We’ve all seen the vague warnings on food labels, such as “May contain tree nuts” or “This product was made in facility that also processes dairy.” At the Food Safety Consortium in October, Steven Gendel, principal of Gendel Food Safety and former FDA Food Allergen Coordinator, offered guidance on when and how these advisory—also known as precautionary—labels should be used by food companies. In his presentation “Allergen Advisory Labeling,” Gendel made clear that these statements are not regulatory requirements and are not to be used for a company’s benefit (i.e, to shield the company from liability). They are for consumers and should be used only to protect consumers in situations where there is a potential risk of cross contamination that cannot be controlled through regulated cross contamination efforts and may cross the threshold of safe levels for allergic consumers.
Steven Gendel
When to Use Allergen Advisory Labels
Advisory labels are to be used after a company has taken all necessary steps to eliminate allergen cross contamination and ensure the absence of allergens, and is unable to prevent the risk of cross contamination. “Companies should have a written justification for using an advisory label statement,” said Gendel.
How to Calibrate Risk
The risk to consumers with allergies is based on a combination of how much of the allergen is present and how much of the product is likely to be consumed. This means that risk should be based on how much of the product the consumer is likely to consume, not the labeled serving size. Take, for example, a small bag of chips that includes nutritional information for two servings per bag. If the consumer is more likely to eat the entire bag in one sitting, the allergen dose should be based on the exposure from one full bag of chips. “The dose can justify use of an allergen advisory label,” said Gendel. (For guidance on dose, the United Nations Food and Agriculture Organization (FAO) has established allergen threshold levels.)
It is also important to note that precautionary or advisory labels are for potential cross contamination risks only. “There is no minimum dose for an ingredient,” said Gendel. “If an allergen is an actual ingredient in the product, it must be on the ingredient label.”
Across the food and beverage industry, organizations are undertaking a wide variety of data-oriented technology initiatives. There are a host of reasons for the trend, and indeed the convergence of multiple factors is likely behind the growing urgency for digitization within many food and beverage brands, manufacturers and supplier organizations. To be sure, ongoing supply chain instability over the last three or more years has put a focus on supply chain resilience and the need for more nimble and flexible supply networks. A dynamic and ever-changing global regulatory landscape is driving compliance and reporting requirements that are increasingly difficult to meet without a solid digital strategy in place. ESG initiatives are driving the need for increased visibility into global supply chains. Evolving consumer preferences create pressures on R&D organizations for continued product innovation, all of which needs to take place within acceptable safety, quality and risk management parameters. And of course, hovering over all of this is a tight (and increasingly costly) labor market, putting increased focus on opportunities for automation and increased efficiently.
Alongside these macro-level global trends, technology itself is moving forward at a rapid pace. The global food and beverage value chain has become more interconnected than ever before, with massive amounts of information moving around the world at remarkable speed. And of course, no discussion of technology is complete without a mention of artificial intelligence (AI). While by no means a new idea—many mature AI-based technologies have existed within the industry for years—AI is evolving quickly. Generative AI technologies, hardly known prior to 2023, are now appearing across the technology landscape, and dominating discussions around technology investment and strategy.
Confronted with all of this, food and beverage industry leaders could be forgiven for feeling a bit overwhelmed. Not only is more information (some valuable, some less so) available than ever before, but a profusion of technology solutions are vying for attention, nearly all promising new levels of insight and productivity. The landscape is complex, but there are a few basic steps that teams can take to help ensure that any potential technology investments are pointed in the right direction and are set up for long term success. Let’s examine five basic, but important steps that can help guide digitization efforts to a strong outcome.
1. Starting with the end in mind. The objective of a technology implementation should never be to implement a platform. Usually, technology investments start with a business problem that needs to be solved. For food safety teams, this can encompass a range of possibilities, from a desire to reduce error and gain efficiencies in processes, to a need for better real-time monitoring of processes already in place, to a desire to decrease global risk exposure in an increasingly diverse supplier environment. Whatever the situation, teams can substantially de-risk technology investments by being crystal clear on the business objectives (not simply the implementation goals) of a given initiative. Clearly defining a “north star” in terms of expected business outcomes, and revisiting those goals often, can help keep projects focused, and avoid costly missteps and poor prioritization decisions along the way.
2. Defining stakeholders. Though seemingly obvious, it can be surprisingly easy for teams to launch an initiative without a clear view of impacted stakeholders. Typically, a given technology solution will have relatively well-understood functional owners within an organization. But it’s equally important to understand downstream groups that may have to interact with the solution or its outputs. Direct users, too, are a stakeholder community that can easily be overlooked. A solution that does its job on paper but doesn’t align with the working conditions of an end-user community is going to run into challenges. External stakeholders may also need to be considered, as suppliers, customers, contract manufacturers and other entities can all become obstacles to program success if their buy-in hasn’t been considered early in the process.
3. Supplementing (vs. replacing) human intelligence. With all the buzz around AI, it’s easy to get excited about the longer-term possibilities of the technology. And that’s appropriate – AI has already had notable effects on industry technologies and will continue to do so in the years to come. But it’s equally important to consider the current state of generative AI solutions, and be realistic about the limitations and risks of the technology as it exists today. A useful framework for this approach can be to think in terms of how AI can help supplement, even maximize, the intelligence and expertise of human users. Can it consolidate data that would be cumbersome to organize and collate? Can it scan information and flag likely priorities for further investigation?
In the high-stakes environment of food safety and quality, the overlay of hard-earned human knowledge and awareness is going to remain necessary for a long time to come. At the same time, AI-based solutions are already present in the space, and those who use them wisely may very well realize a significant market advantage over those who shy away entirely.
