Tag Archives: Focus Article

food safety tech

Next Week: Attend the ‘Drivers in Food Safety Testing’ Webinar

By Food Safety Tech Staff
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food safety tech
Angela Anandappa, Alliance for Advanced Sanitation
Angela Anandappa, Ph.D., founding director of the Alliance for Advanced Sanitation and member of the FST Advisory Board

Join Food Safety Tech next week for the first in a series of complimentary webinars, called Drivers in Food Safety Testing, about the important components and issues that encompass food safety testing. Angela Anandappa, Ph.D., founding director of the Alliance for Advanced Sanitation and member of the FST Advisory Board, will lead the discussion with a presentation about Technologies Leading the Way. The complimentary webinar is aimed at food safety professionals within quality assurance and control, compliance, food lab and contract lab management, and risk management. A technology spotlight given by Lyssa Sakaley, senior global product manager for molecular pathogen testing at MilliporeSigma will follow Anandappa’s presentation. The event will conclude with an interactive Q&A with attendees.

Drivers in Food Safety Testing: Technologies Leading the Way
Wednesday, March 18 at 1 pm ET
Register now!

Christine Charlotte Akselsen, Kezzler
FST Soapbox

Connecting the Dots for Food Safety at GFSI 2020

By Christine Charlotte Akselsen
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Christine Charlotte Akselsen, Kezzler

Representatives at this year’s GFSI conference hailed from 53 countries and spanned the food industry, academia, the public sector and beyond. They came together in Seattle, a city that has long stood at the cutting edge of technological innovation, and as such was a fitting host for this year’s theme: “One Connected World. One Safe Food Supply”.

Speakers at the forefront of their fields shared knowledge and showcased creative methods of delivering connectivity—interpersonal, technology-mediated and otherwise, all geared towards the ultimate goal of helping provide safer food for consumers everywhere.

Meanwhile, there were numerous opportunities to connect with representatives of industry giants such as Costa, Nestle, McDonald’s, Amazon and Starbucks, as well as regulatory agencies, certification & accreditation bodies, NGOs, academia and the media, at the various networking sessions.

Urgent Action Required

As the conference kicked off, it was Peter Freedman, the managing director of The Consumer Goods Forum (CGF), who set out the importance of the task at hand. His message was one of urgency in delivering positive change.

Freedman pointed to recent global events, such as the wildfires in Brazil, as examples of how the world could be at a tipping point. “Action is more urgent than ever”, he told delegates, stating that it is no longer just a matter of responding, but responding urgently. Freedman also pointed to E. coli outbreaks in 2017, 2018 and late 2019 to drive home to industry leaders gathered at the conference that food safety cannot be taken for granted.

The spirit of the event was, as usual, geared towards a collaborative approach. Delegates were asked to leave their commercial interests at the door and work purely towards “a world where all food is safe” for the duration of the event.

“This week is not about us as individuals, it’s about how we come together as a collective of brilliant minds to provide solutions,” GFSI Director Erica Sheward stated. She then invited the audience to stand in recognition of this commitment, and sure enough everyone in the packed auditorium took to their feet demonstrating their commitment to the shared mission.

GFSI’s New Benchmarking Requirements

The GFSI used the conference as a platform to launch its new Benchmarking Requirements Version 2020, which establish a new foundation for food safety. To close the opening session, Sheward joined Mike Robach, Chairman of the GFSI Board, Vice-Chairs Anita Scholte op Reimer and Gillian Kelleher and GFSI Senior Technical Manager Marie-Claude Quentin around a red ‘action button’ to mark their publication.

The requirements are geared towards enabling a common understanding and mutual trust in the supply chain that facilitates trade, improves efficiency and lends nameplate authority to operations certified to a GFSI-recognized program. They incorporate stakeholder input from public consultations and are regularly revised to reflect best practices and evolving needs in the industry.

GFSI positioned the new version as more than just an update, but a complete rethink “representing the beginning of a new generation of recognition”. The two primary objectives of Version 2020, are to achieve transparency and objectivity, with new and strengthened elements that include two new scopes focused on hygienic design, elements of food safety culture and reinforced impartiality of the auditing process and the monitoring of certification bodies.

