FST Soapbox

Inquiries, Responses and Audits: The Chipotle Effect

By Dan Bernkopf
No Comments

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.

David Fried, Food Labs
In the Food Lab

Food Labs: Authentic and Safe Food is Key

By David Fried
No Comments
David Fried, Food Labs

The recent Foods Lab Conference (co-located with Pittcon) was an intersection of compliance, technology and best possible practices. One of the goals of this international symposium was to have laboratories and the food industry recognize one another as part of an effort for a more intentional and collaborative system in the industry, especially in terms of policies and practices.

As a Food Science student from Tallahassee, Florida I ended up at this incredible conference after seeing a blurb for it on LinkedIn and was able to attend as an intern. The two main objectives of my role were to assist with various tasks to help ensure the event transitioned smoothly, as well as further my knowledge base of the enormous realm of food safety. The following are some themes that I heard throughout the two days.

Having the analysis and validation performed or overseen with preventative types of controls from a qualified individual should ideally occur before the food safety plan is implemented. This appears to be desired by the consensus and was a common thread during the conference. If there is a change in a process control, it can have a serious impact on the legitimacy of the documentation if the change is not taken into account. The ISO implementations are food safety management systems and hazard analysis identification, which is the international benchmark for compliance standards.

Analytical scientific instrumentation is absolutely necessary for guaranteeing data and reproducibility on a consistent basis. The scope and complexity of modern technology should be considered when used for repeated trials in which the narrowest margins of results are being demanded by consumers and industry. Microbiologists confirm their peace of mind is reliant on the ability for reproducible experimental trials. In a laboratory, the presence of variables and species must be handled in an extremely controlled manner. All too frequently undesirable organisms appear in foods, and this is often the result of poor food handling practices, fraudulent practices or summed up, lazy shortcuts for the most unthinkable reasons. An effort to decrease these microbes is being made through transparency in supply chains to trace the journey of the food from seed to the table.

Food production is being shaped as a result of FSMA, which is a milestone in food safety. A few features of this legislation are to offer assistance for the food technology sector and address questions about policy and safe handling practices. It has and will continue to influence the process of laboratory accreditation, validation and compliance in order to provide thorough transparency for the development of more modern food systems. There were many fascinating perspectives shared about validation and accreditation for both laboratories and facilities. Many large companies have their laboratories in-house, because it is easier from a production perspective if the product is going to market, to test it repeatedly in order to have less delay in the market launch. There have been times in which carcinogenic fillers or fake foods were portrayed. Examples would be the horse meat and melamine scandals. An additional perspective would be the possibility in protecting the own interests of the company by not disclosing true ingredients, practices, or actual comprehensive food safety evaluation. All are truly unacceptable with regards to mega food base distribution companies. Small- to medium-sized businesses typically source laboratory evaluations to third-party assessors to perform product validation because it’s simply too expensive to implement on their own because of labor, technology and space constraints. Claims of 100% pure olive oil are not true the majority of the time. A sunflower oil and chlorophyll solution can be made to mimic the coloration of pure extra virgin olive oil. So it is commonplace for this sort of solution to be created and combined with pure olive oil at a ratio of 2:1, as a conservative figure. True wording and claims are becoming a thing of the past, because it is way too simple for big food business to engage in such unthinkable practices to maximize their own profits.

A key thread running throughout the conference was the importance of necessitating the collaborative efforts needed to achieve a comprehensive dialogue set in place as a universal type of database. This database would serve as the foundation to ensure safe food practices throughout worldwide food production companies, accredited laboratories, governments, and consumers.

The Food Labs Conference was truly one of fantastic speakers, interesting participants, and fascinating conversation. The advanced topics were explored by professionals who share a deep passion for this vital industry sector. Food Laboratories and the conference, respectively, will become even more revolutionary in terms of future technology, the influence garnered by key publics, and future experts.

