Stacy Vernon

Lessons Learned from Listeria Recalls

By Food Safety Tech Staff
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Stacy Vernon

Listeria monocytogenes continues to be a key factor in food recalls. While it is not the most common pathogen behind foodborne illness, it does have a high mortality rate. Listeria is hearty. It thrives in cold, moist environments, can grow under refrigeration temperatures and is salt tolerant. The risk of listeria contamination can be reduced through stringent sanitation, and environmental monitoring and testing. But far too often, it takes an outbreak or recall for companies to truly understand the efforts needed to find and destroy it in their facilities.

At Food Safety Tech’s Hazards Conference in Columbus, Ohio, in April, Stacy Vernon, Food Safety Operations and Program Manager at CIFT, an Ohio Manufacturing Partner, shared lessons learned from food companies that have experienced Listeria in their facilities and resulting product recalls.

Lesson Learned: Regulatory Requirements

The regulatory requirements related control of listeria monocytogenes can be found at USDA 9 CFR Part 430.4 and FDA 21 CFR Part 117. Both agencies offer guidance documents that serve as valuable resources that food companies can use to build their food safety programs:

USDA FSIS: FSIS-GD-2014-0001 “Controlling Listeria monocytogenes in Post-lethality Exposed Ready-to-Eat Meat and Poultry Products”

FDA: FDA-2008-D-0096 “Control of Listeria monocytogenes in Ready-to-Eat Foods”

“The question is, are your people reading these? Are they aware they exist?” asked Vernon. “In speaking with companies who have gone through recalls, many were not even aware these guidance documents existed or were not utilizing them.”

Lesson Learned: Sanitation Program Shortcomings

“Sanitation is the No. 1 program that you need to have on point,” said Vernon. “Unfortunately, labor shortages and turnover have made this a big challenge in recent years.”

Issues that companies uncovered following recalls include:

  • A lack of understanding of the difference between cleaning and sanitizing
  • Sanitation teams not given enough time to properly sanitize equipment
  • Lack of easy access to the tools needed to sanitize properly
  • Lack of training on or understanding of the seven steps of sanitation
  • Lack of training on what biofilms are and how to detect them

“Sanitation teams tend to be small, and they need to be everywhere,” said Vernon. “Are you looking at their foot traffic? Your sanitation team should get, at least, general training on food safety and pathogens. Make sure this department is not overlooked because they do pose one of the highest risks of cross contamination.”

Lesson Learned: Poor Sanitary Design

Companies cited similar shortcomings in sanitary design. Vernon recommended that companies implement the following practices, if they are not currently following them:

  • Involve your food safety professionals in the purchase of new equipment
  • If purchasing used equipment, make sure that it has been maintained
  • Google “Sanitary Design Checklist.” These free downloads are available from the American Meat Institute, U.S. Dairy and other organizations and are great resources
  • Look for facility and equipment design flaws, such as cracks or separations in the floor, exposed threads, hallow pipes not sealed, bad welds, and water/product accumulation points

“Drain maintenance is also key. One company uses a snake to swab their drains, so they know if they have listeria before it works its way back up into the facility,” said Vernon.

Lesson Learned: Poor Environmental Monitoring Programs

The goals of an environmental monitoring program (EMP) is to aggressively seek and destroy pathogens. “You need to know where listeria is entering the facility, where it harbors and how it moves in your facility so you can effectively eradicate it,” said Vernon. “There is still a mentality that people are scared to find it, so they swab the safest areas. We need to change that mindset to ‘I want to find it and I want to eliminate it.’”

EMPs need to be tailored to your specific facility. Some of the issues companies found with their EMPs following recalls included a lack of internal knowledge to build a comprehensive and custom program and failure to swab properly. “Ask yourself, who is responsible for setting up our EMP and can they do it alone, or do we need outside expertise?” said Vernon.

When swabbing, you need to apply pressure and seek out hard to reach areas. When determining which zones to swab, consider the following:

  • Your risk assessment and hazard analysis
  • Previous environmental monitoring data collected
  • Visual appearance of surface
  • Products produced and intended users
  • Potential for growth after packaging

“Focus on areas where RTE products are exposed. Companies often do not want to swab Zone 1, but one company that went through a recall has implemented swabbing in Zone 1 while they are sampling their products,” said Vernon. “Their reasoning is, the products are already on hold and if they have to throw one shift of product away, it costs much less than a recall or outbreak.”

Lesson Learned: Lack of Employee Knowledge

Several of the companies Vernon spoke with found that they had inadequate food safety and pathogen training and knowledge at all levels; and that they did not have a good sense of employee traffic flow and habits. “When is the last time you stepped back to evaluate traffic flow in your facility?” asked Vernon. “Companies that took the time to evaluate traffic flow and employee practices were often surprised that they did not understand their employees’ movement within the facility or work habits.”

Key areas to investigate include:

  • How do employees and product move through your facility?
  • What is your footwear policy?
  • Are employees following appropriate GMPs for handwashing, PPE, product handling, etc.?
  • Are sanitation employees cleaning properly?

“Changing employee practices doesn’t take a lot of capital,” said Vernon. “It is one of the cheapest ways to mitigate risk.”

Lesson Learned: Not Reassessing Programs

EMP and sanitation programs should be reassessed when findings occur or changes happen in the facility, including anytime you bring in new equipment. “Start with a document review and then reassessment of your environmental monitoring program,” said Vernon.

 

 

 

 

 

 

George Gansner

Now is the Time to Reassess the Food Industry’s Approach to Managing Risk

By George Gansner
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George Gansner

The food industry is under intense scrutiny, with concerns about food safety and quality making headlines around the world. Today, the industry faces unprecedented challenges when it comes to ensuring the safety and security of the global food supply chain. Leaders need to manage known concerns such as foodborne pathogens, food fraud and contamination, as well as emerging challenges, including ingredient scarcity and changes in consumer preferences that have created the need to reformulate recipes quickly, source from new suppliers, and increase imports—all of which contribute to increased risks.

Due to climate change and shifting environmental factors we are seeing crop failures, and new bacteria and antimicrobial resistance to foodborne pathogens, which increase the cost of managing food safety. As consumers demand greater transparency and look to place more trust in the food chain, changing buyer habits further compound these challenges by putting a greater onus on food handling, production, manufacturing, and supply companies to provide more education to consumers about foodborne illnesses.

Recalls are the biggest threat to a brand’s profitability and reputation, and this threat is growing. According to FDA reports, recalls increased by 700% in 2022, with undeclared allergens being the leading cause for the last five years. The Food Safety Authority in the UK tells a similar story with undeclared allergens accounting for 84 of the 150 recalls last year, followed by salmonella, listeria, and foreign body contamination.

As food regulations become more complex to navigate, it is now essential to reassess the industry’s approach to managing risk. Protocols such as VACCP and TACCP are regularly used as part of a solid food defense program to identify risks. But the traditional approach of relying solely on regulations and compliance-based systems is no longer sufficient to ensure food safety in today’s complex, volatile and globalized food supply chains. Now is the time to implement a more holistic and dynamic risk-based approach to managing food safety more effectively.

What Is a Risk-Based Approach to Food Safety?

