Matt Inniger

Work Smarter, Not Harder: Data Collection and Analysis Strategies for Small and Midsize Food Manufacturers

By Matt Inniger
No Comments
Matt Inniger

Generating, collecting, and utilizing process data is essential for maximizing the efficiency, quality, and profitability of any manufacturing operation. However, this is a daunting task for most small and midsize food and beverage manufacturers who may not know where to begin with such an initiative or feel as though they don’t have the resources or expertise to use process data effectively. Here we will explore some of the challenges associated with data collection and analysis, what makes the undertaking worthwhile — specifically for small food and beverage manufacturers — and introduce some tools that make collection and utilization of data easier than you might imagine.

How Do You Make Decisions?

We often assume that every business owner has heard the phrase “transforming your business through the power of the cloud” enough times to make their heads explode. And, that anyone who has heard the phrase must understand the value that information brings to businesses of every size and type. I am not of the opinion that this is a valid assumption. So, let’s start from the top.

Food manufacturing facilities, even small ones, must make countless decisions. From production scheduling to workforce allocation, raw material procurement, and process parameters, the decision-makers in any size operation are always running at full throttle.

How often are decisions made? At least every day, and some of these decisions are made multiple times per day. For process or machine parameters, decision making may even be continuous. What is the basis of these decisions? From personal experience, “how things usually go” or “gut feeling” are typical answers. Who makes these decisions? Often it is the owner or CEO, a manager or supervisor, or the person who has been there the longest.

The last answer to that final question highlights what we call tribal knowledge, and it has become one of the biggest problems facing manufacturers across all sizes and sectors. Consistently putting decisions with huge ramifications solely on the personal experiences of a single person is suboptimal for the sole reason that it presents a huge inaccuracy risk. Add to this: demographic changes — that person you’ve relied on for all these years is retiring — and current challenges in employee turnover, and your suboptimal decision-making process has become an unsustainable one. You’re now the manufacturing equivalent of Gauls staring up at Roman aqueducts, wondering how anyone could build anything so marvelous, with the ability to do so having been lost to time.

Even if you’re aware of a tribal knowledge problem, solving it by trying to get Terry to tell you everything he knows before he retires isn’t exactly a foolproof method of solving it. How can you be sure you covered every possible situation? How can Terry even be sure, when he likely doesn’t realize what all goes into the gut feeling he has about process parameters? The best solution is an independent system that collects, organizes, and presents data so that the basis of any decision being made is clear to all stakeholders.

Overcoming Data Collection Challenges

Food and beverage products are biologically complex and fragile, certainly more so than our counterparts in other manufacturing sectors. Some types of measurement can be destructive to food products, or we may be unable to handle products off-line to perform certain tests or measurements. We also operate in an ambiguous regulatory environment, meaning the food safety ramifications of using different types of measurement tools may present an uncertain amount of risk, leading decision makers to perhaps avoid them altogether.

While these challenges are real, there are two main ways in which they can be overcome. First, improvements in sensor technology are making rapid and accurate measurement of important food product characteristics such as pH, color, product weight, moisture content, water activity, and even texture, more attainable than ever with less initial investment. And, while most of the important product characteristics for food and beverages are only measurable with special tools, the same is not true for most of the important process metrics generated by your operations.

Basic process key performance indicators (KPIs) don’t need to be tied to product metrics at all, and getting this type of KPI monitoring up and running for process metrics such as throughput rate, scrap rate, and downtime doesn’t have to involve automatic data collection. Obviously, the increased sampling rate available through automatic collection would be superior, but even one data point per day in each of these areas over several weeks or months provides adequate baseline assumptions for decision-making.

Tools for Collecting and Analyzing Data

There is a belief that utilizing production data for decision making requires absurdly expensive equipment and/or software. That isn’t the case.

While it is true that more robust tools, meters, and equipment that allow for improved data quality and quantity and more useful insights are expensive, they are not necessary for small and mid-sized manufacturers to get started.

One of the best tools for collecting, organizing, and sharing data that is visible to entire organizations is completely free. Google Sheets, or any other cloud-based spreadsheet software, can be incredibly powerful even with just throughput data collected by hand.

Let’s say the production operation you manage has a capacity problem: You can’t make enough product in an eight-hour shift to keep up with demand, and your employees are telling you it’s time to invest $200k in new equipment with a higher nominal throughput rate. What if, before outlaying significant cash up front for that new line, you spent a whole month going out on the floor four times a day and measuring the units per minute that your line is producing, processing, or packaging? Then, when you review those 80 data points, you find that the median throughput when extrapolated to eight hours is almost double the throughput you’re seeing per day on your line. This is evidence that you have a utilization rate problem, not a throughput problem. Now you can make the decision, informed by objective data, to hold off on new capital investment and focus on solving your utilization problem. Using the same spreadsheet, record line stoppages, when each one occurs, why it occurs, and for how long. This additional information will allow you to make transparent decisions on how to reduce stoppages. Remember, this is all free.

There are also a variety of excellent paid tools, even at the entry level, that make collecting and/or processing data substantially easier. Manufacturing Extension Systems (MES) are a type of software platform dedicated to real-time data collection and process monitoring. Most MES software is enterprise-level, highly specific, and therefore correspondingly expensive. A more recent development in this product sector is “no-code” MES systems, which swap complex traditional coding for more streamlined visual application development, meaning small to midsize manufacturers can customize these MES systems themselves instead of paying a large amount to a software vendor to do it for them.

There are a wide variety of no-code MES systems available, and the Center for Innovative Food Technology (CIFT) usually recommends systems that are set up well for incorporating manually collected data streams. We find this essential for our smaller clients who often don’t have the production scale to justify automatic data collection.

Selecting a Use Case

When getting started with process data utilization, it’s important to have a specific problem you’re trying to solve, or “use case.” Focusing on a use case informs design decisions around what data to collect, how often to sample that data, how to analyze it, and how to display it. When selecting an initial use case for a small to midsize food manufacturer, CIFT uses this framework:

  • Go after low-hanging fruit. Start with the most obvious and impactful problems or opportunities that can be solved or exploited using data collection and analysis, such as reducing scrap, increasing yield, or improving quality.
  • Aim small, miss small. Start with a small scope and scale of data collection and analysis, such as a single product, process, or line, and gradually expand to other areas as the results and confidence grow.
  • Early results support buy-in. Start with the stakeholders and decision makers that are most receptive and supportive of data collection and analysis. Share the early results and success stories with them to gain their buy-in and endorsement for further implementation and adoption.

