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

By Dan Okenu, Ph.D.

Produce safety featured prominently in the recently concluded Food Safety Consortium in Chicago November 17-18, 2014 for two reasons: First, produce remains the largest source of foodborne illness outbreaks in the United States, and second, the recent supplemental notice by FDA calling for another round of public comments on the proposed rule for “Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption.”

Thus, a consortium of growers, processors, packers, suppliers, retailers, buyers, innovators, regulatory officials and food industry consultants came together in the retail foodservice track to discuss “Benchmarking Produce Safety from Farm to Fork.”

The central question revolved around compliance with FSMA provisions to continue supporting the availability of safe quality food in a cost-effective manner. Issues surrounding the provisions of foreign supplier verification and how to engage with FSMA-exempt small local growers and suppliers on produce safety were discussed. The thorny problem of a quick and reliable traceability system for produce was also addressed. Other issues that were discussed include: how to ensure and verify good agricultural practices in the farms; introducing a safe and effective kill step in both cut and whole produce; and how to avoid cross-contamination on washed ready-to eat (RTE) fruits and vegetables. We also deliberated on how to close the gap in-between FDA audits to ensure that proper food safety practices are in place all year round.

The consortium brainstormed on how to take the current produce safety industry practices to the next level, towards a science and risk-based preventive approach as provided for in FSMA. To adequately address the issue of auditing gaps and the FSMA foreign supplier verification provision, it was suggested that it could be cost-effective for large scale buyers to embed their employee on site with large scale growers, processors and suppliers, especially for those located in foreign countries. This will support a real time status update on the food safety practices in place at such foreign facilities by your corporate employees, and in fact reduce the need for expensive frequent and auditing visits that don’t really capture everything. It can also be a conduit for training and maintenance of corporate food safety and quality standard to enhance the delivery of safe quality products, especially if your company is doing business in developing countries where food safety policies and regulatory enforcement are still in rudimentary stages.

Alternatively, make it a corporate policy to do business with only GFSI-certified facilities and increase the frequency and duration of unannounced audit visits for a more representative assessment and documentation of the prevailing food safety practices in place.

In addition, some private-label food programs involve ownership of farms, manufacturing plants and processing facilities. Thus, some retailers operate their own farms and plants both here in the United States and in foreign countries, and that may enhance active managerial control on produce safety from farm to fork. Engaging small local growers who are FSMA-exempt through an organized Agricultural Extension Services will enable resource sharing for implementing standard food safety practices and support integration in the local market. It will not only bring down cost but will also increase the availability of fresh fruits and vegetables without the need of a long distance temperature-controlled distribution network.

Both government and the private sector can support the running of these extension services in a more robust manner that builds upon the current USDA Cooperative Extension System which provides useful, practical research-based information to agricultural producers. A safety gateway could be established for produce from local growers through innovation on an effective pathogen kill step that can achieve up to 5-log reduction using effective consumer-friendly sanitizers.

GRAS classified sanitizers like electrolyte water, Ozone, hydrogen peroxide, chlorine dioxide and sodium hypochlorite are under various stages of R&D and some have been found to extend produce shelf life as well. Since the absence of a microbial risk does not preclude chemical contamination; continuous testing and monitoring for chemical residues that may result from the use of pesticides, contaminated soil or manure is recommended. A reliable produce traceability system will facilitate the investigation of foodborne illness outbreaks and timely corrective actions.Current R&D innovations in this area include the use of DNA tagging to assist in identifying both cut and whole produce even when out of the box. It was also stressed that behavior change is as important as the technology-driven interventions, and as such should be encouraged among retail and foodservice workers to embrace best practices and avoid actions that may lead to cross-contamination of RTE foods. Washing and rinsing of produce singly in running cold water is not only recommended for removing dirt and foreign matter but also for eliminating potential cross-contamination that may result from soaking fruits and vegetables.

Overall, it was a lively discussion that was spiced with practical real world examples by highly experienced industry leaders and decision makers.

October 23, 2014

Retail Food Safety Forum

Ebola Virus and Body Fluids Clean-Up in Retail Food Operations

By Dan Okenu, Ph.D.

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As the Ebola scare spreads in the United States and threatens the rest of the world, it is a race against time to find an effective vaccine or cure. Until then, the old reliable public health method of contact tracing, patient isolation and quarantine of suspected cases to disrupt transmission remains the only choice out there. The establishment of body temperature monitoring stations at the major airports will only capture elevated temperature symptomatic cases. This implies that infected individuals still within the incubation period of up to 21 days may not have high fever and thus may slip through the system. Examples include the index case from Liberia that arrived Dallas, Texas without elevated temperature or symptoms, and the recently infected Dallas Nurse that was cleared by CDC to fly to Cleveland, Ohio without elevated body temperature.

Apart from airports and hospitals, other public places, including retail food service outlets, have the risk of becoming potential sources of contact for fully bloom symptomatic cases that can indeed transmit the Ebola virus and infect several others. Recently a Doctor under voluntary Ebola quarantine after returning from Liberia broke the quarantine to visit her favorite restaurant.

Some of the Ebola transmission dynamics that should be a source of concern to the retail industry are as follows:

Ebola virus is transmitted through close contact with body fluids (blood, urine, saliva, sweat, feces, vomit, breast milk, semen, etc.) from a sick Ebola patient.
Ebola virus can spread through contact with objects likes clothes, bedding, syringes/sharps, medical equipment or contact surfaces contaminated by blood or body fluids of a patient.
Emergency body fluids incidents are regular occurrence from customers in retail food facilities.
According to CDC, Ebola virus dried on contact surfaces like door knobs and countertops can survive for several hours, while Ebola virus in body fluids can survive for several days on contact surfaces at room temperature.
Restrooms at retail outlets are accessible to both customers and the general public, and thus may constitute a hazard in Ebola virus transmission, if not properly cleaned and disinfected (not sanitized!).
Ebola patients can transmit the virus within the time frame of the first appearance of symptoms before hospital isolation. Patients may visit retail environments during this infectious period before the onset of severe symptoms that will trigger immediate hospitalization.