4. Getting real about data quality. Whether the discussion is about AI, data insights, analytics, compliance reporting or automation, most technologies run on data. Put another way, most technologies aren’t any better than the data they consume. The ancient saying, “garbage in, garbage out” remains depressingly current, many decades after the dawn of computing. As a result, it’s important to take a hard look at the quality, completeness, consistency and structure of the information that a potential technology solution will need to access in order to deliver on its promise. On the positive side, qualified technology providers should be able to provide assistance and clear guidance through the data side of any implementation, and in an increasingly networked world, providers may even be able to come to the table with useful industry data and data management practices that make this part of the digitization journey easier and faster. But it’s important not to skip this step; many are the solutions that never lived up to their potential because the data they needed to consume wasn’t workable.
5. Lastly, as initiatives come together, it’s important to loop back to the original business objectives that were clarified in the first step. Have those objectives been met and, crucially, can that be measured? If it can, the project has likely succeeded, and is positioned to yield insights toward the next step in the technology journey.
The good news is that as digitization continues across the food and beverage industry, it creates a greater opportunity for brands, manufacturers and suppliers to move away from the antiquated model of static, linear supply chains, and toward a more interconnected future based both on shared data and shared values. Explore the world’s largest network of F&B brands and suppliers at TraceGains Gather™, and learn more about the growing community of committed safety professionals worldwide.
High Pressure Processing (HPP), also known as high pressure pascalization or cold pasteurization, is a nonthermal (5ºC – 20ºC) food and beverage preservation method that reduces the risk of pathogen contamination and achieves an increased shelf life while maintaining the optimum attributes of fresh products.
It is based on the use of high isostatic pressure transmitted by water of up to 6,000 bar /600MPa /87,000 psi, held for a few minutes. This pressure is transmitted uniformly and instantaneously throughout the product, therefore achieving an effect equivalent to pasteurization, without the use of heat. A highly versatile technology, HPP can be applied to a wide range of foods.
As a post-packaging process, HPP requires the loading of packaged products into baskets, which is traditionally a manual process. After loading and processing, the baskets then exit through an outfeed conveyor, where then again, the packaged product needs to be manually retrieved.
This manual batch process has become a challenge for many processors operating HPP machines due to the difficulty of sourcing labor.
Streamlining Operations with HPP Automation
Hiperbaric Automation Systems provide operational efficiencies and substantial labor reduction, while increasing productivity and providing strict traceability.
An HPP automation line consists of specialized software and hardware that work together to automate key parts of the HPP treatment process:
Product Loading/Unloading: Automated systems use conveyors, robots and tilting stations to move product in and out of HPP vessels, avoiding the ergonomic strains and throughput bottlenecks of manual loading.
Material Handling Equipment: Material handling is known to be tedious and labor-intensive. Companies can optimize production, improve efficiency and promote operator safety by using custom carriers, carrier carts, elevators, turntables, tote-dumpers, pre-feeders and dryers.
Minute RFID & Data Matrix: RFID tags and Data Matrix codes placed on the HPP baskets can help manufacturers track inventory, automate setup, and provide strict traceability and reliability, ensuring that all products are processed.
Why HPP Automation?
Automating the HPP process offers many advantages including increased productivity, cost savings, traceability and operator safety.
Improved Efficiency & Throughput. Without automation, HPP processors struggle to maximize machine runtime. Manual loading/unloading and basket reconfiguration make it hard to start cycles quickly. This downtime curtails throughput. HPP automation helps maximize production productivity by increasing throughput, production line speed and efficiency.
Reduced Labor Requirements. Manual HPP requires extensive labor to keep the machine constantly loaded and running. An automated system can cut labor requirements by more than half. With machines doing the repetitive, heavy lifting, staff can be redeployed to more value-adding tasks.
Prevent Handling Errors. Manual loading/unloading leaves room for human error. Operators may improperly load products. Automation standardizes these processes and minimizes direct handling to prevent human error. Automated data capture also gives full traceability for quality assurance. Ultimately, automation can provide strict traceability and reliability ensuring that all products are processed correctly.
Improved Workplace Safety. Repetitive activities like loading heavy baskets subject workers to ergonomic strains and injury over time. By reducing direct human-machine interaction, automation protects worker health and safety. The facility is a more attractive workplace to retain talent.
Case Study: Evolution Fresh Advances HPP with Automation
Evolution Fresh, a Bolthouse Farms subsidiary, is a premier cold-pressed juice company. The company partnered with Hiperbaric, a high pressure processing equipment manufacturer, to produce juices with fresh quality, clean label and extended shelf life.
Bolthouse Farms acquired Evolution Fresh from Starbucks in May 2022, expanding its beverage offerings from “nutrient-dense, plant-powered juices and smoothies to include a full lineup of primarily organic cold-pressed, premium juices,” according to Bolthouse Farms.
The company is using HPP to keep its juice safe by inactivating foodborne pathogens. Since it is a non-thermal process, it also helps protect the nutrients and delicious, vibrant taste of the premium quality, cold-pressed juices.
The HPP process enables shelf life expansion from three to five days to 55+ days, without preservatives, allowing expanded distribution to grocery channels.
With manual HPP, the company saw multiple stress injuries each year due to lifting and repetitive motion. By moving to automation, the company reduced its reliance on manual labor and made the processes more ergonomic. They eliminated 16,000 lbs. of lifting per day per person. Automation also helped with social distancing requirements due to COVID-19, allowing employees to spread out. Eliminating waste from triple handling and staging also enabled a continuous system rather than a batch process.
Automating the HPP process through an automated solution has enabled Evolution Fresh to increase efficiencies, reduce costs and drive revenue:
Post-HPP automation equipment includes a fully automated robotic arm that empties baskets and robots that assist in sorting and placing bottles upright. Today, Evolution Fresh uses nine employees on the processing line per shift compared to about 19 previously, a more than 50% reduction.
The Future of HPP Automation
The next step in automation will incorporate big data and analytics to create models for predictive maintenance and auto diagnosis. Computing advances and apps will allow real-time control over the automation process. Lastly, augmented reality will enable remote assistance and mixed-reality learning experiences.