Data collection and analysis are powerful tools that can help small to midsize food manufacturers improve their efficiency, quality, and profitability. These tools do pose some challenges and require some strategies to implement and use effectively. By following some of the solutions and tips that we have discussed in this article, manufacturers can overcome the challenges and seize the opportunities of data collection and analysis to achieve a sustainable, competitive, and innovative edge in the food industry.

Guy Yehiav

Driving Restaurant Food Safety with IoT-Enabled Digitalization

By Guy Yehiav
No Comments
Guy Yehiav

Restaurant operators have a critical responsibility to safeguard the health of their customers. Mitigating foodborne illness must be top of mind today more than ever. The potential risks are too severe to overlook, especially with new FSMA 2026 regulations on the horizon.

Take Netflix’s critically acclaimed 2023 documentary Poisoned for example. It cast a light on the consequential impact that poor food safety can have on restaurant customers. More than 48 million Americans suffer from foodborne illness every year, but it’s not always just a minor stomachache or temporary irritable bowels. In some cases, we’re talking about a matter of life and death. Dr. Darin Detwiler, LP.D., a nationally recognized food regulatory leader featured in the Netflix documentary, learned this reality firsthand after the tragic passing of his 16-month-old son from an E. coli infection caused by contaminated ground beef at a Jack in the Box fast food restaurant in 1993. And his family is not alone — there are 3,000 U.S. deaths from foodborne disease annually, with 1 in 3 afflicting children.

There’s also a business continuity component to consider. While no monetary value can be placed on human life, restaurants must understand the financial and brand reputational risks associated with poor food safety. Jack in the Box suffered approximately $160 million in legal penalties and lost sales as a result of the E. coli outbreak — and that was in the early 1990s. That is equivalent to about $350 million today. For a more recent example, Chipotle’s 2016 E. coli outbreak caused 43 restaurants to close, eroded over 45% of the company’s stock value, and resulted in a $6 billion loss in market cap. It underscored the criticality for restaurants to execute on food safety and the financial consequences of failing to do so.

In 2024, safeguarding restaurant customers from foodborne illness will require a shift away from legacy approaches in favor of IoT-enabled digitalized food safety strategies. The integrated use of IoT Sensing-as-a-Service frameworks throughout restaurant facilities provides the operational efficiency, real-time visibility, and data-driven decision making essential to preserve customer health. These frameworks combine IoT sensing and monitoring functions with the power of AI-driven prescriptive analytics to automate fundamental food safety processes such as condition monitoring, task management, compliance reporting, and asset protection. These tools enable the average person to comply with regulation and keep the client safe.

Compounded at scale, they enable restaurant operators to foster a culture of food safety accountability at every level of the enterprise and align with the oncoming realities of FSMA 2026.

FSMA 2026: A New Era on the Horizon

The FSMA 2026 regulations have raised the stakes for restaurant operators to enhance their digital food traceability capabilities. The new rulings will require them to provide verifiable data records of Critical Tracking Events (CTEs) across key hand-off-points of the food chain where products are at risk of spoilage. For example, that could be seafood containers transferred from a distribution truck to a back-house freezer or leafy greens inside a salad bar right before the point of consumption.

Restaurant operators must be able to prove that FSMA 2026 products remained in optimal conditions during critical control points. They will also be required to present an electronic traceability plan that clearly describes their procedure for maintaining records for the foods they handle. In the case of a foodborne illness outbreak at the restaurant, the operator must be able to present traceability records to the FDA within 24 hours if requested.

Maintaining compliance at this granular level requires agile food chain technology. Operators who haven’t invested in digitalization yet should be prioritizing it now ahead of FSMA 2026. It’s impossible for an enterprise to manually record accurate FSMA data across 40 or 50 locations without automation. Manual data logs are often siloed, incomplete, and hindered by human error. Adopting IoT Sensing-as-a-Service frameworks will be critical to preparing for the uncertainty ahead.

Real Time Condition Monitoring

IoT Sensing-as-a-Service frameworks empower operators to collect, analyze, and act on inventory data for a stronger food safety posture. Placed inside a restaurant’s food storage assets, IoT sensing and monitoring devices allow employees to remotely monitor their environmental settings in real time to confirm HACCP compliance standards are maintained. The devices also monitor the performance of those storage assets, automating the detection and prediction of maintenance issues that could lead to an illness-causing event. 

The raw data collected from each individual IoT device flows through a prescriptive analytics platform with continuous telemetry feedback loops that identify potential risks and prescribe mitigation actions. Based on the data-driven insights, restaurants can take the proper steps to ensure their products remain safe to consume.

Leveraging Digital Checklists

Digital checklists are another key component of the IoT Sensing-as-a-Service framework, helping to simplify the complexities of task management within a hectic back-of-house restaurant environment. Serving as an operational execution platform, these checklists enable operators to gain unprecedented visibility into employee efficiency and food safety initiatives. Managing workflows for multiple locations is exceedingly easier, allowing operators to monitor enterprise-wide food safety as quality performance alongside location-specific metrics. And with access to the right prescriptive tasks at the right times, employees can proactively enhance the safety of high-risk menu items such as poultry, leafy greens, and eggs that require stringent temperature-sensitive storage conditions.

In the past, restaurants would respond to incidents after the fact while leveraging unreliable paper-based records to explain what had gone wrong. While this level of manual task management is near impossible to analyze at scale, digital checklists help realize the benefits of a proactive food safety strategy, generating visibility into compliance and operational procedures, regardless of scale, while unlocking insights that prevent foodborne incidents from arising in the first place.

Francine Shaw, Savvy Food Safety, Inc.

Preventing Foodborne Illness Outbreaks

By Francine L. Shaw
No Comments
Francine Shaw, Savvy Food Safety, Inc.

Recent outbreaks of norovirus on cruise ships and in foodservice settings have highlighted the need for more stringent measures to prevent and mitigate the spread of foodborne illnesses. Cruise ships are particularly vulnerable to outbreaks of norovirus due to the large number of people in close quarters and the ease at which this virus spreads.

Norwegian Cruise Lines (NCL) began using hypochlorous acid (HOCL) during the coronavirus pandemic. HOCL is an effective method for eradicating many viruses and pathogens, including COVID-19 and the FDA’s reportable “Big 6” highly infective pathogens: Norovirus, the Hepatitis A virus, Salmonella Typhi, Shigella spp., Shiga toxin-producing E. coli and nontyphoidal Salmonella. According to the CDC’s website, NCL has not had a norovirus outbreak since their implementation of HOCL.

