Susanne Kuehne, Decernis
Food Fraud Quick Bites

You Don’t Want Your Bread Buttered on Both Sides

By Susanne Kuehne
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Susanne Kuehne, Decernis
Red Sunflower
Find records of fraud such as those discussed in this column and more in the Food Fraud Database.

Albania’s National Food Authority NFA discovered food fraud where Ukrainian vegetable fat labeled as margarine was sold as butter and buttermilk, in some cases claiming German origin. The NFA imposed fines and confiscated the fraudulent product. Since the importer did not sufficiently check the trade documents, they are seen as part of the fraud operation. The Albanian government will also increase punishment for those involved in food fraud in the future.

Resources

  1. “Margarine Sold as Butter, NFA Unveils Fraud Scheme” (May 31, 2019). Albanian Daily News. Retrieved from https://albaniandailynews.com/index.php?idm=31993&mod=2
Alec Senese, Bayer Crop Science, Digital Pest Management
Bug Bytes

Did Barcode Scanning Kill IPM Inspections?

By Alec Senese
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Alec Senese, Bayer Crop Science, Digital Pest Management

Barcode placement on rodent traps was introduced as a simple and seemingly obvious way to make sure that the work of an IPM inspection was being performed. Each trap would have to be manually inspected in order to scan the barcode, providing proof that the task was completed.

While this method may be a great way to ensure an important job is being done, the problem with this approach is that it does not ensure the most important jobs are being done. In facilities that are large and complex, the act of checking and scanning traps is a lengthy and laborious process. This leaves little time for thorough investigative inspection and corrective actions, which are a vital part of preventing future rodent problems. Pest control technicians’ time should be spent using their understanding of pest biology and behavior to be pest detectives in your facility, not spending the majority of their time on time-consuming tasks that require little brainpower.

So did barcode scanning kill IPM inspections? Probably not, but it certainly didn’t help.

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

The Changing Face of Leadership in the Food and Beverage Industry

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

Our food system is facing daunting challenges. We must adapt our food systems to sustainably feed almost 10 billion people by 2050 in a world with shifting climate and environmental pressures. In addition, we need to reduce the rising number of undernourished people (an estimated 821 million people in recent years) and confront the significant issue of more than 30% of food production being lost or wasted. Tackling these challenges will require collaboration across all aspects of the food system to assure that production processes, policies and regulations, food safety practices, and affordability align to assure we live in a food secure future. However, most of the current generation of leaders in the food industry has not approached leadership from the systems-thinking approach that will be required to succeed.

Thus, focusing on developing the right skills in the rising next generation of leaders in the food and beverage industry in order to solve these problems will be critical. We need people who can think broadly and are empowered to navigate the complexities of the global food system. Professionals in the food industry need to think beyond the specialties and silos where they currently work. Approaching food problems in an open-minded and cross-disciplinary way will achieve better results for business growth, population well-being, food production and planet sustainability.

In my decades of working in the food industry, I was acutely aware of the challenges that we would face in the future. Now, as part of the Integrated Food Systems Leadership program at the University of Minnesota, we are addressing these issues by helping to train the future leaders that will transform the food system. The following topics are just a few of the areas that we see as essential to develop the food leaders of tomorrow.

Next-Gen Leaders with a Holistic Approach

One of the key steps for new leaders in food and beverage industry is to adapt to food systems thinking. Most professionals were hired for their knowledge in a specific area. Now, to become next-gen leaders, they will need to think about the whole food production system and how all decisions made in this system, from sourcing and production to supply chain and retail sale, affect people and the environment.

Where we source our food and how we produce it is truly global and interconnected. The ingredient and material supply chains are vast and complex. We can no longer afford not to take into consideration where and how these items are being sourced and supplied. Additionally, we can no longer afford not to be responsible for the products produced and how they are affecting the health and well-being of consumers as well as the planet.

The next generation of leaders, no matter what part of the food system they are working in, will need to understand these relationships and think about how all these little pieces from production to marketing and sales work together. When one change is made to the system, whether the idea is from R&D or the marketing department or is caused by a new regulation, this will produce ripple effects across the food system.

