Holly Mockus, Product Manager, Alchemy Systems

10 Training Concepts for an Effective, Engaged Workforce

By Holly Mockus
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Holly Mockus, Product Manager, Alchemy Systems

Effective training programs are the cornerstone of a high performing workplace. Providing the basic knowledge to workers and reinforcing the need to apply that learning in their daily activities are just two critically important facets of a well thought out training system.

Here are 10 concepts that need to be implemented to bring training and education full circle and to provide forward momentum in the process of developing a fully engaged highly productive workforce.

  1. Set learning objectives – determine first what the key points or factors are that will be influenced by this knowledge exchange and how will the outcomes be measured.
  2. Create the content – tailor the message or training information to the specific audience for maximum absorption and comprehension.
  3. Deliver the content – ensure the set-up is conducive to learning. Keeping the message relevant to the workers level of comprehension and using real life examples that they can relate to is a best practice.
  4. Keep training top of mind – use awareness programs as visual and audio prompts that keep the topic out in front of the organization. When everyone walks the walk and talks the talk it makes it harder for the individual leaner to forget what needs to be done and how to do it.
  5. Verify comprehension – use testing, observation and constructive feedback to help employees apply what they have been taught. Be sure that feedback is constructive not punitive and is delivered in real time for maximum effectiveness and greater adoption by the worker.
  6. Track and trend using metrics – Measurement of desired outcomes should be used as a yardstick to help determine if the content, delivery and application of the training is on track or needs course correction.
  7. Never pass up an opportunity to train – refresher training on a regular basis is needed for any program to be effective. Retraining is also very impactful when used as a corrective action or as part of an investigative process.
  8. Keep it fun – capture the learner’s attention by using bright colorful presentations, games or game show formats, and some light humor. A little friendly competition between departments is a great way to engage the workforce while promoting the learning process.
  9. Use positive reinforcement – those that absorb and apply need to be recognized and reinforced. Don’t just say thank you. Recognize the positive impact of their good work habits and how their application of those work habits has resulted in good outcomes.
  10. Hold people accountable – employees that are unwilling to follow training principles need to be held accountable with appropriate consequences. Deciding in advance what the consequences are and hold all employees to the same level of accountability will drive continuous improvement and strengthen the overall training program.

These 10 basic training concepts will provide an excellent cornerstone to support programs across an organization and drive consistency, accountability and employee engagement.

Hear the author speak more on food safety training at the Food Safety Consortium, November 17-18, 2014, Schaumburg, IL. Click here for more details and to register. 

 

Tim Lozier, EtQ, Inc.

What are the 4 Key Elements in Compliance Management Software?

By Timothy Lozier
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Tim Lozier, EtQ, Inc.

Compliance is a broad term in business today. It’s a term that gets thrown around in meetings, operations, regulations, and covers so many definitions. It almost borders on cliche – compliance is broad. But what does it mean?

In simplest terms, “Compliance” means that you are able to do business with confidence. You can operate your business in a manner that means less risk, better quality, safety and governance. It means that you are doing business as you should – as people will expect you to. Compliance management software is designed to help foster this concept, but again, it becomes broad in definition on what can be offered.

What do people need in compliance management software solutions? Here are 4 basics:

A flexible platform

You cannot necessarily place compliance into one operational area. Quality Management Systems, EHS Management Systems, Governance and Risk Systems, and others all fall under the umbrella of compliance. But the core common theme is that you want a solution that will track all your processes, manage them and put controls in place to fix any adverse events quickly and effectively. Trouble is, that you will change processes, you will need to adapt to market changes, business changes and beyond. Having a flexible platform that enables you to periodically make changes easily is a key to compliance management software. You want to make sure the platform you select has this flexible for rapid business process change. Look for a solution that has this flexibility; it enables you to change workflows, and forms as you need to – without any signifcant effort.

Risk management

More and more, compliance is centered around Risk. This is because in the rapdi pace of business today, you cannot easily keep up with compliance without having some level of objective and systematic means to measure events and make decision on those events. Risk tools, and quantitative risk methods are paving the way to enable businesses to quantify their events that are out of compliance, and make decisions on how to mitigate the risk of those events. You want to ensure that your compliance management platform incorporates some level of risk management solution, or builds in a risk assessment to ensure that not only are you addressing the most critical events, but you are also building our a risk based strategy on how to ensure they are mitigated.

Integration and Scalability

Compliance, as stated above is broad. It does not live in a silo; many compliance processes span multiple facilities, departments and operational areas. It also spans multiple business systems. You want a solution that provides a macro-view on the data, and pulls in from other systems, as well as pushes compliance information to other business systems. This way you are creating a “Hub” for compliance that touches all other areas of the business. Similarly, you want to be able to harmonize and standardize your processes related to compliance throughout the enterprise. This requires a system that can span multiple facilities, and create a single source for compliance data. Having a solution that can operate across several business units and locations, while remaining centralized the the core enterprise location is important to maintain control over compliance processes.

