Tag Archives: employees

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part II)

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

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

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

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

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

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

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

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

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

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

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

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

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

Jorge Hernandez, All Baroudi, 2019 Food Safety Consortium Conference & Expo

Food Safety Professionals: Earn Respect and Be True to Yourself

By Maria Fontanazza
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Jorge Hernandez, All Baroudi, 2019 Food Safety Consortium Conference & Expo

Food safety professionals are underappreciated. This statement was met with a round of applause last week at the seventh annual Food Safety Consortium. It was made by Bob Pudlock, president of Gulf Stream Search, who has heard the remark from folks working in this demanding field many times, as his firm works to place them in food safety and quality positions within the industry. Pudlock shared his advice on how you, the food safety professional, can better market yourself and earn the respect of peers and higher-ups, as well as how those who are doing the hiring should approach the process.

Read Bob Pudlock’s insights on recruiting in the food safety and quality field in his column series, Architect the Perfect Food Safety TeamCompany cultures change, the popularity of products (and their safety) ebbs and flows, company leadership fluctuates and a company may even move its corporate headquarters. Amidst all of these changes, the only things that a professional can control are his or her reputation, professional acumen, and enhancing one’s education, said Pudlock. “Focus your energy on improving parts of you. Invest in your brand,” he said. “You never know how you’re being perceived and who’s out there in the crowd.” He added that it’s important to take a moment to do some deep digging and ask questions that can help draw out greater meaning:

  • What do you want to be when you “grow up”?
    • Where are you in your career today?
    • What do you aspire to?
    • What are the obstacles? What’s keeping you from getting there?
Bob Pudlock, 2019 Food Safety Consortium Conference & Expo
Bob Pudlock, president of Gulf Stream Search

“Get yourself in a position where you’re personally responsible for getting yourself in the right lane,” said Pudlock, emphasizing the importance of accountability. He also advises that professionals take a moment each day to work through organizational issues via journaling. Writing serves as a cathartic exercise and can help as one is going through the problem-solving process. “Work through your overwhelm with journaling,” he said.

On Earning Respect

On the final day of the Food Safety Consortium, Pudlock led a panel of industry stakeholders who shared their insights on how to remain motivated and earn the respect of peers and superiors in the industry.

Pudlock: As a food safety professional, what has contributed to your ability earn respect from the peers who you’ve worked with over the years?

Jorge Hernandez, Al Baroudi, 2019 Food Safety Consortium Conference & Expo
(left to right) Jorge Hernandez, vice president, quality assurance at The Wendy’s Company and Al Baroudi, Ph.D., vice president of quality assurance and food safety at The Cheesecake Factory at the 2019 Food Safety Consortium Conference & Expo

Jorge Hernandez, vice president, quality assurance at The Wendy’s Company

“What I’ve learned throughout my career is the fact that you have to understand why you are doing this. You have to reach inside and figure out for yourself, and then build your brand around that. It has to be honest; it has to be true to you. Why are you doing this? Is it to get a paycheck? Is it to get away from the kids? There are multiple reasons. There will be times in this field that you have to make the tough decisions. As you build your career, try to figure out why you really want to do this.”

April Bishop, senior director of food safety at TreeHouse Foods/Bay Valley Foods

“The ‘why’ is for those around me: We [speak] a lot of scientific jargon, and we know what we’re talking about. But the folks on the other side—in sanitation [for example], doing the most miserable job at the worst hours and in the worst condition, [for them] I need to translate all the way to the top on why we need so much time to clean the plants. Simplify the scientific jargon down to the facts that people can understand. Sell them on the ‘why’ of what they’re doing.

April Bishop, Marcus Burgess, 2019 Food Safety Consortium Conference & Expo
(left to right) April Bishop, senior director of food safety at TreeHouse Foods/Bay Valley Foods and Marcus Burgess, senior food safety and quality systems specialist at The Cheesecake Factory

Marcus Burgess, senior food safety and quality systems specialist at The Cheesecake Factory

“A lot of it is communication and being able to relate at all levels from [in the field] to the top. It’s the 30-second conversation with the server or the dishwasher about why food safety is important. Being able to connect with the front line employees goes a long way. Approach the job with professionalism and sincerity. Have integrity and know the reason why you’re doing what you’re doing. It’s easy to see the pot of gold. Be selfless and know that ultimately our obligations is to customers.”

