Registration for the 12th Annual Food Safety Consortium, which will take place October 20-22, 2024, at the Crystal Gateway Marriott in Arlington, Virginia, directly across the Potomac River from Washington, DC, is now open.
Presented by Food Safety Tech, the Program starts with several pre-conference workshops and training which leads into two full days of high-level panel discussions, educational presentations, and networking opportunities.
The Consortium will begin with a keynote presentation from James “Jim” Jones, FDA Deputy Commissioner for Human Foods, followed by a Town Hall with Jones and USDA regulators.
Other agenda highlights include:
Navigating Global Food Systems: Insights and Strategies for Compliance with FDA’s Food Traceability Rule Panelists: Sara Bratager, Sr. Food Safety and Traceability Scientist at IFT; John Crabill, Director of Food Safety & Quality at Chipotle; Adam Friedlander, Policy Analyst, Coordinated Outbeak Response, FDA; and Julie McGill, VP of Supply Chain Strategy and Insight, Trustwell
Food Allergen Controls and the Need for Advisory Labels Presenter: Dr. Steven Gendel, Gendel Food Safety
Understanding Corrective Actions, Nonconformities and Root Cause Analysis Presenter: Heather McLemore, Senior Accreditation Officer, A2LA
The Internal Audit: Going Beyond the Certificate Presenter: Cameron Prince, Executive VP, Regulatory Affairs, The Acheson Group
Using a Food Safety Culture “GPS” to Determine Where You Are and Where You Need to Go Panelists: Tia Glave and Jill Stuber, Catalyst; Cameron Prince and Benjamin Miller, The Acheson Group
Everyone knows a “checklist” when they see it: a systematized tool that lists things, components, steps or criteria whose presence or quantitative amount are essential to the performance of a specific task. The order of items in a checklist may or may not be critical in terms of the sequence of tasks which need to occur.
Checklists serve the wonderful purpose of identifying the important and critical steps needed to manufacture fresh food, fly a plane, perform a surgery or run a nuclear plant. They serve the purpose of helping to make sure that no important step is forgotten, and all critical steps are performed in the right order. Having a high “checklist intelligence” means that checklists are used proactively and dynamically, and that they drive continuous improvement in practices and procedures. And this occurs regardless of personal or organizational biases.
Let’s review some of the published literature on checklists.
A popular book on checklists is “The Checklist Manifesto” (Picador, 2009) by surgeon Atul Gawande. As noted in the book, checklists are very useful when there is a lot to get right, that is, when there is a high degree of complexity for certain actions. For example, commercial airplanes have “become too much airplane for one person to fly.” Hence, the industry uses a number of checklists, especially pre-flight, to address possible risks before the airplane takes to the air. Food manufacturing is similar, especially given its impact on public health.
A distinct disadvantage is that checklists can drive a tyranny of the urgent, i.e., simply checking a box to be done with it.
A distinct advantage of checklists is that they can be built by the “wisdom of a group” of experienced people, and therefore do not rely solely on a single individual’s memory or experience base. A distinct disadvantage is that checklists can drive a tyranny of the urgent, i.e., simply checking a box to be done with it.
Western Michigan University (2017) has an Evaluation Checklist Project with a number of excellent resources showing how to develop checklists for evaluating programs and projects. These include a “checklist for formatting checklists” and scholarly presentations on the logic behind checklists. Their suggestions can easily be re-applied to the food industry.
There are many published articles which address bias in decision making. For example, Ely et al. (2011)[1] studied the use of checklists to reduce diagnostic errors in hospitals, clinics and emergency rooms. Of note, the authors delve into cognitive processes to identify the inherent biases and reliance on intuition that often drive decision-making. They remind checklist developers to take into account “Type 1” thinking processes which are fast, reflexive and intuitive (and usually subconscious) and “Type 2” processes which are analytic, slow and deliberate (and usually take very focused attention).
Application of Checklists in the Food Industry
Checklists are widely used in the food industry. The USDA (2014) has a label submission checklist that helps companies avoid common labeling mistakes, and clarifies what is needed. The agency also has a guideline checklist for the cooking of meat and poultry products.
In the food manufacturing setting, companies often conduct their FSMA-related GMP audits by having employees walk around the plant using a checklist of equipment, documents and practices to look for. Companies making prepared foods have checklists that operators must follow to ensure that proper cooking and cooling procedures have been followed (these are also called SOPs, or Standard Operating Procedures, which are, in essence, checklists). Similarly, sanitation teams follow strict SOPs/checklists to ensure the right sanitizers are used in the right concentrations and for the right durations. Line changeovers often use checklists to prevent allergen cross-contamination. The same is true for pre-production equipment assembly. And product development/chef teams use checklists to ensure that the right ingredients are used, with proper consideration given to allergens, glutens, GMOs and organic product needs.
Finally, some of the most widely used checklists in the food industry are standards, including those developed by the Global Food Safety Initiative (GFSI), Safe Quality Foods (SQF) and the British Retail Consortium Global Standard (BRCGS).
Checklists as an Indicator of Food Safety Audit Maturity
Companies going through the GFSI certification process (e.g., SQF) often follow a three-phase audit maturation process that highlights how checklists can help or hinder food safty. In the first phase, the company is new to the process and therefore may not have systems in place to handle all of the requirements inherent to the standard. Thus, the company may “shotgun” their approach based on where they think they have gaps (by their own evaluation and/or with the help of third-party consultants). In this phase, the SQF Code may not be looked at in its totality nor in its intent, and certain requirements may be looked at as more important than others (with the insidious side effect of some requirements being missed).
