Record keeping important for regulatory compliance and improvement of daily operations
By Wilmer Pacheco, Adam Fahrenholz and Charles Stark
Records are essential for any successful feed manufacturing operation and to comply with local, state, and federal rules. From the regulatory point of view, records are important to comply with Food & Drug Administration (FDA), Occupational Safety & Health Administration (OSHA), and Environmental Protection Agency (EPA) requirements. Compliance with FDA regulations may require records related to medicated feeds, traceability, prohibited mammalian proteins (BSE rule), and of course the Food Safety Modernization Act (FSMA). Employees’ emergency training (e.g., recognizing hazards, use of fire extinguishers, using PPE, first aid, etc.) should be conducted and training records preserved in order to comply with OSHA standards. Some examples of other records related to OSHA compliance may include: preventive measures related to dust control and specific safety protocols (e.g., lockout/tagout, hot work, forklift safety, ladder safety, confined space entry, etc.). Under EPA regulations, facilities must implement spill prevention control, and countermeasure (SPCC) plans in order to prevent the discharge of oil into navigable waters and shorelines. According AFIA SPCC Plan (2010) one of the greatest areas of improvements is employee training and record keeping. Records may also be required related to hazardous air pollutants (e.g., NESHAP rule) and/or disposition of water from various sources, such as from the manufacturing process, cleaning, boiler blowdown discharge, and runoff.
Regardless of their source or purpose, records must be kept in their original forms, be accurate, indelible (not able to be erased or removed), legible, and must be created concurrently with the documented activity. Records should also include, as applicable, the name and location of the facility, identification of the equipment being serviced or inspected, the date and time the activity was documented, the signature or initials of the person performing the activity, and the type of product being manufactured. Some records can be generated automatically by the automation system or associated maintenance and/or production software, and this can be a significant asset because it removes the human error component of forgetting to generate or complete the record of interest.
Records are also important in the evaluation of the overall feed manufacturing operation and for making informed financial decisions in the future. For example, feed mill managers should regularly review records of daily production, ingredient receipts and usage to evaluate variation, and reconciliation records if medications are used. Records of received and used ingredients as well as finished products produced, delivered, and sold can be used for inventory management and process control. Records related to quality control of the incoming ingredients such as protein, moisture, and mycotoxin levels can be used to evaluate ingredient suppliers and subsequently make decisions on which suppliers deliver ingredients with the best quality. And records of weekly or monthly feed mill inspections can be used to prioritize preventive and corrective maintenance.
Records of motor loads, such as operating and idle amperes (amps), can be used to evaluate the performance of employees and equipment. For instance, if hammermills, pellet mills, or bucket elevators run empty for a couple of hours, idle amps can be documented. This information can be used to train employees about the importance of energy conservation and how feed cost can be decreased by managing the equipment efficiently. Records can also be used to decide when hammers or screens need to be changed in the hammermill. As the screens wear, material trying to pass through the screen is deflected, leading to reduced capacity and efficiency. Records of amps and production rate can help feed mill managers and maintenance personnel to determine when the increased energy cost per ton of material exceeds the replacement cost of the screens and hammers. The same principle applies to pellet dies and rolls in pelleting operations.
Shrink records are also important in a feed mill operation. Shrink can be caused either by material or moisture loss. Therefore, it is important to maintain records of moisture, particularly from the major ingredients (corn and SBM), to detect processes (grinding, mixing, conditioning, pelleting, cooling, etc.) in which moisture is gained or lost, and then find alternatives to manage moisture. Moisture records after mixing and conditioning are particularly important. If the moisture content after the mixer is 12.5% and after the conditioner is 16.5%, the conditioning system is adding 4% moisture. Records of moisture and temperature of the mash and the conditioned feed provide an idea of the quality of the steam and put in evidence issues with water carryover to the steam lines. As a rule of thumb, for every 25°F increase of the temperature of the mash, moisture will increase by 1% if the steam quality is adequate. It is worth noting, that for these records to be useful, sampling for moisture analysis after conditioning must be done correctly. It is important to consider that conditioned mash samples are moist and hot; therefore, samples must be sealed in a cup and be allowed to cool down before being homogenized and analyzed for moisture. If hot and moist samples are analyzed without being sealed and cooled, moisture will escape to the environment and the moisture of the samples will be underestimated. This in turn would lead to a collection of inaccurate records. Remember, no records are better than inaccurate records.
The next place where samples must be collected for moisture analysis is after cooling or crumbling. The moisture content of the finished feed should be the same moisture content of the mixed feed +/- 0.25%. A pellet mill running at 50 ton/hr will add 2 tons of water, and this water should be removed by the coolers in order to have neutral moisture loss/gain. Higher moisture in the finished feeds can lead to dilution of the nutritional content, and make the feeds more susceptible to bacterial contamination and mold growth. Furthermore, the temperature of the pellets should be monitored and recorded. Pellets should leave the cooler 5 to 10°F warmer than ambient temperature. If the records of temperature are higher than expected, then the cooler might be the bottle neck and unable to remove the heat and moisture added during the conditioning process, or the retention time in the cooler insufficient for proper heat removal.
Other feed mill records used to monitor daily and/or weekly operations include records of particle size analysis, equipment maintenance, and production records, which are important in case of a recall. Additionally, scale calibration and mixing uniformity records become handy to evaluate batching and mixing systems. During pelleting, records of pellet durability can be generated to make decisions on how to improve or maintain pellet quality.
Finally, keeping operations running smoothly and efficiently is a priority in any feed mill, and relies heavily on generating and maintaining manufacturing costs records such as dollars per ton of feed produced, personnel salaries, electricity costs, boiler fuel costs, and depreciation of the equipment.
Overall, whether records are generated automatically or manually, they are only useful when they are required for compliance or are regularly reviewed and used for process control and/or improvement. With this in mind, it makes sense for all facilities to audit the records be generated and determine how often they should be reviewed in order to evaluate the operations, identify trends, and use the gathered information to improve feed mill operations.