Shawn K. Stevens, Food Industry Counsel
Food Safety Attorney

Federal Government Takes Regulatory and Criminal Offensive Against Food Industry

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

There was been a significant uptick in the amount of foodborne illness outbreaks and food product recalls (there were more than 500 food product recalls last year), many of which have been caused by dangerous pathogens. As FSMA plays a role in addressing this alarming trend, FDA is making several policy changes that will only continue to intensify. The agency is conducting microbiological profiling both inside food processing facilities during routine inspections and testing large amounts of food at the retail level. In addition, it has launched criminal investigations against food companies distributing products that have the potential to cause human illness. In many of these cases, company executives did not have direct knowledge that their products were causing, or had the potential to cause, illness. Many investigations involve Listeria monocytogenes (LM) found in food processing environments or in food products in commerce. Under FDA’s new approach, the failure to eliminate sporadic LM findings in the environment can subject companies to criminal liability. The immediate challenge to the food industry is to find a more effective solution to identify and reduce pervasive pathogens in the processing environment using pathogen-reduction technologies, while simultaneously employing written food safety protocols that can provide additional protection against criminal sanctions.

PulseNet Makes Foodborne Illness Link

Following the conclusion of the infamous the Jack-In-The Box outbreak that sickened 600 and killed four people more than two decades ago, the federal government recognized that similar outbreaks were probably occurring throughout the country, but there were no viable means of detection. As a result, the CDC created the PulseNet database, a mandatory foodborne illness reporting system to detect and track outbreaks in real time. From there, when a patient tested positive for a pathogen of concern (such as Listeria Monocytogenes, Salmonella or E. coli O157:H7), his or her doctor had to report that finding to the state health department. Each state requests copies of the isolates and tests them for the specific genetic DNA fingerprint of the pathogen of interest. These fingerprints are uploaded to PulseNet, and when indistinguishable genetic DNA fingerprints are uploaded from multiple victims, the CDC can recognize that an outbreak is emerging. The agency shares this information with FDA and other federal, state and local health departments as they work to determine a common source. Despite the fact that most illnesses uploaded to PulseNet remain unsolved, the database has helped CDC and FDA solve hundreds of outbreaks that have affected thousands of victims.

My subsequent columns will look at the emerging challenges faced by the food industry, including recent federal criminal investigations, some solutions designed to assess environmental contamination and reduce pathogens, and strategies that you can employ to reduce criminal liability.

John Sammon, ParTech
Retail Food Safety Forum

Break the Pencil: Goodbye Paper, Hello Technology

By John Sammon III
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John Sammon, ParTech

With the passage of FSMA, any location that handles food for public consumption must implement Hazard Analysis and Critical Control Points (HACCP) plans to reduce food safety risks across the food chain. Many businesses with multiple locations in the restaurant and retail industries are finding that traditional paper-based methods of record keeping are no longer adequate to comply with the FSMA. By abandoning paper-based systems and adopting cloud-based technology, restaurant and retail locations can embrace and enforce stronger food safety cultures and help eliminate human error.

According to the CDC, each year an estimated 48 million Americans get sick, 128,000 are hospitalized and 3,000 die from foodborne disease.

Why? The process of purchasing, transporting, preparing and serving food heavily revolves around individual human behaviors related to cooking, cleaning, handling and refrigerating food. When employees do not follow the correct processes and procedures, it can lead to accidental food safety issues.

FSMA & HACCP Plans

In an effort to shift from responding to food contamination incidents after the fact to proactively preventing them, the FDA introduced FSMA in 2011. To allow businesses time to adjust to new rules and regulations, the FSMA requirements are implemented in phases, which began in September 2015 and will continue through May 2016.

As part of a larger food safety initiative, FSMA requires any business that handles food for public consumption to implement a HACCP plan. The purpose of the plan and its procedures is to identify potential hazards in any food-related processes where a lapse in attention or failure to complete a task could turn a potential hazard into an actual one.

The three main components of an HACCP plan that are required to be documented are:

  • Hazards: Evaluate potential hazards that exist in the enterprise. For example, how, when and why Salmonella or Listeria could migrate into a finished product
  • Critical Control Points: Identify critical control points where failures could occur, such as when products are moved from preparation to the sales floor
  • Preventative Steps: Establish the preventative steps that must be followed at each critical control point to reduce hazards, for example, interval checks to make sure correct temperatures, whether hot or cold, are consistently maintained

FSMA also mandates a record of food safety compliance to ensure a company follows its HACCP plan. Every location must document all actions, including ongoing monitoring of when a problem was spotted and corrective actions taken. These records, which have traditionally been created and maintained with pen or pencil and paper logs, must be kept for a minimum of two years.

