By Kevin Payne

When it comes to addressing food safety, did the industry really make any progress in 2018? In 2019, what new approaches or technologies can be successfully applied to prevent problems before they occur and minimize the consumer risk, minimize the market impact, and speed up the identification, isolation and recall of contaminated products?

Field-packed produce offers a unique challenge to the fresh food supply chain, as it is not processed and is not required to adhere to an FDA mandated HACCP (Hazard Analysis and Critical Control Points) process. It has been a challenge for field-packed produce suppliers to proactively identify or prevent contaminated produce from entering the supply chain. As a result, during serious contamination incidents, the reaction is to pull and destroy all suspect product from store shelves and supply chain. Due to the lack of data isolating the source of the contamination, this is the safest approach, but it’s costing the industry millions of dollars. Ultimately, our inability to prevent or quickly isolate these events causes confusion among consumers who don’t know who to trust or what is safe to eat, resulting in a prolonged market impact.

In response to the latest E. coli outbreak involving romaine lettuce, the industry has proposed a voluntary item-level label that reflects the harvest location and date, to help identify safe product to the consumer. At best, this is a stop-gap solution, as it burdens the consumer to identify safe product.

I work in the fresh produce supply chain industry. When I go to the grocery store, I examine the produce, noting the brand and various other factors. I was aware of the romaine problem and the voluntary labeling program, so I knew what to look for. But I’m an exception. Most consumers don’t know romaine lettuce is grown during the summer and fall in northern California and further south during the winter in regions that include Arizona and Mexico. Most consumers don’t know what the “safe date” for harvest really means—nor should they be required to know this information. They look to the industry to manage this. If we buy a car or microwave oven that is found to be unsafe, the manufacturer and the government are responsible for identifying the problem and recalling the product. Yet, in the produce industry, that responsibility seems to be moving to the retailer and consumer.

It’s an unfair burden, as the retailer and consumer do not have the necessary information to make a definitive judgement regarding food safety. The responsibility needs to be shared across the entire fresh food supply chain. Records about the produce need to be shared and maintained from harvest to retail.

Will 2019 be the year that we realize we can address this challenge proactively to improve the safety of our fresh food?

We need a new approach that leverages innovative technology to provide a more reliable solution. For example, irrigation water is often identified as a culprit in spreading bacteria. Yet even with regular testing of irrigation water, the results do not currently guarantee food safety. We see emerging technology that will make regular testing more reliable, accurate and affordable to facilitate more proactive management of the water supply. This will be a critical part of an overall solution for proactive produce food safety.

Blockchain technology has been hailed as a savior of food safety and traceability. Early in 2018, it was all the rage, as various sources claimed that, by using blockchain, recall times could be cut from days or weeks to seconds. But was this an oversimplification? Perhaps so, as this early hype faded by the middle of the year amidst the various food safety outbreaks that went unresolved. Then last August, Gartner, a market analyst firm, declared that blockchain had moved into the “trough of disillusionment” on its 2018 Hype Cycle for Emerging Technologies as a result of over-hyped expectations. The firm predicts that the technology may reach the “plateau of productivity” within the next decade. Can we wait another 10 years before being able to benefit from it? Should we?

We expect that blockchain trials will continue in 2019. But, while blockchain has shown promise in terms of being a secure and immutable data exchange, questions remain. What data about the produce will be entered into the blockchain? How is that data collected? Is the data validated? Bad, inaccurate or incomplete data makes blockchain relatively useless, or worse, as it undermines a trusted platform. Further, without broad agreement and adoption of data collection, blockchain can’t be successful.

For proactive management of food safety, we will also need to address both forward and backward supply chain traceability. One of the challenges realized from recent outbreaks is that it takes time to figure out what is happening. Identifying the source of the illness/outbreak isn’t easy. Once we identify a source (or multiple sources) of the contamination, blockchain—assuming that all of the necessary data has been collected—only helps to more quickly trace back produce to its origin. But, for growers, quickly understanding where all product shipped from a specific location or date is just as critical in understanding and minimizing consumer impact. Tracing product forward enables a grower to proactively inform retailers and restaurants that their product should be recalled.

Blockchain currently does not directly support this forward tracing, but can be augmented to do so. But blockchain can maintain a food safety data item, or items, that could quickly and reliably communicate product status at the pallet-level, providing instant food safety status to the current product owner, even if they didn’t have direct contact with the grower. As such, a hybrid blockchain approach, as espoused by ChainLink Research, is optimal for forward and backward traceability.

Equally important, we need to fully digitize the supply chain to enable blockchain. To make comprehensive data collection feasible, we need to automate data collection by utilizing IoT sensors at the pallet level, to properly reflect how distribution takes place through the supply chain. We need reliable data collection to properly reflect the location and condition of product distributed through a multi-tier distribution network. That level of product data visibility enables proactive management for food safety as well as quality and freshness— well beyond the current trailer-level monitoring that only monitors transit temperatures with no benefit to managing food safety. Effective data capture will define the next generation of fresh food management, as it embraces proactive food safety, quality and freshness management.

