Angelica Grindle, DEKRA

Four Steps for Utilizing Behavioral Science to Control Exposure to COVID-19

By Angelica Grindle, Ph.D.
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Angelica Grindle, DEKRA

Safety is defined as controlling exposure for self and others. Going into 2020, the food industry battled safety concerns such as slips and falls, knife cuts, soft-tissue injuries, etc. As an “essential industry”, food-related organizations now face a unique challenge in controlling exposure to COVID-19. Not only must they keep their facilities clean and employees safe, they must also ensure they do not create additional exposures for their suppliers or customers.

These challenges increase at a time when employees may be distracted by stress, financial uncertainties, job insecurity, and worry for themselves and their families. Additionally, facilities may be understaffed, employees may be doing tasks they do not normally do, and we have swelling populations working from home.

While there is much we cannot control with COVID-19, there are specific behaviors that will reduce the risk of viral exposure for ourselves, our co-workers, and our communities. Decades of research show the power of behavioral science in increasing the consistency of safe behaviors. The spread of COVID-19 serves as an important reminder of what food-related organizations can gain by incorporating a behavioral component into a comprehensive exposure-reduction process.

Whether you have an existing behavior based safety process or not, follow these four steps.

Step 1: Pinpoint Critical COVID-19 Exposure Reduction Behaviors

It is critical to clearly pinpoint the behaviors you want to see occurring at a high rate. In the food industry, an organization must control exposure both within their facilities as well as during interactions with suppliers and customers. Controlling exposure within facilities will typically include those behaviors recommended by the CDC such as:

  1. Maintain six feet of separation at all times possible.
  2. Avoid touching your eyes, nose and mouth with unwashed hands.
  3. Minimize personal interactions to reduce exposure to transmit or receive pathogens.
  4. Frequent 20-second hand washing with soap and warm water.
  5. Make hand disinfectant available.
  6. Use alternatives to shaking hands.
  7. Frequently clean and disinfect common areas, such as meeting rooms, bathrooms, doorknobs, countertops, railings, and light switches.
  8. Sneeze and/or cough into elbow or use a tissue and immediately discard.
  9. Conduct meetings via conferencing rather than in person.
  10.  If you are sick, stay home.
  11. If exposed to COVID-19, self-quarantine for precaution and protection of others.

Supplier/Customer exposure-reduction behaviors will vary depending upon your specific industry and may include pinpointing the critical behaviors for food preparation, loading dock delivery, customer home delivery, and customer pick up. When creating checklists to meet your unique exposures, be sure the behaviors you pinpoint are:

  • Measurable: The behavior can be counted or quantified.
  • Observable: The behavior can be seen or heard by an observer.
  • Reliable: Two or more people agree that they observed the same thing.
  • Active: If a dead man can do it, it is not behavior.
  • Influenceable: Under the control of the performer.

Once you have drafted your checklists, ask yourself, “If everyone in my facility did all of these behaviors all the time, would we be certain that we were controlling exposure for each other, our suppliers, and our customers?” If yes, test your checklists for ease of use and clarity.

Step 2: Develop Your Observation Process

To do this, you will want to ask yourself:

  • Who? Who will do observations? Can we leverage observer expertise from an existing process and have them focus on COVID-19 exposure reduction behaviors or should we create a new observer team?
  • Where? Which specific locations, job types, and/or tasks should be monitored?
  • When? When will observers conduct observations?
  • Data: How will you manage the data obtained during the observations so that it can be used to identify obstacles to safe performance? Can the checklist items be entered into an existing database or will we need to create something new?
  • Communication: What information needs to be communicated before we begin our COVID-19 Exposure Reduction process and over time? How will we communicate it?

Step 3: Conduct Your Observations and Provide Feedback

Starting the Observation
Your observers should explain that they are there to help reduce exposure to COVID-19 by providing feedback on performance.

Recording the Observation
Observers should note on the checklist which behaviors are occurring in a safe manner (protected) and which are increasing exposure to COVID-19 (exposed).

Provide Feedback
Feedback is given in the spirit of reducing exposure. It should be given as soon as possible after the observation to reinforce protected behaviors and give the person to opportunity to modify exposed behaviors.

Success Feedback
Success feedback helps reinforce the behaviors you want occurring consistently. Effective success feedback includes:

  • Context: The situation in which the behavior occurred.
  • Action: The specific behaviors observed which reduce exposure to COVID-19.
  • Result: The impact of those behaviors on themselves or others—in this case, reduced COVID-19 exposure for themselves, their families and community.

“I care about your safety and do not want to see you exposed to COVID-19. I saw you use hand sanitizer prior to putting on eye protection. By doing that, you reduced the likelihood of transferring anything that might have been on your hands to your face which keeps you safe from contracting COVID-19.”

Guidance Feedback

Guidance feedback is given for exposed behaviors to transform that behavior into a protected one. Effective guidance feedback includes Context, Action, Result, but also:

  • Alternative Action: The behavior that would have reduced their exposure to COVID-19.
  • Alternative Result: The impact of that alternative behavior, such as reduced COVID-19 exposure for themselves, their families, and community.

“I care about your safety and do not want to see you exposed to COVID-19. I saw that you touched your face while putting on eye protection. By doing that, you increased the likelihood of transferring anything on your hand to your face which increases your risk of exposure to COVID-19. What could you have done to reduce that exposure?”

When giving guidance feedback, it is important to have a meaningful conversation about what prevented them from doing the safe alternative. Note these obstacles on the checklist.

Step 4: Use Your Data to Remove Obstacles to Safe Practices.

Create a COVID-19 exposure reduction team to analyze observation data. This team will identify systemic or organizational obstacles to safe behavior and develop plans to remove those obstacles. This is critical! When an organization knows that many people are doing the same exposed behavior, it is imperative that they not blame the employees but instead analyze what is going on in the organization that may inadvertently be encouraging these at-risk behaviors.

For example, we know handwashing and/or sanitizing is an important COVID-19 exposure reduction behavior. However, if your employees do not have access to sinks or hand sanitizer, it is not possible for them to reduce their exposure.
Similarly, the CDC recommends that people who are sick not come to work. However, if your organization does not have an adequate sick leave policy, people will come to work sick and expose their co-workers, customers and suppliers to their illness.

Your COVID-19 exposure reduction team should develop plans to remove obstacles to safe behavior using the hierarchy of controls.

Conclusion

Consistently executing critical behaviors is key to reducing exposure to COVID-19 as flattening the curve is imperative in the worldwide fight against this pandemic. Regardless of the type of behavior or the outcome that the behavior impacts, Behavior based safety systems work by providing feedback during the observations and then using the information obtained during the feedback conversation to remove obstacles to safe practices.

By using these tips, you can add a proven and powerful tool to your arsenal in the fight against COVID-19 and help keep your employees, their families, and your community safe.

Crop spraying, Ellutia

From Farm to Fork: The Importance of Nitrosamine Testing in Food Safety

By Andrew James
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Crop spraying, Ellutia

N-nitroso compounds (NOCs), or nitrosamines, have once again made headline news as their occurrence in some pharmaceuticals has led to high profile product recalls in the United States.1 Nitrosamines can be carcinogenic and genotoxic and, in the food industry, can compromise a food product’s quality and safety. One nitrosamine in particular, N-nitrosodimethylamine (NDMA), is a highly potent carcinogen, traces of which are commonly detected in foods and may be used as an indicator compound for the presence of nitrosamines.2

NOCs can potentially make their way into the food chain in a number of ways, including (but not limited to): Via the crop protection products used to maximize agricultural yields; via the sodium and/or potassium salt added to preserve certain meats from bacterial contamination; as a result of the direct-fire drying process in certain foods; and via consumption of nitrates in the diet (present in many vegetables due to natural mineral deposits in the soil), which react with bacteria and acids in the stomach to form nitrosamines.3

The crop protection and food manufacturing industries are focused on ensuring that levels of nitrosamines present in foods are minimal and safe. Detection technology for quantitating the amount of nitrosamines (ppm levels) in a sample had not advanced in nearly 40 years—until recently. Now, a thermal energy analyzer (TEA) —a sensitive and specific detector—is being relied on to provide fast and sensitive analysis for players throughout the food supply chain.

