Walter Brandl
Ask The Expert

Ask the Expert: Walter Brandl

Walter Brandl

As the Regional Director of Chemistry, North America, at Mérieux Nutrisciences, Walter Brandl oversees thousands of employees at the company’s state-of-the-art laboratories throughout the U.S. Here, he discusses the experiences that prepared him for a career in food contamination detection, his greatest successes, and the evolution of third-party testing in food safety. 

How has your professional background prepared you for your role as the Regional Director of Chemistry for North America?

Brandl: Strangely enough I think my experience outside the food industry has prepared me for my role as Regional Director of Chemistry. My background in environmental chemistry has given me insight into many approaches for contaminant determination in foods while my experience in biotechnology analysis allowed me to learn a very structured approach to method development and validation.

Of all the projects you have been a part of, which do you believe have had the most profound impact on food quality and safety?

Brandl: Our work in some of the FDA survey studies on acrylamide, arsenic speciation, and other contaminants that were used to assess risk and help provide a body of knowledge for policy decisions has probably had the biggest impact on food quality and safety. 

As an expert in the field, where do you see third-party testing laboratories headed? What will be the biggest challenges and keys to success?

Brandl: I think that the scientists who previously saw themselves as having purely technical responsibilities are now being asked to become a bigger part of the process in terms of providing guidance and interpretation of results. We will be required to have a more in-depth understanding of our client’s processes and problems so as to take a more active role in solving their problems. Communication and a greater knowledge of multiple industries will be the wave of the future. 

What famous person past or present would you most like to have dinner with and why?

Brandl: Tough question, but I think I would choose one of the very successful sports coaches, someone like Bill Belichick of the New England Patriots or Sir Graham Henry of the New Zealand All Blacks. Probably Graham Henry due to the nature of rugby. The reason is that I see the challenge of blending technical knowledge with personalities and emotions in sport reflected in the passion that scientists have for their endeavors. I would love to get their take on how to maintain intensity without burnout, making everyone’s contribution absolutely essential, and motivating people to get better every day.

Contact our chemistry food experts today! 

FDA Logo
From the Editor’s Desk

FDA Proposes Redesign of Human Foods Program

By Food Safety Tech Staff
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FDA Logo

On January 31, Robert M. Califf, M.D., MACC, FDA Commissioner of Food and Drugs shared a proposal for a unified Human Foods Program that would combine the Center for Food Safety and Applied Nutrition (CFSAN), Office of Food Policy and Response (OFPR) and certain functions of the Office of Regulatory Affairs (ORA) under one leader.

The new model was proposed in response to the findings of an external evaluation of the FDA Foods program conducted by an expert panel of the Reagan-Udall Foundation and a separate internal review of the agency’s infant formula supply chain response completed last year.

The Reagan Udall evaluation identified several concerns, including lack of communication, lack of a clear vision and mission, lack of a clear, overarching leader, and siloed workers within the FDA’s Human Foods program. The panel also found that the FDA Human Foods program was ill defined with multiple agencies, including CFSAN, OFPR and OVA, working independently of each other, often with separate leadership and little sharing of information. It recommended creating a new Federal Food Administration under HHS that would operate parallel to, rather than under the auspices of, the FDA.

In his statement announcing the proposal for a more unified Human Foods program, Califf highlighted the issues identified by these independent reviews, including problems with the current culture, structure, resources, and authorities in the FDA Human Foods program.

“Today I am announcing a new, transformative vision for the FDA Human Foods Program. I am also announcing a transformative vision for the Office of Regulatory Affairs (ORA, the FDA’s field-based operations) to support the FDA organization as a whole. The proposed structures for both groups will have clear priorities that are focused on protecting and promoting a safe, nutritious U.S. food supply that more quickly adapts to an ever-changing and evolving environment,” said Califf.

The “Vision for a Reimagined Human Foods Program” includes the recommendation to create a Human Foods Program under a single leader who reports directly to the Commissioner. Under this plan, the functions of the Center for Food Safety and Applied Nutrition (CFSAN), Office of Food Policy and Response (OFPR), as well as certain functions of ORA will be unified into a new organization called the Human Foods Program.

“The FDA will conduct a competitive national search for a Deputy Commissioner for Human Foods, who will oversee the Program. The person in this position will report directly to me and will be charged with leading a unified Human Foods Program that keeps the foods we regulate safe and nutritious, while ensuring the agency remains on the cutting edge of the latest advancements in science, technology, and nutrition,” said Califf. “The Deputy Commissioner will have decision-making authority over policy, strategy, and regulatory program activities within the Human Foods Program, as well as resource allocation and risk-prioritization.”

Other key elements of the proposed new Human Foods Program include:

  • Creation of a Center for Excellence in Nutrition that prioritizes the agency’s ongoing efforts to help American consumers make more informed food choices, including by working with industry to offer healthier, more nutritious food products.
  • Establishment of an Office of Integrated Food Safety System Partnerships that will focus on elevating, coordinating and integrating the FDA’s food safety and response activities with state and local regulatory partners to more effectively meet the vision of an Integrated Food Safety System in the FDA Food Safety Modernization Act of 2011.

