Melanie J Neumann is Vice President and Chief Financial Officer for The Acheson Group
Beltway Beat

From Beijing to Baltimore Integration and Collaboration a Common Theme

By Melanie Neumann, JD, MS
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Melanie J Neumann is Vice President and Chief Financial Officer for The Acheson Group

At the recent Food Safety Summit in Baltimore, the focus was on building an Integrated Food Safety System (IFSS) to aid in implementing FSMA and continued progress along the path of prevention vs. reaction, while at the International Forum on Food Safety (IFoFS) in Beijing, speakers emphasized colla boration for more effective and accurate communication of food safety risks.

In China, the media often over reports on food safety scandals that are actually food quality issues. Consumers are led to believe that food safety is a widespread problem across China and thus have developed a dis trust in the local food industry. At the heart of the matter is multi-stakeholder risk communication. The media is not solely to blame for this problem. Industry and regulators must be more proactive in communicating the true nature of food-related incidents in a way that is more accessible to consumers and the media.

The entrenched culture and government supremacy of China also contributes to the problem. The food industry typically does not communicate openly about food safety risks once the government has spoken out. However, at IFoFS, openness was a key focus, and I think we are at pivotal turning point. Chinese and other Asian companies, along with the Chinese FDA, have begun discussing the criticality and need for risk communication as it relates to food safety and food quality as a means to protect both consumers and food brands. One significant challenge involves instances in which errors in judgment are not quickly admitted when a regulator positions an incident as one of food safety when soon after it’s realized it is a quality issue. It’s safe to assume that regulators may not take the initiative to openly admit the misclassification, and speaking out against these issues may be perceived as openly challenging the government.

I also see the same phenomenon happening in the United States, but the over-reporting, is more so connected to the lawsuits against FDA and topical focus by consumer activist groups. For example, certain activist groups are over-amplifying the purported risks of GMOs, and we’re seeing over-reporting of the pressure and lawsuits against FDA related to FSMA deadlines. Similar to China, these issues are not food “safety” issues per se, but the media’s coverage exacerbates consumer misunderstanding and feeds a belief of widespread adverse food safety issues.

At the Food Safety Summit there was more focus on the integration and collaboration of federal, state, local, and regulatory bodies to implement FSMA. Michael Taylor, FDA’s Deputy Commissioner of Foods said that the publication of the final rules will meet the court-mandated deadlines, beginning in August. He added that there is an existing, established network between these groups, but FSMA elevates this association to a new level, because Congress has mandated it. The discussion of interaction and integration raised a question during a Town Hall on “integrating” the federal food agencies into a single agency. The general answer: If we were starting from scratch, we probably wouldn’t create separate agencies, but given that there are two today, there are more effective ways of integration versus completely disrupting the system to create a single-agency. (Sorry David—we know how much you would like a single food agency!)

The common thread? The U.S. and China are calling for increased relationship building and trust between all stakeholders. This common thread sews these two conferences, countries, and the global community together. But the question remains, with the media, consumers, regulators and industry seemingly still at odds with each other in both countries, how do we make this happen?

Ron Harrison, Ph.D., Director of Technical Services, Orkin, LLC
Bug Bytes

Five Pest Management Tips for Restaurant Employees

By Ron Harrison, Ph.D.
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Ron Harrison, Ph.D., Director of Technical Services, Orkin, LLC

Restaurants can face major risks related to pest activity, which is why a proper Integrated Pest Management (IPM) program must be in place. However, restaurant owners are not the only ones who should play a part in the IPM program; employees should participate as well.

Often times, live pests are sighted in restaurants, which can result in immediate consequences to a restaurant owner’s bottom line. Therefore, restaurant employees should be trained on how to prevent and react to pest sightings in their establishment.

The following tips will help restaurateurs get their employees on board with pest management:

  1. Contact a pest management professional for a complimentary on-site employee training that will teach employees the importance of pest management and how it could affect the diners’ experience.
  2. Diners have zero tolerance for pests. Ensure employees know the protocol for pest sightings, which should include:
    • Catching the pest for identification
    • Recording when, where and how many pests were seen
    • Assisting your pest management professional to determine the method of treatment.
  3. The most productive way to keep all employees involved in pest management is to add one or two pest control responsibilities to their daily routine. These responsibilities should align with employees’ roles and can be as simple as regularly emptying trash cans and re-lining them, or clearing and sweeping food debris.
  4. In common employee areas, post educational materials such as sanitation checklists and pest identification sheets that provide information on common pests and potential health threats.
  5. Establish an open line of communication that encourages all employees to report pests immediately. Remember that employees can bring pests into the restaurant on their belongings from home, so it’s important that they know pest sighting reports are encouraged to prevent pest activity in areas such as break rooms, the kitchen or the dining area. Fostering an open line of communication will help restaurateurs get ahead of any pest issues and related health and safety threats.
Ron Harrison, Ph.D., Director of Technical Services, Orkin, LLC
Bug Bytes

