If global supply chains were considered complex before COVID-19, it’s hard to imagine what we’d call them now. Is there a single business operating exactly as it did before the pandemic?
All the more surprising, when survival would seem to be the top priority, pre-pandemic risk factors are not only alive and well, but they also actually outweigh coronavirus as strategic business concerns. In fact, COVID-19 didn’t even make the top five risk factors in the World Economic Forum’s 2020 Risk Report.
“While the risk of a pandemic was noted as important in the report, and something for which we are unprepared globally, it was not identified as one of the top five risks in terms of likelihood or impact in the 2020 survey. High-impact and highly probable risks, such as climate change, biodiversity loss and water crises, are just as present now as they were before the pandemic started . . .”
In our experience, some pre-pandemic business trends have actually gone from “warm and fuzzy” to red hot in spite of, or perhaps even due to, the COVID chaos. One prime example is in the case of social audits.
Social audits have been increasingly used over the past decade to evaluate corporate social responsibility and, indeed, the ethical conduct of entire supply chains. We’ve worked extensively with some of the biggest names in consumer electronics to conduct hundreds of social audits among component suppliers of all sizes. These assessments are mandatory, not by law, but by business policy. The vast scope reflects the importance—and business value—of operational factors that go beyond pure economics, whether it’s related to labor practices, health and safety, or environment.
A growing number of organizations strongly believe that social responsibility and profits are not mutually exclusive; they are in fact enablers of one another—but only if you commit to mining the full value of these programs. Think of it like data mining. Within any large body of information, you can almost always find hidden value. If you know how to look and have the proper tools. In the case of social auditing, the tools are the insights and methods employed by the auditing teams.
This is such a vital concept that we have designed its social auditing process to exceed even what the Responsible Business Alliance requires in its code of conduct. As a baseline, like every other auditor, we first look for nonconformities, which are the most serious issues requiring immediate attention. We also report “observations”, a second level of findings that speaks to things that are suboptimal but are not out of compliance, per se. That’s where it usually stops. This is the mentality of fault finding. And it has defined social auditing for a long time.
We can, and do, break that mold. Taking another critical step to ask, “what’s going right?”, provides an extra level of inquiry that probes for opportunities embedded in the fabric of the way things work. It could be an unrecognized best practice, something that people have been doing but nobody took the time, or had the awareness, to document and share. Often times, it’s something frontline workers have done as a response to an unexpected development, like a pandemic that makes you work from home.
In one service-based organization, we found that the sudden shift to working from home led to an unwelcomed rise in cases of domestic violence. We discovered this during audits of pay rates and working hours. The company was able to develop an innovative response, establishing a framework of verbal signals that workers now use to communicate stress or threat. In another instance, while auditing a large industrial company for workplace safety, we found that employees were using a shortcut to avoid a required safety measure. By probing and asking questions in a non-accusatory way, those same workers recommended a very simple workaround to the workaround—thereby restoring the safety measure without adding complexity to the task.
The key to all of this is mindset. Not just ours (the auditors), but the client organization’s as well. You must be willing to broaden the very idea of “compliance.” Sometimes, things that are out of spec are that way for a reason. Rather than lump every outlier as a flaw, you should look beneath the surface and see if there’s a good reason for it. That doesn’t automatically mean nonconformities are suddenly something else. But if you are only looking for problems, that’s all you’re going to find.
I don’t have to tell you that COVID-19 is a crisis, and the consequences have been immediate and difficult. But as I speak to clients and look beyond the immediacy of the problems the food industry is facing, I am seeing positive insights that can help us now and in the future.
Food safety culture hasn’t always been clearly defined, nor has it been a “must” in many food safety systems. But the reality is that food safety culture—and the buy-in that needs to happen in your entire organization—is a direct and important element for staying up to date with new rules and being consistent and compliant at every location.
What Does Food Safety Culture Mean Now?
The definition I have liked most is “food safety culture is what you’re doing when no one is watching.” But with the coronavirus pandemic, everyone is always watching, so the definition must expand.
Customers are carefully watching every employee at every location to gain a feeling of safety and trust at restaurants and eateries. And if employees aren’t up to speed or don’t have buy-in to your food safety culture, or even food safety in general, a single incident can turn away customers for good.
As an example, I recently visited a favorite taco joint. After the cashier rang me up, he put hand sanitizer on his gloves and proceeded to put handfuls of chips into my takeaway bag with those same “sanitized” gloves. I will not be going back.
So, food safety culture is still about what you do when no one is watching and when everyone is watching, making participation from every member of your organization critical.
