Change and continuous improvement go hand in hand. Any continuous improvement journey is just that—a journey, not an endpoint; it’s a process to get to a better place. Successful operations constantly change to meet the evolving needs of the business and its stakeholders. But change can provide lots of speed bumps, roadblocks and yield signs if not managed from a positive perspective. Consider that faster is not always better—simplicity is usually the best way to get from point A to point B. Here are a few helpful hints to help you manage the change that accompanies continuous improvement.
Realize that all things can be improved upon. Whether the improvement is a minor tweak or a major overhaul, objective vision is a must to maintain momentum.
Collection of baseline data is important. Data-driven decisions will provide a road map for improvement with the right direction, use of good data and careful interpretation.
Measuring the result of any change will either validate your assumptions or provide a pivot point for moving in a new direction.
Failure to continually improve is the same as standing still. Don’t let road blocks stop your progress.
Sometimes the smallest improvements yield the best results. Fine tuning doesn’t have to be a massive undertaking. Don’t be afraid to keep it simple.
Change is inevitable, so embrace it. Become an advocate for change through leadership and a positive attitude. Others will follow.
Programs that are improved over time will not be taken for granted. Antiquated processes provide diminishing returns, grow stale, and become extinct quickly.
Involve all stakeholders in continuous improvement efforts. Getting upfront buy-in instills pride of ownership and helps to ensure success.
Train for all changes—whether on the plant floor or an office business process. Up-to-date training is imperative, because adults are creatures of habit. Set your continuous improvement efforts up for success by ensuring that changes have been communicated and reinforced.
Just as in life, effective programs, procedures, and policies are journeys, not destinations. Keeping the journey from becoming an uphill struggle requires a culture of continuous improvement—and a company-wide willingness to embrace change.
The Sanitary Transportation of Human and Animal Food rule goes into effect June 6, 2016. Large businesses must comply by April 6, 2017; small businesses must comply by April 6, 2018. The rule governs the protection of food during transport, including the sanitation of transport vehicles and equipment, refrigeration of food for safety, and proper cleaning of bulk transport vehicles between loads. So you’ll need a game plan…but what should your game plan include?
Read the rule—every word of it—to understand the reasoning behind the decisions made in crafting it and to get a glimpse into how it will be regulated and enforced.
Review all of your processes, protocols, procedures, and contracts to ensure compliance with the rule, and outline responsibility for how you’ll manage the safe transportation of food.
Close any gaps in your current programs to ensure you’ll meet the regulations well in advance of the compliance date.
Kick the tires by conducting mock inspections. Find non-compliances and give yourself time to correct them, rather than wait for bad news during a real inspection.
Confirm the accuracy of all your documentation on a regular basis. Documentation can be the difference between success and failure when it comes to proving that you’re doing the right things.
Get all stakeholders on board to empower employees at all levels and drive culture change.
Establish a driver training program to ensure compliance with the Sanitary Transport rule. Image courtesy of Alchemy Systems (Click to enlarge)
Use Driver Training to Prepare
Drivers are the conductors of the food supply chain. They literally have loads of responsibilities, including maintaining the cold chain, meeting delivery requirements, practicing safe driving always, and meeting all Department of Transportation regulations and requirements. Whether transporting raw materials, packaging, work-in-progress, or finished goods, drivers are the people that keep food safe in transit. So how can you take advantage of your driver training program to ensure compliance with the Sanitary Transport rule?
A blended learning strategy, combining online and instructor-led training, has been shown to provide the best food safety training outcomes.
Use online lessons to introduce and reinforce knowledge of new FSMA regulations and food safety awareness topics. Digital lessons are economical, learner-paced, provide consistent messaging, and are accessible 24/7.
Use hands-on direct instruction for refreshers or for topics like proper vehicle inspections, reefer unit checks, cargo securement, etc.
Subject matter experts should conduct any instructor-led training using a skills check-off approach to document driver’s abilities and to ensure that drivers perform to standard.
Group and prioritize drivers for training based on their compliance history.
Use online lessons and safety messaging proactively to sustain driver compliance and performance.
Use online training at least quarterly, but use safety messaging monthly. Drivers, like all learners, need regular reminders in order to break old habits and form new ones. Communications programs can provide multi-touchpoints to reinforce new knowledge, shift behaviors, and help ensure compliance.
Put Your Game Plan Into Action
The Sanitary Transport Rule is a reality. Now is the time to put written procedures and protocols in place and make sure all stakeholders have a clear understanding of them. Determine precisely who has responsibility for compliance throughout the distribution channels. A blend of online and face-to-face training will ensure compliance, increase performance, and protect foods during transportation operations. The benefits far outweigh the cost.
Most recently we have seen an increase in foodborne illness outbreaks from Listeria to Salmonella to Norovirus to E.coli, many of which are a result of post-lethal contamination of processed foods. This is often a direct result of a gap in the sanitation programs that were in place at the processing facilities. Every facility should conduct a sanitation gap analysis on an annual basis. In order to receive unbiased feedback, this activity is best performed by a third party that is not a chemical provider.
Join Gina Kramer at the Listeria Detection & Control Workshop, May 31–June 1 in St. Paul, MN | LEARN MOREDeveloping and implementing a sound environmental hygiene program at a food processing facility is essential to its success in producing safe food for consumer consumption. There are fundamental basics of sanitation that every plant must follow in developing a strong program. The fundamental basics include: Developing sanitation standard operating procedures (SSOPs) for; Floors and drains, walls, ceilings, equipment and utensils, and employees. SSOPs must also contain perimeter control, foot traffic control into food preparation areas, zoning, and environmental sampling procedures.
VIDEO: Jeff Mitchell and Gina Kramer discuss the increase in Listeria recalls. | WATCH NOW
When developing SSOPs, using the proper risk reduction formula will lead to sanitation success. To determine the best risk reduction formula, I sought the advice of sanitation expert, Jeff Mitchell, vice president of food safety at Chemstar. Before working for Chemstar, Mitchell was the Command Food Safety Officer for the United States Department of Defense (DOD). Serving more than 20 years for the DOD has given him the opportunity to visit thousands of processing facilities all over the world, seeing the best and the worst, and assisting in finding the root cause of contamination issues and negative environmental sampling results. In this article, I share Mitchell’s risk reduction formula for sanitation success and how to use the formula to build a solid and successful sanitation program.