Regulatory Landscape

Both NDMA and the nitrosamine N-nitrososodiethylamine (NDEA) have been classified by national and international regulatory authorities as ‘probable human carcinogens’.3 NDMA in particular is by far the most commonly encountered member of this group of compounds.7

In the United States there are limits for NDMA or total nitrosamines in bacon, barley malt, ham and malt beverages, yet there are currently no regulatory limits for N-nitroso compounds (NOC) in foods in the EU.7

Developers of crop protection products are required to verify the absence of nitrosamines or quantify the amount at ppm levels to ensure they are within the accepted guidelines.

Crop Protection

The presence of nitrosamines must be traced and risk-managed along the food’s journey from farm to fork. The issue affects testing from the very beginning – particularly at the crop protection stage, which is one of the most highly regulated industries in the world. Without crop protection, food and drink expenditures could increase by up to £70 million per year and 40% of the world’s food would not exist.7

Development of a new crop protection product (herbicide, fungicide, insecticide or seed treatment) involves several steps: Discovery and formulation of the product, trials and field development, toxicology, environmental impacts and final registration. New product registration requires demonstration of safety for all aspects of the environment, the workers, the crops that are being protected and the food that is consumed. This involves comprehensive risk assessments being carried out, based on data from numerous safety studies and an understanding of Good Agricultural Practice (GAP).

One global producer of agrochemicals uses a custom version of the TEA to verify the absence of nitrosamines or quantitate the amount of nitrosamines (ppm levels) in its active ingredients. The LC-TEA enables high selectivity for nitro, nitroso and nitrogen (when operating in nitrogen mode), which allows only the compounds of interest to be seen. Additionally, it provides very high sensitivity (<2pg N/sec Signal to Noise 3:1), meaning it is able to detect compounds of interest at extremely low levels. To gain this high sensitivity and specificity, it relies on a selective thermal cleavage of N-NO bond and detection of the liberated NO radical by the chemiluminescent signal generated by its reaction with ozone.

The customized system also uses a different interface with a furnace, rather than the standard pyrolyser, to allow for the additional energy required and larger diameter tubing for working with a liquid sample rather than gas.

The system allows a company to run five to six times more samples with increased automation. As a direct result, significant productivity gains, reduced maintenance costs and more accurate results can be realized.

Food Analysis

Since nitrite was introduced in food preservation in the 1960s, its safety has been debated. The debate continues today, largely because of the benefits of nitrite in food products, particularly processed meats.6 In pork products, such as bacon and cured ham, nitrite is mostly present in the sodium and/or potassium salt added to preserve the meat from bacterial contamination. Although the meat curing process was designed to support preservation without refrigeration, a number of other benefits, such as enhancing color and taste, have since been recognized.

Analytical methods for the determination of N-nitrosamines in foods can differ between volatile and non-volatile compounds. Following extraction, volatile N-nitrosamines can be readily separated by GC using a capillary column and then detected by a TEA detector. The introduction of the TEA offered a new way to determine nitrosamine levels at a time when GC-MS could do so only with difficulty.

To identify and determine constituent amounts of NOCs in foods formed as a direct result of manufacturing and processing, the Food Standards Agency (FSA) approached Premier Analytical Services (PAS) to develop a screening method to identify and determine constituent amounts of NOCs in foods formed as a direct result of manufacturing and processing.

A rapid and selective apparent total nitrosamine content (ATNC) food screening method has been developed with a TEA. This has also been validated for the known dietary NOCs of concern. This method, however, is reliant on semi-selective chemical denitrosation reactions and can give false positives. The results can only be considered as a potential indicator rather than definitive proof of NOC presence.

In tests, approximately half (36 out of 63) samples returned a positive ATNC result. Further analysis of these samples by GC-MS/MS detected volatile nitrosamine contamination in two of 25 samples.

A key role of the TEA in this study was to validate the alternative analytical method of GC-MS/MS. After validation of the technique by TEA, GC-MS/MS has been proven to be highly sensitive and selective for this type of testing.

The Future of Nitrosamine Testing

Many countries have published data showing that toxicological risk from preformed NOCs was no longer considered an area for concern. Possible risks may come from the unintentional addition or contamination of foods with NOCs precursors such as nitrite and from endogenous formation of NOCs and more research is being done in this area.

Research and innovation are the foundations of a competitive food industry. Research in the plant protection industry is driven by farming and the food chain’s demand for greater efficiency and safer products. Because the amount of nitrosamines in food that results in health effects in humans is still unknown, there is scope for research into the chemical formation and transportation of nitrosamines, their occurrence and their impact on our health. Newer chromatographic techniques are only just being applied in this area and could greatly benefit the quantification of nitrosamines. It is essential that these new approaches to quality and validation are applied throughout the food chain.

References

  1. Christensen, J. (2020). More popular heartburn medications recalled due to impurity. CNN.
  2. Hamlet, C, Liang, L. (2017). An investigation to establish the types and levels of N-nitroso compounds (NOC) in UK consumed foods. Premier Analytical Services, 1-79.
  3. Woodcock, J. (2019). Statement alerting patients and health care professionals of NDMA found in samples of ranitidine. Center for Drug Evaluation and Research.
  4. Scanlan, RA. (1983). Formation and occurrence of nitrosamines in food. Cancer res, 43(5) 2435-2440.
  5.  Dowden, A. (2019). The truth about nitrates in your food. BBC Future.
  6.  Park, E. (2015). Distribution of Seven N-nitrosamines in Food. Toxicological research, 31(3) 279-288, doi: 10.5487/TR.2015.31.3.279.
  7.  Crews, C. (2019). The determination of N-nitrosamines in food. Quality Assurance and Safety of Crops & Foods, 1-11, doi: 10.1111/j.1757-837X.2010.00049.x
  8. (1989) Toxicological profile for n-Nitrosodimethylamine., Agency for Toxic substances and disease registry.
  9. Rickard, S. (2010). The value of crop protection, Crop Protection Association.
RS Spectra

Using Raman Spectroscopy to Evaluate Packaging for Frozen Hamburgers

By Gary Johnson, Ph.D.
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RS Spectra

Raman spectroscopy (RS) can be used to identify layers in polymer food packaging films to better understand the laminated plastic’s chemical composition. A Raman spectrum is obtained by illuminating a sample with a laser and collecting and measuring scattered light with a spectrometer. Coupling the spectrometer to a microscope with a mapping stage allows an accurate way to create a chemical map of a film’s composition and structure. The map provides valuable information to better understand the packaging’s barrier properties, structural integrity and layers.

The RS method can be useful for conducting failure analysis (why did a food package fail to meet standards), supply chain validation (is the plastic what the supplier claims), decision making (which plastic should be used), and evaluating package appearance (why is there discoloring, haze or particle inclusions in the film). It provides important information for design, purchasing, product success and other decisions that food manufacturers and packagers regularly face.

Take for example the packaging used for frozen hamburger patties. The film used must be transparent to display the hamburger patties, but it also needs to provide an oxygen barrier in order to prevent the ground beef from turning brown. As such, a polymer layer with low oxygen permeability must be incorporated into the laminated film, along with other components like nylon for strength and polyethylene for heat sealing and water barrier. The most common polymer used as an oxygen barrier is ethylene-vinyl alcohol copolymer (EVOH).

It is important that the film used to package these hamburger patties includes a good heat seal as well as a proper oxygen barrier layer. The possible absence of either of these could result in the undesired effect of ground beef turning brown. Manufacturers may want to test packaging for an EVOH layer to make a purchasing decision or verify a supplier’s claims. Additionally, if the packaging fails, an analysis can determine if the failure was due to having no EVOH barrier layer in the product or if there is a need to investigate other potential issues with the packaging. Regardless of the reason, RS provides a preferable method for rapidly evaluating the plastic for an EVOH oxygen barrier layer.