Shark Tank Sessions

This year’s GFSI program also included a new format to help showcase how the latest technology is being used to further food safety. Leaders in innovation took part in a number of Shark Tank-style breakout sessions to pitch their technology solutions to the sharks and the attendees.

A total of nine cutting-edge companies took to the stage to pitch their concepts to a panel of experts—‘sharks’—who are well-placed to judge their value for the industry. The nine competitors were selected from a large pool of applicants based on their innovative spirit, disruptive potential and feasibility.

Each presenter had 12-minutes to outline the context in which their solution is utilized, the technology supporting it and how it is implemented. Following the pitches, each presenter came under the scrutiny of the sharks who were able to ask clarifying questions.

Kezzler was among the companies to take to the stage with CEO Christine Akselsen sharing insights from work with FrieslandCampina’s infant formula brand, FRISO. Referencing the grass-to-glass case study, she demonstrated how Kezzler’s technology works in practice, tracking information from farms in The Netherlands to consumers in China. Following the sessions an audience vote determined the winner of the competition, which was announced during the final plenary of the conference. Kezzler was also crowned as the first-ever GFSI Shark Tank champion.

RS Spectra

Using Raman Spectroscopy to Evaluate Packaging for Frozen Hamburgers

By Gary Johnson, Ph.D.
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RS Spectra

Raman spectroscopy (RS) can be used to identify layers in polymer food packaging films to better understand the laminated plastic’s chemical composition. A Raman spectrum is obtained by illuminating a sample with a laser and collecting and measuring scattered light with a spectrometer. Coupling the spectrometer to a microscope with a mapping stage allows an accurate way to create a chemical map of a film’s composition and structure. The map provides valuable information to better understand the packaging’s barrier properties, structural integrity and layers.

The RS method can be useful for conducting failure analysis (why did a food package fail to meet standards), supply chain validation (is the plastic what the supplier claims), decision making (which plastic should be used), and evaluating package appearance (why is there discoloring, haze or particle inclusions in the film). It provides important information for design, purchasing, product success and other decisions that food manufacturers and packagers regularly face.

Take for example the packaging used for frozen hamburger patties. The film used must be transparent to display the hamburger patties, but it also needs to provide an oxygen barrier in order to prevent the ground beef from turning brown. As such, a polymer layer with low oxygen permeability must be incorporated into the laminated film, along with other components like nylon for strength and polyethylene for heat sealing and water barrier. The most common polymer used as an oxygen barrier is ethylene-vinyl alcohol copolymer (EVOH).

It is important that the film used to package these hamburger patties includes a good heat seal as well as a proper oxygen barrier layer. The possible absence of either of these could result in the undesired effect of ground beef turning brown. Manufacturers may want to test packaging for an EVOH layer to make a purchasing decision or verify a supplier’s claims. Additionally, if the packaging fails, an analysis can determine if the failure was due to having no EVOH barrier layer in the product or if there is a need to investigate other potential issues with the packaging. Regardless of the reason, RS provides a preferable method for rapidly evaluating the plastic for an EVOH oxygen barrier layer.

The RS method can be used to determine the construction of the laminated film and confirm that it meets specifications. Using the combination of RS with microscopy and mapping allows both identification of the polymers and the evaluator to correlate the composition to the layer structure of the laminated film. This method provides a map showing the composition of each layer in the film. In some cases, the Raman map will show layers that are not resolved in the visible micrograph image. Thus, with RS, one test provides both the structure and composition of each layer of the laminated film.

Laminated film, packaging, Intertek
This sample table illustrates composition and thickness of each layer of a laminated film. Table courtesy of Intertek.

To start, a small section of the film (5 x 10 mm) is cut and mounted with a photocuring resin. A cross section of the mounted film is then cut to expose the layers for analysis. This cross-section is placed on the mapping microscope stage of the Raman instrument. A micrograph image with a 100X objective is obtained and a Raman map of the cross-section with 1 µm2 pixel resolution collected.

A map image is obtained by classical least squares (CLS) fitting example spectra to each of the spectra collected from the cross-section. The example spectra for the CLS fits are averages (mean) of the spectra in the center of each layer with a unique composition as determined by the data (see Figure 1). The final result is a color-coded map that can be superimposed on the micrograph image to show the composition and thickness of each layer in the laminated film. For example, a film with six layers composed of Nylon 6, polyethylene or EVOH would have varying thickness and placement of each layer to achieve the desired result for the product.

