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Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part II)

By Frank Pisciotta, Spence Lane
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Food defense is the effort to protect food from intentional acts of adulteration where there is an intent to cause harm. Like counterterrorism laws for many industries, the IA rule, which established a compliance framework for regulated facilities, requires that these facilities prepare a security plan—in this case, a food defense plan—and conduct a vulnerability assessment (VA) to identify significant vulnerabilities that, if exploited, might cause widescale harm to public health, as defined by the FDA. Lessons learned during the conduct of food defense vulnerability and risk assessments and the preparation of the required food defense plan are detailed throughout this three-part series of articles. Part I of this series addressed the importance of a physical security expert, insider threat detection programs, actionable process steps (APS) and varying approaches to a VA. To further assist facilities with reviewing old or conducting new VAs, Part II will touch on access, subject matter experts, mitigation strategies and community drinking water through more lessons learned from assessments conducted for the largest and most complex global food and beverage facilities.

Lesson 6: Utilization of Card Access. The FDA costs of implementing electronic access control, as reported in the Regulatory Impact Analysis document (page 25) are shown in Table 1.

Average Cost Per Covered Facility Initial Recurring Total Annualized
Prohibit after hours key drop deliveries of raw materials $ $1070 $1070
Electronic access controls for employees $1122 $82 $242
Secured storage of finished products $1999 $– $285
Secured storage of raw materials $3571 $– $508
Cameras with video recording in storage rooms $3144 $– $448
Peer monitoring of access to exposed product (not used) $47 $1122 $1129
Physical inspection of cleaned equipment $– $303 $22
Prohibit staff from bringing personal equipment $157 $– $22
Total $9993 $1455 $2878
Table I. Costs of Mitigation

In our opinion, these costs may be underreported by a factor of five or more. A more realistic number for implementing access control at an opening is $5,000 or more depending on whether the wire needs to be run in conduit, which it typically would. While there are wireless devices available, food and beverage organizations should be mindful that the use of wireless devices may in some cases result in the loss of up to 50% of electronic access control benefits. This happens because doors using this approach may not result in monitored-for-alarm conditions, such as when doors are held open too long or are forced open. Some wireless devices may be able to report these conditions, but not always as reliable as hardwired solutions. Using electronic access control without the door position monitoring capability is a mistake. From a cost standpoint, even a wireless access control device would likely be upwards of $2,000 per opening.

Lesson 7: In the interest of time, and in facilities with more complex processes (which increases the work associated with the VA), plan to have quality, food safety and physical security personnel present for the duration of the VA. But also bring in operational specialists to assess each point, step or procedure for the respective operational areas. You may wish to have a quick high-level briefing for each operational group when it’s their turn to deliberate on their portion of the manufacturing operation. Proper planning can get a hybrid style VA done in one-and-a-half to three days maximum for the most complex of operations.

Lesson 8: Conduct a thorough site tour during the assessment process; do not limit your vulnerability activity to a conference room. Both internal and external tours are important in the assessment process by all members of the team. The external tour is needed to evaluate existing measures and identify vulnerabilities by answering questions such as:

  • Is the perimeter maintained?
  • Are cameras pointed correctly?
  • Are doors secure?
  • Are vehicles screened?
  • Are guards and guard tours effective?
  • Internal tours are important to validate documented HACCP points, steps or procedures.A tour also helps to validate process steps that are in multiple parts and may need to be further assessed as a KAT, for public health impact, accessibility and feasibility or to identify issues that have become “invisible” to site employees which might serve a security purpose.
  • Properly conducted tours measure the effectiveness of a variety of potential internal controls such as:
    • Access control
    • Visitor controls
    • Use of identification measures
    • Use of GMP as a security measure (different colors, access to GMP equipment and clean rooms)
    • Effectiveness of buddy systems
    • Employee presence

Lesson 9: Do not forget the use of community drinking water in your processes. This is an easy way to introduce a variety of contaminants either in areas where water is being treated on site (even boiler rooms) or where water may sit in a bulk liquid tank with accessibility through ladders and ports. In our experience, water is listed on about half of the HACCP flow charts we assessed in the VA process.

Lesson 10: Some mitigation strategies may exist but may not be worth taking credit for in your food defense plan. Due to the record keeping requirements being modeled after HACCP, monitoring, corrective action and verification records are required for each mitigation strategy associated with an APS. This can often create more work than it is worth or result in a requirement to create a new form or record. Appropriate mitigation strategies should always be included in your food defense plan, but sometimes it produces diminishing returns if VA facilitators try to get too creative with mitigation strategies. Also, it is usually better to be able to modify an existing process or form than having to create a new one.