Deli worker checks cold food temperatures using a handheld probe and wireless device. Maintaining proper food temperatures and recording checks for consistency is an important part of HACCP guidelines.
Deli worker checks cold food temperatures using a handheld probe and wireless device. Maintaining proper food temperatures and recording checks for consistency is an important part of HACCP guidelines.

Compliance Challenges

With multiple locations and an ever-changing labor force, it is difficult for companies to be confident that the food they sell is safe and that every employee is acting diligently when it comes to food safety across the entire enterprise.

In a busy restaurant or retail environment with ever-changing customer demands for a variety of different products and services, a food safety culture and plan can unintentionally become compromised.

With local farmers to international food manufacturers supplying fresh, frozen and prepared foods and a variety of workers in contact with each for different reasons, it can be difficult to track food safety procedures.

Add an inefficient, manual, paper-based food safety record-keeping system that does not proactively remind employees to complete tasks or prompt corrective actions when needed, and you are opening the door to potential problems.

It’s Time to Break the Pencil

Companies must implement the highest standards of food safety processes at all levels and locations. Once a food safety culture is defined, it needs to be enforced every day. Employees should be well trained on policies, feel empowered and mandated to behave consistently.

A major part of the solution is abandoning traditional pen or pencil and paper-based record-keeping systems. By adopting technology, restaurants and retail locations can embrace and enforce stronger a food safety culture and help eliminate human error.

Electronic and intelligent checklists and digital record keeping on mobile, handheld solutions that are integrated into the Internet of Things (IoT) represent a major technological advancement over what was previously possible, and can manage and dynamically influence food safety processes. Through connectivity to the cloud, mobile, digital solutions can be deployed anywhere throughout a business, from warehouses to sales floors, to prompt the desired behaviors and provide a detailed, accurate audit trail of completion. Devices can also keep track of relevant safety alerts and recalls to improve efficiencies and initiate steps that may not be part of a typical routine.

Daily employee work schedules can be preloaded and custom electronic-based checklists and templates can be built specifically around potential hazards to manage employee tasks and processes. Any missed steps or violations are flagged for easy correction.

As tasks are completed, data is electronically gathered and transmitted directly to the cloud where it can be stored, analyzed and reported for compliance.

In addition, through the cloud and IoT, employees at various levels of an organization, from corporate headquarters to store managers, can view and access real-time data from each location. New information can be uploaded from any location and automatically distributed to a particular store, region or all locations across an enterprise. Enterprise-wide access helps ensure all locations are practicing the most up-to-date HACCP plan and procedures.

Digital food safety solutions have many benefits for a business:

  • Overall Food Safety: Ensures critical control points are monitored and proper corrective actions are taken when necessary
  • Higher Performance: Employees are reminded to complete assigned tasks, so more tasks are completed on time with fewer misses
  • Audit Trail: Detailed, automated audit trail of who completed the action, what time it was completed and the data retrieved from the action
  • Process Improvement: A single database of comprehensive information detailing timing, missed checklists, commonly missed items and top violations to help improve overall processes
  • Cost Savings: Fewer resources are needed to complete food safety inspections, a 60% reduction in time compared to pen or pencil and paper-based systems1
  • Quality Improvement: In addition to HACCP compliance, the information gathered can be used for quality control. For example identifying where there has been over- or under-cooking in the food preparation process

Handheld, wireless and cloud-based technologies can serve as more accurate, reliable and efficient systems. Electronic systems are part of the solution for businesses to comply with new FSMA regulations and improve food safety procedures. When implemented properly, these technologies can help turn food safety in a positive direction and potentially avoid the next foodborne illness outbreak.

Reference

  1. National Grocers Innovation Center, Center for Advancing Retail Technology. Intelligent Checklist for Quality and Safety in the Supermarket. Retrieved from http://info.partech.com/whitepaper-intelligent-checklist-for-food-safety
Deirdre Schlunegger, CEO of STOP Foodborne Illness
Food Safety Culture Club

A Face Behind Foodborne Illness

By Deirdre Schlunegger
2 Comments
Deirdre Schlunegger, CEO of STOP Foodborne Illness

How is it possible that we are already near the end of the first quarter of the new year?  Time Marches on (pun intended). STOP Foodborne Illness continues to hear the devastating stories of foodborne illness. I am glad that companies vow to turn things around once things have gone wrong, but I do wish that the same companies had been paying attention long before individuals and families had to experience foodborne illness and live with life-long consequences. I believe that, when conducting in food safety training, sharing stories of those impacted by foodborne illness makes a difference. FSMA implementation is being taught, lectured about, absorbed, integrated, regurgitated and debated. FDA Deputy Commissioner of Foods and Veterinary Medicine Mike Taylor, along with his staff, intimately understand the “why” behind FSMA. Every step of the way, human life has been at the forefront of his prevention-based strategy and plans for new food safety legislation.