RS Spectra
Figure 1. Example spectra used to create the CLS model for map image.

The composition map can confirm the presence of an oxygen barrier layer of EVOH, as well as the overall construction of the laminated film. Knowing the thickness of the barrier layer is important since the gas permeability is a function of the film thickness. Determination of the overall film structure allows the end-user to confirm the film meets the specifications from the supplier. In turn, this can be used to make important purchasing decisions or insights into what caused a packaging failure.

While good, successful results will confirm the presence of an EVOH layer, the RS map may also show only polymers that don’t have the required oxygen barrier properties (see Figure 2). The manufacturer would need to check it against a supplier spec sheet. It may ultimately show that the lack of an EVOH layer is what caused the issue with the packaging. If the test is being used for decision-making purposes, the manufacturer would know not to use the product. If a supply chain validation is being run, after checking the spec sheet, the manufacturer may need to correct the situation.

Raman spectroscopy
Figure 2. Raman map overlaid with image of film cross section. Green = nylon; Red = polyethylene; Yellow = ethylene vinyl alcohol copolymer (EVOH).

What if the analysis confirmed that an EVOH layer was present, but the test was done for a failure analysis, meaning the packaging did fail at some point? If the EVOH later is present but the meat is still turning brown and/or spoiling, other potential problems would need to be evaluated. In this case, the issues would most likely be with the heat seal and additional testing of the heat seal would be necessary. Thanks to the RS analysis, the investigation into the packaging failure can proceed, and the issue with the heat seal identified.

By giving a chemical image of the packaging, RS analysis provides a wealth of information about a film that can be vital to a food manufacturer or processor. Knowing why certain films may not be working, either due to faults in chemical makeup or the need to look elsewhere, such as the heat seal, RS quickly and efficiently provides information and answers to help get products to market and meet consumer demand.

Michael Bartholomeusz, TruTag
In the Food Lab

Intelligent Imaging and the Future of Food Safety

By Michael Bartholomeusz, Ph.D.
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Michael Bartholomeusz, TruTag

Traditional approaches to food safety no longer make the grade. It seems that stories of contaminated produce or foodborne illnesses dominate the headlines increasingly often. Some of the current safeguards set in place to protect consumers and ensure that companies are providing the freshest, safest food possible continue to fail across the world. Poorly regulated supply chains and food quality assurance breakdowns often sicken customers and result in recalls or lawsuits that cost money and damage reputations. The question is: What can be done to prevent these types of problems from occurring?

While outdated machinery and human vigilance continue to be the go-to solutions for these problems, cutting-edge intelligent imaging technology promises to eliminate the issues caused by old-fashioned processes that jeopardize consumer safety. This next generation of imaging will increase safety and quality by quickly and accurately detecting problems with food throughout the supply chain.

How Intelligent Imaging Works

In broad terms, intelligent imaging is hyperspectral imaging that uses cutting-edge hardware and software to help users establish better quality assurance markers. The hardware captures the image, and the software processes it to provide actionable data for users by combining the power of conventional spectroscopy with digital imaging.

Conventional machine vision systems generally lack the ability to effectively capture and relay details and nuances to users. Conversely, intelligent imaging technology utilizes superior capabilities in two major areas: Spectral and spatial resolution. Essentially, intelligent imaging systems employ a level of detail far beyond current industry-standard machinery. For example, an RGB camera can see only three colors: Red, green and blue. Hyperspectral imaging can detect between 300 and 600 real colors—that’s 100–200 times more colors than detected by standard RGB cameras.

Intelligent imaging can also be extended into the ultraviolet or infrared spectrum, providing additional details of the chemical and structural composition of food not observable in the visible spectrum. Hyperspectral imaging cameras do this by generating “data cubes.” These are pixels collected within an image that show subtle reflected color differences not observable by humans or conventional cameras. Once generated, these data cubes are classified, labeled and optimized using machine learning to better process information in the future.

Beyond spectral and spatial data, other rudimentary quality assurance systems pose their own distinct limitations. X-rays can be prohibitively expensive and are only focused on catching foreign objects. They are also difficult to calibrate and maintain. Metal detectors are more affordable, but generally only catch metals with strong magnetic fields like iron. Metals including copper and aluminum can slip through, as well as non-metal objects like plastics, wood and feces.