The proposed program would also include the establishment of a Human Foods Advisory Committee made up of external experts who will advise the agency on challenging and emerging issues in food safety, nutrition and innovative food technologies.

“Finally, there will be an emphasis on strengthening our enterprise information technology and analytical capabilities to fulfill the promise described in the New Era of Smarter Food Safety and support the improvement in workflow that will accompany these changes,” said Califf. “This area of focus will support the work of the Human Foods Program by enabling more facile communication, more efficient operations and enhanced empirical risk algorithms to guide the priorities of the program and the work in the field.”

To execute this new plan, the FDA has formed an Implementation and Change Management Group that will be charged with developing a detailed plan for implementation of the newly organized agency. “While details of this proposal continue to be developed, CFSAN, ORA, and OFPR will continue to operate under their current structures, with my direct oversight. I look forward to providing additional public updates by the end of February on our progress, organizational design and timeline,” said Califf.

 

Rick Farrell, Plant-Tours
FST Soapbox

Improving Communication on the Food Plant Floor

By Rick Farrell
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Rick Farrell, Plant-Tours

In the food manufacturing industry, a well-trained workforce is essential to maintaining product quality, consumer safety and operational efficiency. In this line of work, everyone must know what they’re doing and be engaged with the task at hand. Yet, ensuring workers are trained, competent, and properly onboarded can be a challenge.

Time is one of the biggest impediments to employee onboarding and training. Most food manufacturers have limited time to offer training before getting new workers onto the floor, and it can be difficult to offer ongoing training in an efficient and effective manner. Part of this is due to the nature of manufacturing work. The production floor is a fast-paced, noisy environment where workers are engaged in time-dependent, manual activities.

Unlike knowledge-based professionals, it’s difficult to train manufacturing workers without interrupting the corporate workflow. Employees can’t be removed from their work for training purposes without disrupting the rest of production or cutting into manufacturing hours.

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This results in high costs and limited opportunities for dedicated training times, leaving many food manufacturers heavily reliant on initial training and onboarding sessions. As a result, employees often complete their onboarding and initial training without fully grasping what they were taught.

In an independent study by the Center for Research and Public Policy (CRPP), workers across the food chain reported not being well-trained. Nearly one third (29.6%) of respondents felt they hadn’t received enough training to perform work safely, 37.2% felt their training was too complicated or difficult to understand, 20.6% said they received too little safety training before doing their job, and only 51.8% reported receiving enough on-the-job coaching.

We can’t onboard new food workers by dumping knowledge onto them during a few preliminary training sessions, then leaving them to work things out on their own. This can result in employees adopting poor work habits from co-workers, becoming disengaged, and leaving the workplace.

How To Bring New Team Members Up to Speed Quickly

Offering only a few information-packed training sessions or learning courses isn’t an effective way to train workers involved in motor skill-based work. Employees trained this way tend to find the information hard to understand, are likely to forget what they’ve learned, and may have difficulty translating theoretical knowledge into practical work tasks.

If you want to get new hires up to speed faster, offer learning that’s action-oriented, continual, and manageable. Employees, especially new hires, also need immediate feedback on whether they’re performing their work correctly. This requires direct, mid-task guidance and corrective observations rather than delayed video training.

After your initial onboarding and training, employees need ongoing training to reinforce initial learning, deepen knowledge, shore up weak spots, and provide updates. This is best done in brief stretches of around five to seven minutes. Longer learning sessions can overload workers, leading them to tune out, lose focus, and forget. Brief, tactical training sessions are far more effective and efficient, and can be used for on-the-spot training and knowledge refreshment.

Supplement these short training programs by placing multimedia training materials, such as videos or recorded reminders, in break rooms, locker rooms, and other areas where workers spend downtime. Offer mobile coaching tools, apps, and handouts for independent learning.

Peer support can be invaluable in onboarding and training new employees. Workers joining a new organization look to their co-workers to understand how things are done and what values are truly upheld.

By incorporating rapid skill acquisition tactics, environmental learning cues, and approved employee partnering or mentoring programs, companies can onboard and train new employees more quickly, while keeping training requirements manageable and efficient for the organization.

How to Keep Workers Safe and Happy

In the CRPP report, 60.5% of food production supervisors and managers felt that lack of training was the primary cause of workplace injuries within their facility. Employees who are well-trained, supported, and socially engaged report higher levels of job satisfaction and happiness. In addition, they are more comfortable letting higher-ups know about potential issues, leading to a safer work environment and end product.

Therefore, companies must consider cultural onboarding that includes constructive communication and social interaction with coworkers and supervisors, in addition to skill-based and protocol training.

Happy and satisfied workers experience high levels of social exchange with their organizations, leaders, and peers. Good communication allows them to share information, integrate into the culture, become more invested in their work, and achieve positive outcomes.

Manufacturers can support a safer, more productive, and happier working environment by facilitating productive communication on the floor.