Visibility into compliance data

Having a system that can automate the processes related to compliance is immensely valuable, but it is only half the battle. Without visibility into the data, it becomes difficult to get an accurate picture on top-down compliance. You want to make sure that you are building in enterprise reporting and analytics tools to the compliance information. This way, you can see any trends, make decisions on continuous improvement, identify areas for preventive action, and generate compelling and accurate reports on the overall “health” of your compliance management system.

These 4 elements are just basics on compliance management software. Again, there are broad categories to which compliance falls under, and each category will have its own specifics. The key is that with a robust, yet simplistic framework, built upon a enterprise-level platform, you can achieve the goal of doing business with confidence.

Dr. Douglass Marshall, Chief Scientific Officer – Eurofins Microbiology Laboratories

Environmental Monitoring – Another Leg on the Food Safety Management Stool

By Sangita Viswanathan
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Dr. Douglass Marshall, Chief Scientific Officer – Eurofins Microbiology Laboratories

Eurofins laboratories routinely test for the presence of the infectious bacterial generaSalmonella and Listeria monocytogenes in the food processing environment. While L. monocytogenes long has been known as an environmental contaminant, only recently Salmonella has been considered a persistent environmental contaminant.

At this year’s Food Safety Consortium (November 17-18, 2014, Schaumburg, IL), Dr. Douglas L. Marshall, Chief Scientific Officer – Microbiology, for Eurofins Scientific Inc. will present a workshop on Environmental Monitoring. This workshop will provide an overview of analytical methods used, a discussion of the zone approach to environmental monitoring, and a practical example of the use of microbial genetics in Eurofins’ Source Tracking Program to identify and eliminate a pathogen harborage.

In this Q&A with Dr. Marshall, we present a sneak-peek into what to expect in this workshop. Register today to learn more.

Food Safety Tech (FST): How are environmental monitoring requirements changing under FSMA?

Dr. Marshall: The Food Safety Modernization Act passed by Congress contains language in SEC. 418. HAZARD ANALYSIS AND RISK-BASED PREVENTIVE CONTROLS stating: ‘‘(4) the preventive controls implemented under subsection (c) are effectively and significantly minimizing or preventing the occurrence of identified hazards, including through the use of environmental and product testing programs and other appropriate means” and ‘‘(C) An environmental monitoring program to verify the effectiveness of pathogen controls in processes where a food is exposed to a potential contaminant in the environment.”

The Preventive Controls for Human Food Proposed Rule has moved environmental testing to the appendix. It is clearly FDA’s intention that firms use environmental monitoring but how this will ultimately play out in the final rule is unknown. The companies we work with are finding a substantial non-regulatory push for environmental monitoring from their customers. As a result, firms without environmental monitoring programs will find it challenging to escape criticism from inspectors, auditors, and customers.

FST: What are some broad topics you are going to be covering in your FSC presentation?

Dr. Marshall: This EMP workshop will deliver tips for an effective pathogen monitoring program. Highlights include information relevant to answering many EMP questions such as what to test for, what is the value of indicators; where to test, what methods to use, what test volumes are appropriate, how to use trending, and how to remediate an environmental problem.

FST: What are some key challenges when companies do environmental monitoring? For Salmonella, and for Listeria?

Dr. Marshall: Many companies find it difficult to start an EMP program and fail to use the program in a proactive manner as an assessment tool. Environmental monitoring is an essential tool for microbial control, but it is not a control program. Robust programs target areas in a processing plant where environmental pathogen control is critical to product safety. The pathogen of concern may differ depending on food product type and processing conditions.

FST: Why is it important for food companies to pay attention to this critical area of testing?

Dr. Marshall: Numerous recent high-profile foodborne disease outbreaks and large recalls have been traced to poor environmental controls. Lack of effective environmental monitoring by producing firms contributed to these events. As a result, inspectors, auditors, and customers are demanding the placement of environmental monitoring programs as an additional leg on the food safety control stool, adding to GMPs, SSOPs, and HACCP.

FST: What kind of technologies will you be talking about in your presentation?

Dr. Marshall: The talk will present an overview of analytical tools required for routine monitoring and give an example of the use of genetic strain typing as a source-tracking tool for remediation.

Learn more, and register today for the Food Safety Consortium – Multiple Conferences, One Event, featuring 30 plus expert industry speakers, and speakers from FDA, CDC and USDA. 

