Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne.
The nose knows: In case fish smells “fishy”, it is no longer fit for human consumption. A Canadian fish importing company pleaded guilty to the import of 9,000 pounds of rotten and partially decomposed fish into the United States. The potentially adulterated fish was sampled by the FDA, who declared it to be too spoiled to be sold in the country, hence refused its entry into the United States—but the fish was imported via a wrong shipment declaration anyway. The crime of importing refused food carries a prison sentence of up to a year.
In the complex food supply chain, a single product travels a long journey before reaching consumers’ plates. It’s no wonder that it has become so difficult to control the quality and safety of food. As food moves from trucks to conveyor belts and through grocery store shelves and shopping carts, the risk for harmful bacteria to contaminate products rises immensely. What’s worse is pinpointing the source of contamination can be nearly impossible, leaving food manufacturers scrambling to “fix” the error without even knowing the cause.
In recent recalls, processing plants completely shut down operations in an effort to resolve the issue and thoroughly sanitize their entire facilities. While this is good news for consumers, this type of reactive response will undoubtedly have a long-term, irreversible impact on the business—both financially and potentially for the brand’s reputation. Consumers remember the name of the company they heard on the evening news that had to pull thousands of pounds of products from shelves in their city or region. Then, when they make their weekly trip to the grocery store, they likely make sure to avoid that company’s products in fear of potential quality issues that could make them and their families sick. It’s a deadly cycle for consumers and public health, as well as business livelihood.
Product and consumer safety must continue to be the top priority for the food industry. The success of these companies literally depends on it. With so much on the line, the food industry must come together to spark a shift in how they operate to prevent food recalls rather than having to respond to them.
Stopping Recalls to Save Lives and Businesses
To move in the direction of mitigating pathogens from ever coming into contact with food and therefore preventing recalls altogether, processors must develop and deploy new strategies that keep facilities consistently clean. The U.S. government is stepping in with regulations such as FSMA that urge companies to shift from reactively responding to safety issues, to proactively working to prevent them. This is the fundamental shift that is needed across the food supply chain in order to protect consumers and food producing businesses.
Important new technologies have emerged in recent years that can add new layers of meaningful protection to continuously combat contamination across the supply chain. When coupled with existing disinfection and cleaning practices, these new technologies can help mitigate the introduction of harmful pathogens as food moves from point A to point B, with all the stops made in between.
One example is the advent of a new class of technology that incorporates antimicrobial LED lighting, which enables food processors to take an “always on” approach to keeping surfaces free of harmful pathogens. Since these lights meet international standards for unrestricted and continuous use around people, they’re able to irradiate large places and the smallest of spaces, all while workers are present.
However, simply deploying these new technologies isn’t enough. For new prevention strategies to be truly successful, food processors should consider the bigger picture. A large percentage of food processors focus primarily on bolstering their sanitation approaches in the areas that have the highest likelihood of coming into contact with food products. This is logical, as Zone 1 and Zone 2 are typically the highest risk for contracting and spreading harmful pathogens.
Environmental safety zones. Figure courtesy of Vital Vio.
However, processors are leaving holes in their sanitation strategies by not taking measures to keep areas, such as Zone 3 and Zone 4, also well protected. To ensure food remains free of contaminants, plant managers must ensure the entire environment is fully protected, including the belts and vessels that the food touches, as well as the break rooms where employees rest and offices where management holds meetings. If these areas aren’t kept equally as clean, facilities are risking outside contaminants to enter Zone 1 that can ultimately compromise their food products.
Food recalls have become eerily common, putting a strain on public health and businesses. To stop what seems to be rising to crisis level, all companies involved in the food supply chain need to take a proactive stance toward prevention. This means deploying advanced technologies that continuously prevent harmful pathogens from taking root anywhere in their facilities. Simple yet thoughtful solutions, such as antimicrobial LED lighting, ensure food companies are one step closer to keeping all of us and their businesses safe.
Last month, the FDA held a public meeting to discuss its New Era of Smarter Food Safety initiative, with a rallying call to create a more “digital, traceable and safer food system.”