Foundational Science
“An understanding of the difference between transient and persistent (or resident) pathogens is a key part in the foundational science of sanitation solutions,” explained Mitchell as we discussed the details of the risk reduction formula. Transient pathogens are those that are introduced to the processing facility from the external environment. Entrance occurs from deliveries on transportation vehicles and pallets, food, and non-food products and its packaging, employees and visitors, pests and rodents, along with leaks in the roof or improper cleaning of drains, which are known reservoirs.
“Persistent pathogens are those pathogens that establish residency within the processing facility. Most bacteria will aggregate within a biofilm, allowing them to live in communities. A biofilm is a survival mode for the bacteria; it protects it from sanitizer penetration. The biofilm layers actually masks it from sampling detection. You could swab a surface or an area and not get a positive pathogen test result, because the biofilm is masking it,” Mitchell stated. He continued to explain that most contamination risks are likely from established populations. Four things need to exist for resident populations to form: Pathogen introduction, water, trace organics and niche area for attachment and growth. Food processing facilities should be most concerned about these populations, as they’re being traced to many recent outbreaks and recalls.
In his experience, Mitchell shared that sanitation efforts should focus on areas within the processing facility where moisture and nutrients are collected; both are needed for biofilm formation. Disruption of these niche areas containing biofilm can result in direct (food contact) and indirect (non-food contact) contamination if the biofilm is not completely penetrated or removed. This can occur through active and passive dispersal of pathogens. Active dispersal refers to mechanisms that are initiated by the bacteria themselves where they naturally eject from the biofilm and land on other surfaces. Passive dispersal refers to biofilm cell detachment that is mediated by external forces that shear the biofilm, causing it to move and further spread. This can be caused through fluid shear, abrasion and/or vibration due to power washing, equipment vibration, or deep cleaning/scrubbing that does not penetrate and remove all the aggregate layers of biofilm. In other words, the biofilm and pathogens are just smeared around the facility like cleaning a mirror with a greasy wiping cloth.
Chemistry and Application
The cleaning matrix must be considered to properly remove soils that house both transient and persistent pathogens. This is done by combining proper cleaning and sanitizing agent concentration (PPM), adequate exposure time, proper temperature and mechanical action (agitation) or good old elbow grease. If there is a decrease in one area of the matrix, then an increase in the other areas needs to be made as an accommodation to the cleaning process. My years working in industry have taught me that the most expensive quadrant of the cleaning matrix is agitation, because it requires manual labor. Reduction of labor is one of the first ways companies build in efficiencies to increase profit margins. That means a solution must be built that focuses on temperature, concentration and proper contact time to produce the sanitation results necessary to prevent persistent pathogens from establishing residency within processing facilities.
Temperature should be regulated by the type of soils that need to be removed. High fat soils need a higher temperature of about 140⁰ F. However, when removing high protein soils, the temperature needs to be reduced so that the protein is not baked onto the surface. Baked proteins that are not removed become nutrients for bacteria to aggregate and reside. High temperature is does not work in every food processing plant, Jeff explained.
Proper balance of detergent and sanitizer is necessary to remove and destroy both transient and persistent pathogens. The detergent needs to be the right formulation and contact time to break down soils and biofilms with application of the right concentration and contact time of sanitizer to kill the exposed pathogens. Without the right balance in place it can create the perfect storm for spread and contamination within the processing facility.
Validation
Do your homework. Research is the most valuable tool when validating the effectiveness of a cleaning process. Private research is good but not the only form of validation on which to base a business decision. I have found that peer reviewed published research is best to use in validating all quadrants of the cleaning matrix. Academic research based on sound science that has practical application results is worth the investment to make sound business decisions.
Many products have been developed to penetrate and destroy the biofilm layers that bacteria aggregate. Again, do your homework. Choose a product that also provides a pathogen kill once the biofilm has been penetrated. I cannot stress enough to make sure that the SSOPs follow the manufacturer’s validated processes and the sanitation team follows the SSOPs’ directions.
Solution
Applying the desired solution requires dividing the processing facility into zones to designate specific sanitation requirements. This will assist in the development of specific SSOPs that apply the right solution in the right zone throughout the site.
Mitchell also gave great advice about cleaning tools and cleaning chemical basics. He explained that a facility should color code the cleaning tools according to zone and only use them in the designated zone area. This prevents cross contamination from occurring, because cleaning tools can be vehicles of contamination transfer. Utilize foam detergents and foam sanitizers as they are more forgiving and increase contact time, and sanitation crew can see where they have applied the chemicals. Use the Ross-Miles foam test for stability: Foam should last more than three minutes before breaking and turning into a liquid solution that runs down the drain, costing a site money and opening up the potential for introducing pathogens into production rooms.
Mitchell advised the development of sanitation procedures that focus on daily thorough cleaning of everything from the knees down in Zones 1-3. “You want to knock everything down and keep it down. The objective is to keep bacterial creep from occurring,” he said. “Creep is where bacteria are moved by processes like water spray, splash and aerosolization, causing the bacteria to move from one area (it usually develops on the floor) to then move up walls and the legs of equipment, etc.— eventually causing contamination of food during food production and packaging.” Obviously, all food contact surfaces in Zone 1 need to have specialized SSOPs according to the equipment, food processing shifts per day, and type of foods that are being processed.
Mitchell stressed that perimeter and foot traffic control entry programs should incorporate a good foam sanitizer that stands up to the Ross-Miles test with optimal duration of five minutes. The distribution of the foam should cover a large enough area that the employees’ foot path and equipment must travel through the foam to achieve contact to control transient pathogen entrance into Zones 1–3. Concentration levels of these areas should be at least double what the food contact area strength is for effectiveness of log kill needed for control.
