Testing methods, analysis

Beyond the Certificate of Analysis: What Supplier Verification Really Asks of You

By Bala Murugan
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Testing methods, analysis

Walk into most receiving operations and supplier verification looks like a filing system. A lot arrives, a certificate of analysis arrives with it, the COA says the ingredient is within spec, and the document goes into the folder. Box checked. It feels like verification right up until a recall, an FDA inspection, or a customer complaint asks the harder question the folder was never built to answer: not “do we have the paperwork?” but “was the product actually safe?”

Those are not the same question. The space between them is where a surprising number of preventable failures live, and closing it is one of the highest-return moves a quality team can make.

What the rule actually asks for

It helps to start with what FSMA requires, because the regulation is more demanding and more sensible than “keep the COAs on file.”

The Preventive Controls for Human Food rule (21 CFR Part 117) turned supplier oversight from a procurement nicety into a defined food safety control. Under Subpart G, when a hazard in an ingredient is controlled before you receive it what the rule calls a “supply-chain-applied control” your facility has to run a risk-based supply-chain program that gives real assurance the hazard was significantly minimized or prevented.1

Holding paperwork does not satisfy that. The rule expects you to use approved suppliers, decide on and carry out verification activities suited to the hazard, and document what you did. The part many programs miss is that the regulation deliberately scales the verification to the risk. For a hazard with serious health consequences say, a pathogen like Salmonella in a ready-to-eat ingredient an onsite audit of the supplier is the default expectation, before you first approve them and annually after, unless you’ve written down a defensible reason to do something else.3 For lower-risk hazards, sampling and testing, a review of the supplier’s records, or another fitting activity may be enough.

Read that closely and the rule is already making this article’s argument for you: verification is a spectrum, and a certificate is one tool on it right for some hazards, badly undersized for others.

Why a certificate isn’t proof

A COA is, at bottom, an assertion. It says someone tested a sample of a lot, by some method, and got a result. That can be genuinely useful. Treated as proof of safety, though, it has three weak points worth being honest about.

It describes a sample, not your lot. For contaminants that don’t distribute evenly mycotoxins, heavy metals, pathogens in dry goods are the usual suspects the result is only as good as the sampling behind it. Aflatoxin is the textbook case: a few contaminated kernels can carry thousands of times the toxin of the material around them, so a clean number pulled from a careless grab sample tells you about the scoop, not the shipment. If you don’t know how the supplier sampled, you don’t really know what their number means.

It’s only as good as the lab and the method. A result with no validated method behind it, from a laboratory whose competence for that analyte and matrix you can’t establish, is hard to lean on when it matters. That’s the practical case for accredited testing: ISO/IEC 17025 accreditation means a lab has shown technical competence for specific tests, works to validated methods, and proves itself through proficiency testing. A COA from an unknown lab and a report from an accredited one aren’t the same instrument, even when the numbers happen to agree.

And documents can simply be wrong through honest error, a stale specification, or, in the well-documented world of economically motivated adulteration, deliberate falsification. Anyone who has watched the adulteration stories around spices, oils, and honey knows that a supplier’s paperwork and a supplier’s product are not always the same thing.

None of this makes COAs worthless. It means they belong inside a program that occasionally tests whether they’re telling the truth not standing in for one.

Building verification that fits the hazard

The programs that hold up treat verification as a portfolio matched to risk, not a single document repeated for everything. A few principles do most of the work.

Match the effort to the hazard. Put your most rigorous tools onsite audits, independent confirmatory testing against the hazards that could hurt someone, and lighter activities against lower-risk ingredients. That isn’t just sensible; it’s how Subpart G expects you to make approval and verification decisions in the first place.

Spot-check your suppliers’ COAs with your own testing. The goal isn’t to retest every lot of everything nobody requires that, and nobody could afford it. It’s to confirm, on a risk-based cadence, that the supplier’s documentation matches reality, using a lab whose competence for that analyte and matrix you can actually demonstrate. The day your independent result and the supplier’s COA disagree is the day the whole program earns its keep.

Treat sampling as seriously as the assay. For unevenly distributed contaminants, the sampling plan is the control. Specify how representative samples get drawn and ground, because no instrument, however sophisticated, rescues a bad sample.

Revisit suppliers on a schedule and whenever something changes. New ingredient, new origin, new supplier the hazard picture moves, and the paperwork lags. The supply-chain program, and for imported ingredients its sibling the Foreign Supplier Verification Program under 21 CFR Part 1, expects you to weigh supplier performance and reassess when new information about a hazard or a supplier turns up.

Write down the reasoning, not just the result. When you choose a verification activity other than the default for a serious hazard, the rule expects a documented justification.3 The artifact that protects you isn’t only the test report; it’s the recorded logic tying the hazard to the supplier to the activity you picked.

The shift worth making

The real change here is one of posture. A program built to collect documents answers “do we have the paperwork?” A program built to verify answers the question that actually keeps people safe: if this ingredient were out of spec right now, would we catch it before our customer did?

The distance between those two questions gets measured in recalls. FSMA’s supply-chain program sets a floor approved suppliers, risk-based verification, documentation. The manufacturers who turn that floor into genuine protection are the ones who treat a certificate of analysis as the start of verification, not the end of it, and who back their supplier programs with sampling and analytical competence equal to the hazards they’re trying to control.

Paperwork can promise safety. Only verification demonstrates it.

Nuts, tree nuts
Allergen Alley

Aflatoxin: Managing A Stubborn Threat To Global Food Safety

By Stephen Fapohunda
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Nuts, tree nuts

Aflatoxins are a group of secondary metabolites  that   can be highly toxic, mutagenic and most importantly, carcinogenic. They are produced  primarily by species of the fungal genus called Aspergillus under  favourable conditions of humidity, temperature  and matrix integrity (is the food item healthy of not, whole or broken?) The regular species are Aspergillus flavus and Aspergillus parasiticus . Aflatoxins are categorized based on fluorescence and source. The B  and G aflatoxins  give blue and green colour respectively on UV light, while M group is specifically located in the milk of livestock. Both B and G categories are dietary aflatoxins .Ordinarily they are all colourless, tasteless and odourless.

Aflatoxin contamination of crops is a global  food safety concern. The most dangerous form is Aflatoxin B1 (AFB1), classified as a Group 1 carcinogen by the International Agency for Research on Cancer, IARC, which is the technical arm of the WHO. Generally many  food items are susceptible(1.)  however, notable candidate  crops include  maize, groundnuts, tree nuts, and spices on which contamination happens  before harvest and during storage under poor conditions.   (2, 3 )

For food brands, processors, and exporters, aflatoxins represent a dual risk: severe public health consequences and strict regulatory enforcement. In 2024 alone, the EU rejected 127 shipments from Africa due to aflatoxin levels exceeding 2 ppb  for AFB1. For consultants and auditors, understanding aflatoxin risk is now a core compliance skill for food safety, sustainability, and ESG(Environmental, Social and Governance) audits.

Geography

Aflatoxin contamination is not random. It clusters in tropical and subtropical regions with high heat and humidity. High-risk zones  are:

Sub-Saharan Africa like Ghana, Nigeria, Kenya, Tanzania, Senegal where  maize and groundnuts show 60-90% contamination rates. This is why the  various national regulatory agencies like NAFDAC (Nigeria) and KEBS (Kenya) enforce strict testing.

South/Southeast Asia comprising  India, Thailand and Vietnam with  spices, dried chilies, and pistachios being  major export rejection points. Some parts of the US are also recorded to experience  aflatoxin on farm and store. Significant work has been done on the Arizona field with regard to tree nuts, and cotton

Latin America with maize and peanut exports face EU/US border controls.

Low-risk zones include temperate regions like Northern Europe and Canada having a minimal pre-harvest risk but  could invite  post-harvest risk if imports are stored improperly.

For brands sourcing globally, geography is the first risk filter. For example, a peanut butter brand sourcing from west Africa may  face substantially  higher audit risk than one sourcing from the US.

Impact of Climate Change

As in other mycotoxins, climate change is making aflatoxin risk significant  and expanding its range  (4, 5)

The 3 mechanisms associated with climate change are:

Higher temperatures: A. flavus grows fastest at 28-35°C. As West Africa warms, more crops hit this range during growing season. Some  predictions  suggest  a 20% increase in contamination risk in Nigeria by 2030.

Drought stress: Water-stressed maize and groundnuts crack, allowing fungal spores to enter.Both  drought and heat combine to potentiate aflatoxin production,

Unpredictability: In recent times, regions previously “too cold” like Southern Europe are now reporting A. flavus in maize. For auditors, “climate risk” is no longer future talk. Clients must now ask suppliers: “What’s your drought mitigation plan?” If none, then the risk score goes up.

Recent taxonomic advances have expanded the list of known aflatoxin-producing fungi beyond Aspergillus flavus and A. parasiticus. Phylogenetic studies now confirm at least 18 species within Aspergillus section Flavi as aflatoxigenic, including newly described species such as A. korhogoensis from West Africa (6) and A. pseudocaelatus from South America  These cryptic species are morphologically identical to non-toxigenic strains, creating false-negative risks for labs using only visual or TLC methods. Molecular identification targeting aflatoxin biosynthesis genes such as aflR, nor-1, and omtA is now required for regulatory compliance. Climate change is therefore  driving range expansion of section Flavi species into temperate zones, increasing detection complexity for import/export audits (7, 8)

Detection

Effective interventions  rest on reliable detection and quantitation techniques. Detection methods range from field tests to lab confirmation:

Field screening involves  ELISA kits, lateral flow strips with sensitivity of about  5 ppb Many of these give results in  less than 20min.

Laboratory confirmation involving Thin Layer chromatography TC, High Performance Liquid Chromatography  HPLC  and LC/MS-MS  This can detect  about  0.1 ppb. Because of the sensitivity, it is usually recommended and required for EU/US export certificates.

The Polymerase Chain Reaction ,PCR is used to detects fungal DNA, since aflatoxin occurrence depends on the thriving of the fungus.. The MALDI-TOF technique is now the Gold standard for fungal identification due to its speed, low cost per sample and high accuracy.