FDA Deputy Commissioner for Food Policy and Response Frank Yiannas made it clear that the FDA is not replacing FSMA. Rather, the goal is to build on it, recognizing changes in the food industry over the last 10 years and the technologies available to tackle new challenges.
This isn’t surprising given continuing quality issues resulting in food recalls and shelf withdrawals. Last year, two major outbreaks of E. coli that were tied to consumption of romaine lettuce made a mark on industry perceptions, impacting customer trust, brand loyalty and the bottom line of companies involved were affected. Research by Allianz found recall costs could reach $10,000,000 for significant events.
To achieve the FDA’s goal of end-to-end traceability, the amount of information carried by every food item needs to increase, as will information about its location and condition in the supply chain. Grocers are at the sharp end of the food chain, meaning everything the FDA is proposing will impact them. As well as being merchandisers, they are brand-owners in their own right. They work directly with farmers and growers, they are directly involved in food safety, storage and distribution, and they feel the impact of recalls more than most. Unlike others in the food chain, they interact with consumers daily. This is important to note, since consumers are expecting communication on recalls immediately. In a recent study of more than 15,800 global consumers, 66% of respondents noted that they expect immediate notification of a product recall and another 28% stated they expect notification within a week.1 Furthermore, 88% said if a retailer immediately informed them of an issue, they would be more likely or slightly likely to trust them. The study also found that only 16% of consumers completely trust the product information provided to them from retailers today. In short, the impact of recalls extends far beyond the empty store shelf, and gives the industry even more reason to strive for safety.
High-Tech Next Steps
The FDA plans to publish a strategic blueprint early in 2020 of planned actions to meet its goal, but food brands and grocers need not wait to act. Proven technologies like brand compliance solutions, combined with emerging blockchain track and trace solutions and Internet of Things (IoT) sensors can add new depth and detail to traceability in the food supply chain, and these new technologies are already helping grocers and retailers keep consumers safe.
As retailers have sought a better means to track supply chain movements, blockchain technology has emerged as a potential way forward. Originally developed to manage financial transactions involving cryptocurrency, blockchain has proven to be capable of providing a verifiable record of the movement of goods through a supply chain. In fact, one major retailer has been piloting blockchain for more than a year and has already proven its value on produce items, cutting traceability times from more than a week to a matter of seconds. Some want to go even further and use IoT sensors to monitor the condition (e.g., temperature) of food products in the supply chain. Together, blockchain can help trace the path a product took through the supply chain and IoT can monitor the environmental conditions en route, providing a more cohesive picture of its supply chain journey.
But while supporting a few simple products with one ingredient and a one-step supply chain, such as fruits or vegetables, is one thing, scaling to address the needs of the average private brand retailer—now handling more than 10,000 active products from 2,000 production sites globally—is another. Managing the complexity of a product like tiramisu or a ready-made meal with dozens of ingredients, all coming from different sources, needs a different approach. To address the complexity, many are turning to brand compliance solutions—trusted, real-time repositories of information spanning the entire supply chain. For example, those using brand compliance solutions now have complete visibility of the ingredients in their private label products, helping them ensure labeling accuracy and transparency for consumers. Brand compliance tools also bring improved visibility of the food supply chain, enabling them to verify the status of manufacturing sites and respond quickly to food quality issues.
This combination of detailed product and supplier information makes brand compliance a foundational enabler for any blockchain/IoT-based initiative to improve supply chain visibility and traceability. For example, using brand compliance solutions, grocers can:
Confirm the ethical compliance of the supply chain at the point of selection or review, while using blockchain/IoT to monitor the ongoing conformance to these standards
Validate shelf life claims during formulation, while blockchain/IoT monitors logistical movement and environments to optimise products’ freshness
Record products’ formulation and ingredients to ensure safety, legal compliance and labeling accuracy, with blockchain/IoT monitoring the ongoing conformance to these standards
Rapidly identify potential risks across the entire formulation and supply chain, while tracking the affected batches to stores using blockchain and IoT
This convergence of static factual data (e.g., formulation, nutrition and allergens) linked to near real-time traceability and checking offers grocers confidence in the data and supports the consumer’s confidence of an actual product in their basket.