In the second phase of the growth curve, the company recognizes that the food safety requirements are laid out in a very organized and helpful manner: the SQF Code. They realize that if they can match each requirement in the code with practices and procedures, then they can essentially use the code as a checklist. Many companies in this phase build their programs and their audit readiness exactly in the order of the code, and solely to meet the specific requirements detailed in each section of the Code. This ensures that when the SQF auditor comes in, the company will have addressed each and every requirement. This approach serves those companies well who are still in the learning phase of building a strong food safety plan and food safety culture, and generally helps most companies “pass” their food safety audit.
The right culture drives the right entries on the checklists. Not the other way around.
All is well until there is a food safety incident, trade withdrawal or public recall, which can happen in spite of a company checking every box on the SQF “checklist.” A major negative event, or even the recognition that such an event could happen, can therefore rightly push a company into the third phase of using the SQF Code.
In the third phase, a company uses and views checklists as valuable tools (and likely still structures its audit readiness in the same order as the SQF Code). However, the company has critically realized that it needs to go beyond checklists to drive the right food safety culture in the organization. Additional practices, procedures, documentation and systems are put in place to drive the right culture. These in turn make sure that the checklists get checked. Said another way, the right culture drives the right entries on the checklists. Not the other way around.
A Checklist for Checklists
Let’s consider creating a checklist for checklists. Each of the following provides perspective on the value, and the warnings, of using checklists to drive and improve an organization’s food safety culture and therefore its “checklist intelligence.”
Checklists Can Speak the Truth. If the results from a completed checklist are pointing out significant issues, then at the basic level the checklist is working. This is not a time to alter the checklist, which can happen in low-maturity organizations as a way to hide an issue, or an excuse to fill out the checklist incompletely. Rather, complete results should be heralded as validation that the checklist is performing as it should.
Learn From Failures. Something going wrong despite the use of a checklist is a good clue that the wrong things are being checked or that something is missing. This should be discussed broadly and cross-functionally and drive a root-cause analysis, which can markedly point out what got missed, which in turn allows for continual improvement of the checklist.
There Is No “One-Off.” All experienced auditors have heard “this is the first time that this has happened.” Or “there are many unusual things going on at the same time, and this caused the issue; it won’t happen again.” There is no one-off! A root cause analysis should be performed. Checklists must be able to help the organization identify and diagnose root causes.
Check the Checker. Is the person filling out the checklist being driven by the checklist to look for the right food safety behaviors, or is the person merely checking the boxes since that’s the job? Perhaps more insidious, employees might follow a checklist quite diligently—observing just those tasks which are on the list—yet miss faulty or risky behaviors. This may not be the fault of the checklist, but it is certainly the fault of the organization and its training. Relying solely on a checklist can still allow egregious and unwanted behaviors. If the employees are trained only to follow the checklist and make sure it gets filled out, significant untoward behaviors get missed. In this regard, checklists become shackles.
Check the Documents. Critical to some checklists are documents which are meant to substantiate that a particular task on the checklist was taken care of. The utility of these documents is only as good as the value of having them on the checklist to begin with. Time must be taken to identify which procedures or cooking logs, for example, need to be checked as part of a checklist. This is independent of having these documented as part of the organization’s food safety plan.
Honor the System. Checklists are just that: lists. They are not roadmaps, graphs or linkages to knowledge bases. They are static, rather than dynamic systems that drive action and resolution of issues. In general, checklists can be ill-equipped to capture systemic behaviors and the culture of an organization. This is especially true if the checklists are from a third-party and/or have not been adapted to specific organizations and facilities. Hence, checklists should be used for what they can bring—no more, no less.
The Law of Unintended Consequences. An oft-quoted phrase is “you get what you measure.” And this is certainly in play for checklists. If the item on the checklist is wrong, or is directing the wrong behavior, measuring it regularly could serve the unwanted purpose of instilling that behavior as “correct.”
Defeating the Checklist
By now you realize that checklists in the food industry can serve as a crutch or as a divining-rod for continuous improvement of food safety practices and procedures. Following are some indicators that a checklist is not working or is not as effective as it should be.
Too burdensome. A very common checklist used in food manufacturing is the “GMP audit checklist.” This is typically a long list of behaviors and practices which the organization believes it should be engaging in to meet the GMP regulations and produce safe food. Most organizations commit to conducting such audit checklists as part of their promises to the auditing organization. The list gets longer and gets spread across more functions, and all of this work becomes quite burdensome. When it is time for the GFSI audit, missing or incomplete checklists may get pencil-whipped, leading the auditor to believe that the company has been using the checklists regularly.
Pencil-Whipping. As much as putting false entries on a form is unethical, and usually illegal, it can still occur under the right stressors or employee attitudes. Simply checking the boxes on a checklist does no one any favors and can provide a false sense of security.
Complacency. Organizations that rely on the data from checklists could develop a false sense of security and become complacent about corrective actions. Although not necessarily unethical or illegal, someone checking a box as “complete” just because it always has been in the past is misleading (if not outright wrong) if the checker really did not check. Understanding this risk can help define the items in the checklist, including those things needed to ensure that the checklist checker is focused and paying attention.