The RS method can be used to determine the construction of the laminated film and confirm that it meets specifications. Using the combination of RS with microscopy and mapping allows both identification of the polymers and the evaluator to correlate the composition to the layer structure of the laminated film. This method provides a map showing the composition of each layer in the film. In some cases, the Raman map will show layers that are not resolved in the visible micrograph image. Thus, with RS, one test provides both the structure and composition of each layer of the laminated film.

Laminated film, packaging, Intertek
This sample table illustrates composition and thickness of each layer of a laminated film. Table courtesy of Intertek.

To start, a small section of the film (5 x 10 mm) is cut and mounted with a photocuring resin. A cross section of the mounted film is then cut to expose the layers for analysis. This cross-section is placed on the mapping microscope stage of the Raman instrument. A micrograph image with a 100X objective is obtained and a Raman map of the cross-section with 1 µm2 pixel resolution collected.

A map image is obtained by classical least squares (CLS) fitting example spectra to each of the spectra collected from the cross-section. The example spectra for the CLS fits are averages (mean) of the spectra in the center of each layer with a unique composition as determined by the data (see Figure 1). The final result is a color-coded map that can be superimposed on the micrograph image to show the composition and thickness of each layer in the laminated film. For example, a film with six layers composed of Nylon 6, polyethylene or EVOH would have varying thickness and placement of each layer to achieve the desired result for the product.

RS Spectra
Figure 1. Example spectra used to create the CLS model for map image.

The composition map can confirm the presence of an oxygen barrier layer of EVOH, as well as the overall construction of the laminated film. Knowing the thickness of the barrier layer is important since the gas permeability is a function of the film thickness. Determination of the overall film structure allows the end-user to confirm the film meets the specifications from the supplier. In turn, this can be used to make important purchasing decisions or insights into what caused a packaging failure.

While good, successful results will confirm the presence of an EVOH layer, the RS map may also show only polymers that don’t have the required oxygen barrier properties (see Figure 2). The manufacturer would need to check it against a supplier spec sheet. It may ultimately show that the lack of an EVOH layer is what caused the issue with the packaging. If the test is being used for decision-making purposes, the manufacturer would know not to use the product. If a supply chain validation is being run, after checking the spec sheet, the manufacturer may need to correct the situation.

Raman spectroscopy
Figure 2. Raman map overlaid with image of film cross section. Green = nylon; Red = polyethylene; Yellow = ethylene vinyl alcohol copolymer (EVOH).

What if the analysis confirmed that an EVOH layer was present, but the test was done for a failure analysis, meaning the packaging did fail at some point? If the EVOH later is present but the meat is still turning brown and/or spoiling, other potential problems would need to be evaluated. In this case, the issues would most likely be with the heat seal and additional testing of the heat seal would be necessary. Thanks to the RS analysis, the investigation into the packaging failure can proceed, and the issue with the heat seal identified.

By giving a chemical image of the packaging, RS analysis provides a wealth of information about a film that can be vital to a food manufacturer or processor. Knowing why certain films may not be working, either due to faults in chemical makeup or the need to look elsewhere, such as the heat seal, RS quickly and efficiently provides information and answers to help get products to market and meet consumer demand.

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part III)

By Frank Pisciotta, Spence Lane
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Food defense is the effort to protect food from intentional acts of adulteration where there is an intent to cause harm. Like counterterrorism laws for many industries, the IA rule, which established a compliance framework for regulated facilities, requires that these facilities prepare a security plan—in this case, a food defense plan—and conduct a vulnerability assessment (VA) to identify significant vulnerabilities that, if exploited, might cause widescale harm to public health, as defined by the FDA. Lessons learned during the conduct of food defense vulnerability and risk assessments and the preparation of the required food defense plan are detailed throughout this three-part series of articles. Part I of this series addressed the importance of a physical security expert, insider threat detection programs, actionable process steps (APS) and varying approaches to a VA. Part II reviewed access, subject matter experts, mitigation strategies and community drinking water. This final article reviews broad mitigation strategies, feasibility assessments, food defense plans, partial ingredient security and the “Three Element” approach through more lessons learned from assessments conducted for the largest and most complex global food and beverage facilities, but which can also be applied to the smaller facilities that are currently in the process of readying for the next deadline of July 26.

Lesson 14: When the final rule was released, the concept of using broad mitigation strategies was eliminated. That notwithstanding and realizing that many companies seek to operate at a stricter standard for food defense with a clear focus on brand protection, versus only those process steps that potentially could result in a “wide scale public health impact.” Broad or facility-wide mitigation strategies should not be abandoned, but are less likely to get you a lot of credit for IA compliance. Including existing food safety prerequisite programs (PRP), programs and practices that are put in place to maintain a sanitary environment and minimize the risk of introducing a food safety hazard, can, in some cases, also be included as security mitigation. PRP’s with slight modifications can also contribute to a good “food defense” posture. For example, one PRP addresses hazardous chemicals and toxic substances. In some cases, non-food grade substances that could result in product contamination (not necessarily wide-scale public health impact) might be available to a disgruntled insider. It is obvious companies are concerned about contaminants being brought into the plants, but please do not overlook contaminants that are already there and ensure that they are properly secured when not in use.

Other facility-wide programs (broad mitigation) that contribute to effective food defense might include site perimeter or building security, visitor and contractor management, pre-employment background checks, employee security awareness and food defense training and sanitation chemical management.

Lesson 15: If you are using the three elements approach (Guidance Chapter 2 Section G) or the hybrid approach (Guidance Chapter 2 Section H), you will be required to make an assessment on feasibility. In the early VA’s conducted, prior to the second installment of the guidance in March of 2019, feasibility was essentially an all or nothing proposition. One could argue that a judgment call was required as to whether an intentional adulteration incident could be accomplished given the inherent conditions. Those conditions might include a lot of coworkers who might be able to observe and serve as witnesses to deter the act. With the release of the second installment of the guidance from the FDA, a new tool was made available which would allow food and beverage companies to run a calculation and make a more accurate prediction of how much of an unnamed “representative contaminant” which is assumed to be highly lethal and heat stable it might take to contaminate a product batch. Typically, the larger the batch size, the higher the quantity of the “representative contaminant” would be required to achieve a lethal dose (LD) in a serving size. So, to provide an additional level of validation with identified actionable process steps, the use of the LD calculation might be considered to provide more realistic insight into the feasibility element. For instance, if it would require one hundred pounds of the “representative contaminant,” you might feel justified in concluding that it is not realistic to get that amount of contaminant into the batch at the process step and rule out the point, step or procedure as an APS. This can save money and ensure limited food defense resources can be channeled to the areas where legitimate risk can be reduced.

Lesson 16: After an APS is identified, sites will need to determine, as the rule states, whether the existing “mitigation strategies can be applied…to significantly minimize or prevent the significant vulnerability.” Simply stated, what is in place today for food safety, and the broad-based security measures in use, may or may not be enough when you consider an insider motivated to contaminate the product. The FDA’s mitigation strategies database may offer some insights into additional food defense measures to consider. Where additional mitigation strategies are identified, from the time of completion of the VA until a site’s regulatory compliance deadline arrives (next one is July 26, 2020), that change must be incorporated into the food defense plan and fully implemented. We recommend that a site make a list of new mitigation strategies after the VA is complete for tracking purposes during the implementation phase. No mitigation strategies should be included in the food defense plan that are not fully implemented and where records cannot be adequately produced.

Lesson 17: In the second installment of the guidance, the concept of partial ingredients was introduced. The key activity types (KAT) of secondary ingredients is now considered to include the storage of partially used, open containers of secondary ingredients where the tamper-evident packaging has been breached. Tamper evident tape looked to have promising benefits, but several of our clients have abandoned the use of this mitigation strategy, which has been proven repeatedly to be defeated without detection. It appears that using containers that can be secured with numbered seals might be a better option and even better if the seals would be metal detectable in the event one went astray in a product stream.