Jennifer van de Ligt, Food Protection and Defense Institute, University of Minnesota
FST Soapbox

The Changing Face of Leadership in the Food and Beverage Industry

By Jennifer van de Ligt, Ph.D.
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Jennifer van de Ligt, Food Protection and Defense Institute, University of Minnesota

Our food system is facing daunting challenges. We must adapt our food systems to sustainably feed almost 10 billion people by 2050 in a world with shifting climate and environmental pressures. In addition, we need to reduce the rising number of undernourished people (an estimated 821 million people in recent years) and confront the significant issue of more than 30% of food production being lost or wasted. Tackling these challenges will require collaboration across all aspects of the food system to assure that production processes, policies and regulations, food safety practices, and affordability align to assure we live in a food secure future. However, most of the current generation of leaders in the food industry has not approached leadership from the systems-thinking approach that will be required to succeed.

Thus, focusing on developing the right skills in the rising next generation of leaders in the food and beverage industry in order to solve these problems will be critical. We need people who can think broadly and are empowered to navigate the complexities of the global food system. Professionals in the food industry need to think beyond the specialties and silos where they currently work. Approaching food problems in an open-minded and cross-disciplinary way will achieve better results for business growth, population well-being, food production and planet sustainability.

In my decades of working in the food industry, I was acutely aware of the challenges that we would face in the future. Now, as part of the Integrated Food Systems Leadership program at the University of Minnesota, we are addressing these issues by helping to train the future leaders that will transform the food system. The following topics are just a few of the areas that we see as essential to develop the food leaders of tomorrow.

Next-Gen Leaders with a Holistic Approach

One of the key steps for new leaders in food and beverage industry is to adapt to food systems thinking. Most professionals were hired for their knowledge in a specific area. Now, to become next-gen leaders, they will need to think about the whole food production system and how all decisions made in this system, from sourcing and production to supply chain and retail sale, affect people and the environment.

Where we source our food and how we produce it is truly global and interconnected. The ingredient and material supply chains are vast and complex. We can no longer afford not to take into consideration where and how these items are being sourced and supplied. Additionally, we can no longer afford not to be responsible for the products produced and how they are affecting the health and well-being of consumers as well as the planet.

The next generation of leaders, no matter what part of the food system they are working in, will need to understand these relationships and think about how all these little pieces from production to marketing and sales work together. When one change is made to the system, whether the idea is from R&D or the marketing department or is caused by a new regulation, this will produce ripple effects across the food system.

True Leadership vs. Management in the Food System

Often times, the idea of leadership is thought of as just managing people—observing a team and making sure each person is doing their job. This is management and not a true definition of leadership. To be a leader means you have a vision and can paint a clear picture of what you see to others. Leaders build relationships with people who help turn a vision into reality. Leaders aren’t afraid to change the status quo and take risks if those risks will help the long-term plan. Leaders help their team achieve more than any individual on the team thought possible.

Leaders have many qualities. First, they have ideas that should be heard. However, in order for those ideas to see the light of day, professionals must know how to communicate so their opinions and thoughts are considered. Knowing how to package a vision and communicate it more effectively are critical to leadership development.

Second, leaders desire to have a meaningful impact in the world. To be able to effect change, seeing the bigger picture and understanding the interdependencies throughout the food system is paramount. As part of this, they want and need to help other people be heard to move the vision and plan forward. They will need the skills to foster collaboration and innovation within their teams and across disciplines to help everyone succeed in making the changes needed in the food system.

Third, although leaders want to grow their companies, they also want to grow personally. When a vision is created and steps taken to pave the way for that vision to come to fruition, a journey begins. Leaders know that any journey embarked upon is a life-changing experience, and they welcome that new stage.

