Page 90 - FoodFocusThailand No.195 June 2022

STRONG QC & QA

implemented by food operators. A special emphasis is placed on the major defects include 9 points that, if assessed, must not receive 0
prevention and elimination of risk factors that may cause food poisoning mark (“Improvement Required”).
or hazards to consumers. To ensure effective enforcement, punitive 2. The specific regulations (further addition) apply to the following
measures are also stipulated. Any party that violates said notification products:
shall be deemed incompliant with the Section 49 and be subject to fine Specific Regulations 1 – Drinking water in completely sealed
of up to THB 10,000. The law came into force on the 7th of April of container, mineral water, or consumable ice made from filtered water
B.E.2564 (2021) onward, with an extension of the enforcement deadline Specific Regulations 2 – Ready-to-consume, pasteurized, liquid
up to the 7th of October B.E.2564 (2021). dairy products (yogurt not included)
Specific Regulations 3 – Low-acid foods in completely sealed
GMP 420: Good Manufacturing Practices – Well containers and acidified foods that have undergone commercial
Begun, Half Done sterilization
The Food and Drug Administration regulates the standards for food
manufacturing facilities through the GMP law, issued in accordance Assessment and Interpretation Guidelines for
with the GMP Codex, since 2000. However, due to practical problems Application and Usage
in its application, the FDA thus (1) updated the conditions for audit The assessment of the basic regulations shall be based on the audit
reports by compressing the 5 original sets of regulations into just one report for food production facility or Tor.Sor.2, in which different
law called GMP 420 in order to reduce redundancy, save time, lower requirements are categorized as per their characteristics. The
costs, and improve auditing efficiency. All food types share the same assessment shall follow the decision-making chart that constitutes 3
regulatory standard and audit report, although foods in high-risk groups questions with 3 rating levels of assessment: Good (2 marks),
will require additional assessment forms. The FDA also (2) modified Acceptable (1 mark), and Improvement Required (0 mark). The total
the conditions for major defects to reduce food standard problems and rating, following an established calculation formula, must exceed
to ensure that the overall standard is on par with those of the international 60% in each category, and none of the 9 major defects must be
levels. The regulations apply to all commercial food production facilities detected (0 mark) (Figure 3).
(with an exception for some venues ) The assessment of the specific regulations apply to the
1
The main purpose of this law is to ensure the prevention of 3 forms manufacturing facilities of the specific products previously mentioned.
of hazard: physical, chemical, and biological. The physical hazards Without proper control, these foods pose higher food hazard risks.
include, for example, glass fragments, metal nuts, screws, packaging Hence, specific regulations are imperative. The critical control points
fragments, bones, shells, decorative accessories, cigarette components, (CCP) are used as a reference for the assessment and control. The
plasters, hair, nail fragments, wood fragments, rocks, and jewelry. assessment conditions are stricter as only two possible results can
According to the USFDA, the sizes that are deemed hazardous are be achieved: ‘pass’ or ‘fail’. All points must ‘pass’ the inspection
7-25 mm. The chemical hazards are, but not limited to, aflatoxin from requirements (Table 1).
Aspergillus flavus, excessive amount of nitrite in sausages, antibiotic For drinking water, the assessment takes into consideration the
residues in prawns, insecticide residues, and industrial chemical quality of raw water, the improvement process of water quality, and
contaminants from the manufacturing process. The biological hazards the prevention of post-contamination. With regards to ready-to-
are, for instance, pathogenic microbes such as Salmonella spp. in meat consume, pasteurized, liquid dairy products, the points being assessed
products or spices and Clostridium botulinum in canned or retorted are the receipt process of raw milk, the control of pasteurization
foods. If the standards are improved in the future, additional hazard process, and the prevention of post-contamination. Lastly, the low-acid
types may be included and subject to the regulations (Figure 1). canned foods and acidified foods (LACF/AF) that have undergone
commercial sterilization are assessed on the following bases: the
The GMP 420 is divided into 2 parts: validation and the specification of thermal sterilization, in which
adequate equipment suitable for the elimination of C. botulinum spores
1. The fundamental regulations (for all food types) consist of the 5 must be used, for example, the research that under the production
following points: (1) location, manufacturing facility, cleaning process, environment for control the proper environment which make F for
0
and maintenance; (2) equipment, machinery, manufacturing tools, over 3 minutes. The experiment about the temperature distribution
cleaning process, and maintenance: (3) control of production process; (TD) and Heat Penetration (HP); the control of production process,
(4) sanitation; (5) personal hygiene. Each point comprises further sub- in which the production factors involved must be inspected such as
regulations that food operators are advised to follow and also includes weight, pH, temperature or time, the elimination process of
important conditions on major defects, which refer to the factors that, C. botulinum spores, in which different methods, such as retorting
if ignored, will cause food contamination and harm to consumers. The process, aseptic technique, are audited; and the inhibition of spore
growth through the acidification process that helps achieve the pH of
≤ 4.6. The production of these 3 categories of food must be supervised
by adequately trained and knowledgeable personnel that have
successfully passed a certified production control training course.
Food operators are advised to regularly review the laws concerning
the production of food products, look for the updates, and consult with
relevant authorities about case studies. These actions will help expand
food operators’ knowledge regarding the links between food legislation
and different food standards. In addition, deeper insight into these
topics will enable a correct interpretation of food production laws, thus
leading to an effective application of the knowledge in business
practices. As a result, food operators will enjoy the benefits in the
form of cost management optimization and increase in their business
credibility.

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