Episode 12 of the 2020 Food Safety Consortium Virtual Conference Series features a discussion on how food safety professionals can bridge the gap between the C-Suite and Food Safety. The presentation is given by food safety attorney Shawn Stevens of Food Industry Counsel, LLC, and followed by a TechTalk from Michael Alderson of STOP Alliance.
As part of a special offering, Episode 12 been made available for viewing on demand for free. Register to view the on-demand recording.
FDA has released an outbreak investigation table that aims to disseminate information about foodborne illness outbreaks right when the agency begins an investigation. The table, published by the FDA’s Coordinated Outbreak Response and Evaluation (CORE) Network, will be updated with important information before a public health advisory or food recall is issued.
“The outbreak investigation table is a demonstration of our continued commitment to more frequent and transparent communication with stakeholders and consumers about outbreaks we’re investigating,” said Frank Yiannas, deputy commissioner for food policy and response at FDA, in an agency statement. “We have already taken steps to release information early, in some cases prior to a specific food being linked to an outbreak, including in our recent communications on investigations into three ongoing E. coli O157:H7 outbreaks.”
As of November 18, the table listed seven outbreak investigations, only one of which identified a product linked to illnesses. Yiannas pointed out that during the early stages of an investigation, there may not be any action that a consumer can take—however, the tool is in line with the New Era of Smarter Food Safety initiative, which commits to releasing outbreak information in the “earliest stages of an investigation”.
The FDA’s outbreak investigation table is available on the agency’s website.
The theme of better traceability and more transparency is a theme that will only grow stronger in the food industry. Just last week we heard FDA Deputy Commissioner for Food Policy and Response Frank Yiannas talk about the agency’s recently proposed FSMA rule on food traceability during the 2020 Food Safety Consortium Virtual Conference Series. In a recent Q&A with Food Safety Tech, Mikael Bengtsson, industry & solution strategy director for food & beverage at Infor, explains yet another role that technology can play in helping companies maintain agility during changes that affect the supply chain such as the coronavirus pandemic.
Food Safety Tech: How can food suppliers mitigate the risks of foodborne illness outbreaks under the stress of the COVID-19 pandemic and with limited resources?
Mikael Bengtsson: Food safety must always be a top priority for any food and beverage company. The risks associated with contamination can have a severe impact for public health, brand and company reputation. Safety routines are therefore always of the highest priority. In today’s situation with COVID-19, the stress on safety is further increased. Now, it’s not only about keeping products safe but also keeping employees healthy. One progression and resource that all food suppliers must follow is the FDA [FSMA rules], which require suppliers to be diligent and document their compliance. Especially now, while suppliers are faced with limited resources and additional stress during the pandemic, they must rely on the basics—ensuring masks are worn in and out of the workplace, washing hands for at least 20 seconds prior to touching any food, and remaining six feet apart from co-workers. When it comes to a crisis like COVID, take solace in knowing suppliers can rely on the basics—even when conditions are strained.
This year we have seen many companies having to adapt and change quickly. Demand has shifted between products, ingredients have been in shortage and many employees have had to work from home. Some were better prepared than others in adapting to the new situation. Technology plays a big role when it comes to agility. Regarding food safety, there are many proactive measures to be taken. The industry leaders establish transparency in their supply chain both upstream and downstream, use big data analysis to identify inefficiencies, as well as couple IoT with asset management systems to foresee issues before they happen.
FST: How can technology help suppliers meet the growing consumer demand for transparency in an end-to-end supply chain and improve consumer trust?
Bengtsson: Communication with consumers is changing. It is not only about marketing products, but also to educate and interact with consumers. This requires a different approach. Of course, consumers are loyal to brands, but are also tempted to try something new when grocery shopping. After a new study is published or a new story is written, consumers are likely to shift their shopping preferences.
It is therefore important to build a closer connection with consumers. Companies who have full supply chain visibility, transparency and traceability have detailed stories to tell their consumers. One way they can build these stories is by including QR codes on their packages. The consumer can then easily scan the code and be brought to a website that shows more product details—e.g. who was the farmer, how were the animals cared for and what sustainability efforts were involved. These are all important aspects to build consumer trust. According to researchers at MIT Sloan School of Management, investing in supply chain visibility is the optimal way to gain consumer trust, and can lead to increased sales.