Tools and Strategies That Support Effective Communication

Quality on-site communication can be achieved through strategically selected channels and technologies. Most organizations already have effective ways to broadcast communications and offer mass learning opportunities. For example, emails with safety reminders, tips, process guidelines, or recommendations can be blasted out to various employee segments. Video displays, posters, and other media forms can be placed around the environment to provide warnings or critical reminders, while apps and online courses can be used to facilitate independent, self-paced learning.

These are all, however, impersonal mechanisms that don’t connect workers with supervisors who can guide, assess, or correct their knowledge. The real challenge for food manufacturing has always been how to train employees while on-the-job.

Common challenges for management include spending enough personal time with new hires, correcting errors spotted from a distance, guiding workers without interrupting workflow and providing ongoing training without removing workers from the production line.

These specific issues can be resolved with technology that allows instant communication at a distance, such as two-way communication headsets. Two-way headsets enable one-to-one or one-to-many conversations, providing clear audio even on noisy plant floors.

Industrial communication devices can be used to facilitate ad hoc, personalized onboarding assistance or coaching from coworkers and team leaders. Trainers can use headsets to remain connected with new hires, provide training as needed, offer instant corrections, and assess entire groups at a time. To further boost onboarding, experienced peers can be offered headsets to guide new workers.

Food manufacturing has always been a tech-forward industry. Safe and efficient operations depend on the effective use of new technologies. By continuing to investigate and adopt new tools and strategies, manufacturers can continue to drive business objectives forward while bolstering on-the-job safety, performance, and employee satisfaction levels.

Emily Newton, Revolutionized Magazine
FST Soapbox

Level Up Safety with Food Packaging Automation Technologies

By Emily Newton
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Emily Newton, Revolutionized Magazine

Food packaging automation technologies can increase productivity and improve food safety. We highlight three key packaging technologies worth investigating.

1. Image-Based Sensors

Foreign objects in packaged foods are a key cause of recalls and can lead to both physical harm and reputational damage. Some companies are incorporating food packaging automation solutions that rely on cameras to detect foreign objects before products leave production facilities.

In one example, researchers from Ritsumeikan University in Japan used a tactile-based image sensor mounted on a high-resolution camera to look for hard objects, including shell and bone fragments, within soft foods. This technology found sub-millimeter foreign bodies and required only 10 seconds to scan a piece of food.

Some sensors can sort food, such as rice, based on appearance. If the rice does not meet specifications—or if a contaminant is detected—the device emits coordinated air puffs to blow the subpar product or contaminant into a reject bin.

Image-based sensors do not replace people from inspection processes. The goal is to boost quality control by combining advanced technology with human oversight. This allows food packaging plants to reduce the risk of unsafe consumables reaching the market.

2. Robots

Robots have been game-changers in food packaging automation. Statistics show that Chinese food and beverage industry clients purchased an estimated $196 million in robotic technology in 2022, with companies from the U.S. investing roughly $160 million in these technologies. These numbers have climbed since 2020, suggesting more company leaders are embracing robotics for their operations.

Companies that don’t have enough employees to handle the workload can compromise safety if they give workers more responsibilities than they can handle or force them to work too quickly. However, robots can ease some of that strain. One robotic top loader for wrapped food products processes up to 120 products per minute, depending on the type.

In another case, a food packaging plant had only 30 employees but needed to switch to 24/7 production to meet customer demand. Adding three collaborative robots, or cobots, to the workflow made it safe for the small team to ramp up activities without getting overwhelmed.

It can take food packaging plant leaders time and effort to figure out the best ways to bring robots into a facility. It helps to determine which tasks are most prone to errors and likely to result in injury. Alternatively, managers can ask line workers which duties feel the most cumbersome or dangerous.

Many employees are initially hesitant about working with cobots. They feel more positive and comfortable about these changes when they realize the machines supplement their work rather than replace it.

3. Upcycled Food Packaging

Food packaging automation has benefits that extend beyond the production environment. Singapore-based Alterpack uses automated equipment to turn spent grain into takeout containers and other types of packaging. The packaging is microwave and freezer-safe, and people can toss it into their compost heaps after use.

The company’s goal is to help reduce dependence on single-use plastic packaging. The process requires cleaning raw materials, mixing a specialty formula and molding it into desired shapes. Automation keeps these steps safe and consistent.

Other types of automation specific to food packaging focus on consumer safety. One project from the Fraunhofer Institute for Process Engineering and Packaging involved embedding packages of meat and fish with chemosensors to measure freshness. The sensors change color automatically when exposed to volatile compounds that indicate product spoilage. The visual indicator makes it easy for consumers, grocery store workers, and others to see when food is no longer safe to sell or eat.

Elsewhere, a team of researchers from Harvard University and Singapore’s Nanyang Technological University made a type of smart food packaging primarily constructed from corn protein. The packaging contains innovative nanoscale mesh fibers and natural antimicrobial compounds programmed to sense common kinds of bacteria in food. When the bacteria are detected, the packaging automatically sprays out tiny amounts of antimicrobials to keep food fresher and safe to eat for longer.

These are just some of the forward-thinking ways food packaging designers can incorporate automation into their production process. Options like these will likely become more widespread as more people experiment with what’s possible, spurring progress in food safety, productivity and waste reduction.