Pressure to “get back to work” can be one of the quickest means to defeat a checklist.
Inaccurate documents. Practices and procedures change over time, and often the documents that go along with them do not get updated on the production floor. Continual vigilance is needed to ensure that the most up to date documents are aligned with current practices and the details on the checklist. In fact, one of the items on a checklist might be checking the issue dates of key documents being used by operators.
Stress. Pressure to “get back to work” can be one of the quickest means to defeat a checklist. This could be due to senior management’s communications, a team’s own leadership or individuals believing they need to hurry up so that they can resume their “real job.”
The End-Game: A Game of Checkers
To win at the game of checkers (or draughts), there are a number of strategies which experts often espouse, most of which apply to checklists in the food industry.
Control the center: Focus on the stuff that counts, not the stuff on the edges.
Play offense, not defense: Attack the issues that strive to undermine the food safety program.
The goal is to get to the end of the board: The checklist must be completed in its entirety.
Be willing to sacrifice: If an item on the checklist is not working, take it off.
Advance as a group: Don’t just leave checklists to one group (e.g., QA); build and use them based on input from experts from all functions.
Realizing the value of checklists requires the right culture, rules and execution as well as recognition that checklists are tools to maximize risk identification and risk management. Building your organization’s “checklist intelligence” will help in the development of the checklists, the effectiveness of those checking the checklists and in increasing the assurance of those checking the checkers.
The game never ends, which means that with the right strategy you can win all the time.
References:
[1] Ely, John, Graber, Mark, and Croskeey, Pat (2011): Checklists to Reduce Diagnostic Errors, Academic Medicine, 86:307.
The Food Safety Consortium will take place October 20-22, 2024, at the Crystal Gateway Marriott, Arlington VA directly across the Potomic River from Washington, DC. The Program starts with several pre-conference workshops and training which leads into two full days of high-level panel discussions and educational presentations.
Food Safety Tech is thrilled to announce that James (Jim) Jones, Deputy Commissioner for Human Foods at FDA, will be the keynote speaker for the 2024 Food Safety Consortium, which will be held October 20-22 at the Crystal Gateway Marriot in Arlington, Virginia. Jones joined the FDA in September 2023 as the agency’s first Deputy Commissioner for Human Foods.
Now in its 12th year, the Food Safety Consortium brings together food safety and quality assurance professionals for education, networking and discussion geared toward solving the key challenges facing the food safety industry. In addition to two days of educational presentations and panel discussions, the Consortium will offer full-day pre-conference workshops, focused on topics including auditor training and food safety culture design, on Sunday, October 20.
This year’s session highlights include:
Navigating Global Food Systems: Insights and Strategies for Compliance with FDA’s Food Traceability Rule
Presenters: John Crabill, Director of Food Safety & Quality, Chipotle; Adam Friedlander, Policy Analyst, Coordinated Outbreak Response and Evaluation (CORE) Network, FDA; Julie McGill, VP of Supply Chain Strategy & Insights, Trustwell; and Sara Bratager, Sr. Food Safety & Traceability Scientist, Global Food Traceability Center at IFT
Are you the weakest link in the supply chain? Steps for bulletproofing your facility to become a major supplier
Presenters: Jorge Hernandez, VP of Quality Assurance, The Wendy’s Company; Tyler Williams, President, ASI
Next Level Preventive Controls
Presenter: Cathy Crawford, President, HACCP Consulting Group
Understanding Corrective Actions, Nonconformities and Root Cause Analysis
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 its educational content. 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 high-level educational tracks, and network with industry executives to find solutions to improve quality, efficiency and cost effectiveness in the evolving food industry.
Developing an internal audit program does not have to be a dauting task. With a small amount of work upfront a program can be developed and implemented in a matter of weeks. In this article we discuss the key elements of a successful program and provide guidance to ensure that audits add value to the daily operations across the facility.
Have a Plan in Mind
The first step in any successful audit program is to identify the overall structure and format. Audit programs can be set up in a variety of ways ranging from an annual full system audit to monthly departmental audits. The format and structure should be unique to each individual organization. Determine what works best for the organization and stick with it.
Developing a concise schedule will help to ensure expectations are clear. This schedule should be communicated with team members via appropriate channels. Identifying a point person to routinely follow up on the progress of the audits will ensure the program is being managed as expected. Considerations should be made for potential scheduling challenges. Build in additional time for those areas that are known to encounter delays.
Staying consistent with the maintenance and review of the program will ensure all audit activities are conducted within the expected timeframe. This can be accomplished by establishing a routine review of the program. Monthly review meetings can be established to review the audit schedule, results of audits and pending action items. During this time necessary adjustments can be made as needed and communication plans can be established. This helps to drive engagement across the organization around the entire audit program.
Accurate maintenance of audit records is a crucial step in maintaining a successful program. Ensure all records are properly filed and protected by establishing a designated filing system. Developing an organized file structure aids in keeping files in one place and reduces frustrations around locating documentation in the future. Be sure to include records for both internal and external audits as they are a required input to management review and may be needed for future assessments.