Goals for This Year

For 2019, our goals should be to embrace new approaches and technology that:

Identify food contamination at its source and prevent contaminated food from ever entering the supply chain. We need to focus on developing new technologies that make this feasible and cost effective.
Accurately and consistently track product condition and authenticity of fresh produce from the time it is harvested until it is delivered. IoT sensors and proactive fresh food supply chain management solutions provide this capability.
Make it cost-effective and practical for growers, suppliers and grocers to use solutions to improve the entire fresh food supply chain. If we make the process burdensome or without a reasonable ROI, implementation will lag, and the problems will persist. But if we demonstrate that these solutions offer value across the fresh food supply chain—through reduced waste and improved operational efficiency—growers, suppliers, shippers and grocers will embrace them.

February 1, 2019

FST Soapbox

We Need More Qualified Food Scientists

By Moira McGrath

1 Comment

I oversee an executive search firm that specializes in placing food scientists in the food industries. In many of our searches, we are asked specifically for individuals who have food science degrees versus other scientific degrees. When we asked the universities how many students were graduating in the 33 universities approved by IFT, we received a variety of answers. So, in 2006 we started our Food Science Student Survey, asking the chairs of each of the departments to provide the answers to three questions: How many students are in the program, how many are seniors, and how many are pursuing a graduate degree. The survey has been completed every other year since 2006.

The good news is that the numbers have doubled. In 2006, there were only 462 seniors in 33 U.S. universities in food science programs. In 2018, there were 931. The departments vary in size, from UC Davis being the largest program with 249 undergraduate students in their program, to the smallest, Tuskegee University with only 15. The total number of undergraduates in 2018 exceeded 3400. This is good news for the food industry, as there has been a shortage of food scientists for many years, especially due to the baby boomers retiring. With stronger food safety regulations, and a constant need to innovate, the food industry needs more qualified food scientists. We appreciate the efforts of the universities to expand their programs.

Food Science Student Survey, OPUS International, IFT — Survey of Food Science Students in IFT-approved U.S.-based Universities (2018). Table courtesy of OPUS International, Inc.

January 25, 2019

Allergen Alley

Matrix Matters: Why Allergen Test Kits Are Only Half the Story

By Emily Kaufman

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On-site rapid tests for allergens are an important part of any manufacturing facility’s allergen control plan. Several companies offer allergen test kits for day-to-day use, and it can be hard to tell the differences between them or determine which is the best fit for a given facility. What’s a busy QA professional to do?

One of the most overlooked factors when choosing an allergen test kit actually has almost nothing to do with the test kit itself. Instead, it’s much closer to home: The matrices being tested are just as—if not more—important to consider than the test kit itself.

Before you commit to any allergen test kit, you should talk to someone extensively about the types of products you plan to test. There are a variety of surprising and counterintuitive ways that your matrices can impact the functionality of a test, and you’ll save time and money by understanding information BEFORE you start testing. Below, we’ll review some of the most common matrix challenges.

High Fat Matrices

Let’s imagine a facility that makes ice cream and sorbet. Let’s assume they make a gourmet strawberry ice cream and a fat-free strawberry sorbet, both of which ought to be peanut-free—but since some of the ingredients come from a supplier who also works with peanuts, the QA team decides to run a rapid peanut test on the strawberry products.

Much to the team’s surprise, the sorbet tests positive for peanut but the ice cream does not. What could be happening? Of course, the simplest explanation is possible: The sorbet has peanut residue in it and the ice cream does not. However, there’s another, trickier possibility: They could have the same amount of peanut residue, but the full-fat ice cream could inhibit the test kit’s ability to detect the allergen.

In general, the higher the fat content of your matrices, the higher the detection limit on your test kit. It’s an imprecise spectrum: Using rapid tests to find traces of allergenic protein on an oil is nearly impossible, on fat-rich items like ice cream or cream-based soups it’s a challenge, on items with little or no fat it shouldn’t be an issue. That isn’t to say there couldn’t be other issues with low-fat items, as we’ll review below.

Matrices Processed with High Heat

Let’s say our ice cream facility starts making a peanut-butter-swirl flavor. Perhaps they will begin testing their rinsewater for peanut residue after running that flavor, to ensure satisfactory cleaning. The kit they use says it can detect peanut allergen to 5 ppm, and rinsewater is not a high-fat matrix, so they should be good, right?

In this exact example, it’s probably just fine. However, it’s important for the QA team to consider the temperature at which peanuts were roasted. While raw peanut might be detectable at 5 ppm, roasted peanuts could have a detection limit that is much higher. In fact, very strongly roasted peanuts could only be detectable at levels of 500 ppm or more. This doesn’t mean there is no reason to test—but it’s important to know that many antibody-based tests will respond differently to an allergen processed with high heat than one that is raw. The same detection challenge can sometimes be seen with canned or tinned items that are subjected to high heat in processing.

Fermented or Hydrolyzed Matrices

Two of the trickiest items when it comes to allergen detection are soy sauce and fish sauce. In both of these condiments—and many other common ingredients subjected to these types of processing—the allergenic material is subjected to heavy modification. As proteins get folded and broken in unpredictable ways, they become more challenging for antibody-based test kits to detect. In fact, soy sauce and fish sauce are nearly undetectable by most kits.

When validating a cleaning process after using one of these ingredients, often the safest thing to do is to test for a different allergen—formulated in a simpler way—that is also present. Sufficient cleaning after a product made with fish sauce and breadcrumbs, for example, could be proven with a gluten kit; that second allergen will be unaffected by the fermented allergens in the recipe.

