Randy Fields, Repositrak
FST Soapbox

Update: Non-FSMA Food Safety Litigation

By Randy Fields
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Randy Fields, Repositrak

The keynote panel at the 2017 Food Safety Summit in May had, as any food safety professional would expect, a focus on how companies are coping with FSMA and the increased scrutiny they may face. There was unanimous belief on the panel that enforcement is coming and all trading partners need to be prepared, but there was also a look beyond FSMA adoption to what will come next.

First, though, where do we stand with FSMA-related litigation?

Shawn Stevens, one of the leading food industry lawyers, told attendees that it’s important for all retailers, wholesalers, suppliers and affiliates to understand that FDA was commanded by Congress to stop foodborne illness and the impact it has on Americans, plain and simple. His advice is for food pros to learn all aspects of FSMA and do it quickly, saying the goal now is to avoid making the operational mistakes that may result in criminal exposure for the company and its executive leadership team.

Going forward, the industry will not only have to comply with FSMA, but it will also need to address recalls, risk mitigation and other complex food safety issues not directly related to FSMA. Foodborne illness outbreaks will still cause legal claims that can be compounded by personal injury suits and potentially impact a retailer’s reputation negatively. Also, there are trends in organic foods, GMOs, gluten-free items and more that will impact the retailer, supplier and ultimately may result in more litigation.

Jeffrey Steger, assistant director of the Consumer Division at the U.S. Department of Justice (DOJ), reported that companies shouldn’t expect a waning of the federal government’s support of non-FSMA enforcement actions. The DOJ gets involved in cases where there is significant harm to consumers, where food company executives had prior knowledge, and where legal action will protect the integrity of the regulatory system and prevent future harm. It has pursued many high-profile food industry prosecutions to date and he believes this trend will continue.

The importance of the FSMA regulations and the responsibilities placed on the food industry shouldn’t be understated in the context of food-related litigation. But there are other new developments in the marketplace and the extended supply chain that are impacting retailers like transparency in packaging, labeling of social responsibility programs, the move toward clean labels and facility auditing requirements.

Recent research by the Food Marketing Institute indicates retailers and suppliers that connect with shoppers in support of food safety are well positioned to build shopper trust and loyalty. The converse must also be true—companies that have their reputation dragged down due to involvement in food safety litigation will surely be poorly positioned to build shopper trust and loyalty.

Retailers and suppliers need to address all food safety-related issues or risk becoming defendants in a lawsuit or further government regulation. To accomplish this goal and, more importantly, to keep their customers safe, food companies need to nurture an enterprise-wide food safety culture that extends from the executive suite to store personnel –all retail employees must be responsible for food safety. Only then will customers recognize the company as being committed to food safety, and only then will the company get ahead of any potential food safety-related litigation.

Clive Longbottom, Quocirca

The Internet of Things: What the Future Holds

By Clive Longbottom
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Clive Longbottom, Quocirca

While the Internet of Things (IoT) is already having a major impact on safety in the food supply chain we’re only just scratching the surface of what connected devices can do to make the industry safer and more efficient. What strikes us as unique and innovative today will likely become standard across the food industry in the years to come as we find new and better ways to apply the technology in all aspects of the business.

One area we can expect to see the impact of the IoT grow is in a broader adoption of automation across the food supply chain. In the context of farming, we’re likely to see autonomous tractors supplant manually driven tractors as the primary equipment used to prepare land. Automated aerial drones will be able to assess the health of crops and deliver highly targeted applications of fertilizers, insecticides and weed killers to cut down on damage caused to crops by excessive use of those products. Transportation, too, is likely to see the impact of automation as driverless trucks take on the majority of shipments of goods.

Clive Longbottom will be the keynote speaker on a webinar hosted by Rentokil Steritech, the North American division of Rentokil, on July 13 at 1:00 p.m. EDT/10:00 a.m. PDT. The webinar will focus on the future of IoT in the food supply. Register to join by visiting http://tinyurl.com/foodsafety-rentokil-web2

Another key benefit the IoT will bring to the food industry is improved access to valuable data and in-depth analysis. This will allow more accurate tracking of shipments, better monitoring of quality throughout the supply chain and more useful prediction of potential problems. It’s here that we’re likely to see the biggest impact on pest management, as a broad network of connected sensors will be better able to identify and track pest populations, monitoring their movement and growth in a way that allows pest management professionals to target treatments more effectively. A recent survey of food professionals conducted by Quocirca and commissioned by Rentokil Initial shows that 20% of respondents think IoT will help them deal with cyclical problems such as pest swarms and seasonal flooding, while 19% believe it will provide the most benefit by alerting them to immediate issues such as unexpected pest infestations.

One thing we know for sure is that the technology will become more widely adopted throughout the industry as innovation drives costs down. Initially it will be difficult for smaller organizations with lower margins to invest in cutting edge technology, but as iteration and innovation push the boundaries of what IoT can do, they will also make more basic applications more affordable, as we’ve seen with technology across many industries in recent years.

While it’s easy to speculate and imagine a sci-fi-inspired future of driverless trucks, automated farm machines and limitless access to deep analytics, accurately predicting the exact applications of the IoT as it develops proves more difficult. What we do know is that we can expect the adoption of these technologies to grow at an increasing rate as more innovative and cost effective applications of the IoT are developed.

Deirdre Schlunegger, STOP Foodborne Illness
Food Safety Culture Club

Dave Theno’s Legacy: Keeping People Safe

By Deirdre Schlunegger
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Deirdre Schlunegger, STOP Foodborne Illness

I was putting the finishing touches on this month’s blog post when word came of the tragic and untimely death of Dave Theno, a man whose legacy looms large in the world of food safety.

