Measure the risks before you enter a safety and compliance minefield


By Vinh Lam*
Monday, 16 March, 2020

Measure the risks before you enter a safety and compliance minefield

The devil can be in the detail when bringing a new product to market, or upgrading an existing process to ensure it complies with international best practice standards of safety, traceability and quality compliance.

When it comes to food processing machinery, there are stringent hygiene standards that must be followed both for local markets and for exporters — and these standards are not always the same. It only takes a tiny thing to be wrong — the wrong grade of elastomer to seal a hot water or food processing machine for example — for producers to end up with containers of defective product sitting on the wharf after failing in service, or lost in the minefield of national and international compliance and materials verification standards.

Avoid back-to-front product design

One mistake we see from food processing equipment manufacturers — and manufacturers more broadly — is a back-to-front design process in relation to Standards compliance. In these instances, the company designs the product with core components that are totally compliant with all safety and hygiene standards. But then they realise, too late, that one minor component, such as a seal or gasket, is not made from a compliant material. At this point, they have invested so much in the new product, the only thing to do is retrospectively seek a new, compliant component that fits in with the existing design. This narrows down the specification options, because not all components will fit the machine’s specific design. Additionally, it can be an expensive exercise to custom-design a component to fit an existing machine design.

It is far better to design the compliant component into the machine at the earliest possible stage. It not only ensures total compliance of the machine, but allows for cost-efficiencies and optimal component design. We like to encourage manufacturers to adopt a similar approach to woodworkers, who always “measure twice, cut once”. Manufacturers should adopt a practice of checking all machinery componentry once more for compliance prior to moving into production. It could save them time and money and avoid the frustrating experience of having to go back to the drawing board when a machine fails compliance tests.

Export market compliance: a food manufacturing example

One recent example in which we were involved concerned a manufacturer of a food and beverage hot water process product which was seeking to achieve export market certification. The product involved was subject to restrictions on the use of rubber componentry that had traces of a standard chemical found in food-grade rubber manufacturing (sulfur used for curing). Use of this chemical was permitted in some markets, but not in others, where its use would result in products or machinery failing compliance testing — sometimes at great expense.

We partnered with this company to verify compliant materials, based on experience of suitable material used for drinking water standards. We suggested cost-efficient alternative rubber materials that use non-sulfur and complying curing processes, so we were able to agree on one that set the product smoothly on the path to production. This thorough regime of compliance checking (an issue to which I will return shortly) helped save them upfront time by using experience of relevant standards, such as the UK’s WRAS product approval for valves, boilers and showers, which are required to undergo mechanical and water quality testing to qualify for export to this market.

Minor parts have major compliance implications

Food manufacturers are highly aware of the need for standards compliance, but may not realise the large impact a single non-compliant part can have, particularly when exporting to markets with different regulations. The part itself may be worth just a few dollars in a machine or consignment of products worth thousands or tens of thousands of dollars, but the failure of this apparently insignificant part can (and has) jeopardised a potentially lucrative export market — or resulted in hugely expensive returns and reputational damage in a local market. All components in the manufacturing and processing chain today (including the seals and interfacing surfaces in which my team specialises) have to pass not only hygiene, but increasingly stringent compatibility and performance standards and traceability criteria.

If producers unknowingly design a non-compliant product into their process for particular markets, they might have to go right back to the drawing board and reconfigure the entire process at large cost in terms of money, brand reputation and lost time and market opportunity. Material selection is not always just a simple matter of reading a compatibility chart or accepting a component manufacturer’s headline statement, such as “food compatible” or “purpose compatible” at face value. Sometimes such statements are perfectly true in relation to one particular part of a range, but may not be intended to apply to the entire range. Even experienced consultants have to learn the difference, so as to avoid the compliance minefield.

The safety message: verify materials early

The key message here is risk management by researching and verifying materials early, before they are built into a component or machine, at which point it can be much more difficult to reverse engineer a way out of trouble. In the food processing example, a key decision was to research the correct material in the first place — and not get the material selection process back to front, by designing in a flawed component, then attempting to rectify it in retrospect.

But sometimes in our business we do continue to observe expensive results in industry of back-to-front design and material selection. Clearly, it is a far more cost-effective and sensible approach to do the work in advance and — if you do not have all the requisite skills (what company does?) — then involve an experienced partner in the product and material verification process at an early stage. This helps ensure correct safety, compliance and verification right from the outset of design, which is where it should happen for cost-efficiency and getting the product to market quickly.

*Vinh Lam is General Manager of CSGtech.

Top image credit: ©

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