As company stock prices fall due to foodborne illness outbreaks, there are heartbreaking stories of families that may never recover emotionally—and this doesn’t always make the news. Chris, who was sick during the fall season, recently shared his story. 

Chris and his wife
Chris and his wife

He wrote, “I wish that I could express to another person what this experience has been like for me. The physical symptoms are so much more severe than a typical stomach flu or food poisoning, but the truly difficult part has been the emotional anguish I have felt. This illness has been traumatic for me, and I still struggle with the effects of it. I wish it would never happen to another person and I greatly fear having to go through it again when I am older or less healthy—I truly believed it would kill me. I also wish that others would be able to understand how scary it is to feel your life slipping away through illness like this. Feeling like your body is out of control. For it all to occur from eating what I thought was clean and healthy food is sad for me and I hope that no one ever has to feel or experience what I went through.”

Food safety is not a flavor of the month cause or a nice thing in which to aspire. It is critical for the good health of individuals and the good health of business.

Thanks for reading.

John Ryan, Ryan Systems, Inc.
FST Soapbox

Substituted Ingredients Are Only the Tip of the Iceberg

By John M. Ryan, Ph.D.
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John Ryan, Ryan Systems, Inc.

While the United States has no legal definition of food fraud, current thinking tends to be focused primarily on companies and products involved in the illegal substitution of one ingredient for another in a product. Such substitution generally involves substituting a cheap filler in the place of the labeled ingredient. In recent news, Parmesan and Romano cheeses have captured news headlines because of illegal “misbranding” of foods meaning that the label on shredded cheeses from companies like the Castle Cheese, Inc. company in Slippery Rock, PA include ingredients found through FDA testing that are included in percentages beyond allowable levels. In the case of shredded cheeses, so called “imitation” cheese better is known as wood pulp. The labels stated that the ingredients were 100% cheese.

Perhaps Slippery Rock is an apt name for the Castle Cheese operation where the inclusion of wood pulp was cheaper than the inclusion of real parmesan cheese. Such activities are becoming increasingly known as “economically motivated” and the practice is one of economically motivated adulteration. The FSMA final rule, Focused Mitigation Strategies to Protect Food Against Intentional Adulteration, will make these practices illegal.

Such intentional cheating has a long record in the history of food. No one really knows the extent of such food fraud activities, when they started (perhaps at the beginning of time?), or who could claim to be the first person to win an international award for creativity.

There are so many ways to commit food fraud that it boggles the mind and creates an almost complete inability on the part of governments, testing laboratories, food processors, retailers and the public to identify, let alone fully prevent and capture the guilty every single time.

Think about a few things. Is it fraudulent to leave the identification of GMO ingredients off of labels? If a packer knowingly packs a product in dirty packaging, is that practice fraudulent? If the food safety part of the government knows how high the levels of fecal coliform are on most of the produce we eat but does not acknowledge the problems or inform the public, is this practice fraudulent? How about the idea that a retail outlet replaces an “expired” label on hamburger with a new unexpired label? Or how about the time Sysco was shipping perishable foods in refrigerated trucks and storing eggs, milk, meat, chicken and other products in the same storage sheds where you might keep leftover junk from your garage? Do “Good Things Come From Sysco”?

But none of those examples have anything to do with intentionally substituting a cheaper ingredient for an ingredient on the label. Honey, olive oil, coffee, juices, fish, alcohol, milk and dairy products, fish, vitamins, meat, spices, organic foods, maple syrup, peanut product, flavorings, preserves, cereals, colorings, wines, vinegar, purees, sweeteners ,and other ingredients are involved. And food fraud occurs in manufacturing, processing, packing and food holding operations. Such large opportunities for all foods in all operations means the entire food chain is—at one time or another, in one place or another—suspect.

Ryan_foodfraud_packaging

The Grocery Manufacturers Association (GMA) estimates that food fraud may cost the global food industry between $10 billion and $15 billion annually with lost sales between 2% and 15%. They estimate that approximately 10% of all commercial food products are impacted.