Finally, current quality assurance systems have a weakness that can change day-to-day: Human subjectivity. The people put in charge of monitoring in-line quality and food safety are indeed doing their best. However, the naked eye and human brain can be notoriously inconsistent. Perhaps a tired person at the end of a long shift misses a contaminant, or those working two separate shifts judge quality in slightly different ways, leading to divergent standards unbeknownst to both the food processor and the public.

Hyperspectral imaging can immediately provide tangible benefits for users, especially within the following quality assurance categories in the food supply chain:

Pathogen Detection

Pathogen detection is perhaps the biggest concern for both consumers and the food industry overall. Identifying and eliminating Salmonella, Listeria, and E.coli throughout the supply chain is a necessity. Obviously, failure to detect pathogens seriously compromises consumer safety. It also gravely damages the reputations of food brands while leading to recalls and lawsuits.

Current pathogen detection processes, including polymerase chain reaction (PCR), immunoassays and plating, involve complicated and costly sample preparation techniques that can take days to complete and create bottlenecks in the supply chain. These delays adversely impact operating cycles and increase inventory management costs. This is particularly significant for products with a short shelf life. Intelligent imaging technology provides a quick and accurate alternative, saving time and money while keeping customers healthy.

Characterizing Food Freshness

Consumers expect freshness, quality and consistency in their foods. As supply chains lengthen and become more complicated around the world, food spoilage has more opportunity to occur at any point throughout the production process, manifesting in reduced nutrient content and an overall loss of food freshness. Tainted meat products may also sicken consumers. All of these factors significantly affect market prices.

Sensory evaluation, chromatography and spectroscopy have all been used to assess food freshness. However, many spatial and spectral anomalies are missed by conventional tristimulus filter-based systems and each of these approaches has severe limitations from a reliability, cost or speed perspective. Additionally, none is capable of providing an economical inline measurement of freshness, and financial pressure to reduce costs can result in cut corners when these systems are in place. By harnessing meticulous data and providing real-time analysis, hyperspectral imaging mitigates or erases the above limiting factors by simultaneously evaluating color, moisture (dehydration) levels, fat content and protein levels, providing a reliable standardization of these measures.

Foreign Object Detection

The presence of plastics, metals, stones, allergens, glass, rubber, fecal matter, rodents, insect infestation and other foreign objects is a big quality assurance challenge for food processors. Failure to identify foreign objects can lead to major added costs including recalls, litigation and brand damage. As detailed above, automated options like X-rays and metal detectors can only identify certain foreign objects, leaving the rest to pass through untouched. Using superior spectral and spatial recognition capabilities, intelligent imaging technology can catch these objects and alert the appropriate employees or kickstart automated processes to fix the issue.

Mechanical Damage

Though it may not be put on the same level as pathogen detection, food freshness and foreign object detection, consumers put a premium on food uniformity, demanding high levels of consistency in everything from their apples to their zucchini. This can be especially difficult to ensure with agricultural products, where 10–40% of produce undergoes mechanical damage during processing. Increasingly complicated supply chains and progressively more automated production environments make delivering consistent quality more complicated than ever before.

Historically, machine vision systems and spectroscopy have been implemented to assist with damage detection, including bruising and cuts, in sorting facilities. However, these systems lack the spectral differentiation to effectively evaluate food and agricultural products in the stringent manner customers expect. Methods like spot spectroscopy require over-sampling to ensure that any detected aberrations are representative of the whole item. It’s a time-consuming process.

Intelligent imaging uses superior technology and machine learning to identify mechanical damage that’s not visible to humans or conventional machinery. For example, a potato may appear fine on the outside, but have extensive bruising beneath its skin. Hyperspectral imaging can find this bruising and decide whether the potato is too compromised to sell or within the parameters of acceptability.

Intelligent imaging can “see” what humans and older technology simply cannot. With the ability to be deployed at a number of locations within the food supply chain, it’s an adaptable technology with far-reaching applications. From drones measuring crop health in the field to inline or end-of-line positioning in processing facilities, there is the potential to take this beyond factory floors.