Just last week I was corresponding with Dave about an honor that STOP Foodborne Illness wanted to bestow upon him at our annual December event that honors our Food Safety Heroes. He had enthusiastically accepted and we were excited to start planning.

Stop Foodborne Illness has a history that is inextricably woven with many of the threads from which Dave’s life was made. In 1993, Dave was called in to help the fast food restaurant Jack in the Box manage the crisis that was the result of an E. coli O157:H7 outbreak, which eventually killed four children and sickened hundreds of others.

At a time when most everyone working in food hadn’t yet realized that food safety was not just another facet of their operation, Dave Theno stood in the gap and helped usher in what has become the modern age of food safety. As he helped industry get on the right track, he also dedicated his life to learning the stories and sharing the pain of families affected by foodborne illness, foremost among them being Roni Rudolph, whose daughter Lauren Beth was the first to die. Together with other hurting parents, Roni founded what would become Stop Foodborne Illness; and in the words of our good friend Mary Heersink, “transformed isolated losses into something bigger than individual tragedy.”

Dave loved his job and did it well. With compassionate integrity and the heart of an advocate, Dave’s strong leadership was proof that he understood the seriousness of the tasks before him. His clear vision for a safer world where food was concerned was a testament to his calling. If there is anything we can learn from Dave Theno’s life, it is that the story is about people. The bottom line is about people. Dave’s compass was considering all the other “Lauren Beths” in the world, and keeping people safe.

He will be sorely missed . . .

Douglas Marshall, Ph.D., Eurofins
Food Genomics

To Be or Not to Be: Choosing the Best Indicator using Microbiomes

By Douglas Marshall, Ph.D., Gregory Siragusa, Ph.D.
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Douglas Marshall, Ph.D., Eurofins

Whenever an order is placed for an aerobic plate count, lactic acid bacteria count,  Enterobacteriaceae count, coliform count, fecal coliform count, Escherichia coli count, or yeast and mold count, it involves ordering an indicator test. So obviously, in food and water quality safety analyses, indicator microbiology is a highly routine and frequent activity. In fact, many business-to-business transactions are partially dictated by the outcome of indicator tests in the form of purchase specifications. Raw material producers and ingredient manufacturers are required to deliver products that meet the expectations of the buyer. Should such product exceed the predefined specifications, the expected transaction becomes nullified. Finished food product manufacturers also must meet specifications set by retailers and food service buyers. Some regulatory jurisdictions and public health agencies also are in this game, offering regulatory specifications for targeted groups of indicator microbes, such as EPA water quality specifications or FDA zero tolerance of pathogens in ready-to-eat foods. Here we argue that microbiomes can be a valuable tool to help choose and validate the best indicator(s) that may be used under a variety of circumstances.

The microbial indicator premise is that the presence or population size of a single indicator microbe or groups of microbes has some respective correlation with the presence of or population of either undesirable microbes (spoilers or pathogens) or desirable microbes (starter cultures or probiotics). On the public health side, indicator presence or populations can be used to define risk of an adverse public health outcome. Indicators also have utility in assessing process effectiveness, such as presence or populations of spore formers after a heat process. Sanitation efficacy can be judged by the amount of an appropriate indicator, such as residual ATP on a surface or presence of Listeria spp. in a floor drain. Culture houses (i.e., starter cultures, probiotics) and companies that manufacture fermented foods can do routine QC testing for the amount of metabolic byproducts (CO2 or acid development) as an indicator of microbial activity and also measure culture population levels.

Our customers frequently ask us, “Which is the best indicator for my ingredients, process, and products?”  Of course they are looking for a very simple answer but the reality is, we must know many details about the ingredients, product, process, and intended use before we can offer a best guess. Clearly best guesses, even by esteemed experts, can lead to inappropriate indicator choices. At worse, standard industry practice informed by years of use may not offer appropriate scientific validation of the use of chosen indicators.

Another customer question we frequently hear: “My product is not reaching intended shelf life, but indicator counts show it should be fine. What is causing product performance failure?”  In this scenario, the chosen indicator(s) may not allow for cultivation of the offending microbe, resulting in an “all clear” test result. Each indicator test (see Table I) will grow only the microbes able to multiply on the selected medium, at the selected incubation temperature, for the selected incubation time, and under the selected incubation atmosphere.1 Differences in media brand, or even slight deviations in media nutrition, media selective agents, temperature, time or atmosphere will have dramatic implications on what ultimately grows. What is telling is that there are many microbes in the sample that may not be cultivable at all, yet they may contribute to product performance failures. Wouldn’t it be nice if you could run one test and get a good snapshot of the all microbiota present in the specimen?

A further issue is that some microbes, which  may be perfectly able to grow under a certain set of conditions, might be outgrown by other competitors. Therefore, they may not contribute to the countable population. If they are found as a minor population, the odds of identifying them from a plate count are remote. Such microbes may in fact contribute to product failure and yet never be detected by an indicator assay.

An example of well-publicized historical misuse of indicators is the application of fecal coliform counts as indicators of fecal contamination of some dry leafy food products, such as tea leaves. For decades, periodic popular press exposé articles about food service iced tea with high fecal coliform counts have appeared in the news. The respective author’s dramatic conclusion is that such teas are contaminated with feces and a threat to public health. However, in reality, when the bacteria associated with these high counts were actually identified, they were determined to be natural constituents of dry tea leaves and had no association with animal feces.2

An unconventional hypothetical indicator example seems worthy here. If you are a manufacturer of a dried ready-to-eat product or ingredient and your hazard analysis has identified Salmonella as a reasonably foreseeable environmental hazard, most will choose coliform, fecal coliform, E. coli, and/or Enterobacteriaceae counts as potential indicators. We’re sure this sounds familiar so you’re feeling pretty good about now—well, read on, please. What may be less obvious is the potential usefulness of a yeast and mold count for this purpose, because low-level moisture intrusion may lead to growth of these fungal groups and also may lead to enhanced survival/growth of Salmonella. Therefore, one may find the best indicator by looking for an indicator of moisture control problems rather than an indicator of potential fecal contamination.