Environmental monitoring procedures should follow the zoning process set up for sanitation. “Swabbing for Adenosine Triphosphate (ATP) and/or Aerobic plate count (APC) are tools that can be used to help identify biofilm locations. One thing to note is that the bacteria located under the biofilm are in a modified dormant state requiring less energy and making less ATP available for detection. With that said, ATP and APC swabbing are still both viable tools to use in sanitation verification,” said Mitchell. If you only test for general risk pathogens in your facility you may receive false negatives due to biofilm masking the pathogen from showing up as a positive in environmental testing. Utilizing both general pathogen, ATP and APC in concert, is the best combination in a facility’s environmental monitoring program. The goal is to seek and find then destroy and verify.
I recently discovered a great biofilm visual detection test from Realzyme that is wonderful to use to verify whether the sanitation system in place is working. It can also differentiate between protein build-up and biofilm formation. In my professional opinion, this visual detection test is essential to incorporate in a robust environmental testing system.
Safe Food: The End Product
Our responsibility as food safety/quality professionals is to provide the safest, most delicious food for our customers to enjoy. To ensure safe food in our end product, we need to develop a robust sanitation and environmental testing program that follows the risk reduction formula (Foundational Science + Chemistry & Application + Validation = Solution) and conduct an annual sanitation gap analysis by a third-party expert for continuous improvements.
Apply these steps to protect your food, protect your brand and protect your customers so that they Savor Safe Food in every bite!
Food laboratories in the United States may voluntarily choose to become accredited to an international standard known as ISO/IEC 17025:2005. This standard outlines the general requirements for the competence of testing laboratories.
More recently, the FDA issued a final rule on the Accreditation of Third-Party Certification Bodies to Conduct Food Safety Audits and to Issue Certifications (Third-Party rule). Effective January 26, 2016, this final rule states that “for a regulatory audit, (when) sampling and analysis is conducted, the accredited third-party certification body must use a laboratory accredited in accordance with ISO/IEC 17025:2005 or another laboratory accreditation standard that provides at least a similar level of assurance in the validity and reliability of sampling methodologies, analytical methodologies, and analytical results.” In short, for a segment of food laboratories, accreditation has become a necessary credential. At present, it remains a voluntary activity for most food laboratories.
There are accreditation bodies that accredit food laboratories to the ISO/IEC 17025 standard. The major accreditation bodies report on their individual websites which U.S. food laboratories are accredited under their watch.
To find the number of accredited laboratories, a quick search of the websites of four major food laboratory accreditation bodies, A2LA (American Association for Laboratory Accreditation), AIHA-LAP (American Industrial Hygiene Association – Laboratory Accreditation Programs, LLC), ANAB (American National Standards Institute-American Society for Quality), and PJLA (Perry Johnson Laboratory Accreditation) was performed on February 24, 2016. It yielded some debatable results. Here are some of the reasons for the skepticism:
The numbers are self-posted to individual websites. The frequency with which these websites are reviewed or updated is unknown.
Sites list both domestic and international laboratories. While foreign addresses were excluded from the count, those laboratories could perform testing for U.S. entities.
It can be difficult to separate the names of laboratories performing testing on human food versus animal feed.
There are several ways to duplicate or even exclude numbers. As examples, laboratories may be accredited within a food testing program, but may also be accredited under “biological” and/or “chemical” schemes—or vice versa.
In some cases, it is difficult to discern from the listings which laboratories are accredited for food testing versus environmental or pharmaceutical testing.
With all these caveats, the four major laboratory accreditation bodies accredit approximately 300 food laboratories. A2LA captures the lion’s share of this overall number with approximately 200 laboratories.
Let’s move to another source of numbers. A Food Safety News article about food testing and accreditation published in October 2013 states:
But, when it comes to testing our food, experts estimate that less than five percent of the food testing laboratories in the U.S. are accredited according to international standards…
Some believe that FDA will begin requiring accreditation for at least some significant segment of the food testing industry, of which the U.S. has roughly 25,000 laboratories. Whether that’s restricted to third-party labs – numbering roughly 5,000 – or will also include all food manufacturers’ internal labs is yet to be seen.
Using the writer’s sources, simple arithmetic finds 25,000 laboratories multiplied by the estimated 5% accreditation equals roughly 1,250 accredited laboratories in the United States. This, of course, falls far short of the 300 accredited laboratories noted by the major accreditation bodies. This is not to question either the writer’s sources or the websites of the accreditation bodies, but it does highlight an inconsistency in how we account for the laboratories testing our food.
To go a step further, Auburn Health Strategies produced in 2015, a survey of food laboratory directors, technical supervisors and quality assurance managers on the state of food testing. The survey, commissioned by Microbiologics, asked a series of questions, including: “Are the laboratories you use accredited?” The respondents replied that, for their on-site laboratories, 42% were accredited and 58% were not. For their outside, contract laboratories, 90% of respondents stated that these laboratories were accredited and five percent did not know.
A second question asked: “Some laboratories are accredited to an internationally-recognized standard known as ISO 17025. Is this important to you?” Approximately 77% of respondents answered affirmatively. Equally telling, 15% said they did not know or were unsure.
What we do know is that there is not a definitive accounting of food laboratories—accredited or not. This lack of accounting can present very real problems. For example, we do not have a centralized way of determining if a particular laboratory has deficiencies in testing practices or if its accreditation has been revoked. Without knowing where and by whom testing is conducted, we are at a disadvantage in developing nationwide systems for tracking foodborne disease outbreaks and notifying laboratory professionals of emerging pathogens. We most certainly do not know if all food laboratories are following recognized testing methods and standards that affect the food we all consume.
What We Need Now
FSMA includes a provision calling for the establishment of a public registry of accreditation bodies recognized by the Secretary of Health and Human Services. The registry would also contain the laboratories accredited by such recognized organizations. The name and contact information for these laboratories and accreditation bodies would be incorporated into the registry. Rules for the registry have not yet been promulgated by the FDA, but should be. This is a small step toward greater accountability.