What Can You Do Now to Enhance Food Safety Culture?
Practices that enhance food safety culture should initiate a shift in perspective before you implement more tangible activities. These shifts will be more challenging because they require your entire organization to be on board.
Perspective Shifts for Food Safety Culture
One or more paradigm shifts may be necessary to make enhancing your food safety culture successful. Sometimes initiatives like food safety culture can feel more like another addition to your to-do list rather than an asset that ultimately makes the job of a quality manager easier. So, consider these suggested shifts as you move forward.
Food safety culture is part of your food safety system and your corporate social responsibility plans. With any crisis, not just the current pandemic, the values and expectations you instill in your employees can give you an immovable base, even if the surface is in constant fluctuation. And whether you’re dealing with an outbreak or a pandemic, showing you put customers and location employees first demonstrates good corporate citizenship.
Location employees can be your biggest asset or your biggest liability. Employees perform better when they know the purpose behind what they’re doing rather than following rules that may seem arbitrary if they don’t have a clear understanding of why.
Punitive systems encourage hiding problems; supportive systems encourage collaboration and trust. If employees feel safe reporting issues or problems at their location, the more likely they’ll catch small issues before they become huge liabilities.
Food safety culture can be a huge asset. In other words, instead of looking at food safety culture as another chore in your already crowded list, see it as an asset that improves food safety and creates better work environments, which inherently decreases risk and protects your brand.
In-Practice Shifts for Food Safety Culture
The paradigm shifts suggested above help build a support perspective for a strong food safety culture. The following shifts I suggest can help you implement tangible actions that benefit every level of your organization.
Take great care of location employees. These employees are in direct contact with customers the most, and they are truly your first line of defense. Which means they can be an incredible asset or the weakest link.
Consider audit and checklist software over laminated or paper checklists. The right software or app can instantly push new policies or standards to every location and employee at the same time, so everyone is always on the same page. Choose software or other tools that 1) makes it easy for all employees to get the information they need; 2) helps them quickly build behaviors that serve your quality and safety programs; and 3) empowers them to confidently share issues that need to be corrected so you get a true view of the health of any location.
Consider quality management system software. With a platform (there are many that include audit and checklist tools), you can collect data points more quickly and from more sources to create a single source of truth and deepen insights. Software can directly support food safety culture, helping you:
Find new insights and continually improve your processes
Systematically rollout new policies and procedures
Drive adoption of new policies and “build muscle memory” so employees build good habits
Validate that your policies and practices are followed in every location
Identify locations or policies that need increased focus while you reward areas of successful performance.
Look at your organization from a 30,000-foot perspective. This is not so easy to do if you are using manual processes such as paper, file cabinets or even spreadsheets. With those tools, you can see data points, but it takes a lot of work to build a big-picture view. Again, this is where software is invaluable. Many quality management system software options include built-in analytics and reporting, which means much of the work is done for you, saving you valuable time.
I hope your main takeaway from this article is that surviving a crisis requires a strong food safety culture. It helps unify employees across your organization, so everyone knows what’s expected of them and how their work affects the big picture. I see strong evidence that enhancing your food safety culture is more than the “next thing on your to-do list.” It’s a tool that you can put to work to decrease risk, increase compliance, and find small issues before they become huge problems.
Recent food scandals around the world have generated strong public concerns about the safety of the foods being consumed. Severe threats to food safety exist at all stages of the supply chain in the form of physical, chemical and biological contaminants. The current pandemic has escalated the public’s concern about cross contamination between people and food products and packaging. To eliminate food risks, manufacturers need robust technologies that allow for reliable monitoring of key contaminants, while also facilitating compliance with the ISO 17025 standard to prove the technical competence of food testing laboratories.
Without effective data and process management, manufacturers risk erroneous information, compromised product quality and regulatory noncompliance. In this article, we discuss how implementing a LIMS platform enables food manufacturers to meet regulatory requirements and ensure consumer confidence in their products.
Safeguarding Food Quality to Meet Industry Standards
Food testing laboratories are continually updated about foodborne illnesses making headlines. In addition to bacterial contamination in perishable foods and ingredient adulteration for economic gains, chemical contamination is also on the rise due to increased pesticide use. Whether it is Salmonella-contaminated peanut butter or undeclared horsemeat inside beef, each food-related scandal is a strong reminder of the importance of safeguarding food quality.
Food safety requires both preventive activities as well as food quality testing against set quality standards. Establishing standardized systems that address both food safety and quality makes it easier for manufacturers to comply with regulatory requirements, ultimately ensuring the food is safe for public consumption.