Finally, verification screening of all raw materials, ingredients, processes, environmental locations, and products using traditional microbiology tests can quickly become expensive if you are looking at all the potential indicators shown in the table. By first running a single microbiome on a specimen, the predominant microbes and their relative proportional populations will be determined. This knowledge can be used to develop appropriate targeted verification screening for indicators that you now know are relevant to the specimen. Furthermore, the impact of changes in suppliers, processes, or product formulation can be measured using microbiomes to again gain confidence that appropriate indicators are still being used.

We hope this installment of Food Genomics triggers the reader to rethink the indicators they are using and ask the following questions:

  • Why are we using our chosen indicators?
  • Are our indicators telling us what we really need to know?
  • Are there better indicators for my supplier verification program?
  • Are there better indicators for my process verification program?
  • Are there better indicators for my environmental monitoring program?
  • Are there better indicators that more accurately predict product shelf life?
Indicator Test Uses Microbiome
Aerobic Mesophilic Plate Count Estimate population of microbes able to grow at 35°C with air. Overall food quality indicator, shelf life/spoilage predictor Names of predominant microbes and relative proportions of each constituting the aerobic mesophilic population
Anaerobic Mesophilic Plate Count Estimate populations of microbes able to grow at 35°C without oxygen. Shelf life/spoilage predictor of vacuum packaged or modified atmosphere packaged foods. Names of predominant microbes and relative populations of each constituting the anaerobic mesophilic population
Standard Plate Count Similar to APC but used for dairy products. Estimate population of microbes able to grow at 30°C with air. Overall milk quality indicator, shelf life/spoilage predictor Names of predominant microbes and relative populations of each constituting the aerobic mesophilic population
Psychrotrophic Plate Count Estimate population of microbes able to grow at refrigerated temperatures (incubation temperature can vary from 5° to 15°C) with air. Shelf life/spoilage predictor Names of predominant microbes and relative populations of each constituting the aerobic psychrotrophic population
Anaerobic Psychrotrophic Plate Count Estimate population of microbes able to grow at refrigerated temperatures without oxygen. Refrigerated shelf life/spoilage predictor of vacuum or modified atmosphere packaged foods Names of predominant microbes and relative proportions of each constituting the anaerobic psychrotrophic population
Aerobic Thermophilic Plate Count Estimate population of bacterial spores able to grow at high storage temperatures (incubation temperature can vary but usually >45°C) in air or survive a thermal process. Indicator of process failure. Spoilage indicator of improperly hot held foods Names of predominant spores and relative proportions of each constituting the aerobic thermophilic population
Aerobic Mesophilic Spore Estimate population of bacterial spores able to grow at 35°C with air. May indicate possible Bacillus cereus risk. Names of predominant spores and relative proportions of each constituting the aerobic mesophilic spore population
Anaerobic Mesophilic Spore Count Estimate population of bacterial spores able to grow at 35°C without oxygen. Potential shelf life/spoilage indicator of vacuum or modified atmosphere packaged foods. May indicate possible Clostridium botulinum risk. Names of predominant spores and relative proportions of each constituting the anaerobic spore population
Aerobic Psychrophilic Spore Count Estimate population of bacterial spores able to grow at refrigeration temperature with air. Spoilage indicator of refrigerated foods Names of predominant spores and relative proportions of each constituting the aerobic psychrotrophic spore population
Anaerobic Psychrophilic Spore Count Estimate population of bacterial spores able to grow at refrigeration temperature without oxygen. Potential shelf life/spoilage indicator of refrigerated vacuum or modified atmosphere packaged foods. May indicate possible nonproteolytic Clostridium botulinum risk Names of predominant spores and relative proportions of each constituting the anaerobic psychrotrophic spore population
Aerobic Thermophilic Spore Count Estimate population of bacterial spores able to grow at high temperature in air. Spoilage indicator of heat processed foods. Names of predominant spores and relative proportions of each constituting the aerobic thermophilic spore population
Anaerobic Thermophilic Spore Count Estimate population of bacterial spores able to grow at high temperature without oxygen. Spoilage indicator of heat processed, vacuum or modified atmosphere packaged foods Names of predominant spores and relative proportions of each constituting the anaerobic thermophilic spore population
 Thermoduric Plate Count  Estimate population of microbes able to survive a pasteurization process. Used as a shelf life/spoilage predictor Names of predominant microbes and relative proportions surviving a thermal process
 Lactic Acid Bacteria Count  Estimate population of bacteria able to produce lactic acid during growth. Indicator of fermentation success or spoilage failure Names of predominant microbes and relative proportions that produce lactic acid
 Proteolytic Plate Count  Estimate population of microorganisms that produce protease enzymes. Indicator of putrefactive spoilage potential Names of predominant microbes and relative proportions that produce proteases
 Lipolytic Plate Count  Estimate population of microorganisms that produce lipase enzymes. Indicator of lipid hydrolytic rancidity spoilage potential Names of predominant microbes and relative proportions that produce lipases
 Saccharolytic Plate Count  Estimate population of microorganisms that produce amylase enzymes. Indicator of starch hydrolysis spoilage potential Names of predominant microbes and relative proportions that produce amylases
Pectinolytic Plate Count Estimate population of microorganisms that produce pectinase enzymes. Indicator of pectin hydrolysis spoilage potential Names of predominant microbes and relative proportions that produce pectinases
Aciduric Plate Count Estimate population of microorganisms able to grow in a high acid/low pH food. Indicator of spoilage potential Names of predominant microbes and relative proportions surviving an a high acid product
Aciduric Flat Sour Sporeformer Count Estimate population of bacterial spores able to tolerate high acid foods and produce acid without gas production. Indicator of high-acid canned food spoilage potential Names of predominant bacterial spores and relative proportions that grow in a high-acid canned food
Thermophilic Flat Sour Spore Former Count Estimate population of bacterial spores able to grow at high temperature and produce acid. Indicator of canned food spoilage potential Names of predominant bacterial spores and relative proportions that grow and produce acid in a canned food
Sulfide Sporeformer Count Estimate populations of bacterial spores that produce sulfur aroma compounds. Indicator of canned food spoilage potential Names of predominant bacterial spores that produce sulfur compounds
 Halophilic Plate Count  Estimate population of microorganisms able to grow at high salt concentrations. Indicator of microbes that can spoil low water activity foods  Names of predominant microbes and relative proportions that grow in a high-salt food
 Osmophilic Plate Count  Estimate population of microorganisms able to grow at high sugar concentrations. Indicator of microbes that can spoil low water activity foods  Names of predominant microbes and relative proportions that grow in a high-sugar food
 Yeast & Mold Count  Estimate population of fungal microbes. Indicator of fermentation success (mold-ripened cheeses) or spoilage potential  Names of predominant fungi and relative proportions in a specimen
 Preservative Resistant Yeast & Mold Count  Estimate population of fungi able to grow or survive in the presence of a food preservative. Indicator of spoilage potential  Names of predominant fungi and relative proportions that grow in the presence of a food preservative
 Coliform Count  Estimate population of bacteria able to ferment lactose at 35°C within 48 hours with gas production. Indictor of sanitation failure or possible presence of fecal pathogens  Names of predominant bacteria and relative proportions constituting the coliform population of a specimen
 Fecal Coliform Count  Estimate population of bacteria able to ferment lactose at 44°C within 48 hours with gas production. Indictor of possible presence of fecal pathogens  Names of predominant bacteria and relative proportions constituting the fecal coliform population of a specimen
 E. coli count  Estimate population of Escherichia coli. Indicator of fecal contamination and possible presence of enteric pathogens  A microbiome is not a useful addition for this species-specific test
 Total Enterobacteriaceae Count  Estimate population of bacteria able to ferment glucose at 35°C within 24 hours. Indictor of sanitation failure or possible presence of fecal pathogens Names of predominant bacteria and relative proportions constituting the Enterobacteriaceae population of a specimen
 Enterococcus Plate Count  Estimate population of enterococci. Indicator of possible fecal contamination  Names of predominant bacteria and relative proportions constituting the enterococci population of a specimen
 Listeria spp.  Estimate of the presence/absence of Listeria species in a food or environmental sample. Indicator of the possible presence of the pathogen Listeria monocytogenes  Names of predominant Listeria species and relative proportions constituting the Listeria population of a specimen
 Relative ATP Concentration  Estimate the amount of adenosine triphosphate in a food or environmental sample. Indicator for the presence of living cells (food or microbial). Used as an indicator of proper sanitation  Names of predominant microorganisms and relative proportions constituting the microbial population of a specimen taken at the same site swabbed for ATP
Table I. Common microbial indicator tests and the use of microbiomes for validation of effectiveness.1



