Michelle Jones, Shake Shack
Retail Food Safety Forum

Simple Food Safety Training Combats Turnover

By Michelle Jones
3 Comments
Michelle Jones, Shake Shack

Retail food establishments face many challenges, and employee retention is one of the major concerns. Employee retention affects scheduling, hiring, and the overall effectiveness of training.  Food safety training usually suffers when turnover occurs.

The safety of customers is dependent on an employee’s knowledge and execution of the food safety standards that are in place.

The biggest challenge in training in the retail/hospitality industry is the risk that the employee may leave within the first year (or less) of employment. According to Restaurant.org, the average turnover rate for the restaurant/hospitality sector was 66.3% in 2014.1 This turnover rate creates a challenge for maintaining a solid food safety culture.

Restaurants can take proactive steps to create and maintain a food safety culture that is always visible to new and current employees by adopting various techniques.

Signage Is Your Friend

Signage throughout your restaurant is a great way to continuously relay a food safety message without confining employees to a computer or module-based system.  This signage should be simple, sometimes playful and right to the point. An employee or manager takes roughly 30 seconds, on average, to read a message, so the shorter the better.

Visual signage is always a great tool to use in the back of house to relay food safety standards (e.g., proper cooking temperatures, order of storing food in coolers, etc.).  Signage (photos specifically) may also assist employees who may not communicate in English proficiently.  A picture is worth a thousand words, so utilize photos, cartoons or captions in order to relay the message.

Target the Leader

A quality assurance/food safety team should focus its training on the leaders of a region and/or district. Managers have more incentive to stay with companies longer; therefore, food safety training will be retained for a longer period. They may also visit their locations more frequently than the food safety professional, which gives them additional contact with the restaurant-level staff.

To assist these managers in their communication and verification of standards, compose a customized checklist for them to complete during a restaurant visit. The checklist should fulfill the following:

  1. Highlight the top opportunities they seek out (hand washing, sanitizer concentration, etc.)
  2. Provide the proper corrective action to eliminate the opportunities
  3. Considers their time.  A manager does not have the ability to complete a five-page checklist. Keep it simple—just the facts!

If these managers are well versed on food safety and sanitation and procedures, they will be able to hold their restaurants to a higher level of compliance.  So provide them with all of the tools they need to communicate to their employees.

Informed Employees Are Powerful Employees

Creating newsletters or publications serve as a great tool to keep employees informed of food safety policies. These articles can highlight trends in your company and new products available for use (i.e., chemicals, thermometers, etc.).

By law, every restaurant must have an area where employee information is listed (minimum wage, disability rights, etc.).  This board is the perfect place to post your publication.

In conclusion, keeping employees trained on proper food safety standards is the best way to ensure your customers are safe and your brand is protected. Implementing various forms of communication of these standards will create a strong foundation for an excellent food safety culture to exist.

Reference

  1. National Restaurant Association. Hospitality employee turnover rose in 2014.  March 11, 2015.
In the Food Lab

New Dynamics in Environmental Testing

By Erin Dreyling, Ph.D
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Recent recalls and outbreaks associated with Listeria coupled with FDA’s finalization of the FSMA preventive controls rule have heightened the industry’s need to focus on environmental testing programs. The need for a preventive control program with higher resolution is especially highlighted by the government’s increasing use of whole genome sequencing data to more rapidly link human illness to food processing establishments. I work with many customers who simply do not recognize all of the factors that influence their ability to detect Listeria in environmental samples. For many, an environmental sample is collected, shipped to a third-party lab, results are received within two to four days, and few questions asked. Most companies have not invested the time and resources needed to truly understand how each component of an environmental sample impacts their ability to detect Listeria. So what factors should be considered to maximize Listeria detection in the plant environment?

Learn innovative ways to mitigate the threat of Listeria at the Listeria Detection & Control Workshop | May 31–June 1, 2016 | St. Paul, MN | LEARN MOREListeria is a True Survivor

Listeria is inherently a hearty organism that can withstand highly adverse conditions in the plant environment. It is able to survive and grow across a wide range of temperatures, including refrigeration, and it is more tolerant to heat than Salmonella and E. coli. Additionally, the organism survives across a wide pH range, including extended periods in highly acidic conditions, and can survive food processing and preservation with up to 25.5% salt. These traits may result in highly injured Listeria being collected in environmental samples, and requires optimization of the sample collection and analysis process in order for detection and culture confirmation to occur.

Sanitation Programs May Not Destroy Listeria

Sanitation practices are intended to destroy Listeria in the plant environment, but not all sanitizers will be 100% effective. In some cases, sanitizers may not fully kill Listeria, leaving highly injured Listeria that may require an extended lag phase in order for growth and detection during testing. Sub-lethally injured Listeria remains a food safety concern, as the bacteria maintain the ability to recover and flourish in a nutritive environment. Additionally, Listeria readily forms biofilms in the plant environment, which many traditional sanitizers do not effectively remove. Biofilms in the plant environment may maintain low levels of Listeria that may be challenging to detect without the use of a sensitive detection method.