Build a Strong Audit Team
Having a good pool of auditors to pull from is critical. The number of auditors needed will vary based upon the size of the business and complexity of the processes. When considering the format of your team consider the backgrounds of the team members selected. There should be a good mix of experienced and new auditors to provide balance among the group. When assigning auditors to specific areas consider technical knowledge for those complex processes that may require a deeper understanding. Pairing auditors together is a great way for auditors to learn from each other as they work through the review of the data.
Auditing is often a required responsibility for QA/RA. Recruiting internal auditors from departments outside of QA/RA is beneficial, as they bring a different perspective and may ask questions that seem obvious to QA/RA professionals. All of the standards require auditors to be trained and/or competent in the auditing process. Training can be done externally or internally, and companies must show proof of training.
Selecting auditors from varying backgrounds is a great way to incorporate diversity within the team. Each auditor brings their unique experience to the group which builds a richer audit. Varying viewpoints helps to push the team to dig deeper to identify issues that may otherwise go unnoticed. Encourage the audit team to work together to build audit checklists that are specific to the area being audited. Conducting a review of the process and supporting documentation prior to the audit will enable the team to gain an understanding of the area under review. Encourage auditors to not become locked into the checklist but rather think of it as a guide. If audit trails within the scope of the audit arise during the audit be all means explore if time allows. This approach helps to empower the audit team by providing a sense of autonomy over their work.
When building the audit team, management should be mindful of the workload. For the program to be successful you want to ensure that audit team members are not overloaded. Often audits will be delayed due to competing responsibilities of auditors. To mitigate this issue, develop the audit schedule so there is a balance across the assigned audits. Ensuring that the auditor has plenty of time to conduct the audits within the specified timeframe. Overall, the audit team should feel supported and appreciated for their efforts and not be overwhelmed and burdened with the task. A poorly balanced workload only leads to a lack of interest and a disengagement among the audit team.
Provide Opportunities for Education
Providing an understanding of quality management systems and the standard being audited is imperative to the success of any audit program. There are two groups that require education. Education for the auditors and those that are participating in the audits. The auditors need an in-depth understanding of the standard and the requirements which they are auditing against. While the employees need awareness of how the management system is structured and their role in supporting it.
These educational goals can be accomplished both formally and informally across the organization. Auditors will need a more formalized structured training program that focuses on the details of the standard and auditing principles. While employee training can be incorporated into departmental meetings or shared through one-point lessons. Building education programs into existing activities is a great way of incorporating the audit program into the organizational culture. This helps to educate as well as share information with those in the organization who may otherwise not have awareness. This could be conducted via training sessions around processes and their linkage to the standard in which the organization is certified. Providing an understanding of the connections between the departments helps build collaboration between working groups. Employees gain exposure to what others in adjacent departments are doing and obtain a sense of understanding of challenges that may be faced by those groups. This in turn results in a collaborative team approach to the management of the overall system.
Involving employees from all parts of the business helps to drive the message that the system cannot operate in one department alone. Through education, employees will be able to understand their role in the system. This will lead to more engagement in the internal audit program. Employees will become excited to aid in audit activities and improvement initiatives because they will see positive results. They will gain understanding of the impact of their actions and how it impacts the overall system. This value-added approach will result in a favorable outcome for both the organization and the individual employees.
Promote Continuous Improvement
The support of top management is a very important element in the success of any audit program. Establishing a culture of continuous improvement will motivate the team and build engagement across the organization. This can be accomplished by frequently sharing status updates around the management system activities. A simple 15-minute update during sitewide meetings goes a long way. It demonstrates a commitment to the program and growth of the organization and its people.
Develop a format of communicating the details around the management system and any upcoming activities. This can be done by having a specific time each month when updates are provided. Putting this on the calendar will ensure that information is effectively communicated. Details should include both the negative and positive outcomes of internal and external audits. Include specifics around the audit findings and actions taken to address concerns. This will communicate to employees that the organization is serious about growing and is focused on improvement.
Sharing information helps to engage employees by bringing them into the improvement efforts rather than just being bystanders. These seemingly small actions can help drive excitement for the overall program and build a culture of quality. Lastly, be sure to celebrate the wins and ensure that team members are appreciated for their efforts. Building a successful internal audit program is a lot of work. Celebrating and acknowledging the efforts of the team is imperative.
Accomplish the Mission
There are many ways to build a successful internal audit program. Taking the time and effort to think through the process of identifying the format, structure and team members is critical. By reviewing these items upfront roadblocks can be identified early on. There will always be unforeseen challenges yet having a plan is key to developing a successful program. With a strong commitment from top management and a mindset of continuous improvement an organization can establish a robust internal audit program that exceeds expectations.
The Food Safety Consortium Conference has announced a new online Food Safety Training Series, developed to explore critical food safety and quality topics in depth and offer timely information on emerging issues.
The first series is Food Safety Testing – Above and Beyond PCQI Principles, which will include three 90-minute online classes on February 1, 15 and 29. Building on the core PCQI principles, this training covers the key elements of effective food safety testing programs. The course will be led by Trish Wester, President of the Association for Food Safety Auditing Professionals (AFSAP).
Drawing on the extensive training portfolio of AFSAP, the first class includes an overview of general testing principles and the regulatory framework used to enforce compliance. Anticipating an increased focus on chemical testing under the new FDA leadership, a complete class session will be devoted to what, how and when to test for chemical contaminants, with the third and final class of the series devoted to the complexities of microbial testing.