  1. Salfinger, Y, and M.L. Tortorello. (2015). Compendium of Methods for the Microbiological Examination of Foods, 5th Ed. American Public Health Association, Washington, D.C.
  2. Zhao, T., M.R.S. Clavero, M. Doyle, and L.R. Beuchat. (1997). Health relevance of the presence of fecal coliforms in iced tea and leaf tea. J. Food Prot. 60(3):215-218.
Tim Husen, Rollins Technical Services
Bug Bytes

Sanitation Solutions for Pest Problems

By Tim Husen, Ph.D.
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Tim Husen, Rollins Technical Services

It’s no surprise that food manufacturing and processing environments are naturally vulnerable to food safety threats. Food processing environments have all the things a pest needs to thrive: Food, water and shelter. And if poor sanitation is added to the mix, pests can find your food processing plant absolutely irresistible.

An unkempt facility can attract flies, ants, cockroaches and other unwanted common pests such as rodents. All of these common pests could put you or your facility at risk during your next audit.

The good news is pest-related sanitation issues are preventable through proactive and holistic preventive treatment plans. It’s important to establish proper sanitation processes and procedures so that over time, you avoid or reduce the occurrence of pest problems that could cost you major points on an audit and potentially compromise your products.

Many food processing facilities employ integrated pest management (IPM), an approach that helps prevent pest activity before it occurs and uses chemical treatments only as a last resort. The goal with these types of treatments is to give facility managers tools to use in advance of their next audit to stay ahead of pests, to teach employees good practices and to avoid problems before they happen. A good IPM program includes careful documentation of pest issues and the conducive conditions relating to them, as well as any corrective actions taken to resolve them. This documentation is incredibly important not just in solving pest problems, but also in its relevance to FSMA regulations.

When talking to pest management providers, remember that a “one-size fits all” strategy often doesn’t work, so expect your pest control company to recommend a customized plan. Different environments have different “hot spots” (areas where pests typically are present if the conditions are right) and face different pest pressures. However, there are a few key best practices that can be applied to any facility to help protect against pests.

The following guidelines will help to minimize pest activity and prepare for your facility’s next audit.