Sample Collection: Choose the Right Tool for the Job

The neutralizing and nutritive capacity of the collection media used with the collection device can have a significant impact on the ability to resuscitate, detect and culture stressed Listeria. When selecting a collection media, it is important to ensure that the media will effectively neutralize the sanitizers used in the plant environment. For instance, peroxyacetic acid and quaterinary ammonia-based sanitizers will not be neutralized well by commonly used collection media such as Neutralizing Buffer or Letheen Broth. Neutralization of the sanitizer in environmental samples is important in order for resuscitation and growth of any Listeria present within the sample. Additionally, use of a collection media that contains nutrients to begin the resuscitation process for Listeria immediately upon collection is also important for detection and culture confirmation of Listeria in samples. Collection media such as Neutralizing Buffer contains monopatassium phosphate, sodium thiosulfate, and aryl sulfonate complex intended only to neutralize sanitizers. Conversely, D/E Broth and HiCap Broth have components to nourish Listeria and facilitate resuscitation in addition to neutralizing sanitizers.

Enrichment Media Determines Recovery & Growth

Enrichment media plays a major role in the speed of recovery and growth of Listeria in environmental samples. Medias that facilitate faster recovery of injured Listeria allow for shortened lag phases facilitating more rapid growth. Enrichment media that facilitate faster recovery and growth allow Listeria to reach the limit of detection for screening tools more quickly. When paired with a highly sensitive method, enrichment media, which foster greater Listeria growth and recovery, can allow for significant reductions in time to results for screening methods. Additionally, faster recovery and growth of Listeria due to enrichment media can increase the likelihood of culturally confirming Listeria found at low levels pre-enrichment.

Not All Detection Methods are the Same

The ability of a detection method to find Listeria in an environmental sample is impacted by two factors: 1) method sensitivity and 2) method robustness in the presence of sanitizers. The more sensitive a rapid test method, the greater the chance of finding low levels of Listeria in an environmental sample. Low levels of Listeria in environmental samples are likely due to the injured state of Listeria in the plant environment post sanitization. Immuno-based rapid methods have a sensitivity of 105–106, DNA-based methods have a sensitivity of 104–105 and RNA based methods have a sensitivity of 102–103. Using an RNA-based method offers 1 to 2 logs greater sensitivity and greatly increases the chance of finding low-level Listeria.1 This can be particularly true when sampling conditions such as collection media or enrichment media are less than optimal for the neutralization of sanitizers and growth and recovery of Listeria.

Another important factor that influences a test method’s ability to detect Listeria in an environmental sample is the method’s ability to amplify and detect the organism in the presence of sanitizers. Most molecular-based methods do not include a sample clean up step resulting in sanitizer being present during the amplification step. For some methods, sanitizers may inhibit amplification, resulting in indeterminate or false negative results.

Confirmation Requires Optimization of the Sampling Process

The ability to culturally confirm a Listeria sample that screens positive is influenced by the entire environmental sampling process. In order to culture confirm samples with highly injured, low-level Listeria, it is necessary to optimize the sample collection media, enrichment media, and confirmation process to provide the greatest likelihood of culture recovery. If Listeria is not adequately resuscitated and able to achieve sufficient growth, the level of Listeria present in the sample post-enrichment may be below the limit of detection for culture. The likelihood of culture confirmation can be increased by incorporating steps such as a secondary enrichment or concentration via IMS capture. Culture confirmation for samples that screen positive on a rapid method can be especially challenging if a highly sensitive test method is used for screening that may detect Listeria at lower levels than culture. Thus, optimizing the environmental sample program is especially important if confirmation of screening results for highly sensitive methods is desired.

Method Sensitivity and Increased Positivity

Employing a highly sensitive screening tool for environmental samples provides a better lens to view risk within the food safety processing environment. Many companies fear that a more sensitive method will result in significant increases in positivity and cost for increased sanitation. In working with customers who have moved from immune-based methods to a highly sensitivity molecular method, I’ve observed an initial increase in positivity followed by a leveling off of low-level positivity after enhanced interventions are taken in the plant. Companies that proactively seek out and destroy Listeria in their plants are then able to maintain low level rates of positivity with routine cleaning measures, while also maintaining the confidence that they are using the best tool available for Listeria monitoring.

Understand Your Risk & Establish a Culture of Food Safety

It is important for food safety professionals to fully consider the hidden risks that may exist in their plant environment due to the environmental sample process masking the true presence of Listeria. Each component of the environmental monitoring process, sanitizer, collection media, enrichment media, detection method and culture process plays an important role in a company’s ability to be able to detect and culture confirm Listeria in the plant environment. Optimizing each step within the environmental sample process allows a company to be proactive instead of reactive. This approach creates a company culture of food safety that can seek out, detect and destroy Listeria in the plant environment, can significantly mitigate risk. The good news is that by incorporating the right food safety culture and making data-driven choices, today’s manufacturer can achieve both short-term dividends of risk reduction as well as a long-term elevation of control of its process.

Reference

  1. Culture Shift: The New Dynamics of Listeria Environmental Control and Testing. Roka Bioscience, Webinar.
Deirdre Schlunegger, CEO of STOP Foodborne Illness
Food Safety Culture Club

Listeria: The Stories

By Deirdre Schlunegger
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Deirdre Schlunegger, CEO of STOP Foodborne Illness

Listeriosis is serious. As defined by the CDC, the infection usually occurs as a result of consuming food contaminated with Listeria monocytogenes. It mainly affects the older population, pregnant women, newborns, and those who are immunocompromised.