Automation for HPP technology addresses many of today’s production challenges by increasing production line speed and efficiency, improving safety, reducing labor costs and injuries, and delivering accountability.
Everyone understands the importance of a robust food safety program. It should ensure the safety of the product and environment, backed by solid, traceable data. The food industry is vast, stretching from the farm all the way to our plates, and includes a diverse array of foods and drinks. Different segments of this industry have specific needs, whether it’s unique spoilage tests or specialized predictions based on distinct data. Unfortunately, current services haven’t delivered a trustworthy solution for these needs.
Rodrigo Malig is the Chief Product Officer at TAAG Genetics. He oversees both the artificial intelligence and molecular diagnostic teams. In this column, Rodrigo discusses the crucial roles of AI and molecular testing in crafting a reliable, tailored solution for food safety.
What are common deficiencies in current food safety and quality programs?
Malig: Common shortcomings in Food Safety and Quality programs (and frustrations for hardworking FSQA professionals) include:
Lack of Customization: Many programs don’t adapt or customize to specific industry needs.
Routine Sampling Issues: Environmental sampling is often random, lacking intelligent risk-based criteria. There’s also an insufficient adaptive process after each sampling cycle.
Relying on paper files makes keeping track of data, trending it and analyzing it more difficult and time consuming.
Testing Targets: The targets for environmental and finished product testing are often insufficient. For instance, industries need specific tests for spoilage microorganisms, but many don’t have access to these tests and rely instead on general aerobic plate counts, and yeast and mold.
LIMS (Laboratory Information Management System) Limitations: These systems often don’t offer accurate digitized mapping, customization or ability to adapt, leading them to inaccurately represent a facility or its changing needs.
Outdated Methods: Some programs still rely on outdated technologies and methods. Let’s take plate counts for example. There’s a focus on mere quantitative results without the specificity of what those organisms are. This prevents facilities from taking precise corrective and preventive actions. Additionally, we all know plate counts can be time consuming with long incubation times, have limited sensitivity, lack genetic information, require manual labor (thereby creating additional risk for contamination) and increase overall costs. It is essential to determine when plate counts need additional support or substitution, such as with PCR (Polymerase Chain Reaction).
Comparison to FDA Standards: Many confirmation methods are inferior compared to the FDA’s Whole Genome Sequencing.
PCR Kit Issues: When using PCR, many kits test for only a single microorganism. This limitation requires multiple tests to be run, leading to increased turnaround times and costs.
Traceability Concerns: A significant deficiency is the lack of traceability in many programs, requiring additional documentation to be performed on paper.
Incomplete data and analysis: Antiquated data management systems result in insufficient data collection and digitization. Many in the industry still manually write on paper or use Excel spreadsheets, which makes keeping track of data, trending it and analyzing it more difficult and time consuming.
Reactive and not predictive: Because of the deficiencies detailed above, food safety programs become reactive and insufficient to address risk.
How can we improve current food safety and quality programs?
Malig: An improved food safety and quality program must become predictive (and not reactive), by embracing and implementing technology featuring customization, molecular testing and AI. Below is a basic checklist for food companies to follow:
An ideal food safety and quality program should be digital, implement artificial intelligence and molecular testing, be comprehensive, and most importantly be simple and mobile!
Customized Software & Testing: Utilize software and tests tailored to your unique requirements.
Advanced Environmental Sampling: Embrace sampling that’s customized, risk-based, predictive and adaptive. Employ digitization and AI to efficiently map, record, analyze and predict sampling schemes. This system should also adapt after each cycle and accommodate changes in the environment, equipment and processes.
Molecular Testing: Polymerase Chain Reaction (PCR) testing is a molecular biology technique with several advantages, including:
Sensitivity: PCR is highly sensitive and can detect very small amounts of genetic material (DNA or RNA) in a sample. This makes it effective for detection even when the pathogen is present in low concentrations.
Specificity: PCR is highly specific, meaning it can accurately identify and differentiate between different microorganisms or genetic variants. This specificity reduces the likelihood of false-positive results.
Speed: PCR can provide results relatively quickly, often within a few hours, depending on the type of PCR used (e.g., real-time PCR or RT-PCR). This rapid turnaround time is crucial for time sensitive decisions in the food industry.
Cost: PCR can be cost efficient, especially with multiplex PCR kits that detect multiple pathogens in a single reaction, which essentially cuts time, labor, use of lab equipment and space, and overall cost.
Industry-Specific Microorganism Testing: Ensure you’re testing for microorganisms relevant to your industry, processes and products. This is especially crucial if your products are susceptible to spoilage by specific microorganisms.
Adaptive LIMS: Your Laboratory Information Management System (LIMS) should be both customizable and adaptive. It should digitally represent your facility with accuracy and adapt to any changes or needs.
Dynamic Microbiological Programs: Move away from reactive and repetitive testing schemes. Most current microbiological programs tend to test the same samples repeatedly. With the help of AI algorithms, we can now implement preventive and risk-based microbiological programs.
This real-life case study illustrates how a Fortune 100 Company implemented the solutions above to improve their food safety and quality program.
In today’s fast-paced world, ensuring food safety and efficiency is crucial for food businesses. Fortunately, technological advancements, including the Internet of Things (IoT), have revolutionized the way the food industry operates. By leveraging IoT, food businesses can drive efficiency, enhance food safety, mitigate risks and boost transparency throughout the supply chain. All food businesses should be embracing IoT innovations to optimize their operations, improve efficiency, maximize safety and drive key performance indicators (KPIs), including consumer satisfaction, loyalty and sales.