Make Employee Training a Team Effort in Your Pest Management Program

By Ron Harrison, Ph.D.
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Ron Harrison, Ph.D., Director of Technical Services, Orkin, LLC

Pest management plays a key role in food safety and product integrity, and ensuring such is a critical, facility-wide undertaking. The success of a pest management program can be the difference between acing a third-party audit and facing a plant shutdown. An effective program is not just a one-person job; it requires an ongoing team effort from a company’s pest management provider and all employees. As such, beyond selecting an effective pest management provider, it’s equally important to recruit employees to help enhance your efforts. After all, they are the eyes and ears of your facility, as they spend a lot more time there than your pest management provider.

Arming your employees with the right tools and pest control knowledge will set up your pest management program for success. The following steps outline how you can get your entire team involved in your company’s program.

Teach the what, where and how

Your employees can be the first responders to any pest problems, but only if they know what they should be looking for and where they should be looking. For that reason, it’s essential that they complete training on the specific pest pressures your property faces and the red flags that alert them to pest activity.

Many pest control providers offer complimentary employee training, so ask your pest management professional to conduct an on-site training session for your team. These training sessions should include not only information about the specific pest pressures on your property, but also the conducive conditions and pest hot spots that your employees can help control. Pest hot spots are the key areas inside and outside your building that pests target as entry or harborage points. These areas are in constant danger of being penetrated by pests and are areas that currently or have previously had pest issues. Areas with standing water, excessive condensation or improper drainage are just a few examples.

Your pest management professional can also teach your employees the key components of integrated pest management (IPM). Rather than reacting to pest issues, IPM takes a proactive approach through a combination of non-chemical solutions, relying on chemical treatments only as a last resort. Proper sanitation practices, ongoing property maintenance to exclude pests, and regular monitoring are paramount to a pest-free facility.

Training sessions are also a great way for your employees and provider to build a strong relationship so your team is more likely to proactively report any pest issues.

Keep the lines of communication open

An open, ongoing line of communication between management, employees and your pest management provider is also an important component of successful pest management programs. Regular communication helps ensure that your employees are kept in the loop on important pest control information and initiatives. Furthermore, an open line of communication will keep you thinking proactively about pest management, which can help reduce decisions that lead to reactive chemical treatments.

This open dialogue will also help build rapport with your employees so they are more comfortable talking about sensitive issues, including the potential for bringing pests into the facility from home. 

Know your role

Your pest management program will work best when everyone involved knows his or her role. Consider assigning each team member a specific pest management task based on his or her daily duties. For instance, employees involved in facility maintenance can monitor for small holes or gaps in the building façade and seal them immediately to help prevent pest entry. 

 

In case of a pest sighting

Sometimes no matter how effective your IPM program is, resilient pests can still find their way inside your facility. Further, pest activity may not only originate locally, but from other parts of the country throughout the supply chain, making it somewhat difficult to immediately pinpoint the pest issue. This means there is a chance for both live and dead pests to make their way into your product, which can pose a nationwide health and safety threats to consumers.

With this in mind, it’s important to have a plan in place should a pest be spotted. Establish a pest sighting protocol that identifies the steps to report a pest incident, including who should be notified. The following are a few examples of steps that should be included in a pest sighting protocol:

  • If possible, catch and show the pest to your pest management professional.
  • Record the pest activity in a pest sighting report, making note of when, where and how many pests were seen.
  • Work with your pest management professional to determine what is causing the issue and how to resolve it.

Continue the education

Your employees need continued education to help keep your property on the cutting edge of pest control. Many pest management providers offer educational resources that facilities can use as ongoing education, including tip sheets, sanitation and maintenance checklists, and seasonal pest management tips. Ask your pest management provider if they have resources you can share with your team. You may also consider having your pest management professional provide further training sessions on specific pest problems.