A risk-based approach allows the industry to proactively identify potential food safety risks and take appropriate measures to mitigate them, rather than simply responding to problems as they arise. For example, mature food businesses are building on food safety management systems with food safety audits to identify and manage risk to stay ahead of the curve. A risk-based approach helps underpin the continuous improvement process and, by doing so, demonstrates the ability of a company to be a trusted partner in the global food supply chain.

One of the key aspects of a risk-based approach to managing food safety is proactive intervention and control, using relevant data analysis stored in a cloud-based platform. All stakeholders need access to accurate and actionable data during risk assessment and management to make informed decisions. However, there are many barriers to accessing risk-related data for smaller operators, many of which are still working in a largely manual way.

Data must be collated from across the business, and multiple data sources need to be collected and appropriately analyzed to protect both the brand and public health. It is estimated that we are at least 10 years away from any type of interoperability of industry data, which will allow better transparency and visibility of risk across the supply chain.

Stay Ahead of Emerging Legislation

Visibility of the emerging legislation in source countries of ingredients and raw materials is critical, as are contingency sourcing plans and good risk analysis protocols. Food integrity needs to be a standing agenda point as part of internal meetings, and ESG policies need to be visibly delivered. The industry needs to ensure that it is aware of changes in regulations that could impact the safety and quality of its products through horizon scanning tools. There is also an onus on the industry to make its risk assessments more dynamic to incorporate change at a frequency that is appropriate for risk evaluation with effective crisis management plans in place.

Supply Chain Management Is Critical

Sourcing raw materials and ingredients across supply chains requires best practices. You must ensure that your supply chain partners and suppliers know how to manage a crisis and that emerging risks are shared across the supply chain. Quality, food safety, and regulatory divisions must actively participate in risk assessments and receive relevant data and communication. ESG policies also need to include the supply chain; leaders in this space need to be able to verify that these policies are delivering.

Marketing claims must be vetted and aligned with regulations and markets where products are sold. Procurement, supply chain and communication, and external partners such as NGOs and consumer associations are important groups to involve in risk profiling and ongoing management. While managing emerging issues and horizon scanning is critical, it is also important to remain vigilant on the basics, as most food safety and allergen incidents are known risks.

Detecting Food Fraud

Opportunistic food fraud cases are rising in the high food inflation market, with recent examples including everything from adulterated honey to the mislabeling of beef. To deter food fraud, businesses need to focus on risk-based auditing and testing through sampling programs. Knowing your supply chain, shopping around safely, being vigilant about ingredients and specifications, utilizing training, and building awareness and readiness are imperative to deter food fraud and create a culture of confidence and greater food safety.

Think Differently About Managing Risk

Now is the time for the food industry to reassess its approach to managing risk. A risk-based approach focusing on prevention, continuous improvement, and stakeholder collaboration is necessary to ensure a safe and secure food supply chain in an increasingly complex and challenging environment. The industry must prioritize data accessibility and accuracy, have a crisis management plan, be aware of emerging legislation, and include ESG policies in its risk management strategies. By focusing on risk-based auditing and testing, the industry can deter food fraud and create a culture of confidence.

The probability of eliminating all risks is very low, so the food industry must pivot and be agile to challenge the traditional approaches to managing food safety. It is time to think differently about managing risk and adopt new practices that promote prevention and collaboration.

Sandra Eskin, OSU

Highlights from Food Safety Tech’s Hazards Conference

By Food Safety Tech Staff
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Sandra Eskin, OSU

The Food Safety Tech’s Hazards Conference + CFI Think Tank “Industry & Academia Advancing Food Safety Practices, Technology and Research” took place April 3-5 in Columbus, Ohio. The event offered two days of practical education on the detection, mitigation, control and regulation of key food hazards, followed by discussion geared toward identifying gaps for research and innovation.

Sandra Eskin, OSU

Sandra Eskin, Deputy Under Secretary for Food Safety, USDA FSIS, opened the program to discuss the agency’s proposed Salmonella in poultry framework. She highlighted the need for a more comprehensive approach that includes incentives to bring down the Salmonella load in birds entering the slaughterhouse, enhanced monitoring of safety measures within the facility, and enforceable product standards for raw poultry products.

Day one continued with a focus on Salmonella and Listeria. Barb Masters, VP of Regulatory Policy at Tyson Foods presented “Salmonella: What We’ve Learned and Remaining Gaps in Detection and Mitigation.” Masters highlighted key gaps in Salmonella detection, mitigation and research including:

  • Correlating what comes from the farm to what is entering a plant
  • Potential benefits of quantification testing
  • A better understanding of products that have the highest levels of Salmonella
  • Identification of virulence factors of different serotypes
  • The need for rapid testing methods that can be used at the plant level

Sanja Ilic, Ph.D., presented findings on the risks and most effective mitigation methods for listeria in hydroponic systems, followed by a session from Stacy Vernon, Ph.D., on recent listeria outbreaks in RTE meats and ice cream.

Shawn Stevens and Bill Marler

Attorneys Bill Marler, founder of Marler Clark, and Shawn Stevens of the Food Industry Counsel opened day two with an overview of the legal and financial risks of food safety hazards. The program continued with a focus on detection and mitigation of pathogens and biofilms.

 

Session Highlights

Application of Ozone for Decontamination of Fresh Produce with Al Baroudi, Ph.D., VP of Quality Assurance and Food Safety, The Cheesecake Factory, and Ahmed Yousef, Ph.D., Professor and Researcher with the Department of Food Science & Technology, OSU

Estimating Mycotoxin Exposure in Guatemala and Nigeria with Ariel Garsow, Ph.D., Food Safety Technical Specialist at the Global Alliance for Improved Nutrition (GAIN)

Mitigating the Risks of Salmonella and Listeria in Your Facility & Products with Sanjay Gummalla of the American Frozen Food Institute, and Rashmi Rani, Senior Manager of Food Safety and Quality Assurance, Schwan’s Foods

How to Use Whole Genome Sequencing in Operations To Improve Food Safety and Root Cause Analysis with Fabien Robert, Head of Zone AMS, Nestlé

Biofilm Prevention and Control Practices with Charles Giambrone, Food Safety Manager, Rochester Midland

On April 5, attendees joined the Ohio State University Center for Foodborne Illness Research and Prevention (CFI), founded and directed by Barbara Kowalcyk, for its annual “Think Tank.” The program featured student research presentations and an “Einstein Lunch” that brought members of industry together with graduate students and OSU researchers to identify gaps in research in the areas of pathogen detection and mitigation, handwashing and mycotoxins.

“We’re hoping this is the first of future collaborations with CFI and Food Safety Tech, where we have industry and academia presenting together,” said Rick Biros, founder of Food Safety Tech, the Food Safety Consortium and the Food Safety Tech Hazards Conference series. “This is something I feel both academia and industry benefit from, and I look forward to working with Barbara and CFI in the future.”

“I learned a lot myself, and it was great to see this program come together,” said Kowalcyk. “I want to thank the presenters, attendees and all the people who worked behind the scenes to make this event happen.”