The benefits of using IoT in the food industry include:
Enhancing food safety. IoT enables real-time tracking and monitoring of food products throughout the supply chain. With the help of connected sensors and devices, businesses can monitor crucial variables including temperature and humidity to ensure optimal storage conditions. Both companies and consumers benefit from this heightened level of food safety and quality assurance.
Improving supply chain transparency. IoT enhances end-to-end visibility and traceability. By employing sensors and radiofrequency identification (RFID) tags, businesses can track the movement of food products all along the supply chain, from farm to fork. This transparency helps identify the origin of any issues or recalls, significantly reducing the impact on public health. Moreover, it enables quicker and more targeted responses to any potential food safety breaches, mitigating risks, preventing foodborne illness outbreaks and ensuring consumer trust in the food supply chain.
Optimizing shelf life for product inventory. IoT devices collect data on product conditions, such as temperature, humidity and light exposure. This information empowers businesses to optimize inventory management, implement dynamic pricing strategies and reduce waste (and associated costs) by ensuring products are sold or consumed before expiration. By minimizing food waste, companies contribute to sustainability efforts and consumers benefit from fresher and safer products.
Upgrading real-time monitoring and predictive analytics. IoT devices provide real-time data on critical factors, including equipment performance, energy consumption and production processes. Businesses can detect patterns and predict potential issues by leveraging advanced analytics and machine learning algorithms. By identifying risks in advance, companies can proactively address them, preventing downtime and improving overall operational efficiency.
Elevating the customer experience. IoT can also improve the customer experience. Smart shelves equipped with sensors, for example, can offer personalized recommendations, nutritional information and/or recipe suggestions based on customer preferences. Connected devices in restaurants or food delivery services can streamline the ordering process, improve order accuracy and provide real-time status updates, making the customer journey smoother and more convenient.
It’s clear that IoT offers significant benefits for food companies. Following are five important considerations as you investigate these innovative solutions:
Assess your organization’s specific needs. Identify areas of your food business that can benefit from IoT technology. Consider cold chain management, quality control, inventory management and any other aspect of operations or supply chain that can be optimized. Define the specific goals you want to achieve through IoT implementation.
Choose reliable technology. Select IoT devices and solutions that are reliable, scalable and aligned with your business requirements. Prioritize factors such as data security, interoperability, ease of integration and ongoing support. Ensure that the technology you choose meets industry standards and regulations. Work only with trusted tech vendors.
Examine your data management and analytics processes. Develop a robust data management strategy to collect, store and analyze the vast amounts of data that will be generated by the IoT devices. Employ analytics tools to derive actionable insights from the data, and use these insights to make more informed decisions.
Collaborate with the right partners. Explore partnerships with technology providers, industry associations and regulatory bodies to stay updated on emerging standards, best practices and compliance requirements related to IoT technologies in the food industry. Collaborating with experts and industry peers can accelerate your IoT implementation journey.
Prioritize data security. Implement robust security measures to protect your IoT devices and the data they collect. This includes network security, encryption, authentication protocols and regular monitoring for potential vulnerabilities. Safeguarding data privacy and complying with regulations is vital in maintaining trust with customers and partners.
Avoiding IoT-driven technologies in the food industry is no longer an option. These devices have become necessary to drive efficiency, enhance food safety, meet regulatory requirements and consumers’ evolving expectations, and stay competitive. By leveraging IoT solutions, businesses can optimize their processes, improve transparency, reduce waste and provide exceptional customer experiences. However, successful implementation requires a strategic approach, careful planning, ongoing monitoring and continuous improvement. By prioritizing food safety and communication, and identifying areas of greatest need for improvement, the food industry can unlock the full potential of IoT technology and pave the way for a safer future.
Particularly active during summer months when the temperatures are warmer, stinging pests can cause major concerns for your facility operations. Stinging insect populations can grow rapidly if nests are not treated as soon as they are discovered. Hundreds of small, but ferocious pests can disrupt productivity and potentially harm employees with their painful stings.
These stings can sometimes cause more serious health issues including swelling, infections, nausea and/or allergic reactions, so it is important to stay proactive if stinging pests are reported around your facility. Here are some common stinging insects to look out for in and around food processing facilities.
Bees: Most bees rarely sting humans. Stings normally occur when the insects are accidentally contacted by swatting them, grabbing them or finding them in an area unexpectedly. Many bees are considered beneficial and should be safely relocated by a professional when found if they are in an area with people.
Paper Wasp: These pests may at first appear to be yellow jackets with their black bodies and yellow markings. However, they are easily identified by their signature yellow antenna. Preferring to live in dark, void areas, they can be attracted to the dimmer parts of your facility. Paper wasps will sting to protect their colony, releasing toxins that can be harmful to humans and can cause severe allergic reactions.
Hornet: Hornets are some of the more aggressive stinging pests you’ll When perceiving threats, hornets are known to deliver painful stings or even squirt out venom that can sometimes cause temporary blindness to their victim. If you see a hornet’s nest, it is important to stay proactive and contact your pest control provider immediately for treatment and handling.
Yellow Jacket: Known for their signature black bodies and yellow markings, yellow jackets are highly aggressive stinging insects. These pests can cause property damage to wooden surfaces and even drywall. If you see a few adult yellow jackets around your facility, there is likely a nest nearby.
Ants: Some ant species can deliver a painful and sometimes dangerous sting. Fire ants, harvester ants and Asian needle ants for example. These are primarily outdoor ants, but they will come inside at times to look for food and water.
So, how can you help protect your food manufacturing and handling facility—and your employees—against stinging pests? By implementing an Integrated Pest Management (IPM) program.
IPM programs focus on preventive techniques like exclusion, sanitation and maintenance to keep pests where they belong—outside your business. Most food processing facilities have customized IPM programs in place, especially if they undergo regularly third-party food safety audits. These programs are implemented by qualified pest control technicians in collaboration with a facility’s food safety and quality assurance team to help deter pest activity and prevent infestations.