Matrices without Multiple Proteins

Some kits look for a variety of proteins commonly found within one allergen. Other times, though, each test kit will be looking for one specific protein. It’s important to confirm that the allergenic protein your facility works with is in fact an allergenic protein that your test kit is trained to recognize.

Perhaps the most common FALCPA allergen where this plays a role is milk. While there are a number of proteins in milk, casein is the most common and accounts for approximately 80% of the protein in milk, making it a common target for allergen test kits (both rapid and ELISA). The remaining 20% of protein is comprised of various whey proteins, most commonly beta-lactoglobulin.

In the case of our ice cream and sorbet facility mentioned above, a kit that detects casein OR beta-lactoglobulin OR both proteins together could be suitable for confirming that the sorbet is truly milk-free. However, there are other types of product that contain only whey proteins, which are a popular way to increase protein content in a variety of foods and beverages. If a facility that works exclusively with whey proteins uses a kit that only detects casein, they will never have a true understanding of their allergen contamination risk.

Another challenging FALCPA allergen is fish, as there are many different species of fish with quite divergent protein structures. If you are testing for fish contamination, it’s important to understand which species of fish the test you are considering can detect, and which species may pose a problem. If there is a mismatch between kit and matrix, then you’ll need to find a different way to ensure safety.

How to Troubleshoot Your Matrices

If you are beginning an allergen testing program, find time to talk with the manufacturers of any allergen kits you are considering. You may also want to talk with the representatives of any labs that are doing third party testing for you. Some questions to ask include:

What matrices have you validated your tests for?
Do you anticipate any issues with my matrices?
How should I validate your tests for my products?
What factors impact the sensitivity of this kit?
Does the detection limit change based on the matrix?

Your kit manufacturer (or third-party testing lab) should make you feel confident that they understand the quirks of your specific matrices—and they should have ideas for how to troubleshoot any challenges that they foresee. If a supplier tells you that their kit will work equally well across all matrices and declines to offer proof that corresponds to your needs, beware (or at least be prepared to conduct rigorous validation on your own). Allergen detection is complicated, and as with so much of life: If it sounds too good to be true, it probably is.

January 24, 2019

FST Soapbox

The Business Case for PCQI Training

By Laura Lombard

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Beyond reducing liability or checking a regulatory box, investing in robust training can reap measurable business impact. The FSMA regulation requires that Preventive Control Qualified Individuals (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,” as per Subpart C Section 117.180 (c) (1). Even if the person serving in the role of PCQI is qualified through job experience, FDA investigators will expect adherence to development and application of risk-based controls as contained in the standardized PCQI curriculum material or the alternative training allowed in the regulation.

Let’s face it: Our employees serving in the role of PCQI come from a spectrum of food safety plan experience. In addition, many are mentoring new members as Qualified Individuals on the food safety team. Others are building a whole new team from scratch. Team members may be specialized department heads or hold several titles and job duties within a manufacturing facility. Your PCQI is charged with overseeing the development and analysis of the food safety plan. The PCQI needs a team that has had consistent training in the language of the new rules and how to comply to support the PCQI’s charge.

Beyond meeting the regulation, companies should train at the PCQI level to safeguard a company’s product quality, brand and customer base. The fewer food safety-related claims you have, the more you save in costly recalls, loss of current or potential customers, and your brand’s reputation. A company with a robust safety culture has a competitive advantage over competitors who are more lax in their food safety and may suffer financially and reputationally from recalls and customer quality assurance complaints. In an era when customers are seeking more information about the food they consume, being a trusted food safety brand can make your company stand above the crowd.

In addition, consistent training can help with internal culture change and worker productivity. Working on hazard analysis and defining preventive controls requires that employees show critical thinking and problem-solving skills. Team members taking a curriculum with standardized material and consistent learning objectives can reflect together to identify and document gaps and corrections to practices or processes. They can quickly apply their learning for more accurate analysis of the components of the food safety plan. This is the true impact from investment in high quality instruction—motivating employees to learn updated food safety practices, change their behavior, and make more efficient and effective decisions to keep the quality and safety of your products. Well-trained food safety employees are a key factor in the protection of your customers, your company’s brand and the prevention of costly food recalls. The investment in training at the PCQI level is strategic on all fronts.

January 22, 2019

FST Soapbox

Architect the Perfect Food Safety Team: Does Your Next Food Safety or Quality Team Member Even Exist?

By Bob Pudlock

1 Comment

As a food safety leader, you’re accountable for keeping the company in line with regulations and ensuring consumer trust, yet you’re constantly asked to “do more with less”.

In an environment with such a thin margin for error, it’s imperative to have a seamless, friction free, fast but effective recruitment process.

As a food safety leader, you want to move the needle towards more proactive measures to optimize systems, develop more robust risk management systems and above all else get everyone in the company singing the same song when it comes to a food safety “culture”.

Bob Pudlock will be moderating the panel discussion, “Food Safety Leadership: Earning Respect”, at the 2019 Food Safety Consortium | October 1–3 | Schaumburg, ILOur three-part series on architecting the perfect food safety team will show you the components of a hiring and recruitment methodology that you can champion to your internal recruitment team, a third-party recruiter you trust, or you yourself.