Dr. Bob Strong

How to Perform Root Cause Analysis?

By Sangita Viswanathan
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Dr. Bob Strong

SAI Global logoDr. Strong was speaking in a recent webinar onThe Importance of CAPA and Root Cause Analysis for the Food Industry, in which he discussed CAPA, Root Cause Analysis and the benefits of these quality systems. We present below the comprehensive list of questions as presented by Dr. Strong.

Questions to ask: People

  1. Does the person know what he’s expected to do in this job?
  2. Is he well trained?
  3. How much experience does the person have?
  4. Does the person have the right tools/ equipment needed to do the job?
  5. Is the workload reasonable?
  6. Does the person have adequate supervision and support?
  7. Do physical conditions such as light or temperature affect their work?
  8. Who does the person contact when problems arise?

Questions to ask: Method

  1. How is the process used defined?
  2. Is the process regular reviewed for adequacy?
  3. Is the process used affected by external factors?
  4. Have any changes been made recently in the process?
  5. What adjustments must the operator make during the process?
  6. How does the operator know if the process is operating effectively?
  7. Have other methods or processes been considered?

‘What would you do if things go wrong,’ this could be the most revealing question you can ask your employees that it may identify a real issue, added Dr. Strong.

Questions to ask: Equipment

  1. How old is the equipment or machinery?
  2. Is preventive maintenance performed regularly on it?
  3. Is the machine affected by heat, vibration, or other physical factors?
  4. How does the operator know if the machine is operating correctly?
  5. What adjustments must the operator make during the process?
  6. Have any changes been made recently in the equipment?
  7. How is the equipment cleaned?
  8. What tools are used to clean the equipment?

Questions to ask: Raw materials

  1. What is the source of the raw material?
  2. Has there been a change in suppliers recently?
  3. How is the raw material produced?
  4. How is the safety of the raw material verified?
  5. How old is the raw material?
  6. How is safety assessed prior to your operation?
  7. What is the level of safety and quality?
  8. How is the raw material packaged?
  9. Can temperature, light or humidity affect the material quality?

Questions to ask: Environment

  1. How are environmental conditions monitored?
  2. How are environmental conditions controlled?
  3. How is environmental control measuring equipment calibrated?
  4. Are there changes in conditions at different times of the day?
  5. Does environmental change affect the processes being used?
  6. Does environmental change affect the materials being used?

Questions to ask: Inspection System

  1. How frequently are products inspected?
  2. How is the measuring equipment calibrated?
  3. Are all products measured using the same tools or equipment?
  4. How are inspection results recorded?
  5. Is there a set of procedures and do inspectors follow the same procedures?
  6. Do inspectors know how to use the test equipment? 

Ask your team ‘what would happen if the systems weren’t calibrated? Are they giving you valid results?’ Probably that’s why you are not in compliance, explains Dr. Strong. 

All this take takes time and effort, and Dr. Strong urges management to devote the resources to go around ask these questions and get the answers.

What is your experience with Root Cause Analysis? Have your used such questions? Do you have more to add? Join the discussion by commenting below.

For more information, visit SAI Global’s Food Safety Resource Center, to access this complimentary, ON-Demand webinar.

Dr. Jacqueline Southee, U.S. Liaison for FSSC 22000

“Make Consumer Safety and Food Safety a Hard Priority”

By Sangita Viswanathan
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Dr. Jacqueline Southee, U.S. Liaison for FSSC 22000

On September 26, Dr. Jacqueline Southee, U.S. Liaison for FSSC 22000, will present FSSC 22000 – The Road Ahead, as part of the 2014 GFSI Leadership Webcast Series presented by SafetyChain Software and FoodSafetyTech.

Dr. Southee will talk about what’s new for the scheme, what changes are expected in 2015 and beyond, how these changes will affect you, and why it’s important to embrace these changes to be better prepared for upcoming food safety regulations such as FSMA. In this interview with Food Safety Tech’s Sangita Viswanathan, Dr. Southee discusses some of the topics that will be examined in more depth during the webinar – including FSSC 22000’s international food safety management certification scheme and its global integrity program.

Food Safety Tech (FST): We’re very excited to have you participate in the GFSI Leadership Webcast Series. What will you be talking about in terms of current changes with FSSC 22000?

Dr. Southee: The most striking change that FSSC 22000 is undergoing revolves around the rapid uptake of the scheme by industry and the increase in the number of certified sites which currently stand at more than 8000. This represents a 48 percent increase since mid-2013. The standard is currently operating in 146 countries, and has become a truly global scheme. We are also working to extend the scope in line with the GFSI goal to cover the entire supply chain. For instance, we have added animal feed to our scope, and will soon be adding animal farming. We are constantly making adjustments within the scheme to keep in line with GFSI requirements in terms of maintaining the highest possible scheme integrity. Overall, FSSC 22000 is creating a lot of buzz out there and we continue to work to meet the growing needs of the industry.