In the world of quality assurance, where a misdiagnosis can literally result in death, the additional spectral and spatial information provided by hyperspectral imaging can be utilized by food processors to provide important details regarding chemical and structural composition previously not discernible with rudimentary systems. When companies begin using intelligent imaging, it will yield important insights and add value as the food industry searches for reliable solutions to its most serious challenges. Intelligent imaging removes the subjectivity from food quality assurance, turning it into an objective endeavor.

Susanne Kuehne, Decernis
Food Fraud Quick Bites

Novel Foods, Novel Frauds

By Susanne Kuehne
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Susanne Kuehne, Decernis
Purple beans, food fraud
Find records of fraud such as those discussed in this column and more in the Food Fraud Database.
Image credit: Susanne Kuehne

The popularity of plant-based protein powders has skyrocketed, and so has fraudulent activity with so-called protein boosting adulterants. Examples are a variety of beans, such as fava beans, as well as wheat, maize, alfalfa and more. Due to the rapid innovation and development of novelty supplements, regulatory standards are in urgent need of overhaul. Correct ingredient investigation in commercial plant-based protein powders is therefore a must and was investigated in this study with three different diagnostic tools.

Resource

  1. Faller, A.C., et. al. (August 20, 2019). “Investigating appropriate molecular and chemical methods for ingredient identity testing of plant-based protein powder dietary supplements”. Scientific Reports.

Learn more about food fraud and testing technologies at the Food Labs/Cannabis Labs Conference | June 2–4, 2020

Benjamin Katchman, PathogenDx
In the Food Lab

Revolutionary Rapid Testing for Listeria Monocytogenes and Salmonella

By Benjamin A. Katchman, Ph.D., Michael E. Hogan, Ph.D., Nathan Libbey, Patrick M. Bird
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Benjamin Katchman, PathogenDx

The Golden Age of Bacteriology: Discovering the Unknown in a Farm-to-Market Food Supply.

The last quarter of the 19th Century was both horrific and exciting. The world had just emerged from four decades of epidemic in cholera, typhoid fever and other enteric diseases for which no cause was known. Thus, the great scientific minds of Europe sought to find understanding. Robert Koch integrated Pasteur’s Germ Theory in 1861 with the high technology of the day: Mathematical optics and the first industrialized compound microscopes (Siebert, Leiss, 1877), heterocycle chemistry, high-purity solvents (i.e., formaldehyde), availability of engineered glass suitable as microscope slides and precision-molded parts such as tubes and plates in 1877, and industrialized agar production from seaweed in Japan in 1860. The enduring fruit of Koch’s technology integration tour de force is well known: Dye staining of bacteria for sub-micron microscopy, the invention of 13 cm x 1 cm culture tubes and the invention of the “Petri” dish coupled to agar-enriched culture media. Those technologies not only launched “The Golden Age of Bacteriology” but also guided the entire field of analytical microbiology for two lifetimes, becoming bedrock of 20th Century food safety regulation (the Federal Food, Drug and Cosmetic Act in 1938) and well into the 21st century with FSMA.

Learn more about technologies in food safety testing at the Food Labs / Cannabis Labs Conference | June 2–4, 2020 | Register now!Blockchain Microbiology: Managing the Known in an International Food Supply Chain.

If Koch were to reappear in 2020 and were presented with a manual of technical microbiology, he would have little difficulty recognizing the current practice of cell fixation, staining and microscopy, or the SOPs associated with fluid phase enrichment culture and agar plate culture on glass dishes (still named after his lab assistant). The point to be made is that the analytical plate culture technology developed by Koch was game changing then, in the “farm-to-market” supply chain in Koch’s hometown of Berlin. But today, plate culture still takes about 24 to 72 hours for broad class indicator identification and 48 to 96 hours for limited species level identification of common pathogens. In 1880, life was slow and that much time was needed to travel by train from Paris to Berlin. In 2020, that is the time needed to ship food to Berlin from any place on earth. While more rapid tests have been developed such as the ATP assay, they lack the speciation and analytical confidence necessary to provide actionable information to food safety professionals.

It can be argued that leading up to 2020, there has been an significant paradigm shift in the understanding of microbiology (genetics, systems based understanding of microbial function), which can now be coupled to new Third Industrial Age technologies, to make the 2020 international food supply chain safer.

We Are Not in 1880 Anymore: The Time has Come to Move Food Safety Testing into the 21st Century.