The increase in reported norovirus outbreaks, as revealed by CDC’s NoroStat data, underscores the escalating threat posed by this highly contagious virus. With 519 outbreaks recorded between August 1, 2023 and January 15, 2024 — a sharp rise from the previous year’s numbers — the need for proactive measures to curb its spread is evident. Similarly, the surge in Hepatitis A cases, a vaccine-preventable illness that has led to a concerning number of hospitalizations and fatalities, necessitates a closer look at preventive strategies in foodservice settings.

Salmonella, another common culprit in foodborne illness outbreaks, has recently affected hundreds, highlighting the need for more stringent food handling protocols. To mitigate the risk of outbreaks, food businesses should implement and train employees on:

Frequent Handwashing. Emphasize the importance of thorough, proper handwashing among employees to prevent the spread of contagious illnesses such as norovirus. Proper hand hygiene, especially after using the toilet and before handling food, is crucial in maintaining a safe environment. Remember that the purpose of alcohol-based hand sanitizers is to use them as an added precaution. They do not kill non-enveloped viruses such as norovirus.

Surface Sanitization. Implement rigorous sanitation and disinfection practices to reduce the risk of pathogen contamination. Regularly sanitize surfaces, equipment, and high-touch areas to maintain a hygienic environment. Items must be clean before they can be sanitized. It isn’t possible to sanitize dirt.

In addition to HOCL, quats (quaternary ammonium compounds) are approved sanitizers. They have been the food service industry “go to” for years and they are effective. However, research has linked quat exposure to health concerns including asthma, dermatitis, inflammation, infertility and birth defects. There are also concerns that they harm aquatic life and contribute to antimicrobial resistance. Another potential, often overlooked, concern is the issue of quat binding if these chemicals are not used correctly. When used with a cotton or rayon cloth to sanitize surfaces, a bond between the material and the quaternary ammonium is formed. This reduces the concentration of the sanitizer reaching the food contact surface. To reduce this risk, quats should be used with the manufacturer-recommended cleaning cloth.

Food irradiation utilizes ionizing radiation to treat food. It helps to prolong shelf life by reducing the presence of microorganisms and insects. Comparable to the pasteurization of milk and the canning of fruits and vegetables, irradiation contributes to the overall safety of food consumption. The FDA regulates the sources of radiation employed in food irradiation.

Proper Produce Handling. Wash and sanitize fruits and vegetables to eliminate contaminants and reduce the risk of foodborne pathogens such as listeria and salmonella. HOCL can be used as a “kill step” for these foods. Any food suspected of contamination must also be discarded to prevent outbreaks.

Safe Seafood Handling. Ensure that seafood, particularly shellfish, is cooked thoroughly to eliminate noroviruses that may be present. Adhering to proper cooking practices is also essential in safeguarding against foodborne pathogens.

Employee Health Policies. Prohibit sick employees from handling food to prevent the spread of illnesses. Encourage sick employees to stay home and adhere to strict return-to-work guidelines to safeguard against potential contamination.

Proper hygiene, cleaning and sanitation are of paramount importance in food businesses. Combining these protocols with emerging technologies, such as IoT and AI to monitor food products and identify and predict risks, is vital to navigating the challenges of food safety, and ensuring safe products.

Nicole Keresztes James

Five Tips to Prepare for Your Next Audit

By Nicole Keresztes James
No Comments
Nicole Keresztes James

For food manufacturers, passing a third-party food safety and quality audit supports both business growth and the ability to obtain new customers. Many retailers have made certification to a GFSI-benchmarked standard a minimum requirement of their suppliers. Working towards compliance with a third-party audit, let alone a GFSI-benchmarked certification, is a journey that requires significant preparation. Understanding the typical mistakes companies make on this journey, and taking action to avoid them can go a long way in properly preparing for and successfully passing the audit. Here are five essential tips to help businesses prepare for a food safety audit.

1. Start Early

Procrastination is on one of the most common causes of an audit failure. Starting the preparation process too late can cause significant challenges. The first step in preparing for an audit should be to set a timeline well in advance, identifying key checkpoints and milestones to ensure activities meet compliance.

If you have the option, choose an audit standard that fits with the facility and meets the end goal. Some questions to ask in your selection process include:

  • Is the certification to a GFSI-benchmarked standard required?
  • Is a completed third-party food safety and quality audit sufficient?
  • Is a customer-specific audit needed?

Once you’ve decided on the audit standard, select a third-party certification body or audit firm to deliver an audit to the standard’s requirements. Ensuring that the certification body or audit firm you choose is qualified to conduct the audit (e.g., accredited or approved by the standard) is crucial.

Next, secure a copy of the selected standard. With GFSI-aligned programs (including GFSI and non-GFSI benchmarked standards), standard expectations are available freely and directly from the certification program owners. In the case of proprietary third-party audit and customer standards, the chosen certification body or audit firm can assist with providing the necessary expectations.

2. Get Up to Speed

It is extremely important to thoroughly review and familiarize yourself with the standard or expectations manual, especially if the standard or manual is new to the facility. If the audit is a reassessment, ensure you have the most recent version of the standard or manual and thoroughly read it, as updates may have been made since the last audit.

Subscribe to the Food Safety Tech weekly newsletter to stay up-to-date on the latest food safety and regulatory news.

One mistake we sometimes see is failing to designate an internal core team for the audit. Doing so can help ensure the timeline is followed and critical tasks are assigned accordingly. If you are doing a reassessment, ensure that all internal organizational changes have been documented and that organization charts and rosters have been updated.

For reassessments, it’s also important to revisit any nonconformances from previous audits and the reports of any other assessments or internal audits completed. Doing so ahead of time can confirm that corrective actions have been fully implemented and preventive actions put in place, minimizing the recurrence of nonconformances.

3.Complete a Self-Assessment

Conduct an internal audit using the audit standard or expectations manual to identify compliance gaps. Address any deficiencies through corrective actions, focusing on areas such as sanitation and cleanliness, facility condition, pest management programs and maintenance protocols. Looking at each of these areas, identify and address opportunities for improvement. Issues in these areas are very often cited as nonconformances during audits.

Before the audit, meet with your third-party service providers to ensure programs are up to date and that there is awareness of any issues. Even when programs, such as pest control, are outsourced to third-party organizations, the facility remains responsible for overseeing such programs.