Learn more about how you can address Listeria in your facility at Food Safety Tech’s Listeria Detection & Control Workshop | REGISTER NOWThe following are stories of those affected by Listeria. They are devastating, filled with sadness, and associated with tremendous loss.

  • Laureen and her husband Steve were expecting their first child. She was due on April 10, and on September 11, they heard their child’s heartbeat for the first time. On September 25, Laureen felt ill and on September 29 she went to the doctor’s office where she was diagnosed with a cold and sent home. A few days later, Laureen went to the emergency room with a fever of 102.6 degrees.  After the hospital ran some tests, Laureen and Steve were again sent home. However, later that night Laureen began experiencing more symptoms, and she returned to the emergency room and was hospitalized.  On October 5 she had a miscarriage and was told it was due to Listeriosis. They named their baby girl Zena Rose Spitz.
  • Lynn was six months pregnant and on Labor Day, she had flu symptoms. After feeling ill for a few days, she went to the doctor and was told to go to the emergency room right away. The faces of the doctors reflected grave concern. It was decided that they would perform a C-section that night. At 27 weeks, they were told the chances of survival were slim. Lynn’s survival was at risk as well. Their daughter was born with an Apgar score of 2. Her name was to be Julia Patricia. In NICU, Julia underwent many tests and procedures, and her parents were told that Julia was very sick. At one point a priest was called for last rites. Julie stabilized only after many close calls, and her parents were told that Listeria was the culprit. Today Julia has many physical challenges.
  • Michael was born to Stephanie and Michael at 30 weeks of pregnancy with an Apgar score of 2.  Infectious disease reported that the cause of Stephanie and son Michael’s illness was Listeriosis. Sweet little Michael died in Stephanie’s arms as she rocked him to sleep, wrapped in a not-yet-finished baby blanket that her mom had been knitting for her first grandchild. Stephanie had eaten contaminated lettuce.
Shawn K. Stevens, Food Industry Counsel
Food Safety Attorney

The Criminal Offensive Begins

By Shawn K. Stevens
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Shawn K. Stevens, Food Industry Counsel

FDA intends to pursue criminal investigations against any food company executives or quality assurance (QA) managers involved in cases in which a link is made between a positive sample collected by the agency from a food facility or product and a foodborne illness.

In fact, the agency and the U.S. Department of Justice just announced that they will be working together to aggressively enforce food safety laws, including the Food, Drug and Cosmetic Act. In prepared remarks at a food safety conference last week, Benjamin C. Mizer, principal deputy assistant attorney, indicated that criminal prosecution of food companies is a priority moving forward. “When it comes to food safety, we have to rely on the companies who manufacture and distribute food to ensure that the food we buy is safe,” Mizer stated in his remarks. “That is why food safety is a priority for the Justice Department.  Our role in protecting consumer safety is at its apex when consumers can least protect themselves.”

In addition, the FDA is exercising nearly limitless authority to access company records during an inspection and investigation—and in many cases doing so without a warrant.

The Park Doctrine. In 1975, the Park Doctrine solidified FDA’s authority to criminally charge corporate executives and high-level managers. The Supreme Court upheld the conviction of the president of a major grocery chain who was found to be criminally liable for unsanitary conditions existing in a company distribution center, notwithstanding the argument that he had delegated the responsibility for maintaining the cleanliness of the site to his subordinates. The Supreme Court concluded that if a company ships adulterated food, the management of that company can be charged, even if they have no direct knowledge or intent. Under this standard, a food industry executive or QA manager can be sentenced to prison if he or she is aware of a circumstance or condition within his or her facility that could lead to a foodborne illness and fails to take action to correct it. If charged with this type of misdemeanor, the executive could be sentenced to up to a year in prison and a $250,000 fine for each count. On a case-by-case basis, FDA will consider the individual’s position within the company, his or her relationship to the violation, and whether in fact he or she was in a position (or had the authority) to correct the violation. The government is demonstrating that it intends to use criminal sanctions to create a deterrent and compel compliance.

Peanut Corporation of America (PCA): Salmonella outbreak (2008). PCA owner Stewart Parnell was sentenced to 28 years in prison for knowingly selling peanut products contaminated with Salmonella. His brother, a peanut broker, was sentenced to 20 years, and Parnell’s QA manager was sentenced to five years.

Quality Egg: Salmonella outbreak (2010). Quality Egg distributed products linked to a Salmonella outbreak that sickened more than 1,000 people. Company executives did not know that their products were sickening consumers but were nevertheless cited by FDA for failing to control Salmonella in the growing and processing  environment.  When the outbreak was over, FDA conducted a criminal investigation, and company executives were sentenced to three months in jail and slapped with significant fines for food safety violations.

Learn new and innovative approaches to Listeria detection & control at Food Safety Tech’s workshop | May 31–June 1, 2016 | St. Paul, MN | LEARN MOREJensen Farms: Listeria monocytogenes (2011). The company distributed cantaloupe contaminated with Listeria monocytogenes and, over a two-month period, the tainted product sickened nearly 150 people and killed more than 30. Company owners were unaware of product contamination, but federal prosecutors brought criminal charges against the company regardless, arguing that Jensen Farms failed to take appropriate steps to reduce Listeria contamination in its facility. Company owners were sentenced to five years’ probation, six months’ home detention, 100 hours of community service, and assessed individual fines of $150,000.