Implementation of FSMA will result in greater scrutiny of foreign material in food products at every stage of production, as well an entirely new pressure to locate and eliminate the source of contamination from the supply and production chain. Identifying foreign materials found in food products is the first step in determining their source, and therefore in determining how to prevent a given foreign material from being introduced into the product. For identification of small particles ranging from 1–1000 µm, microanalytical techniques are essential.
Examining and Isolating Foreign Material
Before the foreign material is prepared for analysis, the material is examined under a stereomicroscope. Ideally, isolation of the foreign particles from the host matrix and preparation of the foreign particles for microanalysis is performed in a cleanroom, which mitigates the introduction of environmental contamination not related to the initial contamination problem.
Figure 1. Particles filtered from a liquid product.
Under the stereoscope, the foreign material is isolated from the product matrix using a tungsten needle probe. It is photographed and the physical characteristics of the material (color, elasticity, magnetic properties, etc.) are observed and documented. Figure 1 shows particles filtered from a liquid product. In this case, the particles are approximately 100 μm and smaller. Most of the particles appear black to dark brown/orange in color. Some are brittle, while others are not. All are magnet responsive.
Only a few particles must be picked and prepared for analysis in this case because the particles are roughly similar. The coloration of the particles, along with their mechanical properties (magnetic, brittle, hard) indicate that the material is likely inorganic; scanning electron microscopy with energy dispersive X-ray microspectrometry (SEM-EDS) could be used to determine the elemental makeup of the material. The coloration and mechanical properties imply the source of the particles could be production machinery.
Figure 2 (click to enlarge)
Identifying Inorganic Compounds with SEM-EDS
In a scanning electron microscope, a beam of electrons is scanned over the particle producing several signals, some of which are used for imaging, and some that are used for elemental analysis. For this discussion, the signals of interest for elemental analysis are X-rays. The energies of the X-rays are characteristic of the elements found in the sample. By counting these X-rays and arranging them according to their energies, a spectrum is produced, and elements in the sample can be identified and quantified.
Figure 3 (click to enlarge)
Figures 2 and 3 are SEM-EDS data from one of the brittle particles from the filter. The particle is steel corrosion (iron, chromium, and nickel), possibly with brass corrosion (copper and zinc) and some silicate material (elevated silicon and aluminum). Residues of corrosive agents (chlorine and sulfur) are present. The inclusions analyzed are 300 series stainless steel (see Figure 2). SEM-EDS data from one of the harder dark particles is shown in Figure 4. This particle is oxidized 300 series stainless steel, likely Type 316. 300 series stainless steels are not generally magnetic, but magnetism can be induced during wear processes.
Figure 4. SEM-EDS data from harder dark particles. (click to enlarge)
Stainless steels, particularly Type 304 and Type 316 are common in food manufacturing environments. Pinpointing the source of these materials as contaminants can be frustrating due to the number of pieces of equipment made from these alloys. However, other metals are less common, such as Waukesha 88, a bismuth containing nickel-based alloy that is used in pump rotors and other moving parts because of its wear properties. Another less-common alloy is Type 321 stainless steel, a titanium stabilized stainless steel that is used in high temperature equipment where corrosion resistance is needed. Materials such as these are more easily traceable to their source, and therefore more easily repaired and thus eliminated as a source of foreign particles.
Figure 5. Glass particle. (click to enlarge)
Other inorganic materials, such as glass, are also amenable to identification by SEM/EDS. SEM-EDS data from a glass particle is shown in Figure 5. Often, the glass can be identified as soda-lime glass or borosilicate glass. Soda-lime glass is commonly used for glass containers and bakeware; it is a mixture of oxides, mostly silicon dioxide, sodium oxide, and calcium oxide with smaller amounts of other oxide compounds. Borosilicate glass, commonly used in heat-resistant labware, contains silicon dioxide with a few weight percent boron trioxide, along with other oxide compounds; its composition results in a low coefficient of thermal expansion, and it is used in applications where its chemical and heat resistance are necessary. Identifying the glass type is helpful in determining the source of glass particles.
Figure 6. Reference spectrum for Viton. (click to enlarge)
The SEM-EDS method cannot uniquely identify organic compounds, as it provides only elemental information—an EDS spectrum of organic material shows major carbon, and if it is degraded, oxygen. Protein will contain nitrogen as well.
Figure 7. Cellulose IR spectrum. (click to enlarge)
FTIR analysis can identify most organic and a few inorganic materials. For small particles, micro-FTIR (an FTIR system with a microscope coupled to it) is used. Micro-FTIR analysis requires that the sample be thin enough to transmit light, since the system passes a beam of infrared radiation through the sample and records the frequencies at which the sample absorbs infrared radiation. The spectrum from a given material is unique, and even mixtures of materials can often be identified by comparison to known spectra from a reference library using an automated computer search.
Figure 8. Cardboard IR spectrum. (click to enlarge)
In this way, organic materials such as Viton O-rings can be identified (Figure 6 is a reference spectrum for Viton). Other organic material may be present in the product, such as cellulose (see Figure 7) or cardboard (see Figure 8). While these materials are not dangerous as small particles, they are not desirable in food products. When these kinds of things are found, tracing them to their source may be simple (as in the case of the O-ring material) or hard (cellulose can come from paper or cotton clothing, for example).
If the organic material found has inorganic fillers like titanium dioxide or silicon dioxide, then SEM-EDS can be used in concert with the micro-FTIR to refine the material description and simplify the process of identifying the source of the foreign material.
When used in tandem, SEM-EDS to identify inorganic materials and micro-FTIR to identify organic materials can be powerful tools for determining the origin of foreign particles. These microanalysis methods are essential tools for identifying and tracing the source of contaminant particles in food.
All seven core rules of FSMA require general training of individuals or employees and qualified individuals requiring education, training or experience to perform specific tasks. By including training in these regulations, the FDA has made specific training mandatory.