Looking Ahead
It seems clear that the food business is moving in the same direction as airlines and banks and becoming much more data driven. For grocers looking to keep pace, they will need to:
Treat data as a core competency. This means hiring information experts, investing for the future, and using data to identify ways to deliver better, safer products.
Create a customer-centric value promise. Grocers must go beyond regulatory compliance and use data to improve consumer transparency, support ethical sourcing initiatives, expand sustainable packaging and speed innovation.
Go above and beyond. Rather than waiting for FDA direction or simply complying with requirements, brands should take matters into their own hands, hold themselves to high markers and get started now.
In the future, improving the way that we manage the food supply chain is not just about how well we work with trucks and warehouses; it’s about how use information. The FDA’s initiative makes a clear statement that now is the time to modernize our food supply chains. As we look ahead to a new decade, the industry can come together to improve food safety and protect consumers, and we need not wait for the FDA’s blueprint or even the new year to get started.
Reference
Setting the Bar: Global Customer Experience Trends 2019. (2019). Oracle Retail. Retrieved from https://go.oracle.com/LP=86024.
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne.
In a large study of nearly 6000 products, more than a quarter (27%) of herbal medicines and foods sold in 37 countries on six continents was found to be deliberately or accidentally adulterated. In this study, the products, which came in a variety of forms such as softgels, tea and more, were analyzed with high throughput DNA sequencing and showed mislabeling, added fillers, substituted ingredients or contaminants. Such fraud can be a harmful to consumer health and safety, and must be monitored and tracked closely.
Resource
Ichim, M.C. (October 24, 2019). “The DNA-Based Authentication of Commercial Herbal Products Reveals Their Globally Widespread Adulteration”. “Stejarul” Research Centre for Biological Sciences, National Institute of Research and Development for Biological Sciences, Piatra Neamt, Romania. Frontiers in Pharmacology. Retrieved from https://www.frontiersin.org/articles/10.3389/fphar.2019.01227/full.
The food and beverage sector is a huge presence in the U.S. economy. As of 2017, the industry employed 1.46 million people across 27,000 different establishments. Total food and beverage sales stand at around $1.4 trillion and add $164 billion in value to the economy as a whole.1 This presents significant opportunities and risks alike. Companies that trade in food products are held to some of the highest regulatory standards. With globalization ongoing and a higher demand than ever for variety and niche products, companies find they need to expand the mobility of their services. They must also broaden their product choices without missing a beat when it comes to quality.
Augmented reality (AR) and virtual reality (VR) have emerged as unlikely allies in that quest. These technologies are already having a positive impact on food and worker safety in the industry.
Improves New Employee Training
Onboarding and training new employees is a costly and time-consuming endeavor in any industry. Moreover, failure by companies to impart the necessary skills, and failure by employees to retain them, can have ghastly consequences. Errors on assembly lines may result in faulty products, recalls, worker and customer injuries, and worse.
The stakes in the food and beverage sector are just as high as they are in other labor- and detail-oriented industries. VR provides an entirely new kind of training experience for employees, whether they’re working on mastering their pizza cutting technique or brewing the perfect cappuccino. Other times, “getting it right” is about much more than aesthetic appeal and immediate customer satisfaction.
Animal slaughtering and processing facilities represent some of the more extreme examples of potentially dangerous workplaces in the larger food and beverage industry. Between 2011 and 2015, this U.S. sector experienced 73 fatal workplace injuries. Excepting poultry processing, 2015 saw 9,800 recordable incidents in animal processing, or 7.2 cases for every 100 full-time employees.
Some adopters of VR-based employee training claim that virtual reality yields up to an 80% retention rate one year after an employee has been trained. This compares extremely favorably to the estimated 20% retention rate of traditional training techniques.
Training via VR headset can help companies get new hires up to speed faster in a safe, detailed and immersive environment. Food processing and service are high-turnover employment sectors. The right training technology can help workers feel better prepared and more engaged with their work, potentially reducing employee churn.