When it comes to stinging pests, there are a variety of techniques that can help keep these pests at bay:
Maintain your property grounds. Beautiful blooms and elaborate landscaping make your property more attractive to employees, potential clients and flying, stinging pests alike. Trimming overgrown branches, keeping plants from touching the exterior of your building and removing excess wood mulch can help limit the presence of stinging pests.
Secure your exterior. Perhaps the most important preventive measure you can take when it comes to helping eliminate pests inside your facility is implementing exclusion tactics. Exclusion refers to techniques that include the repairing, sealing off, and shutting down of any common entry points for pets around your facility. Make sure to inspect your exterior with your pest control provider to determine where you can continue to secure your facility.
Keep it clean. Maintaining a clean facility cannot be overstated when it comes to helping keep any pests at bay. Make sure you clean your facilities daily, wiping down surfaces, removing clutter and emptying trash cans. Exposed trash and food debris can inadvertently attract stinging pests to your facility. Keep the exterior clean also by not allowing materials and old equipment to accumulate.
Train your staff. Investing in a staff training plan that teaches your employees how to spot signs of stinging pests is also an effective way to help prevent an infestation on the front end. Your employees see and hear more than you might know, which makes them invaluable in helping identify pest issues. Most pest control providers offer complimentary staff training, making this tactic cost-effective for your operations. Once your staff knows the types of stinging pests that frequent your facility, persistent hot spots and the process for reporting pest activity, they’ll be able to help you address pest issues quickly and effectively.
In case of a stinging pest infestation, it is important to quickly notify your pest control provider. Keeping detailed records of where they were seen and high activity times of day can assist them in quickly diagnosing the issue and removing the threat. In cases of extreme infestation, more aggressive pest treatments such as fumigation may be necessary. For certain pests, such as honeybees that are highly beneficial to the environment, relocation/removal done by a professional is paramount. If a hive is disturbed through improper removal, it can prompt an aggressive, antagonistic and perhaps medically hazardous response from the hive. Be sure to check local regulations regarding honeybees. Many states have legal restrictions in place protecting these bees.
Now that you understand some of the types of stinging pests you may encounter and ways to help prevent and control a growing population at your facility, don’t forget to review your unique IPM plan with your pest control provider. If you don’t have an IPM program in place or a reliable pest control provider, now’s the time to implement one before it becomes a costly pest issue—or worse, brings harm to your employees and customers. Staying on top of stinging pests can help keep your product protected, employees safe and business running smoothly.
With 37 facilities and close to 500 suppliers, Kellogg works with a large and diverse workforce. Over the years, the company has implemented several strategies to teach and reinforce good food safety practices. As a member of the Alliance to Stop Foodborne Illness, the company works with Stop to share what they have learned with fellow food industry professionals. We spoke with Sherry Brice, Chief Supply Chain Officer and former VP of Global Quality and Food Safety at WK Kellogg Company, and Vanessa Coffman, Ph.D., Alliance Program Director at Stop Foodborne Illness, to share their insights on training, rewards and free tools that can help food companies of all sizes enhance their food safety culture.
What are some of the strategies that Kellogg is using to strengthen its food safety culture?
Sherry Brice
Brice: Some of the things that Kellogg has implemented over the years—and every year we evolve—include a campaign called “Kellogg Food Safety Own It Every Day.” The campaign is about driving engagement at every level of the organization. We have behaviors that we expect of our employees at the frontline leadership level, the executive level and the management level. We provide training on engagement strategies to better articulate food safety culture, including the things they should recognize and how they should recognize them. We also do virtual reality trainings that help to educate our people. After education and engagement, the third pillar is recognition—recognizing and rewarding people around food safety culture.
Is food safety training part of all employee’s onboarding?
Brice: We do have onboarding for new employees. We also do quarterly and annual trainings, because doing it one time is not enough. You have to repeat, repeat, repeat. We have food safety videos that we have launched in partnership with Stop Foodborne Illness that include real life experiences and stories of people who have dealt with foodborne illness. These help team members internalize the training and personalize it, so they are thinking about the impact their actions have on the customers we serve every day. We use one of the videos for onboarding and also leverage them for our annual training and refresh trainings as well.
How did Stop Foodborne Illness get involved with Kellogg and what kind of resources are available for companies?
Vanessa Coffman, Ph.D.
Coffman: Kellogg has been a member of the Alliance to Stop Foodborne Illness since 2021. We rely heavily on Sherry and her team’s insights in multiple work streams, one of which is the ever-growing video series that is posted to our food safety culture toolkit website, and these are all free and publicly available.
We created two customized videos with Kellogg, each featuring one of Stop’s constituent-advocates alongside a Kellogg executive. These remind employees why food safety is so important and emphasize the commitment that Kellogg has made to safe food. We’ve also worked together on gamified learning, leveraging some of the games that Kellogg uses in its training, and those can also be accessed in the toolkit that is free and publicly available.
Since Kellogg joined the Alliance, has that changed your training strategies or your recognition strategies?
Brice: Stop has given us access to their constituents, which really brings to life why food safety is so important at every level of the organization. Engagement with people who have been affected by foodborne illness is crucial to getting to the hearts and minds of employees, and emphasizing the importance what they do every day.
Since joining the Alliance, we have also added virtual reality to our trainings, starting with the most important one which is around sanitation. We created a virtual reality space where new employees—as part of onboarding—put the glasses on and go through our sanitation process. If you do not do the right step, it will not let you go forward. It’s a way to do hands-on training without having to actually be on the line.
The Alliance has been a great partner for Kellogg. It is an investment, but it is money well spent. When you hear the stories of their constituents, you cannot help but think, I never want a situation like that to be on my watch, what can I do to prevent this from happening?
Kellogg is a very large company. How do you ensure this training is happening and that you’re communicating a consistent message throughout the whole organization?