Pest control is most successful when a team effort is involved. Work with your pest management provider to get your employees up to speed on the pest management efforts at your facility and ensure they have the basic knowledge needed to play a role in keeping pests out.

Maria Fontanazza, Editor-in-Chief, Innovative Publishing Co. LLC
From the Editor’s Desk

Translating the Talk into Action

By Maria Fontanazza
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Maria Fontanazza, Editor-in-Chief, Innovative Publishing Co. LLC

With a little less than two months under my belt as an editor in the food safety industry, I have already started to become a bad dinner date and my hands beg for mercy as a result of my newfound obsession with soap and water.

Quirks aside, I am seeing some common threads in this industry, although they are themes we see in any highly regulated industry. Partnerships. Collaboration. Transparency. Alignment. Accountability. Now more than ever, these words mean something. FSMA has forced the issue of food safety to the forefront. Yet, we’ve barely begun and I’m already hearing the phrase “FSMA Fatigue”.

For the folks who have been involved in preparing for FSMA from the start, they probably are a bit fatigued. There have been many meetings, and there’s been a lot of talking surrounding what’s going to happen, what needs to be done, and what challenges we’ll face (in many cases, together). But let’s not forget that not everyone is as well versed on the nuances of the regulation. I admit, I am raising my hand here… for now.

Now let’s back up a couple of sentences. “There’s been a lot of talk…” Yes, there has been. While these are enthusiastic discussions about what we as regulators, food processors, retailers, suppliers, scientists and everyone in between should be anticipating with FSMA rules and the consequent implementation, HOW are we going to navigate this new frontier?

Let’s start this conversation now.

You’ll see a lot of changes to Food Safety Tech this year. We’ve already started the information exchange with industry stakeholders about how we’re going to work together to get through FSMA implementation and the tools we need to arm our audience with to help them along this journey. We also just announced our Call for Abstracts for the Food Safety Consortium Conference in November.  The Consortium will bring together leaders and regulators in this industry and facilitate a forum for that candid “how” discussion. Food Safety Culture will receive strong attention, and key players will be presenting a case history of how to apply metrics to food safety culture within organizations.

I’m excited to join this industry, and thank you to those who have already extended a warm welcome. And for the many who I have yet to meet, please drop me a note as you encounter challenges or have ideas about critical food safety topics. Our job at Food Safety Tech is to provide a platform through which we can enable a constructive dialogue about overcoming challenges, working together effectively, and navigating this journey into the future of food safety.

Maria Fontanazza
Editor-in-Chief

Dan Okenu, Ph.D., Food Safety Manager, H-E-B
Retail Food Safety Forum

World Health Day Shines Spotlight on Food Safety

By Dan Okenu, Ph.D.
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Dan Okenu, Ph.D., Food Safety Manager, H-E-B

Drawing attention to the fierce urgency to advance overall food safety and reduce the devastating impact of food borne illnesses around the world, the World Health Organization (WHO) dedicated the 2015 World Health Day to Food Safety. To support these efforts, the Laureate International Universities hosted a special webinar as part of its annual activities to mark World Health Day. During the webinar, Constance Shumba, a public health faculty at the University of Roehampton (London) and I explored the potential impact of FSMA on the global food supply with a case study on how the people and government of Uganda are advancing food safety in the sub-Saharan African country.

Globally, more than 2.2 million people, most of whom are children, die of foodborne and waterborne diarrheal diseases annually. In the United States alone, the CDC estimates that 48 million people become ill from food borne diseases each year. About 128,000 of these individuals are hospitalized, resulting in more than 3,000 deaths. The overall annual U.S. economic burden due to food borne illnesses is estimated to cost $77.7 billion.

These grim statistics illustrate the necessity to overhaul the outdated U.S. food safety system. FSMA is the most significant statutory change to both human and animal food safety in more than 70 years (since the passage of the Food Safety & Cosmetic Act of 1938). It is a radical shift from FDA’s previously reactive approach to a more robust, proactive scientific and risk-based prevention-oriented system. When fully implemented in 2016, the most important impact of FSMA will be to ensure that contaminated foods as well as those containing unwholesome or adulterated ingredients never reach retailers and consumers. Interestingly, FSMA may also positively affect the global food supply chain as it drives the improvement of food safety practices around the world, especially in countries that export food and food products to the United States.