FST: What technologies should suppliers leverage to better collaborate with trading partners and ensure consistent food safety procedures?
Bengtsson: When a food safety problem arises, batches, lots, and shipments need to be identified within minutes. Manufacturers must be able to trace all aspects of products throughout the entire supply chain—with complete visibility at the ingredient level—from farm to table, and everything in-between. An efficient and transparent food supply chain requires extensive collaboration and coordination between stakeholders. New technologies can extend both amount of collaboration possibilities and the impact of those collaborations. In order to maintain a transparent, efficient food supply chain, companies need to invest in modern cloud-based ERP and supply chain systems that incorporate the increased visibility of the Internet of Things (IoT) with data sharing, supplier and customer portals, and direct links between systems—all aimed at facilitating joint awareness and coordinated decision-making. Modern technologies that enable transparency will also have the added benefits of meeting consumer demand for product information, identifying and responding to food safety issues, reducing food waste, and supporting sustainability claims.
With significant clusters of COVID-19 infection among employees—16,000 cases and 86 deaths documented by the CDC through May 2020 — the food processing and distribution industry faces significant challenges in reopening their facilities and ramping up to full capacity. Technology for health and safety access governance and intelligence, along with guidelines from the CDC and OSHA, can help support food companies in the automation of certain compliance activities and a safe return-to-work strategy.
Designated part of the essential critical infrastructure by the federal government at the onset of the pandemic in the spring of 2020, the food supply chain needs active solutions to protect its workforce. But there’s more to this back-to-work transition. Workers need to feel safe and trust that new security, safety and compliance processes have their best interests in mind—transferring to an overall positive experience with their employer.
In the age of contagion, the food industry requires ways to communicate better with the workforce, identify and isolate areas of contagion and also deal with the lingering presence of potential bioterrorism, insider threat and cyber-attack. It’s a multi-faceted and complex workspace we’re reentering, one that takes coordination of technology, people and processes. Without it, food suppliers risk plant shutdowns and loss of business continuity.
Bioterrorism and insider threat remain an active part of the supply chain landscape. In fact, according to a June 2020 Wall Street Journal Pro Research Survey of cybersecurity executives at nearly 400 companies, 67% were concerned about malicious insiders. Remote workers and lax controls have exacerbated the situation and rising threats include malicious employees, accidental negligence, contractor or vendor misuse and account compromise.
The ongoing coordination between human resources (HR) and security is a collaborative effort that bolsters food defense in a COVID-19 world. Fueled by digital transformation, converged physical security and HR management solutions are wound together tightly in a coordinated and analytical approach to keep food industry employees safe and operations running smoothly.
These departments, once siloed and co-existing without direct interaction, are benefiting from software’s move to the cloud and open operating platforms, which provides increased opportunity for real-time integration of HR, security and facilities technologies. Moving to a converged approach across all departments, including HR, IT/cyber and operational technology (OT)/SCADA—can effectively secure our most critical food production and distribution resources while actively enforcing compliance and company policies, including COVID-19 mandates. In addition, physical security access governance, in a holistic manner, protects food industry workers and processes from compromised identities, systems and insider threats.
HR and physical security now have the ability to share data-insights to prevent, detect and mitigate the spread of contagions. With this convergence, organizations have the information they need to actively defend and protect the workforce, focusing on the human side of security to yield a positive experience.
This time of unprecedented change has triggered a tectonic shift in the way organizations have been dealing with the health, security and safety of their workforce. Sensing a coming tsunami, HR, corporate real estate and physical security leaders are realizing that they must stop operating in silos and embrace a holistic approach. Enterprise response and recovery plans have become a major catalyst for converged security, as it has proven to be the most effective way to manage workspace access, enforce workforce security, safety and privacy.
Physical identity access management (PIAM) software, including visitor identity management (VIM) are convergence platforms that deliver identity and access governance, health and safety intelligence and compliance validation across the enterprise. PIAM provides a safer work environment by managing physical, logical and operational technology access for employees and visitors, actively enforcing company policies, compliance and industry regulations with built-in best practices and regulatory controls. Automated policy-driven background checks yield real-time vetting of visitors, contractors and employees while validating and identifying any policy violations. PIAM and VIM keeps facilities and workers safe, making sure the employees and visitors only have access to the areas, data and assets they need, including vital food processing areas where deliberate sabotage needs to be kept at bay.