Each year, there are more than 48 million illnesses in the United States due to contaminated food.1 These illnesses place a heavy burden on consumers, food manufacturers, healthcare, and other ancillary parties, resulting in more than $75 billion in cost for the United States alone.2 This figure, while seemingly staggering, may increase in future years as reporting continues to increase. For Salmonella related illnesses alone, an estimated 97% of cases go unreported and Listeria monocytogenes is estimated to cause about 1,600 illnesses each year in the United States with more than 1,500 related hospitalizations and 260 related deaths.1,3 As reporting increases, food producers and regulatory bodies will feel an increased need to surveil all aspects of food production, from soil and air, to final product and packaging. The current standards for pathogenic agriculture and environmental testing, culture-based methods, qPCR and ATP assays are not able to meet the rapid, multiplexed and specificity required to meet the current and future demands of the industry.

At the DNA level, single cell level by PCR, high throughput sequencing, and microarrays provide the ability to identify multiple microbes in less than 24 hours with high levels of sensitivity and specificity (see Figure 1). With unique sample prep methods that obviate enrichment, DNA extraction and purification, these technologies will continue to rapidly reduce total test turnaround times into the single digit hours while simultaneously reducing the costs per test within the economics window of the food safety testing world. There are still growing pains as the industry begins to accept these new molecular approaches to microbiology such as advanced training, novel technology and integrated software analysis.

It is easy to envision that the digital data obtained from DNA-based microbial testing could become the next generation gold standard as a “system parameter” to the food supply chain. Imagine for instance that at time of shipping of a container, a data vector would be produced (i.e., time stamp out, location out, invoice, Listeria Speciation and/or Serovar discrimination, Salmonella Speciation and/or Serovar discrimination, refer toFigure 1) where the added microbial data would be treated as another important digital attribute of the load. Though it may seem far-fetched, such early prototyping through the CDC and USDA has already begun at sites in the U.S. trucking industry, based on DNA microarray and sequencing based microbial testing.

Given that “Third Industrial Revolution” technology can now be used to make microbial detection fast, digital, internet enabled and culture free, we argue here that molecular testing of the food chain (DNA or protein based) should, as soon as possible, be developed and validated to replace culture based analysis.

Broad Microbial Detection
Current microbiological diagnostic technology is only able to test for broad species of family identification of different pathogens. New and emerging molecular diagnostic technology offers a highly multiplexed, rapid, sensitive and specific platforms at increasingly affordable prices. Graphic courtesy of PathogenDx.

References.

  1. Scallan, E., Hoekstra, R. M., Angulo, F. J., Tauxe, R. V., Widdowson, M. A., Roy, S. L., … Griffin, P. M. (2011). Foodborne illness acquired in the United States–major pathogens. Emerging infectious diseases, 17(1), 7–15. doi:10.3201/eid1701.p11101
  2. Scharff, Robert. (2012). Economic Burden from Health Losses Due to Foodborne Illness in the United States. Journal of food protection. 75. 123-31. 10.4315/0362-028X.JFP-11-058.
  3. Mead, P. S., Slutsker, L., Dietz, V., McCaig, L. F., Bresee, J. S., Shapiro, C., … Tauxe, R. V. (1999). Food-related illness and death in the United States. Emerging infectious diseases, 5(5), 607–625. doi:10.3201/eid0505.990502
Peter Jardine, Bayer
Bug Bytes

Sanitation and IPM Inspection

By Peter Jardine
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Peter Jardine, Bayer

Register to attend the complimentary webinar: New Technology’s Impact on Pest Management in a FSMA Regulated World | March 5, 2020 | 12 pm ETMillions of pounds of food are lost every year due to pest activity. A lot of those lost food products could have been prevented through a quality sanitation program. One of the best ways to protect your facility from the potential damage and pathogen spread caused pests like rodents is to maintain a quality sanitation program.

Every sanitation program should take into consideration conditions that are conducive to attracting and supporting unwanted visitors. As rodents are incredibly agile and intelligent creatures, one of the best ways to keep them out of a facility is to give them no reason to be interested in coming in. This means eliminating access to each of their basic needs: Food, water and harborage—in any amount. Remember, they are small, scrappy creatures and only need crumbs and droplets of water to survive. Once you change your perspective from that of a human being to that of a rodent you may be surprised by the bountiful conditions that are at your feet.