Scenes from Food Safety Hazards Conference + CFI Thinktank

OSU 2023   OSU reception 2023  Sanja Ilic

Al Baroudi and Ahmed Yousef  CFI Think tank 2023  Saldesia OSU

Rick and Barbara Kowalcyk  OSu Reception - Steve Mandernach  Fabien Robert

 

 

Wendy White

Train Smarter, Not Harder: Utilizing Effective Training to Empower Employees

By Wendy Wade White
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Wendy White

Training is one of the foundational principles of every food safety program. It is a theme that’s repeated throughout governmental regulations, industry guidelines, and audit requirements, but adult learning can be challenging. It is also expensive, when you factor in the resources needed, salaries of everyone involved, and loss of operational productivity. After all these resources are allocated, it’s frustrating to witness mistakes made by those that have gone through the proper training…so you “retrain” as a corrective action, only to see the same thing happen. When this cycle repeats itself, I can’t help but be reminded of Albert Einstein’s definition of insanity, “Doing the same thing over and over and expecting different results.”

A true preventive measure may be to reevaluate your training methods and train smarter, not harder. Take time to really understand your audience, discover their motivations, and devise ways to truly reach them. The five cornerstones of teaching: legitimacy, authenticity, engagement, empowerment, and simplicity can be used to elevate any training program to make it more effective.

Legitimacy

Your audience will be much more open to receiving the subject matter if they believe in the legitimacy of the source, namely, the trainer. Objectively ask yourself, “Why should I be teaching this class, and why should these people believe what I say?” Take the time to establish yourself as a subject matter expert. Instructors often start with a quick bio slide to explain their qualifications and experience. You can also start by telling your audience a bit about yourself, including your educational background and experience. Also take the time to explain the “why” of what you are teaching. For example, we don’t allow jewelry in the processing room, because it could fall into product or could get caught in a conveyor and cause a serious injury.

Authenticity

Why should these people care about what you say? Steven Covey, author of “The 7 Habits of Highly Effective People” also wrote the book, “The Speed of Trust.” In this book, he explains that trust is the foundational principle that holds all relationships together and the most essential ingredient in effective communication.[1] Establishing trust and authenticity is the quickest means of taking a training from you talking to people to having them hear what you are saying. Some people are automatically suspicious, so being honest and straightforward goes a long way to gaining that trust.

Engagement

I’ve been training adults for my entire 21-year career—see how I started establishing legitimacy with you—and I’ve learned that training is about 90% entertainment and 10% relaying facts and hoping they stick. Remember your favorite teacher. Were they boring and monotone, or lively and engaging? Engagement can be achieved by actively getting your audience to participate. This can be done through verbal quizzes, break-out exercises, live polls, and asking them to share their experiences.

At the end of the day, engagement is coupled with the question, “Why is this important to me?” How do you make the subject matter important to the audience? How can you get them invested in the subject matter and motivated to implement what they’ve learned? When dealing with food safety subject matter, one way is to share foodborne illness statistics and stories of those who have been affected. Stop Foodborne Illness has captured many of these stories on its website. When you identify something that everyone has in common, namely, that we and our loved ones all eat the food that we are producing, it increases audience engagement.

Empowerment

Once you have an engaged audience, the question becomes, “What can I do about it?” By telling the audience what they personally can do to influence (prevent, reduce or, eliminate) the problem, they are more likely to have a vested interest in the outcome.

I was involved in opening a new facility a few years ago. The General Manager personally took every new hire for a tour of the facility to explain the machinery and demonstrate some of the workplace safety features. While on that tour, he told them that each person in this building was allowed to hit the E-Stop button at any time and shut down the line if they saw something wrong or suspected that something wasn’t right, with no repercussions. He emphasized the importance of the subject of food safety by empowering each person with the authority to shut down the line. By giving them this power, he ensured that every person was captivated by the safety training and took the message to heart.

Simplicity

One of my personal mantras is, “Simplicity is the key to sustainability.” The simpler you make something; the more likely people will be to do it correctly and keep it up over time. The more complicated you make something, the less effective it becomes, especially over time. I use this quote when talking about creating procedures, but it’s applicable in the training setting too. The more complex the training, the harder it is to understand. The longer the training, the harder it is to captivate your audience, as people often “check out” and stop paying attention, especially if they’ve worked a long shift and just want to go home. I’ve found that shorter, interactive trainings can be more impactful than longer sessions.

One of my most successful training sessions was as a temporary QA Manager, trying to ensure that the annual training requirements were performed, prior to an audit. I asked the attendees they’d done in the past and got an eye roll along with grumblings about PowerPoint presentations. I decided to try something different and created about 10 “slides” on chart paper and held the training while we stood in a quiet corner of the warehouse. My first group was the third-shift sanitation crew. We spent 20 minutes going over the big concepts, joking about my horrible illustrations, and sharing stories about the subject matter. Afterwards, I asked them how they liked it and got some genuine nods and smiles. I decided to repeat the session with the rest of the processing employees and all the office staff (warehouse setting and all). I was shocked how many people came up to me afterwards and told me how much they enjoyed the session and appreciated the change.

Case Study, “Don’t Throw-Up Worms!”

One of the most effective food safety campaigns in history was the effort to slow cases of Trichinellosis, a foodborne disease that was sweeping the country in the early 1900s. The government’s strategy included new regulations for swine feed and educating the public of the dangers of eating undercooked pork. It started in the 1920s, when Benjamin Schwartz, Senior Zoologist with the Bureau of Animal Industry published a leaflet for the USDA entitled, “Trichinosis: A Disease Caused by Eating Raw Pork.”[2] As a result, the government started surveillance activities to understand the extent of the problem. In the 1930s and 1940s, it was estimated that one in every six Americans was infected with Trichinella spiralis,[3] so the U.S. government implemented a widespread campaign to educate the public.

This campaign, which was so effective that Trichinella is almost unheard of in domestic pork today, worked because they leveraged the five cornerstones to create an extremely effective training.

  • Legitimacy – The U.S. government was a trusted source of knowledge.
  • Authenticity – This message was backed by doctors and scientists from the CDC and other agencies. Also, people knew that pork was the making them sick, so this information was verified by personal experience.
  • Engagement – Because scientists had discovered that Trichinella is a microscopic parasite, they coined the phrase, “Don’t Throw-Up Worms!” since vomiting was a common symptom, and that caught everyone’s attention.
  • Empowerment – The general public had a tremendous amount of control because the solution focused on fully cooking pork at home or ordering pork chops “well done” at restaurants.
  • Simplicity – The solution was extremely easy, just cook your pork a little longer. If it’s easy, people will do it, and they did.

Let’s look at the results. Between 2002 and 2007, the CDC only recorded 52 cases of Trichinellosis and only seven of those were traced to commercial pork.[4] The figure below shows the number of reported cases of Trichinellosis in the U.S. from 1947-2007, and the steady decline is evident.

CDC Trichinellosis graph
CDC surveillance data on reported cases of Trichinellosis in the U.S. from 1947-2007.

 

Trying a New Approach

Occasionally, you’ve got to mix things up to keep your audience interested. There are so many different training tools that are available on the internet, from YouTube videos (my favorite is a rap about handwashing) to novel ideas. You can also change up the setting; try standing in an unusual place in the facility or host a training outside or on the facility floor.

Make sure that you are thinking about your target audience when creating your training. Use language that’s appropriate and techniques that resonate. This might take a little trial and error, so don’t be afraid to try new things and discard the ones that don’t work well.