Health Impacts

Aflatoxin is a silent killer partly because of the difficulty in detection ordinarily. Acute exposure repeatedly at low doses incites aflatoxicosis. In 2004 Kenya outbreak recorded  317 cases and 125 deaths from contaminated maize. Symptoms  express as liver failure, jaundice, or death in days.

Chronic exposure at  low doses over  many years can lead to  liver cancer. AFB1 metabolizes in liver to AFB1-8,9-epoxide which binds DNA. The WHO has estimated 25% of global liver cancer cases are aflatoxin-related, mostly in Africa  and  Asia.

In children symptoms observed include stunted growth  and  immune suppression. Some studies in tropical Africa  revealed that very a high aflatoxin exposure  can lead to double the stunting rates. For infant food brands, this is a regulatory flashpoint . Therefore any claim like “100% natural, safe for kids” on a maize product label  without proof of aflatoxin testing is a compliance red flag.

Regulations and Impact on International Trade

As a result of the health impact to human and animals, aflatoxins are one of the top  reasons food shipments are rejected at borders across the globe  For Aflatoxin B1, the EU set limit is 2 ppb(parts per billion) and 4ppb for total aflatoxins . The FDA in the USA accepts 20ppb for total aflatoxins in maize and  nuts

The EU rejected about 2,200 consignments  between 2020 and 2024, which averagely cost  $50,000 in lost goods  shipping, per rejection. The Rapid Alert System for Food and Feed RASFF is an effect step for European member states that ensures a preemptive action against contaminated imported shipments. In Africa, the instruments for enforcing regulations are relatively weak, leading to a freer circulation of toxic food items.

Apart from rejection, recall costs can  kill brands sometimes leading to a sharp drop in stock. For ESG audits, “supply chain mycotoxin risk” is now a scored item.

The Codex Alimentarius Commission  sets global baseline. 15 ppb total aflatoxins for most nuts. Countries can be stricter. Nigeria  adopts the  Codex standard  and enforcement  now includes  random market raids for  aflatoxin testing with penalties for  violators.

Intervention Strategies

It is very difficult, if not completely impossible to attain zero-level howver, biological control measures have been reported as effective (9) Aflatoxin risk but it can be managed  at 3 levels:

Pre-harvest: Drought-tolerant seeds, proper spacing, timely harvest and biological control like Aflasafe are all effective measures Aflasafe is a non toxigenic A. flavus strain that outcompetes toxic strains.6 Nigeria saw 80% reduction in maize after use(Ranajit (10). The product employs a ‘fungus-fight’ approach.7 In the US, the fields of Arizona witnessed a successful bio-control using same mode of action. The product is Aflaguard  with Aspergillus favus strain AF36 (11)which  is approved for organic use against pistachio, peanuts, almond and corn .

Post-harvest. The use of fast drying to at most 13% moisture within 48hrs as well as proper storage in hermetic bags like PICS bags have been confirmed as reliable . Keeping the storage environment well ventilated and devoid of any other contaminant is also crucial.

Processing. Physical sorting  by removing  visibly mouldy food items  and the use of  laser  sorters to remove damaged kernels are an attraction to exporters, processors and even domestic consumers. Roasting may reduce AFB1 by 40-60% but doesn’t eliminate it . Activated clay binders  and charcoal are effectively used in animal feed but not for human food.

A winning recommendation is  a combination of Awareness, Good Agricultural Practice (GAP), HACCP, ,Capacity building and a soup of Interventions. Generally, the chemical solution is now being discouraged due to inherent hazards

References

1.Esan A; S O Fapohunda; CN Ezekiel; M Sulyok and R Krska 2020 Distribution of fungi and their toxic metabolites in melon and sesameseeds marketed in two major producing states in Nigeria. Mycotoxin Research https://doi.org/10.1007/s12550-020-00400-0

2.Adewunmi ,A A and  Stephen O. Fapohunda 2019. Mycotoxins in Nigerian  cereals and public health implications. Recent Advances in Food Science; 2(4): 200-216

3.Adewunmi A, Stephen O Fapohunda, OlumidecAfolabi and Abiodun Joseph. 2021: Occurrence of mycotoxigenic fungi in guinea corn oleand pearl millet marketed in South west Nigeria. Recent Advances in Food Science 4(3) 341-357

4.Fapohunda S O and A AAdewunmi 2019Climate Change and Mycotoxins–The African Experience. Croatian Journal of Food Science and Technology 11(2)DOI: 10.17508/CJFST.2019.11.2.09

5.Esan A and Fapohunda  S O (2020)Fusarium toxins, climate change and food security Recent Advances in Food Science Open access 3 (3)332-340

6.Carvajal-Campos, A ,AmaLethiciaManizan  ID , SouriaTadrist , David KoffiAkaki ,RoseKoffi-Nevry , Geromy G. Moore , Stephen O. Fapohunda , A Sylviane Bailly, Didier Montet , Isabelle P. Oswald  ID , Sophie Lorber, Catherine Brabet and Olivier Puel(2017). Aspergilluskorhogoensis, a Novel Aflatoxin Producing Species from the Côte d’Ivoire. Toxins  9, 353; doi:10.3390/toxins9110353  1-22

7.Sharma, A.K., Kumar, A., & Rijal, R. (2025). Phylogenetic studies and distinction of aflatoxin-producing Aspergillus species in section Flavi, Ochraceorosei and Nidulantes: A review. Gene, 937, 149151. https://doi.org/10.1016/j.gene.2024.14915

8. Schamann, A., et al. (2024). Comparative analysis of the genomes and aflatoxin production patterns of three species within Aspergillus section Flavi reveals an undescribed chemotype. Communications Biology, 7, 1134. https://doi.org/10.1038/s42003-024-06738-w

9,Fapohunda S. O, Esan A O.  andAnjorin S. T (2017)Biological Control of Mycotoxins : an Update  World Veterinary Journal7 (4) 117-127

10.Cotty PJ.1990. Effect of atoxigenic strains of Aspergillus flavus on aflatoxin contamination of developing cottonseed. Plant Dis. 1990;74(3):233–235. doi: 10.1094/PD-74-0233.

11.Bandyopadhyay R, Atehnkeng J, Ortega-Beltran A, Akande A, Falade TDO and Cotty PJ (2019) “Ground-Truthing” Efficacy of Biological Control for Aflatoxin Mitigation in Farmers’ Fields in Nigeria: From Field Trials to Commercial Usage, a 10-Year Study. Front. Microbiol. 10:2528. doi: 10.3389/fmicb.2019.02528

Workers production line

Beyond Detection: Building a Multi-Layered Food Safety Defense System

By Michael Ciepiela
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Workers production line

In today’s rapidly evolving food safety landscape, recalls continue to outpace many of the advancements made in manufacturing efficiency, automation, and operational performance. Early in my career, a member of the operations team once told me, “If those belts aren’t running, we aren’t making any money.” To a certain extent, that statement is true. The purpose of manufacturing is to efficiently produce a quality product that consumers enjoy. However, in the food and beverage industry, success is measured by more than throughput and production volume. Unlike the latest television or smartphone, where the Voice of the Customer (VoC) may focus on features and performance, food consumers have a much simpler expectation: confidence that the product they are consuming is safe. The challenge arises when operational excellence begins to outpace the food safety systems designed to protect both consumers and brands.

Growth, continuous improvement, and increased throughput should never come at the expense of robust food safety practices. Instead, food safety programs must evolve alongside manufacturing operations to ensure both objectives advance together. The industry frequently discusses food safety culture and what it truly means to establish and sustain one. A strong food safety culture is not achieved simply through policies, procedures, or certifications; it is demonstrated when organizations refuse to compromise established controls, even when production pressures mount. Finding new ways to “keep the belts moving” should never result in bypassing the safeguards designed to prevent food safety failures. Food safety is not the responsibility of a single department—it is a shared responsibility that extends across operations, quality, sanitation, maintenance, supply chain, and leadership teams alike.

During my 13 years in the food industry, I have witnessed a remarkable transformation in how food safety programs are managed. The industry has progressed from paper-based records and spreadsheets to sophisticated Electronic Quality Management Systems (EQMS) capable of real-time monitoring, automated workflows, and predictive analytics powered by artificial intelligence. At the same time, consumers, customers, and regulators are demanding greater transparency, stronger supply chain oversight, and higher standards of accountability than ever before. As a result, food safety and food defense can no longer rely solely on hazard detection. The future of food safety lies in prevention through a multi-layered defense system that integrates supplier controls, facility design, environmental monitoring, advanced detection technologies, employee engagement, and data-driven decision making. The most effective food safety systems are not those that detect hazards after they occur, but those designed to prevent hazards from occurring in the first place.

So, what is a hazard?

Under the Food Safety Modernization Act (FSMA), food manufacturers are required to identify and evaluate potential hazards that could be introduced, occur naturally, or be unintentionally introduced throughout their manufacturing processes. This evaluation extends beyond the product itself and includes every step of the process flow, from receiving raw materials to packaging and distribution. Manufacturers must also consider all process inputs, such as water, ice, compressed air, and employee handling practices, as well as outputs including waste streams, rework, and by-products that could impact food safety.

In addition to evaluating process-related hazards, manufacturers are required to conduct a hazard analysis for each ingredient used in their products. Whether the finished product consists of a single commodity, such as fresh produce, or a complex multi-ingredient formulation, every ingredient must be assessed for potential biological, chemical, and physical hazards. These hazards may originate from the raw material itself, the supplier’s manufacturing practices, transportation conditions, storage environments, or the processing activities conducted within the facility.

A hazard is generally defined as any biological, chemical, or physical agent that has the potential to cause illness, injury, or adverse health effects if not properly controlled. Examples include pathogenic microorganisms such as Salmonella or Listeria monocytogenes, undeclared allergens, cleaning chemical residues, metal fragments, glass, plastic, or other foreign materials. Understanding where hazards originate and how they can enter the food supply chain is the foundation of an effective food safety system and serves as the first step toward developing preventive controls designed to mitigate risk before contamination occurs.