 

Wiping down table
Food Safety Culture Club

Norovirus Season Is Here: Foodservice Actions To Help Prevent Outbreaks

Wiping down table

Cases of norovirus are reaching new highs, necessitating a review of preventive measures for retail food establishments. After experiencing a lull during the first two years of the pandemic, norovirus cases came surging back in the first quarter of 2022, with outbreaks peaking at over 100 per week in late February, according to data from the Centers for Disease Control and Prevention.[1] Last week, the CDC updated its NoroSTAT page showing a similar increase happening over the past four weeks.

“It’s not a coincidence that U.S. norovirus cases dropped to historic lows in 2020 and 2021, then came surging back as Americans began dropping their pandemic precautions this past spring,” said Chip Manuel, Ph.D., Food Safety Science Advisor, GOJO Industries. “People are fatigued by social distancing, isolation and masking, but it is important to remember that everyday practices like hand and surface hygiene help to control norovirus and many other infectious diseases.”

Food establishments can protect their customers from outbreaks by taking the following steps:

  • Keep sick employees home. 70% of norovirus outbreaks are caused by infected foodservice workers,[2]so preventing employees from coming to work sick with norovirus is an important step in preventing outbreaks in foodservice establishments.[3] Adopting sick leave policies and employee wellness screens will reduce the risk of a facility causing a foodborne illness outbreak. Employees that come to work sick can spread the virus to foods, surfaces, customers, and other employees.
  • Practice frequent proper hand hygiene and minimize bare-hand contact with food. Inadequate hand hygiene and bare-hand contact with foods are the most frequently encountered contributing factors to norovirus outbreaks.[4]Ensure bare-hand contact with foods is minimized by emphasizing proper glove use. More frequent handwashing, providing handwash stations, and providing alcohol-based hand sanitizers when soap and water are not available, are all best practices related to hand hygiene.
  • Disinfect high-touch surfaces regularly. Establishments should continue to disinfect high-touch surfaces since they have a direct carryover to controlling foodborne illnesses, especially norovirus. Examples include frequent disinfection of restroom door handles, handwash sink faucet handles, and restroom stall latches.
  • Clean before you sanitize. Proper surface sanitizing requires the surface to be cleaned first to remove all food debris, fats, oils, and other soils. The U.S. Food Code requires that all food-contact surfaces must be cleaned before the sanitizing step.[5]This ensures that the sanitizer solution will remain effective, as these soils can interfere with the sanitizer’s effectiveness.
  • Ditch the “rag and bucket” practice. Using a red bucket of sanitizing solution and a reusable cloth is a common way to sanitize tables in a restaurant. But research shows that reusable cloths can easily become breeding grounds for foodborne disease-causing bacteria.[6]They can then spread pathogens to other surfaces throughout the establishment. Sanitizer solution must be monitored throughout the day so it maintains a required concentration level and be changed out when the solution appears dirty, plus the cloths must be stored in the solution, laundered daily, and not used for multiple tasks. Switching to applying a food-contact sanitizer by spray bottle or a disposable wipe can reduce some of the risks associated with reusable cloths.
  • Use effective surface products with low toxicity that work quickly. Using ready-to-use products with short contact times (e.g., a minute or less for organisms of interest) can increase compliance with enhanced disinfection protocols, which help reduce the risk of an outbreak within a facility. These products also save your staff valuable time. The EPA categorizes products from I (highly toxic) to IV (very low toxicity.) If possible, select products rated as category IV to limit your staff and guests’ exposure to harsh fumes. When using higher toxicity products follow all “Cautions” noted on the product labeling, as these products may require handwashing after use and/or personal protective equipment, such as gloves, gowns, and eye protection during use.

“In 2022, the U.S. saw the largest number of norovirus outbreaks in more than 10 years, even though the 2021-2022 norovirus season peaked late (late February vs. early January),” said Hal King, Ph.D., Managing Partner, Active Food Safety and Founder/CEO, Public Health Innovations. “In 2023, we can expect even more norovirus infections will be circulating in our communities, and many of these infected persons will likely be workers and customers entering restaurants. The best means to reduce the risk of transmission of norovirus in restaurants is to continue to screen employees for wellness (with a focus on all foodborne disease signs and symptoms), continue disinfection of high-touch surfaces in the restaurant (especially the restroom areas), and ensure proper hand hygiene and glove use before, during, and after food preparation.”

 

References:

[1] Centers for Disease Control and Prevention, “Reporting and Surveillance for Norovirus: NoroSTAT.” https://www.cdc.gov/norovirus/reporting/norostat/index.html Accessed Dec. 12, 2022.

[2] Centers for Disease Control and Prevention, “Preventing Norovirus Outbreaks.” https://www.cdc.gov/vitalsigns/norovirus/index.html Accessed Nov. 22, 2022.

[3] Duret, S., et al. Quantitative risk assessment of norovirus transmission in food establishments: evaluating the impact of intervention strategies and food employee behavior on the risk associated with norovirus in foods. Risk Analysis, 37(11), 2080-2106, 2017.