Ready to start improving your food safety culture? Join the Food Safety Culture Design Workshop on October 16, at the 2023 Food Safety Consortium.
Brice: We have a global quality council made up of members from regions around the globe. We all come together on that council to align and make sure we’re all on the same page in terms of what we are going to do to impact the broader organization, and then we disseminate that action out into the regions. This way, we ensure that we have the right ownership, and that everyone is clear on what needs to be done and how we’re going to do it. We also use the council to track and make sure that people are getting access to the videos and completing the training in the time that we have identified.
We created a toolbox tool that is crafted and geared toward Kellogg employees based on the region they’re in, and the council helps to disseminate that and then track that the work is being completed. We also incorporate this into our audit to make sure that people are internalizing the information and getting something out of it.
You mentioned training on engagement strategies, is that through role playing?
Brice: Yes, it really is about how to drive good behaviors, ownership, escalation and empowerment. If you’re a technician and you have to give feedback to a manager, that can really be intimidating, so we want to make sure we’re arming employees with the right tools. We do this in our training by simulating how to have these crucial conversations. If I go into a plant and I’m not following protocol, somebody is going to give me feedback, and I hope that they give it to me in the right way. We want to arm people with the knowledge on how to do that so that they’re comfortable giving that feedback no matter who they are.
Does Kellogg work with its suppliers to help train them as well?
Brice: We do work with our supply base and also our co-manufacturers (co-mans). Our co-mans get a lot of the same training that our plants get. We have an “owner” from the supplier management team that oversees each of the suppliers and that owner manages what training the supplier needs, depending on where that supplier is in their journey. We provide them with the toolbox from Stop, so they can leverage those resources. and we have found that very helpful because if that supplier has a great food safety culture that means we’re going to great materials. Likewise, if our co-mans have a great food safety culture then we feel more comfortable with what they’re producing for us.
In addition to the videos, what are some of the other ways that the Alliance to Stop Foodborne Illness partners with companies?
Coffman: The Alliance was formed in 2018, and we have worked with companies across the food system from farm to fork. We utilize the power of Stop Foodborne Illness constituents and their stories of foodborne Illness. These are people who survived a harrowing experience or the loved ones of those who did not. They will go onsite, take part in town halls, write down their stories and share them on our website, and they have also participated in the videos. We make customized videos for companies like Kellogg, and we’ve been able to leverage that content to create shorter videos that are more generic for the toolkit website.
We also work with companies to develop other materials. As Sherry mentioned, we have some gamified learning. People can download those games and tweak them to their own needs, and some of those have been provided by Kellogg. We’ve also been able to create communication plans based on the nearly 20 Alliance members’ experiences and food safety culture journeys, and we share those plans with the small and medium-sized companies at no cost.
Sherry mentioned recognition of employees, what are good ways to publicly recognize good work in protecting food safety?
Coffman: Like many aspects of food safety culture, it is going to be company dependent. You do want to solicit input from your employees before implementing a rewards program. For example, some people love employee of the month recognition, while others would rather not be publicly recognized. They would prefer a gift card or time off. If you go to our YouTube channel, you can watch some of our past webinars, including one on rewarding and recognition.
Brice: We implemented an “Achievers” platform. Through the platform, we give points to employees and those points can be used to purchase items. We also do on the spot recognition and recognition dinners. It depends on the situation and the person, but “Achievers” is our main recognition platform because we have found that our employees like this. They can trade their points in for a gift card, a T-shirt, a vacuum cleaner—there are many different things on the platform.
It is often said that every company has a food safety culture whether positive or negative, how do you go about assessing where you’re at to understand what you need to implement?
Brice: You can do this through surveys and small group sessions. Asking open-ended questions so people can provide content that helps you understand truly where you’re at and listening are important. Anonymous surveys maybe the best place to start because people may not be very open to speaking up during a small groups. The surveys help you understand where you’re at and what areas do you need to focus on first. Stepping back and looking at what’s happening every day in the company will also give you an understanding of where your company is. How do people feel about stopping a line if they see an issue? Are they comfortable speaking up?
Coffman: Assessment isn’t a one-size-fits-all approach. It has to be carefully thought out and will vary from company to company and even from location to location within the same company. I would like to add that assessment without action is fruitless. If you put forth the time and effort to collect and analyze data, you must take action.
Once you’ve done your assessment and are ready to improve your food safety culture, what are some of the steps you can take to get started?
Coffman: We have a page on our toolkit website dedicated to this, and it leverages learning from our 20 Alliance members from across the industry, looking at both the successes and the bumps they’ve encountered. It is going to look different for each company so I encourage everyone to go to the toolkit website and look at the Plan Your Journey tab.
Brice: The best plan includes people from all areas of the organization. You don’t want just the manufacturing base or the managers, you need to understand why people have the behaviors they have today and what needs to change. If all employees or departments feel that they have ownership in the plan, then the plan will come to fruition faster, and you’ll also create food safety champions along the way.
Drains can harbor pathogens and biofilms in facilities and have been cited as the cause of a Salmonella Motevideo outbreak in Quebec, Canada. For “Investigation of a Salmonella Montevideo Outbreak Related to the Environmental Contamination of a Restaurant Kitchen Drainage System, Québec, Canada, 2020–2021,” (Journal of Food Protection, October 2023), researchers André Paradis, Marie-France Beaudet, Marianne Boisvert Moreau and Caroline Huot, documented the investigation into the outbreak that affected at least 67 people between January 1, 2020 and August 13, 2021. An epidemiological investigation that included whole genome sequencing found that 66% of cases were directly linked to a restaurant in the area.
After an initial evaluation of hygiene, food safety, cases of illness among workers and food sampling failed to establish the source of the outbreak, environmental samples showed that the restaurant’s kitchen drains were contaminated with the same strain of Salmonella Montevideo as the cases in the outbreak. Several cleaning and disinfection methods were used repeatedly. When environmental sampling at the restaurant sites was repeatedly and consecutively negative, cases in the community stopped.