In response to food safety concerns, governing bodies have strengthened regulations. Food manufacturers are now required to ensure bacteria, drug residues and contaminant levels fall within published acceptable limits. In 2017, the ISO 17025 standard was updated to provide a risk-based approach, with an increased focus on information technology, such as the use of software systems and maintaining electronic records.
The FDA issued a notice that by February 2022, food testing, in certain circumstances, must be conducted in compliance with the ISO 17025 standard. This means that laboratories performing food safety testing will need to implement processes and systems to achieve and maintain compliance with the standard, confirming the competence, impartiality and consistent operation of the laboratory.
To meet the ISO 17025 standard, food testing laboratories will need a powerful LIMS platform that integrates into existing workflows and is built to drive and demonstrate compliance.
From Hazard Analysis to Record-Keeping: A Data-Led Approach
Incorporating LIMS into the entire workflow at a food manufacturing facility enables the standardization of processes across its laboratories. Laboratories can seamlessly integrate analytical and quality control workflows. Modern LIMS platforms provide out-of-the-box compliance options to set up food safety and quality control requirements as a preconfigured workflow.
The requirements set by the ISO 17025 standard build upon the critical points for food safety outlined in the Hazard Analysis and Critical Control Points (HACCP) methodology. HACCP, a risk-based safety management procedure, requires food manufacturers to identify, evaluate and address all risks associated with food safety.
LIMS can be used to visualize control points for HACCP analysis according to set limits. Graphic courtesy of Thermo Fisher Scientific.
The systematic HACCP approach involves seven core principles to control food safety hazards. Each of the following seven principles can be directly addressed using LIMS:
Principle 1. Conduct a hazard analysis: Using current and previous data, food safety risks are thoroughly assessed.
Principle 2. Determine the critical control points (CCPs): Each CCP can be entered into LIMS with contamination grades assigned.
Principle 3. Establish critical limits: Based on each CCP specification, analytical critical limits can be set in LIMS.
Principle 4. Establish monitoring procedures: By defining sampling schedules in LIMS and setting other parameters, such as frequency and data visualization, procedures can be closely monitored.
Principle 5. Establish corrective actions: LIMS identifies and reports incidents to drive corrective action. It also enables traceability of contamination and maintains audit trails to review the process.
Principle 6. Establish verification procedures: LIMS verifies procedures and preventive measures at the defined CCPs.
Principle 7. Establish record-keeping and documentation procedures: All data, processes, instrument reports and user details remain secured in LIMS. This information can never be lost or misplaced.
As food manufacturers enforce the safety standards set by HACCP, the process can generate thousands of data points per day. The collected data is only as useful as the system that manages it. Having LIMS manage the laboratory data automates the flow of quality data and simplifies product release.
How LIMS Enable Clear Compliance and Optimal Control
Modern LIMS platforms are built to comply with ISO 17025. Preconfigured processes include instrument and equipment calibration and maintenance management, traceability, record-keeping, validation and reporting, and enable laboratories to achieve compliance, standardize workflows and streamline data management.
The workflow-based functionality in LIMS allows researchers to map laboratory processes, automate decisions and actions based on set criteria, and reduce user intervention. LIMS validate protocols and maintain traceable data records with a clear audit history to remain compliant. Data workflows in LIMS preserve data integrity and provide records, according to the ALCOA+ principles. This framework ensures the data is Attributable, Legible, Contemporaneous, Original and Accurate (ALCOA) as well as complete, consistent and enduring. While the FDA created ALCOA+ for pharmaceutical drug manufacturers, these same principles can be applied to food manufacturers.
Environmental monitoring and quality control (QC) samples can be managed using LIMS and associated with the final product. To plan environmental monitoring, CCPs can be set up in the LIMS for specific locations, such as plants, rooms and laboratories, and the related samples can then be added to the test schedule. Each sample entering the LIMS is associated with the CCP test limits defined in the specification.
Near real-time data visualization and reporting tools can simplify hazard analysis. Managers can display information in different formats to monitor critical points in a process, flag unexpected or out-of-trend numbers, and immediately take corrective action to mitigate the error, meeting the requirements of Principles 4 and 5 of HACCP. LIMS dashboards can be optimized by product and facility to provide visibility into the complete process.
Rules that control sampling procedures are preconfigured in the LIMS along with specific testing rules based on the supplier. If a process is trending out of control, the system will notify laboratory personnel before the product fails specification. If required, incidents can be raised in the LIMS software to track the investigation of the issue while key performance indicators are used to track the overall laboratory performance.