[4] Brown, L. G., et al. Outbreak characteristics associated with identification of contributing factors to foodborne illness outbreaks. Epidemiology and infection, 145(11), 2254–2262, 2017. https://doi.org/10.1017/S0950268817001406

[5] U.S. Food & Drug Administration, “Food Code 2017.” https://www.fda.gov/food/guidanceregulation/retailfoodprotection/foodcode/ucm595139.htm Accessed Nov. 22, 2022.

[6] Scott, E. and Bloomfield, S. 1990. Investigations of the effectiveness of detergent washing, drying and chemical disinfection on contamination of cleaning cloths. J. Appl. Bacteriol. 68: 279-283.

 

Scott C. Algeier
FST Soapbox

Re-Evaluating Our Cybersecurity Posture and Practices

By Scott C. Algeier
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Scott C. Algeier

On November 10, the White House released a National Security Memorandum (NSM) aimed in part at improving cybersecurity within the food and agriculture sector. The NSM contains a clear message: “The evolving threat environment requires the sector and its essential workforce to better prepare for and respond to incidents with broad impacts on our national and economic security.”  If cybersecurity was not a priority for your organization in 2022, it should be one in 2023.

The food and agriculture industry has benefited greatly by incorporating technology into core business functions, which makes the industry more efficient. Farmers now provide more food on less land thanks in part to precision agriculture. A complex, interconnected logistics system—propelled by information technology—enables just in time delivery of product. But this interconnectedness creates risk that needs to be managed. Even if an adversary may not intend to disrupt the food supply chain, a short disruption can quickly rise to a national security concern.

This is the impetus behind the NSM: There is a national security interest in ensuring the integrity and resilience of the global food supply chain. Addressing these threats, however, requires individual action by an untold number of companies. Many of these companies operate on small margins and lack resources to understand the or mitigate cyber risks.

The cyberthreat environment is complex and ever changing. Nation state actors seek core intellectual property and other proprietary information. Social activists launch campaigns aimed at disrupting access to public-facing Internet sites. Mis- and disinformation spreads through social media channels.

Organized cybercriminal gangs are motivated by money. Often, the victim is not necessarily the intended target. But sometimes the food and agriculture industry is targeted specifically. On December 12, the FBI, CISA, the FDA and the Department of Agriculture issued a public advisory warning of Business Email Compromise attacks, demonstrating the financial loss attacks can cause.

Developing a Common Approach to Cyber Risks

Developing a common approach to defend against these threats is challenging since industry and government view risk in different ways. This often leads to disagreement on risk tolerance and risk mitigation. While policymakers focus on national security risks, businesses focus on corporate risks.

While cyber risk is one of many business risks enterprises mitigate, these resources compete against other business priorities. Meanwhile, there is a government interest in ensuring that cyberattacks do not impact national security or cause wide-scale economic damage. Also, the fact that the most advanced cyber adversaries are nation states is a national security concern.

It is not reasonable to expect companies to be able to defend themselves against cyberattacks from well-resourced nation states. However, just because an organization is not able to defend itself from the most sophisticated attacks does not mean it should not defend against less sophisticated and more common attacks.

Hacker
The economics of cybersecurity favor the attackers. Collaboration allows defenders to maximize their resources and gain more even footing to protect their companies.

Realistically, there is a limit to what companies can spend. At some point the cost is not worth the return, and it makes more sense to assume or transfer the risk. In short, the risk management calculus for industry (business risk) and government (national security risk) are different. A business may be effectively managing a threat appropriate to its business risk while government is concerned about the national security risk of that same threat.

While it is important for government to address perceived national security risks, government policy should be informed by industry subject matter expertise. Most of the food and agriculture industry is owned, operated, or managed by private industry. Industry best understands its risks, vulnerabilities, and interdependencies. This expertise needs to be included in policymaking.

Industry Guidance and Reporting Requirements

In the fall of 2022, Congress passed the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) with the goal of helping companies defend against complex cyberattacks. When fully implemented, regulations developed under this law will require critical infrastructure “covered entities” –likely including food and agriculture companies—to report certain cyber incidents to DHS’ Cybersecurity and Infrastructure Security Agency (CISA). The idea is that CISA will use the information in the incident reports to better understand the threats and issue guidance to help industry and government protect themselves. CISA recently concluded a public “Request for Information” and is expected to issue the Notice of Proposed Rulemaking for implementation of this program in March 2024.

CIRCIA signifies a more aggressive regulatory approach by policymakers and is symbolic of a larger debate that has been unfolding for 20 years. That debate being: What is the best way to increase cybersecurity within private industry? Some believe regulations are needed to force organizations to take proper security measures. Others contend that regulations will divert resources from security to compliance and do little to assist small businesses who have the fewest resources and are most at risk.

Regardless, mandatory incident reporting is on its way. However, it should not be viewed as a replacement for voluntary industry action. Voluntary collaboration with industry peers will remain a core component of industry cyber risk management.

There is a long history of such collaboration. For over 20 years, the IT-ISAC has facilitated the sharing of cyber threat intelligence within the IT industry. For over a decade, it also has supported a designated forum for food and agriculture companies to actively engage with each other to mitigate cyber risks. It is the only industry-only forum of its kind established to serve food and agriculture companies.