The foodservice and retail environment is among the vulnerable public places where infection may be possible if appropriate measures, protocols and employee training are not in place. What can retail management do differently to be ready and to proactively safeguard their facilities and protect their customers and the entire public health? The good news is that a lot of these measures are already contained in the Food Code and thus would only need to be reinforced to highlight their importance during these Ebola times.

Some of these proactive measures may include the following:

Establish proper protocol for cleaning and disposal of body fluids (see previous blog on Combating Norovirus Hazards in Retail Foodservice). The pathogen kill-step is the most important step in any body fluid clean-up process and must be done with a disinfectant grade chemical. Adequate personal protective equipment (PPE) like gloves, disposable aprons, and protective eye goggles is mandatory.
Compliance with use of gloves and no bare hands contact with ready-to-eat foods.
Adequate and frequent washing of hands by food handlers while encouraging hand washing by customers through the provision of the necessary accessories in hand wash sinks. According to CDC, Ebola virus is readily killed by using soap and water, bleach or hospital grade disinfectants.
Handle body fluids in the restroom, grocery store aisles, play areas, dining rooms, and kitchen areas as potential infectious materials.
Establish and implement an appropriate Employee Health Policy without punitive measures; to encourage hourly paid employees to stay home when sick.
Introduce a non-residual disinfectant grade chemical (instead of regular sanitizers) for disinfecting restrooms, play areas and high touch points like doors knobs and equipment handles. Note: Disinfectants cannot be used on food contact surfaces.
Eliminate or put on-hold programs like Back Stage Tours that bring customers in close proximity with food and food preparation areas at the back of the house.
Buffet style food services should develop a better strategy to completely protect food from self-service customers.
Proper cleaning and sanitizing of food contact surfaces using best practices like the single use no-rinse cleaning and sanitizing wipes from Sani Professional (see previous blog on Clean Matters). Hand sanitizers should be made available to customers at strategic locations throughout the retail facility to encourage use.
Training and re-training of employees on best practices cannot be over emphasized in this new era of Ebola scare and confusion.

Finally, retail and foodservice employees should be trained to recognize the obvious signs of sick customers especially if accompanied with vomiting and diarrhea. The affected incident area should be cordoned off and the facility may be closed down depending on the severity of the suspected case. The State and Local Public Health officials and the CDC should be notified immediately. In these Ebola times, it’s better to err on the side of caution than to regret actions on a potentially positive Ebola case.

It is indeed a good time also to rethink the level of food safety culture in your organization and what you can do to ensure that your organization is not in the news for the wrong reasons. Foodservice and retail operations must remain on alert until the US Public Health Service and other relevant US government agencies have a complete handle on this monumental public health emergency.

September 25, 2014

Retail Food Safety Forum

Food Spoilage and Food Loss in Retail Environments

By Dan Okenu, Ph.D.

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It can be frustrating to consumers to discover some rotten fruits or not-so-fresh vegetables in their grocery packs in spite of due diligence at the stores. It also leaves a bad taste in the mouth while in your favorite restaurant, you’re served cold food, observe that the taste is just not right, the color of your favorite menu is not the same again or become suspicious that the food texture has been compromised and it doesn’t feel crispy or crunchy any more.

These are the tell-tale signs of food spoilage that customers are confronted with on a daily basis. In foodservice and retail environments, food spoilage constitutes a major food safety and food quality hazard with far reaching regulatory implications as well as being an economic burden with considerable food loss and profit loss. Food manufacturers and processors have achieved a high level of food preservation through several advanced technologies including heat treatment, temperature and water control, pasteurization and canning, specialized packaging like reduced oxygen packaging, fermentation and antimicrobial preservatives. However, food spoilage remains a major challenge in retail and food service. This is mostly as a result of the many food processing and preparation activities, food storage practices, repackaging and food portioning that are required in retail.

In addition, the modern consumers’ preference for fresh foods and the backlash on the use of unnatural preservatives leave foods more vulnerable to spoilage resulting in substantial food loss. Here, we discuss some of the challenges of food spoilage and how to minimize its impact on food safety, quality assurance and profitability in retail food operations.

The most important proactive measure against food spoilage is a tight managerial control on Supplier Food Safety and Quality Assurance. The condition of the food items upon delivery to the retail units will impact the overall shelf life, taste, texture, structural integrity and pathogen level during storage and food preparation activities. Food transportation best practices, cold chain requirements, temperature monitoring system, freeze-thaw detection, appropriate packaging, adulteration prevention and food tracking should be addressed at the supplier level to ensure that deliveries are wholesome safe quality foods. Integrated pest management at suppliers’ facilities and delivery trucks are also essential. Random testing of food products for pathogen content and quality control will assist in compliance with FDA/USDA regulations and internal corporate standards.Thus, a comprehensive evaluation and verification of the supplier food safety and quality assurance programs will help to ensure compliance with all relevant federal/State/local regulations (see previous blog on Supplier Qualification and Compliance using GFSI Benchmarking).

After suppliers deliver safe quality foods, in-store food safety and quality assurance control measures must be activated immediately to maintain safe quality food status until food is served to the customer.

At the retail units, appropriate food handling and storage practices to eliminate cross-contamination is key.

The use of rapid cleanliness monitoring test swabs to validate clean and sanitary food contact surfaces will enable timely corrective actions that would eliminate potentially hazardous food cross-contamination.

Proper hand hygiene by all foodservice employees should be mandatory.

Keeping cold food cold and warm food warm is a food safety mantra that ensures foods don’t get to the temperature danger zone. Temperature monitoring systems for freezers and refrigerators using wireless technologies will ensure a better food storage control even during non-business hours.

Emergency preparedness training for natural disasters and power outages should be in place to avoid surprises.