Finally, it is important to note that leaders can be found in more places than the corner office. Leaders are not just CEOs, but come in varying roles and titles. Developing people’s leadership potential, style and goals for whatever capacity they work in is a critical part of leadership building. Leaders exist within every team, department and work group across a business. Finding them, to grow and foster their potential, is the challenge.

Fostering Professional Development in the Field

Food and beverage companies can do a great deal to address these pressing issues today by instilling a culture of learning in the organization. I have found, more often than not, people who enter this industry are passionate about it. However, when individuals enter a company, especially early in their career, they sometimes face a crisis of faith moment and question that their lifelong training has not prepared them for what they truly want to do.

Many times those in the industry feel like they have ideas or skills that aren’t being leveraged. They may feel like they aren’t being heard or that they’ve been pigeon-holed into one segment of or role in the business. These professionals could be the collateral damage of silo mentality and lack of a culture of learning and growth, especially when they are high-value and have specialized knowledge. Corporations have perfected efficiency by keeping certain departments, and individuals within them, separated in order to optimize their segment’s function. But slotting the business, and individuals, into distinct categories can hinder the ability of these organizations to see and understand the big picture.

By breaking down this silo mentality and promoting systems thinking, businesses can help their talented and dedicated people grow their career, become a better leader, and enable a move across the lattice structure within an organization. Many times these individuals feel a little lost in the mix and frustrated as a cog in the machine and are looking for growth opportunities. This doesn’t necessarily mean they want to move vertically within the organization, but rather learn and grow laterally or diagonally within an organization to both enhance their career and provide a broader benefit to the entire business.

When companies equip professionals with critical-thinking skills, they are developing their professionals who want to make a meaningful impact within their organizations as well as in the entire food system. This is true empowerment to improve the future of food and make companies viable and competitive for the future.

If a company doesn’t have this training ability internally, organizations can support programs that are helping to build these leaders. Programs like the new Integrated Food Systems Leadership are designed to help future leaders bridge the current skills gap in the food system. These future leaders will have the tools to drive the change critical for many companies to succeed while we feed the future.

Bob Pudlock, Gulf Stream Search
FST Soapbox

Architect the Perfect Food Safety Team: Capture Your Ideal Candidate and Set Them Up for Success

By Bob Pudlock
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Bob Pudlock, Gulf Stream Search

If there is one ingredient that contributes the most to a successful food safety team and culture, it’s the senior-most food safety officer taking full responsibility for the recruitment and on-boarding of each of its team members.

“But isn’t that HR’s job?”

“Isn’t that the talent acquisition team’s job?”

“Isn’t that what our internal recruiter is supposed to take care of?”

As an executive recruiter who is asked to transform food safety teams through new hires, I can say with 100% conviction that the answer is NO.

It’s your job as a food safety leader to make sure every step of the recruitment and on-boarding process, from the first connection with the potential candidate all the way through their first review, is performed flawlessly.

The following are some key benchmarks of a well-executed recruitment process.

  • The candidate and food safety leadership team have clear expectations of how the new hire will impact the business.
  • The candidate’s compensation expectations are aligned with the company’s capabilities, both in the short-term as well as in the future.
  • Each member of the food safety team is on the same page during the interview process. There’s a level of coordination and everyone has a role and responsibility that leaves a favorable impression on the candidate that “this is a strong food safety team and one I want to be a part of.”
  • The hiring team, because it’s been so thorough in its due diligence, has no underlying concerns about their decision.
  • The new hire knows when their first review will be, who it will be with, and what benchmarks they’ll be assessed against.
  • Offer, acceptance and start date are presented, accepted and committed to in less than three days.

What happens when YOU don’t take ownership of the candidate and new hire experience?

Bob Pudlock will be moderating the panel discussion, “Food Safety Leadership: Earning Respect”, at the 2019 Food Safety Consortium | October 1–3 | Schaumburg, ILWhen asked to describe why they left a role after less than six months, the most often heard reply is that the food safety leadership and/or recruiter promised something during the interview process and once on board, everything changed.

Another complaint that arises is that elements of relocation packages, sign-on bonuses, on-boarding and training are either not executed or not coordinated with what was promised during the interview process.