The Food and Ag SIG reflects three core realities in cybersecurity. One is that the attackers are already sharing with each other. They are actively leveraging their individual expertise to attack for a common benefit. To keep pace, industry needs to actively share threat analysis and effective defensive mitigations.

Second, the threat landscape is too complex for any one company to defend against alone. There are too many threat actors, too many vulnerabilities, and too few resources for any one company to adequately address the threat by itself. Companies are stronger when working together.

Third, the economics of cybersecurity favor the attackers. It is more expensive to defend than it is to attack. Defenders need to maximize their resources.

A Cost-Effective Force Multiplier

The Food and Ag SIG serves as a cost-effective force multiplier by enabling companies to share active threat intelligence targeting the food and agriculture industry. By engaging with analysts from peer companies facing similar business challenges and threats, companies can reduce their vulnerability to a wide range of risks. While there are common attacks all enterprises face, the food and agriculture industry faces unique actors that utilize customized methods for specific purposes. The IT-ISAC Food and Ag SIG helps companies address this challenge through:

  • An intelligence management platform containing active threat indicators and analysis.
  • Adversary attack playbooks on over 200 threat actors, including those targeting the food and agriculture industry. These playbooks catalogue tactics, techniques, and procedures used by attackers, including how they gain access to and move through environments and actions to defend against these threats.
  • A tracker of over 250 ransomware campaigns impacting the food and agriculture industry.
  • Engagement with cybersecurity analysts from the world’s leading technology companies.
  • Member-only meetings with analysts from peer companies in the food and agriculture industry.
  • Briefings from security experts on attacks and adversaries targeting the industry.
  • Daily reporting on trending threats and vulnerabilities.
  • Vendor neutral Incident specific reporting.

Looking ahead, 2023 will continue to be an active year for cybersecurity. The skillsets of attackers continue to advance. Nation states have the intent and capability to attack private industry. There remains too much reward and too little risk for many criminal gangs. As long as the likelihood of making money remains high and the risk of getting caught remains low, we will continue to see organized cybercriminal activity such as ransomware, despite the great work of our under-resourced law enforcement professionals.

In this environment, every company needs to re-evaluate their security posture and practices. While there is no one-size fits all approach to security, there are steps companies can take to manage their risks. Engage with your industry peers. Back up data. Deploy encryption. Implement and improve patch management policies. Enable multi-factor authentication. Segment networks. Implement credential access and control policies based on an employee’s need for access and terminate such access upon employee separation. Review (or create) and test incident response and business continuity plans. Simple actions can have big results.

Voluntary industry action and active collaboration not only enhances your corporate security it makes the industry as a whole more secure. Active sharing of cyber intelligence and effective mitigations improves security and reduces the potential of disruptions within the supply chain. The voluntary actions of individual companies managing enterprise risk can indeed have the collective effect of reducing national level risk.

Listeria
From the Editor’s Desk

Food Safety Tech Hazards Series Expands to In-Person Events in 2023

By Food Safety Tech Staff
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Listeria

For the past two years, Food Safety Tech, creator of the annual Food Safety Consortium conference, has been supporting FSQA professionals through its virtual Food Safety Tech Hazards Series.

Focused on the four core areas of food safety: detection, mitigation, control and regulation of risk, the series has addressed pathogens, pest control, and physical and chemical hazards facing the food industry.

The virtual conferences, which have attracted thousands of attendees, provide information on ongoing and emerging risks for both new and seasoned FSQA professionals, featuring speakers from industry, regulatory agencies and standards bodies.

In 2023, we are building on the popularity and success of these virtual events by expanding the Food Safety Tech Hazards Series to include two in-person events coming this spring and fall.

In 2022, salmonella– and listeria-related cases represented 37.4% of food and beverage product recalls, an uptick from 33.3% in 2021. “Food safety hazards continue to be a challenge for all aspects of the food industry from farm to fork.” said Rick Biros, president of Innovative Publishing Company, publisher of Food Safety Tech and director of the Food Safety Consortium conference. “The detection, mitigation and control of food safety hazards issues must be discussed among peers and best practices must be shared, something you can’t do virtually. The human connection is so important for conference attendees. Whether it’s a random connection over lunch, a one-on-one question with a speaker after a presentation or a seat next to a new friend in a learning session—connecting with others is what makes events so valuable. This year’s in-person events are designed to help facilitate this much needed critical thinking and sharing of best practices.”

“We look forward to bringing the Food Safety Tech Hazards series to an in-person audience in 2023,” said Inga Hansen, editor of Food Safety Tech. “This format will complement our virtual series and allow for the live discussion and networking that can only be achieved in person.”

Stay tuned for upcoming dates and registration.

 

Matt Regusci
FST Soapbox

Will California and the Supreme Court Cripple the Pork Industry?

By Matt Regusci
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Matt Regusci

An upcoming decision by the Supreme Court could have an enormous impact upon the nation’s pork supply and prices, as well as other industries. For the sake of smaller pig operations nationwide and people in California who are not wealthy, I hope the Court rules that a California law requiring that state businesses can only sell pork from humanely raised pigs is unconstitutional.