Compliance with FDA regulations for safe refrigerated storage, hot holding, cooling and reheating of food within the time and temperature criteria will help eliminate spoilage organisms and preserve the taste, texture and overall quality of food throughout its shelf life, especially for meat and poultry products.

Proper management of products’ shelf life, expiration dates and observing the principle of first in first out (FIFO) should be encouraged. In fact, the food code requires a system for identifying the date or day by which food must be consumed, sold or discarded. Product date marking enables compliance with this food code requirement to date mark all prepared food products, and to demonstrate a procedure that ensures proper discarding of food products on or before the date of expiration. Local health inspectors reference these product date marking labels and enforce them, in addition to food prep activities that may lead to cross-contamination, adulteration or spoilage. Inventory control, forecasting and Lean Six Sigma are important tools for managing food supplies, storage, preparation, stock replenishing and elimination of excess food items that may get past their shelf life.

Raw proteins (meat, sea food and poultry) are arguably the largest cross-contamination sources for pathogens in foodservice. Any novel pathogen reduction or elimination process like the potential production of pathogen-free chicken would be a welcome relief, and will not only save money and labor; it would protect the public health as well.

Produce (fruits and vegetables) remains the largest source of foodborne illness outbreaks in United States, because it’s a ready-to-eat food that doesn’t get the benefit of cooking at high sterilizing temperatures. An effective pathogen kill step for produce using consumer-friendly natural washes like electrolyzed water may serve as a gate keeper in case the safety system fails at the plant level. Ice-cold electrolyzed water is also known to refresh produce and may extend their shelf life as well.

GMO-food products could be engineered to resist pests and spoilage organisms with improved shelf life, but its general acceptability and the FDA labeling disclosure requirements are still contentious issues.

While industry is racing to develop several promising anti-spoilage technologies, active managerial control of the various components of an effective food safety and quality assurance system remains the best practice against food spoilage and associated food losses in retail food operations.

August 21, 2014

Retail Food Safety Forum

Supplier Qualification and Compliance using GFSI Benchmarking

By Dan Okenu, Ph.D.

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An efficient supply chain is very important in retail food operations. To safeguard the supply chain, a comprehensive supplier food safety program should be an integral part of retail foodservice (see my previous blog on Combating Norovirus Hazards in Retail Foodservice). This becomes even more challenging because one, retail foodservice chains don’t own their suppliers; they’re independently managed businesses, and two, the new regulatory burden placed on retailers by FDA through the proposed FSMA rule to ensure that retailers are accountable on the sources and safety of their products to continue serving safe quality foods to their customers.

Thus, continuous verification of supplier qualification and compliance is as important for food manufacturers and food processors, as it is for food retailers. To fulfill this very important business requirement, the retail Food Safety & Quality Assurance job function would usually include the following roles:

To conduct continuous food safety audits and monitor suppliers to ensure compliance with all FDA/USDA, State and local regulatory standards;
To monitor adherence to product specifications, identify deficiencies and implement corrective actions in a timely manner;
To perform internal and external testing to verify risk assessment and risk mitigation procedures.

How do retail folks try to tackle these important business functions, especially since most retail chains have so many domestic and international suppliers? The Global Food Safety Initiative (GFSI) benchmarking provides a common ground for farmers, manufacturers, food processors and retailers on global food safety best practices. GFSI strengthens the supply chain, eliminates multiple auditing, increases confidence in safe quality food delivery while protecting the public health.

The different GFSI schemes which include PrimusGFS, BRC, SQF, GlobalGAP and FSSC2200 are auditing entities involved with several scopes of food safety and quality assurance service standards, while others like AIB, SGS, NSF and SAIGlobal are certification bodies that perform facility audits. As a business-driven initiative, majority of food processing facilities depend on the GFSI Guidance Document for supplier qualification and compliance by using any of their benchmarking schemes. The advantages are tremendous and include less product recalls and voluntary withdrawals, enhanced traceability, clearly defined risk management and HACCP control, acceptable uniform international standards, eliminates redundancy and frees up time and resources for both food manufacturers and retailers.

Apart from supplier compliance and approval, food retail companies also want to ensure that all potential suppliers align with their corporate values and standards of ethics. GFSIschemes however do not cover these corporate needs like environmental sustainability, animal welfare, ethical sourcing, compliant labor utilization, organic and non-GMO product verification. Moreover, the auditing time frame for most GFSI schemes is only about a few days and thus gives just a snapshot of the food safety practices in these GFSI-approved facilities. Retail food companies will therefore require a more elaborate supplier monitoring and approval system to ensure that certified facilities are not just compliant within the FDA auditing time frame of about one to four days, but that their food safety culture and practices are consistent with their corporate mission to deliver safe quality food to customers.

Additionally, such continuous monitoring and verification will ensure that suppliers are also complying with company policies outside the provisions of GFSI schemes. Proper training of retail Food Safety & Quality Assurance managers on FDA/USDA inspection requirements and corporate expectations at the food processing facilities is absolutely required. The use of third party auditors to assist retailers in verifying supplier qualification and compliance is also advisable because of the often overwhelming number of suppliers involved.

Finally, as FDA begins to implement FSMA, it would be pertinent to verify FSMA readiness of the different GFSI schemes. This will ensure that GFSI certified food manufacturing and processing facilities remain in compliance with the new regulatory provisions for FSMA covered facilities. It would help to avoid costly disruptions in the supply chain and allow businesses to meet their projected growth while serving safe quality food to their customers and protecting their business brand. Overall, GFSI certification remains the gold standard that will guarantee supplier qualification and compliance at both domestic and international locations.

Ravi Ramadhar, Food Safety Business Director for Life Sciences Solutions, Thermo Fisher Scientific

August 6, 2014

In the Food Lab

Molecular Diagnostics – Generation 3: 2005 to Present

By Ravi Ramadhar

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In my previous blog, I covered the first two generations of Molecular Diagnostics: Generation one, was the advent of these tests prior to 1995, while the second generation saw the evolution of molecular diagnostics with the emergence of standardized food molecular and method workflow.