FST: We know that audits will be a topic of many questions. Is FSSC 22000 planning changes on the way it does audits? What are some of audit-related topics you’ll be addressing in the webinar?

FSSC 22000 LogoDr. Southee: FSSC 22000 does not do audits itself. It oversees the FSSC 22000 scheme which provides the specifications for the audit which is conducted by a qualified Certification Body. We work with 96 licensed Certification bodies and more than 1500 auditors throughout the world who conduct FSSC 22000 audits. Our goal is to ensure that these audits are conducted consistently and in line with GFSI requirements. We focus on having a global integrity program, and are in regular contact with auditors and Certified Bodies to monitor auditor competence and to ensure that both CB’s and auditors are meeting these requirements. This monitoring may require an increase in the communication that we have with our CB’s and may even result in an increase in the number of visits that we pay to them. The overall goal is to maintain the highest standard of food safety audits for FSSC 22000 certified companies.

FST: You will also be talking about the direction of FSSC 22000 in 2015 and beyond? Is there a “theme” or specific set of business drivers that are driving future changes to FSSC?

Dr. Southee: The main business drivers for FSSC 22000 are increasing transparency across the supply chain, maintaining the highest standard of consistent audits around the globe to promote a continuous improvement in food safety. As a global scheme, we are in a good position to work with many of the world’s leading food manufacturers. We work on ensuring transparency throughout the supply chain to maintain efficiency in the control of food safety, raise the confidence of the customers and the regulators in the third party certification process and to ensure the production of safe food ingredients and products for the consumer.

FST: While we all know change is important, it’s not always easy to get already-burdened food safety organizations to embrace change. What are some of the things we’ll learn in the webinar about why embracing change is critical to the ongoing success of FSSC 22000?

Dr. Southee: The global food manufacturing industry is currently under a tremendous burden with pressures coming from all sides. They must produce safe food efficiently and effectively to meet the demands of the retailers, the regulators and the consumer. What’s more in this truly digital age, where social media drives consumer preference more than anything else, they need to show their commitment to food safety. The new norm is that consumers are “involved” in what they eat. Every step industry takes is scrutinized by everyone with access to the information, and if anything slips out of compliance, it is public knowledge almost within the hour. There’s a constant demand for information, so food manufacturers need to invest in management systems such as FSSC 22000 to manage their food safety effectively, maintain transparency across the industry both for their customers and their consumers and be quick to respond to issues.

FST: We know that you’ll be providing advice on how companies can start today to prepare for tomorrow’s FSSC. Can you tell us some of the topics you’ll be addressing in this part of the webinar?

Dr. Southee: One topic I’ll be addressing is that food safety management should not be considered a cost center. In order to prepare for FSSC 22000, it is critical for senior management within an organization to recognize the need to take responsibility for food safety and that this will involve the need to have a robust food safety management program in place. Many companies now recognize the importance of investing in food safety and this is to the benefit of all. We also hear about the importance of establishing a “food safety culture” and we can talk more about what this means.

FST: It has been said that GFSI certification is a very good start to preparing for FSMA compliance. What are some of the key points you’ll be addressing when it comes to FSMA compliance and FSSC 22000?

Dr. Southee: First of all, I think that the establishment of the GFSI is an example of the food industry already regulating itself. The benchmarking approach has raised the standard of the accredited third party certification process and a company that is certified under a GFSI scheme is already meeting a high standard of food safety. A scheme such as FSSC 22000 provides additional evidence of a company’s commitment to food safety practices and management. The FSSC 22000 scheme meets many of requirements specified by the initial draft of the FSMA rules and existing data suggests that GFSI certification is a very important start to ensuring compliance with FSMA requirements.

To learn more about all of these and many more topics on FSSC 22000 – including live questions from the audience – register today for FSSC 22000 – The Road Ahead, Friday, September 26, with Dr. Jaqueline Southee.

Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

SQF: Where is it Going and What Does it Mean to You

By Sangita Viswanathan
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Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

In a recent webinar, Robert Garfield, Senior Vice President of the Safe Quality Food Institute talked about the SQF standard, changes made in 2014, what is expected in 2015, and how companies can use SQF to be better prepared to comply with rules proposed under the Food Safety Modernization Act. We present below some excerpts from the webinar, organized under the 2014 GFSI Leadership Series. The next webinar in the series will focus on FSSC 22000. Click here to register.

Where is SQF going in 2015 and beyond?