True Leadership vs. Management in the Food System

Often times, the idea of leadership is thought of as just managing people—observing a team and making sure each person is doing their job. This is management and not a true definition of leadership. To be a leader means you have a vision and can paint a clear picture of what you see to others. Leaders build relationships with people who help turn a vision into reality. Leaders aren’t afraid to change the status quo and take risks if those risks will help the long-term plan. Leaders help their team achieve more than any individual on the team thought possible.

Leaders have many qualities. First, they have ideas that should be heard. However, in order for those ideas to see the light of day, professionals must know how to communicate so their opinions and thoughts are considered. Knowing how to package a vision and communicate it more effectively are critical to leadership development.

Second, leaders desire to have a meaningful impact in the world. To be able to effect change, seeing the bigger picture and understanding the interdependencies throughout the food system is paramount. As part of this, they want and need to help other people be heard to move the vision and plan forward. They will need the skills to foster collaboration and innovation within their teams and across disciplines to help everyone succeed in making the changes needed in the food system.

Third, although leaders want to grow their companies, they also want to grow personally. When a vision is created and steps taken to pave the way for that vision to come to fruition, a journey begins. Leaders know that any journey embarked upon is a life-changing experience, and they welcome that new stage.

Finally, it is important to note that leaders can be found in more places than the corner office. Leaders are not just CEOs, but come in varying roles and titles. Developing people’s leadership potential, style and goals for whatever capacity they work in is a critical part of leadership building. Leaders exist within every team, department and work group across a business. Finding them, to grow and foster their potential, is the challenge.

Fostering Professional Development in the Field

Food and beverage companies can do a great deal to address these pressing issues today by instilling a culture of learning in the organization. I have found, more often than not, people who enter this industry are passionate about it. However, when individuals enter a company, especially early in their career, they sometimes face a crisis of faith moment and question that their lifelong training has not prepared them for what they truly want to do.

Many times those in the industry feel like they have ideas or skills that aren’t being leveraged. They may feel like they aren’t being heard or that they’ve been pigeon-holed into one segment of or role in the business. These professionals could be the collateral damage of silo mentality and lack of a culture of learning and growth, especially when they are high-value and have specialized knowledge. Corporations have perfected efficiency by keeping certain departments, and individuals within them, separated in order to optimize their segment’s function. But slotting the business, and individuals, into distinct categories can hinder the ability of these organizations to see and understand the big picture.

By breaking down this silo mentality and promoting systems thinking, businesses can help their talented and dedicated people grow their career, become a better leader, and enable a move across the lattice structure within an organization. Many times these individuals feel a little lost in the mix and frustrated as a cog in the machine and are looking for growth opportunities. This doesn’t necessarily mean they want to move vertically within the organization, but rather learn and grow laterally or diagonally within an organization to both enhance their career and provide a broader benefit to the entire business.

When companies equip professionals with critical-thinking skills, they are developing their professionals who want to make a meaningful impact within their organizations as well as in the entire food system. This is true empowerment to improve the future of food and make companies viable and competitive for the future.

If a company doesn’t have this training ability internally, organizations can support programs that are helping to build these leaders. Programs like the new Integrated Food Systems Leadership are designed to help future leaders bridge the current skills gap in the food system. These future leaders will have the tools to drive the change critical for many companies to succeed while we feed the future.

Laura Lombard, IMEPIK
FST Soapbox

Is Your Facility Properly Prepared to Ensure Preventive Controls are Met?

By Laura Lombard
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Laura Lombard, IMEPIK

Under FSMA, you are required to have at least one Preventive Control Qualified Individual (PCQI) on your staff at all times to build and manage your food safety plan(s) for your manufacturing facilities. Per the regulation, PCQIs “have successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or be otherwise qualified through job experience to develop and apply a food safety system.” (Subpart C Section 117.180 (c) (1))

First and foremost, have you met the basic requirement of having at least one trained PCQI? There are now both online and in-person options to ensure your that food safety or quality assurance manager has had the proper training. Most online options require set times and dates like the in-person version to complete the training. Only one PCQI training currently on the market is completely self-paced and available 24-7. No matter which option you choose, it is a baseline that you ensure you have checked that regulatory box before the FDA comes to inspect your facility.

But what if your PCQI needs to take extended medical leave or moves on to another job? It is a proactive and smart move to have a back-up PCQI trained to both help support your PCQI under regular circumstances and be ready to step in if your quality assurance manager becomes unavailable. For a relatively small investment, you can ensure your company is meeting the regulatory requirement and has the training to provide a safe, quality product.