Helps Eliminate Errors in Food Processing
Augmented reality is already demonstrating great promise in manufacturing, maintenance and other sectors. For instance, an AR headset can give an assembly line worker in an automotive plant detailed, step-by-step breakdowns of their task in their peripheral vision through a digital overlay.
The same goes for food and beverage manufacturing. AR headsets can superimpose a list of inspection or processing tasks for workers to follow as they prepare food items in a manufacturing or distribution facility.
In 2018, there was an estimated 382 recalls involving food products. Augmented reality alone won’t bring that number down to zero. However, it does help reduce instances of line workers and inspectors missing critical steps in processing or packaging that might result in contamination or spoilage.
Eases the Learning Curve in Food Preparation
There are lots of food products in the culinary world that are downright dangerous if they’re not prepared properly and by following specific steps. Elderberries, various species of fish, multiple root vegetables, and even cashews and kidney beans can all induce illness and even death if the right steps aren’t taken to make them fit for consumption.
In early 2019, inspectors descended on a Michelin-starred and highly respected restaurant in Valencia, Spain. The problem? A total of 30 patrons reported falling ill after eating at El País, one of whom lost her life. Everyone reported symptoms similar to food poisoning.
The common element in each case appeared to be morel mushrooms. These are considered a luxury food item, but failure to cook them properly can result in gastric problems and worse. Augmented reality could greatly reduce the likelihood of incidents like this in the future by providing ongoing guidance and reminders to new and veteran chefs alike, without taking the bulk of their attention away from work.
Brings New Efficiencies to Warehousing and Pick-and-Pack
Consumers around the globe are getting used to ordering even highly perishable foodstuffs over the internet—and there’s no putting that genie back in the bottle. Amazon’s takeover of Whole Foods is an indicator of what’s to come: Hundreds of freezer-equipped and climate-controlled warehouses located within a stone’s throw from a majority of the American population.
Ensuring smooth operations in perishable food and beverage supply chains is a major and ongoing struggle. It’s not just a practical headache for companies—it’s something of a moral imperative, too. The World Health Organization finds that around 600 million individuals worldwide fall ill each year due to foodborne illnesses.
Augmented reality won’t completely solve this problem, but it may greatly reduce a major source of potential spoilage and contamination: Inefficiencies in picking and packing operations. Order pickers equipped with AR headsets can:
Receive visual prompts to quickly find their way to designated stow locations in refrigerated warehouses after receiving refrigerated freight.
Locate pick locations more efficiently while retrieving single items or when they already have a partial order of perishable goods picked.
In both cases, the visual cues provided by AR help employees navigate warehousing locations much more quickly and efficiently. This substantially lowers the likelihood that food products are stuck in limbo in unrefrigerated areas, potentially coming into contact with noncompliant temperatures or pathogens. The FDA recognizes mispackaged and mislabeled food products as a major public health risk.
For food and beverage companies, AR should be a welcome development and a worthy investment. FSMA recognized that 48 million Americans get sick each year from compromised foods. The act required these entities to be much more proactive in drawing up prevention plans for known sources of contamination and to be more deliberate in standardizing their processes for safety’s sake.
AR and VR Boost Food, Worker and Customer Safety
Augmented and virtual reality may seem like an unusual ally in an industry where most consumers are primarily focused on the aesthetic and sensory aspects of the experience. However, there’s a whole world that lives and dies according to the speed and attention to detail of employees and decision-makers alike. Augmented realities, and entirely new ones, point the way forward.
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne.
In the United States, the FDA is responsible for regulations and recommendations to protect public health, which includes the prevention of any type of food adulteration (unintentional contamination, intentional adulteration, and food fraud – or “economically motivated adulteration”). FSMA (the Food Safety Modernization Act) resulted in new regulations and guidance with strategies to reduce all types of risks in food facilities. It was the most comprehensive reform of FDA’s food safety regulations in more than 70 years.
Birds of different species can become a pest problem depending upon where they are landing, roosting or nesting. In terms of food facilities, birds can cause various concerns: Product safety risks, possible contamination (bird droppings/feathers), poor audit grades, inspection failure, secondary insect pest problems, vectoring of foodborne illness pathogens, plant closures or fines. It is for these reasons that it is essential that food, beverage and product manufacturers (FBP) establish an integrated bird management (IBM) program.