1. Educate and Enlist Your Employees in the Fight Against Pests

The first step to establishing your sanitation plan is enlisting your staff. One of the strongest building blocks in your defense against pest activity is sanitation. This key component of your IPM plan begins with the vigilance of your employees. Sanitation and pest management aren’t one-and-done tasks. They’re ongoing and you’ll get the best results when the entire staff is on board.

How can they help? Your employees are often the first to notice any potential signs of existing problems, so it’s important to educate them on hot spots where pests could live, what signs they should look for, and what to do if they see a pest issue. Once your employees understand the importance of sanitation, set a zero-tolerance policy for spills, debris and waste. If employees spot a pest, make sure they understand the protocols for documenting its presence. Consider implementing daily, weekly and monthly sanitation routines in addition to an annual deep cleaning.

Finally, enlist your employees to help keep common areas clean, from break rooms to locker rooms. Establish processes to clean up dirty dishes and drink spills, and empty full trash bins immediately. Don’t forget about cleaning the bins themselves! Also, make sure that common refrigerators aren’t filled with past-expiration lunches or snacks. If you’re finding it tough to get employees to participate, most pest management providers will offer a free education program to make employees aware of potential risks and what they can do to help. Sometimes it can help employees to hear from the experts.

2. What’s on the Inside Counts

As the saying goes, what’s on the inside really matters. This is true for the interior sanitation of your processing facility, too. There are a few particularly vulnerable hotspots to be conscious of when putting together your sanitation plan, especially the production floor, the storage areas and the receiving areas.

For obvious reasons, the production floor is one of the most important areas of focus for your sanitation program. Any hygiene issue could directly impact and expose your food products to contamination. Pests love to make their homes in big equipment that is often difficult to access for cleaning. Improper sanitation may lead to bacteria growth on the production line, which poses a major food safety threat. Create a schedule so that all equipment and machinery are sanitized regularly, and don’t forget about paying extra attention to those out-of-sight areas.

Drain flies and other pests live around drains and drain lids. Both should be scrubbed and sanitized regularly to prevent buildup of grease and other gunk that can attract pests. Organic, professional cleaning solutions are a great option to break down tough stains and grime on floors and around drains. These organic cleaners use naturally occurring enzymes and beneficial bacteria to degrade stains, grime and other organic matter build up, which helps reduce the likelihood of drain flies and other pests.

Storage areas are also prone to attracting pests and the potential bacteria they harbor. These cluttered spaces can get filled with extra boxes and other debris, and are perfect locations for pests to hide. Keep these areas clean and clear of clutter so pests have fewer areas to seek shelter and reproduce.

Cockroaches especially love cardboard boxes, so take those to recycling facilities regularly. Remove any equipment that is not being used. If you have re-sealable containers, clean out all the containers before placing new products inside. All containers should be tightly sealed and kept six inches off the floor and 18 inches away from walls. You can also affix mops and other types of cleaning equipment to the wall. Keeping them off the ground will keep them dry and prevent them from sitting in standing water, which is a major hot spot for fly breeding and bacteria build up.

Don’t forget that pests are experts at squeezing under receiving doors and sneaking onto shipments. To prevent unwanted stowaways, ensure your exterior doors form a tight seal when closed and always give delivery trucks and incoming shipments a thorough inspection for pest activity. Pests love to sneak into any opening they can find, so keep building exits, loading docks and other entrances closed as much as possible. Install weather stripping and door sweeps to keep pests out by creating a tight seal around openings. Believe it or not, rats can squeeze through a hole the size of a quarter, mice through a gap the size of a dime, and crawling insect pests through spaces barely noticeable to the human eye. For other cracks and crevices, use weather-resistant sealants to close any openings and consider installing metal mesh for an extra layer of protection against rodents that can gnaw openings to get inside.

3. Don’t Forget the Great Outdoors

To keep your exterior spic and span, create and maintain a regular sanitation schedule for your building’s exterior so it doesn’t become a haven for pests.

Regular pressure washings of sidewalks and walls will knock away any debris or build-up on exterior surfaces and could help remove any bird droppings around the property that could be brought inside by foot traffic. While it seems like a no-brainer, keep dumpsters and recycling collections as far away from facilities as possible, and make sure they are cleaned and sanitized frequently. And like interior cleaning best practices, don’t neglect areas above or out of the line of sight like gutters and rooftop ledges. Sometimes, leaves, standing water and other debris can build up over time, which provides breeding areas and shelter for pests—­especially mosquitoes.

Did you know that flies are not just attracted to food processing facilities because of food smells, but also for their exterior lighting? Flies and other flying insects are attracted to light and may use it for orientation. Mercury-vapor lighting is especially attractive to flies, so consider swapping mercury-vapor lamps next to entryways with sodium-vapor lights or LEDs. And to lure flies away from your building, place your facility’s mercury-vapor lighting at least 100 feet from entrances. It is often important to remember that the best option is always to direct lighting towards a building rather than mount lighting on it.

Good outdoor pest maintenance also includes landscaping. Trim your trees often and keep plants at least 12 inches away from your building. This decreases the chance of pests using vegetation as breeding or nesting grounds and the chances they’ll get access to your facility. Standing water often becomes a breeding site and moisture source that could provide pests like flies, mosquitoes and rodents with water necessary for survival. Remove any standing water around your building to prevent this and remove any reason for those pests to stick around. Look for stagnant water in gutters, ponds, birdbaths, water fountains and any other places that water could sit for more than a week without moving.

These proactive pest management tips will be useful in protecting your building and products from food safety threats. If there are any tasks that require additional help, consider talking to your pest management provider about creating an IPM plan. They will walk through your facility with you to identify any hotspots and suggest potential corrective actions—you’ll be glad you did when it’s time for your next audit.