Several provisions of FSMA will affect food exporters to the United States both in terms of reshaping their local food safety policies to align with the new law and the resulting improvement in food safety practices. Some of the areas of potential impact include:

  • Foreign Supplier Verification Program
  • Effective Traceability and Recall Program
  • Hazard Analysis and Risk-based Preventive Control (HARPC) System
  • Documentation and Record Keeping Inspections
  • Sanitary Transportation Rule for Human and Animal Foods
  • Produce Safety Standards for the Growing, Harvesting, Packing and Holding of Produce for Human Consumption.

Notably, regulatory agencies of major U.S. trading partners are in the process of updating their food safety laws to ensure that local food productions remain in compliance with FSMA. Canada, Mexico, China and Australia are among the countries that are proactively working with their U.S. counterparts to ensure compliance and uninterrupted food exports to U.S. markets. Overall, it will be easier for developed economies with fairly robust food safety regulatory policies to upgrade and catch up with the new FSMA requirements.

Developing nations will be the hardest hit, as an extensive overhaul may be required to meet FSMA regulations. In the face of poor infrastructures, these countries may struggle when upgrading their systems to achieve compliance and maintain a certain level of trade relations with the United States, not just in raw materials or unprocessed food and food products, but also in valued-added food exports. Despite these challenges, these countries are motivated to remain trusted U.S. food-trading partners and will most likely improve their food safety policies and practices, thus helping to make the global food supply safer.

Uganda is an example of a developing country that is making serious efforts to improve its food safety policies and programs. The country is working on its Food and Drug Act of 1964 and its subsequent Drug Act of 1993 to develop a modern and unified National Food Safety Law. To make the global food supply safer through FSMA, the United States must collaborate with its trading partners around the world in building and upgrading their food safety systems. This would be beneficial to U.S. companies doing business in foreign countries either in terms of manufacturing their own private food labels or simply in assisting local industries in these countries in growing, processing and packaging food and food products destined for the U.S. market. It would also help these countries upgrade their food safety laws, improve export capabilities, and balance trade with the United States, consequently making food safer for their own citizens.

During the webinar we also emphasized the need to focus on the family kitchen in improving food safety practices around the world, using the five WHO key principles to a safer quality food:

  • Keep clean—engage in proper washing of hands and food contact surfaces
  • Cook food thoroughly to the required temperatures
  • Separate raw and ready-to-eat (RTE) foods to avoid cross-contamination
  • Keep food at safe temperatures to ensure that hot food remains hot and cold food remains cold at all times
  • Use safe water and raw materials to avoid cross-contamination

We all agreed that the culture of food safety must start in the home and at a very early stage in life and from there, spread to our schools, and public and private institutions. Food companies must do all that is necessary to uphold the integrity of the highly profitable food industry by delivering safe quality food to their customers. Overall, the global food supply chain will be made safer with a considerable reduction in food borne illnesses, and chemical or physical adulteration of foods.

The webinar referenced in this column, “From Farm to Fork – A Public Health Perspective”, can be found on the Walden University (Minneapolis) website.

Okenu is also affiliated with Walden University as a contributing professor in public health

Rick Biros, President/Publisher, Innovative Publishing Co. LLC
Biros' Blog

Food Safety Tech Welcomes New Editor

By Rick Biros
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Rick Biros, President/Publisher, Innovative Publishing Co. LLC

We launched Food Safety Tech three years ago this month.  Sangita Viswanathan has lead the editorial efforts for those three years and has played a significant role in launching Food Safety Tech and helping establish it as a leading industry news source.  I wish Sangita the best as she has left Food Safety Tech to spend more time with her family.

I am thrilled to introduce Maria Fontanazza as Food Safety Tech’s new Editor in Chief.  Maria has more than a decade of experience in journalism, marketing and communications within the medical device industry. While at UBM Canon for more than eight years, she served in various editorial roles, including as the managing editor for Medical Device + Diagnostic Industry (MD+DI). She has authored hundreds of articles that have appeared in domestic and international industry publications and has moderated educational sessions and panel discussions at various industry events. Maria also has experience in organizing industry conferences and tradeshows as well as in website design and development.

Maria brings contacts and experience to Innovative Publishing and will have an immediate impact on our medical device online journal, Medical Device Summit.  Having worked in an FDA regulated industry, the learning curve for the food industry will not be long, especially with the help of Food Safety Tech’s solid group of Editorial Advisors including David Acheson, Shawn Stevens, Mark Carter, Purnandu Vasavada, Hal King, Gina Kramer, Beth Johnson and Bill Bremer, to name just a few.  She will be traveling to many of the food conferences such as GMA’s Food Science Forum, Food Safety Summit, IAFP and the Food Safety Consortium.