ConAgra: Salmonella (2006­–2007). In 2014 FDA urged criminal charges be brought against ConAgra for distributing Salmonella-contaminated peanut butter, which sickened about 700 people, between 2006 and 2007. The company pled guilty to the charges and paid more than $11 million infines.

On May 2, 2014 FDA announced its intent to pursue “[c]riminal prosecution for falsifying records, lying to FDA, knowingly putting consumers at risk, or in other appropriate cases.”

Blue Bell: Listeria monocytogenes (2010–2015). In 2015, Blue Bell Creameries was linked to an outbreak in which FDA connected positive samples from those taken at retail and those taken at production facilities to seven case patients in the CDC database who carried the same strain of Listeria. Last year the agency urged the company to recall all of its products. What’s most concerning about the investigation is the fact that the first people who became sick fell ill more than five years ago (January 2010); two more illnesses were recorded in 2011, followed by one in 2012, and three in 2014. The final illness was reported January 2015.

The U.S. Department of Justice (DOJ) confirmed that FDA and the DOJ are making criminal sanctions “a priority” when companies “fail to live up to their obligations to protect the safety of the food that all of us eat.” The DOJ, working with FDA, has served federal grand jury subpoenas to Blue Bell, and is likely scanning food company records and executive emails to justify any criminal charges. If criminal charges are indeed brought against Blue Bell, FDA will likely argue that the company was periodically finding LM in its facilities over the past five years and failed to take sufficient action to correct the condition, which (as proven by the seven matching cases in PulseNet ),  resulted in human illness. Although this seems like an extreme approach, given the ubiquitous nature of LM, it is the approach the agency is aggressively pursuing.

Chipotle Mexican Grill: Norovirus (2015). For several months last year, Chipotle was unable to contain and manage numerous foodborne illness outbreaks. In a public filing the national restaurant chain confirmed that it received a federal grand jury subpoena from the DOJ in connection with a norovirus outbreak that occurred at a location in which more than 200 customers became ill.

According to reports, Chipotle executives became aware that numerous employees had reported being sick in August 2015, yet they waited a few days before informing the local health department of the illnesses and closing the restaurant. In turn, it appears that FDA and the DOJ initiated a criminal investigation and served the grand jury subpoenas in order to gain access to corporate emails and determine whether company executives waited “too long” after learning about the illnesses to take action. On January 28, officials from Chipotle confirmed that the restaurant chain was served with a subpoena that broadened the scope of the initial criminal investigation by the U.S. Attorney’s office for the Central District of California. This subpoena requires Chipotle to produce documents and information related to company-wide food safety matters dating back to January 1, 2013, and supersedes the subpoena served in December 2015 that was limited to a restaurant in Simi Valley, California. Although FDA is trying to uncover how the recent outbreaks occurred, the agency is also engaging in a broader “fishing expedition” to determine whether there is further justification to bring criminal sanctions as a result of any of the company’s broader food safety conduct.

Multiple Non-public Cases

The DOJ, in cooperation with FDA, is currently pursuing criminal investigations against many other companies connected to other reported illnesses. As these are ongoing investigations, the underlying facts cannot be disclosed publicly. However, the most important lesson to be learned is that food companies must be prepared to better control pathogens in their environment in order to protect themselves from criminal prosecutions. My subsequent column will discuss these strategies.

FST Soapbox

Intelligent Algorithms Shape Food Safety

By Steven Burton
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The North American food safety testing market is projected to reach $16 billion by 2020, according to a recent study by Markets and Markets. In just a few short years, it’s safe to say that purchasing a software solution to create and manage food safety programs will become ubiquitous, equivalent to that of employing any other software tool such as Microsoft Excel.

However, there is a broad range of capabilities for food safety software, and some solutions are much more complex than others. Many types of HACCP software operate as part of an ERP system, merely managing documents online under IT administration. But the technological capabilities of a food safety management system are endless in terms of value-driven innovation. Any competitive software on the market should go further, and be flexible and agile enough to meet and contain the challenges of a changing regulatory landscape and aggressive market space.

One of the ways food safety management can take things further is through the use of intelligent algorithms that can help food safety professionals get the most out of their software—and their HACCP plan. For example, instead of manually searching for all the physical, chemical and biological hazards (as well as radiological hazards under HARPC), intelligent algorithms can use data from other HACCP plans to suggest hazards. By comparing facility types, process flows, ingredients and more, a sophisticated algorithm can make smart suggestions that give food safety professionals a significant leg up, cutting down research time and providing a context of learning since it’s much easier to learn by example than starting from scratch. As such, suggestions can equip food safety professionals with the right mindset to discover potential hazards.

There are core benefits to searching for software technologies that have intelligent algorithms in place to analyze and retrieve data for those food businesses looking to get the most long-term value out of their vendor purchase.

Facilities with High-Risk Products and Complex Process Steps

High-risk foods are defined by the FDA as foods that “may contain pathogenic microorganisms and will normally support formation of toxins or growth of pathogenic microorganisms.” High-risk foods include raw meat, poultry, fish, dairy, fresh fruit, and vegetables, and processors working with these products handle more hazards and process steps in general than processors making low-risk foods. Instead of sorting through hundreds of hazards, facilities with high-risk products and complex process steps are able to skip much of the manual grunt work and simply select automatically generated hazards and process steps suggested to them at their fingertips.