John Sammon, ParTech
FST Soapbox

Keeping Food Safe using IoT in the Digital Supply Chain

By John Sammon III
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John Sammon, ParTech

Technology advancement continues to mature at a fairly predictable rate in terms of processing speed, size, battery life and perhaps most importantly, costs. Whereas 100 years ago the telephone, followed by the radio, were just being invented, today we are steadily marching toward a 100 gigabyte / second transfer rate. These conditions are what originally launched the Information Age and it now clears a path for 50 billion connected devices in the next three to five years.

To me, “Internet of Things” (IoT) is one of those catch-all phrases that encompasses so many different technologies, value propositions and solution sets. This means that when we discuss IoT, we can be talking about a device in your home or a device used to monitor the stability of a section of the Alaskan pipeline between Coldfoot and Deadhorse. Therefore, we should condense the topic at hand down to cold chain logistics and IoT.

The cold chain is an uninterrupted supply chain we control so temperature is maintained to ensure both quality and safety of food. This includes all segments of food production, transport, warehousing, distribution, handling, preparation and storage.

Environmental conditions are essential in both quality and safety for proper food logistics, and therefore this industry was among the first to proliferate IoT. It began 15 years ago in the “over the road” and “rail” transport space when companies began to use satellite and cellular technologies to track and monitor the status, well-being and health of temperature-controlled cargos. The real-time nature of these solutions and the cloud-based historical records were the foundation of IoT as we understand it today.

Whereas these earlier solutions focused on the segments of supply chain where risks are most high, today IoT technology is implemented from source to destination. Smart devices are showing up all over the supply chain. These independent devices can work independently or collectively to capture and even halt food contamination before it happens. Temperature is essential, but more and more food safety IoT will detect gases, along with other environmental conditions that can predict and accurately report the evidence of pathogens.

But what is driving the IoT adoption? How do these disparate technologies come together in a cohesive way to build solutions that are proficient and economical? And perhaps most importantly, what is next?


Consumer demand for fresher, safer and responsibly sourced foods are driving much of the IoT adoption. More retailers are focusing on customer loyalty and trust as key metrics for success. So whether it is blueberries 12 months out of the year, or whole meal replacements such as a vegetarian lasagna, people want more than low cost; they= want transparency and quality. This demand drives behavior throughout the supply chain.


The technology required to make this happen is ubiquitous and indeed, fascinating. Starting with the sensor technology first, we are seeing more “things” that can detect. In addition, the intelligence embedded in the devices provides accurate performance while preserving battery life, by reporting on exceptions.

The delivery of information has improved with multi- modes using cellular, Wi-Fi, Bluetooth, RFID, and various other scan/read technologies. Wireless is everywhere.

We are also seeing the explosion of APIs in all IoT solution sets. API stands for “Application Programing Interface”. Web APIs are a framework that allows for future functionality within applications. APIs allow the building of HTTP services that are compatible with a broad range of clients (sensors, mobile devices and browsers). This framework sets a standard for how different components of software should interact with one another.

The development and advancement of cloud technology acts as the backbone of all IoT. These central repositories of data (which becomes information) virtually never go down, are endlessly scalable and elastic without which there would be no internet.

Lastly, we have mobility. Mobility can be wearable or a handheld. The app plays a critical role in the proliferation of IoT. Smart devices are essential to solutions when stakeholders are everywhere throughout the supply chain. The application to see real-time information and track progress lives in Google Play and iTunes stores. Mobility coupled with wireless allows for real-time alerting and alarming directly to responsible stakeholders.

What’s Next

I believe that we will begin to see more “Solutions of Solutions”: Systems created out of many different technologies that when brought together generate widespread value.

As an example, global sourcing coupled with sophisticated, informed consumers has yielded technologies such as IBM’s Blockchain, which is designed for a single version of truth about a product from source to origin. Similar to Bitcoin, this technology allows for a decentralized exchange of valuable information whereby all participants benefit in the sharing of data.

The largest U.S.-based retailers are investing millions of dollars in these traceability technologies, not just to protect their brands, but because consumers expect transparency, demand quality and seek sustainability. The laws of economics (supply and demand) dictate that those that source these foods, such as meats, fishes, fruits and vegetables, must then also invest in technologies that share data.

However, because the Blockchain concept is designed such that no one single entity controls enterprise-wide information, the entire supply chain becomes transparent, which yields trust that everyone owns access and visibility. Each source of data in the chain is interdependent upon other sources, therefore all are compelled to behave rationally and responsibly. At its foundation, Blockchain is a database of information from (n) sources whereby a decentralized structure yields shared values for all stakeholders.

Jennifer van de Ligt, Food Protection and Defense Institute, University of Minnesota
FST Soapbox

Hot Topics in Intentional Adulteration, Food Fraud and Food Crime

By Jennifer van de Ligt, Ph.D.
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Jennifer van de Ligt, Food Protection and Defense Institute, University of Minnesota

The Food Protection and Defense Institute held its annual Food Defense Conference on May 3 and 4. This unique conference focused on food fraud detection, food crime, intentional adulteration FSMA updates, advocacy for food protection and defense, and big data and how to use it. The event garnered active discussion and collaboration among speakers and attendees representing six international government agencies, 11 domestic federal, state and local government agencies, 33 private food sector partners, and many academic partners.

The keynote address by Andy Morling, head of the UK National Food Crime Unit, led off the conference with discussion on food fraud and food crime. He profiled the tremendous work being taken to bridge the food regulatory and criminal systems to curb food crime in the UK. The UK response to food crime is guided by the 4P approach: Prevent, Protect, Prepare and Pursue. The Protect (reducing vulnerabilities) and Prepare (investing in capacity and capability building) components of the 4P approach embody key concepts of successful food defense plans.