Our first of three articles will focus on the IDENTIFICATION step, where, based on your job description, your compensation plan and your skill set requirements, you’ll be able to quantify the size of your candidate pool locally, regionally and nationally fast. This is really important.

Most companies don’t do this.

Internal recruitment teams aren’t optimized to do a deep dive on each job profile, whether it’s a Food Safety Specialist or a VP of Food Safety. The gap is exacerbated in food safety and quality due to the significant uptick in expertise required to execute on all the requirements that today’s food safety climate requires. Many roles that historically required only “attention to detail” and “Microsoft Excel skills” now require a microbiology or chemistry degree as well as subject matter expertise with quality management and ERP systems.

Unfortunately, your internal talent acquisition team will find it next to impossible to tell you how many SQF-certified QA managers with experience in a manufacturing setting with a Bachelors degree that reside within 30 miles of each plant in your network, much less be in a position to effectively contact and recruit them quickly.

You have to know where your future team members are today—either through internal means (your talent acquisition team) or externally(a recruitment firm)….and you can’t wait until you’ve had an unexpected resignation.

It’s like burying a fire extinguisher in your closet and not remembering where it is–if everyone in the house doesn’t know where it is, it hasn’t been tested, and it’s not located in the optimal place, it will serve no purpose when it’s an emergency.

At a recruitment firm approaching the food safety talent ecosystem and executing a search is done in much the same manner as how you develop your company’s HACCP plan.

Your HACCP plan addresses:

What threats and hazards are we trying to avoid?
What are we trying to achieve with our plan?
What does a fully executed plan entail? Safe food and…..

Similarly, we start a search with a role’s “intent” fully defined.

The “intent” of the role rarely exists in a job description—this is fleshed out when having a conversation with a client. It starts with a series of questions such as:

What is the first area of focus this person will tackle?
What problem(s) will they be tasked with solving?
What will this person’s area of focus look like after a year(best case)?

It’s an oft-overlooked step because most of our hiring managers are so busy they end up using the same cut-and-paste job description that’s been used for the last 10 years.

An example our clients have used for searches we’ve completed for them include:

“In 12 months, the new hire will have fulfilled our company’s initiative to attain SQF Certification Level III for Plant X.”
“Within 12 months, the new hire will have participated in the installation and led internal training of plant personnel; each plant team member will have been trained and passed internal testing requirements of the new system.”
“The new hire will lead improvement initiatives that dramatically improve our KPI indicators around hazardous materials and foreign objects within 6 months of hire.”

With the end result in mind, you now have a clearer picture of what you’re looking for in your new hire rather than a stale, generic job description which, oh by the way, every other company is looking for.

With a clear picture of who you’re looking for and the end results you’re looking for, the next crucial step in the IDENTIFY stage is determining to what degree that candidate exists and is available in the market.

If you create a “wish list” in a vacuum without determining how many people actually have those criteria, it’s equivalent to developing a HACCP plan without validating it.

How do you validate a HACCP plan? You test it. You challenge the thresholds. That takes time, sure, but at the end of the testing, you know where the Critical Control Points are( room for improvement), you know better what absolutely needs to be changed (Corrective Action).

How you validate your HACCP plan is similar to how we provide our clients with data that reflects the feasibility their expectations – from there, we chip around the edges of the requirements until we have a large enough candidate pool from which we can effectively execute a recruitment strategy.

For example, we’re often asked to help clients with a search that has the following particulars:

Plant QA Manager with three years of management experience
QA Manager with management experience in a food, beverage, ingredient or flavor manufacturing/processing environment
Bachelor degree in Chemistry and/or Biology
Local candidates only

Each of the four-above criteria is a “limiter” of some sort—as you work through the list and add a requirement or a “must have”, the candidate pool decreases.

In the example above, the limiter that impacts the candidate pool the most will be the last one: “Local candidates only.”

That limiter might be forced on food safety or the quality department because of budget restrictions or it may be your choice altogether. Regardless, you’ve set the parameter and now it needs to be tested. Weeks and months can be lost if the search is executed without first knowing how many candidates actually have these skills locally.

You know how it feels when Marketing calls you in to test a new innovation for a product launch, three months into the gig? How within minutes of showing up at the trial you realize that production and quality will be compromised? How you wish they would have involved you from the start so you could have saved them, the company and your team all the headaches, time and money by offering an alternative? If only they would have asked you sooner?!?!

It’s the same with a search for a candidate with a particular set of skills and/or experience that doesn’t actually exist.

So, what’s the answer?

Well, the optimal strategy is to know every single food safety / quality candidate in the local market and/or nationally (especially if your category has more stringent needs like Dairy, Brewing, etc.) and to nurture them on an ongoing basis. You’ve done the work up front to assess and determine the caliber of the local candidate pool – since you’re already in rapport with the target candidate base, the turn-around time when you’re in a pinch is significantly shorter.

When a client asks us for the requirement we outlined above, we deliver an audit of that expectation within 48 hours, letting them know if that person actually exists and how many of them.

No time is lost. We have countless examples in the last year of alerting our client that two, yes two QA director candidates have the “must have” skills locally they are requesting, and neither is interested. We get clients to that point of discovery within hours, with tangible real-live data(not opinions), where they can then reassess their requirements and expand their candidate pool.