4. Prepare Documentation and Ensure Implementation

Documentation is critical for audit success. Ensure a comprehensive review of your food safety systems (e.g., HACCP and FSMA PC) to ensure that they are current and valid. Review the efficiency of your process implementation and verify that the documentation and processes are aligned.

Training is a must-have for audit compliance; therefore, confirm that internal training has occurred and been documented. This includes training not just for the team escorting the auditor during the audit but for all employees, as during the visit employees in functions key to the audit’s scope may be called on by the auditor to answer questions. Remember, well-trained employees are confident in conducting and describing their processes and how they connect to food safety and quality. They must also follow the procedures as stated in the documented programs and policies.

5. Collaborate and Ask for Help

Failures occur when assumptions are made. Many audits are unsuccessful because facility management and employees assume they understand and have implemented the necessary requirements.

When in doubt, ask for help. As stated above, preparing for any audit is a significant undertaking. Expert resources can help with that preparation and assist with avoiding gaps and the rework that occurs when expectations are not clearly understood. Check with the certification body or audit firm that has scheduled the audit—many will offer separate consulting and training services to help with audit preparation.

It is important to note that one facility is just one point in the overall supply chain and that stakeholders include both suppliers and customers of the facility. These suppliers and customers can play a role in the success of an audit. Ensure that communication with all involved parties is part of the preparation.

Keep the Momentum Going

Once you complete an audit, celebrate and congratulate the team. At the same time, remember that the work doesn’t end once the audit is complete. Even after completing the corrective actions, you should start preparing for the next audit by keeping documents and records updated. Adequate food safety and quality assurance are only possible when activities connected to these concepts are carried out every day. Keeping compliance top-of-mind daily has the additional significant benefit of always being audit-ready.

As the adage says, “Fail to plan, plan to fail.” This certainly rings true with audit readiness. However, it is key to remember that an audit is merely a data point on the spectrum of a robust food safety and quality system that is constantly evolving and improving. This comprehensive system does not come about just because there is an audit to plan for. It is a product of daily work to ensure that procedures and policies are being followed and a cross-functional team that is striving to make a facility’s food safety culture stronger and ever more capable of preventing food safety and quality incidents.

Sayed M Naim Khalid

The Imperative for an Integrated Food Safety Management System

By Sayed M Naim Khalid
No Comments
Sayed M Naim Khalid

As the global food industry continues to evolve, the importance of ensuring food safety has never been more critical. Various standards and certifications, such as GFSI, Organic, Global GAP, HACCP, and ISO standards, have been established to address different aspects of food safety. However, the proliferation of these diverse standards pose a significant challenge — especially for small businesses — in terms of cost, complexity, and overall compliance. In this article, we will explore the need for an integrated food safety management system (FSMS) that consolidates these standards into a comprehensive and unified framework.

Current Challenges in Food Safety Standards

The food industry is subject to a multitude of regulations and standards, each designed to address specific concerns related to food safety. The Global Food Safety Initiative (GFSI) aims to harmonize and strengthen food safety standards across the supply chain. Similarly, standards like Organic, Global GAP, HACCP, and ISO provide guidelines for organic production, agricultural practices, hazard analysis, and quality management systems, respectively.

While these standards individually contribute to enhancing food safety, their coexistence often imposes a heavy burden on businesses, particularly smaller ones. Each standard necessitates a separate certification process, involving costs related to preparation, audits, and ongoing maintenance. This fragmented approach can be overwhelming for businesses, leading to inefficiencies and potential gaps in compliance.

Cost Implications for Small Businesses

Small and medium-sized enterprises (SMEs) in the food industry face a unique set of challenges when it comes to adhering to multiple food safety standards. The financial implications of obtaining certifications for each standard can be prohibitive. For instance, a small-scale food producer dealing with organic products may also need to comply with GFSI standards for global market access.

Certification costs — including consulting fees, documentation, and audit expenses —  quickly accumulate. Moreover, the need for ongoing compliance monitoring and updates can strain the already limited resources of smaller businesses. This situation raises concerns about the equitable access to global markets for businesses of all sizes.

The Role of an Integrated Food Safety Management System

The call for an integrated FSMS is rooted in the idea of streamlining and unifying the various standards to create a more accessible and efficient framework. By integrating these standards, businesses could achieve a single certification that covers multiple aspects of food safety, reducing the financial and administrative burden.

Integration can lead to a more cohesive approach to food safety, eliminating redundancies and ensuring a holistic understanding of potential risks throughout the supply chain. This not only simplifies the certification process but also facilitates better communication and collaboration among stakeholders, including producers, processors, distributors, and regulators. Benefits of an integrated FSMS include:

  • Cost Efficiency. An integrated FSMS would significantly reduce the costs associated with multiple certifications. Businesses can allocate resources more efficiently, making certification attainable for a broader range of enterprises.
  • Simplified Compliance. Streamlining standards into a unified system simplifies compliance efforts. Businesses can focus on meeting a comprehensive set of requirements rather than navigating the intricacies of various individual standards.
  • Enhanced Food Safety. Integration ensures a more comprehensive and interconnected understanding of food safety risks. This can result in a more effective preventive approach, addressing potential hazards at various stages of the production and distribution process.
  • Global Market Access. A single, globally recognized certification can facilitate market access for businesses, especially SMEs. This reduces barriers to entry and fosters fair competition in the global marketplace.
  • Improved Collaboration. Stakeholders across the supply chain can better collaborate when operating under a common framework. Enhanced communication and information sharing contribute to a more resilient and responsive food safety ecosystem.
  • Adaptability to Emerging Challenges. An integrated FSMS can be designed to incorporate emerging challenges and adapt to evolving risks in the food industry. This flexibility ensures that the system remains relevant and effective over time.

Challenges in Implementing an Integrated FSMS

While the benefits of an integrated FSMS are evident, the transition from the current fragmented system to a unified framework is not without challenges. Some potential hurdles include:

  • Resistance to Change. Stakeholders accustomed to existing standards may resist the shift towards integration. Overcoming resistance through education and awareness campaigns is crucial for successful implementation.
  • Technical Harmonization. Ensuring technical harmonization across different standards requires meticulous planning and collaboration. Consensus on common terminology, risk assessment methodologies, and other technical aspects is essential.
  • Regulatory Alignment. Coordinating with regulatory bodies to align an integrated FSMS with existing regulations is necessary. This involves addressing legal and regulatory challenges to ensure widespread acceptance.
  • Resource Allocation. Developing and implementing an integrated FSMS requires significant resources. Small businesses, in particular, may need support and incentives to make the transition feasible.
  • Global Acceptance. Achieving global acceptance of an integrated FSMS may take time. International cooperation and agreement on common standards are vital to ensure recognition across borders.