Laura Gutierrez Becerra
Women in Food Safety

Raising Up Women in Food Safety: Let’s Do This Together

By Laura Gutierrez Becerra, Melanie Neumann, JD, MS, Melody Ge
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Laura Gutierrez Becerra

This month we are truly honored to introduce two committee members who are devoted to helping women in the industry, especially young professionals. Melanie Neumann and Laura Gutierrez Becerra are outstanding professionals who believe in the importance of women in leadership roles.

Melanie Neumann, Neumann Risk Services
Melanie Neumann, Neumann Risk Services, LLC

Melanie Neumann, Executive Vice President and General Counsel, Matrix Sciences

Melanie Neumann leverages both a juris doctorate law degree specializing in food laws and regulations and a Master’s degree in food science to assist the food and beverage industry with regulatory, business, brand and public health risk management solutions in today’s ever-changing risk landscape. Neumann launched her career as a food law attorney for Hormel Foods Corporation, and held similar roles at The Schwan Food Company, and the law firm of Fredrikson & Byron, all based in Minnesota where she was born and raised by her mother who was described by Melanie as “the reason I am as successful as I am today.” After her initial career launch, Neumann evolved into food safety and enterprise risk management consulting roles for Pricewaterhouse Coopers and boutique food safety consulting firms before launching her own business, Neumann Risk Services, which was subsequently assumed by Matrix Sciences International, Inc.— food safety and quality experts focusing on microbiological, chemistry, analytical, residue and pesticide laboratory testing, sensory testing, data analytics and food safety risk management advisory services. (Neumann is also a member of Food Safety Tech’s Advisory Board).

Laura Gutierrez Becerra, Food Safety & Quality Assurance Director, Calyxt

Born and raised in Mexico, Laura Gutierrez Becerra completed her undergraduate studies in biological and pharmaceutical chemistry and holds a Master’s degree in food science and technology. Her passion for embracing a safe global food supply chain started in college while participating in a student exchange program where she saw the need to help other countries improve their food safety systems and establish a global food safety culture. Gutierrez Becerra’s experience includes corporate restaurant, retail and manufacturing food sectors where she has established risk-based food safety programs and led management of quality through the product lifecycle while embracing strong partnerships with stakeholders in order achieve a shared preventative accountability.

What prompted the launch of a group that focuses on female professional development in the food safety sector?

Melanie Neumann: Melanie’s commitment to empowering women has a long history, starting with encouraging women to actively participate in local and state politics to volunteering for female running programs that empower girls to realize they can always do more than they think they can. In the food safety arena, Neumann was the first female to serve in nearly every professional role she has held, so she is well aware of the trials—and the joys—of paving the way not only for herself but for other women as well. In founding and running her own successful consulting firm, she understands the courage, commitment, fears and support required to successfully navigate professional advancement in food safety, while still preserving a balance to pursue her passion. She competes in the Ironman long-distance triathlons and is participating in her ninth Ironman triathlon in April 2020.

Laura Gutierrez Becerra
Laura Gutierrez Becerra, Calyxt

Laura Gutierrez Becerra: Raising a multi-cultural and multi-lingual family with her husband, Gutierrez Becerra embraces diversity of thought and inclusion of ideology for the establishment of a global food safety culture. Building the strengths of young women during their educational and career journeys will help build the foundation for a strong and diverse food safety community. Gutierrez Becerra also believes it is important to have male food safety leaders participate in this group to walk the audience through their experiences when bringing women along their own professional career, as well as sharing what they have learned while partnering with women in food safety roles at all leadership levels

How do you see this group positioned in the future?

Neumann: Neumann envisions a female-forward/female-centric group where women in food safety can gain mentoring, networking and volunteer opportunities, and share successes and challenges unique to women in the field. That said, she also sees a role for our male counterparts in food safety to provide insights into successful strategies and tactics for females to consider leveraging. Neumann views our field as one, but comprised of many perspectives, and is dedicated to helping ensure that each voice is heard.

Gutierrez Becerra: Based on the fact that the food industry is continually and rapidly evolving—where product launches are led by consumer trends and behaviors—Gutierrez Becerra sees and believes this social network will support women in connecting and guiding each other while learning from each others careers and challenging experiences regardless of the career level. She also believes this group can be a great venue through which to seek advice and embrace work/life balance while striving for a career path.