The advent of automated DNA sequencing and use of multiple fluorescent dyes by companies like Applied Biosystems and Roche led to the development of multiple fluorescent dyes and real- time quantitative PCR systems (qPCR). At first these qPCR systems were only used in the research environment, but quickly found their way to the food industry.

Applications such as quantitation of GMOs and multiple pathogen targets became common. Real-time PCR systems permitted users to visualize amplification as it happened and enabled simultaneous detection of multiple targets. With the use of newer chemistries and improved enzymes, shorter amplification cycles – sometimes as low as 40 minutes – could be achieved. The real-time systems offered faster time-to-result with additional target probes and thus higher target specificity. As with most molecular methods, the workflow was sensitive to food matrix inhibition and required alternative sample preparation methods to meet the wide variety of food matrixes.

Within this generation of solutions, alternatives were introduced, that promised faster, easier or more sensitive results. These included alternative to either the detection method or enzymes utilized Iisothermal amplification, for example without need for multiplexing capability of qPCR or internal controls, as well as targeting alternative nucleic acid such as RNA were introduced to the food market. These incremental improvements did not lead to any significant new paradigms or improvements to the food testing workflow. Their emergence instead led to an explosion of additional and alternative molecular platforms for food, without any real innovation. Within this, solutions introduced to the food industry eventually brought us to where we are today.

Directly taking systems from the clinical diagnostics workflow and introducing these platforms and systems as food solutions. While these systems automate the entire workflow or automate the PCR setup it remains to be seen if with their higher complexity and high maintenance these systems can survive the food industry. The basic molecular workflow for food has remained intact since its introduction in the late 1990s with innovation more or less stagnant. What’s needed is for someone to truly develop a platform from the ground up with the food laboratory in mind.

Today’s landscape and what’s next

Today, there are some early signals of where innovations and changes for food labs will emerge. A recent poster by Nestle, for example, highlighted the uses of next-generation sequencing (NGS) and DNA sequencing to develop a DNA method to allow the identification of coffee varieties through the value chain, from the field to the finished product. The method is applied on routine basis to guarantee the purity and authenticity of raw material used by Nespresso.

Applications of NGS in outbreak response and trace back investigations are being used in parallel with existing technologies. Finally, availability of new sequencing data enables better assay design and development of adjacent technologies.

NGS was preceded by emulsion amplification and sequencing by synthesis. These developments led to the development and introduction of digital PCR. Within a digital PCR reaction, millions of simultaneous reactions from one sample occur. The advantages of dPCR include lower and absolute, not relative gene copy number. The data has high precision and has better tolerance to inhibitors. These characteristics can lead to better and more precise molecular tests in food. , Before dPCR wide spread adoption is seen, however, the limitations of high cost and limited dynamic range must be addressed.

It’s not only in the testing labs and adjacent technologies that NGS is having an impact. In the labs driving innovation in food and food ingredient development, applications of NGS are being used to develop targeted food ingredients.

Nestle is the leader in this convergence of food, health and nutrition and over the last three years, the company has acquired and formed partnerships targeting the space. In its formation of the Nestle Institute of Health Sciences, Emmanuel Baetge, head of NHIS, emphasized NHIS expertise and research capabilities using systems biology, next generation sequencing, and human genetics.

The world of food safety is as dynamic as the natural flora of food itself. Changing regulations, evolving organisms, technological change and consumers’ changing tastes require new solutions. The requirements of the food laboratory have not changed. They are the protectors of brands and the teams we trust to deliver safe and quality foods. However, how they do that has and will continue to change.

Next time… molecular serotyping.

References:

Wetterstrand KA. DNA Sequencing Costs: Data from the NHGRI Genome Sequencing Program (GSP) Available at: www.genome.gov/sequencingcosts. Accessed 1/13/2014 [DOA 1/13/12014].
Beilei Ge and Jianghong Meng , 2009 14: 235 Advanced Technologies for Pathogen and Toxin Detection in Foods: Current Applications and Future Journal of Laboratory Automation DOI: 10.1016/j.jala.2008.12.012.
Morisset D, Sˇ tebih D, Milavec M, Gruden K, Zˇ el J (2013) Quantitative Analysis of Food and Feed Samples with Droplet Digital PCR. PLoS ONE 8(5):e62583. doi:10.1371/journal.pone.0062583.
http://www.nestle-nespresso.com/asset-libraries/Related%20documents%20not%20indexed/Nespresso%20poster%20ASIC2012%20DNA%20traceability.pdf

July 31, 2014

Retail Food Safety Forum

Combating Norovirus Hazards in Retail Food Service – Part 3

By Dan Okenu, Ph.D.

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In the past two weeks, this blog has covered how Norovirus is the leading cause of foodborne illness worldwide, some potential sources of outbreak, and the importance of proper handwashing, developing an employee health policy, building a comprehensive food safety program, and training of employees. One critical aspect of Norovirus management is proper attention paid to cleaning and disposal of body fluids.

Proper cleaning and disposal of body fluids

The food code requires that retail foodservice establishments have proper procedures in place for emergency body fluids clean-up. Body fluids incidents in the dining room, play areas or back of the house are arguably the single most important source of Norovirus cross contamination in the restaurant, if clean-up and disposal are not performed according to standard operating procedures. The components of an effective and compliant SOP for emergency body fluids clean-up may include the following:

Written step by step procedure to contain, isolate, clean and disinfect affected areas;
Ready and easily accessible emergency body fluid clean-up kit;
Use of PPEs like disposable aprons, gloves and protective eye glasses;
Norovirus approved disinfectant as a kill step before and after clean-up;
Containment of body fluids spill using absorbent yellow spill pads to reduce aerosols;
Affected area should be isolated to avoid accidental dispersal by guests;
Discard all affected open food and decontaminate all affected surfaces;
Stop all food prep until body fluids are contained, cleaned and affected area disinfected;
Perform clean-up with disposable towels and yellow spill pads for easy disposal;
Wear triple gloves to avoid contaminating the clean-up kit and storage area;
Dispose clean-up trash straight in outside dumpster without passing through kitchen; and
Employee must wash hands twice, first in the bathroom and then in the kitchen.