Following the Process Flow

When people hear the phrase “hazard intrusion,” it is natural to immediately think of physical foreign materials such as plastic, metal, glass, wood, or other extraneous objects entering a product. While physical hazards are often the most visible and easiest for consumers to recognize, they represent only one category of food safety hazards. An effective food safety program must also account for chemical hazards, such as undeclared allergens, cleaning and sanitation chemicals, lubricants, and pesticide residues, as well as biological hazards, including pathogenic microorganisms such as Salmonella, Listeria monocytogenes, and pathogenic strains of E. coli.

One of the greatest challenges facing food manufacturers is that these hazards can be introduced at virtually any point throughout the supply chain and production process. Hazards may originate from raw materials and ingredients, supplier practices, employee handling, equipment design, utility systems such as water or compressed air, sanitation activities, environmental conditions, packaging materials, or transportation practices. Even after multiple preventive controls have been established, opportunities for contamination can still exist if systems are not properly maintained and verified.

This reality highlights why modern food safety programs can no longer focus solely on detecting hazards in finished products. Organizations must implement multiple layers of preventive controls designed to identify, mitigate, and control risks before they impact product safety. Understanding how physical, chemical, and biological hazards can enter the process is the first step toward building a comprehensive food safety defense system capable of protecting both consumers and brands.

Shifting to Prevention

While the detection of a food safety hazard before product release is certainly a success, it often still carries significant consequences for the manufacturer. Foreign material findings, allergen cross-contact events, or pathogen detections frequently result in product holds, rework, additional inspections, production downtime, investigations, and increased labor costs. Although these outcomes are far preferable to releasing contaminated product into commerce, they still represent failures somewhere within the process that require resources to correct and manage.

The consequences become substantially greater when a hazard is not detected and affected product reaches the consumer. Product recalls can cost organizations millions of dollars in direct and indirect expenses, including product retrieval, disposal, regulatory oversight, legal liability, lost sales, brand damage, and diminished consumer trust. In many cases, the long-term impact on a company’s reputation can far exceed the immediate financial costs associated with the recall itself. For this reason, food safety professionals often face the challenge of justifying investments in new technologies, equipment, and preventive control programs, particularly when capital expenditures are under scrutiny.

This is where the philosophy of modern food safety has fundamentally shifted. Rather than relying solely on detection systems to identify hazards after they have occurred, organizations are increasingly investing in preventive measures designed to stop hazards from entering the process altogether. Enhanced supplier verification programs, sanitary equipment design, environmental monitoring, allergen management systems, predictive analytics, employee training, and advanced inspection technologies all serve as layers of protection that reduce risk before contamination occurs. The most effective food safety programs recognize that while detection remains essential, prevention delivers the greatest return by protecting consumers, preserving brand integrity, and avoiding the substantial costs associated with food safety failures.

Controls That Matter

Mitigating food safety risks and potential points of hazard intrusion throughout the manufacturing process requires the implementation of control measures designed to either prevent, eliminate, or reduce hazards to acceptable levels. Depending on the nature and severity of the hazard, these controls may be managed as preventive controls within a food safety plan or identified as Critical Control Points (CCPs). Regardless of the designation, each control must be supported by appropriate monitoring, verification, and corrective action procedures to ensure effectiveness. While every food manufacturing operation is unique, biological, chemical, and physical hazards each have distinct monitoring and control strategies.

Biological hazard controls are often centered around an Environmental Monitoring Program (EMP), which serves as an early warning system for potential pathogen harborage within the facility. Areas identified as higher risk for pathogen growth, particularly those located near food contact surfaces, are routinely swabbed on a predetermined frequency to verify sanitary conditions. These locations may include floor drains, equipment framework, conveyor supports, wheels, and, in some cases, food contact surfaces themselves. Depending on the product and associated risk profile, finished product pathogen testing may also be performed to further validate that products are free from contamination. However, biological hazard prevention extends beyond testing programs. Effective sanitation procedures, hygienically designed equipment, validated cleaning methods, sanitizer concentration monitoring, and ATP verification programs all play a critical role in reducing risk. As I often say, production starts with sanitation; without effective cleaning and sanitation practices, even the most advanced food safety programs can quickly become ineffective.

Chemical hazard controls focus primarily on preventing contamination from allergens, cleaning compounds, lubricants, and other chemical agents used throughout the facility. Verification that food contact surfaces are free from detergent and sanitizer residues prior to production is a critical component of any sanitation program. Equally important is the management of allergen cross-contact through proper cleaning validation, product scheduling, segregation practices, employee training, and label verification programs. The consequences of allergen contamination can be severe, particularly for sensitive consumers, with reactions ranging from mild discomfort to life-threatening anaphylaxis. As a result, undeclared allergens continue to be one of the leading causes of food recalls across the industry.

Physical hazard controls are designed to prevent or detect foreign materials before they reach the consumer. Common preventive measures include equipment inspections, preventive maintenance programs, sanitary equipment design, and foreign material control programs. Detection technologies such as metal detectors and X-ray systems are frequently implemented as CCPs or preventive controls to identify and remove contaminated product from the production stream. Depending on the manufacturing process, additional controls such as magnets, screens, filters, and sieves may be utilized to capture foreign materials before they enter finished products. While these systems are highly effective at detecting hazards, they should be viewed as one layer within a broader prevention strategy rather than the sole means of protection.

The most successful food safety programs recognize that no single control can eliminate all risk. Instead, they rely on multiple layers of preventive and monitoring activities working together to identify hazards early, prevent contamination events, and protect both consumers and the organization.

Creating a Culture of Prevention

Even the most robust food safety systems, advanced detection technologies, and comprehensive preventive controls can fail if the organization does not foster a culture that supports them. Food safety culture is the collective mindset, behaviors, and values that influence how employees approach food safety on a daily basis, especially when no one is watching. Building a culture of prevention requires more than annual training sessions or compliance audits; it requires visible leadership commitment, employee engagement, accountability, and continuous communication across all levels of the organization. From sanitation personnel and machine operators to supervisors and executive leadership, every individual plays a role in identifying risks, reporting concerns, and protecting consumers. When food safety becomes embedded into everyday decision-making rather than treated as a regulatory requirement, organizations move beyond simply reacting to hazards and begin proactively preventing them. Ultimately, the strongest defense against biological, chemical, and physical hazards is not a piece of equipment or a written procedure, but a workforce that understands the importance of food safety and is empowered to uphold it every day.

What the Future Holds for Food Safety Hazard Prevention

The food industry has made tremendous advancements in technology, automation, and operational efficiency, yet the fundamental responsibility remains unchanged: producing safe food for consumers. While detection systems such as metal detectors, X-ray units, environmental monitoring programs, allergen testing, and pathogen analyses remain critical components of a food safety program, the future of food safety lies in prevention. The most successful organizations recognize that hazard control is not achieved through a single piece of equipment, a laboratory result, or a regulatory requirement, but through a comprehensive system of preventive controls working together to reduce risk before contamination occurs.

Building an effective food safety defense system requires a multi-layered approach that incorporates supplier oversight, hygienic design, sanitation, environmental monitoring, allergen management, foreign material controls, employee engagement, and emerging technologies. Equally important is fostering a culture where every employee understands their role in protecting the consumer and where food safety is viewed as a shared responsibility rather than the sole responsibility of the Quality department. When food safety programs evolve alongside operational growth, organizations can achieve both production excellence and consumer protection without sacrificing one for the other.

At the end of the day, keeping the belts running is important, but ensuring that every product leaving the facility is safe is what sustains consumer trust, protects brand integrity, and ultimately keeps those belts running for years to come. The strongest food safety programs are not those that simply detect hazards—they are the ones that prevent them.

Food processing, pest management
Ask The Expert

Food Processing Pest Management: Where Pests Are Hiding in Your Facility — And How an IPM Program Helps Stop Them

By Patricia Hottel
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Food processing, pest management

A strong food processing pest management program starts with looking at the facility the way pests do. That means combining sanitation, maintenance, exclusion, monitoring, documentation and staff training into a proactive Integrated Pest Management (IPM) approach.

Key Takeaways for Food Processing Facilities

  • Pests often hide in ordinary operational areas that provide the moisture, food sources and shelter they need to survive and reproduce.
  • Drains, spaces under equipment and tight equipment layouts can make sanitation and exclusion efforts more difficult and provide food, moisture and shelter for pests.
  • Loading docks, delivery trucks and pallets can bring pests into a facility from other locations on the supply chain.
  • One of the first steps to food processing pest management is a comprehensive facility inspection that identifies pests and pest-conducive conditions like access, attractants and harborage.
  • IPM supports audit readiness by bringing together inspection, prevention, corrective action and documentation.

Where do pests hide in a food processing facility?

Pests most often hide in loading docks, floor drains, equipment voids, ingredient storage areas, employee breakrooms and waste handling zones. These locations provide the food, moisture, shelter and access that pests need to survive and reproduce in food processing facilities.

Food and beverage processors face a tougher pest challenge than many commercial businesses: their facilities can create the food, moisture, shelter and access pests seek, while strict food safety regulations leave little room for error. Under FDA’s preventive controls rule, food processing facilities must follow Current Good Manufacturing Practice requirements, as well as hazard analysis and risk-based preventive control requirements, under 21 CFR Part 117.¹

Pest activity can also affect food safety, sanitation, compliance and audit readiness. Orkin’s Food Safety Precision Protection™ integrates pest prevention into FSMA Food Safety Plan readiness, with a focus on reducing contamination risk and supporting audit-ready operations.²

What pest-conducive conditions are in food processing facilities?

The most common pest-conducive conditions in food processing facilities include food residue, standing water, organic buildup, damaged packaging, open waste containers and structural gaps that allow pests to enter.

Common attractants include spilled ingredients, organic buildup in drains or on equipment, standing water or leaks, open waste containers, damaged packaging or exterior vegetation. Different types of pests are attracted to different conditions. For example, flies may be attracted to clogged drains, while birds may create a sanitation risk around open loading docks or rooflines. Stored product pests can hitchhike in ingredients or packaging and turn storage areas into high-risk zones.²

IPM programs help teams move from reactive response to prevention. Orkin’s guidance emphasizes that IPM should prioritize facility inspections and maintenance, exclusion and sanitation first, with facility teams serving as active partners in prevention.³

What are the most overlooked pest hiding spots?