As Gen Z and Millennials overtake older generations as the majority of the workforce, there has been a lot of research into effective training for younger generations. One technique that is garnering a lot of interest is gamification. I’ve seen video games that replicate a chef at a busy restaurant, in which good manufacturing practices must be used to fulfill multiple orders. This might be more effective than sitting an 18-year-old down for a four-hour ServSafe training. It doesn’t have to be as complex as a specially designed video game, I’ve seen things as simple as food safety word searches and crossword puzzles that are left in the breakroom. Trivia is also a popular and engaging tool to use during training sessions, especially when there are fun prizes on the line.

Reconsider your approach to training by implementing the five cornerstones of teaching and trying novel approaches. Even small changes can make a big difference. Reach out to your colleagues to learn what has worked for them, and try new tools to help make these sessions more enjoyable for all the participants which will directly increase the effectiveness of your training program.

 

References:

[1] Covey, Stephen M. R. 2008. The Speed of Trust. London, England: Simon & Schuster.

[2] Schwartz, B. 1929. Trichinosis: A Disease Caused by Eating Raw Pork. USDA Leaflet No. 34; 1-12. https://archive.org/details/trichinosisdisea34schw/page/n1/mode/2up

[3] Most H. Trichinellosis in the United States: Changing Epidemiology During Past 25 Years. JAMA. 1965;193(11):871–873. https://jamanetwork.com/journals/jama/fullarticle/656503

[4] Kennedy, E. E. et al. 2009. Trichinellosis Surveillance – United States, 2002-2007. CDC MMWR. 58 (09); 1-7. https://www.cdc.gov/mmwr/preview/mmwrhtml/ss5809a1.htm

Emily Newton, Revolutionized Magazine

Utilizing Technology To Eliminate Food Processing Bottlenecks

By Emily Newton
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Emily Newton, Revolutionized Magazine

Food processing bottlenecks are a persistent problem in the industry. Whether due to labor shortages, shifts in consumer demand leading to product or formulation changes, or inefficient facility design, new technologies are coming to market that can help companies identify and overcome these challenges.

Overcoming Labor Shortages

A 2023 survey from Food Processing found that 40% of respondents plan to add new employees to their workforces this year. The survey highlighted the challenges companies continue to face due to labor shortages, including the inability to find enough workers and difficulty in retaining skilled employees. These problems collectively can cause food processing bottlenecks, particularly as companies seek to scale output to meet growing demand and enhance training to build employees’ skills.

Taiwan’s Taipei Medical University is using virtual reality (VR) at its food safety training center, and the technology shows promise as a faster and more engaging training tool. A professor familiar with the implementation of the technology noted that it can reduce safety-related errors and improve knowledge retention, as workers appreciate engaging in the more immersive learning style of VR compared to watching videos and reading textbook chapters.

That means it could also encourage workers to acquire new skills. That’s vital since the Food Processing survey noted that 55% of respondents have ramped up their in-house technical training in response worker shortages.

Incorporating new technologies, such as VR, may improve onboarding while also helping companies attract younger employees seeking companies that keep pace with modern times.

Digital Twins Increase Visibility

Digital twins are highly realistic models that allow companies to run various scenarios in a controlled environment before trying them in real life. They can help managers identify potential bottlenecks prior to implementing a new product or process, and can help solve existing bottlenecks by showing why an assembly line at a particular plant is less efficient than one at a nearby facility operated by the same company.

Digital twins can also help companies reduce waste. In one example, Accenture and Mars collaborated on a digital twin that enabled real-time monitoring of a filling process. That approach prevented too much product from going into a package.

When it comes to food safety, digital twins can identify insufficient food safety measures, highlighting where and how to make improvements.

One company even developed a digital twin for flavor formulations and customer response predictions. Nearly 90% of new food products remain on the market for only one year. The digital twin developed by Foodpairing was designed to predict “winning” formulations to increase the likelihood of success before introducing new food products.

Robots Supplement Human Efforts

There are limits to how fast humans can work safely and maintain stringent quality control. That’s why many food processing businesses have begun using robots to increase efficiency.

In one case, a food processor used cobots to decrease the six-hour time frame required to transition an assembly line to a different product. These robots also allowed the company to move to 24/7 production, which aligned with customer demand.

FlexCRAFT, a Dutch research program centered on using dual-arm robots for greenhouse management, food processing and packaging, has built machines with grippers that can handle various product shapes and packages.

The food processing application centers on deploying robots to separate, remove or cut various chicken parts. The team is currently developing machines to handle variations in size or type to ensure the robots can work with wings as well as thighs. Future initiatives include incorporating active learning and task planning to further improve the technology.

Food processing bottlenecks can keep companies from meeting goals and remaining competitive in a demanding marketplace. However, technology increasingly provides feasible solutions to help overcome these obstacles.

Leaders tasked with approving technological implementations should assess the most significant issues in their companies. From there, they can investigate which technologies have the most appropriate capabilities to reduce or solve those problems.

Matthew Taylor

Mitigating the Risks of Food Fraud in an Inflationary Environment

By Matthew Taylor
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Matthew Taylor

Inflation can create a challenging environment for the food industry, making it more difficult to maintain product quality, safety, and transparency. In August 2022, U.S. food inflation hit a 40-year high of 11.4% and has since remained persistently high, at 10.1% in January 2023. Manufacturers and suppliers must stay vigilant and take proactive steps to mitigate the risks posed by stubbornly high food inflation and increasingly complex supply chains.

Inflation can be a catalyst for risk in food supply chains for several reasons. Rising prices could encourage bad actors or tempt manufacturers and suppliers to cut corners or compromise quality to maintain profit margins. This can lead to an increased risk of food fraud, where lower-quality or counterfeit ingredients are substituted for genuine ones or where mislabeled products are sold to unsuspecting consumers. Supply chain disruptions could increasingly affect manufacturers as suppliers struggle to manage the increased costs of raw materials, transportation, and labor, as seen this winter in Europe, with the UK experiencing shortages of tomatoes and eggs. This can result in delays, shortages, and other logistical challenges that can make it difficult to maintain product quality and safety.

Inflation can also increase food allergy and sensitivity incidents. Mislabeling or allergen contamination due to substituted alternative ingredients could put allergen or intolerance sufferers at greater risk, as well as your brand. With the threat of food fraud lurking in increasingly complex and volatile supply chains, what steps can food manufacturers take to protect themselves and their customers?

Tackling Food Fraud and Allergen Incidents

Despite legislative and industry process improvements, food fraud continues to be a significant risk in the food industry, costing businesses an estimated $30 to $40 billion annually. Food fraud refers to any act of deception, intentional or otherwise, that is intended to result in the sale of a food product that is not what it purports to be. This can take many forms, from adulterating ingredients to misbranding and counterfeiting.

The consequences of food fraud can be severe and include economic losses, harm to human health, damage to the reputation of food companies and loss of consumer confidence in the food supply. Food fraud can also cause environmental consequences, including the illegal use of pesticides, or overfishing, which can have long-term effects on the environment, wildlife, and ecosystems.