An IBM program will ensure that every essential team member is on the same page in terms of the protocols for managing pest birds within and around the facility. Even if a facility has taken a proactive approach to bird control, the potential exists for birds to enter a facility. Especially considering bird pressures around adjacent properties, buildings, bodies of water and food sources near the facility.
Read Part I of this series: Bird Problems and Control Methods for Food Production FacilitiesIBM for food industry facilities is a systematic approach to preventing birds from gaining access within a facility and reducing the length of time birds remain within a facility. Nuisance birds, depending upon how severe the bird pressure—i.e., how many birds are landing, roosting and/or nesting within a given area—can cause severe damage to equipment, property, food products, displays, vegetation, façade signage, ledges, roofs, HVAC equipment, drains, fire suppression, electrical equipment and more. The longer that birds are permitted to remain within and around a facility, the more damage they can cause, and the harder it is to remedy the problem. Thus, it is critical to remove any birds that have gained entry as soon as possible to prevent possible FBP contamination and the birds getting comfortable within the facility.
There are several components to developing an IBM program. First, you need to conduct a complete inspection of the interior/exterior of the facility, followed by a review of the current data as well as any historical bird data. Now that you have all the raw data, you can begin developing the site-specific IBM plan for the FBP facility. Now that you have the program designed, the program can be implemented. Finally, after a defined timeframe that the IBM program has been active, the program needs to be evaluated to determine if any adjustments need to be made to the program.
Inspection
The first step in developing an IBM program is to conduct an initial site inspection audit of the interior and exterior of the facility.
An example of an integrated bird management food safety audit checklist. Credit: Aviaway
The following various elements need to be inspected and with said findings documented.
An example of an interior audit spreadsheet. Source: Aviaway. (Click to enlarge)
On the interior of the facility, look at the following items:
Active Birds with the Facility
List the areas and locations of birds
Example: Location(s): Food prep area(s), warehouse, etc.
Any history of birds and related areas
Interior Landscaping
Type(s) and necessity
Food Processing Areas
Any active control measures in place
Assess the level of risk
Bay Doors
Location(s): Gaps
Location(s): Bumpers
General Doors
Location(s): Gaps
Location(s): Bumpers
Location(s): Structural
Location(s): Doors left open
Additional Access Point(s)
Check all equipment areas that enter/exit building
Pipe-Line Penetrations
Sanitation
Conductive Conditions
Location(s): Standing water
Location(s): Food Sources
Debris
Bird Droppings or Nesting Materials
Staff feeding birds
All access to food and water
An example of an exterior audit spreadsheet. Source: Aviaway. (Click to enlarge)
On the exterior of the facility, look at the following items:
Active birds with the facility
List the areas and locations of birds
Example: Locations(s): Rear loading dock
Any history of birds around the exterior of the facility
Adjacent Structures
Accessory buildings and structures
Sanitation Practices (Exterior)
Location(s): Dumpsters
Exposed food sources and spillage
Trash Receptacles
Trash Removal Frequency
Food Waste on Ground
Cleaning Practices
Cleaning Practices Schedule
Cleaning Food Waste Bins
Motion Doors
Bay Doors (Exterior)
Location(s): Gaps
Location(s): Bumpers
Location(s): Structural
General Doors (Exterior)
Location(s) Doors Being Left Open
Additional Access Point(s)
Bodies of Water
Conductive Conditions
Structural (Exterior)
Location(s): Pipe-Line Penetrations
Location(s): Flashing
Location(s): Pipes
Location(s): Openings
Location(s): Roof
Location(s): Roof Hatches
Location(s): Windows
Location(s): Canopy (Front/Rear)
Location(s): Awnings (Front/Rear)
Location(s): Façade Signage (Front/Rear/Side)
Drainage
Standing Water
Clogged Drains
Landscaping
Retention ponds
Bird Droppings or Nesting Materials
Exterior Storage
Merchandise Displays
Existing Bird Control Devices
Review
Next, after all the above items have been inspected and findings recorded, all the data needs to be reviewed. In addtion, all the current bird management practices within the facility, documentation practices, and current audit/inspection findings should be all evaluated together. All this information is your road map for developing your IBM Program. Make sure that while you are collecting all the said raw data, you also speak with all necessary staff to get the most accurate information possible.