It’s a healthy conversation when it’s done early and up front— it results in less spinning of wheels and more productive dialogue around working within capabilities and restraints.

So do that—get your talent acquisition partner and talk to them specifically about your wish list, and have them come back to you with tangible numbers that validate whether or not what you’re asking for is reasonable.

Once you’ve done that and have a large enough pool of candidates to whom you can market the opportunity, you’ll be operating from a position of strength when it comes time to ASSESS the candidates who are brought forward. We’ll dive into more about the ASSESS step in Part two of our three-part series.

January 21, 2019

Retail Food Safety Forum

How Can We Make Food Labeling More Consistent?

By Megan Ray Nichols

2 Comments

Consistent Inconsistencies

Current food labels may seem to possess a wealth of information, but they’re often challenging to read even if you know what you’re looking for. Additionally, studies have shown that even accurate food labels don’t work —they lead to no significant dietary changes. Even posting the calorie counts on fast food menus did little to change people’s eating habits.

It might sound as simple as telling consumers to read the ingredients labels on the items that they’re purchasing. The problem with this—aside from the fact that ingredients are often printed in a painfully small font—is that you almost need a degree in chemistry to understand the components. This confusion is a big issue with processed foods that contain a variety of chemicals to protect the flavor of the food and preserve it during storage.

When it comes down to it, choosing healthy foods isn’t the problem—or at least, not the only problem. Picking a healthy option isn’t as complicated as doing your taxes or choosing a mortgage when you purchase a home. We as consumers have plenty of information available to us when it comes to eating healthy. The problem is the fact that it’s easier and usually cheaper to choose the unhealthy option. You can buy a can of soda for $0.50, while a bottle of water often costs more than $1 at a soda machine or convenience store.

No One Reads Them Anymore

Another big issue with nutrition labels is that no one bothers to read them anymore. One survey found that two-thirds of young adults in the Minneapolis-St. Paul area don’t bother reading nutrition labels or worry about the nutrition content of what they’re eating.

While the survey didn’t explore why adults were no longer utilizing nutrition labeling, it’s likely due to a combination of consumer distrust and confusion. People either don’t trust that the labels contain accurate information, or they’re merely confused by the information presented in that format.

The Healthwashing Dilemma

How many times have you walked into the grocery store and chosen a brand based on whether or not it had “All-Natural” or “Organic” labels? Even if these phrases are written on the label, that doesn’t necessarily mean that the food contained within falls under either of those categories. That’s where the problem of healthwashing occurs.

Food packages will slap these labels on their product even if it doesn’t apply—a company can claim that their product is “all natural” and still use pesticides on it. Some businesses use products like pyrethrins, which are potentially dangerous pesticides derived from natural sources—specifically, the chrysanthemum flower.

Food companies don’t typically like to advertise this information because it might discourage potential consumers from choosing their brand, especially if the user is concerned about their health and is trying to remove all chemicals and pesticides from their food chain.

Fixing the Labeling Problem

What can we do to encourage consumers to pay attention to nutrition labels? The biggest challenge lies in making these labels more consistent and transparent. That task is more complicated than it sounds since there is no regulation or standardization in nutrition labeling. Clean labeling could be the solution.

Five key facets define clean labels — Simple ingredients lists, transparency in ingredients and packaging, no flowery language, accurate images and fresh food—are top priorities for consumers, with transparency being in the highest demand. However, these labels face the same problems as current nutrition labels—a lack of standardization. When asking more than 27,000 people in 31 countries what they thought clean labeling meant, more than a third had no idea, according to a report from Packaged Facts.

Many companies have started to transition to clean labels, but no law currently requires businesses to do so.

The Need for Change in Food Labeling Consistency

Food labeling could potentially help consumers make healthier choices if they were more accurate and easier to understand. Eliminating the flowery language that currently defines food labeling is one step in the right direction. The federal government— or, more specifically, the FDA— may need to step in as well to create standards that each company can be held to so that consumers know what exactly is in their food, no matter the brand.

Food labels are on nearly everything that we buy, except for fresh meat and produce. It’s time to create a standard and transparent label that everyone can understand.

January 17, 2019

FST Soapbox

Does the Sanitary Transportation Regulation Require Seals for LTL Shipments?

By Erika Miller

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This question has come up frequently in our FSMA Sanitary Transportation workshop. Just as with all the parts of FSMA, the focus of the Sanitary Transportation of Human and Animal Food regulation is on addressing hazards that may be present throughout the food chain and assigning responsibility (liability) for preventing those hazards. There are very few specific requirements—most of it is couched in very general language, for flexibility on both sides (FDA’s and industry’s).

While the regulation does not specifically address locks or seals on trailers, the FDA has stated publicly that they intend to enforce the adherence of industry to generally accepted best practices. Sometimes, as in the case of certain animal food applications, the FDA has stated they will accept mild steel transports instead of stainless (as would typically be required for hauling food) because it’s all about the risk, and mild steel is not a risk in those applications. What is the risk of an unlocked load to the food being hauled, and to the business being conducted? Maybe a seal or lock on an LTL can protect a significant investment from an identified hazard.