Considering the fact that the food industry claims their profit margins are only a few percent, it would seem that if they wanted to reduce food costs, food fraud would surely be a prime business improvement target. And GMA, unfortunately, is also focused on economically motivated adulteration such as unapproved additives, mislabeling, counterfeit ingredients, transshipment (shipping from one country to another to repackage and relabel in order to avoid taxes), and dilution.

When a consumer enters a supermarket in search of fresh meat, poultry or fish to cook for dinner, he or she knows little about how those products were packaged. Adding water to the pad that is often inserted under the meat to soak up blood, adds weight to the scale and money to the price. Packing the meat using carbon monoxide is common in order to “preserve” the product color. Red meat should look red, right? While the FDA considers this practice generally recognized as safe (GRAS), studies regarding how carbon monoxide interacts with the foam packaging and the clear plastic wrap covering the package are nonexistent. What makes the practice deceptive is the lack of information on the label that tells consumers carbon monoxide is used to preserve color. Of equal importance are recent studies that clearly show that many of the plastics used in today’s food packaging operations contain toxic chemicals shown to be dangerous to humans.

Interestingly enough, the European Union has a definition of food fraud:

‘Food fraud is a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain’.

After the monster European horsemeat scandal (remember that one?) in which horse meat was substituted for beef to the embarrassment of many companies, such as Burger King and Ikea, the United Kingdom promised proactive solutions from food laboratories and improving supply chain audits in an effort to slow and diminish the number of incidents reported annually.

In the United States, we frequently point to the melamine (milk substitution) in baby formula or the pet food problems that came out of China as evidence that foreign companies are primarily to blame for food fraud. Coupled with governmental trade agreements and the attitude that other countries are dumping substandard product on American consumers, it seems easy to blame others for food fraud –except for the fact that we in America are dealing with so many incidents.

The problem with our inability to tackle food fraud in part comes from the gap between our ability to identify and develop appropriate and targeted food ingredient testing capabilities. So many types of food, so many types of tests, so many types of ingredients, and so many types of ways to intentionally or accidentally cheat the system all combine to confuse and confound our efforts to quickly and economically establish detection systems.

In most food distribution arenas, food traceability systems are slowly being agreed upon and implemented. However, the FDA does not seem to be able to help with establishing data and other standards that would help establish traceability requirements designed to quickly and accurately get to the source suppliers in food fraud events. Other industries under FDA medical device and drug laws have worked to establish solid chain of custody systems. Chain of custody implies that the suppliers and handlers are legally responsible and clearly identified. Leadership in this area is clearly needed.

While there are many good resources evolving both within and outside of the United States, those resources are scarce and relatively immature. It seems that without some basics, such as legal definitions, standardized testing practices, and an agreement that food fraud is much more than substitution of one ingredient for another, we have a very long way to go if we expect to get the food fraud system under control.

Gina Kramer
Food Safety Think Tank

Listeria, the Pesky Bug is Everywhere!

By Gina R. Nicholson-Kramer
2 Comments
Gina Kramer

“When a flower doesn’t bloom you fix the environment in which it grows, not the flower.”  A quote, by Alexander Den Heijer, trainer, speaker, purposologist, that rings true in food safety. When there is a contamination issue in food processing, one must fix the environment in which food is being processed. Safe food is a product of a clean environment.

We have better environmental sampling programs in our food manufacturing plants and processing facilities, and we have sanitation standard operating procedures, so why are we seeing a prevalence of Listeria, and in rising numbers?  I recently sat down with Jeff Mitchell, vice president of food safety at Chemstar, about the recent increase in Listeria outbreaks and how you can rid your facility of the dangerous pathogen.

We’re seeing Listeria—in product recalls and outbreaks—over the last couple of years, and in multiple numbers. Why do you think this is happening?

Jeff Mitchell, Gina Kramer, Listeria
My interview with Jeff Mitchell about the increase in Listeria recalls.  Watch the video

Jeff Mitchell: The distribution of Listeria in the environment has not changed, and the processes that we use for processing food really haven’t changed. What’s changed is the way that we collect data. We have PulseNet now, which gathers information. If someone goes to a medical treatment facility with a foodborne illness, they’re going to investigate that and they’re going to get the whole genome sequencing on the pathogen.