Tasks that were once performed manually, such as maintaining staff training records or equipment calibration schedules, can now be managed directly in LIMS. Using LIMS, analysts can manage instrument maintenance down to its individual component parts. System alerts also ensure timely recalibration and regular servicing to maintain compliance without system downtime or unplanned interruptions. The system can prevent users from executing tests without the proper training records or if the instrument is due for calibration or maintenance work. Operators can approve and sign documents electronically, maintaining a permanent record, according to Principle 7 of HACCP.
LIMS allow seamless collaboration between teams spread across different locations. For instance, users from any facility or even internationally can securely use system dashboards and generate reports. When final testing is complete, Certificates of Analysis (CoAs) can be autogenerated with final results and showing that the product met specifications. All activities in the system are tracked and stored in the audit trail.
With features designed to address the HACCP principles and meet the ISO 17025 compliance requirements, modern LIMS enable manufacturers to optimize workflows and maintain traceability from individual batches of raw materials all the way through to the finished product.
Conclusion
To maintain the highest food quality and safeguard consumer health, laboratories need reliable data management systems. By complying with the ISO 17025 standard before the upcoming mandate by the FDA, food testing laboratories can ensure data integrity and effective process management. LIMS platforms provide laboratories with integrated workflows, automated procedures and electronic record-keeping, making the whole process more efficient and productive.
With even the slightest oversight, food manufacturers not only risk product recalls and lost revenue, but also losing the consumers’ trust. By upholding data integrity, LIMS play an important role in ensuring food safety and quality.
With the COVID-19 pandemic continuing to take a toll on live events, Innovative Publishing Company, Inc. has made the careful decision to convert the Food Safety Consortium, which historically has taken place in Schaumburg, IL, to a virtual conference. This move takes into consideration Illinois’ COVID-19 plan to reopen its economy, which is a Five-Phase Plan. Phase 5 occurs when groups larger than 50 (conferences and conventions specifically mentioned) will be allowed. The state enters Phase 5 only when a vaccine or an effective treatment is in place. The decision to take the Food Safety Consortium virtual is based on the Illinois reopening plan, along with considering the safety and well being of staff, attendees, speakers and sponsors.
Every Thursday, beginning on September 10 through November 12, the Food Safety Consortium Virtual Conference Series will host two presentations and two sponsored Tech Talks, followed by a panel discussion with attendees. Food Safety Tech is the media sponsor.
“This will be much more than a bunch of webinars. We are excited to offer a virtual platform that facilitates greater human interaction,” says Rick Biros, president of Innovative Publishing and director of the Food Safety Consortium. “Whether it’s a random connection in a hotel lobby, a stroll by a booth at a trade show, or a seat next to a new friend in a learning session, we recognize that human connection is important for events. That’s why we’ve invested in new tools for the FSC Conference Virtual Platform to ensure those discussions, discoveries and connections can go on whether our event is offline or online. The new platform provides attendees with a way to keep track of live sessions, connect with sponsors and engage with peers, all in a familiar way. It will also include an event App that offers interactive features.”
Frank Yiannas, FDA deputy commissioner for food policy and response, will remain a keynote speaker, with the new presentation date to be announced.
Call for Abstracts
We are accepting abstracts for participation in the Food Safety Consortium Virtual Series. On the Submit an Abstract page, select Food Safety Consortium 2020 in the drop-down menu.
Categories include:
Food safety
Food defense
Food integrity
Food safety supply chain management
Lessons learned COVID-19
Regulatory compliance
Facility design
C-suite executive forum
Tech Talk Sponsorship
Companies that are interested in sponsoring a 10-minute technical presentation during the series can also submit their abstract through the portal. For pricing information, contact IPC Sales Director RJ Palermo.
Food Safety Tech publishes news, technology, trends, regulations, and expert opinions on food safety, food quality, food business and food sustainability. We also offer educational, career advancement and networking opportunities to the global food industry. This information exchange is facilitated through ePublishing, digital and live events.
About the Food Safety Consortium Conference and Expo (The live event)
Food companies are concerned about protecting their customers, their brands and their own company’s financial bottom line. The term “Food Protection” requires a company-wide culture that incorporates food safety, food integrity and food defense into the company’s Food Protection strategy.
The Food Safety Consortium is an educational and networking event for Food Protection that has food safety, food integrity and food defense as the foundation of the educational content of the program. With a unique focus on science, technology and compliance, the “Consortium” enables attendees to engage in conversations that are critical for advancing careers and organizations alike. Delegates visit with exhibitors to learn about cutting-edge solutions, explore three high-level educational tracks for learning valuable industry trends, and network with industry executives to find solutions to improve quality, efficiency and cost effectiveness in the evolving food industry.