This year, you will see many changes and additions to Food Safety Tech many of which will be spearheaded by Maria. She’s already had an impact with Food Safety Tech’s twitter account, @FoodSafetyTech, with frequent new tweets.

Please feel free to reach out to Maria with your thoughts, comments, perhaps your interest in contributing an article or just to say hi. 

All the best!

Rick Biros
Publisher/President

Dan Okenu, Ph.D., Food Safety Manager, H-E-B
Retail Food Safety Forum

The Impact of FSMA on Private Label Food Retailers

By Dan Okenu, Ph.D.
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Dan Okenu, Ph.D., Food Safety Manager, H-E-B

When fully implemented, possibly by the spring of 2016, the new U.S. Food Safety Modernization Act (FSMA) will raise the bar on food safety regulatory compliance both in the United States and around the world. The key provisions of FSMA will shift emphasis from the current reactive approach to food safety and food security, towards a more proactive science-based risk mitigation and prevention strategy. The impact will be felt across the entire global food supply delivery system from farm to fork including private label foods manufacturers, processors, suppliers, importers and retailers.

It has been projected that the sales of private label groceries in the United States alone will grow by 36 percent from $98 billion in 2011 to $133 billion in 2016. This impressive growth may be as a result of the competitive pricing of private label foods and the comparable quality with major brand products, as well as the convenience and customer trust in these in-store retail brands by today’s savvy shoppers. The consumer-friendly collaboration of private label manufacturers and retailers, or retailers that own their own private label manufacturing facilities is known to reduce the unnecessary supply chain costs by improving supply chain efficiency, enhances processes and systems, and improves the overall customer experience. These great value-proposition attributes will continue to make in-store private label products popular among consumers and profitable for businesses.

An important question however is how the new FSMA regulatory climate will impact these private label food products amid this growing popularity and in the context of the core business benefits of active management control, competitive prices, considerable return-on-investment and consumer satisfaction. On top of this list is the FSMA requirement for risk-based foreign supplier verification. This is to ensure that imported foods manufactured by foreign third party vendors or by US companies running their own facilities overseas are in compliance with the new FDA requirements, and that the food products are not adulterated or misbranded. Retailers of private label foods will be required to provide documented evidence from an accredited certification entity that shows that their foreign-supplied food products are in compliance. Frequent inspections of these foreign-based facilities and foods imported into the United States will be mandated under the new rule.

FSMA also sets the bar higher for retailers of private label foods in the key areas of food safety record keeping and documentation, traceability/recall programs, upgrading from ordinary HACCP to the more advanced Hazard Analysis and Risk-based Preventive Controls (HARPC), and implementing a verifiable supply chain management program. These provisions have the potential of making it more profitable for companies to manufacture their private label foods here in the United States instead of overseas where they lack active managerial control to ensure full compliance. Although domestic US-based manufacturers and suppliers are already covered under FSMA, retailers of private label food products manufactured in the United States are still advised to consistently verify that their suppliers are compliant, since retailers will also be liable for any infringement or negative outcome from such products.

For private label retailers that have proactively pursued industry benchmarking standards by insisting on GFSI certified facilities and who have an effective verifiable food safety management system in place, the impact of FSMA will be minimal. They will only need to re-examine their processes and systems to identify any gaps within the provisions of the new rule and put corrective actions in place. For others hoping to play catch-up, implementing the new FSMA requirements may become so overwhelming that the obvious business benefits of in-store private label foods like competitive prices and comparable quality with major brands may become severely undermined. The relationship of private label food manufacturers and processors with their retail partners could be impacted, as retailers would need to collaborate to profitably deliver what their customers want, namely, safe quality competitively priced mix of private label and brand food products.

Although the production and sale of safe quality food is mandatory to all food companies, under FSMA, small companies with less than $500k in annual sales and who sell directly to consumers within 275 miles radius of their facility may be exempt from some of the rigorous requirements of the preventive control rule. However, when large companies patronize these small local businesses, they must ensure that they are in full compliance since liability extends to retailers. National food service chains that manufacture their own private label ingredients and condiments or obtain these supplies from third party vendors are also expected to comply with the new rules. Overall, companies will be better off taking proactive steps in evaluating their suppliers’ food safety management system in line with the preventative control provisions under FSMA.