Garfield: The standard is going to be focused on enhanced compliance programs and improving the database reporting systems. For instance, if it concerns someone in the bakery or dairy industry, we would like to know how they are doing versus the industry as a whole. We are hoping that better database reporting can help with this, especially when it comes to non-compliances.

Another area we are working on is establishing Cooperative Agreements. In 2014, we finalized an agreement with the American Feed Industry Association and we are working with their food safety program. We are hoping to not just work cooperatively with the private sector, but also with various government agencies and other stakeholders.

Other areas we are growing in 2015 are expanding our language alternatives, subject matter training and developing industry specific guidance.

There are many changes proposed to food safety regulations and food safety schemes such as SQF. How will companies be affected by these changes and why is embracing these changes so important to industry?

Garfield: Embracing all these changes is critical for the food industry to do everything they possibly can to ensure that they are making and selling a safe product. At the end of the day, there is no one ‘magic bullet’ solution to food safety. Embracing these changes to food safety rules and standards will help the CEO and management team sleep better at night, knowing that they are doing what they can to protect their product, their brand name and their consumers. Also, companies need to understand that the regulatory climate will completely change in the next few years, so it’s critical for companies to start acting now to meet these new requirements that will start being in effect from October 2015.

How can companies start preparing today for tomorrow’s SQF?

Garfield: I tell companies and retailers I talk to that if they are interested in doing SQF because they want to be ‘GFSI certified,’ that’s the wrong reason to do this. To get started, management commitment and changing the culture of the entire company is critical. Starting from the CEO and going all the way to the man operating machinery on the floor, you should aim to get a commitment to food safety, where food safety management is the most important issue for the company. If you start working on that today, you can accomplish great things for the company in not just reducing recalls, but improving the overall functioning of that company.

How can SQF help prepare companies for FSMA?

Garfield: The first step is to look at the Preventive Controls and the Fresh Produce rules and see how these apply to your company. I suggest hiring an independent expert to take a look at your facility and see how your company fares against these rules and have a better understanding about where you will be when these rules are finalized by October 2015. While you will have one to three years to comply with these rules after that point, you need to get the management buy in and strong food safety management systems in place now. Start now, and don’t wait for the final rules to be announced.

Listen to this complimentary webinar today to learn more about how SQF differs from other food safety programs, unannounced audits, changes with allergen control standards, and how to become SQF certified. Click here to access the recording.

2014 GFSI Leadership Series continues with FSSC 22000: The Road Ahead. Click here to register for this informative webinar on Friday, September 26, 2014, featuring Jacqueline Southee, U.S. Liaison, FSSC 22000, who will talk about what’s new for FSSC 22000 this year, where FSSC 22000 is going in 2015 and beyond, how you will be affected by the changes, and how to start preparing today. Plus Jacqueline will take your questions live!

Katie Moore, Intelligent Platforms’ Global Industry Manager for Food & Beverage, GE

Big Picture Understanding for Better Food Safety

By Sangita Viswanathan
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Katie Moore, Intelligent Platforms’ Global Industry Manager for Food & Beverage, GE

Having worked in the food & beverage industry as a plant manager, Katie Moore knows just how important food safety is to a company’s brand and profits. As GE Intelligent Platforms’ Global Industry Manager for Food & Beverage, she uses today’s connected technology to help prevent food safety issues and expensive recalls.

Companies want to do the right thing and try to control what is known. They want to mitigate risks when possible. But without a clear and complete line of sight to real-time process data and information, like whether or not your HACCP processes have been followed, correctly, each and every time as stated in your HACCP Plan, how can you truly have peace of mind going to sleep every night? That’s the gap that’s plaguing food companies and managers, says Moore.

Against the backdrop of evolving food safety rules under the Food Safety Modernization Act, Moore sees manufacturers in the food and beverage industry in a wait-and-watch mode.

“Since these rules are still in the process of being finalized, everyone’s waiting to see what the final regulations will look like. This is the right time for manufacturers to educate themselves, and implement new steps and programs to assess and mitigate risk,” she explains. Moore feels larger companies are much better at addressing these changes, because of having greater resources or collaborations with industry associations, while small and medium sized companies are continuing to implement HACCP and GFSI standards, but are a step or two behind their larger counterparts.

There is a lot of risk management going on, and it all begins with HACCP, says Moore. But a gap she’s noticing is a lot of records still being paper-based.

“There is still a lot of work being done on paper. And data is not being transferred automatically. Because of this, there is no way to go back and learn from what’s going on and identify trends and issues. There is truly no electronic capture of data. This lack of learning and understanding of trends and changes is a big gap,” Moore adds.