Several leading consumer packaged goods (CPG) brands and retailers started collaborating last year to address an issue growing larger by the day—inaccurate product data in the supply chain. They have challenged themselves to better serve customers who are shopping for their groceries more and more with smartphone in hand or shopping online. These companies worked together with the common understanding that standardization is imperative to have a consistent view of product data across the supply chain.
A new, global cloud-based registry that will help trading partners confirm the unique identity of products. Image courtesy of GS1.
The group led by GS1 and the Consumer Goods Forum focused on the root causes of bad data in the retail grocery industry. Verified by GS1— a new, global cloud-based registry that will help trading partners confirm the unique identity of products—resulted from these discussions. It will serve as a single source for retailers, marketplaces and the solution providers they work with to automatically check core product attributes to help ensure the integrity of product listings.
For these recipients to access trusted data through this registry platform, brands must first provide seven core attributes for an “identification card” for products, similar to the identification card you carry around in your wallet. Much like eye color, hair color and height, products have attributes used by retailers to confirm the product is what a brand says it is. Each one provides a layer of trust to help increase efficiency and accuracy in the supply chain.
Let’s break down the importance of these attributes and learn why they are essential to confirm a product’s unique identity.
The Identification Number
Global Trade Item Number (GTIN) is used to uniquely identify a trade item in the global supply chain. This number is encoded into the U.P.C. barcode used at the point of sale or can be included in online product listings.
The GTIN plays a critical role in a product’s identity due to the way it is constructed. The brand owner selling the product is identified in the number itself in the form of a company prefix, the first few numbers of the GTIN. But over the years, erroneous numbers have plagued the CPG industry. A prefix that has four zeros, for example, is an indicator that the GTIN is not unique and might have been the result of human error. Also, some brand owners have found that GTINs were “borrowed” from other products during the setup process, resulting in duplicate GTINs in the supply chain, often tied to very different products. The GTIN is the key piece of information for a retailer to know they are working with a reputable company and can confidently add a product to their offering.
The Essential Descriptors
Brand name is another important part of a product’s identity, especially in relation to its GTIN. Verified by GS1 will provide a way for brands and retailers to make sure the right brand name is used in connection with the right GTIN. GS1 worked with member companies to set forth a common definition for brand name to increase consistency in the supply chain. It is a name provided by the brand owner that is intended to be recognized by the consumer as represented on the product.
Let’s say your company makes jam. The brand name would be Sticky’s Traditional, because that is what’s recognizable by the consumer. Some contributors to Verified by GS1 were surprised to find extreme inconsistencies with brand names in their backend systems, which caused confusion for consumers who searched online for familiar keywords and came up with nothing.
Product description is defined as a description of a product using a combination of key elements familiar to consumers, such as flavor or scent. The description should be unique so that consumers can properly distinguish it from other products. In our jam example, the product description is just what it sounds like it would be: Sticky’s Traditional Raspberry Jam, Low Sugar, 18 oz.
An example of a standard, front-facing product image URL. Image courtesy of GS1.
Much like your driver’s license describes what you look like through eye color, hair color, or whether or not you wear glasses, the product description is what the consumer can visually confirm when they look at the package. Another key attribute in the Verified by GS1 identification card, the product image URL, serves the same purpose. A standardized product image clearly depicts the product being sold, and the industry can now align on a common naming convention for the image as well as how to communicate the image to trading partners.
The Necessary Technical Components
The three remaining parts of the product’s ID card are the components of identification most important for machines to read and understand and are less sought-after by consumers. Global product category, for example, is a classification code developed in accordance with GS1 Standards that provides buyers and sellers a common language for grouping products in the same way. It could be used as classifying option for consumers shopping online. In our jam example, the global product category is “10000581 – Food Glazes (Shelf Stable).”
Net content and unit of measure are essential to commonly represent a product’s weights and dimensions. This attribute makes it clear that metrics and units of measure go hand-in-hand—our jar of jam cannot just say NET 18. It needs to say it weighs NET 18 OZ. Either of these attributes independent of each other are red flags that the data is erroneous.
Country of sale or target market are used interchangeably and both indicate the location where the product is being sold. For multinational companies selling products in more than one country, this becomes important to ensure the right language is on the right product packaging to match the target market where it is being sold. For example, one product that has French on its packaging should signify France as its country of sale/target market, while an identical product with German on its packaging should be coded for Germany.