Lesson 18: Food defense plan unification. Facilities regulated under the IA rule are likely to already have a food defense plan for other initiates such as SQF or BRC. The IA Rule is not unlike other counter-terrorism regulations in potential to create challenges to meet voluntary and regulatory requirements without having multiple food defense plans. The IA Rule based on its modeling after HACCP creates some very specific requirements in terms of how data needs to be presented and records maintained. Sites may be doing other things to support food defense, and one strategy that might keep auditors in their lane would be to include any non-IA Rule food defense content (e.g., for SQF or BRC) in an appendix to the IA Rule Food Defense Plan.

Lesson 19: Under the VA method the FDA refers to as “the “Three Element” approach, suggestion is made in the guidance released in March 2019 that regulated facilities might consider creating stratified categories for each element of public health impact, degree of physical access and ability of the attacker to successfully contaminate product. This is asking regulated facilities to engineer their own vulnerability assessment methodology. It is our opinion that this is asking a lot from a food and beverage facility and that creating categories for each element (e.g., refer to Table 3 on page 54) will extend the time it takes to complete a vulnerability assessment, create a lot more uncertainty in the process and does not necessarily help companies to identify the areas where intentional adulteration risk is highest.

Conclusion

Organizations who have yet to execute vulnerability assessments (due July 26) or those who have already completed vulnerability assessments who may wish to reflect back on their existing VAs in an effort to eliminate unnecessary APS’s should find these strategies helpful in focusing limited resources to the areas where they can have the greatest effect. Since the initiation of this article series, the FDA has released its third installment of the guidance. Once we reflect on this new installment, we will address our thoughts in a future article.

Chocolate

Chocolate and Big Data: The Recipe for Food Safety Is Changing

By Steven Sklare
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Chocolate

Almost everybody loves chocolate, an ancient, basic, almost universal and primal source of pleasure. “The story of chocolate beings with cocoa trees that grew wild in the tropical rainforests of the Amazon basin and other areas in Central and South America for thousands of years… Christopher Columbus is said to have brought the first cocoa beans back to Europe from his fourth visit to the New World” between 1502 and 1504.1

Unfortunately, the production of chocolate and chocolate products today is as complex as any other global food product with supply chains that reach from one end of the world to the other. The complexity of the supply chain and production, along with the universal demand for the finished product, exposes chocolate to increasing pressure from numerous hazards, both unintentional and intentional. For example, we know that more than 70% of cocoa production takes place in West African countries, particularly the Ivory Coast and Ghana. These regions are politically unstable, and production is frequently disrupted by fighting. While production has started to expand into more stable regions, it has not yet become diversified enough to normalize the supply. About 17% of production takes place in the Americas (primarily South America) and 9% from Asia and Oceania.2

In today’s world of global commerce these pressures are not unique to chocolate. Food quality and safety experts should be armed with tools and innovations that can help them examine specific hazards and fraud pertaining to chocolate and chocolate products. In fact, the global nature of the chocolate market, requires fast reflexes that protect brand integrity and dynamic quality processes supported by informed decisions. Digital tools have become a necessity when a fast interpretation of dynamic data is needed. If a food organization is going to effectively protect the public’s health, protect their brand and comply with various governmental regulations and non-governmental standards such as GFSI, horizon scanning, along with the use of food safety intelligent digital tools, needs to be incorporated into food company’s core FSQA program.

This article pulls information from a recent industry report about chocolate products that presents an examination of the specific hazards and fraud pertaining to chocolate and chocolate products along with ways to utilize this information.

Cocoa and chocolate products rely on high quality ingredients and raw materials, strict supplier partnership schemes and conformity to clearly defined quality and safety standards. During the past 10 years there have been a significant number of food safety incidents associated with chocolate products. The presence of Salmonella enterica, Listeria monocytogenes, allergens and foreign materials in cocoa/chocolate products have been reported on a global scale. Today, information on food safety incidents and potential risks is quickly and widely available by way of the internet. However, because the pertinent data is frequently siloed, food safety professionals are unable to take full advantage of it.

Top Emerging Hazards: Chocolate Products (2013-2018)

Publicly available data, from sources such as European Union RASFF, Australian Competition and Consumer Commission, UK Food Standards Agency, FDA, Food Standards Australia New Zealand (FSANZ), shows a significant increase in identified food safety incidents for cocoa/chocolate products from 2013 to 2018. For this same time period, the top emerging hazards that were identified for chocolate products were the following:

  • Allergens: 51.60%
  • Biological: 16.49%
  • Foreign bodies: 13.83%
  • Chemical: 7.45%
  • Fraud: 6.38%
  • Food additives & flavorings: 4.26%
  • Other hazards: 2.66%

By using such information to identify critical food safety protection trends, which we define to include food safety (unintentional adulteration) and food fraud (intentional adulteration, inclusive of authenticity/intentional misrepresentation) we can better construct our food protection systems to focus on the areas that present the greatest threats to public health, brand protection and compliance.

A Data Driven Approach

Monitoring Incoming Raw Materials
Assessment and identification of potential food protection issues, including food safety and fraud, at the stage of incoming raw materials is of vital importance for food manufacturers. Knowledge of the associated risks and vulnerabilities allows for timely actions and appropriate measures that may ultimately prevent an incident from occurring.

Specifically, the efficient utilization of global food safety and fraud information should allow for:

  • Identification of prevalent, increasing and/or emerging risks and vulnerabilities associated with raw materials
  • Comparative evaluation of the risk profile for different raw materials’ origins
  • Critical evaluation and risk-based selection of raw materials’ suppliers

A comprehensive risk assessment must start with the consideration of the identified food safety incidents of the raw material, which include the inherent characteristics of the raw material. Next, the origin-related risks must be taken into account and then the supplier-related risks must be examined. The full risk assessment is driven by the appropriate food safety data, its analysis and application of risk assessment scientific models on top of the data.

Using food safety intelligent digital tools to analyze almost 400 unique, chocolate product related food safety incidents around the globe provides us with important, useful insights about cocoa as a raw material, as a raw material from a specific origin and as a raw material being provided by specific suppliers. The graph below represents the results of the analysis illustrating the trend of incidents reported between 2002 and 2018. It can be observed that after a significant rise between 2009 and 2010, the number of incidents approximately doubled and remained at that level for the rest of the evaluated period (i.e., from 2010 to 2018), compared to the period from 2002 to 2005.

Cocoa incidents, FOODAKAI
Graph from Case Study: Chocolate Products: lessons learned from global food safety and fraud data and the guidance it can provide to the food industry,
an industry report from FOODAKAI. Used with permission.

By further analyzing the data stemming from the 400 food safety incidents and breaking them down into more defined hazards, for incoming raw materials, we can clearly see that chemical hazards represent the major hazard category for cocoa.

  • Chemical: 73.46%
  • Biological: 16.49%
  • Organoleptic aspects: 5.93%
  • Other Hazards: 4.38%
  • Fraud: 2.32%
  • Foreign bodies: 2.06%
  • Food additives and flavorings: .77%
  • Allergens: .52%
  • Food contact materials: .52%

Using the appropriate analytical tools, someone can drill down into the data and identify the specific incidents within the different hazard categories. For example, within the “chemical hazard” category specific hazards such as organophosphates, neonicotinoids, pyrethroids and organochlorines were identified.

Comparative Evaluation of Risk Profiles for Different Origins of Raw Materials
The main regions of origin for cocoa globally are Africa, Asia and South America. After collecting and analyzing all relevant data from recalls and border rejections and the frequency of pertinent incidents, we can accurately identify the top hazards for cocoa by region.

The top five specific hazards for the regions under discussion are listed in Table I.