The pathogen kill-step is the most important step in the body fluid clean-up process. The preferred option is to use a disinfectant grade chemical instead of regular sanitizers.

Ecolab’s Insta-Use Multi-purpose Disinfectant Cleaner is effective against Norovirus (and other viruses), mold, mildew and bacteria. It cleans, deodorizes and disinfects in one labor saving step and packaged in an easy to use compact cartridge with less storage space requirement. Caution: Disinfectant is not approved for food contact surfaces and cannot be used as a replacement for regular sanitizers on food contact surfaces.

Proper training of team members and associates is required before use to encourage compliance.

In conclusion, Norovirus is still a major infectious pathogen associated with foodservice operations in spite of several regulatory control and technological advances to curtail its occurrence and prevalence. Until a viable vaccine or an effective drug becomes available against Norovirus, rigorous implementation of food safety procedures, behavioral changes and continuous training of both foodservice workers and customers will remain the industry’s best practices at prevention and control. Overall, it makes a lot of business sense to do all that it takes to protect your customers against the threat of Norovirus infection, and by so doing, equally protect your business brand and the entire public health.

July 17, 2014

Retail Food Safety Forum

Combating Norovirus Hazards in Retail Foodservice

By Dan Okenu, Ph.D.

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Norovirus is the number one cause of foodborne disease outbreaks worldwide. It makes people sick causing nausea, stomach cramping, vomiting and diarrhea or “stomach flu” and leads to a lot of discomfort and even death, especially in vulnerable populations like children and the elderly. Elevated risk of infection is associated with certain foods that are served raw, like fruits and vegetables, contaminated ready-to-eat (RTE) foods, or improperly cooked Oysters from contaminated waters. According to the CDC, Norovirus is the leading cause of illness and outbreaks from contaminated foods in the United States, especially in retail foodservice settings like restaurants.

Some of the potential sources of Norovirus outbreaks in retail foodservice are as follows:

Infected food handlers
Infected non-food workers and guests
Bare hands contact with RTE foods
Contamination of food deliveries at source
Improper cleaning and disposal of body fluids
Training gap on sanitizer and disinfectant use
Aerosolized vomitus around food and people
Contaminated food contact and non-food contact surfaces
Improper hand washing by food handlers
Cross contamination from restrooms
Cross contamination from high touch points in the back of the house

It is apparent from the statistics that Norovirus constitutes a major hazard to the retail foodservice industry. The good news, however, is that there are a lot of cost-effective strategies that can be implemented in a proactive manner to reduce its spread and impact on businesses, protect customers and the bottom line. Some of these preventive measures will be discussed here and in next week’s blog post.

Proper Hand Washing by Foodservice Workers

Proper hand washing is the most cost-effective method for preventing cross-contaminations including Norovirus in a retail foodservice environment. Hand wash sinks should be appropriately located to encourage compliance by both foodservice workers and guests. For example; the food code requires handling dry clean dishes with clean hands during the dish washing process. Thus, it makes a lot sense to install a hand wash sink in close proximity to an automated dishwasher. This will enhance hand washing compliance by Team Members before handling and stacking dry clean dishes. Adequate soap and hand sanitizers should be provided at all hand washing stations including restrooms. Whereas the use of hand sanitizers is not a replacement for proper hand washing with soap, there is evidence that hand sanitizers are effective against Norovirus. Proper hand washing remains the preferred option however, since the use of soap can indeed get rid of other cross contaminating organic matter and dirt. Incentive programs may be used to encourage frequent and proper hand washing by foodservice workers. More resources may be found at handwashingforlife.com to help foodservice establishments update their hand washing culture.

While enforcing proper hand washing among foodservice employees is desirable, it is also advisable to encourage hand washing among guests. Norovirus can be transmitted by infected guests to the foodservice establishment especially in buffet style restaurants where guests come in very close proximity with RTE foods. Facility design that encourages hand washing by guests was elegantly captured by the Florida based PDQ restaurant chain that installed a hand wash sink in their main dining room with a strong brand statement that “quality and clean go hand in hand”. The strategic location of a hand wash sink encourages hand washing by guests, especially among children in the full view of their parents, and with less cross contaminating contact surfaces as found in the restrooms.

Restroom Cleaning and Sanitation

Color coded cleaning and sanitizing tools are recommended for restrooms to prevent cross contamination. Tools will be dedicated for use in restrooms only and stored in a dedicated storage or closet to avoid accidental use in other areas of the foodservice establishment. The restroom can be the most important part of the restaurant with opportunities to prevent infections. Guests may also use the cleanliness of the restroom as a measure of food safety commitment by the retail food establishment (see my previous blog on “Clean Matters”). Thus, extra efforts are required to maintain and keep restrooms in a clean and sanitary condition all the time. Use of disinfectant grade chemicals for disinfecting restrooms, body fluids clean-up and high touch point areas is recommended. The alternative of preparing high concentration sanitizers is laborious and prone to mistakes by foodservice workers. In addition, such high concentrated sanitizers like 1000 – 5000 ppm chlorine-based sanitizer can be a safety concern to employees when used without PPEs. Frequent cleaning, disinfecting and replenishing of hand soap and sanitizers in the restroom are effective measures against restroom infections and cross contaminations including Norovirus.

Stay tuned for more preventative measures to be discussed in next week’s blog post…

July 17, 2014

Retail Food Safety Forum

Combating Norovirus Hazards in Retail Food Service – Part 2

By Dan Okenu, Ph.D.