All seven attributes are pieces of information deemed important to consumer satisfaction and serve as a jumping off point for the transparency initiatives being demanded by consumers. While it is only just ramping up in the retail grocery industry now, Verified by GS1 is designed to help several different types of industries confirm product identity. It has the potential to significantly improve the foundational data that will only grow in importance as more consumers shop digitally.
Ultimately, as more data is shared consistently according to standards, incremental progress will be made toward the ultimate goal of cementing the trust of consumers, no matter where and how they encounter information about the products they purchase.
— UPDATE — March 9, 2020 – IPC and the Food Labs/Cannabis Labs Conference want to reassure you, that in case of any disruption that may prevent the production of this live event at its physical location in Rockville, MD due to COVID-19, all sessions will be converted to a virtual conference on the already planned dates. Please note that if you initially register as a virtual participant (meaning you have no intentions of traveling to the event regardless) and the on-site event is not cancelled, you will ONLY be able to listen to the General Sessions and the Cannabis Sessions. You will have not have access to the Food Labs Sessions and there will be NO recording of these sessions. If you have any questions, please contact Veronica Allen, Event Manager.
–END UPDATE —
EDGARTOWN, MA, Jan. 22, 2020 – Innovative Publishing Co., the publisher of Food Safety Tech and organizer of the Food Safety Consortium Conference & Expo is announcing the launch of the Food Labs Conference. The event will address regulatory, compliance and risk management issues that companies face in the area of testing and food laboratory management. It will take place on June 3–4 in Rockville, MD.
Some of the critical topics include discussion of FDA’s proposed FSMA rule, Laboratory Accreditation Program for Food Testing; considerations in laboratory design; pathogen testing and detection; food fraud; advances in testing and lab technology; allergen testing, control and management; validation and proficiency testing; and much more.
The event is co-located with the Cannabis Labs Conference, which will focus on science, technology, regulatory compliance and quality management. More information about this event is available on Cannabis Industry Journal.
“By presenting two industry conferences under one roof, we can provide attendees with technology, regulatory compliance and best practices that cannabis and food might share but also focused topics that are unique to cannabis or food laboratory industry needs,” said Rick Biros, president of Innovative Publishing Co., Inc. and director of the Food Labs Conference.
The agenda and speakers will be announced in early March.
About Food Safety Tech Food Safety Tech publishes news, technology, trends, regulations, and expert opinions on food safety, food quality, food business and food sustainability. We also offer educational, career advancement and networking opportunities to the global food industry. This information exchange is facilitated through ePublishing, digital and live events.
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:
Engineers responsible for writing up investigations and reports
Tech writers who must communicate the results of testing in reports, write up papers, produce arguments for or against an issue
Middle-level managers who are attempting to make arguments or show results
Laboratory staff who document results and write reports
Technicians who must write up test protocols, non-conformance reports, corrective actions, reports to upper management, etc.
Quality Assurance/Quality Control and Regulatory Compliance people who must document clearly the purpose of investigations and produce final reports that clearly state actions to be performed or the results of testing
In a Q&A with Food Safety Tech, Eddie Hall, business development director and food safety expert at Vital Vio looks ahead to 2020 and how technology will be impacting food safety, the additional measures that the industry will be taking to protect consumers, and the critical emphasis on sanitation.
Food Safety Tech: What are some of the touch points for food safety innovation in the supply chain in 2020?
Eddie Hall, business development director and food safety expert at Vital Vio
Eddie Hall: When we think of the supply chain, we often imagine food traveling during transportation—by road, rail and air. During transit, our food comes into contact with countless surfaces, hands, tools and bacteria that travels from the farm to the table. However, transit isn’t the only place for germ spread and bacteria growth. When food reaches the factory for processing and packaging, there are opportunities for contact with debris, mold and dust, along with un-sanitized machinery and employees. Not only does this negatively affect the health of our workers, but also the cleanliness and safety of the food that consumers are buying off the shelves. In food manufacturing plants, Zones 1 and 2 are the most obvious for safety innovation in the supply chain, given food is bound to come into contact with tools, conveyor belts, etc. However, processors must consider the touch points in Zones 3 and 4 as well—such as employee break rooms, bathrooms and offices around the plant that foster bacteria. If these areas are not cleaned, food manufacturers have a significantly higher chance of breeding bacteria in food production areas, even if the right protocols are put in place in those zones.
FST: How will the retail sector step up to the consumer demand for safer food?