Economically Motivated Adulteration and Food Fraud will be discussed at the Food Safety Supply Chain Conference | June 5–6, 2017 | Learn moreThe food crime discussion was followed by insight on food fraud detection in the European Union from Franz Ulberth, Ph.D., head of the Fraud Detection and Prevention Unit at the European Commission’s Joint Research Centre. This included results from Operation Opson in which Europol and INTERPOL coordinated with 61 countries. The goal of Operation Opson is to protect public health and safety through international cooperation to combat counterfeit and substandard food and drink. In Operation Opson VI, more than 9,800 tons, 26.4 million liters, and 13 million units/items of potentially hazardous food worth an estimated €230 million were seized between December 2016 and March 2017. The scope of products seized spans the range of all foods and beverages such as mineral water, alcohol, olive oil, seasonings, seafood and caviar, and includes both every day and luxury items. In addition, Dr. Ulberth outlined key characteristics of food fraud, the most common foods susceptible to fraud, and types of vulnerability and mitigation in the food fraud area.

Defense against food fraud through the use of genomics and ingredient supply chain understanding were presented by Robert Hanner of the Biodiversity Institute of Ontario at the University of Guelph and Cheryl Deem, executive director of the American Spice Trade Association, respectively. Genomics have been particularly helpful in identifying and quantifying the prevalence of seafood fraud. The most common seafood fraud is when one species of seafood is marketed and sold as a different species. The primary driver for this deception is to promote lower quality or illegal seafood species as a species of higher quality, premium location, or simply allowed in commerce. The genomics technique has been used successfully in the food fraud arena. It identified puffer fish, which produces a toxin, being deceptively marketed as monkfish. The accurate identification allowed public health officials to confirm that consumer illnesses accompanying this deception were caused by puffer fish toxin consumption. Similar to analytical techniques, supply chain understanding can help protect food manufacturers and consumers from food fraud. For example, major spice providers worked together to develop a guide to identification and prevention of adulteration because spices are often a target for adulteration. One aspect of the guide is a decision tree used to protect against supply chain vulnerabilities.

The conference also featured the authors of the FSMA Mitigation Strategies to Protect Against Intentional Adulteration Rule. They are part of the Food Defense and Emergency Coordination Staff at CFSAN. The author of the Intentional Adulteration rule discussed updated information on FDA efforts to develop both guidance for industry and training materials to support implementation of the regulation. In addition, they provided insight on the use of key activity types as an appropriate method for vulnerability assessments. For inspection and compliance, the authors indicated a two-step approach will be taken. The two-step approach will include a quick check at all registered facilities that is followed by a food defense inspection at a limited number of prioritized facilities. Inspection will occur in a tiered and staged approach after compliance dates pass. The FDA presentation at the Food Defense Conference was the launch of the new information campaign with additional detail and insight on guidance, training, inspection and vulnerability assessment approaches.

The knowledge and passion of the professionals gathered at the conference allowed appreciation of and connection between the incredible global efforts dedicated to improving defense and protection of the food system. The future of food defense to protect and create a resilient food system will be assured by continued efforts and expertise shared like those at this conference.

Judy Black, Rentokil
FST Soapbox

What Is the Internet of Things and How Does It Impact Food Safety?

By Judy Black
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Judy Black, Rentokil

The Internet of Things (IoT) is a category of objects or devices—things—equipped with electronics and online capabilities that let them communicate data to computers and other networked devices. In the home, this may take the form of smart locks that can be controlled via the homeowner’s work computer or a Wi-Fi-enabled thermostat, allowing the user to monitor and control the temperature of their home from a smartphone app. While the in-home applications of IoT may get more consumer attention, many of its most interesting applications are happening in the business and industrial world.

You may have seen TV ads from General Electric or IBM promoting their work on networks of connected trains, semi-trucks and warehouses that communicate precise tracking of cargo and packages in shipping. As more industries begin to see how big data and instant communication can improve their efficiency, IoT is quickly catching on in many fields, including the food business. Indeed, those involved in shipping raw materials or finished food products are likely familiar with the IoT’s impact on the supply chain. The rest of the food industry isn’t far behind, as more than 57% of respondents to a recent survey of food professionals conducted by Quocirca indicated IoT has already impacted their organization.

Judy Black will be hosting a webinar on the applications of IoT in the food supply chain on Wednesday, May 24 at 1 pm ET/10 am PT. Register now

From farm to fork, connected devices are collecting data and sharing it through centralized networks that help the industry better manage supplies and finished food products. Sensors in the ground can measure moisture levels and regulate irrigation systems to ensure no crops receive too much or too little water and keep farmers informed on soil conditions in real time. At the warehouse level, incoming and outgoing food products can be tagged and scanned to automatically track data like the farm of origin or any other information required by law. In any phase of the supply chain, IoT may take the form of smart pest control devices specifying when they need service or when something has been captured in a trap.

We’re still in the early stages of IoT’s deployment throughout the food industry, but its benefits are already showing up in better food safety practices and a more efficient supply chain, both of which help to cut down on waste and reduce risk. This network of connected devices and centralized hubs for data analysis will only grow in importance as the technology develops and drives innovation in how we can use this data to improve every aspect of the business.

Randy Fields, Repositrak
FST Soapbox

Food Safety Technology Disrupters

By Randy Fields
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Randy Fields, Repositrak

We’ve all heard about the latest disrupters in the retail supply chain, like the Internet of Things, wearable computers, cognitive analytics, machine learning and even the new value chain in which these technologies intercede to provide a better and more accurate shopping experience for consumers. There are also developments like digital fabrication that interacts with both the consumer and appliances to improve the way product gets to the consumer from the point of production.