Pests can be found throughout  a facility, but some spots are more likely than others to harbor pests because they provide the right conditions for survival.

Loading Docks, Receiving Doors and Deliveries

With frequently opened bay doors, loading docks create frequent opportunities for pests to enter a facility. Pests don’t need a bay door to enter a facility, though — they can also sneak through tiny gaps under doors with damaged sweeps, broken window seals, cracks in exterior walls or through shipments.

Teams should inspect a facility’s exteriors for potential pest entrances and carefully inspect incoming shipments to avoid bringing pests inside. In every incoming shipment, look for gnaw marks, droppings, rub marks, damaged packaging, visible pests or other signs of pest activity.

Orkin Pros can recommend exclusion tools tailored to your facility’s needs, such as door sweeps to help close gaps and dock leveler seals or air curtains to help reduce flying pest entry at high-traffic openings. These are practical tools, but they must be maintained to remain effective. Orkin Pros can help identify which tools need to be replaced or repaired.

 

Drains and Wet Processing Areas

Drains, wet processing areas, leaks, gaps in equipment and other areas with standing water can collect organic buildup that provide food sources and breeding locations for pests like flies.⁴

Sanitation teams and pest management professionals should inspect drains, cracked flooring, standing water and hard-to-reach spaces under mixers, blenders and other equipment. These areas should be cleaned regularly to avoid organic debris from occurring.

Actizyme® Floor and Drain Cleaner uses enzymes to help break down organic material in drains, floors, pipes and crevices that can contribute to odors and fly activity. Orkin’s Small Fly Foam Service may also help address small fly pressure in drains and production-adjacent areas.

While not a standalone fly control solution, LED Insect Light Traps (ILTs) can provide valuable monitoring data and visibility into fly activity trends when placed appropriately.

Mixers, Blenders and Other Equipment

Equipment is often full of hard-to-reach, warm, food-adjacent spaces that can become a magnet for pest activity if not properly maintained.

Organic matter can collect around mixers, blenders, batching units and other equipment. Tight equipment placement may improve floor efficiency, but it can also make cleaning harder and lead to moisture and food buildup. With specialized training and deep industry expertise, Orkin Pros can collaborate with facility managers to identify potential pest hotspots in and around the facility.⁴

Teams should inspect beneath equipment legs, behind panels, around floor mounts and inside openings in equipment. Sanitation plans should define cleaning frequency, responsible roles and verification steps.

Ingredient Storage

Dry storage areas can feel lower risk because they are not wet or messy, but stored product pests can affect ingredients, packaging, supplies, audit outcomes and brand reputation.² Watch for webbing, larvae, adult insects, damaged packaging, residue and expired inventory.

Good storage habits matter. Rotate stock, maintain spacing for inspection, keep items off the floor and address damaged packaging quickly. Orkin’s Stored Product Pest Control service can support ingredient and grain-related pest concerns through inspection, monitoring tools such as pheromone traps and ongoing program adjustments.

Breakrooms and Employee Areas

A forgotten snack in a locker can support pest activity that eventually intersects with production. Employee areas can attract ants, cockroaches, rodents and flies when food storage, spills, trash or moisture get overlooked. Inspect lockers, vending areas, breakroom cabinets, trash containers, floor edges and gaps around plumbing or utility lines.

Staff training is essential. Employees should know how to report pest sightings, where to store food, why sanitation matters and what small signs are cues that a pest issue is emerging. Orkin Pros can provide staff training to help employees identify pest signs and understand their role in prevention.

Waste Areas

Waste areas offer food sources, moisture and odors. That makes them a high-priority inspection zone for flies, rodents, birds and other occasional invaders.

Check compactors, dumpsters, recycling bins, floor drains and other waste areas for signs of pest activity. Keep lids closed, clean spills quickly and power-wash dumpsters and the concrete pad beneath them to help keep buildup and odors under control.

How does IPM support audit readiness?

Integrated Pest Management (IPM) supports audit readiness by combining inspection, monitoring, corrective actions, documentation and trend analysis into a structured pest prevention program.

Audit-ready facilities maintain clear, thorough records of proactive IPM programs, pest activity, corrective actions and verification of effectiveness.

Orkin’s Food Safety Precision Protection is designed to support audit-ready documentation as part of a facility’s IPM program. Orkin InSite® gives customers 24/7 access to digital service records, monitoring data and trend reports in a convenient online dashboard.²

FAQs

Where do pests most often hide in food processing facilities?

Pests can hide in nearly all parts of a facility, but they’re especially likely to be found in areas with food sources, moisture, warmth and openings for pest entry and harborage.

Why are drains a common site of pest issues in food plants?

Drains can collect moist organic material . These conditions can attract and support small flies and other pests, especially in wet processing areas or under equipment where cleaning is more difficult.

How can loading docks increase pest pressure?

Loading dock doors and receiving doors are opened and closed often, giving pests an opportunity to enter a facility. Regular dock inspections and exclusion measures like air curtains and vinyl strip doors help reduce entry opportunities.

How can equipment sanitation affect pest activity?

Equipment sanitation affects pest activity because food residue and moisture can collect around, beneath and behind equipment such as mixers and blenders. Cleaning beyond visible surfaces helps reduce organic buildup and potential food sources or pest harborage.

What documentation do auditors expect from a pest management program?

Food processing, pest management
Your goal, and the goal of your pest control partner, should be that your facility is ready for an audit at any time. (Image courtesy of Orkin)

Auditors commonly review service records, monitoring logs, device maps, corrective actions, trend reports, product usage records, training documentation and evidence that deficiencies were addressed.

Orkin InSite® provides a comprehensive view of your pest management program through a convenient online dashboard, giving customers a streamlined way to manage reporting, notifications and team connectivity across one or multiple locations. With one-time setup, you can customize preferences, adjust them at any time and have reports delivered straight to your inbox.

What are the most common pests in food processing facilities?
The most common pests in food processing facilities include flies, cockroaches, rodents and stored product pests, all of which can create food safety, sanitation and compliance risks.

How do stored product pests enter a facility?
Stored product pests often enter food processing facilities through incoming ingredients, packaging, pallets or shipments, then spread when products are stored without proper inspection and rotation.

How often should food processing facility staff and pest management professionals inspect for pests?
Food processing facilities should inspect for pests routinely, with frequency based on risk factors such as seasonality, facility conditions, pest history and audit or regulatory requirements.

How does pest management support FSMA compliance?

Pest management supports FSMA compliance by helping facilities identify, prevent and document pest risks that could compromise food safety or sanitation standards.

Allergen Alley

How conveyor design can reduce allergen cross-contact in multi-product food facilities

By Rich Lunden
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Allergen cross-contact remains one of the most urgent safety challenges in food manufacturing. Food allergies can cause severe reactions, including life-threatening anaphylaxis, and even small amounts of an undeclared allergen can be enough to trigger a serious event in a sensitive consumer.¹ ³ Precision stainless steel belts offer a practical answer because their flat, nonporous surface helps prevent allergen residues from being trapped or transferred between product runs. For processors, the consequences reach far beyond one production error. Undeclared allergen incidents can lead to recalls, regulatory action, lost production time and lasting damage to consumer trust.² ³

The urgency is increasing because many processors are managing broader product portfolios, shorter production runs and more frequent changeovers on shared equipment. In a multi-product facility, the risk is straightforward: Residue from one product run can remain on equipment and move into the next product if the system is not designed and cleaned effectively. FDA has specifically identified shared food-processing equipment as a source of allergen cross-contact, and it requires manufacturers to implement controls that significantly minimize or prevent that hazard.³ ⁴

That makes conveyor design a food safety issue, not just a mechanical decision. Conveyors are present at nearly every stage of production. They move ingredients, intermediate product and finished goods through processing, cooling, inspection and packaging. When the belt surface traps residue, requires lubrication or sheds particles, the conveyor can become a persistent source of allergen carryover. When the system is designed for cleanability and stable operation, it can help processors reduce that risk while maintaining efficiency.

Why allergen control deserves more attention now

Food manufacturers have always had to manage allergens carefully, but the current operating environment raises the stakes. Product variety has expanded across many categories. More facilities are running allergen-containing and allergen-free products on the same lines. Changeovers are happening more often, and every changeover creates another opportunity for allergen residue to remain behind.

That matters because the people affected by these failures are not dealing with a minor quality issue. They are dealing with a potential life-safety event. FDA notes that exposure to food allergens poses a risk for potentially severe and life-threatening reactions, and that undeclared food allergens remain a leading cause of food product recalls.³ For processors, that means allergen control has to be treated as a core part of operational design, verification and daily execution.

Sanitation programs remain essential, but sanitation alone is not enough if the equipment works against the process. Cleaning teams can only remove what they can access. Validation becomes more difficult when the product-contact surface contains pores, seams, cracks, worn areas or places where product dust can collect. Equipment design determines how difficult the cleaning task will be before a sanitation crew starts.

Why conveyor design matters in allergen prevention

FDA’s preventive controls framework makes clear that food allergen controls and sanitation controls are written procedures facilities must have and implement to control allergen cross-contact and maintain sanitary conditions that minimize food allergen hazards.⁴ In practical terms, that means processors need equipment that supports those procedures under real production conditions.

A conveyor belt sits directly in the product zone. Its surface condition affects how much residue remains after discharge, how easily cleaning crews can remove what remains and how consistently the line can be returned to a validated state for the next run. The conveyor’s surrounding design matters too. Transfer points, supports, return paths, pulley areas and frame geometry can all create places where small food particles, oils or sticky product films collect.

FDA’s draft food allergen program guidance tells manufacturers to consider how current good manufacturing practice measures prevent allergen cross-contact due to plant design, sanitary operations, equipment and utensils, ingredients and manufacturing operations. That guidance also recommends incorporating design features that minimize the potential for allergen cross-contact and facilitate cleaning of equipment.⁵

How residue remains on conventional conveying surfaces

Residue can remain after a product run in ways that are easy to underestimate. Powders settle in worn or irregular surfaces. Small food particles gather at edges and transfer points. Oily ingredients cling to rough contact areas. Sticky products leave thin films behind that are not always visible during routine inspection. In a shared-line environment, even a small amount of material left on the conveyor can become the source of an undeclared allergen in the next batch.