Small Business Owners or Basic Food Safety Professionals

It’s common for small food businesses to put the bulk of their food safety duties on the shoulders of the owner. For many who have no previous background in food safety, there can be an unexpected and frustrating learning curve to overcome before you can pay the sweat equity required to develop a HACCP plan, and not for lack of trying. Similarly, junior food safety employees in new facilities can find established food safety practices challenging to navigate. Through intelligent algorithms, a software system can reinforce food safety hazards and process steps that might have been missed or forgotten by making them instantly available for retrieval and selection.

Giving Back Time

Recordkeeping is an essential component to an excellent food safety culture. In the grand scheme of things, managing resources to allocate time to high-level tasks that require human expertise on the production floor is a critical activity that most food safety professionals prioritize. Having more time to correct potential risk actions is crucial to ensuring the lowest possible likelihood of a recall. Smart software systems facilitate better employee time management practices so they can maximize their hours for meaningful, rather than menial, work. By taking back the time that would have been spent researching hazards, smart suggestions provide food safety professionals with a starting point that allows them to choose from a curated selection without delay.

Experimental Facilities with Changing Product Portfolio

Facilities that have a tendency to experiment with product development (i.e., food startups) are prone to using a significant amount of ingredients and formulas. When it comes time to present the right information for inspections and audits, this translates into a substantial amount of additional work in maintaining a HACCP plan. Intelligent algorithms enable a clear and organized focus, eliminating the minutiae surrounding information management of experimental product development.

New Regulations and International Compliance

Around the world new regulations surrounding acceptable food safety documentation are coming into effect; notably, FSMA even adds to the traditional hazards included under HACCP. For foreign exporters as well as American businesses, regulatory expectations for a more comprehensive approach to hazards and critical control points are higher than in the past. In the face of new regulatory demands, smart algorithms help food businesses lay out a common framework so that they can build internationally compliant programs

Extra Safeguard Check

Human error is inevitable. The beauty of technology is that it acts as a safeguard to ensure there are no glaring omissions that may have an impact on food safety duties. As a final once-over before sending in the HACCP plan, it makes good sense to have smart suggestions to cover all the bases.

Intelligent algorithms allow food safety professionals to do more with their time. By selecting from suggestions related to ingredients, materials, packing and process steps, a considerable amount of time is restored to the work day compared to the time-consuming exercise of manually assembling lists. The main benefit to a food safety software solution with intelligent algorithms is to reinforce the right mindset for listing physical, chemical and biological hazards for ingredients, material, processes and beyond. While smart suggestions should always be verified by a food safety professional familiar with the internal operations of a facility, for companies that aim to work smarter but not harder, smart algorithms are a key feature to keep in mind when researching software vendors.

Shawn K. Stevens, Food Industry Counsel
Food Safety Attorney

FDA’s Tactics to Reduce Outbreaks and Recalls

By Shawn K. Stevens
1 Comment
Shawn K. Stevens, Food Industry Counsel

The advent of PulseNet in the late 1990s enabled more effective identification of outbreaks, even as many of them overlapped. The database brought to light the fact that many of the products sold in commerce nationwide contained ingredients that were at risk of contamination with dangerous pathogens. In many instances, these ingredients were in products from a single lot or batch and then sold by a single supplier to dozens of customers. From there, they were used in hundreds of products that would be distributed into thousands of retail locations.

Attend Food Safety Tech‘s Listeria Detection & Control Workshop | May 31–June 1 in St. Paul, MN | LEARN MOREFDA created the Reportable Food Registry (RFR) as a way to prevent the shipment of contaminated ingredients into the food supply. If received ingredients or products test positive for contaminants, the RFR requires that the company inform FDA. The agency uses the reports to take regulatory action against the original supplier and requires that all ingredients or products from all potentially affected lots be recalled from commerce. Because the RFR allows FDA to immediately begin tracking and containing ingredients testing positive for pathogens, its introduction in 2009 resulted in a significant spike in recalls.

Driven by the recalls triggered by PulseNet and the RFR, a national perception about an extremely unsafe U.S. food supply began to emerge. The public and media demanded that Congress take action, and so FSMA was born. The regulations require all FDA-regulated food companies to develop and implement written preventative control programs designed to control pathogens and other hazards in food. As a result, food companies will face heightened regulatory risk, scrutiny and exposure.

To further decrease the incidence of outbreaks and recalls, FDA is implementing regulatory enforcement initiatives that include sampling food products at retail for the presence of pathogens; conducting microbiological profiling of food processing facilities during routine inspections; and exploring criminal sanctions against companies that have been linked to positive samples in food products or production facilities associated with an outbreak or foodborne illness.

Microbiological Sampling in Retail

FDA is sampling products intended for human consumption as well as those for animal consumption. As testing continues at the retail level, the likelihood of more food products testing positive for the presence of pathogens is much higher. When positive product samples are found, FDA will take immediate action against the company that processed the product and require the company to recall all affected product. The agency will also demand access to the production facility at issue and conduct extensive environmental sampling, including from drains, floors, walls, production equipment, and finished products, in an effort to find the same strain as the sample testing positive at retail.  If product or environmental samples test positive, FDA will perform genetic DNA testing on the isolates and compare the DNA fingerprints against those of the isolates collected from sick case patients in PulseNet over the past 15 years. If a match between the DNA fingerprint and an illness(es) in PulseNet is found, the agency will presume that these illnesses were caused by product originating from that particular facility. FDA will also demand access to all food production and microbiological testing records from previous months, or years, and critique those records.