Lesson 11: In cases of multi-site assessments, teams at one plant may reach a different conclusion than another plant on whether an identical point, set or procedure is an APS. This is not necessarily a problem, as there may be different inherent conditions from one site to the next. However, we strongly suggest that there be a final overall review from a quality control standpoint to analyze such inconsistencies adjudicate accordingly where there is no basis for varying conclusions.

Lesson 12: If there is no person formally responsible for physical security at your site, you may have a potential gap in a critical subject matter area. Physical security measures will make at least a partial contribution to food defense. Over 30 years, we have seen many organizations deploy electronic access control, video surveillance and lock and key control systems ineffectively, which provides a false sense of security and results in unidentified vulnerability. It is as important to select the right physical security measures to deploy, but also critical to administer them in a manner that meets the intended outcome. Most companies do not have the luxury of a full-time security professional, but someone at the plant needs to be provided with a basic level of competency in physical security to optimize your food defense posture. We have developed several online training modules that can help someone who is new to security on key food defense processes and security system administration.

Lesson 13: As companies move into ongoing implementation and execution of the mitigation strategies, it is important to check that your mitigation strategies are working correctly. You will be required to have a monitoring component, correction action and verification intended for compliance assurance. However, one of the most effective programs we recommend for our clients’ food defense and physical security programs is the penetration test. The penetration test is intended to achieve continuous improvement when the program is regularly challenged. The Safe Quality Food (SQF) Institute may agree with this and now requires facilities that are SQF certified to challenge their food defense plan at least once annually. We believe that frequency should be higher. Simple challenge tests can be conducted in 10 minutes or less and provide substantial insight into whether your mitigation strategies are properly working or whether they represent food defense theater. For instance, if a stranger were sent through the plant, how long would it take for employees to recognize and either challenge or report the condition? Another test might include placing a sanitation chemical in the production area at the wrong time. Would employees recognize, remove and investigate that situation? Challenge tests are easy high impact activities; and regardless of the outcome, can be used to raise awareness and reinforce positive behaviors.

Whether training a new security officer, reviewing existing security plans or preparing for an upcoming vulnerability assessment (due July 26, 2020), these lessons learned from experienced security consultants should help to focus efforts and eliminate unnecessary steps at your facility. The final installment in this series will address broad mitigation strategies, the “Three Element” approach and food defense plan unification.

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part I)

By Frank Pisciotta, Spence Lane
No Comments

Food defense is the effort to protect food from intentional acts of adulteration where there is an intent to cause harm. Like counterterrorism laws for many industries, the IA rule, which established a compliance framework for regulated facilities, requires that these facilities prepare a security plan—in this case, a food defense plan—and conduct a vulnerability assessment (VA) to identify significant vulnerabilities that, if exploited, might cause widescale harm to public health, as defined by the FDA. Lessons learned during the conduct of food defense vulnerability and risk assessments and the preparation of the required food defense plan are detailed throughout this three-part series of articles. Part I of this series is intended to assist facilities that have not yet conducted vulnerability assessments or wish to review those already conducted, by leveraging lessons learned from assessments conducted for the largest and most complex global food and beverage facilities.

Lesson 1: VA outcomes are greatly enhanced if a physical security professional is consulted. In support of this contention, there are several physical security mitigation strategies, which can be employed to support a food defense program, that are frequently under-utilized and are not optimally managed by non-security staff. Also, the FDA seems to promote the use of cameras even though this equipment is unlikely to prevent an incident of intentional adulteration. For organizations that choose to use video surveillance, a competent security professional can help organizations engineer and operate video surveillance for maximum benefits and to meet challenging record-keeping requirements when this mitigation strategy is included in a food defense plan.

Lesson 2: Given the focus by the FDA on the insider, a formal insider threat detection program is highly recommended. Trying to promote the common, “See Something, Say Something” strategy may not be enough. For example, if employees are not clearly told what to look for in terms of uniform requirements, how to identify persons who do not belong or changes to a coworker’s baseline behavior, which may indicate moving toward a path to violence or sabotage, then “See Something, Say Something” may end up being no more than a catchy slogan.