Over the course of the epidemiologic investigation, public health responders learned that the restaurant had experienced an accidental fire in its kitchen before the Salmonella Montevideo outbreak began. According to the Québec City fire department’s incident report, the fire started in—and was limited to—the oven used for cooking chicken.
The authors posited that the fire in the kitchen, which required emergency response from firefighters who used a powder extinguisher first, then a water jet to contain and extinguish the flames, may have played a role in the contamination of the restaurant’s sinks and drains.
The authors concluded that, “The most plausible explanation for the origin of this outbreak remains the contamination of the drains in Restaurant A. The presence of contaminated biofilm in the restaurant’s kitchen drainage system may have had a role to play in the extended duration of this outbreak.”
I have a tattoo on my arm of a stamp that proudly, if not entirely accurately, declares that I am “100% organic.” As a food lawyer and general foodie, it is very much on brand. I cover it with my sleeve whenever I go to court or otherwise feel that it is professionally appropriate to do so. But otherwise, my tattoo isn’t much of a liability, even if I display it to the world while proudly eating chemical-laden foods; to the contrary, it’s a fun conversation starter.
Unfortunately, the same cannot be said for food packaging. Food manufacturers who make that same claim, or others like it, without following the USDA’s stringent organic-labeling regulations, will face a lot more than a raised eyebrow, particularly since the USDA recently strengthened its enforcement ability with a new final rule that became effective earlier this year. So how can you let your more health-conscious customers know about the purity of your food without getting in trouble?
The safest and easiest way to do this is simply to identify any organic ingredients on the information panel of your packaging. If less than 70% of your ingredients are organic (by weight, excluding water and salt), then this is your only option. The ingredients listed as organic must in fact have been produced in compliance with the organic regulations and must not have come into contact with any prohibited substances. And you must keep records that allow the USDA to confirm this. Limiting your organic labeling to the information panel means that you don’t have to certify as an organic handler.
If more than 70% of the ingredients in your product are organic, then you probably want your customers to know that without having to read the ingredient list. Depending on the composition of your product, you want your principal display panel to declare that your food is “100% Organic,” “Organic,” or “Made with Organic” ingredients. The trade-off for making any of these claims is that you must certify as an organic handler, unless an exclusion or exemption applies to you. The ins-and-outs of certification are outside the scope of this article, but you can find them by referencing the regulations in 7 CFR 205. Although obtaining and maintaining certification is a rigorous standard, it allows you to use the USDA seal on your packaging.
Breaking Down the Three Types of Organic Claims
Let’s look at the broad requirements for these three types of claims. To make a claim that your product is “100% Organic,” all of your ingredients, and any processing aids, must have been produced in accordance with the organic regulations. Pretty simple, and common-sense.
To make an “Organic” claim, at least 95% of your ingredients, by weight, must have been produced in accordance with the organic regulations. Any nonorganic agricultural ingredients must meet a list of criteria, including that they are not commercially available in organic form and are not produced using certain prohibited processes. In addition, any nonagricultural ingredients including processing aids must be on the regulations’ list of approved substances.
To make a claim that your product is “Made with organic” ingredients, the product must contain at least 70% organic ingredients, by weight. In addition, all agricultural products must be produced without the use of sewage sludge, and cannot be irradiated or genetically engineered, and any nonagricultural ingredients including processing aids must be on the regulations’ list of approved substances. You are also limited to three ingredients or types of ingredients, and those ingredients must be included on the list of ingredients set forth in the regulations. The list currently consists of fish, fruits, grains, herbs, meats, nuts, oils, poultry, seeds, spices, sweeteners, vegetables and processed milk products. And all types of the ingredient (for example, tomatoes and tomato paste), must be organic, unless the non-organic type is identified separately as non-organic.
A major exemption for food manufacturers applies to producers of organic products whose agricultural income from organic sales is less than $5,000 a year. If this describes you, then you needn’t go through the rigorous certification process, but you must still follow the regulations for producing and handling organic products and all the applicable labeling requirements. The trade-off for avoiding the rigors of certification is that you may not use the USDA stamp on your products, and anyone who purchases your products cannot label them organic. And you must keep records sufficient to prove that any ingredients labeled as organic were in fact organically produced and handled and to verify the quantities that were produced from these ingredients.
To recap, absent an exemption or other exclusion, if you want to make a bold declaration about the organic nature of your ingredients, you will need to certify as an organic handler and follow all the relevant labeling regulations. For your efforts, you get to display the USDA seal on your products. If an exemption applies to you, you may make that bold declaration without certifying, but you do not get the added legitimacy of the USDA seal. If certification doesn’t make sense for you and no exemption or exclusion applies, then you may not make any bold declaration, and you are limited to listing the ingredients on the information panel.
Follow the regulations carefully. After all, what holds true for tattoos also holds true for organic labeling. Always think before you ink!
In a report released in May of 2023, the Institute of Food Technologists (IFT) offered an encouraging and attainable outlook for cooperative and effective functionality throughout the global food supply chain. And with traceability as the primary goal in this diverse landscape of users, challenges and solutions abound. Less a snapshot of where we have been, this report is a helpful guide to where we are going and how best the industry will achieve compliance to the Food Safety Modernization Act (FSMA) by January 20, 2026.
Traceability Challenges in a Global Food Supply Chain
Traceability is a common goal in all industries. But when food and beverage is your bread and butter, the ability to trace a single ingredient can be a matter of life and death. Based on findings in a 2006 study, the Center for Disease Control (CDC) reported the following yearly totals: 37.2 million cases of foodborne illnesses; 228,744 resulting hospitalizations; and 2,612 deaths.[1] In order to improve the landscape of health and safety in the food and beverage industry, the IFT in conjunction with the FDA embarked on a study[2] of how low- or no-cost technology could improve traceability for businesses within the global food supply chain.