In the food safety space, an oft-held complaint is that the confidence and conviction of food safety leadership during the interview process disappears when the new hire arrives; the new hire experiences a lack of respect shown to food safety personnel, and their leadership team retreats in the background and doesn’t provide cover for the on-the-ground team.

It’s unfortunate but true—a misstep in the recruiting and on-boarding process in an otherwise flawlessly executed hiring process can have drastic consequences on a new hire’s experience.

Imagine a meal at a five-star restaurant with family and friends that goes off flawlessly, only to find out the next morning that half your guests are in the emergency room with food poisoning.

It’s no different when a new hire’s on-boarding experience destroys the goodwill that was created during the hiring process.

In talent acquisition, a flawlessly executed hiring process, followed by an on-boarding experience that aligns with what the new hire was promised during the interview process is the key to future employee referrals—no area of a food or beverage company needs more strong employee referrals than food safety.

It’s also a big part of why food safety staff can act with confidence in calling out protocol violations or unsafe practices that play out in facilities or with suppliers. When trust and goodwill with senior food safety leadership is in place, the food safety team can do their job knowing their boss has their back.

Adam Serfas, R.S. Quality
Food Safety Culture Club

Step Back and Assess Your Food Safety Culture

By Adam Serfas
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Adam Serfas, R.S. Quality

Fostering a strong food safety culture is one of the most important things those in leadership in the food manufacturing and processing industries can do. Whereas laws dictate the food safety regulations to which food manufacturers and processors should adhere, facility food safety and color-coding plans dictate how those regulations should be followed, and it is the inherent culture of the facility that ensures these guidelines and procedures will be followed. A facility’s culture is made up of the shared values of the company, the unwritten norms—good and bad—that ultimately influence the behavior of those in the company. It most often stems from those at the leadership level as they set the tone and expectations for the organization.

Most importantly, however, is the understanding that culture is fluid. Be-cause it is not defined but rather just is, a culture can morph over time in a ripple effect manner. If those in leadership begin to place a higher emphasis on food safety, middle level managers will take note and those sentiments—consciously or unconsciously—will be echoed to those lower in the company’s organizational hierarchy.

At the same time, the reverse is equally and, perhaps, even more likely, true. It’s often harder to do the right thing when it comes to food safety; there are extra steps involved to ensure the environment and tools used are clean, to check and double check the quality of the product and to communicate any concerns that may be encountered along the way. It’s easy to look at someone who takes shortcuts—particularly someone at a higher level than you—and decide that’s an accepted behavior. This can lead to devastating results quickly in a food processing or manufacturing facility where everything from the profit margins to the ability to employ workers to the legal standing of the company hinges on quality assurance.

That said, it’s important that those at the leadership level prioritize foster-ing a positive food safety culture by leading by example. Additionally, it’s vital to regularly glean a quick read of the room to stay on top of culture shifts. The following are some questions you can use to guide that check-in and identify potential red flags long before those worst-case scenarios have a chance to play out.

Would you describe the company’s food safety expectations to be one-size-fits-all notions or, rather, clearly defined rules tailored to different teams and job roles?

If you would put your company in the first category, it’s important you take some time to consider the procedures and guidelines put in place in your facility. Whereas you want company-wide buy-in for overarching food safety priorities, the job role will look very different for, say, someone on the packaging line versus the janitorial team. Within those teams, there should be a shared vernacular and routine specifically related to the job role they need to carry out. It’s unfair and perhaps a bit risky to assume that employees will know how to best carry out their job if “best” is never properly defined for them in training procedures.

Is there clear and consistent messaging that stems from leadership about a commitment to food safety?

The actions and words of those at the highest level of an organizational hierarchy set expectations for the entire company. It’s not only important that they communicate the importance of food safety to the company, but that they return to that conversation often. It’s a good idea to reiterate the significance of food safety considerations in vision and mission statement documents but to also bring it up during staff meetings, company-wide emails and annual reports. Food safety trainings should be held regularly as the more of-ten you highlight these expectations, the more they are thought about across the company. That consideration is what ultimately leads to action.