Training Required by FSMA Final Rules
In the current Good Manufacturing Practices (cGMP) and preventive control rules, as per 21 CFR 117.4 and 507.4, all individuals engaged in the manufacturing, processing, packing and holding of food must have the education, training or experience to perform assigned duties and must be trained in the principles of food hygiene and food safety. However, the preventive controls qualified individual (PCQI) and qualified auditor, to rules 21 CFR 117.180 and 507.53, can be an individual who has successfully completed a class equivalent in curriculum to that recognized by the FDA, or have the necessary job experience. In both cases, the training must be documented, including the date of training, type of training and those personnel trained.
This means that all employees are to be trained in food hygiene and food safety to at least the standard presented in the regulations and more specifically as per the cGMP requirements. Additionally, individuals who are responsible for a specific critical control point will still need to be trained in HACCP. However, this will probably not be sufficient for an employee responsible for preventive control, as he or she may require training in Hazard Analysis Risk-Based Preventive Control (HARPC), or training specific to the area in which the employee is involved (e.g., allergens, sanitation, supply chain or recall programs, or preventive controls).
For the preventive control qualified individual and qualified auditor, the training needed may be that of the approved FDA curriculum, as developed by the Food Safety Preventive Control Alliance (FSPCA). Although this training course is not a regulatory requirement, FDA inspectors and other regulatory personnel who are auditing facilities will have completed this training, meaning qualified auditors will be expected to have this training, and eventually preventive controls qualified individuals (PCQIs) will be expected to do so too. The qualified auditor and a PCQI will still require the education, experience and other training to perform the specific job duties as listed in the regulations. Unfortunately, it is likely that neither the industry nor the government will have enough lead instructors ready to train everyone who would want or need to be trained before the compliance dates become effective. Additionally, this training course is not yet available for animal food, and the industry has been informed by FSPCA that a Foreign Supplier Verification Program (FSVP) training module will be added to the training course. The FSVP is discussed in the Supply-Chain Preventive Control module, and the fact that there are some similarities between these regulations helps individuals involved in the FSVP program, or in auditing it.
In the produce safety rule, training requirements are listed in subpart C 21 CFR 112.21, 112.22, 112.23 and 112.30. Personnel who require training are those handling covered produce and their supervisors. As with the cGMP and preventive control rules, the principles of food hygiene and food safety must be taught to these personnel. More specifically they must learn how to identify an ill or infected person, and be taught about microorganisms of public health significance, such as Salmonella, Listeria and E. coli O157 on food contact surfaces. Additionally, personnel who harvest covered produce must be trained in recognizing produce that is contaminated with known or reasonably foreseeable hazards to ensure it isn’t harvested. These personnel must be trained in the use of harvest containers and equipment to ensure that they are functioning properly, clean and maintained, and to identify when they are not. At the same time, employees must be trained in correcting any issues or in reporting them to a supervisor in order to have them corrected. All this training must be documented in the same way as the cGMP and preventive control programs.
Unlike the cGMP and preventive control rules, the produce safety rule’s requirement to have a qualified individual, supervisor or responsible party on each farm that has completed a recognized FDA course, or equivalent, is not optional. This course will be available through the Produce Safety Alliance and is anticipated to start in September 2016. The grower food safety course required for supervisors will include an introduction to produce safety, worker health and hygiene training, soil amendments, wildlife, domestic animals and land use, agricultural water, post-harvest handling and sanitation, as well as how to develop a food safety plan.
The training for produce, conducted by the Produce Safety Alliance and/or trained trainers, does not cover training for sprouts; training for sprouts is being developed by the Sprout Safety Alliance and will include topics specifically for sprouts, such as antimicrobial treatment of sprouting seeds.
In the FSVP, the qualified individuals must have the education, training or experience necessary to perform activities as per 21 CFR 1.503. These qualified individuals will develop the FSVP and those activities such as hazard analysis, supplier approval, determining verification activities and frequency, corrective actions and other activities for the FSVP. These personnel must be able to read and understand the records to be reviewed for this program. This means they must know English and may also need to know the local language at point of product manufacture or farming.
At this time there is no structured training program for these individuals, but the FSPCA training program, alongside education and experience can provide the training necessary for these people to perform the job activities. A PCQI would be qualified for the role of a FSVP qualified individual, but the FSVP probably would not be qualified for the PCQI role. This is because the activities in the FSVP are not as complicated as those required by the cGMP and preventive controls rules, and therefore the FSVP qualifications would not need to be as stringent.
Training Under Proposed Rules
In the proposal for Sanitary Transportation of Human and Animal Foods, 21 CFR 1.910, the FDA requires carriers of these products to train personnel who are engaged in transportation operations. This should include awareness of potential food safety problems that may occur to food during transport, basic sanitary practices that would address those problems and the responsibilities of the carriers in the regulation. As with all training in these regulations, the type of training, who was trained and when they were trained must be documented.
Since this is a proposal, the training for teaching the carrier’s responsibility is not yet finalized but will require nothing more than explaining that section of the regulation. The training of potential food safety issues and the problems that might occur during transport are handled during standard cGMP and food safety training.
For the proposed Intentional Adulteration rule, per 21 CFR 121.160, the personnel and supervisors assigned to the actionable process steps must receive training in food defense awareness and their responsibilities in implementing the migration strategies. Also, as per 21 CFR 121.130, the vulnerability assessment is to be performed by a qualified individual, and this individual is to be qualified through experience and/or appropriate training.
For basic food defense, the FDA offers various courses and information, such as Food Defense 101, on their food defense webpage. An online course is offered in English and Spanish and covers the awareness training and the regulations for employees. Upon course completion, a certificate is provided. The agency also has a downloadable food defense plan builder that can be used to develop a food defense program. The agency also provides vulnerability assessment software, but additional training in PAS 96 or ISO/TS 22000 food defense would aid qualified personnel in making sure that this vulnerability assessment is correct and that the strategies to reduce risks are appropriate and not excessive.