The need for an integrated food safety management system is evident in the face of an ever-evolving food industry. As standards such as GFSI, Organic, Global GAP, HACCP, and ISO play crucial roles in ensuring food safety, their integration into a comprehensive framework is imperative. The benefits, including cost efficiency, simplified compliance, enhanced food safety, global market access, improved collaboration, and adaptability to emerging challenges, make a compelling case for the adoption of an integrated FSMS.

While challenges in implementation exist, the long-term advantages for businesses, consumers, and the industry as a whole outweigh the difficulties. Governments, regulatory bodies, industry associations, and businesses should collaboratively work towards the development and adoption of an integrated FSMS that strengthens food safety practices, fosters innovation, and promotes equitable access to global markets. In doing so, the global food industry can move towards a more unified and resilient future, ensuring the safety and quality of food products for generations to come.

Paul Damaren

The New Era of Quality Management Solutions

By Paul Damaren
No Comments
Paul Damaren

Food businesses must prioritize safety and quality by taking every known precaution to protect their foods, customers, employees, and businesses. The most effective way for food brands to ensure safety, quality, and compliance is to use technology to elevate their quality management programs.

Technology, including artificial intelligence (AI), the Internet of Things (IoT), blockchain, and machine learning, can make food significantly safer by improving food safety protocols, quality control, compliance, and supply chain management.

The Importance of Quality Management

Whether you’re a processor, manufacturer, distributor, retailer, or other food business, you must ensure that your safety and quality practices are consistent and properly maintained. And you must confirm that all employees follow gold standard safety protocols to minimize risks and maximize safety. But that isn’t enough on its own. You must also manage your entire supply chain to be certain that foods are safe and proper protocols are followed through every step of the journey.

Businesses need to maintain high-quality standards while also scaling production, introducing new products, providing exceptional customer service, and meeting evolving consumer demands. That’s no small feat! Fortunately, several tech tools now exist that can help food brands elevate their quality management programs and safety efforts.

Quality Management Tools Have Improved Dramatically

The way that organizations manage their food safety and quality programs has improved significantly over the years. Savvy food businesses have ditched their manual paper systems due to drawbacks such as being unable to provide real-time, integrated data across an enterprise. Manual systems also come with compliance risks, as employees could do sloppy or incomplete work on inspections, audits, and safety checks — or skip them altogether. Tech solutions offer more efficient and accurate ways to conduct and track quality management programs.

Food businesses should rely on digital quality management solutions that:

  • Are made specifically for the food sector, addressing food brands’ unique challenges and needs.
  • Are comprehensive, offering audit management, compliance tracking, risk assessment, supplier quality management, and quality control in one easy-to-use solution.
  • Include mobile auditing features to enhance on-site inspection efficiency, which is crucial for maintaining quality in fast-paced environments.
  • Feature compliance and reporting capabilities to ensure adherence to the latest regulatory requirements.
  • Allow brands to manage their suppliers, ensuring everyone is committed to the highest safety and quality standards, as any weak link in the supply chain can jeopardize the integrity of the food, leaving end-users vulnerable.

Technologies To Elevate Quality Programs

The integration of technology in the food sector has been exciting, and we have learned much about which technologies offer the greatest benefit. Some of the most valuable solutions include:

  • Busy food brands can leverage automation to reduce administrative burdens and time-consuming tasks and improve efficiency, consistency, accuracy, and productivity.
  • AI and machine learning. These solutions offer predictive maintenance of equipment, quality control, and yield optimization, and give business owners critical, real-time data to drive more informed decision-making. Additionally, machine learning algorithms can predict food safety risks based on various parameters, such as storage conditions and handling.
  • IoT devices monitor safety and quality parameters, including temperature, humidity, and vibration to identify and either resolve or alert companies to safety and quality risks. IoT provides constant feedback, so food brands can quickly prevent (or remediate) safety breaches and quality degradation.
  • Blockchain can provide food authentication through increased transparency and enhanced food traceability. Food brands can leverage blockchain technology to ensure the food they’re getting is safe, authentic, and high-quality. Blockchain can trace food back to its source to prevent food fraud, increase food safety, and improve recalls in the event of a safety breach.

A New Era of Food Safety & Quality Software

As these technologies have made their way into the food industry, we are seeing continuous improvement in quality management tools, including:

  • More comprehensive functions. When multiple functions are packaged together in a single intuitive solution, it allows food brands to streamline their quality management processes, aligning with industry-specific requirements.
  • More robust compliance management. Additional compliance management features help brands better understand ever-evolving regulations and adhere to stringent safety standards. And that’s reassuring for customers and end-users, including the retailers that sell the products, the restaurants that serve them, and the consumers that eat them.
  • Focus on supply chain management. Supply chain management has seen a technological overhaul around quality assurance, providing more transparency and traceability from farm to fork. Focusing on every point across the supply chain is crucial in an industry where the quality of the end product is directly influenced by the quality of the sourced materials.
  • Mobile auditing. Mobile auditing solutions within quality monitoring programs allow organizations to facilitate real-time data collection and reporting, a critical factor for onsite inspections in food production, processing, manufacturing, and retail environments.
  • Accessible for all. As tech solutions have become more affordable, accessible, scalable, and user-friendly, they have become more attainable for food businesses of all sizes and budgets. While some brands may worry that digital quality management solutions require significant investment, think of the ROI you’ll receive by avoiding brand damaging and expensive safety and quality breaches.

Digital quality management solutions have become essential for every food business, allowing brands to avoid costly, damaging breaches. Food businesses would be wise to adopt and embrace this new era of quality management solutions to maximize safety, minimize risks, and demonstrate their commitment to quality and compliance.

Emily Newton, Revolutionized Magazine

Technologies To Prevent Microbial Contamination in Dairy Production

By Emily Newton
No Comments
Emily Newton, Revolutionized Magazine

Although milk is among the most regulated food products in the nation, microbial contamination remains a long-standing pain point. Milk products can become tainted at every stage in the production process. Microbial contamination renders farmers’ yields worthless, sharply increases production facilities’ financial losses, and backs up production.