Do members of leadership take on an active role during food safety training sessions?

Again, we cannot stress enough the importance of those at the top setting the tone for a positive food safety culture by not only talking the talk but also walking the walk. Employees will take note if those higher up in the company who take time out of their day to partake in food safety training. It sends the message that this is indeed important to the company and therefore should be important to the employees.

Are food safety expectations communicated to employees via multiple communication outlets?

Just as a teacher in grade school aims to consider the unique learning styles of students, you should be mindful of the ways in which you are communicating with your team. Some people retain information best through auditory exposure, some are more visual learners and, for some, recall is best after hands-on activities. Consider the ways in which your currently communicate food safety expectations to employees and take note of any additional approaches you might need to take to best reach all employees.

Along those same lines, you should be mindful of additional considerations that might be necessary depending on the makeup of your staff. We recommend working closely with human resources to identify whether or not you should incorporate multi-lingual training procedures and how to best accommodate any employees with disabilities.

Does your company have an obvious method in place for raising concerns about food safety?

The mistake a lot of facilities make is focusing too much on what it looks like for things to go as planned and to overlook procedures for when things don’t go according to plan. If you asked any member of your team, they should be able to tell you the preferred method for reporting any concerns related to food safety. We recommend polling a few employees across different job roles to see if that is the case. If not, it’s vital you establish a protocol and clearly communicate that protocol to all employees. The easier the protocol, the more likely employees are to remember it and to follow through when necessary.

Erika Miller
FST Soapbox

Employee Buy-in to Ensure FSMA Compliance

By Erika Miller
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Erika Miller

Getting employees on board can be one of the most difficult parts of any major change within a company. When things are operating just fine from the perspective of the employee, the cries of, “but we’ve always done it this way!” can be deafening. As a manager, it is our job to explain the new requirements in a way that encourages buy-in from employees at all levels of the organization, and to always present a united front with the company, even if we do not fully understand why a change is important. It is almost a guarantee a business would not spend money implementing a major change if there was not an impetus behind it. One crack in the façade can lead to an entire shift becoming demoralized and disheartened.

Compliance with FSMA is no exception. Although the aim of the act is to reduce food safety risks to the population of the United States, the added paperwork and regulatory requirements can seem onerous to the employees responsible for doing the work. I would encourage any managers who are experiencing some feelings of “why me?” to search YouTube for the videos made by families touched by major foodborne illness outbreaks. The pregnant mothers whose babies are infected with Listeria from deli meat sandwiches are particularly heartbreaking for those who have children.

Once a manager has convinced him or herself of the importance of compliance with the new food safety regulations, it’s time to get your employees on board as well. If you can, show them the same videos you saw to encourage their buy-in. Listeria is a danger in any plant handling a ready-to-eat product or one that could be improperly cooked by the end user. Remember, cooking instructions do not absolve the manufacturer of the responsibility to produce food free of hazards! With the internet, impactful videos are only a click away. Just remember to always fully vet the video before attempting an at-work viewing party—lots of people on the internet have senses of humor that may not translate well to the workplace.

Making the issue personal also works well. This is a great way to get the message home about allergens. In any group of associates, chances are good that at least one of them will have a close friend or family member who is affected by a food allergy. Ask people to raise their hands if they know anyone who is allergic to food. Ask them what that person must do to protect themselves. Frequently, the answer is that the allergic consumer can only read the label. This is a great teaching tool for the importance of proper labeling and can be used as a lead-in to the introduction of a new Allergen Preventive Control, if one is required. Ask the employees to visualize the people they know with food allergies when completing the required records, or performing the onerous tasks, and imagine themselves as the last line of defense.

Many companies employ the services of temporary agencies. These companies can offer a great solution for a company that is concerned about the exposure to litigation that can occur through employee separation. Some industries have high levels of turnover or seasonal operations, which can prove difficult to manage for busy HR departments. Turnover can lead to a loss of accountability as well, such as when an employee informs you that their training was deficient (leading to a major snafu). If their predecessor was not in the position long enough and the chain of training was broken, it can take a substantial investment of time and energy from a senior individual to train that relatively low-paid position back to base minimum level. Outsourcing some of the work to a temporary agency can seem like a godsend at first. They find them, they train them, and all the hiring company must do is eliminate downtime. Who wouldn’t?