Generally, in most food hauling operations, seals or locks are required on trailers by businesses in order to protect their investments. They are also expected under GFSI-approved food safety management systems, used by most food manufacturers (which are private, voluntary standards, not regulatory). They are definitely required if you want to haul 100% juice under Juice HACCP and the JPA guidelines.

There are so few straightforward answers with FSMA. You must always look at your operation, your risks, and decide if controls are necessary. Document the basis for your decision, ensuring it is based on facts. If the FDA inquires, you must make your case for your decision. Do you feel comfortable defending it, all the way to a court of law if need be? If so, then stand by it.

If there are potential risks to food that is being hauled (don’t forget about defense-type risks as well, like the truck being stolen or misrepresented) then you must take reasonable, industry-standard precautions to prevent those hazards from occurring.

Of course, you want to do this anyway because it is smart business.

January 16, 2019

Food Fraud Quick Bites

Media Sources for Food Fraud Intelligence

By Karen Everstine, Ph.D.

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A recently published paper advocates the inclusion of media reports as a source of information for assessing food fraud vulnerability.¹ Those of us who maintain the Food Fraud Database could not agree more. We have been monitoring media reports for years and they are an important source of information in the database (accounting for 45% of all primary source references).

As I mentioned in last month’s post, there are challenges with using media reports to inform food fraud vulnerability. Many media reports are general discussions of the issue of food fraud and are not necessarily reporting new information. It may be difficult to filter out these types of reports without manual review. There may also be concerns about the validity of media reports on food fraud. This is the reason we implemented a classification for “weight of evidence” for incident records in the database. Overall, approximately 30% of the incident records in our database are classified as a “low” weight of evidence due to unverifiable data or a lack of corroborating reports. Some of our users choose to filter these out of their searches.

We have received requests for information about how the data in the Food Fraud Database compares with numbers reported in the paper. Table 11 in the paper described the top product categories, countries and type of fraud as reported in four food safety tracking systems.¹ We have adapted that table below to data from the Food Fraud Database.

Product Category	%	Country of Origin	%	Type	%
Meat/Poultry	18	India	26	Dilution/substitution (misrepresentation of animal origin)	26
Seafood	16	China	9	Dilution/substitution (“other”)	19
Dairy Products	14	United States	9	Dilution/substitution with a non-food substance	14
Alcoholic Beverages	6	Columbia	6	Dilution/substitution (misrepresentation of botanical origin)	12
The most common food fraud records (“cases”) in the Food Fraud Database (2014-2015)

As shown in Table 11 in the paper, the top four products by number of articles in the media monitoring system (in 2014-2015) were meat, seafood, milk and alcohol. As shown above, when looking at data in the Food Fraud Database from 2014 and 2015, the top ingredient categories are very similar: Meat/Poultry, Seafood, Dairy Products, and Alcoholic Beverages. However, there was little agreement in the country of origin of the reported cases among any of the systems. For the Food Fraud Database (shown above), the top countries of origin in 2014–2015 were India, China, the United States and Colombia. According to the paper, the top countries of origin reported by the food fraud media monitoring system were Egypt, the United States, the U.K. and Saudi Arabia. The top country of origin reported by RASFF was China and by HorizonScan was the Czech Republic.

Table 4 reported the “types” of food fraud (which correspond to what we call “reasons for adulteration”) and the corresponding number of articles collected, which we have also adapted to the data in the Food Fraud Database below.

Types of Food Fraud in Records in the Food Fraud Database (2014–2015)
Type of Food Fraud	Number of Records	%
Dilution/substitution – misrepresentation of animal origin	212	26
Dilution/substitution (other)	159	19
Dilution/substitution with a substance not approved for use in foods	118	14
Dilution/substitution – misrepresentation of botanical origin	101	12
Unknown	87	11
Fraudulent labeling	64	8
Artificial enhancement of apparent protein content	58	7
Artificial enhancement with color additives	57	7
Other	41	5
Dilution/substitution – misrepresentation of geographic origin	40	5
Dilution/substitution – misrepresentation of varietal origin	28	3
Use of unapproved biocides (antibiotics, anti-fungal agents, preservatives, etc.)	21	3
Artificial enhancement (other)	7	1
Formulation of an entirely fraudulent product using multiple techniques and adulterants	2	0
TOTAL	828	*
* Greater than 100% because one record can have multiple types of associated fraud

It is not possible to make meaningful comparisons among the reported fraud “types” without harmonized definitions and standardization of data collection processes, as noted in the paper. A glance at Table 1 from the paper illustrates the variety of food fraud categorizations in use among the various systems.¹ Generally, it is a challenge to directly compare any of the information coming from various sources such as RASFF, HorizonScan, the Food Fraud Database and others, due to the differences in the way data is collected, standardized and reported.

In contrast with foodborne illnesses, which are generally required to be reported to public health agencies, food fraud typically does not result in acute illness and is difficult to track. The nature of food fraud combined with differences in data tracking systems make it almost impossible to reconcile the data among the various systems. Regardless of which system is reporting, the reports are likely just a fraction of the true occurrence of food fraud; however, each can provide valuable perspective on risks to food safety (including those from food fraud). A holistic assessment of food fraud vulnerability should take into account a wide variety of information sources, including media reports.