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In recent years, several high-profile cases of food fraud have occurred, including the widespread contamination of infant formula with melamine in China and the horse meat scandal in Europe. These incidents have highlighted the need for better measures to prevent food fraud and to ensure the safety of the food supply.

To protect the integrity and bolster consumer and producer confidence in organic food, which has long been a target of food fraud, the USDA published one of the largest-ever reforms to their organic program in January 2023. However, many risks remain as legislation tries to catch and close loopholes.

One of the challenges of preventing food fraud is that the supply chain is often complex and global, making it difficult to track the origin of ingredients and monitor their quality. In addition, many food frauds are not detected until they reach the end-consumer, making it difficult to recall contaminated products. In order to mitigate the risk of food fraud, it is essential to plan ahead and implement strong supply chain management practices, including the use of technology such as traceability systems and predictive analytics.

A good starting point to mitigate your risk of food fraud is to conduct a deep dive into your highest-risk raw materials and suppliers instead of trying to tackle everything at once, particularly if you have a large number of raw materials to assess. For instance, you may want to prioritize raw materials that have been linked to recent fraud incidents, such as infant formula, honey, and olive oil.

Four Steps to Protecting Your Business

Know your supply chain. Controlling and understanding your supply chain is essential for minimizing risk. It is important to audit your supply chain back to the field, if possible, or at least to the production and processing facility. For smaller businesses, forensic auditing may not be feasible. However, there are still steps they can take to protect themselves, such as seeking third-party certification programs that verify the sustainability, quality, and ethical sourcing of ingredients. Going back by more than one step in your supply chain is crucial, and conducting a vulnerability assessment of your raw materials and suppliers is an excellent starting point.

Shop around safely. Review the market for potential alternate suppliers or less ‘at risk’ ingredients, subject to the required quality checks and labeling requirements. It is crucial to thoroughly assess current and potential new suppliers and ensure they meet the minimum Global Food Safety Initiative (GFSI) certification standards, wherever possible. Scrutinize all raw material specifications, including the country of origin, as countries with less established food safety regulations may pose a higher risk. Establishing solid relationships with your suppliers and engaging in regular communication with them is also essential to maintain a high standard of quality, safety, and sustainability.

Be vigilant about ingredients. Markets are constantly evolving, and economic, social, and environmental changes can impact the substitution risk profile of any ingredient that you purchase. To manage this risk, it is essential to have an up-to-date awareness of the various market forces that affect ingredients and their availability.

It is important to note that product adulteration may not always be motivated by economic factors. As ingredients become in short supply, manufacturers may make local substitution decisions to keep the supply available. Remember, there is no substitute for a thorough risk-assessed approach to managing this challenge with a complete and detailed understanding of your supply chains.

Utilize training to build awareness and readiness. Training employees on how to identify, prevent and respond to incidents of potential food fraud or allergens is essential but often challenging for food manufacturers. Regular training should include the types of fraud, how to recognize suspicious behavior, and the importance of accurate record-keeping. Ensuring your teams are trained on what to do is there is a food fraud issue is also key, as is testing the teams through mock exercises to see how they would manage a food fraud event in the business.

Persistently high food inflation rates have created a challenging environment for the food industry, making it harder for manufacturers and suppliers to maintain product quality, safety, and transparency. Food businesses must exercise extra vigilance to face an increased risk of food fraud, supply chain disruptions, and an increase in food allergy and sensitivity incidents. Now is the time to proactively mitigate these risks by prioritizing transparency, gaining control and understanding of supply chains, and acting to prevent food fraud.

It is important to note that no system is foolproof. Food manufacturers should regularly assess and improve their supply chain management practices to ensure they are up to date with industry best practices and changing threats. Increasing your transparency in the ingredient supply chain requires a commitment to responsible sourcing and a willingness to invest in traceability, certification, and supplier relationships. While the risks to food quality and safety are well known, businesses need to ask themselves the right questions and take the necessary steps to protect themselves and their customers. By doing so, they can protect their brand reputation and consumer confidence in the food supply and the environment.

 

Craig Butt

Preparing for the Proposed EU Ban on PFAS

By Food Safety Tech Staff
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Craig Butt

In February, the European Union (EU) announced a proposed ban on the production, use, and sale of about 10,000 per- and polyfluoroalkyl substances (PFAS). We spoke with Craig Butt, Ph.D., Senior Staff Scientist for Food/Environmental Science at SCIEX to learn more about the proposal, how it may affect the food industry and how companies can begin preparing for more stringent regulations both in the EU and the U.S.

What do food companies need to know about the EU’s proposed ban on PFAS?

Butt: First, it is a proposal at this point and it is open to six-month commentary. About a year from now they will make an official decision. Whatever they decide will slowly be rolled out, but it is a huge and very comprehensive proposed ban that will impact people globally.

We live in an environment of global trade, so this will impact those that manufacture food packaging as well as any food products that might be coming across EU lines. What’s most interesting to me about this is the idea that, in the U.S. there’s a lot of attention on drinking water and drinking water regulations, but to propose banning PFAS in products, that takes the regulations further up the chain.

Is this a true ban on PFAS in the products or are they lowering the threshold from current levels?

Butt: There are two aspects to it. It would set lower limits, but they are also seeking more comprehensive monitoring. Typically, regulation and detection of PFAS has involved specific, targeted sets of compounds.

The problem with PFAS is, it is not like banning or reducing use of a single pesticide, you’re talking about potentially 5,000 different chemicals—depending on how you define them—and maybe even 12,000 different chemicals. So how do you address PFAS as a group? This proposal is trying to address that by looking at not only targeted compounds, but PFAS as a class and trying to understand the control of those compounds as a group.

There is still a lot of work to be done before we see where it falls out. The devil is always in the details, and I know there’s going to be pressure on multiple sides. You’re going to have pressure from one group saying this isn’t strict enough and the other side saying this is too strict and everyone’s going to go bankrupt.

But when you read it and you see the ban on products and certain thresholds in those products, I’m pretty sure that’s going to stay, particularly where they’re looking at total PFAS or total fluorine content. That tells us that we’re going to have to go beyond just looking for a targeted list of compounds and do a better job of characterizing all the fluorine compounds that are in there.

Does the proposal primarily focus on food contact packaging or the food products themselves?

Butt: There is still some clarity needed in terms of what the regulations will look like in the final document, but it seems to be focused more on the source, which would be the food packaging paper and products, rather than the food itself.

Where is the industry now in terms of detection and remediation of PFAS and where will it potentially need to go to meet these new regulations, if passed?

Butt: It is important to remember that there was a time before PFAS were widespread in food packaging, and I do know that companies are making efforts to look for alternatives. Back in the early 2000s when 3M banned Scotch Guard, it wasn’t too long until suitable alternatives were found. In the U.S., some manufacturers—working with the FDA—have agreed to change what’s in their food contact materials. In terms of what the industry has in the warehouse ready to go, it is unclear, but companies have seen the writing on the wall and are taking steps to find alternatives. Still, the move totally away from fluorochemicals will likely be a bit of a shock to those who make them.

The concerns will be whether the non-fluorinated chemicals are as effective as the PFAS, and if they are not will they still be satisfactory? We also need to be cautious as we investigate alternatives because we don’t want to replace these PFAS chemicals with newer chemicals that we don’t yet have knowledge about their toxicology or environmental impact on.