“I am excited about the brand expansion of the Food Safety Consortium moving into training. Last year, we introduced two highly successful training programs, one on site and the other as a hybrid of three online classes followed by an onsite class. The Food Safety Testing Above & Beyond PCQI Principles Series is the first of several new and innovative programs we’ll offer this year,” said Rick Biros, founder of the Food Safety Consortium and publisher of Food Safety Tech.
The classes will feature a two-way virtual training format. All webcams will be on so the instructor can see each trainee and each trainee can see the instructor. This allows the instructor to monitor the class progress throughout, encouraging group discussion and live questions, replicating an in-person training experience without the need for travel. Space is limited, as class size is limited to 20 participants per series.
“I’m thrilled to bring food safety training to a new level. Working with the Consortium, we developed the Virtual Live concept that blends the best attributes of instructor led in-person training with the cost effectiveness of web-based programs. This should provide increased access to training for all food safety employees, which will have a positive impact on food safety,” said Wester.
Who should attend?
All levels of QA/QC personnel interested in advancing their food safety career into food safety program management and plan development in a wide range of product categories.
Entry level food personnel would also benefit from the course format.
Food Safety Auditors of all levels will increase their understanding of the food safety principles used in the area of product and environmental testing.
4.5 CE Hours and Certificate of Attendance: The Food Safety Consortium Conference’s Training, developed by AFSAP, is recognized by NEHA (National Environmental Health Association) for Continuing Education (CE) Hours. Upon completion of the training, each trainee will receive a Certificate of Attendance.
Culture is not an initiative but rather the enabler of all initiatives, as observed rightly by Larry Senn, who is considered the Father of Corporate Culture. Similarly, food safety culture (FSC) is the solid foundation that enables organizations to ultimately minimize food safety risks. This is why the simple idea of food safety culture emerges to be a powerful concept in reducing the global burden of foodborne diseases.
Let us consider some facts:
Employees working in food enterprises worldwide are required to be well-trained in food safety practices
A vast amount of food safety research is conducted around the world to improve and enhance food safety management
Companies are required to follow elaborate food safety regulations that include mandatory testing and inspections
It is quite contradictory that food safety remains a major public health threat. One way to understand why this happens is that just because something has been done in a specified manner for a long duration does not necessarily mean it is being done the right way. Hence, there must be a missing ingredient fundamental to preventing food safety incidents, which many have concluded relates to lack of a strong food safety culture.
The Importance of Food Safety Culture in Simple Terms
The behavior of your staff and leadership demonstrates whether each employee understands and is committed to ensuring your products are safe to consume and of good quality. In short, food safety equals behavior. This is the core notion Frank Yiannas talks about in his book, Food Safety Culture: Creating a Behavior-Based Food Safety Management System.
One of the most well-known outcomes associated with lack of a strong food safety culture was the PCA (Peanut Corporation of America) outbreak in 2009 when peanuts contaminated with Salmonella caused nine deaths, 11,000 to 20,000 illnesses, and a recall of 4,000 products. A proactive food safety culture that is centered on rigorous testing, quality control protocols, sanitation and traceability measures could have detected and prevented the spread outbreak, saving lives and money.
Companies are investigating and/or implementing food safety culture training and practices because no matter what we say or document regarding food safety, we cannot make progress unless we actually put these words into practice.
A systematic review of the scientific literature on food safety culture (FSC), published by the FDA in 2022 views food safety culture as a scientific concept. In conducting the study, FDA aspired to present food safety culture as a valid subset of science, rather than just a slogan, and use the knowledge obtained to provide tools that stakeholders can use to develop and assess their own food safety culture. This review is considered the primary groundwork for FDA’s efforts to uplift food safety culture in the industry, among consumers, and in regard to the present regulatory oversight.
Challenges and Barriers to Accomplishing a Strong and Effective Food Safety Culture
The predominant challenges and barriers to creating, promoting and evaluating a strong and effective Food Safety Culture, as presented in the review, include:
Over-reliance on food safety management systems (FSMS)
FSMS plays a non-negotiable role in every food enterprise. Nevertheless, FSMS tend to be process focused and thus do not affect how human attitudes influence food safety. This is where a behavior-based FSMS is beneficial to forge a well-built FSC, as it offers a total system approach based on scientific knowledge of human behavior, organizational culture, and food safety.
Prioritization of cost-saving and money-earning
A profit-focused mentality is often the main barrier to implementing a positive FSC. Compromising food safety principles to save costs is never a good strategy. It can even be counter-productive as a negative FSC can eventually lead to a food safety incident, generating tremendous economic losses for the organization. An ideal FSC ensures that an obligation to food safety exists throughout the firm that outweighs all other company goals and practices.
Frequent staff turnover
Continuous staff turnover is a common phenomenon in the food sector. High staff turnover requires constant training and supervision to ensure employees’ understand the risks and other essential criteria needed for an adequate food safety climate. It also is challenging to ascertain the commitment and accountability of employees with temporary contracts.
Optimistic bias
Though it is said ‘experience is the best teacher, and the worst experiences teach the best lessons,’ it is always better for employees to realize that they are not immune to food contamination before experiencing a vulnerability to food safety. Every member of a food enterprise should know that they cannot afford optimism bias in terms of food safety, and that it is imperative to be prepared—and on the look out for—worst case scenarios.