Reference

Bouzembrak, Y., et al. (November 2018). Development of food fraud media monitoring system based on text mining. Food Control. Vol. 93. Retrieved from https://doi.org/10.1016/j.foodcont.2018.06.003

January 11, 2019

FST Soapbox

Glove Polymers: The Unregulated Food Safety Threat

By Steve Ardagh

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Various polymers are used in food contact applications that include food packaging and disposable gloves. More than 30 different types are used in packaging and up to six in disposables gloves. In terms of safeguards for the U.S. food supply as well as user safety, it is worth noting that 87% of the production of packaging polymers is based in the United States and subject to FDA regulation and monitoring. On the other hand, all (100%) of the 100 or more glove factories supplying the United States are based in Southeast Asia, according to a report by the British Medical Association and are not subjected to the same FDA monitoring or scrutiny.¹

Packaging production is carefully overseen by the FDA, is included in FSMA, and covered in the HACCP process. Toxicology of food packaging is carefully prescribed and subject to strict enforcement action from production to storage.

Glove factories, however, are generally self-regulated, with FDA compliance required for a rough outline of the ingredients of the gloves rather than the final product. Few controls are required for glove manufacturing relating to the reliability of raw materials, manufacturing processes and factory compliance. A clear opportunity exists for accidental contamination within the glove-making process. More significantly, because of the geographic and economic implications in workforce and workplace conditions, intentional contamination potential is greatly increased. Polymer gloves utilized in food processing and service have been implicated in 15–18% of foodborne illness outbreaks in the United States.²

There is a striking difference in the requirements for these two different types of food contact polymers. Food packaging is extensively regulated, gets tested within the context of completed food product and has production primarily in the United States under close supervision. Disposable gloves, on the other hand, rely on self certification, often with testing results only on glove constituents, and little or no oversight of factory process and conditions. It seems as though this is a glaringly obvious but little accounted for risk to the U.S. food sector.

As a result, based on the root cause analysis of food cross contamination, a selection of tests and certifications, some of which are unique to the glove industry, are being implemented by one particular glove supplier. These tests ensure that their gloves coming into the United States are made in clean, well-run factories, free of any type of contamination and are consistent in material makeup to original food safe specifications. This glove fingerprint testing program consists of a number of proprietary risk reduction steps and targeted third-party testing methods, includes gas chromatography combined with mass spectroscopy (GC/MS, surface free energy determination, in vitro cytotoxicity analysis, and microbial viability-linked metagenomic analysis.

With a great deal of faith placed on a glove supplier’s ability to deliver disposable gloves sight unseen, I believe these tests are essential to further reduce the food safety risks associated with them. Objective…Zero surprises!

References

Bhutta, M. and Santhakumar, A. (March 2016). In Good Hands. Tackling labor rights concerns in the manufacture of medical gloves. British Medical Association. Retrieved from https://www.bma.org.uk/collective-voice/influence/international/global-justice/fair-medical-trade/medical-gloves-report.
Michaels, B. (2018). Determination of the % of Foodborne Illness Outbreaks Attributed to Glove-Related Cross-Contamination. Unpublished report

The author would like to acknowledge Barry Michaels, an international scientific consultant on food safety, infectious disease transmission and glove use, who has assisted in the fingerprint testing program discussed in this column.

January 4, 2019

FST Soapbox

How Supply Chain Digitalization and Data Helps Prevent Costly Recalls

By Gisli Herjolfsson

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Recalls are something that food brands plan for but hope to never experience. They are an important public safety issue, but they also have a significant economic impact as well. At best, a product recall is a benign mistake that causes little more than aggravation and inconvenience for a few angry customers. At worst, the consequences can be tragic, both in terms of human and financial impact.

Industry research conducted by the Food Marketing Institute and Grocery Manufacturers Association places the average cost of a single recall at $10 million. That calculation includes only the direct costs of a recall. For the full, long-term costs, including direct and indirect liabilities, you’d need to further account for the immediate loss in sales, litigation costs, as well as any long-term damage caused from a loss in consumer confidence in your brand.

Consumers’ relationship with food is ever changing. They demand transparency about its contents, origin and safety, and for good reason. The World Health Organization estimates that nearly 1 in 10 people are sickened yearly from eating contaminated food, leading to 420,000 deaths. Consumers have long memories for businesses that poison them. The larger the size of your company and the more attention it receives, the potentially greater impact on your long-term business prospects. With the recent E. coli outbreaks tied to romaine lettuce, food safety is top of mind for consumers, and it is impacting entire market segments.

One of the easiest ways to prevent recalls associated with perishable foods is to ensure that food and beverage products are safely produced and continually kept at the right temperatures. Sounds easy, right? In reality, it is far from it.
Gaining end-to-end supply chain visibility can help you prevent costly recalls altogether. Data that today’s technology provides will be important for mitigating risk and protecting a brand’s reputation.

Get Proactive

The idea of prevention is paramount to FSMA. It’s clear that the FDA expects that once a producer or supplier discovers that something has gone wrong, they go back and figure out exactly what happened so that they can put measures in place to prevent it from happening again.

While current FDA guidelines and various EU safety regulations generally require that food can be tracked one step up and one step down the supply chain, this remains a very siloed approach to traceability and is open to risks—risks that producers, food retailers and restaurant brands cannot afford to take.