A lot of recent recalls are due to supplier problems, so everyone focuses on that. Companies are managing the biggest risk, which is their suppliers, and there are a lot of solutions available to manage supplier compliance. “But true value can be realized when this is tied in with your manufacturing processes and specifications. How is the food handled in my line, my tanks and my processing facility…. If companies have this continuous visibility it will contribute to food safety and quality improvements growing by leaps and bounds. And also companies will be able to track and trace throughout the process, and react a lot quicker,” she describes.

Mergers and acquisitions in the F&B space

These days, there is a lot of consolidation happening in the F&B space. Historically, whenever there is a merger of two food companies, there is a challenge to have in place a sound business continuity plan. For instance, Moore asks, if there’s a recall, then how do we react? If there is an issue isolated to one facility, how can we cover our bases and mitigate risks? How can we make sure our customers get our products? From an IT perspective also, there are some challenges that need to be addressed. For instance, what GFSI scheme are we using? Do we merge these two standards and our supporting IT infrastructure, or continue to work with two separate standards? The key in making this decision is to utilize big data analytics to determine which process has been working most efficiently and to factor in the cost of replacing or retrofitting the extremely expensive manufacturing equipment.

According to Moore, F&B managers need tools that can help them improve compliance to food safety, have better visualization and hence greater visibility either on the plant floor or via mobile platforms, have the ability to pull up a wide range of information and share it with people. F&B companies usually handle a wide range of project management systems, typically working on different software from different vendors.

At GE Intelligent Platforms, Moore says, the products ‘talk’ to different systems and data management software to try and address the challenge of collecting, managing and trending large amounts of data.

So are companies embracing technology solutions to better manage food safety and quality? Moore feels that a driving force is lacking.

“Once something happens and FDA has to react, the chips will start to fall. There will be a lot of recourse to technology that will be required, but right now there’s no driving force. Once FDA puts the hammer down on electronic documentation, F&B companies will start to move faster,” she sums up.

Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

FSMA Fridays: Concerns Around High-Risk Food Methodology

By Sangita Viswanathan
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Sangita Viswanathan, Former Editor-in-Chief, FoodSafetyTech

In February 2014, FDA published a Draft Approach for Designating High-Risk Foods under the Food Safety Modernization Act, with the purpose to identify high-risk foods based on specific parameters for additional recordkeeping requirements to enable rapid, effective tracking in the event of foodborne illness outbreak.

What are the factors by which a food is designated as ‘high-risk?” will FDA do such an analysis for every single food product? And what are concerns about this approach?

At a recent FSMA Fridays webinar, presented by SafetyChain, Dr. David Acheson and Jennifer McEntire, Ph.D., of The Acheson Group focused on this topic.

What will the high-risk foods list be used for?

Dr. David Acheson: What FDA wants to do with the high-risk foods list is to mainly leverage this for better product tracking. FDA will also have greater authority to ask for more information and keep more records for these high-risk foods, though the agency hasn’t clearly specified what information yet. Also the frequency of routine inspections for high-risk foods will be greater: once every three years, compared to once in every five years for non-high risk foods. One area which FDA hasn’t elaborated on is importers needing certificates for high-risk foods entering the U.S. Initially, the agency had considered this, but didn’t have a system in place to require this. Now the requirements are proposed in the FSMA rules and third-party audits can support this.

What are factors that will determine if a food is high risk?

Jennifer McIntyre: FDA considered several areas and has finalized a detailed methodology to identify high-risk foods based on the following parameters:

  • Frequency of outbreak and occurrence of illness associated with that food since 1998;
  • Severity of those illnesses;
  • Likelihood of contamination;
  • Growth potential of that food;
  • Is there an opportunity during processing for that product to become contaminated;
  • Consumption of that food product; and
  • Economic impact associated with that food product in case there’s an outbreak or recall.

This approach is based on an evaluation of chemical and microbial hazards combined with foods using criteria that encompass the FSMA-required factors.

How will each food be scored and is there a distinguishing line between high-risk and non-high risk foods?

McEntire: Food will be rated on a 1 to 9 scale, with 1 being low, 3 being medium, and 9 being high. Companies have these three options to choose from. There’s no clear line the agency has proposed to determine what foods are on the list and what aren’t.

Is FDA going to do this analysis for every single food product? Where will they get the data from?

Acheson: There’s no way the agency can do this for every single food product. They are looking at a lot of parameters to consider. What they might do, and they are already doing, is try to bunch food products and commodities together, so there will be buckets of food identified as high-risk and non high-risk. Getting all that data will prove to be a challenge, considering that what’s available is quite thin. Private sector may have data that could help the agency, but then there’s the concern that if you share the data voluntarily, you have a risk of your product being classified as high-risk.