Microbiological Sampling in Food Production Facilities

In accordance with FSMA, FDA will inspect all food production facilities (drains, floors, walls, food processing equipment, and finished products) that process high-risk ingredients or food products within the next three years (lower risk facilities will be inspected within the next five years). The agency is also performing extensive microbiological profiling of the food processing environment in all production facilities during routine inspections. If a positive sample is found, FDA may require the company to recall the affected product. It is expected that the level of sampling will intensity in the coming months and years as a result of FSMA mandates. And as the extensive microbiological sampling in food production facilities continues, FDA will perform genetic DNA testing on any positive samples collected, once again comparing the DNA fingerprints of samples against those of sick case patients over the last two decades. If a match is found, FDA will take the same course of action as in retail and presume all illnesses were caused by a food product originating from that specific facility. When that occurs, in addition to the potential recalls that may be required, the food companies at issue may become the target of a criminal investigation as well.

My next column will cite recent examples of FDA’s criminal offensive against food companies.

Steven Guterman, InstantLabs
In the Food Lab

Save Seafood with Digital Tracking

By Steven Guterman, Sarah McMullin, Steve Phelan
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Steven Guterman, InstantLabs

The combination of improved digital tracking along the food supply chain, as well as fast, accurate DNA testing will provide modern, state-of-the-art tools essential to guarantee accurate labeling for the ever-increasing quantities of foods and ingredients shipped globally.

The sheer scale of the international food supply chain creates opportunities for unscrupulous parties to substitute cheaper products with false labels. We know fraud is obviously a part of the problem. Some suppliers and distributors engage in economically motivated substitution. That is certain.

It’s equally true, however, that some seafood misidentification is inadvertent. In fact, some species identification challenges are inevitable, particularly at the end of the chain after processing. We believe most providers want to act in an ethical manner.

Virtually all seafood fraud involves the falsification or manipulation of documents created to guarantee that the label on the outside of the box matches the seafood on the inside. Unfortunately, the documents are too often vague, misleading or deliberately fraudulent.

Oceana, an international non-profit focused solely on protecting oceans and ocean resources, has published extensively on seafood fraud and continues to educate the public and government through science-based campaigns.

Seafood fraud is not just an economic issue. If the product source is unknown, it is possible to introduce harmful contamination into the food supply. By deploying two actions simultaneously, we can help address this problem and reduce mistakes and mishandling:

  • Improved digital tracking technologies deployed along the supply chain
  • Faster, DNA-based in-house testing to generate results in hours

Strategic collaborations can help industry respond to broad challenges such as seafood fraud. We partner with the University of Guelph to develop DNA-based tests for quick and accurate species identification. The accuracy and portability produced by this partnership allow companies to deploy tests conveniently at many points in the supply chain and get accurate species identification results in hours.

Our new collaboration with SAP, the largest global enterprise digital partner in the world, will help ensure that test results can be integrated with a company’s supply chain data for instant visibility and action throughout the enterprise. In fact, SAP provides enterprise-level software to customers who distribute 78% of the world’s food and accordingly its supply chain validation features have earned global acceptance.

The food fraud and safety digital tracking innovations being developed by SAP will be critical in attacking fraud. Linking paper documents with definitive test results at all points in the supply chain is no longer a realistic solution. Paper trails in use today do not go far enough. Product volume has rendered paper unworkable. Frustrated retailers voice concerns that their customers believe they are doing more testing and validation than they can actually undertake.

We must generate more reliable data and make it available everywhere in seconds in order to protect and strengthen the global seafood supply chain.

Catfish will become the first seafood species to be covered by United States regulations as a result of recent Congressional legislation. This change will immediately challenge the capability of supply chain accuracy. Catfish are but one species among thousands.

Increasingly, researchers and academics in the food industry recognize fast and reliable in-house and on-site testing as the most effective method to resolve the challenges of seafood authentication.

DNA-based analyses have proven repeatedly to be the most effective process to ensure accurate species identification across all food products. Unfortunately, verifying a species using DNA sequencing techniques typically takes one to two weeks to go from sample to result. With many products, and especially with seafood, speed on the production line is essential. In many cases, waiting two weeks for results is just not an acceptable solution.

Furthermore, “dipstick” or lateral-flow tests may work on unprocessed food at the species level, however, DNA testing provides the only accurate test method to differentiate species and sub-species in both raw and processed foods.

Polymerase chain reaction (PCR), which analyzes the sample DNA, can provide accurate results in two to three hours, which in turn enhances the confidence of producers, wholesalers and retailers in the products they sell and minimizes their risk of recalls and brand damage.

New technology eliminates multi-day delays for test results that slow down the process unnecessarily. Traditional testing options require sending samples to commercial laboratories that usually require weeks to return results. These delays can be expensive and cumbersome. Worse, they may prevent fast, accurate testing to monitor problems before they reach a retail environment, where brand and reputational risk are higher.

Rapid DNA-based testing conducted in-house and supported by sophisticated digital tracking technologies will improve seafood identification with the seafood supply chain. This technological combination will improve our global food chain and allow us to do business with safety and confidence in the accuracy and reliability of seafood shipments.