There’s a difference between understanding what transient Listeria is and resident Listeria. I think there are a lot of sanitation efforts being put forth to eliminate the resident populations—those are the populations we’re most concerned about, and they’re the ones that are being related back to a lot of these recalls.

If I have resident Listeria in my facility, why can’t I find it?

Food Safety Tech is organizing a Listeria Detection & Control Workshop, May 31 – June 1, 2016 in St. Paul, MN. LEARN MOREMitchell: Resident populations of Listeria are found in a biofilm—most bacteria aggregate within a biofilm. A biofilm is a survival mode for the bacteria; it protects it from sanitizer penetration. That layer actually masks it from sampling. You could swab a surface or an area and not pick it up, because the biofilm is masking it.

Jeff goes on to discuss the type of sanitation program that companies should have in place to get rid of resident Listeria. You can learn about the steps you need to take in my video interview.

Ryan Mead, Focus-Works
FST Soapbox

8 Reasons to Go Digital 2016

By Ryan Mead
No Comments
Ryan Mead, Focus-Works

This year, more food manufacturing companies than ever are actively seeking software solutions for food safety and quality management. The majority of food businesses still collect food safety records using pen and paper, which is a time-consuming process and is far from reliable. Fortunately, food safety software is drastically changing the way HACCP and other QA/QC data becomes collected and stored. The following are some reasons food safety software is a must-have in 2016.

1.     Overwhelming Amount of Paperwork

Many employees at food manufacturing facilities—whether meats, baked goods, or beverages—still rely on pen and paper forms, checklists, and log books to manage their food safety operations. This allows operator errors and omissions to happen far too easily. Even well managed systems that use paperwork can reach a tipping point. Quality managers already have a big enough workload, and piling on the job of verifying all paperwork only increases the chances of a failure.

2.     Constant Change in Food Safety Standards

FSMA, the most sweeping reform of food safety laws in more than 70 years, was signed into law in 2011. While most food manufacturers have only been mandated to register, the time of more strict enforcement is coming. Global standards for food safety such as, SQF and BRC, fall within this generation of compliance. The necessities of these programs are constantly changing, becoming stricter and introducing new categories of requirements. Food safety software offers an effective way to deal with the ever-shifting landscape by providing evolving solutions managed by a software provider.

3.     Consumer Confidence

Consumer expect a safe and healthy product, and as such, a company must instill a feeling of confidence. When a product is expected to provide nutrition, energy and enjoyment any incidence of foodborne illness will only prevent future confidence in the product. In addition, the consumer is likely to spread the news among peers about how he or she became sick. It is the duty of the food company to do everything in its power to process, store and prepare food in the safest way possible. That process starts with ensuring a higher level of reliability in a food safety program, which can be achieved by using food safety software.

4.     Economics

No food company wants to deal with the hassle of a lawsuit from an outbreak or recall. These events can cost thousands, if not millions, of dollars in damages and  cause serious loss to a company of any size. Although many companies carry insurance for these occurrences, there still is the loss of sale from consumer mistrust. Investing in software can help companies increase profits by improving efficiencies. For example, companies can measure these efficiencies not only from labor savings but also from significant savings in paper and toner (i.e., saving $2000–$5000 a year).

5.     Operator Error and Omission

In an age in which documentation is becoming digitalized, food safety requirements are becoming more tedious. Even the smallest employee error can have massive repercussions. The cost of added staff is one thing, but the reliability of the data and adherence to schedule is another. Relying on inaccurate data collection may result in a recall or damage to a company’s brand.

Pencil whipping (faking paperwork) occurs for a variety of reasons, from employees taking short cuts to avoidance of writing down out-of-spec data. Manual record keeping has proven over time to be prone to errors. Employees, bored with the distraction of measuring and writing down dough or batch temperatures, piece weights or metal detector tests, and fill out forms with moot numbers just to complete the form.

6.     Monitoring and Notification

Being aware of control points is another way in which companies can avoid disaster. Food safety software can give companies the ability to monitor oven and freezer temperatures, metal detectors, tests or any other control point in real time. This capability also alerts users when a control point is out of deviation (doing so at a glance), along with sending custom notifications, allowing a plant to quickly address problems while simultaneously properly documenting the issue.