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Last week, in this blog we discussed that Norovirus is the leading cause of foodborne illness worldwide, some potential sources of outbreak, and the importance of proper handwashing and cleaning and disposal of body fluids. In this second part of the blog, we will cover developing an employee health policy, building a comprehensive food safety program, and training of employees.

Develop an employee health policy

It is important to develop an employee health policy with detailed guidelines for sick employees. Sick foodservice workers are required to stay off work until fully recovered and cleared by their Doctor. When an employee becomes sick at work, such an employee must report to the immediate supervisor, and be allowed to leave work to attend to the ill-health. Reportable diseases must be reported upon diagnosis to enable the Local Health Department and affected foodservice establishment take necessary actions to protect the public health. There should be a crisis management plan in case the media gets involved in any such reportable infectious disease situations. To enable ill-health reporting compliance by employees, foodservice establishments are encouraged to adopt an employee health policy that is not punitive in nature.

Managers and supervisors should also be trained to recognize abnormal behaviors and tell-tale signs of ill-health in employees who may choose not to report due to the potential of losing hourly wages. Employee health policy training should be mandatory – to report injuries, ill-health and to follow the exclusion policy from food prep until fully certified and cleared to return to work by the Doctor.

For more resources on employee health policy, please see FDA’s Employee Health and Personal Hygiene Handbook for practices and behaviors of food service workers that can help reduce the spread of infectious diseases in retail food operations.

Self-auditing of food safety procedures

Active managerial control will enable verification of the food safety program for potential corrective actions that may be required including retraining of staff. A self-auditing system will ensure that risk mitigation is applied at every stage of foodservice operations with HACCP plans implemented and verified. In addition, a third party auditing will identify the weak links in the system and help prepare the establishment for Local Health inspections. Proper cleaning and sanitation of contact surfaces, observing the temperature rule – keeping cold food cold and hot food hot or routine cleaning and sanitizing of high touch points surfaces are examples of food safety procedures that managers can evaluate and verify on daily basis to continue serving safe quality food to customers. Effective implementation of these food safety standard will have a direct correlation with reduction in cross-contamination including Norovirus prevention.

Comprehensive supplier food safety program

Food can get contaminated at any point during the farm to fork journey. A robust supplier food safety program will ensure better control of potential risk transfer in retail food operations. A system that ensures that approved certified suppliers are continuously verified will capture any potential system failure and implement corrective action both at the supplier and retail levels. The use of approved suppliers is an important risk mitigation step that should be mandatory and verified to ensure that all deliveries are of the highest food safety and quality standard. Since risk burden may be accentuated at retail foodservice due to multiple operational processes in the kitchen, it is important to assess the risk burden at the supplier level, to enable effective mitigation. Thus, a dedicated supplier food safety monitoring, evaluation and verification is absolutely required at retail foodservice to assist in eliminating any food safety weak link in the supply chain. The safe quality food outcome will remain complementary and supportive of the supply chain’s mission of “never run out”.

Training of employees on standard operating procedures

Proper and continuous training of employees is fundamental to a successful food safety program in retail food operations. We may have the best food safety program in place but if these important SOPs are not properly implemented at every operational step as a result of training gap, it may in fact introduce a greater risk into the system. Since most hourly foodservice workers are young adults with a higher than normal turn-over rate, effective communication and continuous training will help keep a good handle on the food safety know-how of each batch of employees. Consequently, it is absolutely necessary to have a certified food safety manager as the person-in-charge to oversee foodservice operations. Training the trainers, managers and training directors will assist in meeting the training needs of all employees including hourly and temporary workers and for compliance with food code requirements.

Online food safety courses and training is the preferred method of instruction for most large retail foodservice chains. These training materials can be accessed anywhere in handheld devices and can be updated in real time. Online training however should not be a replacement for personalized one-on-one onsite training on the job. Hand washing compliance, no bare hands contact with RTE foods, clean-up of body fluids, separating high risk raw chicken, beef and sea foods from RTE foods using a color coded system, and observing critical control points in the food prep process are some of the SOPs that require continuous training and verification to ensure compliance.

Dr. Jim Fredericks, Chief Entomologist & Vice President of Technical and Regulatory Affairs, National Pest Management Association

July 10, 2014

Bug Bytes

Why is Pest Management Critical to Food Manufacturing Operations

By Dr. Jim Fredericks

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Every manager of a food manufacturing plant knows that food safety cannot be compromised under any circumstances and that the entire process is dependent on a number of aspects working effectively, efficiently and in a healthy and safe manner. However, no process is foolproof and any breakdown in the manufacturing process could lead to contamination. Some of the most pervasive contaminants come as a result of insects, rodents and other pathogens finding their way into the plant. It is for this reason that pest management is critical to food manufacturing.

Depending on the type of food product and how it is processed, there are ample opportunities for pests to associate themselves into the food manufacturing life cycle – be it during the growth cycle, at harvest, within the mode of transportation, during material preparation and final processing.

Fortunately, today’s scientific equipment provides the ability to detect amounts of contaminated materials in a given finished product down to the nanogram and “zero” continues to get smaller and smaller with each advancement in chemical [contaminate] detection technology. However, as plant science and seed chemistry improve, so does yield production. With this production increase comes additional processes that create opportunity for pest threats to enter food-manufacturing operations. In order to maintain a safe and clean facility both the food manufacturing facility manager and pest management personnel must address each issue head on.

There are a number of factors that pose challenges to proper pest management in food facilities such as the time of operation [some pests prefer daytime, while others prefer nighttime], production cycles [season of harvest can denote degree of pest infestation], maintenance schedule [how often do lines or plants shut down for cleaning and up keep], delivery schedule and flow of raw materials [when and how they enter and leave] throughout the plant. The addition of other factors, like moisture levels and temperature extremes within the construction elements of the plant, can create ideal conditions for pest harborage and nesting areas.