A key element of an insider threat detection program is the completion of effective background checks for all persons who will be allowed in the facility unescorted. This includes temporary employees and contractors. A common theme in many of the recent, serious intentional adulteration incidents was that the person responsible was involved in some sort of grievance observable to coworkers and supervisors. In all insider threat detection programs, the grievance becomes an important trip wire. The Carnegie Mellon University Software Engineering Institute has published a document titled, “Common Sense Guide to Mitigating Insider Threats, Sixth Edition”. In this document is some particularly helpful guidance that can be used to stand up an insider threat detection program, but this is an effort that can take some time to fully implement.

Lesson 3: The FDA has made it abundantly clear that they believe the focus for the food and beverage industry should be the radicalized insider. A closer look at all the recently publicized contamination events suggests that there are other profiles that need to be considered. A good foundational model for building profiles of potential offenders can be found in the OSHA definitions for workplace violence offenders, which has been expanded to address ideologically based attacks. Table I applies those descriptions to the food and beverage industry, with an asterisk placed by those offender profiles that exist in recent incidents and discussed later in the text.

Class OSHA Workplace Violence Offender Description Motivation Translated to the Food and Beverage Industry
1 The offender has no legitimate relationship to the business or its employee(s). Rather, the violence is incidental to another crime, such as robbery, shoplifting, trespassing or seeking social media fame. Behavioral Health Patient *
Social Media Fame Seeker *
Copycat *
Extortion *
Economic motivation *
2 The violent person has a legitimate relationship with the business—for example, the person is a customer, client, patient, student, or inmate—and becomes violent while being served by the business, violence falls into this category. My load isn’t ready, you are costing me money
3 The offender of this type of violence could be a current employee or past employee of the organization who attacks or threatens other employee(s) in the workplace. I am upset with a coworker and adulterate to create problems for that person *
I am upset with the company and adulterate as retribution and to harm the brand *
Youthful stupidity
I am not paid enough *
4 The offender may or may not have a relationship with the business but has a personal (or perceived personal) relationship with the victim. I am upset with an intimate partner/ coworker and adulterate to create problems for that person
5 Ideological workplace violence is directed at an organization, its people, and/or property for ideological, religious or political reasons. The violence is perpetrated by extremists and value-driven groups justified by their beliefs. Radicalized Insider
Table I. A description of OSHA workplace violence offenders and how it can be applied to the F&B industry.

A supermarket in Michigan recalled 1,700 lbs. of ground beef after 111 people fell ill with nicotine poisoning. The offender, an employee, mixed insecticide into the meat to get his supervisor in trouble. In Australia, the entire strawberry industry was brought to its knees after a disgruntled supervisor “spiked” strawberries with needles. There were more than 230 copycat incidents impacting many companies. A contract employee in Japan, apparently disgruntled over his low pay, sprayed pesticide on a frozen food processing line resulting in illnesses to more than 2,000 people. A contract worker upset with a union dispute with the company at a food manufacturing plant videoed himself urinating on the production line, then uploaded the video to the Internet. Be cognizant of any grievances in the workplace and increase monitoring or take other proactive steps to reduce the risk of intentional adulteration.

Lesson 4: The IA Rule requires that every point, step and procedure be analyzed to determine if it is an actionable process step (APS). The Hazard Analysis Critical Control Point flow charts are a good starting point to comply with this element of the law but cannot be counted on completely to achieve the standard of analyzing every point, step or procedure. Critical thinking and persons familiar with the production process need to be involved to ensure that no steps are missed. Oftentimes companies modify the HACCP flow diagrams after a VA.

Lesson 5: The FDA states in the second installment of guidance (here’s the full copy) to the industry that, “There are many possible approaches to conducting a VA. You may choose an approach based on considerations such as the time and resources available and the level of specificity desired. You have the flexibility to choose any VA approach, as long as your VA contains each required component (21 CFR 121.130).”

The FDA further states that the Key Activity Type, or KAT method, is an appropriate method for conducting a VA because it reflects consideration of the three required elements and the inside attacker. Using this methodology alone, however, can result in substantially more APS’s, which might otherwise be ruled out for practical purposes such as a lack of accessibility or a lack of feasibility to contaminate the product at a point, step or procedure. We have experienced up to a 90% decline in APS’s by utilizing another FDA recommended assessment approach, the hybrid approach, which assesses each point, step or procedure as first whether it is a KAT. Then to qualify as an APS, it must also trigger positively for public health impact, accessibility and feasibility to contaminate the product.