Surface stability matters as much as surface cleanability. A belt that degrades over time becomes harder to clean because use and sanitation change the condition of the material. Tiny defects can turn into retention points. Once that happens, the sanitation process becomes less repeatable, and allergen verification becomes more difficult.

Lubrication can add another concern. In food production, any substance introduced near the product zone deserves close scrutiny. Lubrication points can attract product dust and create more areas where allergen residue accumulates. They can also complicate cleaning and inspection.

Particle shedding is another issue that is often treated as a maintenance problem when it should also be viewed as a hygiene concern. If a conveying surface frays, flakes or sheds particles, those particles can introduce contaminants into the product zone and carry residue into adjacent areas.

Why precision stainless steel belts help reduce cross-contact

Precision stainless steel belts, including PureSteel® metal belts, provide a flat, nonporous product-contact surface. That surface does not absorb product residue and does not present the same types of harborage points created by more irregular or degradable materials. Powders, oils and small food particles are less likely to become embedded in the belt surface, which helps reduce carryover between product runs.

They also do not require lubrication. That simplifies sanitation and removes one more place where residue can accumulate. In facilities where changeovers are frequent, that can improve cleaning consistency and reduce the time needed to prepare the line for the next product.

Precision stainless steel belts will not fray and shed particles in the way some other belt materials can. Their resistance to corrosion is equally important. FDA guidance emphasizes cleaning procedures tailored to both residue type and food-contact surface.⁵ A corrosion-resistant stainless steel belt helps processors maintain a stable surface through repeated exposure to water, detergents and sanitation chemistry, supporting thorough, repeatable cleaning over time.

In addition, these belts provide high positional accuracy and consistent tracking. That precision reduces product movement variability, limiting spillover and buildup along conveyor edges or transfer points. Less residual material during production means less to remove during sanitation.

The role of wire mesh belts in hygienic conveyor design

Wire mesh conveyor belts are another proven option for food processors focused on sanitation and contamination control. Constructed from stainless steel, they provide a nonporous surface that resists bacterial growth and maintains structural integrity under demanding conditions such as high-temperature baking or freezing operations.

One of the defining advantages of wire mesh belts is their open design. The mesh allows for airflow and drainage, which is critical in processes that involve cooling, drying or washing. This openness helps prevent debris accumulation and supports more effective cleaning, particularly when using clean-in-place systems.

Wire mesh belts are also highly durable and resistant to corrosion from moisture and cleaning agents. Their design allows for efficient washdowns with reduced water and chemical usage, supporting both sanitation goals and operational efficiency. Many designs also allow for straightforward repair through splicing, which can extend service life without compromising hygienic performance.

From a compliance standpoint, stainless steel wire mesh belts can meet FDA and USDA requirements for direct food contact when properly specified and maintained. Their ability to withstand aggressive sanitation protocols without degradation makes them a practical solution in facilities with strict hygiene requirements.

Choosing between solid stainless steel and wire mesh belts

While both precision stainless steel belts and wire mesh belts support hygienic conveying, their strengths align with different application requirements.

Solid stainless steel belts are best suited for applications that demand maximum surface control. Their flat, continuous surface eliminates openings where product particles could fall through or become trapped. This makes them particularly effective in allergen-sensitive environments where preventing any residue carryover is critical. They also deliver superior positional accuracy, making them ideal for indexing, inspection and automated processes where precision matters.

Wire mesh belts, by contrast, are defined by their openness. That design allows air, liquids and heat to pass through the belt, making them well suited for baking, frying, freezing and drying processes. The open structure reduces contact area and promotes faster cooling or drainage, which can be essential for certain food products.

There are also practical considerations related to system design.  Wire mesh belts can be produced in very wide formats, which is beneficial for large-scale processing lines. Solid stainless steel belts are typically selected when precision and surface integrity outweigh the need for openness.

In allergen control specifically, the choice often depends on how residue behaves in the process. If the priority is preventing any product from becoming lodged or retained, a solid stainless steel belt provides a clear advantage. If the process benefits from airflow and wash-through cleaning, a wire mesh belt may offer better performance.

Cleanability and efficiency are connected

In a multi-product facility, allergen control and line efficiency are closely linked. Equipment that is difficult to clean extends downtime, increases labor demands and adds uncertainty during verification. Equipment designed for cleanability helps teams complete sanitation more thoroughly and restart production with greater confidence.

Conveyor performance during production also affects what sanitation teams face afterward. A belt that runs flat and tracks accurately is less likely to create unnecessary spillover, edge buildup or product agitation. Less residue around the conveyor path means less material to remove during changeover.

This is where equipment choice becomes part of a broader allergen management strategy. A processor still needs training, production scheduling, sanitation validation and verification. But the conveyor system should support those controls, not make them harder to execute.

What processors should look for

When evaluating conveyors for allergen-sensitive production, processors should ask direct questions:

  • Is the product-contact surface flat, nonporous and easy to sanitize?
  • Does the system avoid lubrication in the product zone?
  • Will the belt maintain its surface integrity after repeated sanitation cycles?
  • Are transfer points and surrounding components accessible for inspection and cleaning?
  • Does the conveyor design minimize places where small food particles can collect during normal production?
  • Does the belt type align with process needs such as airflow, drainage or precision handling?

These questions shift the discussion from simple equipment selection to risk reduction.

Conclusion

Allergen cross-contact is not just a compliance issue. It is a consumer safety issue with potentially severe consequences. Conveyor design plays a direct role in controlling that risk.

Precision stainless steel belts such as PureSteel® provide a flat, stable, nonporous surface that supports consistent sanitation and minimizes residue carryover. Wire mesh belts offer complementary advantages through their open design, enabling airflow, drainage and efficient cleaning in the right applications.

For multi-product food facilities, selecting the appropriate conveyor system is a practical step toward stronger allergen control and more reliable operations. The right choice depends on process requirements, but in all cases, the goal remains the same: reduce contamination risk while maintaining efficient, repeatable production.

References

  1. S. Food and Drug Administration. Food Allergies: What You Need to Know. Aug. 16, 2024.
  2. S. Food and Drug Administration. Food Allergies. Updated March 11, 2026.
  3. S. Food and Drug Administration. The Current Food Allergen Landscape. May 5, 2021.
  4. S. Food and Drug Administration. FSMA Final Rule for Preventive Controls for Human Food. Jan. 6, 2025.
  5. S. Food and Drug Administration. Hazard Analysis and Risk-Based Preventive Controls for Human Food: Draft Guidance for Industry, Chapter 11: Food Allergen Program. Draft guidance.

 

Preventing Container Damage and Contamination in High Production Environments

By Emily Newton
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At high speed and in hygienic conditions, empty aluminum cans, PET bottles and glass containers have to be carried from pallet storage to areas for rinsing, filling and packaging. This must be done without deformation, tumbling or contamination. An automatic depalletizing machine may be the answer.

Due to higher throughput requirements, the first step of the packaging line often determines if the container arrives at the filling equipment intact. Depalletizing systems remove containers from pallet loads and move them via conveyor systems to a system that rinses and fills them. If integrated properly with the rest of the line, they stabilize container movement and reduce the risk of contamination before production.

Best Manufacturing Practices

Cans await the next stage of production

Current good manufacturing practices covered by the U.S. Food and Drug Administration include sanitary operations, plant equipment and production controls to prevent contamination during food processing. Machinery design and operations provide two key elements of contamination control practices in beverage manufacturing environments.

Why Container Damage Often Starts at the Pallet

Many problems start before the container reaches the filler. When palletized loads are moved, any damaged or displaced pallets can lead to unstable layers. Differences in the lift levels can cause denting or tipping. According to the Packaging Machinery Manufacturers Institute, container damage can be caused by:

  • Pallet misalignment or shifted container layers.
  • Debris from slip sheets or pallet materials.
  • Uneven transfer from pallets to conveyors.
  • Pressure differences between aluminum, PET and glass containers.

As depalletizing is typically the first mechanical transfer in a packaging line, careful equipment design can reduce these issues.

Layer Handling Improves Container Stability

The best way to prevent damage at high speeds is to handle the containers layer-wise rather than individually. That way, the pressure distribution stabilizes and reduces the friction between them.

According to Ska Fabricating, a depalletizer is used in beverage and consumer packaged goods manufacturing to remove products or containers from pallets and place them on conveyors or production lines. This eases rinsing and filling, while maintaining consistent container orientation.

Layer transfer systems are commonly used in beverage plants, often in conjunction with conveyor and rinser systems when depalletizing aluminum cans, PET bottles and glass bottles. This machinery must manage high throughput rates with minimal stress on the containers early in the packaging process.

Stable Container Transfer Prevents Downstream Disruptions

Containers are aligned and oriented as they are moved from layers of pallets into conveyors feeding rinsers and fillers.

To solve misalignment problems, A-B-C Packaging Machine Corp. recommends equipment designed to maintain a controlled flow of containers. It states that the Model 108 depalletizer provides an uninterrupted flow of containers to the processing line, maintaining a steady flow during high-speed packaging operations.

Keeping containers moving in consistent flows reduces dented cans, tipped bottles and production loss.

Sanitation and Equipment Design Work Together

Preventing contamination is about more than cleaning. Equipment design can directly affect the ability to clean and sanitize.

The FDA stresses that cleaning and sanitizing food-contact surfaces is critical in controlling contamination. A dirty or poorly maintained surface promotes impurities. Proper equipment layouts and the ability to remove built-up debris determine sanitation effectiveness.

Depalletizers, when combined with a slip-sheet removal and pallet centering system, may help reduce debris from entering production. The Ferrum Group designs its beverage depalletizing machines for high-speed production systems, supporting container handling and separating palletized materials from receptacles before they are fed into the fill line.