Technology disrupters can fundamentally change supply chains, destroying existing ones and creating new ones. Other disruptions can be caused by not a single technology but by several new and existing technologies that come together in innovative ways. Smart retailers and their trading partners are working to judge the impact of these technology disrupters before or at least as they occur. They need to be more proactive by investing in key areas of strategy, culture and partnership.

A company’s supply chain can be the weakest link in its food safety program. Learn how to mitigate these risks at the Food Safety Supply Chain conference | June 5-6, 2017

Many of the technology disrupters in food safety are based on the growing ability to apply analytics, including machine learning, to drive a better understanding of and increase the personalized relationships with the consumer, and to glean insight from all the data being collected. Knowing exactly what information shoppers require to feel safe with the products they are buying from you can only help build and maintain a great reputation. Further, analytics help companies predict and address the weakest links on the production floor and in their own extended supply chain to keep those customers free from potentially deadly pathogens.

Cloud computing for the delivery of IT and business processes as digital services is transforming the food safety world through the unprecedented speed and agility it enables for mobile and social engagement. Telling your customers that a recalled product could cause an illness used to require lots of phone calls or even snail mail, but now technologies in the cloud facilitate almost instantaneous messaging of the warning to whole or subsets of a population. This is just one of the ways that everyone from shoppers to business people are changing the way they interact with each other and the way we all do business due to the cloud.

Security in general and cybersecurity specifically are disrupters for companies concerned with food safety, because they can fall prey to sophisticated hackers and other crooks that try to ransom a business’ reputation in the digital world. Think how important it is to protect your own information as well as that of your consumers and customers for payment details and personal data. Now add health data to the mix and you’ll recognize the critical nature of the issue.

All of these technology disrupters have the potential to seriously impair your food safety plans and procedures, but they can also help you better deploy resources to address individual food safety emergencies and ongoing issues. Knowing the impact of the disruption is the first step in addressing it; then you need to develop a plan that helps you take advantage of the positive sides of the disruption and eliminate the negative ones.

Deirdre Schlunegger, CEO of STOP Foodborne Illness
Food Safety Culture Club

How Do We Incentivize Behavior Change?

By Deirdre Schlunegger
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Deirdre Schlunegger, CEO of STOP Foodborne Illness

In March, I presented and participated in a session regarding produce safety at The Global Food Safety Conference in Houston. In April, I was the keynote speaker at the BRC conference in Orlando, Florida. I asked: What incentivizes the human spirit and how do we draw on people’s creativity and their ability to have empathy and to solve problems?  Which interventions are more or less likely to stimulate one’s ability to care about food safety as it relates to human beings? Knowledge alone seldom changes behavior. The imagination benefits from stimulation—for example, listening to personal stories. For change to happen, there must be an emotional connection to the idea of achievable outcomes.

This past year we spoke at a large food company. During a pre-call to discuss what the presentation might look like, one man said that nearly 20 years ago, he heard Nancy Donley speak about her son Alex, who died at the age of six from a foodborne illness. He said since that time, he has never looked at food safety the same way, and he takes every single infraction dealing with food safety as a possible consequence for someone’s life. A rational understanding of what a better outcome might look like will often involve a deeper understanding and a connection with an issue and with the individuals related to that issue. Change is difficult. We often don’t learn until we risk collapse or fail. In a moment of crisis, we are presented with a unique opportunity for change. This idea could stand to be finely calibrated, as there are moments that are too painful to activate learning as one struggles with a deep sense of hopelessness, and there are moments when change lies outside the realm of possibilities. An analytic perspective without access to emotional content is unlikely to provide the conditions for change, but a link between the head and the heart may initiate transformation.

I met Will Daniels, formerly of Earthbound Farms after an emotional presentation he made at a conference. He spoke about a young boy who died from the spinach outbreak and he referred to his children of nearly the same age. He also presented the sequence of events that led to and followed the outbreak in a very factual and logical way. This link between his head and his heart delivered a presentation that was impactful, emotional, factual and sincere. A cold analysis of a problem is seldom sufficient, nor is the condition of people when they are stuck in an overwhelming emotional state. The challenge is to find middle ground and put together thinking and feeling in a context where a coherent narrative will be created. For individuals to change their behavior, we must influence not only their environment, but their hearts and their minds. What we do know about change and people’s readiness to change is that it has much to do with timing and ripeness. The crucial question is whether issues are close enough to the surface to break into the public discourse or to have an impact on a system. As a protective mechanism, people resist the pain of engagement and hold onto old assumptions, often adopting a deluded narrative. People may find that blaming others, scapegoating, externalizing the other party, denying the problem, jumping to conclusions, or launching a distracting issue might restore stability and feel less stressful than facing and taking responsibility for a complex challenge.

We often see change in companies and their policies after they have experienced an outbreak, not before. Over the years we have seen this with several companies whose confidence was high prior to an outbreak, as they had never had a problem before and felt as if they were immune. The challenge is to allow for conditions in that there is sufficient pressure to change but there is also a safety net in place. There is a real tension between the pressure to change and the conditions that allow for necessary creativity, flexibility and imagination to get us through a crisis.   Businesses that are transparent in their admittance to a problem often are better able to create change in a safe environment. In other words, “yes, we have a problem and what are we going to do to change course?” Crisis isn’t necessary but in reality, catastrophic events often precede modifications in policy and practice. Creating a head/heart connection during planning and training may deliver a sense of urgency to help individuals remember “the why” behind food safety.

Until we prepare for a future with a sense of urgency and commitment and fully integrate “the why behind food safety”, we will merely repeat errors of the past. It takes courage and true leadership to carry out a vision, a future that doesn’t deny or divorce itself from the past but uses it in such a way that opens the door to progress. We have improved our narratives and are better at risk analysis and detection, and I believe we will continue to improve.