There is an abundance of training courses and materials available from the FDA, USDA FSIS, associations and industry. FSMA employee training requires having personnel with the proscribed education and experience to perform specific tasks, and that they be trained as soon as possible in order for them to develop the programs. Additionally, all personnel should be trained at least annually in food hygiene, food safety and food defense.
Monitoring for veterinary drug residues is conducted to ensure food safety and compliance with approved veterinary medicine practices. Veterinary drugs are used in animal husbandry for a variety of reasons, including as a curative/preventive of disease in herd and flock, to improve meat quality, and to promote growth. The chemical classes of drugs that may be used are broad, but major classes include antibiotics, anti-parasitics, and hormones. While risk-modifiers are used to minimize risk for consumption, residues from these drugs, their breakdown metabolites, or associated impurities of the drug may persist in animal tissue, necessitating the requirement that contaminant testing be undertaken.
In the United States, trace analysis of contaminants in food products began in the early 1970s following amendments to the Federal Food, Drug, and Cosmetic Act (FFDCA) in 1968. Worldwide, the regulatory requirements for contaminants in food have seen significant tightening due to a number of high-profile contamination crises and increased trade of food across country borders. From the technology standpoint, lower detection limits have been made possible by improvement of the detection capabilities of the analytical methods and instruments. Some of the most stringent requirements for contaminants in food are found in the European Union, where the levels of contamination should be below Minimum Residue Limits (MRLs), whereas in the United States, such limits are called U.S. tolerances.
Image courtesy of MilliporeSigma
When analyzing for drug residues, the choice of tissue has historically been the liver and kidney tissues, as these organs serve to remove the contaminants from the body and, as a result, the concentration of contaminants there is higher and easier to detect. Muscle tissue now often is added to the target list, as its contamination would have a direct impact on consumers.
With regards to veterinary drugs testing, one can distinguish between screening methods and confirmatory methods. The former should be fast and high-throughput and used to detect the presence of an analyte. The confirmatory methods should be able to provide confirmation of an analyte’s identity and quantitation at the levels of interest. Microbiological methods were popular for screening of antimicrobial drugs since these drugs inhibit growth of microorganisms, but suffer from a lack of specificity since not all microorganisms are equally sensitive to all antibiotics. Rapid screening methods include immunoassay-based testing kits, which are specific, fast, and can include multiple antibiotic classes in one test. Confirmatory methods typically include chemical analysis techniques with LC-MS detection, which provides the best ionization for most classes of veterinary drugs, along with better selectivity for focused analysis and lower detection limits. LC-MS can provide specific analysis of compounds from multiple classes in the same run through either targeted MS/MS or non-targeted analysis of unknowns through high mass resolution methods. The speed of LC-MS analysis has improved with the introduction of ultra-high pressure liquid chromatography-MS (UHPLC-MS) instruments. In the last few years, UHPLC-MS methods simultaneously serve as screening and confirmation methods for multiple classes, so called “multi-residue methods”. Some of these methods use MS/MS detectors and some use high-resolution mass spectrometers utilizing time-of-flight and ion trap detectors. These methods now can provide fast turn-around time and better accuracy in comparison to microbiological methods. They may be preferentially used by testing laboratories that are equipped and capable of utilizing the latest MS instrument technologies.
The 4th Annual Food Labs conference provides practical solutions and best practices on running, managing and equipping a food lab. | March 7–8, 2016, Atlanta, GA | LEARN MOREAll mass spectrometry methods that strive to perform simultaneous analysis of multiple veterinary drug classes are prone to the same drawbacks. Due to the differences in the analytes’ polarity, acidity and hydrophobicity, the quantitative extraction of analytes from tissue samples could be difficult. Ideally, the sample preparation methods should be compatible for compounds with varying physico-chemical properties but still provide selective separation from the matrix components to avoid occurrence of matrix effects during quantitation. The co-extracted matrix impurities are undesirable since they can affect the ionization of targeted analytes and result in under- or over-estimation of their concentration (ion suppression or enhancement). Due to the difficulty in designing a method that works for a wide variety of analytes, cleanup is often omitted for multi-class multi-analytes methods, and the stable isotope internal standards are used to correct for ionization effects during quantitation. However, omitting the sample cleanup could lead to other methodology problems.
As noted in the veterinary drug analysis session during the 2015 AOAC Annual meeting, sample cleanliness can result not only in matrix effects and impact quantitation, but it can also have an effect on the mass accuracy when high-resolution mass spectrometry is used and, therefore, can affect the identification of the analytes and lead to false negatives.
The most often used methodologies for sample cleanup during analysis of veterinary drugs in tissues is solid-phase extraction (SPE), both in cartridge and dispersive formats. C18 SPE proved to be a very versatile sorbent that often resulted in the best cleanup and best precision of analysis, closely followed by polymeric sorbents when applied to multi-class LC-MS analysis.
Aminoglycosides Antibiotics
Aminoglycosides is one class of veterinary antibiotics that is hard to include into multi-class methods. The aminoglycoside structures include connected modified sugars with different number of substituents including hydroxy- and amino-groups. The higher degree of polarity for aminoglycosides contributes to their solubility properties: these compounds are freely soluble in water and to some extent are soluble in lower alcohols, but are not soluble in common organic solvents and have solubility issues in solvent-water mixtures with high organic contents. Therefore, the normal extraction conditions that include organic solvents and are frequently applied to most other classes of veterinary drugs do not work well for aminoglycosides. A separate method is often used to extract and analyze these antibiotics.
Most often aminoglycosides are detected by mass spectrometry through the formation of positive ions during electrospray ionization. The LC separation of aminoglycosides could be done by either a reversed-phase (RP) method with ion-pair mobile phase additive to insure the retention of compounds or by HILIC chromatography. We have investigated both methods and looked at the sensitivity for detection of these compounds. The use of ion-pair is most often presented as a disadvantage, as it can reduce the analyte signal through the decrease of ionization efficiency and fouling the LC-MS instrument. While the use of ion-pair in our study decreased the ionization for some of the lighter compounds in this class (streptomycin, puromycin), ionization efficiency increased for the heavier mass compounds (gentamycin, neomycin). RP chromatography resulted in improved separation of the analytes compared to HILIC. LC-MS fouling from the use of HFBA was not observed in our investigation that spanned the course of a couple of years. In the HILIC mode with use of formic acid as a mobile phase additive, the detection of neomycin was problematic due to very low sensitivity. It was as low as one seventh of the sensitivity obtained by RP method.