Early spoilage is likely if microorganisms such as Pseudomonas fluorescens and Streptococcus aren’t caught in time. Illnesses caused by Listeria monocytogenes, E. coli and Campylobacter will occur if timely recalls are not issued. In the event of a recall or contamination event, the brand’s reputations and relationships with manufacturers will be damaged, and affected consumers may seek legal or regulatory action. Fortunately, emerging dairy industry technologies can help prevent microbial contamination in novel ways.

Common Microbial Contaminants in Dairy Production

Microbial contaminants take many forms in the dairy industry, as milk’s complex biology can conceal pathogenic molds, bacteria, and yeasts. Listeria monocytogenes, E. coli, Campylobacter and Pseudomonas fluorescens are some of the most common microorganisms present in dairy products.

Biofilms — microbial cells that adhere to a surface to reproduce — are a relatively overlooked source of contamination. Biofilms can persist on equipment throughout the processing chain and lead to continuous contamination, if left unchecked, highlighting the importance of proactive cleaning and maintenance.

Sources of Microbial Contamination in Dairy Production

Microbial contamination can come from dairy cattle, transport, equipment, and production staff. Virtually every stage in the process — from farmer to consumer — offers opportunities to introduce a potentially lethal contaminant.

Water used during handling and processing is one of the most prominent sources of microbial contamination. Microorganisms present in the water can contaminate food manufacturers’ equipment, tainting every product in a batch. Additionally, dairy cattle may drink from sources with high bacterial loads and produce unclean milk. Dairy cattle can consume or interact with microorganisms that cause infections and diseases. Mastitis — often caused by E. coli, Streptococcus dysgalactiae and Streptococcus uberis — is a common disease in dairy cows that can lead to production of tainted milk.

Dairy farmers who attempt to remedy dairy cattle’s ailments could cause further issues. While labs often catch and reject antibiotic-resistant bacteria, their methods are not 100% accurate. These failures highlight the need for thorough detection and treatment methods.

If milk makes it to a facility untainted, poor facility management can lead to contamination. Equipment covered in biofilm or immersed in liquids with high bacterial loads will taint the product on the production line. Poor or inadequate hygiene practices among production staff, such as wearing contaminated shoes or forgetting to wash their hands, can also lead to contamination of milk products.

Technologies That Combat Contamination

Research teams and industry experts have been working hard to develop new technologies to reduce the risk of microbial contamination. Following are some of the novel dairy industry technologies that are making products safer from farm to fork.

Ultrasonication. Ultrasonication cavitation is an emerging technology that can help to prevent microbial contamination. This noninvasive treatment method is cost-effective and environmentally safe to deploy. It can measure microorganisms in milk products, destroy microbials, reduce allergens, and improve enzyme inactivation. 

Thermal Biosensors. Researchers recently developed a thermal biosensor capable of onsite microbial detection. They describe it as an easily scalable, cost-effective prescreening tool. The sensor identifies high bacterial loads including Klebsiella pneumoniae and Staphylococcus aureus. It is most effective when used in tangent with other methods and technologies.

Pulsed Electric Fields. A pulsed electric field (PEF) is a nonthermal treatment that disrupts microbial growth. It uses irreversible electroporation to target and interrupt microorganisms’ reproduction while preserving milk products’ nutritional and sensory characteristics. However, researchers note that PEF-treated dairy might have a shorter shelf life.

Cold Plasma. Cold plasma is a coating technology that inhibits biofilm formation and repels microorganisms. It can detect toxins and improve enzyme inactivation. One case involving sheep’s milk resulted in a 94.2% reduction in bacterial count. Dairy production facilities can also use it to decontaminate and sterilize equipment. Notably, it causes less degradation over time than wet chemical treatments.

Emerging Technologies Entering the Dairy Industry

In addition to the technologies mentioned above, there are two emerging technologies that may reshape how the dairy industry addresses risks of microbial contamination:

Patch-Based Biosensors. Researchers have developed a new patch-based device to prevent microbial contamination. All food manufacturers must do is place this tasteless, food-safe sticker inside their containers. An internal biosensor then detects and repels unwanted microorganisms automatically. This technology can be modified for specific pathogens.

While this technology is still in development, multiple peer-reviewed studies have highlighted its capabilities. Some variants of the patch-based biosensor can react to bacterial growth within 72 hours or less. Various research teams have created mechanical, electrochemical and bioluminescent sensors to explore this technology’s full potential.

Electron Beam Irradiation. Electron beam irradiation (EBI) is a nonthermal treatment that has numerous advantages over traditional thermal decontamination methods. It is faster, more environmentally friendly and has a lesser impact on milk products’ nutritional values.

Although EBI is new to the dairy industry, it has a long history as a food production and agriculture sterilization tool. The FDA evaluated it for three decades and deemed it safe, approving it for numerous applications. With further testing, milk products will soon follow suit.

EBI decreases contamination in raw milk samples by inactivating potentially harmful pathogenic bacteria. It reduces microbial infection risks to fewer than one out of 9.7 million people when processing at a 2 kGy dose. It leaves no chemical residues and does not alter products.

This technology has the potential to drastically reduce the microbial load in milk products while maintaining desired characteristics. Although EBI lowers the vitamin B2 content of pasteurized milk by about 32%, it remains within the USDA’s nutritional guidelines. EBI’s effectiveness increases substantially if production facilities combine it with other tools.

Most professionals understand new, advanced tools are essential. Realistically, conventional methods are quickly becoming outdated and pose significant safety gaps. Production facilities that leverage the latest dairy industry technology can prevent microbial contamination to deliver safer products to processors and consumers

Olvia Pitts

Internal Audit Planning: The Key to a Successful Audit Program

By Olivia Pitts
No Comments
Olvia Pitts

The first step in internal audit planning is to understand the process and the available resources. The format and structure of the internal audit program will vary between organizations. Factors such as company size, culture, and staffing play a significant role in the development of the program structure. Auditing requires time and commitment to be effective. Top management should be involved in this process to ensure there is a clear understanding of the level of commitment needed across the site. This activity can be incorporated into annual strategic planning meetings or through the management review process. Participants should include members of top management and relevant support staff.

Once the team is gathered, discuss the options and identify the preferred structure. This is a great time to discuss needed resources and identify a point person to oversee the program. Though not a standard requirement, identifying someone to manage the program provides high-level visibility of the overall effectiveness. Responsibilities may include oversight of internal audit scheduling, auditor training, and maintenance of records. Having someone dedicated this role will help to ensure that the program is being managed as expected.