While prevention of bioterrorism and insider threat is ongoing at food distribution, production and processing facilities there’s been a notable shift during the pandemic that focuses on the health and safety of workers. Security is no longer simply about keeping the bad guys out; it’s about safety and protecting workers from unsafe behavior.
Workforce health and safety access governance software solutions help organizations open safely in a frictionless, controlled and secure way by automating and enforcing COVID-19 related policies and procedures. Automated batch email/text notifications with self-service links send requests to the remote workforce for self-attestation and self-reporting offsite and enable access by the worker to the facility based on health, travel and other company policies.
Here’s how it works: An employee completes the self-reporting health and travel questionnaire through a mobile app, which triggers automated workflows based on those answers. These health questionnaires collect data and document employee activity during lockdown, including infection, symptoms or exposure. The employee’s self-attestation request comes to the manager for action, and based on answers the worker is considered high risk and per policy their access to the facility is revoked for 14 days while they are in quarantine. A similar self-attestation and workflow then applies to reinstatement for the employee. This reporting and workflow can be configured specifically to the facility. Enterprises can further customize their visitor identity management to provide clear communication of current policies during the outbreak, reinforcing WHO best practices.
Health and safety access governance and intelligence provides prescreening support of workforce site entry with automated policy enforcements. Pre-registered and onsite visitors/contractors check-in/check-out with prescreening, watch list and other checks prior to access. In the production or distribution facility, health and safety analytics track confirmed or potentially exposed COVID-19 workers, identify exposed areas for lockdown and/or sanitization, social distancing violation, location heat map and other actionable health & safety analytics.
PIAM also allows you to automate your communications and deliver clear expectations and procedures to your workforce, visitors and contractors pre-visit and onsite—adding to a seamless experience.
Security convergence delivers a comprehensive, holistic solution across the entire food value chain, from sourcing to production to retail distribution. Human resources and physical security have teamed up—yielding real-time data that can prevent, detect and mitigate the spread of contagions. With this convergence comes greater situational awareness that defends and protects the workforce, with a strong focus on safety and building trust between worker and employer.
The COVID-19 pandemic emphatically laid bare the supply chain and supplier vulnerabilities that we face in our increasingly global food supply chains. Last month my company, Mesh Intelligence, convened a group of 14 leading supply chain, risk, sourcing and food safety executives drawn from some of the largest and most innovative food companies around the globe and in all aspects of the supply chain—from manufacturing, importing, distribution, logistics and retail. They volunteered their time to explore new solutions to better manage risk in their global food supply chains and are working together to develop and guide a lasting solution to address the challenges they faced across the past few months and manage supply chain in a more uncertain environment.
The group discussed how the tools and processes they currently use to manage supply chains are inadequate in identifying the scale, scope and intensity of new issues that arose during the pandemic and, more importantly, how these solutions need to be augmented in the future. To zero in on practical solutions, this group focused on the most critical challenges to address; understanding the best practices to tackle these issues; and guiding the development of data driven, practical and scalable solutions to predict risk.
Key insights from the group discussion include:
Participants of the group are also getting early access to the solution and data to support them in their food safety and supply chain risk management efforts. The group will continue to meet on over the next few months to continue to guide the development of a food supply chain risk management solution. We look forward to keeping you updated. If you have insights on this issue, we encourage you to reach out. If you are interested in learning more about us or joining the group, please contact us at nicole@meshintel.com
Technical writing is not as simple as it sounds—especially as it relates to writing non-conformances and CAPAs. Innovative Publishing is offering a Technical Writing Virtual Workshop that takes place over two two-hour sessions on March 3 and 10. The event is being hosted by Food Safety Tech’s sister publication, MedTech Intelligence, but the content is applicable to the food industry as well.
The course will be instructed by world-class, international quality and regulatory consultant Mark Proulx, president of MLB Consulting Services. Proulx has more than 25 years of direct manufacturing, auditing, and FDA experience and is a certified quality auditor and Six Sigma Black Belt.