Hall: Consumers are increasingly demanding transparency around how food ends up on their plate, and prioritizing purchasing from brands that they trust to be safe. Food suppliers are being careful to remove harmful chemicals from the manufacturing process, along with displaying ingredients and supply chain information. For example, Bumble Bee Foods is using blockchain technology for its tuna fish, allowing consumers to access detailed information around the tuna’s origin, authenticity, freshness and sustainability by scanning the QR code on its packaging. Panera Bread has been consistent in offering customers ingredient transparency [by] providing calorie counts on menu items and removing antibiotic-treated animal proteins, as well as vocalizing recent efforts to perform safety audits throughout its supply chain. Not only does tracking technology and clarity meet consumers’ demands, but [it] also helps retailers pinpoint locations of outbreaks, foodborne illness and mislabeling. We’re already seeing retailers step up to meet the growing demand for safer food, but in 2020 we will see an uptick in brand transparency around supply chain information, safety programs and ingredient clarity within restaurants, fast food chains, processing companies and grocery stores.
FST: How will automation play a role in advancing food safety?
Hall: Food processing companies and retailers are implementing remote monitoring technologies that track data and help measure protocol, temperature controls, sanitation, record-keeping and food traceability. Automation can also help advance food safety through methods such as enhance sanitation and sterilization efforts. It is critical for food industry employees to maintain clean environments, but continuously cleaning every hour of every day can become labor-intensive, and sometimes fall off the to-do list. Automated technologies can take on some of these tedious tasks and work in our favor to heighten food safety. For example, Stop and Shop’s new robot, Marty, patrols the aisles to detect food on the floor, torn packaging, empty shelves and more. However, robots aren’t the only place we’re seeing automation in action. Vital Vio has found a way to automate killing bacteria through antimicrobial LED lighting technology, which continuously kills pathogens with the flick of a switch. Automated tech isn’t meant to replace workers, but to enhance their work around cleaning, sanitizing and meeting safety requirements. In 2020, automation is expected to explode and it’s important for leaders in the food and beverage industry to take advantage of safety tech innovations to advance food safety in 2020 and beyond.
FST: How will food companies continue to work towards reducing contamination issues and recalls?
Hall: The U.S. government has stepped in to tackle issues in the food industry by implementing new regulations, such as FSMA. This regulation urges food companies to shift from reactively responding to safety and contamination issues, to proactively working to prevent them. In an effort to reduce recalls, retail giant Walmart recently employed blockchain to track its lettuce supply chains all the way back to the grower. For food companies to reduce contamination, they must also implement more automated sanitation technologies along the supply chain. The most common food contaminants are usually invisible to the naked eye, such as mold, Listeria, Salmonella and E. coli. Sanitation automation tech—such as antimicrobial LED lighting—can continuously kill microscopic bacteria and prevent regrowth, ensuring clean food and equipment. Not only will food companies begin implementing more sanitization technologies, but also focus on other ways, like blockchain traceability, to prevent food recalls and bacteria growth that pose serious health risks to their customers.
FST: Any additional comments?
Hall: Our Dirty Truth report reveals disturbing stats around Americans’ cleaning habits, such as 1 in 4 (27%) do not sanitize their hands after traveling on public transportation. This means that factory or grocery employees that commute to work via bus, train, etc. are bringing bacteria and other germs with them. What’s worse, 1 in 6 Americans get sick and 3,000 die each year from consuming contaminated foods or beverages. This alarming rate can only be improved if we see effort from all sides of the industry—including food processors, manufacturers, workers throughout the supply chain and retailers. Continuous cleaning and sanitation measures can be labor-intensive and sometimes impossible to tackle throughout the day. Luckily, automated technology exists and is expected to address this growing issue of contamination, the spread of bacteria, recalls, and consumer demand for safety and transparency.
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. Read the final installment of this series on Lessons Learned from Intentional Adulteration Vulnerability Assessments, Part III.
Visibility, accountability and traceability are paramount in the agriculture industry, says Allison Kopf, founder and CEO of Artemis. In a Q&A with Food Safety Tech, Kopf explains how growers can take advantage of cultivation management platforms to better arm them with the tools they need to help prevent food safety issues within their operations and maintain compliance.
Food Safety Tech: What are the key challenges and risks that growers face in managing their operations?
Allison Kopf: One of the easiest challenges for growers to overcome is how they collect and utilize data. I’ve spent my entire career in agriculture, and it’s been painful to watch operations track all of their farm data on clipboards and spreadsheets. By not digitizing processes, growers become bogged down by the process of logging information and sifting through old notebooks for usable insights—if they even choose to do that.
Allison Kopf is the founder and CEO of Artemis, a cultivation management platform serving the fruit, vegetable, floriculture, cannabis, and hemp industries. She is also is an investment partner at XFactor Ventures and serves on the boards of Cornell University’s Controlled Environment Agriculture program and Santa Clara University’s College of Arts and Sciences.