Zia Siddiqi, Orkin
Bug Bytes

How to Find the Right Pest Management Partner

By Zia Siddiqi, Ph.D.
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Zia Siddiqi, Orkin

When you choose a new vendor to partner with you, the decision is always important. Every vendor plays a role in your business and bottom line.

Some vendors, like pest control providers, can protect your brand and even help boost your reputation in the industry. When you factor in everything your pest control program can affect, it’s clear that picking the right pest management provider is one of the most important vendor decisions you’ll have to make.

Under FSMA, food processing facilities must execute proactive pest control programs and documentation efforts that not only follow and but also implement a risk-based prevention program to protect their product and consumer base
Under FSMA, food processing facilities must implement proactive pest control programs  and a risk-based prevention program to protect their product and consumer base. Image courtesy of Orkin.

Consider how pest management can impact your audit scores, especially when you’re expected to be audit-ready at any time. The success of your third-party audit hinges on documentation, and the pest management portion can make all the difference in your score, accounting for up to 20%. FSMA requires food processing facilities to execute proactive pest control programs and documentation efforts that not only follow and but also implement a risk-based prevention program to protect their product and consumer base. Just one low score can cause your customers to lose trust in your business—and if they pull their support, you could see a major impact on your balance sheet.

The safety of your products and even the health of your employees are also at stake. Cockroaches and ants can pick up and transfer harmful bacteria. Flies can spread disease-causing organisms when they land—and they land frequently, it can lead to them leaving their traces in an abundance of places.

Then there are rodents, which can also cause serious health problems. According to the Centers for Disease Control and Prevention, rats and mice are known to spread bacteria like Salmonella and E. coli, as well as more than 35 diseases worldwide, such as Hantavirus.

A Blueprint for Success

From its impact on audit scores to its role in abating health concerns to brand protection, pest control should be a priority for any food processing facility. There are several best practices to follow, most of them falling under the umbrella of Integrated Pest Management (IPM). IPM is the preferred proactive pest management practice in the food processing business, and it can help meet and exceed the requirements of industry auditors.

IPM programs are ongoing, comprehensive and well-documented, focusing on risk-based preventive strategies like sanitation and facility maintenance to help prevent pest activity. They’re also customizable based on your property and the pests you face.

It’s essential to find the right, licensed and experienced pest management professional who will partner with you and your staff to implement a customized IPM program for your facility and help keep pest problems away. When starting your search for a pest management partner, be sure to ask about IPM. One-size-fits-all pest management solutions are simply not effective, so look for a provider who can tailor an IPM program specifically to your needs.

When searching for a pest management partner, look for one that stands out with the following guidelines.

Talk to your peers. If you’re looking for pest management recommendations, start by talking to your industry colleagues about the successes—or challenges—they’ve had with their vendors. If you’re a member of a larger network or GPO, you may have a preferred provider in which to start your search.

Start with an inspection. Once you have a list of options to check out, it’s time to put them to the test. As IPM programs are customizable, insist that your prospects inspect your facility to determine the challenges you face and the services you need.

Get the details in writing. Remember, FSMA requires written risk-based preventive food safety plans that detail likely hazards, corrective actions and results. With this in mind, your pest management professional should thoroughly document any service visits and corrective actions.

Documenting your pest management plan does more than fulfill the FSMA requirement. The best pest management providers will document their every move, using the information to determine pest trends, which can aid in decisions about how to best manage pest activity going forward. These records should be kept on-site for any surprise audits.

Ask for audit help. In addition to documentation, your pest management professional should work with you to ensure all documents are in proper order and audit-ready at any time. Look for a provider that can help you prepare for the third-party auditor and food safety standards with which your facility is required to comply, and even provide on-site support the day of your audit.

Think about your entire staff. One of the most overlooked variables when choosing a pest management provider isn’t how the company works in your facility, it’s how it works with your staff. For your new pest management program to be effective, your staff has to buy in—and your new provider can help.

Your employees play an important role in reporting pest sightings and keeping your facility clean. With this in mind, make sure to ask about resources that your pest management professional can offer your staff. Many offer staff training and educational resources like tip sheets and checklists, and often at no extra cost.

Add accountability, establish thresholds. You may pick an outstanding pest management partner, but ideal results won’t happen overnight. Depending on your facility, creating a pest-free environment can be difficult, even with the best of help.

Progress is achievable and quantifiable when you have pest thresholds. Thresholds dictate how much and what kind of pest activity is acceptable before corrective actions need to be taken, and they are best set by working with your pest control professional because several factors can come into play.

Older facilities or buildings in environments more conducive to pest activity, such as areas near water, locales in warm environments or heavily wooded spaces, may face more pest pressures than newer establishments. Your pest management professional may want to counter these challenges with exclusion recommendations that can include extensive building maintenance and repairs.

If you’re in a newer building and don’t currently battle any present pest issues, it may be perfectly reasonable to move forward with a “one pest is one too many” threshold. To make sure your program stays this effective, your provider may need to adjust tactics of your IPM program over time.

Even with a sound IPM plan, however, if you are currently battling pests like cockroaches, flies or ants, reaching your threshold goals will take time. Work with your pest management provider to create a timeline for steady and reasonable improvement.