How Digitalization Can Assist in Developing and Sustaining a Solid Food Safety Culture
Ideally, a commitment to food safety begins with management and permeates through the organization at all levels. Digital tools, particularly those used to manage the supply chain, can help. By establishing a network platform that integrates the online and offline worlds, digitalization connects all facets of the food production and processing chain. Let us break down how digital tools can be implemented throughout the food industry to enhance supply chain processes while nurturing a strong food safety culture.
1. Setting Expectations
Digital tools allow for the efficient creation, distribution and maintenance of food safety policies, procedures and protocols. By utilizing digital systems, organizations can document and disseminate clear expectations regarding food safety practices. This includes defining standard operating procedures (SOPs), hygiene protocols and compliance guidelines. These digital resources can be easily accessed by employees, ensuring that everyone is aware of the established standards and expectations.
2. Communication & Training
The next step is to properly communicate the established strategies among the employees and enforce them. This is where learning management systems and digital employee training platforms come in handy, as they engage and educate employees by conveying information and instructions related to various aspects of the organization. These tech-enabled solutions can also play a vital role in authorizing employees to collaborate via more efficient communication channels, address food safety compliance concerns and initiate appropriate corrective and preventive actions when necessary.
These tools allow companies to create training programs that utilize interactive modules, visual content, videos and quizzes to enhance employee learning and retention, while accommodating diverse learning styles such as flexible self-paced or group training. The training courses can be scheduled and assigned to individuals or groups according to the configured training types. Alerts and notifications can be promptly delivered to relevant personnel to inform them about critical updates and send reminders regarding their training courses. They also help companies track and manage training assignments, ensuring that employees complete required training within specified timeframes. Overall, they empower organizations to propagate information efficiently, advance knowledge transfer and ensure compliance with training requirements, thereby fostering a well-informed and competent workforce.
3. Monitoring
Scheduling features of tech-enabled solutions offer a valuable means to successfully plan and monitor regular inspections, maintenance tasks and quality checks. Digital task assignment empowers employees to be accountable, confirm that responsibilities are clearly communicated, eliminate ambiguities in executing food business operations and track the progress and completion of each process, elevating the overall transparency of the supply chain process.
Notifications can be automatically generated to alert employees about upcoming inspections or any deviations from standard procedures. It is also possible to maintain an audit log, capturing and storing a detailed record of all food industry activities, actions and events. Another component that can be advantageous for monitoring efforts is a change log, which becomes useful for tracking modifications made to procedures, allowing for traceability, accountability and assistance with regulatory compliance efforts.
4. Reporting
Digital tools typically include robust dashboards that can provide real-time insights into the supply chain. These intuitive interfaces can display data such as key metrics, compliance rates, inspection results, incident reports and corrective actions taken. Moreover, advanced filtering and drill-down capabilities enable users to delve deeper into specific data segments, facilitating in-depth analysis and comprehensive reporting.
Trend analysis tools can be employed to identify patterns and highlight areas that require further attention. They often incorporate predictive analytics and forecasting models, aiding businesses in predicting demand, optimizing inventory management and reducing waste. Furthermore, employee key performance indicators (KPIs) can be accessed through reporting mechanisms, and trend analysis features, which allows management to gauge employee contributions in upholding a food safety culture.
Tech-savvy solutions, such as food safety management software, are gaining significant traction in the market as they help food enterprises streamline their operations, optimize efficiency, promote transparency and accountability, and ensure compliance with food safety and quality regulations. All of which ultimately serve to instill a responsibility for food safety throughout your organization.
With 37 facilities and close to 500 suppliers, Kellogg works with a large and diverse workforce. Over the years, the company has implemented several strategies to teach and reinforce good food safety practices. As a member of the Alliance to Stop Foodborne Illness, the company works with Stop to share what they have learned with fellow food industry professionals. We spoke with Sherry Brice, Chief Supply Chain Officer and former VP of Global Quality and Food Safety at WK Kellogg Company, and Vanessa Coffman, Ph.D., Alliance Program Director at Stop Foodborne Illness, to share their insights on training, rewards and free tools that can help food companies of all sizes enhance their food safety culture.
What are some of the strategies that Kellogg is using to strengthen its food safety culture?
Sherry Brice
Brice: Some of the things that Kellogg has implemented over the years—and every year we evolve—include a campaign called “Kellogg Food Safety Own It Every Day.” The campaign is about driving engagement at every level of the organization. We have behaviors that we expect of our employees at the frontline leadership level, the executive level and the management level. We provide training on engagement strategies to better articulate food safety culture, including the things they should recognize and how they should recognize them. We also do virtual reality trainings that help to educate our people. After education and engagement, the third pillar is recognition—recognizing and rewarding people around food safety culture.
Is food safety training part of all employee’s onboarding?
Brice: We do have onboarding for new employees. We also do quarterly and annual trainings, because doing it one time is not enough. You have to repeat, repeat, repeat. We have food safety videos that we have launched in partnership with Stop Foodborne Illness that include real life experiences and stories of people who have dealt with foodborne illness. These help team members internalize the training and personalize it, so they are thinking about the impact their actions have on the customers we serve every day. We use one of the videos for onboarding and also leverage them for our annual training and refresh trainings as well.
How did Stop Foodborne Illness get involved with Kellogg and what kind of resources are available for companies?