The FSMA regulation does not require you to have a PCQI for every facility but does require an individual food safety plan per location. Depending on how many facilities your particular company has, you may want to consider more than one PCQI to ensure that food safety plans are regularly updated and properly implemented. Many companies are now training the entire quality assurance department or a facility cross-functional team to be PCQIs and participate on the food safety team. Again, the relatively small investment in properly training personnel can save your company hundreds of thousands or millions of dollars in costly recalls, lost revenue due to negative brand reputation, and FDA fines. The average recall costs $10 million, not including brand damage and lost customers.

It is simply prudent to invest in PCQI training beyond the basic requirement of the FSMA regulation. Companies should train their quality assurance or food safety staff at the PCQI level to protect a company’s product quality, brand and customer base. The fewer food safety-related claims you have, the more that can be saved in costly recalls, loss of current or potential customers, and brand reputation. Lastly, a company with a robust safety culture has a competitive advantage over competitors who are less inclined to invest sufficiently in their food safety training and may suffer financial repercussions and damage to reputation as a result of recalls and customer quality assurance complaints.

Susanne Kuehne, Decernis
Food Fraud Quick Bites

This Bufala Is No Bufala

By Susanne Kuehne
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Susanne Kuehne, Decernis
Bufala
Find examples of these records and more in the Food Fraud Database.

Who doesn’t enjoy a nice Insalata Caprese or pizza Margherita with fresh tomatoes and mozzarella? Based on regulations in the EU and Italy, mozzarella di bufala is supposed to be made with buffalo milk only. “Bufala” in Italian may also mean “media hoax”, however, in this case, science shows that there is indeed “no bufala”. Multiple reaction monitoring mass spectrometry brings wide-spread fraught to light, showing that two-thirds of the tested supermarket and restaurant products are made with much cheaper cow’s milk, according to a study published in Food Control.

Resources

Gunning, Y., et al. (July 2019). “Quantitative authenticity testing of buffalo mozzarella via αs1-Casein using multiple reaction monitoring mass spectrometry”. Food Control. Volume 101, Pages 189-197. Retrieved from https://www.sciencedirect.com/science/article/pii/S0956713519300775?via%3Dihub

Bob Pudlock, Gulf Stream Search
FST Soapbox

Architect the Perfect Food Safety Team: Capture Your Ideal Candidate and Set Them Up for Success

By Bob Pudlock
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Bob Pudlock, Gulf Stream Search

If there is one ingredient that contributes the most to a successful food safety team and culture, it’s the senior-most food safety officer taking full responsibility for the recruitment and on-boarding of each of its team members.

“But isn’t that HR’s job?”

“Isn’t that the talent acquisition team’s job?”

“Isn’t that what our internal recruiter is supposed to take care of?”

As an executive recruiter who is asked to transform food safety teams through new hires, I can say with 100% conviction that the answer is NO.

It’s your job as a food safety leader to make sure every step of the recruitment and on-boarding process, from the first connection with the potential candidate all the way through their first review, is performed flawlessly.

The following are some key benchmarks of a well-executed recruitment process.

  • The candidate and food safety leadership team have clear expectations of how the new hire will impact the business.
  • The candidate’s compensation expectations are aligned with the company’s capabilities, both in the short-term as well as in the future.
  • Each member of the food safety team is on the same page during the interview process. There’s a level of coordination and everyone has a role and responsibility that leaves a favorable impression on the candidate that “this is a strong food safety team and one I want to be a part of.”
  • The hiring team, because it’s been so thorough in its due diligence, has no underlying concerns about their decision.
  • The new hire knows when their first review will be, who it will be with, and what benchmarks they’ll be assessed against.
  • Offer, acceptance and start date are presented, accepted and committed to in less than three days.

What happens when YOU don’t take ownership of the candidate and new hire experience?

Bob Pudlock will be moderating the panel discussion, “Food Safety Leadership: Earning Respect”, at the 2019 Food Safety Consortium | October 1–3 | Schaumburg, ILWhen asked to describe why they left a role after less than six months, the most often heard reply is that the food safety leadership and/or recruiter promised something during the interview process and once on board, everything changed.