The workshop was developed for the following industry professionals:
Learn more about this special Technical Writing Virtual Workshop now! Register by February 11 for a special discount.
Industry from the public and private sector joined for a record turnout during the FDA public meeting yesterday to discuss the agency’s initiative, a new era of smarter food safety. The meeting, which was at maximum capacity for both in-person as well as webcast attendance, began with a call to action from FDA Deputy Commissioner, Office of Food Policy and Response, Frank Yiannas on the importance of all stakeholders in the industry to work together to drive the change. As Yiannas has previously commented, the food industry is in the midst of a revolution. The world is changing faster than ever, and the FDA is challenged with not just creating a safer, more technology-centric and traceable food system, but also getting there faster and more effectively. “I’ve always believed that words we use are important,” he said. As the day’s various discussions would be around the new era of smarter food safety, Yiannas gave the audience a definition to consider: “A new era is a memorable or important date or event, especially one that begins with a new period in our history.”
FDA held breakout sessions centered on areas critical to the initiative:
During each session, FDA facilitators asked the audience questions. The following are some key points brought out during the breakouts.
The FDA meeting also included panel discussions that drew out the realities FDA must consider in this rapidly changing environment. “These are exciting times and this initiative is recasting our thinking in a whole new light,” said CFSAN Director Susan Mayne, adding, “We need to get ahead of these challenges and not be in reactive mode.”
Consumer awareness and demands for healthy, locally sourced and minimally processed food, for example, are creating increased pressures on food companies and retailers. In addition, the digital savvy and diverse Generation Z (the population born between 1990 and 2010, which will comprise nearly 40% of the U.S. population by 2020) has buying habits and a strong desire for transparency that is shifting how food companies will need to do business, according to Mary Wagner, president of MX Wagner & Associates.
“Trust represents safety, quality and commitment on a much more personal level to our consumers,” said Dirk Herdes, senior vice president at the Nielsen Company, emphasizing the need to communicate with authenticity. “Consumers have never been more informed, but never have been more overwhelmed with information. It’s not data—it’s trust. Trust is the new currency with which we’ll operate.”
FDA and USDA also remain committed to building a stronger relationship between the agencies, said Mindy Brashears, Ph.D., deputy undersecretary for food safety at USDA. “As science moves forward, we have to allow our policies to move forward to keep consumers safe,” she added.
The comments shared during yesterday’s meeting, along with written and electronic comments (with a deadline of November 20), will be considered as FDA puts together its blueprint document for a new era of smarter food safety. More information about providing comments can be found on the Federal Register page.
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.
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.
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.
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!
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:
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.
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.
Fostering a strong food safety culture is one of the most important things those in leadership in the food manufacturing and processing industries can do. Whereas laws dictate the food safety regulations to which food manufacturers and processors should adhere, facility food safety and color-coding plans dictate how those regulations should be followed, and it is the inherent culture of the facility that ensures these guidelines and procedures will be followed. A facility’s culture is made up of the shared values of the company, the unwritten norms—good and bad—that ultimately influence the behavior of those in the company. It most often stems from those at the leadership level as they set the tone and expectations for the organization.
Most importantly, however, is the understanding that culture is fluid. Be-cause it is not defined but rather just is, a culture can morph over time in a ripple effect manner. If those in leadership begin to place a higher emphasis on food safety, middle level managers will take note and those sentiments—consciously or unconsciously—will be echoed to those lower in the company’s organizational hierarchy.
At the same time, the reverse is equally and, perhaps, even more likely, true. It’s often harder to do the right thing when it comes to food safety; there are extra steps involved to ensure the environment and tools used are clean, to check and double check the quality of the product and to communicate any concerns that may be encountered along the way. It’s easy to look at someone who takes shortcuts—particularly someone at a higher level than you—and decide that’s an accepted behavior. This can lead to devastating results quickly in a food processing or manufacturing facility where everything from the profit margins to the ability to employ workers to the legal standing of the company hinges on quality assurance.