Once you choose a pest management partner, keep the lines of communication open and establish roles for everyone involved. Set benchmarks for your pest management program and specific times throughout the year to evaluate the program’s success and areas of improvement with your provider.

Keep all of this in mind, and you can help build a solid, long-lasting partnership. As a result, pest sightings can fall as your audit scores rise.

Gina Kramer
Food Safety Think Tank

Mobile Technology Could Help Your Business in an Outbreak

By Gina R. Nicholson-Kramer
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Gina Kramer

Join Gina Kramer at the Listeria Detection & Control Workshop, May 31–June 1 in St. Paul, MN | LEARN MOREI recently spoke with Wes Billingslea, one of the co-founder’s of Till Mobile Corp., a company founded because its team realized large brands needed to connect all the way down to the smallholder and grower level. There are more than 6 billion mobile devices on earth and only a small percentage of them are smartphones. Till uses voice, text, and SMS-mobile to enable two-way communication with smallholders, and to deliver visibility and traceability. The company is able to collect massive amounts of data from growers because there is no resistance to using mobile phones. It works with your existing systems to identify and fill data gaps that create risk. The big brands access detailed analytics and can communicate directly throughout their supply chain to accelerate supplier onboarding, support local and alternate sourcing, and check inventory, pricing, and food safety standards.

I asked Wes, as a food company, how could this technology save me money? To start, it allows you to check inventory and pricing, and helps you adhere to your food safety standards beyond the packinghouse or distributor. It can also help you get more out of your existing systems to protect your IT infrastructure.

In the following video, we discuss the Salmonella outbreak in cucumbers that occurred last summer. In such a scenario, this new technology could help save food retailers money during an outbreak or recall by giving them greater visibility and real-time data, and help them source alternatives directly.

FST Soapbox

Inquiries, Responses and Audits: The Chipotle Effect

By Dan Bernkopf
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In an age where news is reported instantly, those outside the food industry have a heightened awareness and concern over their favorite brands’ commitment to food safety. Conversely, every food industry’s safety and quality operations teams are more than likely putting measures in place to tighten up their supply chain controls and re-evaluate their own food safety programs to ensure that their companies don’t become the next headline.

You better believe suppliers and their customers alike are also re-evaluating their ability to quickly, and effectively, respond to such an incident with the data and records needed to determine root causes—and with good merit, especially if you take a step back and really think about what is needed when a response or inquiry comes in surrounding a Chipotle-type food safety incident. Responses to such incidents typically fall along the lines of: 

  • Evidence of current food safety plan, including comprehensive risk analysis, HACCP/HARPC plan, validation studies or documents
  • Inspection data and documents on your suppliers, including onsite inspection, transportation and product receiving inspections, complete with non-compliance reports and CAPAs for the last six months
  • All data records relative to your internal processing CCP(s) or equivalent, including monitoring frequencies and all non-compliance reports, complete with their CAPAs for the last six months
  • All regulatory and non-regulatory audit reports or actions, including non-compliance reports and their CAPAs
  • Additional available internal or external laboratory evidence that demonstrates environmental monitoring of your facilities and resulting continuous improvement and sanitation validation for the last two years
  • Additional internal or external laboratory pathogen monitoring programs for field, transportation, raw material supply and finished products, etc. as evidence to support your food safety program

The sheer volume of records, data and information needed in such an on-demand short timeframe can be extremely overwhelming. Without quick access to the critical records needed to determine root cause or, more importantly, thwart an incident from expanding, food safety and quality operations should be taking a close look at how they are managing their food safety data records and reports.

Are binders full of documents, or a combination of paper/silo data records going to suffice when it comes to inquiries, responses (and audits)? Or, is there a better way to manage food safety and quality data to ensure not only data is accessible, but also that food safety programs are working?

One sure bet is that there will be a higher number of audits and inquiries. Is your team and/or supplier prepared for the increase of these types of activities?

  • Inquiry: A request for a single or series of data and or documents usually related to a specific FSQA event or question
  • Response: The collected data, data reports, document or document reports related to a specific audit or inquiry
  • Audit: An activity that reviews one or many elements of a food safety plan to assure that the plan is complete, performed as described and meets the food safety design as intended. Audits are known and expected activities to review such safety plan elements even though the actual audit date and time may be known or unknown

We all know that audits are often lengthy exercises, yet they are still predictable. On the other hand, inquiries can be more difficult in that information requests may involve a very deep dive into a very specific area of inquiry.

In all honesty, if inquiries or responses or audits have to be planned for in advance, then you are not prepared. In order to always be prepared, it’s imperative to have better systems in place to manage any type of internal or external examination of your food safety and quality information. Regardless of whether it is an audit, response or inquiry, it is important to have easy access to records, verify that your programs are working, have corrective actions in place, and show visibility (and transparency) in your operation.

Thus it all comes back to how you or your suppliers are managing food safety records day in, day out. If FSQA operations are still relying on manual-based food safety and quality management processes versus food safety and quality management technologies, then chances are that you’re reacting to latent results, and you’re not able to identify trends and opportunities for improvement. The burden to manage inquires, responses or audits—as they continue to grow in cadence—will become overwhelming.

Without a doubt, the Chipotle effect is being felt throughout the industry. There will be increased accountability to ensure an adequate food safety program is in place and verification that the program is working. It will become even more imperative—and expected—that data and records are readily available to efficiently respond to inquiries, responses and audits.