Documentation
Now that you have conducted your inspections and collected all the data, it’s time to create a site-specific IBM Policy & Plan for the facility. The development and implementation of the IBM plan will provide the appropriate procedures that are to be implemented to prevent, control and exclude birds from entering a facility and from keeping birds an acceptable distance away from the facility. With proper training and implementation of IBM procedures, there will be a reduced likelihood that birds will be able to enter the facility, and the length of time birds remain inside the facility will be reduced—thus, reducing the level of pest bird damage caused, reducing hazards to food sources, equipment, the public, and the facility environment.
Each facility is unique in its operation, location and potential for bird activity. The facility’s IBM plan will be designed to factor its control options when remedying and preventing bird pressure.
Implementation
Now that you have an IBM Plan, it’s time to implement the plan. First, make any necessary changes based upon findings of the audit and review of all data. Next, correct any conducive conditions that were discovered during the inspection. All the items that may require adjustment may need to be planned out depending upon budgetary constraints. Define staff roles regarding bird control efforts on a front-line facility level. Each member of the action team must fully understand their role and responsibility about the implementation and day-to-day operation of the plan.
The IBM Plan is the roadmap that should be followed for managing pest birds throughout the interior and exterior of the facility and related structures. It will set forth the facility’s bird threshold levels and site-specific facility needs. Furthermore, the IBM Plan will provide in detail how each phase of the plan will be implemented at each facility. The facility coordinator, in collaboration with the IBM coordinator, shall be responsible for the administration and implementation of the IBM plan. Each of their roles and responsibly should be thoroughly reviewed and understood.
Next, conduct staff training on proper bird control removal methods if handing live removal internally. Otherwise, what are the approved processes for third-party vendors who are providing removal services? Finally, conduct a review of the new documentation process to record all necessary data for the IBM program. Data collection is a critical component in evaluating the success of the plan and determining if any adjustments need to be made.
Evaluation
To ensure goal compliance, the IBM program should be evaluated at each site annually. The review must consist of all records, the number of birds that gained access into the store, corrective actions taken (at the facility level and outside efforts), and any plan adjustments. By reviewing all the data collected, the plan’s effectiveness can be determined, and whether alterations need to be made. Note that the IBM plan is not a static document that sits in a binder. The plan will have to evolve as operations change, or the set goals of the program are not met.
Conclusion
A proactive approach to reducing bird populations is critical for food industry facilities. As such, the IBM program will ensure that your entire staff is adequately trained on all the site-specific bird control methods, reduce the frequency of birds entering the facility and create a documented bird control program that is designed for your specific facility.
By Cori Goldberg, Adam Brownrout, John Kendzior No Comments
On October 29, 2019, the USDA released its long-awaited draft rule establishing a domestic hemp production plan, providing clarity to growers and ancillary businesses about how the USDA will regulate the hemp crop. The USDA, under authority provided by the 2018 Agricultural Improvement Act (2018 Farm Bill), was tasked with promulgating regulations and guidelines to establish and administer a program for the production of hemp in the United States. This rule has now arrived and been published in the Federal Register. The rule provides requirements for all state and tribal hemp production plans including requirements for testing hemp, licensing growers, disposing of non-compliant hemp, and collecting and storing information related to hemp production. The USDA will now accept public comment on the rule until December 30, 2019.