Africa South America Asia
1 Organophosphate 2,4-dinitrophenol (DNP) 2,4-dinitrophenol (DNP)
2 Molds Pyrethroid Poor or insufficient controls
3 Neonicotinoid Aflatoxin Aflatoxin
4 Pyrethroid Cadmium Spoilage
5 Organochlorine Anilinopyrimidine Salmonella
Table I.  Top Five Hazards By Region

After the first level of analysis, a further interpretation of the data using the appropriate data intelligence tools can help to reach to very specific information on the nature of the incidents. This provides additional detail that is helpful in understanding how the regional risk profiles compare. For example, the prevalence of chemical contamination, as either industrial contaminants or pesticides, has been a commonly observed pattern for all three of the regions in Table I. However, beyond the general hazard category level, there are also different trends with regard to specific hazards for the three different regions. One such example is the increased presence of mold in cocoa beans coming from Africa.

The primary hazard categories for cocoa, as a raw ingredient were identified and a comparison among the primary hazards for cocoa by region (origin-specific) should take place. The next step in a data-powered supplier assessment workflow would be to incorporate our use of global food safety data in evaluating the suppliers of the raw materials.

The Role of Global Food Safety Data

This article has been focused on chocolate products but has only touched the surface in terms of the information available in the complete report, which also includes specific information about key raw materials. Let’s also be clear, that the techniques and tools used to generate this information are applicable to all food products and ingredients. As we strive to produce food safely in the 21st Century and beyond, we must adapt our methods or be left behind.

The regulatory environment the food industry must operate in has never been more intense. The threats to an organization’s brand have never been greater. This is not going to change. What must change is the way in which food companies confront these challenges.

Global food safety data can contribute to the establishment of an adaptive food safety/QA process that will provide time savings and improve a quality team’s efficiency and performance.

Based on the continuous analysis of food recalls and rejections by key national and international food authorities, a food safety / quality assurance manager could establish an adaptive supplier verification process and risk assessment process by utilizing the knowledge provided by such data. In that way, QA, procurement, food safety and quality departments can be empowered with critical supplier data that will inform the internal procedures for incoming materials and ingredients (e.g., raw materials, packaging materials) and allow for adaptive laboratory testing routines and compliance protocols. Moreover, food safety systems can become adaptive, enabling quality assurance and safety professionals to quickly update points of critical control when needed, and intervene in important stages of the chocolate manufacturing process.

References

  1. Discovering Chocolate. The Great Chocolate Discovery. Cadbury website. Retrieved from https://www.cadbury.com.au/About-Chocolate/Discovering-Chocolate.aspx.
  2. Chocolate Industry Analysis 2020 – Cost & Trends. Retrieved from https://www.franchisehelp.com/industry-reports/chocolate-industry-analysis-2020-cost-trends/.
Production line, NiceLabel

Farm-to-Fork Transparency: How Digitized Labeling Can Prevent a Major Allergen Recall

By Lee Patty
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Production line, NiceLabel

For consumers and brands alike, the damaging impact of mislabeling or neglecting to clearly outline an allergen can be colossal. Therefore, to prevent a health and business disaster, best practices around allergen labeling must be top of mind. Luckily, technology can help, and the farm-to-fork transparency provided by a centralized and digitized modern label management system can ensure organizations improve responsiveness and accuracy while reducing costs beyond those saved by mitigating recalls.

No one wants to face a recall, but have you done enough to prevent one from happening to you? More than 650 food products were recalled last year in the United States alone. And one of the leading causes might just be the easiest to prevent: Undeclared allergens.

According to the Q2 2019 Stericycle Recall Index, undeclared allergens are the leading cause of U.S. food recalls, accounting for 48.4% of food recalls from the FDA and 62.9% of food pounds recalled by the USDA. This statistic becomes more alarming considering that roughly 11% of US adults have a food allergy, according to JAMA.

Enacted in 2004, the Food Allergen Labeling and Consumer Protection Act (FALCPA) stipulates that all packaged food regulated under the Federal Food Drug and Cosmetic Act (FFD&C) comply by listing major food allergens. “Major allergens” refers to milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, and soybeans, and for nuts and shellfish, the species must be declared.

For brands, the damaging impact of mislabeling or neglecting to clearly outline an allergen can be colossal, resulting in costly recalls or litigation. However, the impact to consumers can be even greater when one small mistake can cause serious illness, or worse, death. To prevent a health and business nightmare, best practices around allergen labeling must be top of mind.

However, with constantly changing legislation, this can be easier said than done. For instance, in a move that outpaced the FDA, Illinois issued a state law requiring sesame labeling. And in the UK, Natasha’s Law was recently introduced, requiring companies to label all food ingredients on fresh pre-packaged food after 15-year-old Natasha Ednan-Laperouse died of a sesame allergy from a sandwich that didn’t list all the ingredients.

The need for optimal allergen labeling is clear, so how can organizations ensure allergens are clearly labeled on their products and meet existing standards while preparing for future requirements?

Though the underlying principle behind a clear label is simple, the process of designing such labels can be multifaceted and difficult to streamline—especially if labels are designed, printed and managed by separate users across a franchise or store network. And this challenge is multiplied further when products reach across international boundaries. But technology can help, and the farm-to-fork transparency provided by a centralized and digitized modern label management system can ensure organizations improve responsiveness and accuracy while reducing costs beyond those saved by mitigating recalls.

Disorganized Sprawl: A Major Hurdle to Effective Labeling

When implemented properly, modern label management can cost-effectively centralize labeling, reducing inefficiencies and human error. However, before this can happen, there are a few common roadblocks that may make standardizing the labeling process challenging.

One issue may be a sprawl of legacy equipment that is not integrated into a cohesive network. For instance, a legacy labeling system may only support certain label printers while certain manufacturers of direct marking equipment may only support their own propriety brand of printers. In another sense, a lack of standardization can also make it difficult to efficiently integrate labeling with other business solutions like manufacturing execution systems (MES) and enterprise resource planning (ERP) systems.

A damaging impact of sprawl is adoption of a wide range of different labeling applications across various facilities. This will result in inconsistent label formatting, the need to create the same label multiple times, and the need to accommodate different systems and printers. Consequences of this may be a lack of centralized storage when everything is saved locally, complex user training encompassing many software programs, an increased burden on IT, and a great deal of extra administration and human intervention to maintain and update labels.

Another problem with a disorganized ecosystem for labeling is that quality assurance inevitably suffers because tracing a label’s history or implementing standardized approval processes can be difficult or impossible. To accurately track labeling, it’s necessary to have a production log stating where and when labels were produced and who produced them. Having such a log and using it effectively requires centralization or else it can become difficult to track different versions or enforce universal approval processes for altering templates.

Implementing Modernized Labeling to Improve QA

Modern label management systems can help suppliers and manufacturers standardize and control marking packaging or label production across an entire organizational ecosystem. These solutions feature a central, web-based document management system and provide a reliable storage space for label templates and label history. This will enable changes and updates to be tracked centrally, so local facilities can access uniform and accurate templates to produce labels.

An ideal label management system can also interface with a multitude of direct marking and labeling printers, even if they are from different manufacturers, and it can integrate labeling and direct marking with a business system’s master data, which eliminates manual data entry errors. This decreases upfront capital expenditures in more costly efforts to standardize equipment, provides a system that is easy to integrate with partners, saves costs generated from having to discard product or rework labels, and increases a company’s ability to implement unified, organization-wide labeling processes.

Centralized Labeling is Easily Delivered Through Cloud

To many, the thought of migrating legacy labeling to a centralized system or investing a large sum of resources into centralizing labeling may seem inordinate or daunting. However, cloud technology makes migrating to a modern label management system feasible for organizations of all sizes.

With the cloud, designing labels and ensuring quality assurance becomes far more accessible. Additionally, the software-as-a-service (SaaS) model doesn’t require the capital investments or operations and maintenance upkeep associated with costly IT infrastructure and is easily scalable depending on business needs. This is a game changer for small to medium sized businesses who can now benefit from a centralized labeling system because of the cloud.

The Benefits of a “Single-source-of-truth”

In addition to other benefits, integrating a modern label management solution with other business systems allows users to access a “single-source-of-truth.” This allows for enforceable, specific user roles with logins for each user as well as traceability and transparency across all factories that produce products. The traceability from being able to monitor a “single-source-of-truth” is a critical component to farm-to-fork transparency because it can provide an accurate production log overviewing label versions and changes, so companies can pinpoint the locations and causes of labeling inaccuracies and fix them instantly.