For USDA-regulated products, HACCP employs a similar process. Prevention is key, and if your monitoring measures miss an issue that could compromise food safety, you’ll need to go back and determine the root cause of the problem.
A cold food manufacturer can do a lot to control risks under its own roof, but how do you avoid costly recalls with ingredients or with temperature abuse after a product leaves the facility? Regulations or not, knowing where your ingredients and food products come from and being assured of their safety is critical in protecting your brand and company from the financial and reputational damage caused by a food recall.

Looking forward in the supply chain, maintaining the cold chain is necessary for many products, including fresh produce, frozen and deep frozen foods, and also those that must be kept at room temperature but still require temperature control. Even if you and your suppliers are incredibly careful and practice prudent safety measures, you may not have full visibility over who else is handling your products. If temperature mishandling by someone else necessitates a food recall or results in a food safety incident, it is still associated with your brand, even if you weren’t the direct culprit.

For many food retailer and restaurant chains, it is common practice for them to share their internal food safety guidelines with their suppliers and partners, and require that they prove a product’s source of origin, lifespan, how those products are stored and transported from point A to point B, as well as the environmental conditions in which foods are kept. Allowing suppliers and logistics partners to self-manage their supply chain does nothing to proactively ensure that they and a food brand aren’t in the headlines due to a food safety incident.

Digitally Connect the Supply Chain

This is where technology and data can play a critical role in managing your temperature-controlled food and beverage products. More and more food enterprises are utilizing Internet of Things (IoT) technologies that talk to the internet so they can collect supply chain data into dashboards and access it on demand.

IoT can be considered as a central nervous system for the supply chain. Through IoT, you can track shipments or trace temperature, moisture or other factors that can have an impact on food quality. Not only can you discover problems more rapidly with this technology, you can narrow the scope of recall. For businesses transporting temperature-sensitive products, this means they can manage product movement data in real-time and respond to issues before they lead to a food safety incident or product waste.

From a food production standpoint, IoT solutions can substantially reduce recalls from issues like labeling, processing and contamination. One of the primary causes of a food recall is microbiological in nature, with the majority of cases involving fruits and produce. IoT data can help detect issues further upstream in the supply chain and, since products will change hands several times before they reach a consumer, it can give you a complete picture of the product’s lifecycle—something that cannot be done with clipboards and ad hoc or periodic inspections.

Through cloud technology, food businesses can connect their end-to-end supply chain, analyze data, discover trends, illuminate weak points and directly respond to them to improve their overall processes.

Track and Trace Everything

Continuous and consistent tracking and tracing through technology not only simplifies recalls, it helps prevent them altogether. The only thing worse than being faced with a food recall is not knowing which products are affected or where exactly they are located.

Real-time temperature monitoring and product movement traceability technology can give you the confidence that foods are continuously kept at their required temperatures and remain safe for consumption. When you need to track and trace an ingredient or product, time is often of the essence. Delays may mean more resources and efforts are spent in producing something that may be rejected, or worse, recalled, or that the potentially impacted product isn’t isolated in time.

The digital integration of suppliers and other partners is vital if a food enterprise wants to have more control over its cold chain. Consumer demand for social responsibility and ethical business operations means that businesses need to provide greater visibility and transparency into the origins of their products. With today’s supply chains, having data—essentially, a horizontal IT layer that lets people share and access data—removes the barriers of communication among stakeholders.
IoT serves as a tool to remove the barriers to collaboration between food manufacturers, food logistics businesses, restaurant and food retail chains, regulatory agencies, and the end consumer. It increases the transparency of information and helps to deliver better products throughout the food supply chain.

Get Started

Acknowledging that most food companies have limited resources, food brands can still face their efforts only on the suppliers and customers that are of the greatest concern. Often this means looking at the combination of “high-risk product” with “high-risk supplier/partner” and prioritizing that part of the supply chain. This prioritization will help food brands allocate their resources and focus their time and money on the highest risks to their customers and brand. Once they’re able to reap the benefits of a preventive food safety program, they’re better able to justify allocating additional resources to other parts of the cold chain.

While IoT, cloud monitoring and traceability technology has been around for some time, real-time data is now becoming standard. Traditionally, the cost of IoT technology and data infrastructure could be quite expensive. However, different business models like subscription are on the rise, which lower the cost of entry for new prospects and can connect a broader range of products, not only high-value goods.

Although many food brands already have some proactive food safety programs in place, it only takes one incident to lead to a major food recall—even if it isn’t your company’s product—and it can negatively impact your business.
As an industry, food brands need to continue raising the bar in terms of what is considered standard and “best practice” when building an effective, proactive food safety strategy. Utilizing best-in-class technology can ensure the delivery of safe foods to the market, prevent recalls, protect business interests, and most importantly, protect consumers.

Will 2019 be the year that we realize we can address this challenge proactively to improve the safety of our fresh food?

Goals for This Year

High Fat Matrices

Matrices Processed with High Heat

Fermented or Hydrolyzed Matrices

Matrices without Multiple Proteins

How to Troubleshoot Your Matrices

Consistent Inconsistencies

No One Reads Them Anymore

The Healthwashing Dilemma

Fixing the Labeling Problem

The Need for Change in Food Labeling Consistency

Reference

Get Proactive

Digitally Connect the Supply Chain

Track and Trace Everything

Get Started

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