The world is a smaller place today and food transportation can be accomplished by multiple sources; food products are now shared across borders and oceans in a much shorter time frame than before. Due to the potential introduction of a new pest species or plant disease, it is crucial that facilities and their pest management partners develop a common platform for risk assessment, analysis and preventive controls to achieve success. Having the ability, discipline and quality control processes in place to intercept or disrupt this potential hazard are extremely important. The pest management professional is a line of defense that supports the food manufactures by inspecting, performing audits, identifying and preventing, improving and correcting hazards or situations that could cause damage, contamination or illness.

The consequences of not taking pest management seriously can be devastating to a food manufacturing company – resulting in fines, production shutdowns, closures and even bankruptcy filings. Not to mention a tarnished reputation, shaken confidence and public scrutiny of the brand and finished product. Certain failures may even create a system wide product recall compounding the negative effects.

The words ‘and’, ‘team’, ‘partner’ and ‘critical’ to describe the approach of a pest management professional and food manufacturing facility management and are key in understanding the role each plays – one to cut the risks and the other to protect, both helping each other accomplish the desired level of food safety.

Being proactive about food safety, including pest management, is paramount in protecting life and health. In the food safety industry food manufacturers work with a lot of different standards, protocols and regulations, such as Good Manufacturing Practices (GMPs), Standard Operating Procedures (SOPs), and Hazard Analysis Critical Control Point (HAACP). The standards are risk-based in order to address the issues as risks to public health and food safety due to activities of pests.

FDA is trying to level the playing field on food safety with the implementation of the Food Safety Modernization Act (FSMA) – the biggest change to food safety laws since the 1930’s – helping to bring together the various practices and governing agencies under a common goal – preventing food borne illness with sustainable and accountable improvements in food safety using prevention based controls.

As part of FSMA compliance, the pest management professional must be an integrated member of the food safety team. Thorough knowledge of the plant’s quality programs, manufacturing practices, approved product lists and sanitation programs is critical to success. Both pest management professionals and food manufacturing operations managers should also be aware of new pest control products and application techniques to fully offer the facility the best pest management program possible.

In all food manufacturing facilities, the pest management professional and manufacturing operations facility manager should both be prepared to:

Work together with open communication.
Provide training to both sides, whereas the plant team trains the pest management professional on the facility and processes with expectations of the service agreed upon. The pest management professional trains the food manufacturing team on basic pest management and where this fits into their food safety program and HACCP system.
Set written expectations of services, treatments as well as a process for proper documentation. Utilize an appropriate accountability system of mapping and numbering all points of inspection, monitoring and treatment.
Both parties should remain open to conversation regarding new and innovative techniques and treatment options that utilize the preventive intent of FSMA in conjunction with the concept of Integrated Pest Management (IPM).

The bottom line is that foodborne illness is largely preventable if everyone can be held responsible and accountable at each step they own for controlling hazards that can cause illness.

June 13, 2014

Retail Food Safety Forum

Testing and Evaluation of Food Safety Tools Simplified

By Dan Okenu, Ph.D.

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The management of Food Safety and Quality Assurance (FSQA) system is a key business function that plays a very important role in the sustenance of the food industry. Its primary objective is to produce and serve safe quality food to consumers, through compliance with all relevant Federal, State and Local regulatory laws. It assists in the reduction of food wastage or food spoilage, and thus has a strong impact on the bottom line. Proper management of the FSQA system protects business brands, ensuring that they don’t become part of the gloomy statistics on foodborne disease outbreaks and damaging recalls. In all cases, the protection of the entire public health remains sacrosanct, and in fact, closely aligns with the primary business objective of getting a reasonable return-on-investment. Inevitably, businesses rely on a timely and cost-effective project management to ensure that their FSQA system remains relevant and sustainable for a continuous business growth.

Potential sources of new FSQA projects

Projects intended for the improvement of an FSQA system may be identified and initiated based on input from the following sources:

Regulatory compliance with applicable Federal, State and Local laws;
Voice of customers through complaints obtained by customer calls;
Technology-driven continuous improvement to upgrade to a smarter method, process, equipment or service;
Voice of business franchise operators, owners, managers and team members aimed at improving operational efficiency; and
Operational challenges observed by corporate staff during field visits.

Examples of FSQA projects that require testing and evaluation

At every stage, there will be tons of very important projects requiring urgent attention and competing for limited resources with corporate advertising and brand campaigns which have fixed budgets. Some of these projects may be as simple as putting a new dish-washing scrub pad in the system. This project may have been initiated following several reports by team members that current green scrub pad is not effective and also releases greenish color with scrub pad debris reported in ready-to-eat (RTE) foods. The associated risk is that foreign material in food constitutes a health hazard while improper washing of dish wares may lead to cross-contamination and outbreak of foodborne illness. This is easy but still requires testing to confirm that the new scrub pad is the best cost-effective option. Other projects however may be as complex as introducing a new produce (fruits & vegetables) safety system that includes a pathogen kill-step, instead of the regular cold water rinse. This will provide an extra layer of produce safety at the retail level, in case the system fails at the processing plant facility level, for instance, in the case ofthe multistate Listeria outbreak involving Cantaloupes from Jensen Farms, Colorado in 2011.

Another new initiative could be working with suppliers to validate a new method for detecting bone fragments and physical contamination of boneless poultry meat. Revamping the automated dish-washing room to improve food code compliance is a multifaceted project that requires a lot of resources and planning for a successful testing and evaluation.