These systems also help keep production areas clean and protect containers during transportation.

Automation Tools Offer High Throughput While Retaining Control

Modern beverage facilities require an optimal trade-off between protecting containers from mechanical damage and production speed, which is greatly helped by automation.

According to BW Integrated Systems, conventional depalletizers remove containers one layer at a time and carefully push them onto conveyor belts, leading to the next step in the packaging process. They also hold containers in place during high-speed operations.

Automated depalletizing lines may include conveyors, inspection systems, rinsers and other ancillary equipment to maintain container flow while protecting the packaging.

Depalletizing Considerations for Beverage Co-Packers

Beverage co-packers often will co-pack for more than one container type within the same plant, such as beer in aluminum cans, tea and juice in PET bottles, and specialty drinks in glass.

Because there are so many kinds, flexible depalletizing systems are common now. One type of depalletizer may only work with one type of container. Others can work with glass, plastic and metal containers, switching between formats without sacrificing throughput.

Since co-packers may produce multiple brands, this allows for streamlined production schedules and minimizes container damage during changeovers.

Features of Modern High-Speed Depalletizers

Manufacturers considering an automatic depalletizer machine consider various operational factors:

  • Layer handling capability: Allow container transfer with little mechanical impact
  • Material suitability: Suitable for aluminum, polyethylene terephthalate and glass
  • Order of operations: Prevents pallet pieces from contaminating product after removal of the slip-sheet
  • Changeover flexibility: Enables faster conversion to a different container format
  • System integration: Eases the flow of containers from filler to packer

These and other features allow beverage facilities to package products at high speeds while also protecting containers.

Frequently Asked Questions

Here are some common questions manufacturers have about using depalletizers to help prevent damage and contamination.

What is the function of a beverage depalletizer in production?

A depalletizer removes containers from the product layer on the pallet, placing them on a conveyor for rinsing, filling and packaging.

Why is container protection important before filling?

Dented or misaligned containers can cause problems downstream in the filling and sealing processes. Damage prevention during depalletizing can eliminate these problems and improve packaging efficiency.

How do depalletizers help?

Some depalletizing systems also remove slip sheets and other pallet debris before the containers are rinsed, preventing foreign material from entering the production line.

When should beverage facilities update their depalletizing equipment?

Facilities will typically update depalletizers when production speeds increase or when new container styles or sanitation regulations are introduced.

Protecting Containers in High-Speed Beverage Production

Preventive measures to prevent damage and contamination are taken at the beginning of the packaging process. Depalletizing systems stabilize container handling by consistently removing debris-free pallets for downstream processing.

Modern, high-volume beverage manufacturers can employ depalletizer equipment with conveyors and sanitation systems, which can achieve high throughput and maintain container integrity in harsh environments.

Bug Bytes

Fly Control in Food Processing Facilities: Reducing Seasonal Risks

By Patricia Hottel
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Flies are often dismissed as a nuisance, but in food processing environments they present a real risk as vectors of disease and a potential source of costly operational disruptions. They follow the conditions they need to survive — moisture, residue and access.¹ By addressing those conditions early, food processing facility managers can help reduce fly risks.

Under Section 402(a)(4) of the Federal Food, Drug and Cosmetic Act, food may be deemed adulterated if exposed to conditions where contamination is possible.4 Fly activity fits squarely within that definition, as these insects move freely between waste sources and food-contact surfaces, potentially spreading pathogens.³

Pest Prevention Pre-Requisites must demonstrate that risks are identified, recorded and corrective action is taken through documented procedures. Modern food safety systems, including FSMA Preventive Controls and GFSI-benchmarked standards, rely on integrated pest management (IPM) practices as part of a Pest Management Pre-Requisite.

IPM is a science-based pest control strategy that focuses on prevention, monitoring, documentation and targeted treatment using the lowest risk methods that are effective to minimize pest risks in regulated environments such as food processing facilities.

Where Fly Activity Signals Breakdown in Preventive Controls

Small structure-infesting flies like drain and phorid flies are weak fliers and tend to stay close to the conditions they need to survive — places with moisture, organic materials or waste and gaps to get indoors.

Drains and Biofilm

Drains are a common breeding site for small structure-infesting flies. Organic material accumulates below the surface, forming biofilm that supports larval development. Surface cleaning may improve appearance, but without removing that buildup, the food source remains.²

Bleach doesn’t remove biofilm­ — it just slides right over it. Instead, facilities should use a biological drain cleaner with enzymes that can eat through the gunk.

Waste Handling and Dumpster Areas

Regularly cleaning waste bins, including power washing the concrete pad beneath them, can help remove fly-attracting scents and buildup. (Credit Orkin Commercial)

Waste zones create strong odor signals that attract multiple species of flies including filth flies like the house fly and small flies like phorid flies. Inadequate cleaning or dumpsters located close to buildings can sustain fly populations that migrate toward production areas.²

Dumpsters should be cleaned regularly, including pressure-washing the concrete pad beneath them to eliminate residue that can attract and support fly populations. When waste haulers replace dumpsters, they should be cleaned prior to delivery.

Moisture and Condensation

Flies need moisture to survive. Condensation lines, leaks and standing water create ideal breeding conditions. Organic material with a high moisture content is required for successful fly development.3

Receiving and Loading Docks

Food processing facilities are especially vulnerable to fly activity near building entrances and loading docks, where flies can enter a facility from outside. Doors should not be left open when not use.  When closed, there should be a tight seal around all sides. Mechanical controls, such as air curtains, can help create barriers that flies cannot penetrate.

How Does Fly Activity Impact Audit Readiness?

Within the modern regulatory landscape, auditors review documentation as evidence of preventive pest management, including fly control. To meet FSMA-aligned Food Safety Plan standards, Pest Prevention Pre-Requisites must demonstrate that issues are resolved through documented monitoring procedures, activity thresholds, pest sighting logs, corrective actions and verification.

If fly activity is observed, auditors will evaluate how the facility responded. Was the source of the issue identified? Were corrective actions taken? Was the treatment effective?

When looking for a pest management partner, consider partners that offer documentation, like a digital pest management reporting platform as part of services. For example, Orkin InSite® helps facility managers easily locate reports, manage multiple locations, track pest trends and receive proactive program recommendations.

In food processing facilities, many types of documentation are necessary to meet auditor standards, including but not limited to:

  • Initial risk assessments and defined action thresholds for preventive controls
  • Detailed service reports documenting activity and actions
  • Pest sighting logs and trend reports
  • Compliance documents such as licenses, insurance, training verification and other certifications

The Orkin InSite system is designed to house and archive all your documentation requirements for quick and easy retrieval as required by FSMA.

Food processing managers should also keep logs of reported pest sightings. Not only are they expected by auditors, but pest sighting logs can help facilities identify pest issues early on, recognize patterns and be used to verify the Pest Prevention Pre-Requisite through trending analysis, easily conducted through the InSite system. To give auditors an accurate picture of your facility’s IPM plan, log entries should include matching documentation of  actions in place and preventive controls taken.

Each log should document these details of the pest sighting:

  • Date and time
  • Individual reporting the activity
  • Pest identification, including a sample if captured
  • Exact location
  • Actions taken to avoid future occurrences 4

Fly Prevention Strategies Within a Pest Prevention Pre-Requisite

Effective fly control is grounded in structured, evidence-based IPM programs that emphasize prevention, monitoring and documentation.¹ These programs reflect standards-driven methodologies backed by trained professionals who understand regulatory expectations and facility operations.

Inspection: Finding the Source

Effective fly control begins with a structured inspection protocol targeting the four conditions that support fly survival and reproduction inside and around commercial food environments:

  1. Drains and Pipe Systems: Check for organic accumulation and biofilm formation, primary breeding sites for phorid flies and drain flies.
  2. Ingredient Storage Zones: Identify improperly stored or exposed raw materials that attract house flies and blow flies.
  3. Waste and Dumpster Areas: Assess proximity to building entrances and organic residue buildup. Use self-closing lids on exterior trash receptacles, including those used in exterior employee break areas and truck driver entrances.
  4. Structural Access Points²: Document gaps, failing door seals and screen integrity at loading docks, vents, windows and receiving areas.

Commercial technicians should conduct facility-specific inspections as part of a structured IPM program, generating documented findings that support FSMA Preventive Controls compliance and GFSI audit readiness.

Sanitation: Removing the Breeding Sites

Flies depend on moist organic material to eat and complete their life cycle. Sanitation practices can help remove the organic material that flies need to survive and reproduce.

  • Mechanically remove heavy accumulations of debris from drains and supplement drain cleaning with biological cleaners. Enzymes in biological cleaners help remove biofilm, not just surface residue
  • Keep waste containers away from building entrances, use self-closing lids on trash receptacles and clean them regularly
  • Deploy sanitation and cleaning practices to remove debris and organic buildup from production zones³

Exclusion: Controlling Access

Exclusion measures help keep flies outside where they belong:

  • Maintain door sweeps and test them with the “dollar bill test.” If you can slide a dollar bill under the door sweep, it’s no longer effective and should be replaced immediately.
  • A 16 mesh screen will exclude most flies. Fungus gnats and Drosophila fruit flies require an even smaller mesh size of 20. Make sure all screens are tight fitting without any gaps.
  • Use air curtains at entry points, which create a blast of air that is difficult for flies to penetrate.
  • Work with a HVAC professional to maintain the building’s positive air pressure.  Negative air pressure can draw and pull flies into the structure through air currents.2

Mechanical Controls: Monitoring Activity

Monitoring tools support verification of effectiveness and trend analysis.

  • To maximize capture rates and facilitate trap service, install Insect Light Traps (ILTs)   at approximately 5 feet off the ground. This will facilitate proper functionality and provide the recommended height for maximizing capture rates.
  • Avoid placement near food or food contact surfaces to prevent attracting flies to these areas.
  • Use capture data to identify patterns of fly activity in your facility.²

How Fly Control Involves the Whole Team

Sustained fly control requires coordination across teams and consistent execution.