The instrument response for aminoglycosides also depends on sample extraction and cleanup and the accompanying matrix ionization effects. The extraction from animal tissues has been traditionally done using the McIlvaine buffer that includes 2% Tricloroacetic acid (TCA) to precipitate proteins and release any bound analytes and 0.4 mM EDTA to prevent the binding of the analytes to cations and/or glass. Then the extract undergoes cleanup steps using SPE. The SPE sorbent most often used is a cation exchange phase, as the aminoglycosides have ionizable amino-groups and can be retained from the extract through ion-exchange interactions. Another option for the SPE cleanup became recently available—molecularly imprinted polymeric (MIP) SPE. MIPs, which are sometimes called “chemical antibodies”, mimic the performance of immunoaffinity sorbents. MIPs have binding sites that conform to the shape and functionality of a specific compound or a compound class. Strong binding of the analyte to the MIP makes it possible to perform intensive SPE washes that lead to very clean samples. Unlike immunoaffinity sorbents, MIPs are compatible with organic solvents and strong acids and bases.
We have tested the MIP SPE versus the traditional weak cation exchange (WCX) SPE cleanup for aminoglycosides spiked into pork tissue. The resulting ionization effects were compared as an indication of samples cleanliness. The quantitation in both cases was done using matrix-matched calibration curves and in both cases the recoveries for most of the ten tested aminoglycosides were above 70% (with exception of spectinomycin at 33% in case of WCX cleanup and tobramycin at 55% in case of MIP cleanup). For the two cleanup methods, there was a significant difference in matrix effects. In Figure 1, matrix factors close to 1.0 indicate little to no matrix influence for analyte detection: the ionization of the analyte in mass spectrometer is not influenced by co-extracted matrix impurities and quantitation values are not skewed. Values for matrix factors that are significantly greater than 1.0 suggest matrix enhancement for the analyte and values less than 1.0 are considered to be the result of matrix suppression. Significant matrix suppression was observed for all analytes when WCX SPE was used for cleanup. The ion suppression effect was significantly less for samples cleaned using MIP SPE. In addition, we observed significant time savings when using the MIP SPE cleanup method, as it did not require sample evaporation after using water-containing elution solvent.
Figure 1. Matrix factors close to 1.0 indicate little to no matrix influence for analyte detection
Conclusions
While improvement in the laboratory instrumentation allows the simultaneous and fast analysis of multiple contaminants, sample preparation remains important for reliable identification of contaminants in screening methods and error-free quantitation in confirmatory methods. Both the extraction and sample cleanup methods can contribute to accurate multi-class methods analyzing wide variety of veterinary drugs. New and upcoming technologies such as molecularly-imprinted polymers could be used for more targeted analysis of specific classes of analytes via instrumental methods.
The FSMA Third Party Accreditation (TPA) final rule was published in the Federal Register in final form on November 27, 2015. Although TPA is not limited to imported food, its primary use will most likely be for food imports. TPA offers foreign food facilities and food importers a way to show FDA that the items coming to the United States meet federal food safety requirements.
An acceptable audit by a certified auditor is the only way an importer can take advantage of another FDA program, the Voluntary Qualified Importer Program (VQIP), which offers expedited review and entry of food. If FDA deems it necessary, the agency can also require certified audits for the import of specific foods.
The TPA process requires a number of administrative steps by FDA and non-FDA entities before the first third-party inspection is made. The four major steps are:
FDA is responsible for officially recognizing accreditation bodies.
An officially recognized accreditation body will accredit third-party certification bodies.
The accredited third-party certification body will certify third-party auditors.
The certified auditors will conduct consultative and regulatory audits of food facilities.
If FDA does not find an applicant that it can officially recognize as an accreditation body within two years, it may directly accredit third-party certification bodies.
In order to recognize an accreditation body, FDA must review an applicant’s legal authority, competency, capacity, conflict-of-interest safeguards, quality assurance and record procedures. By using an already existing framework familiar to industry, accreditation bodies and certification bodies will be allowed to use documentation of their conformance with the International Organization for Standardization and the International Electrotechnical Commission (ISO/IEC) standards, supplemented if necessary, in meeting program requirements under this rule. An official recognition of an accreditation body is granted for up to five years.
FDA is authorized to recognize a foreign government/agency or a private third party as an accreditation body under TPA.
Recognized accreditation bodies under TPA will be required to:
Evaluate potential third-party certification bodies for accreditation, including observing representative samples of the prospective certification body’s work
Monitor performance of the third-party certification bodies it has accredited, including periodical on-site observations, and notifying the FDA of any change in, or withdrawal of, accreditations it has granted
Self-evaluate and correct any problems in their own performance
Submit monitoring and self-assessment reports and other notifications to the FDA
Maintain and provide the FDA access to records required to be kept under the program
Once accredited, third-party certification bodies under TPA are required to perform unannounced facility audits, and to notify the FDA if a condition is found that could cause or contribute to a serious risk to public health.
The food industry is becoming increasingly fast-paced. Regulations are changing, the supply chain is becoming more transparent, and resources are harder to access. To meet the needs of an ever-changing industry, digital learning is becoming the go-to solution for training managers and frontline food handlers alike, as it can be done quickly and efficiently. Now that most people have smartphones and mobile devices, there are multiple ways to make learning accessible.
Image courtesy of Alchemy Systems
The “Mind of the Food Worker” study conducted by the Center for Research and Public Policy (CRPP) points out that food workers have developed a preference for digital training over traditional classroom or instructor-conducted training. There are many new approaches to learning, including web-based eLearning, kiosk, gamification/competition, social media, digital signage, and coordinated communication programs. Let’s take a closer look at each of these.
eLearning
eLearning is no longer about reading through a PowerPoint presentation or watching a pre-recorded video. The number of companies offering eLearning continues to increase, as do the topics, content and format of the content. In addition, eLearning carries the added benefit of being affordable. For many companies, saving on the cost of travel when an individual attends a workshop provides an attractive incentive.