Are there any concerns being expressed in the industry about this approach?

McEntire: There are many concerns that industry is expressing right now, such as, given the limited data, how do you choose which foods to look at? How do you make sure that the analysis of one food can be applied to another food? How can we factor differences in processing and facilities? How will all the data be used? The parameters specify considering outbreaks going back to 1998 – some of this information has changed tremendously, and this will not factor in new regulations under FSMA.

One major concern is how can I get off the list? If you are considered a high-risk food now, but change your methodologies etc., can you get off the list? We need to see another iteration of this proposed rule from FDA to see if this rule can evolve and address some of these concerns.

What are some next steps for high-risk food methodology and what should industry do to prepare?

Acheson: Determining whether a food is high-risk or low risk will depend on the type of data being collected. The agency’s authority to increase demand for data for purposes of better tracking will require more robust data collection on the part of industry. Food companies will need to assess the data sets they are collecting now, and their product tracking system. Consider the IFT report and its recommendations to learn specifically what data should be collected. If a company determines that some of its products are going to be designated as high-risk, then they need to consider what the criteria will be for gaining that import certificate. Is that food being produced according to the standards that FDA is expecting? Pay attention to your foreign suppliers and ensure that they understand the need to be compliant with FSMA rules, and have sound food safety programs in place.

If this rule is a one-way street, where a food can only be moved from low-risk to being designated as ‘high-risk,’ then that would be disappointing and would detract from seeking improvement and rewarding behavior. The rule needs to consider situations when a company puts in specific mitigation steps in place, so can the food then be categorized as low risk?

For more details and to access FSMA Fridays webinars, please click here.

Sustainability and Food Waste: Would You Eat Expired Food?

By Aaron G. Biros
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“Food waste, if it were a country, would be the third largest emitter of carbon dioxide and methane, behind the U.S. and China,” says Doug Rauch, former president of Trader Joe’s. How can innovation in food safety technology and systems help reduce food waste?

Nearly half of all food produced throughout the world is lost to waste every year. Such an enormous amount of waste should motivate food companies to look for innovative ways to reduce waste and become more sustainable.

Food waste is an issue that encompasses the entire food industry, occurring at all stages of food production including harvesting, processing, retail, and consumption. Therefore food safety and quality professionals, because of their connection to the entire food production process, have an opportunity to mitigate waste by introducing a number of sustainable and innovative practices for utilizing otherwise unused food.

Discarded byproducts and material lost throughout the food production process should be viewed as opportunities worth exploiting for every company. Extracting value from normally wasted material allows businesses to increase efficiency dramatically. Incorporating sustainable practices like food waste reduction can present very marketable opportunities to increase margins.

Former president of Trader Joe’s and keynote speaker at the 2014 IFT Conference in New Orleans, Doug Rauch, is a prominent advocate for addressing food waste on a national scale. During his keynote address, he spoke of the immediate need for food waste reduction: “Food waste, if it were a country, would be the third largest emitter of carbon dioxide and methane, behind the U.S. and China.” 

As the global population continues to rise, and developing countries emulate developed countries’ unsustainable production practices, Rauch believes we will begin to see a change of pace. “The next food revolution is going to be about what we’re not eating; it’s going to be about the food we throw away.”

One in six people in the United States are food insecure and obesity has reached record numbers across the country, with some states reaching over 40 percent. In his keynote speech, Rauch cites these figures, correlating poor nutrition to lower socioeconomic status. Rauch launched the Urban Food Initiative to combat poor nutrition with solving the food waste crisis in mind. His idea involves getting expired (or soon to be expired) food to fight poor nutrition in low-income neighborhoods at fast food prices.

Quality and safety play an integral role in the use of food that would normally be discarded. Brian Turner, Senior Manager of Food Safety Information Services at Sodexo, is on the advisory board for the Food Recovery Network, which is an organization that works with college campuses in reducing food waste and hunger. While these programs are very innovative on paper, Turner emphasizes the “concern for procedures and protocol to minimize quality and food safety issues.”

This highlights an opportunity for food safety professionals to help innovate along the way in the processes of reducing waste and hunger, while implementing key quality and safety practices. Organizations and initiatives like these are helping to emphasize the importance of mitigating waste, while addressing other key social and economic problems. In addressing food waste alone, sustainable practices throughout the value chain can be versatile to extend across markets.

Robert Evans, of the Diana Food Division, was a speaker on a food waste panel at the 2014 IFT conference who discussed extracting value from byproducts. Evans believes that “extracting byproducts in the natural food ingredients industry can provide functional solutions around the world and minimize upstream losses to food waste.”