Vanessa Coffman, Ph.D.
Coffman: Kellogg has been a member of the Alliance to Stop Foodborne Illness since 2021. We rely heavily on Sherry and her team’s insights in multiple work streams, one of which is the ever-growing video series that is posted to our food safety culture toolkit website, and these are all free and publicly available.
We created two customized videos with Kellogg, each featuring one of Stop’s constituent-advocates alongside a Kellogg executive. These remind employees why food safety is so important and emphasize the commitment that Kellogg has made to safe food. We’ve also worked together on gamified learning, leveraging some of the games that Kellogg uses in its training, and those can also be accessed in the toolkit that is free and publicly available.
Since Kellogg joined the Alliance, has that changed your training strategies or your recognition strategies?
Brice: Stop has given us access to their constituents, which really brings to life why food safety is so important at every level of the organization. Engagement with people who have been affected by foodborne illness is crucial to getting to the hearts and minds of employees, and emphasizing the importance what they do every day.
Since joining the Alliance, we have also added virtual reality to our trainings, starting with the most important one which is around sanitation. We created a virtual reality space where new employees—as part of onboarding—put the glasses on and go through our sanitation process. If you do not do the right step, it will not let you go forward. It’s a way to do hands-on training without having to actually be on the line.
The Alliance has been a great partner for Kellogg. It is an investment, but it is money well spent. When you hear the stories of their constituents, you cannot help but think, I never want a situation like that to be on my watch, what can I do to prevent this from happening?
Kellogg is a very large company. How do you ensure this training is happening and that you’re communicating a consistent message throughout the whole organization?
Ready to start improving your food safety culture? Join the Food Safety Culture Design Workshop on October 16, at the 2023 Food Safety Consortium.
Brice: We have a global quality council made up of members from regions around the globe. We all come together on that council to align and make sure we’re all on the same page in terms of what we are going to do to impact the broader organization, and then we disseminate that action out into the regions. This way, we ensure that we have the right ownership, and that everyone is clear on what needs to be done and how we’re going to do it. We also use the council to track and make sure that people are getting access to the videos and completing the training in the time that we have identified.
We created a toolbox tool that is crafted and geared toward Kellogg employees based on the region they’re in, and the council helps to disseminate that and then track that the work is being completed. We also incorporate this into our audit to make sure that people are internalizing the information and getting something out of it.
You mentioned training on engagement strategies, is that through role playing?
Brice: Yes, it really is about how to drive good behaviors, ownership, escalation and empowerment. If you’re a technician and you have to give feedback to a manager, that can really be intimidating, so we want to make sure we’re arming employees with the right tools. We do this in our training by simulating how to have these crucial conversations. If I go into a plant and I’m not following protocol, somebody is going to give me feedback, and I hope that they give it to me in the right way. We want to arm people with the knowledge on how to do that so that they’re comfortable giving that feedback no matter who they are.
Does Kellogg work with its suppliers to help train them as well?
Brice: We do work with our supply base and also our co-manufacturers (co-mans). Our co-mans get a lot of the same training that our plants get. We have an “owner” from the supplier management team that oversees each of the suppliers and that owner manages what training the supplier needs, depending on where that supplier is in their journey. We provide them with the toolbox from Stop, so they can leverage those resources. and we have found that very helpful because if that supplier has a great food safety culture that means we’re going to great materials. Likewise, if our co-mans have a great food safety culture then we feel more comfortable with what they’re producing for us.
In addition to the videos, what are some of the other ways that the Alliance to Stop Foodborne Illness partners with companies?
Coffman: The Alliance was formed in 2018, and we have worked with companies across the food system from farm to fork. We utilize the power of Stop Foodborne Illness constituents and their stories of foodborne Illness. These are people who survived a harrowing experience or the loved ones of those who did not. They will go onsite, take part in town halls, write down their stories and share them on our website, and they have also participated in the videos. We make customized videos for companies like Kellogg, and we’ve been able to leverage that content to create shorter videos that are more generic for the toolkit website.
We also work with companies to develop other materials. As Sherry mentioned, we have some gamified learning. People can download those games and tweak them to their own needs, and some of those have been provided by Kellogg. We’ve also been able to create communication plans based on the nearly 20 Alliance members’ experiences and food safety culture journeys, and we share those plans with the small and medium-sized companies at no cost.
Sherry mentioned recognition of employees, what are good ways to publicly recognize good work in protecting food safety?
Coffman: Like many aspects of food safety culture, it is going to be company dependent. You do want to solicit input from your employees before implementing a rewards program. For example, some people love employee of the month recognition, while others would rather not be publicly recognized. They would prefer a gift card or time off. If you go to our YouTube channel, you can watch some of our past webinars, including one on rewarding and recognition.
Brice: We implemented an “Achievers” platform. Through the platform, we give points to employees and those points can be used to purchase items. We also do on the spot recognition and recognition dinners. It depends on the situation and the person, but “Achievers” is our main recognition platform because we have found that our employees like this. They can trade their points in for a gift card, a T-shirt, a vacuum cleaner—there are many different things on the platform.
It is often said that every company has a food safety culture whether positive or negative, how do you go about assessing where you’re at to understand what you need to implement?