A modern label management system also enables organizations to nimbly respond to new regulatory requirements because alterations only need to be made in one location, new templates can be previewed before going to production, and nutrition and allergen functionality can be easily formatted so that it is clear and stands out to the consumer. This increases labeling consistency and accuracy, and saves time when rules change and when new products need to be incorporated during a merger or acquisition.

Futureproofing and Ensuring Consumer Safety with Allergen Labeling

In today’s world, food and beverage manufacturers must rise to the challenge of changing regulations while meeting the call of shifting customer demands and integrating themselves within greater business ecosystems and extended supply chains. In the case of allergen labeling, this may mean preparing labels for different countries, which have varying standards for labeling allergens like sesame, royal jelly, bee pollen, buckwheat and latex, or ensuring labels can be altered quickly when new products are rolled out or when bodies like the FDA revamp standards.

Companies that implement modern label management solutions position themselves to adapt to competition and regulations quickly, implement solutions that can easily be integrated with partners in a supply chain, and streamline quality control. This can help improve productivity, reduce labeling errors, increase collaboration, and prevent product recalls. But most importantly, it helps ensure the safety of consumers everywhere.

Salami, plastic packaging

Using Raman Spectroscopy to Evaluate Laminated Food Packaging Films

By Ellen Link, Gary Johnson, Ph.D.
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Salami, plastic packaging

Laminated plastics are common and popular food packaging options. They are strong and flexible, making them ideal for both packing and presentation, and can be used for cooking, frozen foods, drink pouches, snack products and even pet food. Yet, unreliable plastics can create a problem for food packaging and the safety of a product.

If a grade of plastic is not what was promised or needed, there can be issues that lead to spoilage, spills and messes, crystallization, mold or other risks. Additionally, there may be concerns about how laminated films will interact with the product itself, as it could impact food safety or lifecycle. For these reasons, it is critical to have accurate information when evaluating the plastics films used in food packaging.

Raman Spectroscopy

Raman spectroscopy (RS) is a powerful method of identifying and characterizing chemical compounds based on light scattering by a sample. It can be used to identify layers in food packaging films to accurately understand the chemical makeup of the laminated plastic. The effect is named for its inventor, C.V. Raman, who was awarded the Nobel prize in physics for its discovery in 1930. It is a non-destructive method that uses an induced-dipole mechanism to probe the vibrations of the chemical bonds in a molecule. The Raman spectrum shows a pattern of molecular vibrations that represents a detailed chemical fingerprint of a material, providing insights into the product composition.

A Raman spectrum is obtained by illuminating the sample with a laser and collecting and measuring the scattered light with a spectrometer. The molecular vibrational modes vary depending on the geometry and electronic structure of the chemical compound present in the sample. By controlling the position of the laser focus point on a sample, a map of the composition can be created. This provides valuable information on the plastic film related to its composition, such as number of layers, thickness of each layer and overall make-up.

In the food packaging and safety industry, this technique can be used to evaluate laminated plastic films by examining polymers, minerals, and/or inorganic fillers and pigments present in the film. Specific food packaging products that can benefit from RS assessments include heat seals, containers, lids, films and wrappers both for durability and performance and for diffusion, permeation or other concerns.

Benefits and Limitations

There are numerous benefits to using the RS method. A major advantage is that there is virtually no sample preparation necessary; spectra can be obtained without direct contact, such as through the sides of glass vials or through windows in reaction cells. As a non-destructive technique, it allows an easy, highly accurate way to take a sample, create a chemical composition map and better understand films’ barrier properties, structural integrity and layers. It has broad applicability and works using conventional microscope optics.

There are, of course, limitations to the approach, as well. Fluorescent components or impurities in a sample can emit a photoluminescent background that overwhelms the Raman scattering. Samples can also be damaged by the laser if too much power is used, or the sample absorbs light at the laser wavelength. Samples that do fluoresce and samples that are photolabile act as common interferences for the RS method. In many cases, these interferences can be overcome with the proper choice of laser and sampling techniques. Additionally, while RS provides an accurate analysis of laminated films, the technique cannot be used on metals or metallic compounds (which can be assessed using scanning electron microscopy or light optical microscopy) or organic pigments or ink layers (which can be assessed with other infrared techniques).

Using RS for Food Packaging

RS can offer a variety of insights for food packaging films:

  • Failure analysis. If a plastic used for a heat seal in a fruit or yogurt cup fails, it could result in a mess for manufacturers, stores or the consumer. Exposure to air or elements could also lead to spoilage, particularly for refrigerated foods. Inconsistent plastic packaging could result in weak points that break, crack or puncture, which could also result in mold, mess or other spoilage concerns. If a manufacturer experiences a failure in a heat seal or packaging leading to leakage or spoilage, RS analysis can help determine why the failure occurred (was in the plastic film or something else) to help prevent future issues.
  • Supply chain validation. It is extremely important that the plastic films coming from suppliers are what they are promising and what the manufacturer needs. RS analysis can be used to determine the chemical make-up and morphology of packaging to confirm a supplier’s claims before proceeding with use of the film in food packaging and products.
  • Simple decision making. If a manufacturer is trying to decide which material to use, RS can provide answers. For example, if there is a need for moisture non-permeating films and there are multiple options available, an RS chemical map can illustrate what to expect with each option, aiding in the decision-making process when combined with other known factors such as cost or timing. If there is an additive in the food product that may diffuse into the film, RS can determine which material might best resist the potential problem.
  • Packaging appearance. If there is a swirl or haze in the packaging, RS can compare the area with the issue to a clear section to determine if the defect in the film is a foreign polymer or an inorganic pigment or filler, identifying the source of the problem.

RS analysis provides a wealth of information in a manner that is non-destructive. Giving a chemical fingerprint to identify composition with extremely good spatial resolution gives manufacturers valuable information that can be used to mitigate issues, correct problems or make important decisions. These actions in turn can help ensure food safety, which builds brand image and manufacturer equity. Ultimately, RS analysis can play an important role in the success of a product, a brand or a company.

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part II)

By Frank Pisciotta, Spence Lane
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Food defense is the effort to protect food from intentional acts of adulteration where there is an intent to cause harm. Like counterterrorism laws for many industries, the IA rule, which established a compliance framework for regulated facilities, requires that these facilities prepare a security plan—in this case, a food defense plan—and conduct a vulnerability assessment (VA) to identify significant vulnerabilities that, if exploited, might cause widescale harm to public health, as defined by the FDA. Lessons learned during the conduct of food defense vulnerability and risk assessments and the preparation of the required food defense plan are detailed throughout this three-part series of articles. Part I of this series addressed the importance of a physical security expert, insider threat detection programs, actionable process steps (APS) and varying approaches to a VA. To further assist facilities with reviewing old or conducting new VAs, Part II will touch on access, subject matter experts, mitigation strategies and community drinking water through more lessons learned from assessments conducted for the largest and most complex global food and beverage facilities.

Lesson 6: Utilization of Card Access. The FDA costs of implementing electronic access control, as reported in the Regulatory Impact Analysis document (page 25) are shown in Table 1.

Average Cost Per Covered Facility Initial Recurring Total Annualized
Prohibit after hours key drop deliveries of raw materials $ $1070 $1070
Electronic access controls for employees $1122 $82 $242
Secured storage of finished products $1999 $– $285
Secured storage of raw materials $3571 $– $508
Cameras with video recording in storage rooms $3144 $– $448
Peer monitoring of access to exposed product (not used) $47 $1122 $1129
Physical inspection of cleaned equipment $– $303 $22
Prohibit staff from bringing personal equipment $157 $– $22
Total $9993 $1455 $2878
Table I. Costs of Mitigation

In our opinion, these costs may be underreported by a factor of five or more. A more realistic number for implementing access control at an opening is $5,000 or more depending on whether the wire needs to be run in conduit, which it typically would. While there are wireless devices available, food and beverage organizations should be mindful that the use of wireless devices may in some cases result in the loss of up to 50% of electronic access control benefits. This happens because doors using this approach may not result in monitored-for-alarm conditions, such as when doors are held open too long or are forced open. Some wireless devices may be able to report these conditions, but not always as reliable as hardwired solutions. Using electronic access control without the door position monitoring capability is a mistake. From a cost standpoint, even a wireless access control device would likely be upwards of $2,000 per opening.