What should people looking at now in terms of investigating new products and understanding what they’re going to need to do in terms of detection?

Butt: Detection is the first step. Some folks may not be aware of what’s in the products they are buying in terms of raw materials. You want to know what’s in your own products and the products you are using. There is a huge risk in terms of public relations and reputation. The last thing a company wants to do is have a third party test their products and find out that there are PFAS in them and have that potential reputational damage, because there are a lot of third parties out there that do that, and they are not afraid to name names.

Are there effective tests available if you want to start checking your packaging?

Butt: Yes, we have gotten very good at measuring extremely low levels as well as reducing some of the impacts on data quality and detection in terms of confirmed detection. We can measure things at trace levels and accurately say that they are there. That’s from a targeted standpoint. But we’re also very good at doing non-targeted work to find some of those unknown PFAS that may not be on a standard monitoring list but can help improve the further characterization of what’s there.

A lot of attention has been on PFOS and PFOA, but if you are only looking at those compounds, then you are doing yourself a disservice because what we know and what we’ve seen through time is that those lists of dangerous compounds only continue to grow. As regulators become aware of their presence and their toxicology and as analytical chemists get better and publish findings of these new compounds in consumer products, then the list will continue to grow.

In terms of the regulatory climate here in the U.S., where do you think we’re headed?

Butt: Back in the late 2000s, the FDA scientists produced some really incredible work looking at PFAS in food packaging and their migration out of that packaging into foods, and we continue to work with them. They are great scientists and they published some groundbreaking research. However, these are not the same scientists who make the regulations.

There have been some voluntary agreements with some of the manufacturers to reduce the use of chemicals that are larger—the long chain compounds—which are more likely to accumulate in human blood. But these EU regulations will put a whole lot more pressure on companies to look at PFAS as a larger class of chemicals.

As companies look for alternatives that are a) effective and b) not dangerous, are leaching tests typically part of testing these new products?

Butt: The EU regulations do have a leaching component for some of the food packaging materials, particularly for plastic food packaging. You do need to assess the leaching from plasticizer compounds. I’m not sure if there’s a similar leeching test for PFAS, because PFAS are a little bit weird in the sense that, in the past, most of the chemicals that we were concerned about were those that were fat soluble. We know that fatty foods like yogurts are very good at pulling out the contaminants from the food packaging, but PFAS are a little bit odd because they like more neutral compounds, ones that have some emulsifying properties to them—not super fatty or super water soluble—so you have to be cautious that the right kind of migration tests are being used and are fully applicable for these compounds.

One of the things that makes PFAS so interesting is that they don’t behave like our traditional hydrophobic organic contaminants. They don’t build up in your fat. Years ago, when we were worried about DDT and PCBs and some of those other chlorinated pesticides it was because they build up in your fat. But PFAS build up in the blood, kidney and liver, which from a chemical standpoint is interesting but it also means that some of our tests have to be revised for them.

But the really big thing is, with all the PFAS that are out there, the onus now seems to be shifting on to the manufacturer to know what is in their products beyond just the big ones of PFOS and PFOA. I think that is where we’re going in terms of the testing market. It’s not just testing for individual compounds, but doing a total PFAS analysis at a screening level and then, if a product is above a certain threshold, we do a more targeted, specific analysis.

Paul Damaren and Francine Shaw

The Return to Hospitality: How To Enhance Employee Onboarding

By Francine L. Shaw, Paul Damaren
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Paul Damaren and Francine Shaw

After restaurants nationwide experienced several years of a stressful, disruptive labor shortage, the leisure and hospitality industry has recently added 128,000 jobs, leading all sectors.

Hiring new employees is exciting, especially after years of being seriously understaffed. As you welcome new employees to your team, do not underestimate the importance of onboarding, as 69% of employees are more likely to stay with a company for three years if they were onboarded properly. Additionally, organizations with an official onboarding process experience 50% greater new-hire productivity.

When new hires are trained properly, they feel more confident in their roles and the companies they work for can maximize safety, quality, and compliance. To accomplish this, restaurants and other food businesses should:

Adopt Integrated Digital Solutions

Tech solutions can improve all aspects of your operations, making everything from budgeting to scheduling, forecasting, purchasing, and inspecting more efficient, accurate, and streamlined. Tech tools offer many significant benefits, helping your brand save time and money, reduce waste, and optimize operations.

What’s more, an integrated tech stack can help you get a holistic view of your entire enterprise, whether you have one location or dozens. Easy-to-understand reports provide critical information, allowing operators to make more informed, data-driven decisions.

Digital tools do require an investment, but they offer a tremendous ROI. These solutions help improve safety, efficiency, transparency, accuracy, and consistency. These positive changes boost key performance indicators, including increased sales, profits, customer loyalty, and employee retention.

Prioritize Safety, Quality, and Compliance

Each year, 48 million (1 in 6) Americans get sick from contaminated food or beverages. Don’t let food safety breaches happen at your business!

Prioritize a food safety culture, where all employees work together to maximize safety and minimize risks. Put food safety protocols in place and be certain that all employees are following them. Provide the proper tools for employees to ensure food safety, such as Bluetooth sensors that can tell when walk-in temperatures rise above safe temperatures, and state-of-the-art food thermometers that ensure foods are cooked to proper temps.

It’s not enough just to follow proper food safety protocols yourself, you must be sure that all your suppliers adhere to the strictest food safety standards, as well. If you are following all the right protocols, but a supplier delivers compromised products, your customers (and your business) are at risk.

Food safety and quality assurance must be followed from each product’s point of origin until it’s prepared and served to the consumer. Audit all suppliers regularly and be sure that they have proper, up-to-date safety certifications. When you have multiple suppliers—as most food businesses do—it can be overwhelming to track and organize these important safety certifications manually. Tech tools make this ongoing process easier and more accurate.

Modernize Training Efforts

Some food brands, particularly smaller companies, think that they don’t need a formal training or onboarding process, or they rely on antiquated training programs that have been in place for many years. Swap out your outdated (and/or informal) training programs in favor of something more modern, relevant, and tech driven.

Add more interactive tech elements to your training program, such as microlearning platforms and gamification, to make the information more engaging and memorable. Supplement online training efforts with a live trainer, who can spotlight best practices, answer questions, and role play with your employees to make the lessons stick.

Don’t just tell employees what to do but explain why the rules are so important. Employees are more likely to comply when they understand why the rules are in place.

Keep in mind that training never officially ends. Provide ongoing training opportunities so employees on all shifts can keep important information top-of-mind. Digital tools not only provide key information during initial onboarding, but are essential for reinforcing lessons, delivering updates, and sending reminders throughout each employee’s tenure.

Work to Retain Employees

Did you know that the average restaurant employee changes jobs every 56 days, and that losing a front-line employee costs a restaurant an average of $5,864?

Digital solutions can help you retain employees, as these technologies make their jobs much easier. Tech tools can streamline tedious administrative tasks, such as inspections and inventory, so your employees can spend more time doing the things they enjoy, such as cooking delicious meals and interacting with guests.