Another complaint that arises is that elements of relocation packages, sign-on bonuses, on-boarding and training are either not executed or not coordinated with what was promised during the interview process.

In the food safety space, an oft-held complaint is that the confidence and conviction of food safety leadership during the interview process disappears when the new hire arrives; the new hire experiences a lack of respect shown to food safety personnel, and their leadership team retreats in the background and doesn’t provide cover for the on-the-ground team.

It’s unfortunate but true—a misstep in the recruiting and on-boarding process in an otherwise flawlessly executed hiring process can have drastic consequences on a new hire’s experience.

Imagine a meal at a five-star restaurant with family and friends that goes off flawlessly, only to find out the next morning that half your guests are in the emergency room with food poisoning.

It’s no different when a new hire’s on-boarding experience destroys the goodwill that was created during the hiring process.

In talent acquisition, a flawlessly executed hiring process, followed by an on-boarding experience that aligns with what the new hire was promised during the interview process is the key to future employee referrals—no area of a food or beverage company needs more strong employee referrals than food safety.

It’s also a big part of why food safety staff can act with confidence in calling out protocol violations or unsafe practices that play out in facilities or with suppliers. When trust and goodwill with senior food safety leadership is in place, the food safety team can do their job knowing their boss has their back.

Susanne Kuehne, Decernis
Food Fraud Quick Bites

This Smells Quite Fishy

By Susanne Kuehne
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Susanne Kuehne, Decernis
Food fraud, Fish
Records involving fraud can be found in the Food Fraud Database. Image credit: Susanne Kuehne

In a EU-wide coordinated effort, more than a dozen members of an organized criminal group were arrested. The criminals were fishing with illegal methods, and processed and stored their catch in unsanitary conditions. Consumers’ health was possibly affected by the rotting fish being treated with bleach to mask unsavory smells, with the goal to sell the fish in multiple EU countries, yielding a revenue of more than €100,000 per year. In addition, the gang committed tax and money laundering crimes.

Resources

  1. EU-OCS Editor (May 16 2019). “Tons of contaminated fish seized in EU-wide operation”. EU-OCS Latest News on Crime and Security in Europe. Retrieved from https://eu-ocs.com/tons-of-contaminated-fish-seized-in-eu-wide-operation/
Megan Nichols
FST Soapbox

Technology Tools Improving Food Safety

By Megan Ray Nichols
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Megan Nichols

To cap off a tumultuous year for foodborne illnesses, the end of 2018 saw a rather large E. coli outbreak that affected several different types of lettuce. In all, about 62 people got sick in the United States, with another 29 affected in Canada. The outbreak was traced back to a farm in California thanks to a specific DNA fingerprint in the E. coli. It started in a water reservoir and spread to the nearby crops.

Unfortunately, the event was only one of two separate incidents involving romaine lettuce last year. Another E.coli outbreak was traced back to a source in Arizona. Are these outbreaks more common than we realize? The CDC estimates that 48 million Americans fall ill each year from foodborne pathogens. Of those who get sick, 128,000 have to be hospitalized, and about 3,000 perish.

It’s clear that the industry as a whole needs to buckle down and find more effective solutions, not just for preventing outbreaks but also for mitigating damage when they happen. A new level of safety and management can be achieved with the help of many new, innovative technologies.

The following are some of the technology tools shaping the future of food safety and quality management fields.

Blockchain

As a result of the E. coli outbreak, Walmart implemented blockchain technology to track leafy greens and boost supply chain transparency. The systems and infrastructure is anticipated to be in place by the end of 2019.

Blockchain is a secure, digital ledger. It holds information about various transactions and data, all of which are carried out on the network. It’s called a blockchain because each data set within the network is a chunk or “block,” and they’re all linked to one another—hence the chain portion of the name. What this allows for is complete transparency throughout the supply chain, because you can track goods from their origin all the way to distribution and sale.

Each block is essentially a chunk of information, and when it’s entered into the chain, it cannot be altered, modified or manipulated. It’s simply there for viewing publicly. You cannot alter information contained within a single block without modifying the entire chain—which operates much like a peer-to-peer network and is split across many devices and servers.
This unique form of security establishes trust, accuracy and a clear representation of what’s happening. It allows a company to track contaminated foods along their journey, stopping them before they contaminate other goods or reach customers.