Continuing education around the process is vital to ensure everyone is in alignment. This includes education for both top management and plant staff. All employees should be aware of the audit program activities regardless of their level within the organization. Developing a format for driving awareness helps to reduce any fears around participation in audits as an auditee. Individuals who are unaware of the format and structure will often avoid being interviewed for fear of saying the wrong thing. These types of issues can be resolved by sharing the message that internal audits are a way to improve current processes and procedures. They are not intended to be a fault-finding activity but rather a way to grow.

Business is constantly changing thus resulting in events that may impact the internal audit program. A process review is not a one-time activity. Be sure to set aside time, at least annually, to review the overall format and structure of the program. Identify areas that need improvement and celebrate areas of success. Remember the program needs to work for each individual organization. Adapting and changing to fit the needs of the team should be expected, especially in the early days of the internal audit program.

Utilize Auditing Tools

The proper adoption of auditing tools will provide significant benefit across the auditing program. Tools often used in auditing include the sitewide audit schedule, audit plans, and audit checklists. By implementing these tools, the audit program becomes streamlined reducing confusion and driving the program to success.

Audit scheduling is made up of two parts. It includes the overall schedule for the entire organization and the individual audit schedule otherwise known as the audit plan. The sitewide audit schedule should encompass each functional area within the scope of the management system, while the individual audit plan should detail the specific areas being audited. Developing these two documents requires input from the entire management team. This should not be a task that is undertaken alone. Involving team members aids in spreading awareness of the needs and expectations around the audit program. The management team should be provided with clear expectations around the timing needed for each audit. This information not only allows the plant staff to prepare for visitors within their areas but also establishes a collaborative approach to internal auditing. When determining the timing for each of the audits, the team should provide an overview of what processes and records will be reviewed and the number of interviews needed. This information provides an outline for time and resources needed for each audit. Considerations should be made for unexpected delays or the need for special accommodation requirements due to production demands. This may require scheduling during specific times or bringing in additional support staff to support the production lines during the audit. By taking time to review potential issues upfront, the risk of audits being cancelled or delayed is greatly reduced.

For those areas identified as potentially challenging it’s a good idea to build the sitewide schedule so that it allows for flexibility. This may include scheduling higher risk audits earlier in the year to build in more time, or allowing the department manager to provide the preferred audit dates. When developing the schedule be careful not to overload with an extensive number of audits. There should be an adequate balance to avoid potential issues. The auditing structure can be set up in a variety of formats. Some organizations choose to audit by department, while others prefer reviewing by process to capture a cross-functional view. Both formats can be used to confirm conformance to established requirements. Identify the requirements and the records needing review to determine the logical format for the organization. The key is to allow ample time to cover the entire scope of the individual audit. Keep in mind additional time may need to be built into areas that require lengthy transit times to arrive in the audit area.

Once the overall audit schedule has been established, the next step is developing an audit plan. This critical step is often overlooked to save time; however, having an audit plan is the true time saver. It helps to set the framework for the audit and aids the auditor in developing a clear understanding of what needs to be reviewed. A well-developed audit plan will include a timeline, processes being audited, auditee and applicable standard or internal documentation references. By outlining this information, the auditor will develop a clear path for the audit. The audit plan can also be shared with auditees to provide communication around expectations and requirements going into the audit.

The audit checklist is another valuable tool available to the auditor. A checklist should include such details as the scope, objectives, focus area and questions for the auditee. This tool helps the auditor stay focused and remain on track throughout the audit. Once developed, audit checklists can be reused and adapted for future audits. The checklist should be written to focus on the overall process being audited. Be sure to include both standard requirements and requirements related to internal processes and procedures of the organization. A well-developed checklist contains a mix of process specific and high-level management system questions focused on the overall system. The high-level questions can target such areas as quality policy, quality objectives document control and continual improvement. By creating and reviewing the audit checklist prior to the audit the auditor will be prepared and efficiently utilize their time.

Support the Audit Team

The most effective way to support the audit team is to ensure top management finds the audit program beneficial to the organization. Strong support from top management will empower the audit team and encourage them to drive change. When developing a new internal audit program ensure that the top management team is aware of the resources needed to develop the program. Help them to understand the time commitment and explain any disruptions the audits may cause in the daily activities. By communicating this information up front the risk of audits being delayed due to constraints related to management will be significantly reduced. As the program progresses, provide updates on status of the audits and actions implemented. This will help to reinforce the continuous improvement mentality and demonstrate the value of the program.

Holding frequent meetings with the audit team will help to drive the importance of the audit program. It will also help to identify potential issues with scheduling and clarify any misunderstandings. These meetings can also be used to educate auditors about the standard or internal requirements. Limit the meeting to an hour or less to maintain the interest of the audience. As auditors work through the audit process, they may need additional help preparing audit plans and audit checklists. Encourage the team members to work together and learn from each other. Becoming a skilled auditor takes practice. Encourage the audit team at a minimum to participate in audits quarterly. As the team grows, provide feedback on their progress and achievements that have been accomplished. Feedback is crucial in building the confidence of internal auditors and the overall audit program.

Providing communication and awareness to the entire organization around the audit program is an important element of supporting the team. Many employees know little about the program unless directly as a part of their role. Auditing requires an extensive amount of work and time commitment. Often the role is voluntary or an addition to the employee’s current role. It’s imperative that the management team acknowledge the workload required of those asked to conduct and participate in audits. This will provide the auditors and auditees with a sense of appreciation for their efforts, thus resulting in a workforce with a committed focus on continual improvement.

Be Consistent

Developing a strong internal audit program does not happen overnight. Instilling audit planning into the internal audit program will provide organization-wide success. Ensure that the team has a full understanding of the process and encourage the use of auditing tools across the organization. When issues occur be willing to change course and adapt as needed. Internal audit programs are ever changing and will need consistent maintenance to be the most effective. Through the support of top management and the utilization of these valuable concepts a strong foundation can be established. Be consistent and positive results will follow.

Liz Figueredo

Preparing for the USDA Strengthening Organic Enforcement Rule’s Implementation

By Liz Figueredo
No Comments
Liz Figueredo

Businesses in the organic food supply chain have just weeks to prepare for the upcoming implementation of the United States Department of Agriculture (USDA)’s Strengthening Organic Enforcement (SOE) Rule. This updating regulation, which goes into effect on March 19, 2024, aims to fortify the integrity of USDA organic products. From manufacturers to retailers, businesses across the supply chain must adjust their procedures and practices to comply with the updated rule.