Offer competitive pay, appealing benefits, growth opportunities, mentorship, and a supportive culture. And don’t discount the “seemingly small” gestures that can be a big deal to your team. Thank your employees often and sincerely. Praise them in staff meetings for going above and beyond. Write thank you notes. Give bonuses and small gifts. Promote from within.

Get Inspired by Innovative Brands

It may sound like something out of a science fiction novel, but White Castle has a robot working its fryer. Dominos has delivered its first pizza by drone. KFC is using facial recognition technology that recognizes repeat visitors and tailors their experiences based on their past orders and meal preferences. And Panera Bread uses geofencing to track each customer’s location so employees can promptly bring their order to their vehicle.

Your organization may not yet be able to afford robotics in your kitchen or drone deliveries, and that’s OK. But, as tech solutions become more affordable, accessible, and user-friendly for food businesses of all sizes and budgets, it’s clear that technology is improving many aspects of our industry. Digital solutions are no longer “nice to have” luxury items. They’re necessities for brands that prioritize consistently excellent and safe experiences.

By investigating and integrating new technologies, you can provide better service, safer food, and a more convenient dining experience. All of which will help you better meet (and exceed) customer expectations.

Olivia Pitts

How to Successfully Implement an Integrated Management System

By Olivia Pitts
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Olivia Pitts

Implementing an integrated management system that encompasses food safety and quality standards is a complex process that requires careful planning, team buy-in and good communication. If an organization fails to plan properly, these large-scale projects can fall by the wayside.

The planning process will help to identify risks and potential roadblocks. Keep expectations realistic by considering the stakeholders’ needs and expectations. Reach out to those impacted for feedback before the project launches. The information gathered can be helpful in identifying stakeholders’ concerns, unforeseen issues, and resource constraints that may impact the project.

It’s also important to understand the certification process when working through the planning phase, as processes may vary slightly between certification bodies. Factors such as the need for single site vs. multi-site certification, number of standards included, the organization size, geographic location, and auditor availability can all impact the timeline. Meeting with your certification body to walk through these details will aid in setting a realistic project timeline.

Develop a Communication Plan

Communicating project details is critical to project success. This can be done in a variety of ways; often the development of a communication plan will help to set things into motion. These plans describe the who, what, when, and how of the project. Larger companies may need a more in-depth plan while smaller companies can take a more informal approach.

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Work with your management team to develop messaging for the larger organization around the project that fits into the overall strategic vision of the organization. The message should communicate the plan for fulfilling the goals and objectives of the project as well as the strategic connection to the overall vision or mission of the company. Remember, there is no one size fits all for communication plans. Feel free to get creative and do what works best for your organization.

Once the plan has been outlined, engage top management to build a strong foundation for success. Get their buy in on the timeline and agenda. Look to them to provide overall support of the project and act as advocates for implementing the change. Seek out their advice when issues arise or when delays are encountered. They are often the key to helping move the project forward.

Planning an official project kickoff as well as milestone events is a great way to give the project momentum. Encourage top management to attend the kickoff, and keep everyone engaged by providing frequent status updates. Highlight success stories and small wins throughout the life of the project.

Encourage implementation team members to communicate regularly with their internal groups. Utilizing communication boards and site wide meetings to keep everyone apprised of progress is helpful. Implementation projects often take several months, so it’s wise to continuously share information to keep motivation up.

Intentionally Select Team Members

Identifying the right people for the implementation team is a critical step in the project development process. Integrated systems often require collaboration between a variety of groups. When building your implementation team consider current activities and identify processes that are within the scope of the standards being implemented. The individuals who manage these processes are the ideal candidates for the implementation team. Pulling from a pool of subject matter experts will help to streamline the process, as the team will be able to spend their time aligning current business practices rather than mastering the subject. Utilize your team’s expertise and influence to drive change. An understanding of the standards requirements will help identify the specific expertise needed.

Review the standards within the scope of the project and identify differences and commonalities. This should be relatively simple due to fact that ISO standards are all based upon a High-Level Structure (HLS) format, which harmonizes the standard format and requirements. The standard creators adopted this approach with the understanding that many organizations intend to integrate management systems. Similarities often lie within management system activities such as context, leadership, document control, management review, internal audit, and corrective action.

Team meeting
Your team should include subject matter experts related to the standards requirements.

In each of the standards there are sections that will be unique depending on the specific focus. For example, ISO 9001 has extensive requirements around customer focus and operations, while ISO 22000 is tailored towards food safety with specific requirements around HACCP and PRPs. Identify who within the organization has the skillsets needed for the project and create an outline for the roles and responsibilities of each team member.

When establishing roles and responsibilities seek input from the team members and take into consideration their workloads outside of the project. Implementation projects require an extensive amount of time, so you want to ensure you don’t overload them.

Consider allowing team members to establish their own deadlines to provide them with a sense of ownership of their identified areas. Use small, focused teams to help break the project down into segments to make it easier to manage. Team members will be able to focus on their individual tasks and not be overwhelmed with the overall scope. If workload is a concern, consider splitting responsibilities between team members or reaching out to those in your organization who maybe underutilized.

Building the project around current processes and process owners will save time and reduce the need to sell the idea of implementing an integrated system. Many times, organizations are unknowingly meeting partial requirements and only minor modifications will be needed to close the gap. By utilizing internal subject matter experts, gaps can be identified and corrective actions established with minimal effort.

Utilize Auditing Throughout Implementation

Gap assessments and internal audits are an excellent way to ensure the implementation efforts are going as intended. Conducting a gap assessment of the management system provides an overview of the full system and highlights where gaps may lie. This is a great tool to use for project planning and timeline development. The quantity and complexity of the gaps will help guide the team to the areas that need heightened focus.

Develop a team action log to track status of specific actions and identify responsible parties. Keep it simple with clearly identified project milestones. Consider incorporating these milestones into communication plans for awareness across the organization.

Once the team has begun to close the gaps identified, the next step is to verify that the changes are effective. Internal audits can be used to confirm that changes are being rolled out as intended.

Establish an audit program early in the implementation process to help clarify the requirements across the organization. The format of the audit schedule will be unique to each company. Consider aligning with the current processes or departments for a streamlined approach.

As integration activities are rolled out, conduct focused audits a few weeks after launch to verify proper adoption. Work with the team to build a checklist tailored to the process or department being audited. This customized approach will provide a detailed look at current activities.

Take time to accurately document the requirements and any nonconformities. Document the findings in a formal report and set aside time to discuss the results with the auditee. Be sure to include any positive findings that are encountered. Lastly, come to an agreement on the timeline for corrective actions and set a date for any follow-up audits.

When working through corrective actions be sure to work with your stakeholders to help them understand the ISO requirements and how the organization can adapt to meet them. Encourage them to ask for operator input on corrections. Their firsthand knowledge of day-to-day operations provides great insight on current processes.

Utilize team huddles or site wide meetings to spread awareness of the audit results and status of the implementation project. Be sure to allow time for questions and provide follow up as needed. With proper planning, leadership buy-in and consistent communication throughout the process, implementing an integrated management system can become a more manageable and positive process for the entire team.