7.     Audits: Go from Stressful to Easy

An upcoming audit can be stressful for any company, involving numerous people who are gathering an abundance of documentation. With food safety software there is no reason to scramble to get documentation together or waste precious time preparing it. Auditors can simply view a company’s software for any requested documentation. For example, a company can produce random temperature logs, metal detector times, SSOPs, customer complaints and a variety of other documentation in just a few clicks.

8.     The Technology Is Available

One of the reasons why so many companies continue to use paper and Excel-based systems today is because they are unaware of the abilities and functionality available to them. After completing the formidable task of attaining a new-found level of compliance, some companies may find it daunting to continue to go to the next step of converting to a computerized system. Finding user-friendly food safety software that has good customer support, as well as solutions that are customized to user needs, is not necessarily easy. The key is to find software and a supplier that can provide the right solution for your company and food safety program, whether it’s HACCP, BRC or SQF, and ensure that it fits within an acceptable budget. Consider not only the initial cost but also the cost of implementation. What resources will be required? How much can the supplier help with implementation? Having the right answers and the true costs will assist you in arriving at the correct solution.

Fritz Kriete
FST Soapbox

5 Ways Food Companies Can Protect Themselves And Customers

By Fritz Kriete
No Comments
Fritz Kriete

While illnesses linked to Chipotle restaurants are grabbing headlines, the federal government recently took steps to improve how manufacturers and packagers process and handle food. Last year FDA released several final FSMA rules, giving food companies a roadmap for ensuring food safety. The proactive approach of the regulations can help companies avoid the hazards that lead to disease and allergen contaminations, and even legal troubles. Indeed, unsafe food handling can carry costly consequences from both a financial standpoint as well as in lives lost or harmed.

In 2011, the good intentions of a family-owned cantaloupe company produced tragic results. The company, seeking more natural melons, followed a consultant’s advice and discontinued the chlorine rinse used to wash off contaminants. A Listeria outbreak followed, killing 33 people and hospitalizing 147 more. Although prosecution is rare in foodborne disease outbreaks, the company owners were sentenced to probation, home detention, community service, and $150,000 each in restitution.

A more egregious case occurred in September 2015, when the former CEO of the Peanut Corporation of America was convicted of knowingly shipping Salmonella-tainted peanut butter, which had caused an outbreak that killed nine people and sickened hundreds more. Stewart Parnell was sentenced to 28 years in federal prison.

The new regulations require companies to undertake hazard analyses of their production, along with remedial steps. This scrutiny leads to the creation of a written plan that details the controls to prevent contamination and establish a schedule for periodic testing. This analysis and control system is called the Hazard Analysis Critical Control Point, or HACCP.

Adherence to regulations doesn’t necessarily protect a company from liability, but not adhering can sound a company’s death knell when there’s a problem. The following are five ways in which companies can protect themselves:

  1. Put food safety first. The company culture must revolve around it. The message that the HACCP plan is to be followed must be relayed to all levels of the organization. Otherwise, companies can face severe consequences, based on the question, “Did the company behave badly enough to face strong punitive damages?”
  2. Concentrate on internal communications. In many cases, food recalls happen because of a breakdown in the communication process.
  3. Hire accredited consultants. Make sure that your consultants are qualified and have been accredited by an appropriate body such as the International HACCP Alliance or The Seafood HACCP Alliance.
  4. Don’t overlook supplied products. Suppliers should adhere to strict contamination-prevention protocols, but don’t assume they follow guidelines completely or have flawless processes.  Your contracts with them should require that they periodically audit their facilities and share the audit results with you.
  5. Label clearly. Packaging language might state that a product is manufactured in facilities that also process allergens such as peanuts and tree nuts. These types of warnings allow consumers to make up their own minds. It is also a reminder that HACCP plans must address prevention of cross-contamination (i.e., putting cleaning protocols in place if products with and without allergens are processed on the same equipment).

Many problems involve internal slip-ups or problems with supplied ingredients that allow contaminated food to reach consumers. If the contamination becomes known—and it often is not, when victims don’t equate their illnesses with tainted food—the businesses involved often face strict liability, meaning they carry some blame even if they didn’t act in a negligent manner and cause the problem directly.

Keep in mind that liability isn’t the only consequence of non-compliance. A recall or outbreak can damage the reputation of the company and the product. The cantaloupe tragedy sent sales of the melons plummeting, even in states not linked to the outbreak.