Organizations who have yet to execute vulnerability assessments (due July 26, 2020) or who may wish to reflect back on their existing VA’s in an effort to eliminate unnecessary APS’s should find these strategies helpful to focus limited resources to the areas where they can have the greatest effect. The next two articles in this series will cover more information on electronic access, the value of site tours, comparisons to drinking water security strategies, dealing with multi-site assessments and more. Read Part II of this series on intentional adulteration.

Laura Nelson, Alchemy

Changing Consumer Preferences and Employee Compliance Training Driving Industry Evolution

By Maria Fontanazza
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Laura Nelson, Alchemy

The food industry is undergoing considerable change, especially as consumers become increasingly more vocal about their preferences and concerns, and as technology improvement and adoption plays a larger role in the conversation. In a recent Q&A with Food Safety Tech, Laura Dunn Nelson, vice president of food safety at Alchemy, shares her thoughts about current industry trends and how they are impacting food companies, where more help is needed, as well as ways in which companies can help advance food safety culture internally.

Food Safety Tech: The food industry is rapidly evolving. What are some of the trends you’re seeing and are these posing different challenges to food manufacturers?

Laura Dunn Nelson: The food industry is rapidly evolving in three key areas: Who produces our food, the variety of our food, and how consumers access our food.

As consumers continue to shift their food preferences toward an increase in healthy ingredients, locally sourced products, and clean labels, companies in turn continue to innovate and reformulate. Mergers and acquisitions continue as larger companies look to partner with niche companies that are focused on products marketed to the health-conscious consumer. Companies like Impossible Foods and Beyond Meat are expanding rapidly, reaching both vegans and meat eaters in the United States and expanding into international markets. Ever-changing consumer preferences create challenges for the industry to accelerate their research and development processes in order to remain competitive in the marketplace.

Changes in product formulas and increases in product lines create the need for new ingredient procurement, changes in production schedules, and new operating procedures. There has been a proliferation of start-up companies using CBD as an ingredient for food and beverages despite the lagging food safety regulations forcing some city and state regulators like New York City to create their own ban of CBD products. As the FDA explores future regulations, producers and consumers are left to determine the safety of these products.

Home delivery of food continues to be a hot trend as the market continues to grow for companies like UberEats, Grubhub, retailers and foodservice companies like Domino’s Pizza where you can Tweet your pizza order. The home delivery service area presents new considerations for food safety including monitoring appropriate product temperatures.

Finally, discussion around blockchain technology continues to gain prominence as companies work to develop transparency within their supply chain. For many companies, this will translate into a significant shift in technology adoption and a move away from disparate data sources and therefore an investment in not only the technology but in revising their procurement processes.

Laura Nelson, Alchemy
Laura Nelson is vice president of food safety at Alchemy and currently serves as the vice-chair of the Food Safety Culture Professional Development Group (PDG) for IAFP.

FST: What are the areas in which you feel companies need a bit more guidance?

Nelson: How we effectively train our employees to ensure learning and comprehension is paramount to our success in the future. IBM Institute for Business Value recently completed their study “The Enterprise Guide to Closing the Skills Gap,” and noted “120 million workers in the world’s biggest economies may need to be retrained as a result of artificial intelligence (AI) and automation in the workplace.” Reskilling will be the new norm as new technologies and automation of equipment disrupt the current state.

Deloitte noted that “reinventing the way people learn” was the number one trend in the 2019 Global Human Capital Trends Report. Many companies are focused almost exclusively on mandatory compliance training and conducting the training the same way they have for years. Typically, orientation food safety training is provided during the employee’s first week of work and annual refreshers are given every year. In the Global Food Safety Training Survey that Alchemy provides to the global industry with Campden BRI, we consistently find that 67% of responding QA managers report that employees do not follow their food safety programs, despite their food safety training. Unfortunately, the emphasis on food safety is often relegated to that one day a year of refresher training with little reinforcement the remaining 364 days of the year. The ‘noise’ of competing priorities of production and customer expectations often distracts employees from their food safety responsibilities.

Some companies still define training as classroom training when, in fact, employees are being trained each and every day by their supervisors and peers. Companies that put additional emphasis in not only their training but validation of training through observations of employees’ food safety behaviors achieve higher food safety compliance. The power of two-way conversations between the employee and the supervisor as a coach creates an environment of communication and trust.