Although the USDA rule will greatly contribute to the expansion of legally grown hemp in the United States, this rule does not alter the law regarding CBD foods and CBD dietary supplement products. This is because the 2018 Farm Bill left intact FDA’s authority to regulate the sale and marketing of CBD foods, dietary supplements, drugs, and cosmetics, as those product types fall under FDA’s purview generally. FDA has allowed the sale of CBD cosmetics, with certain restrictions, and companies may submit CBD products to FDA through FDA’s drug approval process. However, it has maintained that the addition of CBD to foods and dietary supplements is illegal. Under the federal Food, Drug, and Cosmetic Act (FDCA), once a substance is approved as an Active Pharmaceutical Ingredient (API) in an FDA-approved drug, that substance may not be placed into interstate commerce in a food. Also under the FDCA, once a substance is approved as an API in an FDA-approved drug, that substance is excluded from the definition of a dietary supplement. FDA approved the pediatric epilepsy drug, Epidiolex, whose API is CBD. Therefore, FDA has concluded that CBD may not be placed into foods in interstate commerce and that CBD products are excluded from the dietary supplement definition and therefore may not be sold as dietary supplements. The USDA rule does nothing to change the legal status of CBD food or dietary supplement products. Thus, despite the expected increase of hemp availability following the passage of the USDA rule, CBD companies must wait for the FDA green-light in order to manufacture or sell hemp-derived CBD food products lawfully.Learn more about important regulatory & quality issues in the cannabis space from Cannabis Industry Journal
However, the rule does state that additional hemp is necessary to support the growing CBD market, and it notably put pressure on FDA by stating that if “FDA does not provide clarity about their plans for future regulation of CBD, there will continue to be uncertainty and downward pressure on the CBD portion of the hemp market.”
So what does the USDA rule do? Under the USDA rule, states and tribes will have the option of either submitting a proposed hemp regulation plan to the USDA for approval or agreeing to submit to the USDA’s general requirements. All state and tribal plans must include certain provisions, including but not limited to:
Land used for production: State and tribal plans must identify a process for collecting, storing and maintaining relevant information regarding land used for growing hemp in the state. This includes information regarding the description, acreage, and boundaries of the farm land.
Sampling and testing for delta-9 tetrahydrocannabinol (THC): State and tribal plans must implement testing procedures to ensure that plants do not exceed THC levels above 0.3% (as provided in the 2018 Farm Bill). All testing facilities must be DEA approved, as non-compliant product with THC levels over 0.3% would be considered “marihuana” and a schedule 1 substance under the Controlled Substances Act of 1970 (CSA). Additionally, laboratories will be required to report a “measure of uncertainty” in their testing, designed to provide a buffer for the potential variation in sampling and testing procedures. Accordingly, plants testing higher than 0.3% THC but still within the “measure of uncertainty” will be considered compliant.
Disposal of non-compliant products: States and tribes must develop a procedure for destroying non-compliant cannabis containing more than 0.3% THC. Because non-compliant product is considered a controlled substance, all product must be disposed of in a manner consistent with the CSA. Therefore, product must be collected and destroyed by a DEA agent or law enforcement officer.
Inspection of hemp producers: States and tribes must develop procedures for inspecting hemp producers on an annual basis and also for inspecting random samples. The state must also develop procedures to identify and attempt to correct certain negligent acts such as not obtaining licenses or producers exceeding acceptable hemp THC levels.
Information sharing: State and tribal plans must include procedures for reporting information to the USDA. This information must be provided to the USDA within 30 days of receipt from the hemp producers and includes contact information for all hemp producers in the state, legal descriptions of the land used for hemp production, and the license status of all hemp producers in the state.
In states and tribes without an approved or proposed plan, hemp producers will be subject to the USDA general plan. The general plan also provides similar requirements for the testing and sampling of hemp. The USDA will provide licenses directly to hemp producers in states without an approved or submitted plan as some states may not want to have primary regulatory authority of hemp. These states will essentially hand over regulatory responsibility to the USDA. These licenses will be available by application 30 days after the final rule is published. Notably, the draft USDA rule also provides that states and tribes are restricted from prohibiting the transportation or shipment of hemp or hemp products produced under a state plan, tribal plan or a license issued under the FDA. The interstate commerce provision should put an end to the arrests of those transporting legally produced hemp from one state to another. For example, in July 2019, a trucker was arrested and charged with felony possessions of marijuana and intent to distribute while transporting legally grown hemp through South Dakota (South Dakota still considers hemp a controlled substance).