 

 

 

 

Wendy White

Understanding the True Purpose of Environmental Monitoring Programs

By Wendy Wade White
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Wendy White

 Salmonella and Listeria are among the most prevalent foodborne pathogens, causing untold illnesses and a significant number of recalls each year. Experts have determined that the source of this contamination often comes from the manufacturing facility. Five years ago, the FDA published, Draft Guidance for Industry: Control of Listeria Monocytogenes in Ready-To-Eat Foods (we’ve also been promised a similar guidance document for Salmonella). The Food Safety Modernization Act’s Preventive Controls for Human Foods also contains provisions for evaluation of environmental pathogens in a ready-to-eat hazard analysis.

Employee in cheese plant
A product’s risk level varies based on the amount of pre-packaging exposure to the environment and direct handling by employees.

The challenge with these pathogens is that they are often found in the surrounding environment, and once they enter a facility and become entrenched, these residential pathogens can cause sporadic contamination that is very hard to pinpoint. The best way to prevent this type of contamination is to design and implement a robust Environmental Monitoring Program (EMP), and many manufacturers have added these surveillance programs to their food safety systems.

Unfortunately, many do not understand that the true purpose of EMPs is to seek and destroy residential microorganisms of concern that are living inside facilities before they have a chance to proliferate and contaminate products. This key control involves swabbing surfaces around the facility in the hopes of finding any of these residential pathogens or spoilage organisms. Having a robust, written EMP that includes clear action levels for unsatisfactory results and corresponding corrective actions will help manage pathogen positives and mitigate disaster.

Defining the EMP Scope and Balancing Resources

When designing an EMP, it’s easy to understand how expensive they can become. The question is, “How extensive does your EMP really need to be?” It’s best to start with a risk assessment to understand the program size and then estimate a realistic budget.

These programs are more necessary for ready-to-eat facilities, especially ones in which the post-processed product is exposed to the environment before being safely packaged. Risk is determined by how much pre-packaging exposure the product receives, the amount of direct handling by employees, and the condition of the equipment and surrounding facility. Use this risk analysis to determine how much sampling must be done to properly survey the facility. The scope of the program (and therefore the budget) must be balanced with the risk (severity and likelihood) of contamination.

It is then important to understand the microorganism(s) of concern for your products, facility, and processes. For example, should you stick to true pathogen testing or indicator organisms, such as Aerobic Plate Count (APC or TPC), Enterobacter, or Total Coliform tests? If you do test for pathogens, Listeria is more appropriate for wet processing environments and Salmonella better for dry processing; you might need to test for both. Sometimes its beneficial to evaluate spoilage organisms, such as yeast and mold testing, depending on the risk. For example, a ketchup facility may be less worried about residential pathogens than osmophilic yeast.

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Next, one must determine the frequency and number of swabs that should be taken. Most facilities are large and contain thousands of potential hiding spots for microorganisms. For this reason, understanding your facility’s risk and available resources, and prioritizing the swabbing site selection can help maximize efforts. Will a dozen swabs every quarter be sufficient? What is your level of confidence that the sampling program is sufficient to find any hidden biological hazards? Being logical about the target microorganisms and swab frequency/number can help control the budget and allow for better use of resources to accomplish the true EMP goal, minimizing risk to your product.

Creating an Acceptable Site List

Just as important as defining the microbe of concern and the frequency/number of swabs is creating a good site list. An EMP expert once advised to, “think like Salmonella.” Where is our target pathogen/microbe of concern most likely to be hiding? Factors to consider are potential ingress points (roof leaks, employee shoes), opportunities for travel (water/air flow points like drains, foot or wheeled traffic routes), and likely niches (cracks and crevasses). Also important are areas that are often missed by the sanitation crew due to inaccessibility.

Organizing surfaces into zones is a good means of prioritizing swabbing. Zone 1 (food-contact surfaces) and Zone 2 (surfaces adjacent to food-contact surfaces) are cleaned often and not as likely to harbor hidden caches of microbes. It’s important to conduct routine verification testing of these equipment surfaces to evaluate the performance of sanitation, but this is somewhat different than the true purpose of EMP, which is to seek and destroy residential biological hazards. Zone 3 surfaces (those inside production areas but not immediately near food-contact surfaces) are the best focus for an EMP site list, and most of the surface swabbing should be concentrated in these areas.

Consider areas within the facility that could harbor microorganisms and allow biofilms to develop. Cracks, areas regularly exposed to water, and places that are very hard to reach/clean are all likely candidates. These include underneath equipment frames, inside motor casings and pumps, deep inside drains, underneath ramps and stairs and inside air vents/AC units. Cast a wide net, ensuring that all areas are rotated through the swabbing list, while prioritizing the high-risk locations.

The main stumbling block that managers face when designing EMP is challenging themselves to find problems, because once you find an issue, you must deal with the consequences.

Having a Game Plan for Unsatisfactory Results

The best way to mitigate the fear of success (finding a residential pathogen or microbial issue) is to be prepared with an action plan. This starts by defining what constitutes an unacceptable result. Pathogen results are easy (the presence of a pathogen is always unsatisfactory) but the quantitative results from indicator organisms can be tricky. How high do your Enterobacter or yeast/mold results need to be before they trigger action? What is that action?

Family in grocery store
Environmental monitoring programs are most needed in facilities that process and package ready to eat foods.

It’s all too common for unsatisfactory swabs to reemerge a few weeks after initial corrective actions because the true source of the contamination wasn’t found. Requirements for EMP corrective actions are often limited to 1) Reclean 2) Reswab and 3) Retrain. This is extremely limited and doesn’t really address the root cause. Vector swabbing is a great tool to identify root cause, as well as conduct an evaluation of variables that could spread contamination. For example, Listeria found in a drain might have originated by an unsealed wall/floor junction, a perfect microbial niche. When the crack is flooded, the biofilm periodically releases fresh contamination to spread across the floor and into the original identified drain.

Different results should trigger different responses. Certainly, reclean/retest/retrain is a smart approach, but finding the true source of the contamination and taking steps to eliminate it is vital. This might involve special cleaning, such as fogging or hiring a consultant. It might require a redesign of equipment or replace and repair of damaged or vulnerable areas. Ensure that all unsatisfactory results involve an investigation, graph results to identify trends, and communication of findings to all appropriate stakeholders.

EMP Review and Reevaluation

EMP doesn’t have to be a static program, and there’s no “one-size fits all” approach. It’s recommended to design your program based on risk and the above-mentioned variables, implement, and monitor the results. If you never find unsatisfactory results, you might need to increase your frequency/number of swabs or reevaluate your site list. Are you properly challenging yourself? Are you REALLY trying to find problems or just going through the motions to satisfy some requirement? You know your products, facility, and employees and should be able to make these determinations. Don’t be afraid to revise your EMP as a result of historical data and changing variables inside the facility. This might involve increasing your frequency/number of swabs, but the reverse might also be appropriate. Sometimes EMP can be scaled back, and those resources better used elsewhere.

The best approach to a well-written EMP is to understand the scope by considering the risk and applicable variables, employing thoughtful and risk-based logic to the design, and planning for potential unsatisfactory results with thorough corrective actions. Be mindful the true purpose of Environmental Monitoring Programs, which is to seek and destroy harmful microorganisms of concern inside your facility. A robust EMP, coupled with proper training, implementation, monitoring/trending, and communication, will go a long way towards peace of mind that your facility isn’t harboring a potential, biological hazard threat.