Brice: You can do this through surveys and small group sessions. Asking open-ended questions so people can provide content that helps you understand truly where you’re at and listening are important. Anonymous surveys maybe the best place to start because people may not be very open to speaking up during a small groups. The surveys help you understand where you’re at and what areas do you need to focus on first. Stepping back and looking at what’s happening every day in the company will also give you an understanding of where your company is. How do people feel about stopping a line if they see an issue? Are they comfortable speaking up?
Coffman: Assessment isn’t a one-size-fits-all approach. It has to be carefully thought out and will vary from company to company and even from location to location within the same company. I would like to add that assessment without action is fruitless. If you put forth the time and effort to collect and analyze data, you must take action.
Once you’ve done your assessment and are ready to improve your food safety culture, what are some of the steps you can take to get started?
Coffman: We have a page on our toolkit website dedicated to this, and it leverages learning from our 20 Alliance members from across the industry, looking at both the successes and the bumps they’ve encountered. It is going to look different for each company so I encourage everyone to go to the toolkit website and look at the Plan Your Journey tab.
Brice: The best plan includes people from all areas of the organization. You don’t want just the manufacturing base or the managers, you need to understand why people have the behaviors they have today and what needs to change. If all employees or departments feel that they have ownership in the plan, then the plan will come to fruition faster, and you’ll also create food safety champions along the way.
The FDA and Stop Foodborne Illness are hosting the eighth webinar in the ongoing series of webinars exploring food safety culture on September 13, 2023, from 12pm to 1:00pm ET. “Facing Food Safety Challenges through Culture and Persistence” will focus on the importance of a strong food safety culture and how it can help organizations address food safety challenges they may face.
Guest speakers include:
Kerry Bridges, Vice President of Food Safety, Chipotle Mexican Grill
Al Almanza, Global Head of Food Safety and Quality Assurance, JBS Foods
Lone Jespersen, Principal and Founder, Cultivate SA
Conrad Choiniere, PhD, Director, Office of Analytics and Outreach, Center for Food Safety and Applied Nutrition, FDA
Those interested in attending the free webinar can register here.
The food industry has faced numerous challenges in recent years that have disrupted its stability and normal operations. While it might feel like the industry is finally starting to stabilize, there is still a long way to go to achieve a steady new normal. The industry remains extremely vulnerable to inflation pressures, product shortages, cyberattacks and food fraud. Any one of these risks can send a manufacturer or restaurant scrambling to replace missing ingredients or supplies and resume operations.
In today’s unpredictable landscape, crisis management plans are essential for reducing downtime, safeguarding food quality and maintaining customer trust. These plans help establish backup suppliers in times of supply chain disruptions and bolster defenses against cyberattacks and food fraud. While there is no one-size-fits-all approach, developing a customized crisis management plan tailored to your specific production risks is crucial. Below are some insights into using a crisis management plan to tackle common threats faced by food manufacturers and restaurants.
Vendor Management: Ensuring Continuity
Vendors play a key role in the food industry, and their vulnerabilities can directly impact your food safety and quality. Ingredient shortages and price fluctuations create supply chain disruptions that must be managed through proactive measures.
Including a vendor replacement strategy in the crisis management plan enables quick adaptation to unforeseen circumstances. This strategy should encompass multiple sourcing options, rigorous vendor audits, effective communication channels, comprehensive product specifications and efficient change management processes.
Detecting and Preventing Food Fraud
When supply chains are disrupted, food fraud becomes a serious concern. Counterfeiting, dilution, substitution and mislabeling pose risks to both food quality and safety. To combat food fraud effectively, it’s important to vet suppliers to ensure they provide the correct ingredients and adhere to quality standards.
Integrating your supplier selection processes into the crisis management plan will help ensure consistency as you vet new suppliers. Additionally, frontline employees should receive training to detect food fraud. This includes training that enables them to identify abnormalities in raw materials, manufacturing processes and finished goods.
Risk management is not solely the responsibility of leadership. To effectively combat food fraud, it needs to be part of your frontline worker food safety training program.
Safeguarding Against Cyber Threats
With increasing reliance on technology, the food industry has become more vulnerable than ever to cyber threats. Last year, the U.S. cybersecurity company Dragos identified the food and beverage sector as the second largest victim of cyberattacks, making it imperative to prioritize cybersecurity measures.
While robust security platforms and backup systems are important, the most effective defense lies in having an informed workforce trained to identify and prevent potential attacks. It’s critical to ensure your crisis management plan includes preventative measures such as educating employees on recognizing suspicious emails, updating passwords regularly and avoiding risky online behavior.
Transparent Communication Builds Trust
When changes occur in suppliers, products or ingredients, transparent communication with your customers is vital. The crisis management plan should lay out clear guidelines for informing customers on important updates, including formulation and label changes when different ingredients or formulas are used. These guidelines should have the agreement and support of multiple internal departments, including management, marketing, production, safety and quality. Implementing thorough communication strategies can be time-consuming, but surprising customers with unexpected product changes can cause lasting damage to their trust and loyalty.
In today’s challenging food industry environment, proactive planning and risk mitigation are crucial for preserving business continuity, brand reputation and customer relationships. A comprehensive crisis management plan tailored to address specific threats is essential. By prioritizing cybersecurity, vendor management, fraud prevention and transparent communication, food businesses can navigate the challenges effectively and ensure their long-term success in this rapidly evolving landscape.
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