In conclusion, FSMA brings with it, a complete paradigm shift that will impact the entire global food supply chain. Retailers of private label foods must continue to assure their customers that their favorite in-store brands were produced, processed, stored and handled in a safe manner every step of the way. Thus, FSMA readiness and preparedness must include a comprehensive gap analysis to identify provisions of the new rules that must be implemented to stay ahead of the curve by next year when these regulations will potentially come into effect.

 

Dan Okenu, Ph.D., Food Safety Manager, H-E-B
Retail Food Safety Forum

Developing an Enduring Food Safety Culture

By Dan Okenu, Ph.D.
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Dan Okenu, Ph.D., Food Safety Manager, H-E-B

Food safety gap analysis is a process improvement management tool that helps to identify areas of risk and associated gaps in the internal food safety programs that must be addressed to ensure high confidence in your Food Safety management system. It is structured to benchmark the level of food safety, and to highlight potential areas of concern that might impact the business, customers and the overall business brand. Although a continuous internal self-assessment is encouraged, best practices require the use of third party consultants to sieve and weave through the entire organization to determine the efficiency and effectiveness of processes and systems and to make appropriate recommendations for improvement.

The NSF has a robust food safety gap analysis protocol which is referred to as a Maturity Model Assessment. It is very detailed and extensive involving site visits, observations and interviews of senior management. It is deliberately designed to completely evaluate the preparedness of the entire organization in food safety best practices. Such an unbiased third party instrument is an excellent assessment tool for any organization’s food safety culture.

Why is developing an enduring food safety culture important to the business? A senior manager in a large retail food company once told us in a meeting that although he had been with the company for almost 15 years that he still didn’t really understand what the Food Safety team was doing. We all thought that this manager was just being sarcastic but on closer scrutiny, we discovered that not only did he not understand the why and how of the many ongoing food safety projects, but also thought that a lot of those projects were not really required, since according to him, there had not been any major food safety event in the last 15 years while he had been with the company.

This is obviously a bad commentary on this particular organization’s food safety culture. First, the food safety team appeared not to be doing a good job in sensitizing all parts of the business on the importance and business value proposition of its food safety practices and initiatives. Second, that senior manager may have been working in a silo without interfacing with other business functions and stakeholders to completely understand how his projects and programs impact other parts of the business. Consequently, every food company must encourage and support the development of an enduring food safety culture to avoid such grievous disconnect between its food safety management system and the important stakeholders that influence its successful implementation.

An enduring food safety culture – will the customer notice?

Recently, we had an opportunity to visit a large retail food company in the Southwest. The parking lot was so tidy that we couldn’t find a single piece of trash usually left by customers on carts or littered around cars and cart holding stations. The facility floors were so polished and sparkling clean that you could see your reflection and yet the floor coefficient of friction remained at its best to avoid slip and fall accidents. After taking in all the neatly arranged food prep work areas, the correct use of gloves, proper hand washing and the overall professionalism of the foodservice workers, I managed to excuse myself to take a look at the restroom. In my mind, the condition of the restroom would be the true test for an organizational food safety commitment from the customers’ standpoint. Even as a Cleaning & Sanitation enthusiast who is never satisfied unless it feels and smells clean and sanitary, I was impressed by what I saw.

To further validate my observations, I left the guided tour and sneaked into one of the company’s stores in a less affluent neighborhood, and it still looked good.

Several days later, I had an opportunity to meet with the company’s senior vice president. How did you do it? I asked. I got a very simple response but yet so revealing. Food safety culture is taken seriously by the company leadership, from the top down (and not from the bottom up! my emphasis). The Director of Food Safety reports directly both to the senior vice president and to the CEO. This means that food safety has direct access to top level management.

Listen to this: every employee in the organization including senior management sat through a food safety training certification on a regular basis. The best part – the CEO actually attends food safety conferences along with the food safety team. According to the senior vice president, the rate of return on investment continues to be outstanding, and the company is still expanding, in spite of the uncertainty in the current business environment. Thus, it appears that an enduring food safety culture is also good for business!