Lesson 7: In the interest of time, and in facilities with more complex processes (which increases the work associated with the VA), plan to have quality, food safety and physical security personnel present for the duration of the VA. But also bring in operational specialists to assess each point, step or procedure for the respective operational areas. You may wish to have a quick high-level briefing for each operational group when it’s their turn to deliberate on their portion of the manufacturing operation. Proper planning can get a hybrid style VA done in one-and-a-half to three days maximum for the most complex of operations.

Lesson 8: Conduct a thorough site tour during the assessment process; do not limit your vulnerability activity to a conference room. Both internal and external tours are important in the assessment process by all members of the team. The external tour is needed to evaluate existing measures and identify vulnerabilities by answering questions such as:

  • Is the perimeter maintained?
  • Are cameras pointed correctly?
  • Are doors secure?
  • Are vehicles screened?
  • Are guards and guard tours effective?
  • Internal tours are important to validate documented HACCP points, steps or procedures.A tour also helps to validate process steps that are in multiple parts and may need to be further assessed as a KAT, for public health impact, accessibility and feasibility or to identify issues that have become “invisible” to site employees which might serve a security purpose.
  • Properly conducted tours measure the effectiveness of a variety of potential internal controls such as:
    • Access control
    • Visitor controls
    • Use of identification measures
    • Use of GMP as a security measure (different colors, access to GMP equipment and clean rooms)
    • Effectiveness of buddy systems
    • Employee presence

Lesson 9: Do not forget the use of community drinking water in your processes. This is an easy way to introduce a variety of contaminants either in areas where water is being treated on site (even boiler rooms) or where water may sit in a bulk liquid tank with accessibility through ladders and ports. In our experience, water is listed on about half of the HACCP flow charts we assessed in the VA process.

Lesson 10: Some mitigation strategies may exist but may not be worth taking credit for in your food defense plan. Due to the record keeping requirements being modeled after HACCP, monitoring, corrective action and verification records are required for each mitigation strategy associated with an APS. This can often create more work than it is worth or result in a requirement to create a new form or record. Appropriate mitigation strategies should always be included in your food defense plan, but sometimes it produces diminishing returns if VA facilitators try to get too creative with mitigation strategies. Also, it is usually better to be able to modify an existing process or form than having to create a new one.

Lesson 11: In cases of multi-site assessments, teams at one plant may reach a different conclusion than another plant on whether an identical point, set or procedure is an APS. This is not necessarily a problem, as there may be different inherent conditions from one site to the next. However, we strongly suggest that there be a final overall review from a quality control standpoint to analyze such inconsistencies adjudicate accordingly where there is no basis for varying conclusions.

Lesson 12: If there is no person formally responsible for physical security at your site, you may have a potential gap in a critical subject matter area. Physical security measures will make at least a partial contribution to food defense. Over 30 years, we have seen many organizations deploy electronic access control, video surveillance and lock and key control systems ineffectively, which provides a false sense of security and results in unidentified vulnerability. It is as important to select the right physical security measures to deploy, but also critical to administer them in a manner that meets the intended outcome. Most companies do not have the luxury of a full-time security professional, but someone at the plant needs to be provided with a basic level of competency in physical security to optimize your food defense posture. We have developed several online training modules that can help someone who is new to security on key food defense processes and security system administration.

Lesson 13: As companies move into ongoing implementation and execution of the mitigation strategies, it is important to check that your mitigation strategies are working correctly. You will be required to have a monitoring component, correction action and verification intended for compliance assurance. However, one of the most effective programs we recommend for our clients’ food defense and physical security programs is the penetration test. The penetration test is intended to achieve continuous improvement when the program is regularly challenged. The Safe Quality Food (SQF) Institute may agree with this and now requires facilities that are SQF certified to challenge their food defense plan at least once annually. We believe that frequency should be higher. Simple challenge tests can be conducted in 10 minutes or less and provide substantial insight into whether your mitigation strategies are properly working or whether they represent food defense theater. For instance, if a stranger were sent through the plant, how long would it take for employees to recognize and either challenge or report the condition? Another test might include placing a sanitation chemical in the production area at the wrong time. Would employees recognize, remove and investigate that situation? Challenge tests are easy high impact activities; and regardless of the outcome, can be used to raise awareness and reinforce positive behaviors.

Whether training a new security officer, reviewing existing security plans or preparing for an upcoming vulnerability assessment (due July 26, 2020), these lessons learned from experienced security consultants should help to focus efforts and eliminate unnecessary steps at your facility. The final installment in this series will address broad mitigation strategies, the “Three Element” approach and food defense plan unification. Read the final installment of this series on Lessons Learned from Intentional Adulteration Vulnerability Assessments, Part III.

magnifying glass

Food Fraud and Adulteration Detection Using FTIR Spectroscopy

By Ryan Smith, Ph.D.
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magnifying glass

Producers of food-based products are faced with challenges of maintaining the safety and quality of their products, while also managing rapid screening of raw materials and ingredients. Failure to adequately address both challenges can be costly, with estimated recall costs alone starting around $10 million, in addition to any litigation costs.1 Long-term costs can accumulate further as a result of damage to brand reputation. A vast array of methods has been employed to meet these challenges, and adoption continues to increase as technology becomes smaller, cheaper and more user friendly. One such technique is Fourier transform infrared (FTIR) spectroscopy, an analytical technique that is widely used for quick (typically 20–60 seconds per measurement) and non-destructive testing of both man-made and natural materials in food products. The uniformity and physical state of the sample (solid vs. liquid) will dictate the specifics of the hardware used to perform such analyses, and the algorithm applied to the identification task will depend, in part, on the expected variability of the ingredient.

Infrared spectral measurements provide a “compositional snapshot”— capturing information related to the chemical bonds present in the material. Figure 1 shows an example of a mid-infrared spectrum of peppermint oil. Typically, the position of a peak along the x-axis (wavenumber) is indicative of the type of chemical bond, while the peak height is related either to the identity of the material, or to the concentration of the material in a mixture. In the case of peppermint oil, a complex set of spectral peaks is observed due to multiple individual naturally occurring molecular species in the oil.

Mid-infrared spectrum, peppermint oil
Figure 1. Mid-infrared spectrum of peppermint oil. The spectrum represents a “chemical snapshot” of the oil, as different peaks are produced as a result of different chemical bonds in the oil.

Once the infrared spectrum of an ingredient is measured, it is then compared to a reference set of known good ingredients. It is important that the reference spectrum or spectra are measured with ingredients or materials that are known to be good (or pure)—otherwise the measurements will only represent lot-to-lot variation. The comparative analysis can assist lab personnel in gaining valuable information—such as whether the correct ingredient was received, whether the ingredient was adulterated or replaced for dishonest gain, or whether the product is of acceptable quality for use. The use of comparative algorithms for ingredient identification also decreases subjectivity by reducing the need for visual inspection and interpretation of the measured spectrum.

Correlation is perhaps the most widely used algorithm for material identification with infrared spectroscopy and has been utilized with infrared spectra for identification purposes at least as early as the 1970s.2 When using this approach, the correlation coefficient is calculated between the spectrum of the test sample and each spectrum of the known good set. Calculated values will range from 0, which represents absolutely no match (wrong or unexpected material), to 1, representing a perfect match. These values are typically sorted from highest to lowest, and the material is accepted or rejected based on whether the calculated correlation lies above or below an identified threshold. Due to the one-to-one nature of this comparison, it is best suited to identification of materials that have little or no expected variability. For example, Figure 2 shows an overlay of a mid-infrared spectrum of an ingredient compared to a spectrum of sucrose. The correlation calculated between the two spectra is 0.998, so the incoming ingredient is determined to be sucrose. Figure 3 shows an overlay of the same mid-infrared spectrum of sucrose with a spectrum of citric acid. Notable differences are observed between the two spectra, and a significant change in the correlation is observed, with a coefficient of 0.040 calculated between the two spectra. The citric acid sample would not pass as sucrose with the measurement and algorithm settings used in this example.