  • Sanitation teams address organic buildup and prompt waste removal.
  • Maintenance teams keep exclusion measures, like door sweeps, in good working condition.
  • Quality and operations teams verify documentation and corrective actions to reinforce cGMP compliance and stay audit-ready

Facilities that integrate these functions into day-to-day operations are better positioned to protect the integrity of the food produced and avoid costly operational disruptions and  damaging shutdowns tied to audit findings.

Working with pest control partners who understand the demands of food processing environments — and who provide proactive guidance, structured programs and audit-ready documentation — helps facilities stay prepared year after year.

Ask The Expert

Food Safety as Business Infrastructure

By Azure Edwards, M.S.
No Comments

Fifteen years after FSMA reoriented food safety around prevention, the technical infrastructure is largely in place. What is becoming visible at this maturity point is the layer beneath it — the business decisions, governance structures, and organizational design that determine whether that infrastructure actually holds under real operational conditions.

This five-part series examines food safety through the business realities that leaders already navigate: profitability, risk, growth, brand trust, and organizational function. Not to reframe food safety as a business problem, but to make visible what the industry has earned the right to see clearly. Food safety outcomes are shaped upstream of the technical program, in the structures responsible for decision-making and execution. Each article stands alone. Together they trace a single line of thinking about where the conversation goes next.

The Business Layer of Food Safety

Fifteen years after FSMA reoriented the food safety conversation from response to prevention, the industry is taking stock of how far it has come and beginning to ask what comes next. The technical infrastructure that the regulation called for is largely in place. Preventive controls, environmental monitoring, supplier verification, documented systems designed to demonstrate control: organizations have invested heavily in building these programs, and the investment has mattered. What is becoming visible at this maturity point, precisely because the technical layer is now developed enough to examine clearly, is the layer beneath it. The decisions that shape how work actually happens, the authority structures that determine who can act and when, and the resource allocations that establish what the system can realistically do under pressure. The industry recognizes this layer. Food safety is earning a seat at the leadership table, and the conversation arriving with it is more sophisticated than it has ever been. What is still being built is the shared language that allows that recognition to move from individual insight into organizational practice — the clarity that lets the governance layer function not just as something experienced professionals can describe, but as something the organization can deliberately act on.

That gap between recognition and shared operational language is where most recurring food safety instability actually lives. A single deviation is an event. The same deviation returning across multiple corrective action cycles, under different operators and different supervisors, despite documented resolution, is something else. It is the friction that has become familiar, and the category of work the organization has silently learned to expect rather than eliminate. Fifteen years of investment in preventive infrastructure has produced something valuable that the industry hasn’t fully used yet — a record precise enough to show, over time, not just what went wrong, but what keeps returning and why. The correction closed the record. It did not reach the source.

Consider what that looks like on the floor. A food manufacturing facility has a recurring GMP issue: sanitation tools left on the floor rather than returned to storage after use. The expectation is documented, the procedure exists, and the team has been trained far more than once. When the issue surfaces again, the response follows the familiar path: a reminder, a retraining, a corrective action that closes with appropriate documentation. And for a period things improve… until they don’t. What finally shifted the outcome wasn’t a stronger procedure or more consistent enforcement. It was a different question: not what are people doing wrong, but what is the system making it easier to do? When I examined the actual conditions rather than the behavior, the answer was immediate. Storage locations were positioned away from where the tools were used, the hardware didn’t fit the tools being issued, and returning equipment properly required extra movement that, under the pace of a working shift, simply didn’t happen reliably. Once the storage locations were repositioned and the hardware matched the tools, the issue resolved without additional training, without escalation, without any of the interventions that had been tried before. The behavior changed because the conditions changed.

What that case reveals extends well past its specific details. Through multiple corrective cycles, the investigation had been aimed at the people in the system — their knowledge, their habits, their compliance — when the actual source of the pattern was sitting in the design of the environment they were working in. This is the structure of most recurring food safety problems: not absent standards, not insufficient commitment, but a mismatch between where the response is directed and where the condition actually originates. The organization had a functioning program and genuine investment in food safety outcomes, but neither were sufficient to stabilize a condition that lived upstream of where the program was looking. That gap between where the system looks and where the condition lives is precisely what the governance layer is responsible for closing, and precisely what the industry’s next conversation needs to address.

Food safety is one of the few functions in a business where this gap becomes consistently legible to both the people running the floor and the people running the business. A corrective action log read as a list of resolved tickets tells you how responsive the system is. The same log read as a transcript of what keeps coming back tells you something different — which areas generate repeated entries, which responses cycle through without producing stability, which categories of work the organization has learned to absorb as routine rather than resolve at the source. That second reading requires treating the pattern across entries as more informative than any individual entry, and asking what organizational conditions would have to be true for this pattern to keep generating itself. The data to answer that question already exists in most operations. What’s needed is the orientation to read it at the right level — one that connects what operators see on the floor to the decisions that executives are positioned to change.

The layer that determines whether those conditions get addressed is not the technical program layer. Everything built over the last fifteen years — the controls, the monitoring, the documentation infrastructure — operates within conditions established further upstream: in how decisions get made about work design and resource allocation, in how authority is distributed and what happens when it’s exercised under pressure, in how competing priorities get resolved when production demands and safety requirements arrive at the same moment. Those decisions, and the organizational structures that make them, are what food safety outcomes are actually built on. When that structure is coherent, the technical programs beneath it tend to function as designed. When it isn’t, those programs compensate by absorbing strain, generating more corrective activity, and requiring more verification while the conditions producing that activity remain in place.

Reading the pattern accurately means asking questions at the right level of the system, not about the procedure that was missed or the person who was present. What decisions and structures established the conditions those people were working within? That inquiry moves the conversation out of the technical program and into the business itself: into how the organization is structured to make and carry decisions under ordinary operational pressure, and whether that structure is coherent enough to support the systems that depend on it. What it costs when it isn’t (corrective cycles, absorbed inefficiency, work that keeps having to be done twice) is where the stakes become most visible to leadership, and most familiar to the people closest to the work.

Big data

AI Is Becoming a Practical Food Safety Equalizer for Small and Mid Sized Manufacturers

By Matthew Kang
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Big data

For small and mid sized food manufacturers, the real food safety challenge is often not the absence of programs. It is the difficulty of executing them consistently with limited people, limited time, and limited system support. AI does not replace food safety culture, trained employees, or management accountability. What it can do is reduce documentation drag, connect fragmented records, and give small plants better visibility into the daily factors that affect both compliance and performance.

Most small food plants already have some version of HACCP, sanitation procedures, allergen controls, supplier documentation, and corrective action forms. On paper, the structure exists. The problem is that these programs often live in separate places. Some information is in handwritten logs. Some is in Excel files. Some sits in email trails. Some remains in the memory of one or two experienced employees. In a large company, those gaps are often absorbed by specialized teams. In a 20 person plant, they become part of the day’s friction. USDA FSIS guidance for small and very small establishments reflects that reality by offering practical compliance guidance for smaller operations rather than assuming large company infrastructure.¹ ²

That is one reason AI matters. Not because it is futuristic, but because small food companies and facilities need tools that help them execute what they are already supposed to be doing.

FDA’s Food Traceability Final Rule makes that challenge even more visible. For foods on the Food Traceability List, firms are expected to maintain linked records around Critical Tracking Events and Key Data Elements so food can be identified and removed from the market more quickly when necessary. FDA has also said that, under current law, it does not intend to enforce the rule before July 20, 2028.³ ⁴

I did not introduce AI as a food safety system. At first, I was simply trying to make our ordinary plant records easier to use. What surprised me was how quickly those same operating records turned into food safety records once they were organized properly.

The first and most important use case was the daily production report.

A typical report includes labor hours, raw material use, number of batches, yield, run time, and overhead assumptions. But what makes that report valuable is the context around the numbers. A forming machine goes down and creates a one hour delay. A new operator joins the line and throughput drops. A raw material lot arrives with inconsistent quality and forces rework or a change in handling. Before AI, those details usually existed as loose comments. They were written down, but not really used.

That changed once we started combining the numbers and the narrative in one place. After a few weeks, I started noticing which problems were truly random and which ones kept coming back. A yield problem was not always just a yield problem. Sometimes it pointed to operator inconsistency. Sometimes it pointed to equipment instability. Sometimes it started with raw material quality. In a small plant, those issues do not stay in their own lane. They spill into sanitation timing, rushed handling, delayed changeovers, and rework decisions. That is when I realized AI was doing more than saving time. It was helping us see operational patterns we had been living with but not fully recognizing.

A second use case involved incoming raw materials.

In a small food company or facility, receiving is one of the most important control points, but also one of the easiest places for information to become fragmented. We began using simple photo capture of ingredient statements and specification sheets to pull out allergen information, compare those ingredients against non allergen counterparts, and flag price changes. If a supplier raised a price or changed a formulation, that information could be reflected back into costing and into the same day’s production analysis.

This mattered more than I expected. In the past, allergen characteristics, lot information, and pricing changes could all be reviewed by different people at different times. That made it too easy for something important to be noticed late. Once those pieces were pulled together, receiving became much more useful as an early warning point instead of just a paperwork step.

A third application involved process data and compliance follow through.

Post process data logger outputs, for example, became more useful when we reviewed them for patterns instead of as isolated records. If a cooling trend began to drift or a cook step started landing too close to the lower end of a target range, we could see it earlier. The same logic applied when a USDA or FSIS noncompliance record was issued. What used to require digging through prior records, emails, and deadlines could be organized into a more structured workflow. That did not remove the need for qualified review. It still required human judgment and human sign off. But it cut down the time spent assembling information that already existed in scattered places.

Monthly closing and costing created another layer of value. By comparing accounting data with production report trends, it became easier to see whether a margin decline was being driven by labor inefficiency, unstable yield, supplier inflation, or poor scheduling. In a small plant, food safety discipline and operational discipline are closely tied together. Rework, spoilage, excessive changeovers, and weak lot visibility are cost problems. They are also signals of weak execution. Once those signals become visible earlier, management decisions improve.