Although a third party food safety gap analysis is recommended for evaluating an organization’s food safety culture and commitment, let me challenge you to do it differently using the benchmarks from this exemplary retail food company in the Southwest, as follows:

  • Are you able to get your CEO to attend a major food safety conference?
  • Does your food safety team have direct access to top level leadership management or at a minimum reports directly to a Vice President who can take far reaching decisions before situation snowballs into something big and messy for your customers?
  • Is there any kind of company-wide food safety awareness training for all employees especially including senior leadership management in your organization?
  • Is every company employee aware of how their specific job function interfaces with food safety in fulfilling the company’s mission and supporting customer satisfaction? A good example would be an hourly worker at the store level knowing why we need 50 – 100 ppm chlorine based sanitizer to sanitize food contact surfaces, and the CEO understands that proper sanitation of food contact surfaces using the right tools by employees with the right training is mandatory.

Cleanliness and the perception of cleanliness are the key customer indicators for any good food safety culture. Customers don’t care about complex food safety management system that sometimes is so cumbersome to implement by folks at the frontlines. Instead, customers care about the little tell-tale signs of food safety that they see during their brief visit to your retail foodservice establishment. If the customer can trust you in such little things like keeping the parking lot, dining room, restroom or drive-through clean, it becomes even easier to trust you on the big stuff that happens away from the prying eyes of the customer at the back of the house. There’s an empirical evidence that cleanliness is directly and significantly associated with increased sales and profitability.

So, let’s take a moment at the beginning of this year and make yet another new year resolution to perform our annual food safety gap analysis, assess our organization’s food safety culture and implement the much needed corrective actions to fill these gaps towards the establishment of an enduring food safety culture. Let us convince senior management that it is good business that not only pays for itself but pushes customer satisfaction and profitability beyond our wildest dreams. Happy New Year, folks!

Gina Kramer
Food Safety Think Tank

An Introduction

By Gina R. Nicholson-Kramer
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Gina Kramer

This new column on Food Safety Tech is a B2B forum for food safety tech, food manufacturing, food distribution, food retailer service/sales, and chemical and tools manufacturing companies in our industry. One of the important efforts we all have in common in this industry is we must continually identify food safety risk (or gaps) in food manufacturing, distribution, and sales to develop improved systems, methods, chemicals, and tools to fill these gaps and reduce risk. In the near future, many of these efforts will be mandatory due to the new regulatory rules being developed through FSMA.

Food Safety Think TankMy goal for this column is to facilitate new thinking to stimulate innovative solutions in food safety for our industry. I have the experience of leading large chain food sales and food service food safety programs; working with business professionals within our respective food companies and with our vendors, to develop systems and tools to improve food safety.

How can this column be of value to our industry?

  • Follow the column. Subscribe to FST News, and receive notifications of the column in your inbox whenever we post something new.
  • Participate. The column should be more than just a source for useful information; I actually want to start a conversation with you – industry professionals. Respond to column posts and share what you know, ask questions, submit ideas, inform us of gaps you see in food safety, and share your efforts, etc.
  • Contribute. We are actively looking for industry professionals who want to share their work in food safety. Whether it’s benchmarking existing solutions or sharing your research that defines gaps and new opportunities for innovation, we need your contributions. Let’s invoke a broad range of new ideas across a wide range of issues to speed up new or improved tools, reduce cost, improve efficiency, and even develop new business models for food safety solutions. Write to me at Gina@SavourFoodSafety.com. I look forward to hearing from you. 
Dan Okenu, Ph.D., Food Safety Manager, H-E-B
Retail Food Safety Forum

Bridging the Gap in Food Safety Training at the Frontlines

By Dan Okenu, Ph.D.
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Dan Okenu, Ph.D., Food Safety Manager, H-E-B

Whenever food safety professionals gather together in any conference, there is always emphasis on how to close the training gap that exists between industry best standards and the actual food safety practices on the frontlines of consumer interface. In retail foodservice, this enormous training gap can be better visualized in the publicly available records of local health inspections or in the privately held third party food safety audit reports. As a food safety enthusiast, I do check on these health department scores on restaurants before taking my family out for our favorite meals. Such consumer pre-check vetting is becoming routine for several social media savvy individuals as this information becomes easily accessible to the public on hand-held electronic devices.

HDScores is a good example of an app that shows health inspection scores for restaurants and other food establishments. As part of public service, local news media also publish these health inspection violations to guide consumers in making better and safe choices. These violations have direct negative impact on the bottom line, especially for repeat and gross violations like pest management issues which can lead to closure of the facility until adequate corrective actions are implemented and the facility is certified compliant before it opens for business again, in the interest of public safety.