However, over time, many companies find the time and money they saved at the outset comes back around to bite them in the end. Temp agencies often do not keep good records, and if you are relying on them to deliver crucial introductory food safety training before they send candidates to you to begin, you may end up in a bind when your auditor or FDA investigator asks to see your training records. The obvious solution is to bring all training back in-house, but that can partly defeat the purpose of having the temp agency in the first place.

Marc Simony, TraceGains

The Culture of Change Management

By Food Safety Tech Staff
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Marc Simony, TraceGains

Complying with FSMA regulations or GFSI schemes isn’t always straightforward, but that also may not be the biggest challenge facing companies today. According to Marc Simony of the TraceGains Network, the large issue is change management and the culture shift that is happening within companies. In a quick video shot during the 2016 Food Safety Consortium, Simony explains.

 

Frank Yiannas, VP of Food Safety, Walmart

Use Homophily to Deliver Food Safety Message

By Food Safety Tech Staff
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Frank Yiannas, VP of Food Safety, Walmart

Watch part I of the video with Frank Yiannas: Apply Behavioral Science Techniques to Food SafetyWho is your company charging with delivering the food safety message? Are they believable? Frank Yiannas, vice president of food safety at Walmart, provides insights about how companies should be spreading their message when implementing a behavior-based food safety program. By applying the principle of homophily, companies (especially global organizations) can communicate more effectively with employees—and in a more believable way.

 

Lone Jespersen, Food Safety Consortium

Food Safety Culture Series: What’s the Controversy?

By Maria Fontanazza
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Lone Jespersen, Food Safety Consortium

From measurement tools to a shift in mindset and leadership, a recent debate at the Food Safety Consortium brought to light the varying levels of opinion and understanding about food safety culture. In a four-part series with Food Safety Tech, Brian Bedard, executive director of the GMA Science and Education Foundation and Lone Jespersen, director of food safety at Maple Leaf Foods continue the conversation about food safety culture and where it’s headed in 2016.

Food Safety Tech: What is the most controversial aspect to the concept of Food Safety Culture?

Lone Jespersen, Food Safety Consortium
Lone Jespersen debates food safety culture at the Food Safety Consortium in November.

Lone Jespersen: I don’t think there are a lot of controversial aspects. I think the debate in Chicago [at the Food Safety Consortium] showed exactly that—companies understand the importance of food safety culture. The challenges that we collectively face lies in what food safety culture is and how we can best measure improvements within our organization to sustain a strong and effective food safety culture. That, by definition, requires that we know what food safety culture is and what we are going to measure. That is where the lack of clarity, understanding, and alignment is.

Over the last few months, I’ve done a lot of comparisons between the measurement tools, and they’re actually not terribly different, but as usual, we get confused by words. As long as we have a clear understanding of how tools are different and what they actually measure, it will be possible for each of us to select the best method for our organization. It’s more confusion than controversy. If we speak of controversy, I think it is with manufacturers and processors who are increasingly worried about what FDA is going to do when they talk about the food safety culture—will investigators come and look for food safety culture without a clear understanding of what it is? Again, it requires that we have a common understanding, which we don’t have today.

Brian Bedard, GMA, Food Safety Consortium
Brian Bedard of the GMA SEF at the Food Safety Consortium

Brian Bedard: I agree. It’s not really controversy; it’s more of confusion and misunderstanding. We’re seeing some alignment and a better understanding that food safety culture is not something totally different and out in left field; it’s a new way of looking at food safety that is all-encompassing and gets around what was happening in the past, which was an ad-hoc, disjointed approach to dealing with food safety issues. It gives companies a more refined process to drive food safety that everyone can understand, from senior managers right on down.

Regulators around the world are looking at food safety culture as one way to help them do their work better. Our concern is that food safety culture shouldn’t become a regulatory tool per se but should be awareness and [an] appreciation that food safety culture at a company can help regulators better understand the risks they are supposed to be evaluating in a preventive manner.