Production scheduling turned out to be one of the clearest examples of AI’s practical value. In a small facility, the best schedule is not simply the one that fills the day. It is the one that balances labor availability, sanitation windows, equipment uptime, maintenance timing, raw material readiness, and product mix. We began reviewing historical combinations of labor, line setup, batch sequence, and uptime that had previously produced stronger margins and smoother runs. It was not perfect. But it did stop us from planning only by instinct.

That also created a sustainability benefit. Better schedules can reduce avoidable changeovers, overproduction, product loss, and inefficient use of labor and energy. For small plants, sustainability does not begin with a polished ESG report. It begins with running a tighter operation. When inventory is more visible, fewer ingredients expire unnoticed. When schedules are better sequenced, fewer unnecessary runs are made. When traceability is better structured, edible surplus is easier to identify and donate instead of discard. In California, where edible food recovery and organic waste diversion obligations under SB 1383 are part of the operating landscape, those improvements are not abstract. They can affect whether product is simply written off or handled more responsibly.⁹

None of this means AI should be treated casually.

The stronger its role becomes, the more important governance becomes. That is why the NIST AI Risk Management Framework is useful even though it is not a food law. It gives smaller organizations a practical framework for thinking about trustworthiness, transparency, validation, human oversight, and risk management. Published as NIST AI 100-1 in January 2023, it was developed under the National Artificial Intelligence Initiative Act of 2020 and is voluntary, non sector specific, and broadly applicable across sectors.⁸

For a small food company or facility, that does not require a long policy manual. It does require a few clear rules. Which decisions require human sign off. Which records are AI assisted but still human verified. How outputs are checked against current FDA regulations, USDA FSIS guidance, customer requirements, and plant procedures. What data may be uploaded into external tools, and by whom. These questions matter because AI can produce text that sounds authoritative even when it is wrong. In food safety, that is not a minor issue. It is a governance issue.

The same caution applies to digital records. FDA’s Part 11 guidance makes clear that electronic records used in regulated settings remain subject to the applicable predicate rules.⁵ USDA FSIS has also made clear that electronic monitoring and recording records may be used to satisfy HACCP, sanitation, and related requirements, and that electronic records are treated the same as paper records.⁶ ⁷

The food safety world often talks in terms of programs, plans, and frameworks. Those matter. But in small and mid sized manufacturing, the real test is whether those systems can still be executed on an ordinary Tuesday while labor is tight, equipment is acting up, and a late shipment has already disrupted the day. That is where food safety often breaks down. Not in theory, but in execution.

That is why I see AI less as a replacement for expertise and more as a practical equalizer. In a 20 person plant, it can create better visibility, better consistency, and better follow through than the staffing level would otherwise allow.

References

¹ U.S. Department of Agriculture, Food Safety and Inspection Service. Small & Very Small Plant Guidance.
² U.S. Department of Agriculture, Food Safety and Inspection Service. HACCP Guidance. Last updated Jan. 12, 2022.
³ U.S. Food and Drug Administration. FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods.
⁴ U.S. Food and Drug Administration. Food Traceability List.
⁵ U.S. Food and Drug Administration. Part 11, Electronic Records; Electronic Signatures — Scope and Application. Guidance for Industry. September 2003.
⁶ U.S. Department of Agriculture, Food Safety and Inspection Service. Verifying Video or Other Electronic Monitoring Records. FSIS Directive 5000.9. Aug. 26, 2011.
⁷ U.S. Department of Agriculture, Food Safety and Inspection Service. Compliance Guidelines for Use of Video or Other Electronic Monitoring or Recording Equipment in Federally Inspected Establishments. Guideline ID FSIS-GD-2011-0001. August 2011.
⁸ National Institute of Standards and Technology. Artificial Intelligence Risk Management Framework (AI RMF 1.0). NIST AI 100-1. Jan. 26, 2023.
⁹ California Department of Resources Recycling and Recovery. Food Recovery Questions and Answers.

Collaboration Graphic

The Missing Layer in Food Safety Systems

By Azure Edwards, M.S.
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Collaboration Graphic

Food safety systems are often evaluated through the strength of their technical programs. Organizations invest heavily in preventive controls, environmental monitoring, supplier verification, and documentation systems designed to demonstrate regulatory compliance.

Yet many companies still encounter instability in their food safety programs, even when the required systems appear to be in place.

  • Corrective actions repeat.
  • Audit findings reappear across facilities.
  • Operational practices vary from site to site.

When these patterns emerge, the instinct is often to add more documentation, training, or oversight. But in many cases the issue is not the absence of technical controls. It is the absence of a stable governance structure capable of translating safety expectations into consistent operational practice.

Understanding this governance layer can help explain why food safety systems sometimes struggle to stabilize as organizations grow.

Signals of Governance Instability

When governance structures are underdeveloped, organizations often experience recognizable patterns. Food safety programs may appear complete on paper, yet operational stability remains difficult to achieve. Common signals include:

  • corrective actions addressing the same underlying issues repeatedly
  • compliance programs dependent on specific individuals rather than system design
  • inconsistent practices across facilities, shifts, or teams
  • unclear authority for safety-related decisions

  • reactive responses to audits or inspections

These patterns are often interpreted as training gaps, communication problems, or culture challenges. In many cases, however, they reflect a deeper issue: the governance structures required to translate food safety expectations into consistent operational practice were never fully established.

Governance Exists Before Compliance

As food businesses expand, they move through stages of increasing regulatory oversight. A cottage food operation may manage safety practices informally. Licensed commercial kitchens introduce sanitation programs and basic documentation. Commercial manufacturers implement preventive controls, monitoring systems, and structured records. Enterprise operations standardize these systems across facilities and supply chains.

At each stage, regulatory expectations become more visible and formalized. However, the underlying conditions required to produce safe food do not begin with regulation. They exist before it.

Regulatory frameworks primarily make those conditions observable and enforceable. When organizations grow quickly or transition between operational stages, regulatory oversight often reveals governance structures that were never fully developed.

Common symptoms include fragmented compliance programs, inconsistent operational practices, reliance on individual expertise rather than system design, and reactive responses to audits or inspections.

Organizations frequently respond by expanding documentation requirements or implementing additional procedures. While these interventions can address immediate gaps, they may not resolve the deeper governance instability beneath them.

The Structural Conditions of Safe Food Production

Across all scales of food production, stable food safety governance depends on several core conditions.

  1. The decision authority for safety must be clear. Food safety decisions must be anchored in identifiable operational authority. When responsibility is diffuse or ambiguous, operational decisions may drift away from safety expectations.
  2. Organizations must maintain visibility into where hazards and contamination risks can occur across processes, materials, and the operational environment. This awareness forms the foundation for preventive control strategies.
  3. Operational practices must exist to prevent contamination and control risk. These practices may appear as formal procedures, sanitation programs, or routine operational behaviors embedded in daily work.
  4. Organizations must manage suppliers and external inputs intentionally. Ingredients, packaging materials, and outsourced processes introduce variability into the production system and require structured oversight.
  5. Systems must exist to detect deviations and respond consistently. Monitoring, verification, and escalation mechanisms allow organizations to identify when conditions diverge from expected standards and ensure that appropriate responses occur.
  6. Organizations must maintain records sufficient to demonstrate control. Documentation provides traceability, accountability, and evidence that governance systems function as intended.

These structural conditions exist before audits, certifications, or inspections. Regulatory frameworks formalize and observe them, but they do not originate from those frameworks.

The architecture of food safety governance remains relatively consistent across organizations of different sizes. What changes with scale is how visible and distributed that architecture becomes.

In early-stage operations, governance conditions are often implicit. Safety decisions are managed directly by founders or operators who maintain personal oversight of production activities. As organizations grow, responsibilities become distributed across teams and departments. Preventive control programs become formalized, and operational systems become more structured.

Instability often occurs during these transitions. Oversight mechanisms such as inspections, customer requirements, or certification audits rarely introduce entirely new expectations. Instead, they expose structural conditions that were already necessary but not previously formalized.

Organizations may then attempt to compensate by layering additional documentation or procedures onto an unstable governance foundation. Without addressing the structural layer beneath those programs, stability can remain difficult to achieve.

The Orientation Challenge

Even when organizations recognize the structural elements required for safe food production, another challenge remains: interpreting operational complexity in a way that allows those structures to be built coherently.

Food safety systems operate within sociotechnical environments where technical programs, operational realities, leadership decisions, and human behavior interact continuously.

Attempts to correct one domain without addressing the others often produce temporary or fragile improvements.

Stable systems require an orientation that helps organizations interpret how these elements interact and translate them into coherent governance structures. In practical terms, this means understanding where safety-related decisions are actually made and how risk signals move through the organization. When those pathways are unclear, even well-designed technical programs can struggle to function consistently.

This orientation exists upstream of technical program design. It shapes how organizations interpret regulatory expectations, operational constraints, and risk signals before specific programs are implemented.

Building Systems That Can Endure

Reliable food safety systems must function under ordinary operational conditions. They must withstand staffing changes, production pressure, operational growth, and the variability of real manufacturing environments.

Systems that depend on exceptional individuals or constant intervention tend to degrade over time. Durability emerges when governance structures provide:

  • clear operational priorities
  • defined decision authority
  • consistent escalation pathways

  • shared understanding of risk

When these elements are present, technical programs can operate as intended. When they are absent, organizations often rely on documentation, enforcement, or external oversight to compensate for deeper structural ambiguity.

Seeing the System Clearly

Food safety governance ultimately involves more than compliance or technical expertise. It requires organizational structures capable of translating risk awareness into coherent operational practice.

When organizations understand the structural conditions required for safe food production—and the reasoning patterns that allow those conditions to be built—technical programs become more stable and scalable.

Rather than introducing new requirements, this perspective helps make visible the governance realities that have always existed within safe food production.

Once visible, those structures can be developed deliberately, supporting food safety systems that remain stable even as organizations grow and operational complexity increases.

References

  1. Codex Alimentarius Commission. General Principles of Food Hygiene CXC 1-1969. FAO/WHO.

  2. U.S. Food and Drug Administration. FSMA Final Rule for Preventive Controls for Human Food. FDA.

  3. GFSI. A Culture of Food Safety: A Position Paper from the Global Food Safety Initiative. 2018.