At issue is National Pork Producers Council v. Ross, a suit born out of California’s 2018 ballot measure Proposition 12, which forbade the sale of pork in the Golden State unless the sow that birthed the pigs was granted 24 feet of space. Most commercial pig operations confine pigs in smaller spaces. After California voters passed the measure—over 60% voted in favor of it—two trade groups sued, arguing that it upended interstate commerce and defied sensible business practices.

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The rule would barely touch the California pork farming industry, which is relatively small—the state accounts for just 1% of the pork producers in the country. But pig farming in states like Iowa, Minnesota, North Carolina, Illinois and Indiana—the nation’s top 5 pork producers—would suffer quite a bit should if measure is not struck down by justices.

By imposing this 24-foot requirement on all pork imported into California, the state is effectively dictating how industries in other states do business. While California isn’t a big pork production state, it’s a large consumer—Golden Staters consume 15% of all pork produced in the United States, and import 99% of their pork. If the law remains in place, only the largest pig producers in the industry could serve California, and thus survive in a highly competitive marketplace nationwide; they will have the resources to meet California’s demands and create separate facilities for California pork. So one regrettable side effect of Proposition 12 would be the acceleration of consolidation among pig operations.

Another ripple effect, should the law remain in place, will an increase in pork prices in California, which will hit the poor the hardest. The large operations in pig production states that have the resources to create separate facilities for California pork will likely charge far more for the bacon, chops, and ribs they produce. And there will be less of it, further pushing up prices.

Along these lines, California is an intensely diverse state. Many of the cultures that populate two of the state’s largest broad immigrant categories—Latin American (representing half of immigrants) and Asian (with 39% of the state’s immigrants)—include people from countries including Mexico, the Philippines and Vietnam, where pork figures largely into their cuisines. With inflation rising at rates not seen in more than 40 years, the nation’s poor, including many new immigrants, already are suffering. A dramatic spike in pork prices would further disrupt their lives.

During oral arguments, both liberal and conservative justices explored the heart of the problem with Proposition 12. Justice Amy Coney Barrett, for example, asked if it would be acceptable for California to “pass a law that said we’re not going to buy any pork from companies that don’t require all their employees to be vaccinated or from corporations that don’t fund gender-affirming surgery?” Justice Elena Kagan wondered if a state could ban the import of wood products unless they were treated with specified pesticides.

Potential Precedent of Prop 12

Their probing questions reveal concerns about Proposition 12’s potential precedent for sparking more legal warfare between states with competing political identities. Should the justices allow Proposition 12 to stand, what stops Texas voters from approving a law that bans the importation of products from companies that pay for employees’ birth control? Or Massachusetts voters from voting in favor of prohibiting chicken from states with abortion bans, which today would damage the chicken industry in Indiana, the third-largest chicken supplier in the nation, as well as other states.

One result, said Justice Kagan, could be that states “are constantly at each other’s throats” by targeting one another’s industries with bans on commercial activity between states.

The justices ruling will hinge on how they interpret the Constitution’s commerce clause, which aims to encourage interstate commerce and block trade wars between states. It is obvious that California’s law will inhibit interstate commerce between California and the nation’s pork-producing states. But that doesn’t mean justices will conclude that the California law should be dumped. Other justices, especially Justice Neil Gorsuch, seem to side with California.

“We’re going to have to balance your veterinary experts against California’s veterinary experts, the economic interests of Iowa farmers against California’s moral concerns and their views about complicity in animal cruelty,” Gorsuch told a lawyer representing pork producers, as reported in the New York Times. “Is that any job for a court of law? I mean, the commerce clause, after all, is in Article I, which would allow Congress to resolve any of these questions.” He also wondered whether since some pork producers are willing to satisfy California’s new requirements, wouldn’t it be a good idea to let the market decide whether the law works?

If justices’ do decide the California law is illegal, it could have repercussions beyond the pork industry. For example, California sets auto emissions standards for vehicle sales in the state that exceed federal standards; it is the only state with the right to do that. The so-called “California Waiver” imposes burdens upon automakers that seek to sell in the nation’s largest market for auto sales. Meanwhile, a new California law requires that by 2035, all new vehicles sold in the state are electric, hydrogen-fueled or at least plug-in hybrid. If the Supreme Court, which will issue its opinion on National Pork Producers Council v. Ross between December of this year and June of 2023, rules against California it also could impact the sanctity of laws like California’s emissions standards.

“How many laws would fall?” Justice Barrett asked during the hearing. “California has higher emission standards on automobiles and many other states. Would that fall?”

No matter what the Court decides with this case, it will affect life in the U.S. In the context of the pork industry, I sympathize with animal rights advocates who seek to improve conditions for livestock. But Proposition 12 is the wrong way to go about effecting meaningful and fair change in the pork industry.