The GMA Science Forum takes place April 18–21, 2016 in Washington, DC | LEARN MOREJespersen: It’s also about looking at food safety culture and the discussion today, which largely takes place in the forum of food scientists, food safety leaders, heads of food safety at large organizations—in other words, between individuals who are educated and experienced food safety professionals. Their experience is in developing microbiological environmental testing programs, full-scale food safety management systems that go across manufacturing facilities—very complex and technical issues, all of which couldn’t be more different than that required of a professional within an organizational where it’s about behaviors and consequences. The same goes for investigators and auditors [and their roles]—they’re good at assessing written systems, etc. What about behavioural observations and assessments? This stakeholder assessment hasn’t been a part of the debate, and we need to bring it in.

Top 10 Tips for Creating a Sustained Food Safety Culture

By Holly Mockus
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After much anticipation, FDA has finally published the FSMA final rules. If you’ve had time to dig into the details, you most likely noted the new initiative that requires companies to measure food safety culture. The industry is also seeing SQF, BRC and other GFSI audit schemes ramping up discussions around measuring food safety culture. However, FDA and GFSI audits aside, how do you create a culture for sustained compliance with this initiative? Follow these 10 tips to ensure your food safety culture is constant and in line with the new requirements

Photo credit: Dennis Burnett for Alchemy Systems
Set clear expectations for employees across the board. Photo credit: Dennis Burnett for Alchemy Systems

1: Create a solid foundation of programs, procedures and policies

Have a preset annual schedule for review and update of all programs, procedures and policies. Don’t let the schedule slide because there are competing priorities. A small pebble is all it takes to start ripple effect in the company, making it difficult to recover.

2: Set clear expectations, driven from the top down

Everyone should follow the rules and guidelines—from visitors to the CEO to the plant manager to the hourly employee. A “no exceptions” policy will drive a culture that is sustainable and drive a “this-is-just-how-we-do-things” mindset.

3: Use record keeping to ensure that food safety culture is well documented and data-driven

Collect the data that is measureable and non-subjective to help drive continuous improvement. If you collect it, you must do something with it. Good documentation is imperative to proving you did what you said you were going to do, especially in the event of an audit. Be stringent in training, and review all documentation before it hits the file cabinet to ensure it is accurate and appropriate.

4: Implement a robust continuous improvement process

Forward momentum through a continuous improvement process cannot be achieved unless management nurtures the program. If you are not continuously improving, you are falling behind.

5: Have a 360-degree approach to employee engagement with 24/7 awareness and communication

Top-down communication is critical to highlighting the priorities and needs of an organization and will not be effective unless an organized program is in place. Organizations that are not making the necessary pivots to communicate with the multiple generations within their workplace today will struggle to sustain change.

6: Foster an atmosphere of mutual respect

Treat people as you would like to be treated, turn the other cheek, etc. There may be lots of adages you quote, but which one best describes your facility and the relationships with management and peers on a daily basis?

7: Be sure employees have consumer awareness for the products they produce

Do your employees know who the end consumer is of the product that they are producing every day?  Does your culture include a review of consumer complaints and customer complaints with your frontline workers?  Listening in to a call center is a very powerful way to help employees understand what affects consumers and how their job is critical to avoiding a food safety or quality issue.

8: Create accountability across the board

Hold folks who do not support the culture in which you are striving to develop or maintain accountable, regardless of their position or stature.

9: Provide positive reinforcement. It’s the best motivator

Work to catch people doing things right and make a big fuss when you do. Positive reinforcement for a job well done is the most powerful motivator. It helps keep every team member on board with food safety commitments.

10: Celebrate often

We spend too much time at work not to celebrate all the good things that are accomplished. Whether it’s a cake and recognition for those that served in the armed forces on Veterans Day or a successful launch of a new product—celebrations are a great way to recognize and reinforce your employees’ hard work. Identifying and correcting mistakes should also be celebrated; they are fertile ground for making changes and provide great nutrients for continuous improvement.