirements often apply to food facilities. Some multi-establishment food processing facilities overlook the fact that they may have to submit Form R or Form A reports for chemicals used in agricultural operations.

Hazardous waste

As a food processor, you produce wastes that could be hazardous. For example, Food processors will most likely generate spent solvent wastes, which are F-listed wastes. Other wastes commonly generated at food facilities include the following:

• Spent or unusable chemical preservatives,
• Vehicle maintenance waste,
• Solvents,
• Liquid flux for soldering,
• Waste ink,
• Solvent-laden rags,
• Used fountain solution, and
• Used oil.

If your facility has an underground storage tank (UST) system, you are subject to requirements for USTs containing petroleum products or hazardous substances.