Mid-infrared spectrum, sucrose
Figure 2. An overlay of the mid-infrared spectrum of sucrose and a spectrum of a different sample of sucrose.
Mid-infrared spectrium, sucrose, citric acid
Figure 3: An overlay of the mid-infrared spectrum of sucrose and a spectrum of citric acid.

When testing samples with modest or high natural variability, acceptable materials can produce a wider range of infrared spectral features, which result in a correspondingly broad range of calculated correlation values. The spread in correlation values could be of concern as it may lead to modification of algorithm parameters or procedures to “work around” this variation. Resulting compromises can increase the potential for false positives, meaning the incorrect ingredient or adulterated material might be judged as passing. Multivariate algorithms provide a robust means for evaluating ingredient identity for samples with high natural variability.

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Data protection, security

The Digital Transformation of Global Food Security

By Katie Evans
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Data protection, security

Modern food supply chains are inherently complex, with products typically passing through multiple suppliers and distributors, as well as countries and continents, before they end up on the supermarket shelf. While global supply chains offer consumers greater choice and convenience, they also make protecting the security of food products more challenging. With additional stakeholders between farm and fork, products are exposed to an elevated risk of biological or chemical contamination, as well as food counterfeiting and adulteration challenges—potentially putting consumer health and brand reputation in jeopardy.

Given the importance of maintaining the safety, quality and provenance of food products, global regulatory bodies are placing the integrity of supply chains under increased scrutiny. In the United States, for example, the adoption of FSMA moved the focus from responding to foodborne illnesses to preventing them by prioritizing comprehensive food testing measures, enforcing inspections and checks, and enabling authorities to react appropriately to safety issues through fines, recalls or permit suspensions.1 Similarly, China’s revised Food Safety Law (known as FSL 2015) is widely considered to be the strictest in the country’s history, and seeks to drive up quality standards by empowering regulators, and enhancing traceability and accountability through robust record-keeping. 2 The European Union continues to closely regulate and monitor food safety through its General Food Law, which is independently overseen by the European Food Safety Authority from a scientific perspective.

Achieving the Highest Standards of Food Security, Integrity and Traceability

For producers, manufacturers and distributors, the heightened regulatory focus on the security and integrity of the food supply chain has placed additional emphasis on accurate record-keeping, transparent accountability and end-to-end traceability. To meet the needs of the modern regulatory landscape, food chain stakeholders require robust systems and tools to manage their quality control (QC), environmental monitoring and chain of custody data. Despite this, many businesses still handle this information using paper-based approaches or localized spreadsheets, which can compromise operational efficiency and regulatory compliance.

The fundamental flaw of these traditional data management approaches is their reliance on manual data entry and transcription steps, leaving information vulnerable to human error. To ensure the accuracy of data, some companies implement resource-intensive verification or review checks. However, these steps inevitably extend workflows and delay decision-making, ultimately holding up the release of products at a high cost to businesses. Moreover, as paper and spreadsheet-based data management systems must be updated by hand, they often serve merely as a record of past events and are unable to provide insight into ongoing activities. The time lag associated with recording and accessing supply chain information means that vital insight is typically unavailable until the end of a process, and data cannot be used to optimize operations in real-time.

Furthermore, using traditional data management approaches, gathering information in the event of an audit or food safety incident can be extremely challenging. Trawling through paperwork or requesting information contained in spreadsheets saved on local computers is time-consuming and resource-intensive. When it comes to establishing accountability for actions, these systems are often unable to provide a complete audit trail of events.

Digital Solutions Transform Food Security and Compliance

Given the limitations of traditional workflows, food supply chain stakeholders are increasingly seeking more robust data management solutions that will allow them to drive efficiency, while meeting the latest regulatory expectations. For many businesses, laboratory information management systems (LIMS) are proving to be a highly effective solution for collecting, storing and sharing their QC, environmental monitoring and chain of custody data.

One of the most significant advantages of managing data using LIMS is the way in which they bring together people, instruments, workflows and data in a single integrated system. When it comes to managing the receipt of raw materials, for example, LIMS can improve overall workflow visibility, and help to make processes faster and more efficient. By using barcodes, radiofrequency identification (RFID) tags or near-field communication, samples can be tracked by the system throughout various laboratory and storage locations. With LIMS tracking samples at every stage, ingredients and other materials can be automatically released into production as soon as the QC results have been authorized, streamlining processes and eliminating costly delays.

By storing the standard operating procedures (SOPs) used for raw material testing or QC centrally in a LIMS, worklists, protocols and instrument methods can be automatically downloaded directly to equipment. In this way, LIMS are able to eliminate time-consuming data entry steps, reducing the potential for human error and improving data integrity. When integrated with laboratory execution systems (LES), these solutions can even guide operators step-by-step through procedures, ensuring SOPs are executed consistently, and in a regulatory compliant manner. Not only can these integrated solutions improve the reliability and consistency of data by making sure tests are performed in a standardized way across multiple sites and testing teams, they can also boost operational efficiency by simplifying set-up procedures and accelerating the delivery of results. What’s more, because LIMS can provide a detailed audit trail of all user interactions within the system, this centralized approach to data management is a robust way of ensuring full traceability and accountability.

This high level of operational efficiency and usability also extends to the way in which data is processed, analyzed and reported. LIMS platforms can support multi-level parameter review and can rapidly perform calculations and check results against specifications for relevant customers. In this way, LIMS can ensure pathogens, pesticides and veterinary drug residues are within specifications for specific markets. With all data stored centrally, certificates of analysis can be automatically delivered to enterprise resource planning (ERP) software or process information management systems (PIMS) to facilitate rapid decision-making and batch release. Furthermore, the sophisticated data analysis tools built into the most advanced LIMS software enable users to monitor the way in which instruments are used and how they are performing, helping businesses to manage their assets more efficiently. Using predictive algorithms to warn users when principal QC instruments are showing early signs of deterioration, the latest LIMS can help companies take preventative action before small issues turn into much bigger problems. As a result, these powerful tools can help to reduce unplanned maintenance, keep supply chains moving, and better maintain the quality and integrity of goods.

While LIMS are very effective at building more resilient supply chains and preventing food security issues, they also make responding to potential threats much faster, easier and more efficient. With real-time access to QC, environmental monitoring and chain of custody data, food contamination or adulteration issues can be detected early, triggering the prompt isolation of affected batches before they are released. And in the event of a recall or audit, batch traceability in modern LIMS enables the rapid retrieval of relevant results and metadata associated with suspect products through all stages of production. This allows the determination of affected batches and swift action to be taken, which can be instrumental in protecting consumer safety as well as brand value.

Using LIMS to Protect Security and Integrity of the Food Supply Chain

Increasingly, LIMS are helping businesses transform food security by bringing people, instruments and workflows into a single integrated system. By simplifying and automating processes, providing end-to-end visibility across the food supply chain, and protecting the integrity of data at every stage, these robust digital solutions are not only helping food supply chain stakeholders to ensure full compliance with the latest regulations; they are enabling businesses to operate more efficiently, too.

References

  1. FDA. (2011). FDA Food Safety Modernization Act. Accessed October 3, 2019. Retrieved from https://www.fda.gov/food/food-safety-modernization-act-fsma/full-text-food-safety-modernization-act-fsma.
  2. Balzano, J. (2015). “Revised Food Safety Law In China Signals Many Changes And Some Surprises”. Forbes. Accessed October 3, 2019. Retrieved from https://www.forbes.com/sites/johnbalzano/2015/05/03/revised-food-safety-law-in-china-signals-many-changes-and-some-surprises/#624b72db6e59.