One of the greatest challenges in achieving uniform traceability lies in the vastness within the food supply chain itself. Those beholden to compliance are defined as “all persons who manufacture, process, pack, or hold foods that appear on the Food Traceability List (FTL).[3]” And this rule applies to all foods that are consumed in the U.S. market, not just those grown in the U.S. All laborers—planters, harvesters, processors, handlers, packers, distributors, shippers and retailers—who interact with any item on the FTL[4] must be recorded and tracked according to FDA guidelines. These guidelines include procedural protocol for food handling as well as timelines for processing and documentation. Whether the starting point of a single ingredient is stateside or overseas, it generally travels several places before arriving on a grocery store shelf or appearing on a restaurant’s menu.
Within this huge network of players lies the next challenge: economic and technological diversity. While economy and technology are not always one and the same, the typical overlap is demonstrated in the specific case of a head of lettuce. On one end of the supply chain continuum, a head of lettuce begins its journey in a field. There are no handheld scanners or databases in this lettuce’s origin story. There is only the hot sun, an irrigation system, and hard-working people laboring up and down the rows of lettuce. Now flash forward to Aisle 1 of your local grocery store. By now this lettuce has been inspected, washed, shrink-wrapped, labeled, UPC-ed, shipped, received and shelved. With each new set of hands it has passed through—both human and mechanical—it has likely experienced an ascending economic stratum with advancing technological features at each step. Sophistication and automation often increase exponentially as the number of places on the continuum increases. A head of lettuce purchased at your local farmers market, for instance, may have only changed hands once or not at all, while a vacuum-sealed carton of greens at your regional mega-outlet has likely seen many locales as well as top-of-the-line technology and automation.
In addition to a variety of technologies, it is likely that this head of lettuce has also passed through the hands of people speaking multiple languages. The laborers at the beginning of the continuum are often non-native English speakers. And regardless of a laborer’s native tongue, lower rates of literacy are common in entry level food industry jobs. According to statistics published by the Department of Labor in 2018, 77% of U.S. farmworkers report Spanish as their primary language. And the same report states that the average level of formal education completed was eighth grade.[5] Therefore, compliance across the continuum must be translatable and comprehendible to all levels of experience and available in all languages of users.
The challenge of complete supply chain compliance from one end of the spectrum to the other warrants cooperation across many lines: state, national, linguistic, cultural and economic to name a few. The need for intuitive solutions and an easy to implement process is paramount.
Technology as the Traceability Solution
With a better understanding of the global food supply chain itself, it is not hard to see why solutions can be found in the tech sector. When the food supply chain existed primarily in a local economy, keeping paper records was a viable process. Now the food supply chain is a global enterprise, and as such, processes must also operate on a global scale.
Tech solutions offer ready-made customization. Language translations, infographics, flowcharts and videos are easily incorporated into platforms for ease of use across all segments of the supply chain. This is beneficial to both domestic and international operations, and it is especially advantageous to those whose operations span both.
The availability of cloud-based platforms has elevated technological capabilities. No longer does every physical operation need its own dedicated server; rather, information is stored and remains accessible anywhere—from a single lettuce field all the way to the grocery store aisle across the world.
“It used to be common that shipments would arrive without necessary paperwork such as invoices, bills of lading or certificates of analysis. Even shipping labels would commonly be ripped off or illegible,” says Geoff Ellis, COO of Wherefour. “Things get lost in the mail. But when all pertinent information is stored in the cloud, it’s unquestionably accessible to the receiver, the shipper and the transport company.”
Not only does the use of cloud-based technology streamline operations for shipping and receiving, but it does the work ahead of time for quality assurance and regulatory compliance. Documentation does not have to be intentionally gathered and prepared for audits. Everything is already in order when a cloud-based tech platform is employed.
The FSMA’s Traceability Plan guide[6] mandates specific controls and standards for record keeping, all of which are reliant on lot codes. Lot code traceability is easily achievable with a comprehensive software solution. And data sharing is significantly improved with a cloud-based system. All involved parties can be in separate parts of one building or in different parts of the world, and they can still be on the same page operationally.
Expertise in the Tech Sector
With the FDA’s commitment to increased traceability, a shift in focus from response to prevention is apparent. And tech solutions have the unique ability to measure efficacy in procedural implementation across the supply chain continuum. Records are created, stored and shared in perpetuity, and those records can be instantly accessed from any location. Leaders in the tech industry are interested in creating solutions that are scalable and transferable. It is not uncommon for a platform whose original design was to address problems in one industry to end up solving a problem in a different industry altogether. Software solutions are by nature about operational functionality and can be applied to any operation therein.
Furthermore, evolution in the tech sector is rapid and collaborative. Expert insights and advancements drive competitors to continually improve and increase productivity and efficiency. “The tech sector is driven by a healthy sense of collaboration and competition,” says Ellis. “It’s exciting to watch the bar being raised by our competitors. It really motivates us to raise it even further with each new feature we develop.”
In order to achieve FSMA compliance within the diverse global food supply chain, implementing low- or no-cost tech-enabled traceability solutions is essential. It is in everyone’s best interest to remove any barriers that would otherwise prevent viable and nutritious food from getting to market.
References
[1] Scallan, E., Hoekstra, R. M., Angulo, F. J., Tauxe, R. V., Widdowson, M., Roy, S. L….Griffin, P. M. (2011). Foodborne Illness Acquired in the United States—Major Pathogens. Emerging Infectious Diseases, 17(1), 7-15. https://doi.org/10.3201/eid1701.p11101
[6] Requirements for Additional Traceability Records for Certain Foods: What You Need to Know About the FDA Regulation: Guidance for Industry. Small Entity Compliance Guide. (2023, May). Retrieved from https://www.fda.gov/media/168142/download
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