Alchemy worked with independent researchers to determine the effect of active coaching with prescribed behavior feedback on the plant floor. The results were conclusive: every facility included in the study revealed a 38% improvement in aligned employee behaviors.

Ultimately, companies need to evaluate their current learning organization for effectiveness and focus on job competencies and their ongoing assessment of compliant employee behaviors.

FST: What maturity level are you seeing in the industry related to food safety culture and the related implementation of best practices?

Nelson: The food industry is still relatively new to the concept of a mature food safety culture, and even how to define that. The industry focus of this topic has largely been driven by efforts within the GFSI community, particularly with the publication of the position paper “A Culture of Food Safety.” Pioneers in food safety culture research, like Dr. Lone Jespersen, and emerging training assessment tools are working toward pushing these newer concepts to the mainstream of our industry.

As with many important constructs, the QA/QC team is typically tasked with introducing this concept to their organization, defining their company’s level of food safety culture maturity, and establishing a continuous improvement plan. This is a tough ask from individuals who typically have a technical education background with little experience in behavioral science. To address these challenges, there are a growing number of consultants, books, and resources to help define a company’s food safety culture maturity and establish improvement strategies.

To help frame the benefits of a mature culture, a recent publication by Lone Jespersen et al, “The Impact of Maturing Food Safety Culture and a Pathway to Economic Gain,” notes the value of a mature food safety culture in reducing the cost of poor quality and food safety risks. Research indicates that many companies are currently in mid-maturity of their food safety culture. Suggested best practices to help an organization mature their food safety culture include:

  1. Foster cross-company ownership of food safety.
  2. Move from compliance driven operations to risk reduction through continuous improvement.
  3. Improve engagement skills of technical staff.

The first step is an assessment to understand the company’s unique performance gaps, either through an internal review or an external assessment. Once the specific gaps are identified, companies can develop their food safety culture improvement plan and execute. It’s helpful to conduct a reassessment over time to ensure the established improvement strategies are successful.

The effort can be challenging but research confirms that a more mature food safety culture will deliver improved food safety performance of food safety behaviors, improved product quality, and a reduction in food safety risks.

Chelle Hartzer, Orkin
Bug Bytes

Stay Audit-Ready, Anytime with Integrated Pest Management

By Chelle Hartzer
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Chelle Hartzer, Orkin

The unlimited supply of food sources that manufacturing facilities provide can make pest management a daunting task, especially with the scrutiny of third-party auditors, government regulators and customers. These high standards, along with yours, mean that diligence is a key ingredient in the recipe for pest management success.

Why is this important? The steps you take to prevent pests, and how issues are resolved if pest activity is detected, affects the overall credibility of your business. After all, pest management can account for up to 20% of an audit score.

Auditors look for an integrated pest management (IPM) plan, which includes prevention, monitoring, trend reports and corrective actions. If you want to stay audit-ready, all the time, implement the following five principles.

Open Lines of Communication

A successful pest management partnership is just that: A partnership. Create an open dialogue for ongoing communication with your pest management provider. Everyone has a role to play from sanitation to inspection to maintenance. For example, if there are any changes in your facility, such as alteration of a production line, let your provider know during their next service visit. During each visit, it’s important to set aside time to discuss what was found and done during the visit, including new pest sightings and concerns.

Communication shouldn’t be limited to the management team; your entire staff should be on board. During their day-to-day duties, employees should know what to look for, and most importantly, what to do if they notice pests or signs of pests. Reporting the issue right away can make a huge difference in solving a pest problem before it gets out of hand. Also, most pest management providers offer staff training sessions. These can be an overview of the basics during your next staff meeting or a specialized training on a pertinent issue.

Inspect Regularly

A thorough inspection can tell you a lot about your facility and the places most at risk for pests. Your pest management provider will be doing inspections every visit, but routine inspections should be done by site personnel as well. Everyone at the site has a set of eyes, so why not use them? This way, you can identify hot spots for pests and keep a closer eye on them. Pests are small and can get in through the tiniest of gaps, so some potential entry points to look out for are:
• Windows and doors. Leaving them propped open is an invitation for all sorts of pests. Don’t forget to check the bottom door seal and ensure it is sealed tight to the ground.

  • Floor drains. Sewers can serve as a freeway system for cockroaches, and drains can grant them food, water and shelter.
  • Dock plates. A great entry point for pests, as there are often gaps surrounding dock plates.
  • Ventilation intakes. These are a favorite spot for perching, roosting or nesting birds, as well as entry points for flying insects.
  • Roof. You can’t forget about the roof, as it serves as a common entry point for birds, rodents and other pests.