The SOE Rule calls for the implementation of more rigorous certification practices for various types of businesses, including key links in the organic supply chain such as importers, exporters, brokers, traders and storage facilities. Because these organizations have not historically been required to be certified, it’s likely there will be an increase in last-minute organic certification applications. To accommodate the incorporation of these new entities, USDA-accredited certifying agents are now offering expanded services, including on-site inspections with enhanced authority to prevent fraud and non-compliance.

Changes Throughout the Supply Chain

Business activities that encompass any form of aggregating, culling, packaging, repackaging, storing or related processes of USDA organic products are now required to obtain certified organic status. In addition to a broader spectrum of handlers throughout the supply chain requiring certification, low-risk businesses in the exempt category must still adhere to stringent contamination prevention protocols and maintain meticulous records. This underscores the integral role of record-keeping and anti-fraud systems throughout the supply chain. To find out if your business should seek organic certification, try NSF’s interactive online decision tree tool.

Next Steps to Compliance

The USDA estimates that 1,000 domestic businesses will need to achieve organic certification prior to the Rule going into effect. Businesses must work with an independent, third-party certification body that is accredited by the USDA, such as Quality Assurance International (QAI), an NSF company, to secure certification. Once certified, labels—including non-retail and bulk labels—must be updated to demonstrate compliance.

The organic certification process involves completing an application, submitting documentation, an on-site inspection and technical review. To achieve certification, the applying business must resolve any noncompliances in a timely manner. After successfully completing the inspection and technical review process, the business will receive an official, numbered certificate and can then use the organic mark on its product labels. The certificate will also be added to the Organic Integrity Database and will be downloadable by the public. Each certificate includes a Scope and Product Summary Addendum.

The SOE Rule also calls for a mandatory electronic National Organic Program (NOP) Import Certificate for any organic product entering the US, regardless of the country of origin.

A crucial component of compliance with the Rule is creating or updating an Organic Systems Plan (OSP). An OSP acts as both an economic management tool and a contract between certifiers and certified operations and comprises a description of practices, list of substances, monitoring practices, recordkeeping systems, contamination prevention plans and specific information pertaining to an operation. This document safeguards organizations through supply chain traceability and organic fraud prevention procedures and is required for organic certification.

In addition to the requirements for businesses under the SOE Rule, USDA–accredited certifiers will provide enhanced oversight through possible unannounced inspections, inspector training, trace-back and mass balance audits, and new rules specifically for grower groups.

QAI and NSF offer a free SOE Rule toolkit to support organizations across the supply chain. The toolkit includes an interactive decision tree, FAQs, readiness checklist and links to educational webinars.

Jennifer Allen

Consumers: A New Food Labeling Authority

By Jennifer Allen
No Comments
Jennifer Allen

Pop quiz. Who regulates food? You’re probably going through an alphabet soup of agencies in your head right now, and you wouldn’t be wrong. FDA, USDA, FTC, state and local agencies, all play a role in regulating the food we eat. But how many of you thought of the consumer? In recent years, consumers have increasingly become a de facto regulatory agency by harnessing the power of the courts. Statements on your labels that may pass muster with FDA and other agencies are falling afoul of consumer expectations, and consumers are seeking, and sometimes obtaining, redress in the courts. Although there have been some more promising rulings lately suggesting that some courts at least are beginning to rein in these types of claims, food manufacturers should nevertheless be vigilant.

Take, for example, the case of Mantikas v. Kellogg Company. There, a group of consumers sued the manufacturer of Cheez-It crackers. The crackers were available in a version that contained the language “Whole Grain” in large font in the middle of the principal display panel, with smaller language stating “Made with 8G of whole grain per serving” in the corner. But the ingredients panel showed that enriched white flour was the primary ingredient. The Second Circuit Court of Appeals held that the consumers had stated a claim under their states’ consumer protection laws. Even though the product did in fact contain 8 grams of whole grains, and even though the consumer could look to the ingredient panel to learn that the primary ingredient was white flour, the court explained that the purpose of the back and side panels is to offer more detailed information than that on the front panel, not to correct a misconception caused by a misleading representation on the front panel. The “whole grain” representation was clearly intended to mislead the consumer into believing that the product was made predominantly or entirely with whole grains when that was not in fact true. The fact that the consumer could figure that out by reading the ingredients panel was not enough to satisfy the court.

Consumers are also on the attack against terms like “real,” “natural,” “good for you,” “pure,” and “wholesome,” terms that are not explicitly regulated by FDA. What each of these terms has in common is that they are vague and hard to prove or disprove. What does “real” even mean? Under one definition, all food is real unless it’s the plastic food in a child’s toy box. Cyanide is natural, and may even be pure, but we wouldn’t want to eat it. And almost everything we eat could be good for us in the sense that it helps stave off starvation. You see where I’m going with this. These terms are wildly open to interpretation, and the chances of you and your consumer interpreting them the same way are slim. Better to stick to narrower terms that you can substantiate. For example, you might say that your popsicles are flavored with the juice of real fruit, though, like Cheez-Its, beware of making that claim if the majority of the flavor is not from real fruit juice.

And consumer suits go way beyond the content of the product. Take, for example, the case of Broomfield v. Craft Brew Alliance, Inc. In that case, a group of consumers sued over labeling that deceived them into believing that Craft Brew’s beer was made in Hawaii. While the defendant did manufacture beer in Hawaii, the beer it sold on the mainland was made on the mainland. The court sided with the consumers. While pictures of surf boards and the phrase “Liquid Aloha” weren’t enough to make the case, Craft Brew went far beyond that, with a map of Hawaii depicting the location of its brewery, a Hawaiian address, and an invitation to visit the brewery when in Hawaii.

So what’s a manufacturer to do? When coming up with that enticing label, first, think like a consumer. What might that consumer believe or, at least, what might they be able to convince a court that they believed? Second, conduct a risk/benefit analysis. Is that “all natural” label expected to generate enough extra sales to justify the risk of a consumer lawsuit. Finally, ask your attorney to check on the existing legal landscape. Has another manufacturer run into legal problems using the very same language you want to use? If so, did the court suggest ways in which the manufacturer could have cured the problem? If in doubt, use specific, verifiable statements over vague pronouncements of “healthiness.” And above all, don’t play games with the consumer. If you’re trying to make your product look healthier than it is, there are plenty of plaintiffs’ lawyers ready and waiting to challenge you in court.