Testing and evaluation milestones

A systematic approach is required to properly test and evaluate new FSQA products or services before a chain-wide roll-out is authorized by management. Depending on whether we are looking to introduce a new product or service into the system, some of the testing and evaluation milestones may include a combination of:

R&D to determine and evaluate options to resolve issue;
Review of options for industry best practices by FSQA team;
Cross-functional team evaluation by stakeholders to determine impact on key business functions, including a robust business analysis to determine cost implications;
Vendor verification to certify compliant business status;
Execution of a Non-Disclosure Agreement (NDA) or Master Vendor Agreement (MVA) between corporate and vendor partner, to legally protect all parties;
Preliminary testing at the corporate Technical Center for proof of principle and to evaluate product safety and potential OSHA requirements at a controlled environment;
One store test to determine operational feasibility in an actual business environment;
Three to 10-store testing to evaluate operational dynamics in a larger number of stores;
Thirty to 60 store-market testing in different markets to carefully monitor usage and operational outcome and ensure compliance and expectations, and extrapolate results to mimic a national chain wide roll-out;
Performance survey of test stores, data collation, analysis and review of results, followed by management approval;
Chain-wide roll-out by a cross functional team representing all impacted areas of the business; and
Post-chain-wide roll-out follow-up to monitor usage and resolve any lingering issue, namely:

Adequate SOP training to reinforce proper use;
Vigorous marketing campaign to increase chain-wide usage and compliance;
Effective ordering and delivery logistics; and
Potential short term and long term quality issues.

Developing an FSQA project matrix template

Certainly, the need to initiate new FSQA projects will increase as the various parts of the new Food Safety Modernization Act (FSMA) come into full force. Since FSMA brings a new regulatory burden on the food industry, its full implementation will require new ways of doing business, and most likely will affect the overall cost. This calls for a smarter management strategy to keep costs down and customers happy. The massive number of legitimate but competing food safety projects literally begging for attention can be overwhelming for Managers, especially with resources always in short supply. With this scenario, it is critical for the Manager to develop an FSQA project matrix template that delineates the level of importance of each project based on overall risk assessment, cost-benefit ratio, regulatory food code requirements, and buy-in by stakeholders, including management and final end-users.

FSQA project implementation and recipe for success

Testing and evaluation can be an expensive venture considering the test duration, number of test stores involved and capacity utilization for test products. The good news however is that most vendors are willing to fund substantial portion or even the entire test. This is essentially because vendors want to demonstrate that their product works, are in compliance, certified and approved by relevant federal, state and local agencies, and fulfills all obligations as outlined in the statement of work. It is a win-win situation for both vendor and corporate because once a product is approved for chain wide roll-out, it can stay in use for several years until an upgraded becomes available. Thus, corporate funding commitment may be minimal and restricted only to staff time for overseeing the testing process. It is important to mention that training is a critical component at every stage of the testing process. Standard operating procedures, training video clips and on-site training are required to ensure that test product is used according to manufacturer’s instruction and in compliance with all relevant regulations. Due diligence and proper training of end-users including store managers, team members and associates will ensure that the roll-out of a food safety tool to mitigate an existing risk does not introduce a new risk in food service operations. An example is the introduction of a new disinfectant to comply with a new regulation that requires a Norovirus approved disinfectant grade chemical for cleaning playgrounds. The disinfectant however is not approved for food contact surfaces since it’s not a regular strength sanitizer.

Consequently, any inadvertent cross-usage on food contact surfaces may constitute a serious food safety risk. Similarly, an SOP training gap may result in higher risk if associates using yellow color-coded aprons for raw food processing cross-contaminates the RTE food board areas with raw chicken/beef contaminated aprons. For instance, the Costco Rotisserie Chicken recall of late 2013 appears to have been linked with Salmonella cross-contamination after the cooking process in the food preparation area. Thus, proper training on the useof food safety tools and processes is critical both during product testing and post-chain-wide roll-out, to accurately evaluate and monitor risk mitigation practices.

To enable success, food retail chains employ the services of third party consultants to assist in-house staff and bring project-specific subject matter expertise to the table for rigorous risk assessment and risk mitigation. This strategy will also assist in timely communication that support buy-in by senior management and other relevant stakeholders. In addition, the implementation of such projects will remain effective and efficient, freeing up valuable time for corporate staff to continue supporting the business in the most critical areas of providing seamless customer services. Most importantly, a third party working in concert with vendors and corporate staff will bring an unbiased product testing and evaluation standard that cannot be left entirely at the discretion of vendor partners.

Proper documentation is required at every stage to ensure that all potential confounding factors are considered and evaluated at every level. Surveys, feedback compilation and analysis by a third party will assist in building credibility for test data, and enable management have the right set of data to make an informed business decision. Some level of customization may be involved as issues raised by stakeholders are addressed during the testing process. Open communication is important to keep all parties in the loop and encourage honest discussion of issues and how best to resolve them in a cost-effective manner.

Conclusion

Testing of new FSQA tools and services is a cost saving process that helps Managers to completely resolve potential issues upfront before introducing products into the system. Improperly tested food safety products may lead to a breach in the system down the road. Ordinarily, the use of transparent plastic wrap to cover raw chicken pans during the thawing process is an excellent barrier against cross-contamination of food-contact and non-food contact surfaces with raw chicken juice. However, the transparent nature of the plastic wrap makes it extremely difficult to see a torn piece of plastic wrap inside the raw chicken pan. Due diligence during testing should identify such aberration and resolve it by customizing into easily identifiable yellow color coded plastic wrap. This test-mode corrective action will ensure that torn pieces of plastic wrap won’t get into food served to customers after chain-wide roll-out.

While proper testing, evaluation and roll-out of new FSQA products and services may be laborious, time consuming and somewhat expensive, it is still considered one of the industry best practices that supports the delivery of safe quality food to customers and protects the business brand. Overall, it benefits businesses in the long run to budget enough resources for this very important business function, instead of postponing or scrapping risk mitigation programs until crisis situation that may hurt customers, business brand and undermine return-on-investment.

Benchmarking Produce Safety in the New FSMA Regulatory Climate

Ebola Virus and Body Fluids Clean-Up in Retail Food Operations

Food Spoilage and Food Loss in Retail Environments

Supplier Qualification and Compliance using GFSI Benchmarking