Another thing to look for is conducive conditions, such as sanitation issues and moisture problems. These are areas where there may not be pests yet, but they provide a perfect situation that pests could take advantage of if they aren’t dealt with. Make sure to take pictures of deficiencies so that can be shared with the maintenance department or third-party who can fix it. You can also take a picture of the work when it has been finished, showing the corrective action!

Keep It Clean

Proper sanitation is key to maintaining food safety and for preventing and reducing pests. You need a written sanitation plan to keep your cleaning routine organized and ensure no spots are left unattended for too long. The following are some additional steps consider:

  • Minimize and contain production waste. While it’s impossible to clean up all the food in a food processing site (you are producing said food!), it’s important to clean up spills quickly and regularly remove food waste.
  • Keep storage areas dry and organized.
  • Remember FIFO procedures (first in, first out) when it comes to raw ingredients and finished products.
  • Clean and maintain employee areas such as break rooms and locker rooms.
  • Ensure the outside of your facility stays clean and neat with all garbage going into trash cans with fitted lids.
  • Make sure dumpsters are emptied regularly and the area around them kept clean.

Monitoring

Monitoring devices for many pests will be placed strategically around your facility. Some common ones are insect light traps (ILTs), rodent traps and bait stations, insect pheromone traps and glue boards. It’s important to let employees know what these are there for and to respect the devices (try not to run them over with a fork lift or unplug them to charge a cell phone). These devices will be checked on a regular basis and the type of pest and the number of pests will be recorded. This data can then be analyzed over time to show trends, hot spots, and even seasonal issues. Review this with your pest management provider on a regular basis and establish thresholds and corrective actions to deal with the issues when they reach your threshold. The pest sighting log can also be considered a monitoring tool. Every time someone writes down an issue they have seen, this can be quickly checked and dealt with.

Maintain Proper Documentation

Pest management isn’t a one-time thing but a cycle of ongoing actions and reactions. Capturing the process is extremely important for many reasons. It allows you to analyze, refine and re-adjust for the best results. It’s a great way to identify issues early. Also, it’s a critical step for auditors. Appropriate documentation must be kept on hand and up-to-date. There’s lots of documentation to keep when it comes to pest management and your provider should be keeping all of that ready—from general documentation like your annual facility assessment and risk assessment to training and certification records, pest sighting reports, safety data sheets and more.

The documentation aspect may seem like a lot at first, but a pest management provider can break it down and make it easier. It’s absolutely necessary for food and product safety and will become second nature over time.

Ibidun Layi-Ojo, Prometric
FST Soapbox

A Best-Practices Approach to Properly Assessing Food Safety Workers

By Ibidun Layi-Ojo
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Ibidun Layi-Ojo, Prometric

Success Factor 3: Create exams that properly assess the workforce.

Food safety exams give employers the peace of mind that the employees they hire can do the job they were trained to do and help prevent food safety incidents from happening. Equipped with the right training and assessment developed by responsible and qualified companies, employees in the field―ranging from food handlers to food managers―are the first line of defense to uphold the highest of food safety and security standards.

My previous two columns in Food Safety Tech explained important factors that employers need to consider when developing a food safety assessment program. Working with a quality-driven food safety assessment provider to develop the exam is a critical first step. Equally important is the practice of using exams with rigorous, reliable and relatable questions that are developed, tested and continuously evaluated to correlate with market needs and trends.

This article focuses on another key factor that should not be overlooked. In order to properly assess the workforce, exams must reflect best practices for test taking and learning, and be in sync with how the workforce operates and processes information. It is not enough for food safety assessment providers to merely develop questions and exams. A comprehensive exam creation process that takes into consideration technical and human factors allows for a fair assessment of workers’ knowledge and skills, while also providing feedback on exam performance that can be used to adapt exams in an ever-changing industry.

What should employers look for to help ensure that exams can properly assess the food safety workforce?

First, food safety exams should test what a food safety worker needs to know, and quality-driven assessment providers should solicit input from the industry during the exam creation process. Test developers should use surveys, conduct interviews and facilitate panel-based meetings to gather information. They also should invest in close collaboration with industry-leading subject matter experts (SMEs), as well as food handlers, managers and regulators in order to create questions and exams that are relevant. By engaging SMEs during the question writing and exam creation process, qualified food safety assessment providers can pinpoint the important information to be developed into questions and implemented in the exams.