To minimize the hit on sales, a recall team should be in place, with a plan modeled on crisis management principles. Team members should come from all divisions of the company, including transportation and distribution to track down products, and communications to manage messaging. Legal counsel should be on board to advise on the ramifications.

When it comes to foodborne outbreaks, it’s a matter of taking classic prevention and preparation steps. Do everything you can to keep it from happening, but be ready just in case it does.

Tim Curran, Sample6
FST Soapbox

Putting FSMA Into Practice

By Tim Curran
1 Comment
Tim Curran, Sample6

High-profile food recalls and food-borne illnesses continue to keep food safety top of mind. Yet, many in the industry are still struggling to put the best practices we’ve learned over the years about how to properly secure our global food chain into practice. Put simply: The focus needs to be on prevention rather than reaction.

Food safety procedures must be strengthened across the board to meet increasing regulatory pressures and prevent massive recalls and illness outbreaks. FSMA puts the principles of prevention into law. The first major update of federal food safety laws since 1938, it was signed into law by President Obama at the start of 2011. After years of debate, it is now finalized and implementation can begin. The objective of FSMA is to ensure that the U.S. food supply is safe by shifting the focus from reaction to prevention. Now, who can argue with that?

FSMA also pushes the FDA to extend beyond its traditional reactive role. For the first time, the FDA has the power to stop unsafe and possibly contaminated food from entering the food supply.

Let’s take a quick step back so we can explore how to best put it into action. FSMA is made up of five primary provisions:

  • Preventive controls
  • Inspection and compliance
  • Imported food safety
  • Response
  • Enhanced partnerships

I’d argue that the first provision is the true heart of FSMA: Prevention. The first provision focuses on preventative controls and provides a framework for an effective food safety program. In FSMA, this is broken into five key parts, including hazard analysis, preventative controls, monitoring, corrective action and verification. But what does that mean to you? You can best comply with these requirements by implementing better visualization, documentation and communication tools. Let’s walk through each section and the types of tools that you should consider.

Hazard Analysis. Most companies have strong HACCP plans in place, taking account food safety hazards at all stages of production. Risk assessment and risk management must be taken into account and critical control points defined. However, to manage this going forward, consider tools that enable visibility into the current and historical situation at those control points to allow your team to see their proximity to each other, as well as to other components in the plant.

Preventive Controls. Preventative controls are also called out as part of the FSMA requirements. This includes food allergen, supply-chain and sanitation controls in place, as well as sound recall plans. Again, critical control points (CCPs) are the key to ensuring your controls are effective. Also, consider trying indicator test points to stay one step ahead! Indicator test points, as advocated by food safety leader, John Butts, are one or more steps removed from your CCPs. By testing in these areas, you can identify possible risk areas before they even reach control points. This enables a much more proactive approach.

Monitoring. Your plant should have a monitoring plan that includes written procedures for monitoring preventive controls and how frequently they should be performed. This plan should take into account zone coverage, randomization, test frequency, test timing and sampling order. Depending on the business and regulatory rules of a plant, testing should include non-food contact and food contact surfaces. In order to ensure that testing is representative of the conditions in the plant, randomization of test points is important. In addition, test frequency and test timing should be defined, and organizations should seek tools that help to automate these business rules.

Corrective Action. Hope for the best, but always plan for the worst. What is your corrective action plan? You must have a written procedure for identifying and correcting a problem. For both your plant and for regulators, a clear record of your plan and that the steps were followed to close out any issues is required. Make sure that the team understands the steps that are required, number of re-tests and any recall requirements. Look for tools that automatically alert the relevant team members of the situation and track response and testing so that you can easily share this level of detail as needed.

Verification. Trust but verify. Having a plan is only half the job. Using your environmental and finished product testing programs to ensure that controls and corrective actions are effective turns your plan into action. Rapid testing technologies keep the time between testing and results tight. Also, communication of verification results keeps the team coordinated around food safety.

The move to more preventative food safety procedures does not have to create massive headaches. Compliance with FSMA will ultimately help your business and guarantee that you are providing safe food for your customers to consume. Many food companies have been implementing these best-practice guidelines for years. Thanks to FMSA, we all now get an easy-to-follow checklist.

Shifting from reaction to prevention makes food safer—and now, it is also the law. The first step is to make sure you have a good understanding of the components. Only then can you find the best tools and technologies to support you. Lastly, make sure that your team is well aligned around the goals and objectives of your food safety program. Together, we can make food safer.