According to health inspection records, there are three most common food safety violations, which include failure to wash hands, improper temperature control, and cross-contamination challenges. Below are examples of actual violation citations from health inspectors:

  • Single-use gloves used for multiple tasks that present risk of cross-contamination.
  • Food prep employees wearing gloves to prepare food and then used to open cooler doors and get items from the back kitchen; employees then return to the front prep line and continue food prep without discarding gloves, washing hands, and putting new gloves.
  • Cutting boards in disrepair with significant cuts and mold build-up.
  • Ice-machine and area around soda dispenser nozzles were unclean with significant mold build-up.
  • Dish machine observed cleaning dishes without dispensing any sanitizer.
  • Food observed in walk-in cooler and racks in prep area that had been cooling for 2+ hours without reaching 70 ̊ F.
  • Potentially hazardous food made onsite were observed without labels, and not properly cooled.
  • In use wet wiping cloths stored in chlorine sanitizer that was below 50 ppm.
  • Employee observed discarding trash outside, and then re-entered facility and started working on cookie dough without washing hands.

While food safety employees at the corporate offices are adequately trained and participate in refresher courses through conferences and workshops, the frontline foodservice employees are not as lucky, and yet they are the ones that actually implement the fancy and sometimes complicated SOPs conceptualized and developed by the corporate food safety staff.

Let’s face it folks; our food safety management system is as good as the efficiency and effectiveness of its implementation by employees with direct access to food and food products at the frontlines. We must endeavor to give these very important stakeholders the right tools and adequate training to get the job done.

A conscientious head of Food Safety in one of the large retail foodservice chains who wanted to evaluate the effectiveness of their approved SOPs, volunteered to exchange his corporate suit with an apron, and worked the entire day at the restaurant, performing assigned chores exactly as written and approved by corporate. To his chagrin, he discovered that the simplest of tasks was not only time consuming and labor intensive but absolutely impossible to implement according to the books. The SOPs were simply not operationally feasible!

The take home message was that SOPs must be operationalized within the context of the prevailing conditions in the retail foodservice units, in a simple language that could easily be understood and replicated by foodservice employees who are mostly young adults in career transition status.

Other factors that may account for this training gap include the high turn-over rate for these young hourly and seasonal employees who receive little or no food safety training before getting involved in the next peak sales rush hour. The use of e-learning modules on hand-held devices may be the preferred option to reach employees in real time, but it has its short comings in being impersonal with non-interactive mode of instruction and over generalization, even when different operational situations exist in the retail units. In foodservice operations, the back of the house is not for the fainthearted, especially during the high peak periods of breakfast, lunch and dinner. Without proper training, food safety can be compromised during such rush hours in trying to keep up with high volume sales within a small window period.

In a recent Global Food Safety Survey of 649 food establishments worldwide, improved product quality and higher employee morale were identified as the greatest benefits of effective food safety training, while finding the time for training was recognized as the greatest challenge. Thus, to bridge this training gap among frontline retail and foodservice workers, some of the corporate policies that should be emphasized are as follows:

  • Set aside time for on-the-job training; the generally preferred training method in food industry.
  • A certified training director should be on site at all times, to train hourly and seasonal employees, and training the trainer should be a corporate responsibility.
  • Corporate staff must ditch their suits and ties, and pick up the aprons to serve in the frontlines at least once a month, not only to ensure that their SOPs are operationally feasible but to understudy the thorny operational issues that can be fixed to improve efficiency.
  • Improved hourly wages and paid sick leave will attract a more committed workforce and lower the turn-over rate to ensure continuity in food safety management at the store unit level.
  • The use of incentives to encourage healthy competition among retail units and employees will improve adherence to food safety standards.
  • Encourage active managerial control using evaluation tools like wireless temperature monitors, hand washing monitors or cleanliness testing swabs that measure cleanliness to ensure that corrective actions are implemented in a timely manner.
  • Empower the retail units to conduct self-in-house food safety auditing on a daily and weekly basis to determine performance, and assist in compliance and preparations for third party audits and local health inspections.

In conclusion, it is absolutely necessary to explain the “why” of every food safety procedure to retail and foodservice workers, so that they are fully aware of the food safety implications of their actions. It definitely makes a lot of business sense to invest in continuous training of these frontline employees on the rudiments of food safety, to empower them, to safeguard the huge cost of corporate food safety management system, to protect your brand, and to protect the public health.