I was visiting a farm the other day and the grower pulled out a big binder. The binder contained all of his standard operating procedures and growing specifications for the varieties he’s grown over the past 20 years. Then he pulled out a pile of black notebooks. If you’ve ever worked on a farm, you’d recognize grower notebooks anywhere. They’re used to log data points such as yield, quality and notes on production. These notebooks sit in filing cabinets with the hopeful promise of becoming useful at some point in the future—to stop production from falling into the same pitfalls or to mirror successful outcomes. However, in reality, the notebooks never see the light of day again. The grower talked about the pain of this process—when he goes on vacation, no one can fill his shoes; when he retires, so does the information in his head; when auditors come in, they’ll have to duplicate work to create proper documentation; and worse, it’s impossible to determine what resources are needed proactively based on anything other than gut. Here’s the bigger issue: All of the solutions are there; they’re just filed away in notebooks sitting in the filing cabinet.
Labor is the number one expense for commercial growing operations. Unless you’re a data analyst and don’t have the full-time responsibilities of managing a complex growing operation, spreadsheets and notebooks won’t give you the details needed to figure out when and where you’re over- or under-staffing. Guessing labor needs day-to-day is horribly inefficient and expensive.
Another challenge is managing food safety and compliance. Food contamination remains a huge issue within the agriculture industry. E. coli, Listeria and other outbreaks (usually linked to leafy greens, berries and other specialty crops) happen regularly. If crops are not tracked, it can take months to follow the contamination up the chain to its source. Once identified, growers might have to destroy entire batches of crops rather than the specific culprit if they don’t have appropriate tracking methods in place. This is a time-consuming and expensive waste.
Existing solutions that growers use like ERPs are great for tracking payroll, billing, inventory, logistics, etc., but the downside is that they’re expensive, difficult to implement, and most importantly aren’t specific to the agriculture industry. The result is that growers can manage some data digitally, but not everything, and certainly not in one place. This is where a cultivation management platform (CMP) comes into play.
FST:How are technologies helping address these issues?
Kopf: More and more solutions are coming online to enable commercial growers to detect, prevent and trace food safety issues, and stay compliant with regulations. The key is making sure growers are not just tracking data but also ensuring the data becomes accessible and functional. A CMP can offer growers what ERPs and other farm management software can’t: Detailed and complete visibility of operations, labor accountability and crop traceability.
A CMP enables better product safety by keeping crop data easily traceable across the supply chain. Rather than having to destroy entire batches in the event of contamination, growers can simply trace it to the source and pinpoint the problem. A CMP greatly decreases the time it takes to log food safety data, which also helps growers’ bottom line.
CMPs also help growers manage regulatory compliance. This is true within the food industry as well as the cannabis industry. Regulations surrounding legal pesticides are changing all the time. It’s difficult keeping up with constantly shifting regulatory environment. In cannabis this is especially true. By keeping crops easily traceable, growers can seamlessly manage standard operating procedures across the operation (GAP, HACCP, SQF, FSMA, etc.) and streamline audits of all their permits, licenses, records and logs, which can be digitized and organized in one place.
FST: Where is the future headed regarding the use of technology that generates actionable data for growers? How is this changing the game in sustainability?
Kopf: Technology such as artificial intelligence and the internet of things are changing just about every industry. This is true of agriculture as well. Some of these changes are already happening: Farmers use autonomous tractors, drones to monitor crops, and AI to optimize water usage.
As the agriculture industry becomes more connected, the more growers will be able to access meaningful and actionable information. Plugging into this data will be the key for growers who want to stay profitable. These technologies will give them up-to-the-second information about the health of their crops, but will also drive their pest, labor, and risk & compliance management strategies, all of which affect food safety.
When growers optimize their operations and production for profitability, naturally they are able to optimize for sustainability as well. More gain from fewer resources. It costs its customers less money, time and hassle to run their farms and it costs the planet less of its resources.
Technology innovation, including CMPs, enable cultivation that will provide food for a growing population despite decreasing resources. Technology that works both with outdoor and greenhouse growing operations will help fight food scarcity by keeping crops growing in areas where they might not be able to grow naturally. It also keeps production efficient, driving productivity as higher yields will be necessary.
Beyond scarcity, traceability capabilities enforce food security which is arguable the largest public health concern across the agricultural supply chain. More than 3,000 people die every year due to foodborne illness. By making a safer, traceable supply chain, new technology that enables growers to leverage their data will protect human life.
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