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

Testing and Evaluation of Food Safety Tools Simplified

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

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.

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.

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

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