That said, it’s important that those at the leadership level prioritize foster-ing a positive food safety culture by leading by example. Additionally, it’s vital to regularly glean a quick read of the room to stay on top of culture shifts. The following are some questions you can use to guide that check-in and identify potential red flags long before those worst-case scenarios have a chance to play out.
If you would put your company in the first category, it’s important you take some time to consider the procedures and guidelines put in place in your facility. Whereas you want company-wide buy-in for overarching food safety priorities, the job role will look very different for, say, someone on the packaging line versus the janitorial team. Within those teams, there should be a shared vernacular and routine specifically related to the job role they need to carry out. It’s unfair and perhaps a bit risky to assume that employees will know how to best carry out their job if “best” is never properly defined for them in training procedures.
The actions and words of those at the highest level of an organizational hierarchy set expectations for the entire company. It’s not only important that they communicate the importance of food safety to the company, but that they return to that conversation often. It’s a good idea to reiterate the significance of food safety considerations in vision and mission statement documents but to also bring it up during staff meetings, company-wide emails and annual reports. Food safety trainings should be held regularly as the more of-ten you highlight these expectations, the more they are thought about across the company. That consideration is what ultimately leads to action.
Again, we cannot stress enough the importance of those at the top setting the tone for a positive food safety culture by not only talking the talk but also walking the walk. Employees will take note if those higher up in the company who take time out of their day to partake in food safety training. It sends the message that this is indeed important to the company and therefore should be important to the employees.
Just as a teacher in grade school aims to consider the unique learning styles of students, you should be mindful of the ways in which you are communicating with your team. Some people retain information best through auditory exposure, some are more visual learners and, for some, recall is best after hands-on activities. Consider the ways in which your currently communicate food safety expectations to employees and take note of any additional approaches you might need to take to best reach all employees.
Along those same lines, you should be mindful of additional considerations that might be necessary depending on the makeup of your staff. We recommend working closely with human resources to identify whether or not you should incorporate multi-lingual training procedures and how to best accommodate any employees with disabilities.
The mistake a lot of facilities make is focusing too much on what it looks like for things to go as planned and to overlook procedures for when things don’t go according to plan. If you asked any member of your team, they should be able to tell you the preferred method for reporting any concerns related to food safety. We recommend polling a few employees across different job roles to see if that is the case. If not, it’s vital you establish a protocol and clearly communicate that protocol to all employees. The easier the protocol, the more likely employees are to remember it and to follow through when necessary.
Traceability and risk management go hand-in-hand. In a Q&A with Food Safety Tech, Bryan Cohn, food safety solution engineer at FoodLogiQ, shares his thoughts on risk and the critical role of communication.
Food Safety Tech: What does risk analysis mean in a complex supply chain?
Bryan Cohn: Risk analysis means the same thing it has always meant. The concept of risk is elemental; it transcends all of humanity and is rooted deep within our very DNA. Sure, we’ve added tools and technology to help us, but we still can not see into the future; thus, there will always be a risk. The best way to perceive, evaluate and comprehend risk in a complex world is faster and more accurate communications.
FST: Why is communication critical to avoid or mitigate risks within the supply chain?
Cohn: Let’s use an analogy here. Nobody likes traffic, right? In the morning when you’re getting ready for work, you might turn on the local news or check your favorite navigation app to find out the traffic conditions along your commute. You know your commute like the back of your hand, and you’re aware of every potential trouble spot along the way. But like most of us, you probably rely on fast and accurate communication from either traffic cameras, local news reports, or navigation information on your phone to give you a real-time analysis of what is happening. So aside from the usual trouble spots, you are made aware of any unexpected traffic accidents, road construction, or weather delays, which allows you to make real-time, actionable decisions about your commute.
If we think ahead – the same way we do about our work commute – and re-evaluate our communication strategy around our supply chains, we can begin to take a much stronger proactive approach to risk analysis and mitigation. If we spot a trend within our supply chain that may increase risk, we can take action before a threat materializes or intensifies.
FST: Can your risk management plan create value in the company?
Cohn: Any time a good communications strategy is integrated into your risk management program, you create value. By soliciting, evaluating and responding to feedback, you will inherently mitigate risk by addressing potential problems before they become problems and identifying new threats in a fast moving complex supply chain.