In addition to incorporating industry stakeholder input, it is important for assessment providers to have a comprehensive understanding of the various assessment modalities —from selected response item types, such as multiple choice assessments, to performance-based, interactive scenarios that mirror real-life situations—and select the appropriate modality to maintain test fidelity.

Food safety assessment, training
Image courtesy of Prometric

An assessment provider with this level of proficiency can leverage the combination of its expertise and industry awareness to determine the best modality for the food safety workforce. For example, progressive assessment providers are actively investing in interactive, animated, scenario-based assesments because they believe this type of testing might better assess the skills and knowledge required to successfully perform in the workplace while providing:

  • High candidate engagement levels—with real-life scenarios being more relatable.
  • A safe environment for candidates to practice and understand the consequences of their actions.

Another critical component in creating effective exams is for the assessment provider to continuously review the content and incorporate quantitative and qualitative feedback from data and test takers respectively. By reviewing feedback regularly, asssessment providers can enhance the exams and adjust accordingly—keeping the exam relevant to the workforce and the industry. As the workforce and the industry change, so should food safety exam and certification programs. A feedback loop is essential to help ensure that the exam stays relevant to those who work in the food service industry as they seek to prove that they have mastered the necessary principles and skills to protect the public against food incidents. If a food safety exam does not properly assess the workforce, the consequences can be significant, not only to public health and safety, but also to the companies preparing, handling and serving food that could experience loss of reputation, revenue and the business.

Quality-driven food safety assessment providers follow a best-practices approach for creating exams and certificate/certification programs. They demonstrate a thorough understanding of behavioral learning, the necesary job skills and regulatory compliance requirements. A food safety exam that properly assesses the workforce will:

  • Solicit industry input.
  • Incorporate interactive scenarios that mirror real-life situations.
  • Create a feedback loop and adaptable exams that can easily be modified to stay abreast with the ever-changing industry.

While food handlers may be one of the biggest vulnerabilities in a safe food supply and delivery chain, they also represent one of the greatest opportunities to guard against food safety issues. Developing an effective food safety assessment program as part of a preventative strategy will help ensure both public health and corporate long-term business success.

Bill Bremer is Principal, Food Safety Compliance at Kestrel Management LLC
FST Soapbox

FSMA Checklist: Foreign Supplier Verification Program Requirements

By Bill Bremer
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Bill Bremer is Principal, Food Safety Compliance at Kestrel Management LLC

As all the FSMA rules move to enforcement status, food companies must prepare to best respond to requirements and, correspondingly, to develop required programs such as the Foreign Supplier Verification Program (FSVP) rule. The FSVP requires impacted companies to document specific verification steps to satisfy regulations and meet foreign-supplied shipment information requirements. These requirements took effect on May 30, 2017 for companies importing certain food products to the United States.

How much do you know about FSVP? Test your smarts by taking the FSMA FSVP IQ Test here Ultimately, the purpose of the FSVP is to document the shipping paperwork necessary to provide evidence and verification that a foreign supplier’s food-grade product shipped to a U.S. customer meets the requirements of FSMA. A company’s FSVP may include providing an additional level of evidence that the foreign company distributes safe foreign-supplied food products to the United States, the qualification of these suppliers, verification of supplier and shipment information, and records to verify the shipment of all imported food under FSMA and food safety plans. This information provides the U.S. customer receiving the product necessary proof of compliance and a record that the foreign-supplied material meets imported food product requirements.

Self-Diagnostic Assessment Tool

The following self-diagnostic assessment tool can help organizations better determine their current state of planning when it comes to implementing and managing FSMA FSVP requirements. To complete your own assessment, review and compare your programs to the questions in Table I.

FSMA, Foreign Supplier Verification Program
Table I. Kestrel Management’s self-diagnostic tool can help a company assess its Foreign Supplier Verification Program (FSVP) for FSMA compliance.

Get Compliance-Ready

Companies must have the appropriate systems in place to comply with FSMA FSVP requirements or face possible willful non-conformance, which can include fines and criminal penalties under FDA enforcement. The questions above will help companies identify areas to consider regarding their FSVP programs. Kestrel can also help answer questions, provide input on solutions, discuss how to better manage all your food safety requirements, and change “No” responses into “Yes” responses that promote best practices for FSMA and food safety compliance.