Through involving the entire value chain, from sustainable agricultural practices and raw material sourcing to safe extraction methods, Evans believes that we can bring functional molecules to the market and reduce carbon footprints. Larger food companies are beginning to take action in the reduction of food waste, but innovation needs to occur at a system level across the supply chain to curb wasteful and unsustainable practices. Extracting value from byproducts along with smart sourcing are just some of the sustainable practices being introduced. Food safety and quality oversight at every step along the way is crucial to reducing food waste by ensuring that otherwise wasted products are held to the same quality standards as other ingredients. With that being said, we will continue to see innovation in food safety technology and systems play a dominant role in reducing food waste and utilizing byproducts.

Robert Garfield, Senior Vice President of the Safe Quality Food Institute

SQF – The Road Ahead: Interview with Robert Garfield

By Michael Biros
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Robert Garfield, Senior Vice President of the Safe Quality Food Institute

Food Safety Tech: We’re very excited to have you kick off the SafetyChain/Food Safety Tech GFSI Leadership Webcast Series with your August 22 webinar, “SQF – The Road Ahead” webinar. Can you start by telling us what is new with SQF today? What are some of the things you’ll be talking about in terms of current changes?

Bob Garfield: We’re very busy here. We have a new version of our code, 7.2, which was introduced in the beginning of July. GFSI benchmarks standards every 3 years. Historically, SQF hasn’t waited for every 3 years to revise our code. This is the second time since our last benchmark that we will be revising our code based on the best science and technology that our stakeholders are putting forward. We’re pretty excited about that. We’ve added in some things that we think are important for all suppliers and people using the SQF code to keep them at the leading edge of science, technology, and the needs of buyers. That’s the primary one, but there are a bunch of things that I will be talking about as well in the webcast, including new modules on produce, feed, and pet food.

FST: We’re sure that unannounced SQF audits will be a topic of many questions during the webcast. What are some of the key takeaways attendees will leave the webinar with on this topic?

Garfield: Change is always difficult for some organizations. I understand why, but going through the SQF process is not to just get a certificate on the wall. We know from our stakeholders that it’s a commitment to food safety management, all the time, from the top to the bottom of a facility’s management. A facility needs to be audit-ready all the time, and we believe that the unannounced audit protocol that we are establishing will allow facilities to accomplish that audit readiness goal. We are fully aware that regulators and other food safety stakeholders are more and more looking at unannounced audits as the direction that food auditing needs to take in order to ensure consumers that what we are doing is the best it can be. It’s the most that we can do to ensure the safety of the food supply.

SQFI LogoFST: You will also be talking about the direction of SQF in 2015 and beyond? Is there a “theme” or specific set of business drivers that are driving future changes to SQF?

Garfield: Yes, there is. The business driver that is the primary focus of SQF is exactly what our executive committee from the Food Marketing Institute has told us – that the value proposition for SQF is to improve safety internationally as much as possible. Retailers are the closest that anyone can get to consumers. They believe that the purpose and the scope of SQF has to be continuous improvement to make food safety as close to foolproof as possible.

FST: What are some of the things we’ll learn in the webinar about why embracing change is critical to the ongoing success of SQF?

Garfield: Change is always critical and important. Embracing change is critical to the success of SQF because it is not a stagnant standard. It changes as science and technology evolve. Food safety and food safety management in particular are two areas that are constantly evolving as we learn more about how to protect the food supply chain, and we continuously update the code to make improvements that reflect this. Change is critical to the success of SQF. We are constantly evolving the code – it’s a process that must be ongoing.

FST: We know that you’ll be providing advice on how companies can start today to prepare for tomorrow’s SQF. Can you tell us some of the topics you’ll be addressing in this part of the webinar?

Garfield: To clarify, SQF doesn’t provide advice – we provide guidance with the SQF code. As we continue to evolve the code, we also evolve our guidance to support that process. I’ll be talking about things we do to help our users and stakeholders to evolve their own knowledge. For example, I’ll discuss our advanced practitioner course that we’ve just started to offer to help practitioners gain better understanding and know-how about how to manage food safety at their facilities.

FST: It has been said that SQF certification is a very good start to preparing for FSMA compliance. What are some of the key points you’ll be addressing when it comes to FSMA compliance?

Garfield: It is a good start. SQF is an international code and there are things in the code that are equal to or above what FSMA is requiring. There are also areas that are different. This is why we’ve hired Dr. David Acheson to do a comparison of our code against FSMA’s proposed preventive control and produce rules. Both of these comparisons are available on our website at www.sqfi.com. We’ll be able to make more comparisons/gap analysis when the final rules come out in 2015. As I discussed with FDA, we’ll look at the final rules and see how we match, exceed, or may need to do some work on our particular code if we think it’s appropriate.

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