Infrared Heating

Thanks to the rising popularity of ready-to-eat meals, the industry is under pressure to adopt preservation and pasteurization methods. Particularly, they must be able to sanitize foods and package them with minimal exposure and bacteria levels. This practice allows them to stay fresh for longer and protects customers from potential foodborne illness.

Infrared heating is a method of surface pasteurization, and has been used for meats such as ham. Infrared lamps radiate heat at low temperatures, effectively killing surface bacteria and contaminants. The idea is to decontaminate or sanitize the surface of foods before final packaging occurs.

Industrial IoT and Smart Sensors

The food and beverage industry has a rather unique challenge with regard to supply chain operations. Food may be clean and correctly handled at the source with no traces of contamination, but it’s then passed on to a third party, which changes the game. Maybe a refrigerated transport breaks down, and the food within is thawed out. Perhaps a distributor doesn’t appropriately store perishable goods, resulting in serious contamination.

This transportation stage can be more effectively tracked and optimized with the help of modern IoT and smart, connected sensors. RFID tags, for instance, can be embedded in the packaging of foods to track their movements and various stats. Additional sensors can monitor storage temps, travel times, unexpected exposure, package tears and more.

More importantly, they’re often connected to a central data processing system where AI and machine learning platforms or human laborers can identify problematic changes. This setup allows supply chain participants to take action sooner in order to remedy potential problems or even pull contaminated goods out of the supply.

They can also help cut down on fraud or falsified records, which is a growing problem in the industry. Imagine an event where an employee says that a package was handled properly via forms or reporting tools, yet it was exposed to damaging elements. The implications of even simple fraud can be significant. Technology that automatically and consistently reports information—over manual entry—can help eliminate this possibility altogether.

Next-Generation Sequencing

NGS refers to a high-throughput DNA sequencing process that is now available to the food industry as a whole. It’s cheaper, more effective and takes a lot less time to complete, which means DNA and RNA sequencing is more accessible to food companies and suppliers now than it ever has been.

NGS can be used to assess and sequence hundreds of different samples at a time at rates of up to 25 million reads per experiment. What that means is that monitoring teams can accurately identify foodborne pathogens and contamination at the speed of the modern market. It is also a highly capable form of food safety measurement and is quickly replacing older, molecular-based methods like PCR.

Ultimately, NGS will lead to vastly improved testing and measurement processes, which can identify potential issues faster and in higher quantities than traditional methods. The food industry will be all the better and safer for it.

The Market Is Ever Evolving

While these technologies are certainly making a splash—and will shape the future of the food safety industry—they do not exist in a vacuum. There are dozens of other technologies and solutions being explored. It is important to understand that many new technologies could rise to the surface even within the next year.

The good news is that it’s all meant to improve the industry, particularly when it comes to the freshness, quality and health of the goods that consumers eat.

Karen Everstine, Decernis
Food Fraud Quick Bites

A Different Type of Food Fraud

By Karen Everstine, Ph.D.
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Karen Everstine, Decernis

Food Fraud: Problem Solved? Learn more at the 2019 Food Safety Supply Chain Conference | May 29–30, 2019 | Attend in Rockville, MD or virtually The typical motivation for food fraud is replacing a more expensive ingredient with a less expensive one, thereby increasing profits or competitiveness on the market. Another form of fraud involves the use of active pharmaceutical ingredients in products marketed as dietary supplements or foods containing dietary supplements.

Last month, an instant coffee drink purportedly containing “natural herbs” tongkat ali, guarana, and maca was reported to actually contain two pharmaceutical ingredients (APIs) approved by the FDA for the treatment of male erectile dysfunction. In this case, the motivation for fraud is “spiking” with the “intent to impart an effect that cannot be achieved by the dietary ingredients alone.” This is an ongoing challenge for regulators and other stakeholders who work to ensure the safety of the supplements market. This type of fraud in dietary supplements is also an important health risk to consumers, since unintentional consumption of APIs can result in unintended side effects or adverse interactions with other drugs. A quick glance at the FDA’s Medication Health Fraud Page illustrates how common this type of adulteration is, most notably in products advertised for erectile dysfunction, weight loss and sports performance.