So while the USDA rule is much anticipated and grabbed the attention of many when published, food and dietary supplement manufacturers, distributors, and retailers are still stuck where they were before. We will all continue to wait and see what FDA will do.
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne.
Governments are responsible for the regulatory framework and consumer food protection to keep their citizens safe. In Germany, the Federal Office of Consumer Protection and Food Safety is responsible for national food safety as well as cross-border trade and international information exchange. The German BLV is also the contact point for the EU’s Rapid Alert System for Food and Feed, RASFF. To ensure consumer safety, the Max Rubner-Institut employs some 200 scientists who research food safety, nutrition and food fraud.
Many have seen some variation of the bell curve used to visualize the distribution of the five personality types of technology adopters (see Figure 1). These personality types were first ideated by Beal and Bohlen to highlight personality types that were more or less likely to adopt new technology in agriculture. This model has been expanded to include many other types of technology and is still used today.
Which type are you? While it can be fun dinner conversation to compare and contrast your tech enthusiast friends who always have the latest iPhone with laggard pals who insist on using a flip phone, is it possible that self-awareness of your product adoption personality could be vital to your personal and professional success?
Are you an early adopter who is excited and interested by how new technology offerings can change how you live and work? Or are you perhaps a member of the late majority that prefers to play it safe? More importantly, does your product adoption personality serve you in your career? Or does your resistance to change impede your company’s ability to thrive in a competitive marketplace where embracing innovation is key to protecting your product and brand? If the answer is yes, it may be worth keeping that propensity in mind as you make technology decisions at work.
We are each complex human beings who unintentionally bring our unique biases and habits to work with us. Rather than letting those biases and habits control our decisions, we can choose to be aware of our tendencies towards important issues like choosing whether to invest in new technology and approach problems through a less biased lens. When it comes to something as important as food safety and brand equity, we can’t afford to let our biases be in control. It is important to know that any technology provider worth their salt will happily answer questions and even let you try their solution. This firsthand experience is invaluable when choosing to invest in new solutions. Knowledge is powerful and you may be surprised at where it leads.
Elise Forward
Elise Forward is the president and principal consultant of Forward Food Solutions. Forward Food Solutions is dedicated to helping food manufacturers, distributors, and importers update and strengthen their food safety and quality systems. Forward uses her production, distribution, and supply chain experience to help companies in both the international and domestic markets. She is a member of IAFP, AFDO, ASQ, IFT, and MWFPA.
April Bishop
April Bishop is a senior director of food safety with TreeHouse Foods where she leads a team of food safety professionals to support 40+ plants, including food safety training, food safety plans, food defense plans, sanitation, pest control, microbiology, allergen control, and all other things food safety related. Bishop led the TreeHouse team to win the 2017 Food Quality & Safety magazine’s Food Quality & Safety Award recognizing that TreeHouse Foods employs high product standards and expectations, demonstrates excellence across all categories in its submission, and has a commitment to investing in technology, improving employee training, HACCP implementation and utilizing audits.
Bishop has more than 20 years of experience in the food industry and is a 12-year member of the International Association for Food Protection (IAFP), founding the Nebraska chapter with several co-workers in 2009. She is an active member of 6 IAFP Professional Development Groups, the Alliance for Listeriosis Prevention, the National Pasta Association, American Peanut Council, and the Food Defense Consortium.
Melody Ge
Melody Ge is head of compliance at Corvium, Inc. She has more than 10 years of experience in food safety and quality in different stakeholder positions including certification program owner, retailer, manufacturer, and food safety testing lab. Ge is a six-sigma black belt certified professional with experience in food safety consulting. Currently, Ge serves as the head of compliance at Corvium to ensure the product and data are in compliance with regulatory and customers’ requirements and needs. Prior to Corvium, Ge was a senior consultant and deputy QA director with Lidl US where she established the QA department for Lidl US expansion. Ge also worked as compliance manager at SQFI where her responsibilities include overseeing auditing results, stakeholders monitor and code Version 7 and 8 development. Ge started her career being the R&D and food safety director at Beyond Meat. Ge holds both M.S. and B.S. in food science and engineering.
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