The ability to learn at one’s own pace at the time and place of one’s choosing has special appeal for today’s learners. The availability of eLearning via mobile devices is meeting that desire. It can be seen everywhere—people glued to their mobile devices while waiting in line, taking a lunch break, or in the evenings on their own time. This is multitasking at its finest.
Kiosks
The ability to take a device to a quiet environment helps with concentration and efficiency in training. Kiosks can be set up in an area that is conducive to learning with no traffic, noise or other distractions and are popping up at workplaces more and more. Learners can come and go at their convenience. A learning lab set up in a manufacturing facility will pay for itself very quickly. Sending workers to the lab one at a time is much more cost effective than shutting down a line or area of the plant for group or classroom training.
Gamification
Gamification, the use of interactive tools in conjunction with learning, is a term being used more often in training industry vocabulary. For example, it can involve the addition of a word and a definition-matching exercise in conjunction with a training module to encourage learners to retain what they have just learned. It also makes the education process more fun—and it seems to be working.
Gone are the days of sitting through hours and hours of dry lectures or reading textbooks that simply do not resonate. This method has always been especially difficult for employees working in a food plant. Sitting in a warm darkened room listening to a droning presentation is an invitation to sleep. Gamification eliminates the droning, and requires attention and participation.
The Association for Psychological Science has confirmed that competition engages learners, drives retention, and leads to higher test scores. Got a boring topic for training? Get your game on! A great example of gamified learning that is readily available is Merriam-Webster’s Word of the Day. Sign up for free and receive a daily email with a new word, along with its pronunciation, definition(s), use and history. The email also links to several great games that provide word calisthenics for the brain.
Social Media
Leveraging social media helps to expand and continuously improve training programs. This mode of technology will ensure that every employee in a company has timely, consistent answers to questions. Using private company social media provides a safe environment for posting questions and answers while complementing a training program and filling any knowledge gaps. The CRPP study points out that 80% of workers regularly use public social media platforms such as Facebook and LinkedIn.
Companies can take full advantage of this familiarity with social media by providing an internal forum that encourages open discussion and group learning. This approach enables the workforce to engage in an interactive learning path that is continually up to date. Internal social media also encourages networking, which fosters a sense of camaraderie between individuals, along with company loyalty. One major food company that has used this approach has seen employee questions flourish from 3,000 entries in the first year to more than 15,000 the following year. What an incredible way to keep the workforce updated minute by minute with appropriate, relevant answers to their inquiries.
There is no question that we are in the midst of a unique time period in history. Technology is continuing to innovate at an increasingly rapid rate, which has led to drastic changes that affect nearly every corner of day-to-day life. From the way we find information to our food choices, technology is influencing our lives in new ways.
The Rise of the Internet
Mary Meeker, the venture capitalist who was dubbed the “Queen of the Internet” more than 15 years ago, has described the current Internet age as a period of reimagining. At the heart of this reimagining has been the rapid growth, maturity and adoption of the Internet and Internet-enabled technologies.
In her most recent 2015 research, Meeker published some fascinating statistics. The number of people online has ballooned more 80 times, from a user base of a mere 35 million in 1995 to a staggering 2.8 billion users in less than 20 years. This figure translates into nearly 40% of the total global population.
A breakdown of the 2.8 billion Internet users in 2014. This figure (39% global penetration) exploded from the approximately 35 million users in 1995. Source: Internet Trends 2015 – Code Conference
It hasn’t just been the volume of usage that has evolved radically. The nature by which those billions of users are signing online has also changed. It’s hard to believe that the original iPhone was released in 2007, less than 10 years ago. In that time, the mobile Internet has gone from a novelty to a necessity for many of us in our daily lives. This smartphone adoption has fueled Internet use and has drastically increased the ease with which consumers can get online.
Reimagining Communication and Compliance
The result of our new “always-on,” globally connected world (to borrow Meeker’s term) is a complete reimagining of communication. Consumers expect a velocity and volume of communication that the world has never before experienced. We now take for granted that we can reach friends, family and acquaintances anywhere in the world—at any time—in an instant. This has also drastically changed our expectations of business relationships.
Consumers in an ever-connected world have an expectation of availability and transparency of information from the brands with which they interact and the establishments they frequent. What this means for businesses is that customers expect to have a degree of access to business data that they’ve never asked for previously.
A tangible side effect of this desire for data transparency can be seen within the regulatory environment that organizations operate. Governments and regulatory bodies have increased their expectations of data access and availability over time, resulting in more stringent regulations across the board.
Research from Enhesa shows that the regulatory growth rate is nearly as staggering as Internet growth rates. According to the firm’s research, from 2007–2014 regulatory increases by region were as follows:
North America: +146%
Europe: +206%
Asia: +104%
Impact on Food Safety: Consumer Engagement and Regulatory Growth
One particular area of regulatory growth has occurred within the food and beverage sector. Arguably no product category has a more direct impact on consumers than food, as it literally fuels us each day. It’s no wonder that in an environment of increasing regulations and more empowered consumers that food quality and food safety are under increased scrutiny.
In today’s environment, it becomes much more challenging to brush aside product recalls and food safety incidents or bury these stories in specialized media. The latest news is not just a fleeting negative headline. In a worst-case scenario these incidents are viral, voracious and more shareable than ever before. From Listeria outbreaks to contaminated meat to questionable farming practices—when fueled by the Internet, the negative branding impact of these stories can be staggering. Consumers are paying attention and engaging with these stories—for example, during a Listeria or Salmonella outbreak, online searches for these terms significantly rise.
The rise of hyper-aware consumers has had a measurable impact. As a result, governments have been quick to respond and have beefed up existing regulations for the food and beverage sector via FSMA and GFSI.
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