In March, an energy drink was banned in Zambia after Ugandan authorities determined it contained sildenafil citrate (the active ingredient in Viagra). In 2015, Chinese authorities investigated distillers of a popular liquor under suspicion of adding the same substance. Adding to the challenge of this type of fraud is the fact that certain consumers may view food and dietary supplement products containing APIs as more appealing, not less.

Both manufacturers and consumers should use good judgment when purchasing dietary supplements or foods marketed as containing dietary supplements. There are educational resources available for consumers and guidance for industry to support the quality assurance and safety of these products. These include the NIH Office of Dietary Supplements and the National Center for Complementary and Integrative Health, the American Botanical Council, the American Herbal Products Association and USP.

Images of the recalled product from FDA’s website. Records involving fraud can be found in the Food Fraud Database.
Mitzi Baum, Stop Foodborne Illness
Food Safety Culture Club

Building a Safer Supply Chain, Increasing Foodborne Illness Awareness, and Progress in Sustainability: A Q&A with Stop’s New CEO

By Maria Fontanazza
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Mitzi Baum, Stop Foodborne Illness

Last week Stop Foodborne Illness announced who would be filling the role of its retiring CEO Deirdre Schlunegger: Mitzi Baum. Previously managing director of food safety at Feeding America, Baum has extensive experience in the non-profit space as well as the realm of retail management. In a Q&A with Food Safety Tech, Baum discusses where she sees Stop Foodborne Illness moving forward in its advocacy role and how the organization will work with both industry as well as consumers in the future.

“I am excited to assume the role of CEO at Stop Foodborne Illness. We are at a point in our evolution to identify new opportunities to expand awareness, create a strategy to pursue those new opportunities and implement and execute our plan,” says Baum. “You will be hearing a lot from Stop in the near future.”

Food Safety Tech: You bring a tremendous amount of experience to your new role at Stop Foodborne Illness. How will the organization work with industry to advocate for food safety moving forward?

Mitzi Baum: In my previous position, I had the opportunity to build relationships, network with food safety peers in food manufacturing and retail and work on food safety issues. I would like to use that experience to our advantage as we identify new ways to work cooperatively with industry to move toward a safer supply chain and expand foodborne illness education and awareness throughout the food system. Stop has also fostered many relationships over the years; now we would like to translate those relationships into partnerships to affect greater impact and reduce the incidence of foodborne illnesses.

FST: Where are the key areas in which Stop will be focusing in its continued effort to both promote awareness of foodborne illness as well as prevention?

Baum: Moving forward, we will build upon relationships to promote awareness of foodborne illness prevention. Currently, we have 10 industry partners working with Stop to identify new training techniques to increase awareness of the impact of foodborne illnesses. In the next few months, we will run pilots to test the techniques, gather data, make adjustments and reassess. After the pilot phase, we will work with an expanding number of companies to implement an appropriate model that will result in measurable improvements for internal foodborne illness awareness.

Mitzi Baum, Stop Foodborne Illness
Mitzi Baum, CEO, Stop Foodborne Illness

FST: Given your experience in food insecurity, where do you see the most progress in addressing sustainability? Where is there work do be done?

Baum: There has been a lot of progress regarding increased awareness of sustainability and reduction of wasted food. Sustainability is an essential part of the food industry and there has been little to no discussion about the topic until the past few years. Thankfully, it has become a badge of honor for companies to include sustainability into their organizational culture. With a pivot to focus on sustainability, topics such as utilization of natural resources, types of packaging materials and long-term environmental impact have become the focus for an industry that can be a model for other industries.

With regard to food waste, the new cooperative initiative between USDA, EPA and FDA can certainly help to accelerate impact. It is my hope that the regulatory agencies can work to modify regulations that prohibit the donation of safe, wholesome foods that end up in landfill rather than on the dinner table. The amount of wasted food in this country is shameful.

FST: As FDA steps into its “New Era of Smarter Food Safety”, will Stop Foodborne Illness be collaborating with the agency on any new/current initiatives?

Baum: Absolutely. We want to participate and represent our constituents in this important work. Stop’s expertise and consumer-focused perspective is essential to have at the table. As the FDA plan rolls out, Stop will be identify the appropriate opportunities to assert its influence and continue to advocate for sound food safety policy.