Wendy White
Bug Bytes

Maximize Your Pest Control Program

By Wendy Wade White
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Wendy White

Pest Control (PC) companies have become so good at controlling insects, birds, rodents, and other pests that facility oversight of pest management programs often falls by the wayside. This neglect can cause huge issues when pest management plans are dusted off by an auditor or inspector or when there is an unexpected infestation. Here are a few, easy methods to help you improve your Pest Control Program and validate the efforts of your third-party PC provider.

Validating Facility Pest Maps

A common PC program nonconformance involves discrepancies to the Facility Pest Map. The number and placement of internal tin cat traps, fly lights, external bait stations, pheromone traps, etc. can become inaccurate over time. Ask your PC provider to update your map at least annually or when there are major changes. Small changes can be written on the map if they are dated and initialed. When a new version of the map is released, select someone to validate it by physically walking around the facility, checking the placard number and placement of the traps to the map, and making note of any discrepancies.

Dead cockroaches
Review Pest Control Service Reports for observations on conditions that could lead to a pest control issue and suggestions for corrective actions.

It’s also a good idea to periodically walk the map throughout the year to ensure that these devices haven’t been damaged. We all know how much forklifts love to crush tin cats, and these traps always seem to get moved around (used to prop open door or knocked out of the way). Different sections could be added to a monthly GMP internal audit to ensure the entire facility and surrounding grounds are covered.

Analyze Service Reports and Trends

It’s amazing how often Pest Control Service Reports are generated and fall into the black hole that is the Pest Control book. Sometimes they are signed by a facility representative, but how often is that person paying attention to the report’s contents to really understand the facility’s vulnerabilities? Many PC providers include observations on conditions that could lead to a pest control issue, suggestions for corrective actions, and other valuable advice for improvement. How often are these words heeded? Often pest control nonconformances discovered in audits and inspections were previously identified by a PC provider. Someone at the facility should be periodically analyzing these service reports to extract this information and act upon any necessary corrective actions. The designated employee can set themselves a calendar reminder to perform this task on a monthly or quarterly basis, remembering to document any corrective actions.

In addition to service reports, many PC providers also provide trending information, which summarizes pest activity over time. Many facilities don’t understand how valuable this information can be. For example, looking at rodent activity (gnaw marks on the bait) of your external bait stations can help identify the locations in your grounds with the most rodent activity. Some rodent activity is expected, but if it’s excessive, there could be a root cause that can be improved. For example, there may be a harborage point or perhaps the grass in the back field should be mowed more frequently in the summer or you may identify areas where additional bait stations are needed.

Leveraging Pest Control Provider Expertise

Many PC providers have entomologists and other pest experts on staff that can conduct an initial vulnerability assessment, which is normally revised annually, to customize the PC program and better protect the facility. These individuals can also be utilized to troubleshoot infestations. Once the type of pest is identified, specific corrective actions can be implemented to eradicate the infestation and preventive actions carried out to prevent a reoccurrence. For example, if birds are a problem around the shipping docks, nets might be used to reduce access to the rafters for nesting birds, or random sirens might be used to scare away migratory birds. For insect infestations, different chemicals (and the application of those chemicals) might be used to maximize remediation.

Mouse
Post a copy of the Pest Sighting Log in the employee breakroom, and empower employees to report any issues.

At a minimum, PC providers should be providing you with a PC book which contains: a current facility map, regular service reports, current licenses for all PC technicians, and the Safety Data Sheets for all chemicals that might be used inside your facility.

Better Utilize the Pest Sighting Log

All PC programs use a Sighting Log in which any pest observations made between PC technician visits can be identified and acted upon. Too often, this log is hidden in the PC book and only used by a designated facility representative. There might be an understanding that sightings observed by other employees are reported to QA, so they can log the sighting. Sometimes this procedure works, but it’s often disrupted and the PC technician doesn’t receive this valuable information. How many issues could be prevented by identifying the problem early?

A solution is to post a copy of the Pest Sighting Log in the employee breakroom and direct the PC technician to check it during services. Train all employees of the purpose and location of this log, and empower them to report any issues. Employees have a vested interest in preventing pest infestations in their workplace, so you might be surprised how successful this simple change can be.

Pest Control Program Innovations

PC programs haven’t changed much in the last few decades. PC providers use technicians to make regularly scheduled visits to maintain pest control devices and apply chemicals when needed. For large facilities, this can be an arduous practice involving hours or even days of work. In the past few years, there have been significant efforts to automize these efforts, allowing remote monitoring of PC devices. Most of the larger PC providers have been working towards this technology and a few now these devices commercially available.

There are some clear benefits to remote monitoring. It gives PC technicians more time to investigate potential issues instead of checking empty traps. Also, remote activity notifications can lead to earlier action, which can prevent mild issues from turning into full-blown infestations. These devices can also be used in hard-to-reach places, such as a narrow void in the ceiling. There are still some concerns with this technology; it’s much more expensive than traditional devices and an automated system could lead to complacency.

While we wait for the technology to become perfected, there are many small changes that can make immediate improvements to your PC program. Validate your program to better understand vulnerabilities, analyze service reports and trends to identify emerging issues, and leverage the resources (pest experts and internal employees) already available to maximize efforts and strengthen your PC program.