We invite you to join the group, For Women in Food Safety or direct message Melody Ge on LinkedIn. We welcome all the support and are constantly looking for mentors. If you are interested in mentoring the young food safety professionals, please reach out to Melody Ge, Jill Hoffman, Jacqueline Southee, Melanie Neumann and Laura Gutierrez Becerra through the group. We can do this together!

Susanne Kuehne, Decernis
Food Fraud Quick Bites

Germany’s Food Warning Website

By Susanne Kuehne
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Susanne Kuehne, Decernis
Food fraud, Germany
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne

Unapproved ingredients and allergens, whether added intentionally or unintentionally, were the third largest reason for recalls in Germany last year, behind microbiological contamination and impurities from foreign matter. The German food warning system by the BVL (Bundesamt fuer Verbraucherschutz und Lebensmittelsicherheit) is accessible by the public and provides detailed information of warnings considering food and beverages. The warnings issued per year are growing steadily, from 100 warnings in 2015 to 161 in 2017 to 198 warnings in 2019.

Resource

  1. WirtschaftsWoche (January 10, 2020) “Um Rueckruf wird gebeten”. Retrieved from WirtschaftsWoche3, 2020. Original source Bundesamt fuer Verbraucherschutz und Lebensmittelsicherheit

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part III)

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. Part II reviewed access, subject matter experts, mitigation strategies and community drinking water. This final article reviews broad mitigation strategies, feasibility assessments, food defense plans, partial ingredient security and the “Three Element” approach through more lessons learned from assessments conducted for the largest and most complex global food and beverage facilities, but which can also be applied to the smaller facilities that are currently in the process of readying for the next deadline of July 26.

Lesson 14: When the final rule was released, the concept of using broad mitigation strategies was eliminated. That notwithstanding and realizing that many companies seek to operate at a stricter standard for food defense with a clear focus on brand protection, versus only those process steps that potentially could result in a “wide scale public health impact.” Broad or facility-wide mitigation strategies should not be abandoned, but are less likely to get you a lot of credit for IA compliance. Including existing food safety prerequisite programs (PRP), programs and practices that are put in place to maintain a sanitary environment and minimize the risk of introducing a food safety hazard, can, in some cases, also be included as security mitigation. PRP’s with slight modifications can also contribute to a good “food defense” posture. For example, one PRP addresses hazardous chemicals and toxic substances. In some cases, non-food grade substances that could result in product contamination (not necessarily wide-scale public health impact) might be available to a disgruntled insider. It is obvious companies are concerned about contaminants being brought into the plants, but please do not overlook contaminants that are already there and ensure that they are properly secured when not in use.

Other facility-wide programs (broad mitigation) that contribute to effective food defense might include site perimeter or building security, visitor and contractor management, pre-employment background checks, employee security awareness and food defense training and sanitation chemical management.

Lesson 15: If you are using the three elements approach (Guidance Chapter 2 Section G) or the hybrid approach (Guidance Chapter 2 Section H), you will be required to make an assessment on feasibility. In the early VA’s conducted, prior to the second installment of the guidance in March of 2019, feasibility was essentially an all or nothing proposition. One could argue that a judgment call was required as to whether an intentional adulteration incident could be accomplished given the inherent conditions. Those conditions might include a lot of coworkers who might be able to observe and serve as witnesses to deter the act. With the release of the second installment of the guidance from the FDA, a new tool was made available which would allow food and beverage companies to run a calculation and make a more accurate prediction of how much of an unnamed “representative contaminant” which is assumed to be highly lethal and heat stable it might take to contaminate a product batch. Typically, the larger the batch size, the higher the quantity of the “representative contaminant” would be required to achieve a lethal dose (LD) in a serving size. So, to provide an additional level of validation with identified actionable process steps, the use of the LD calculation might be considered to provide more realistic insight into the feasibility element. For instance, if it would require one hundred pounds of the “representative contaminant,” you might feel justified in concluding that it is not realistic to get that amount of contaminant into the batch at the process step and rule out the point, step or procedure as an APS. This can save money and ensure limited food defense resources can be channeled to the areas where legitimate risk can be reduced.

Lesson 16: After an APS is identified, sites will need to determine, as the rule states, whether the existing “mitigation strategies can be applied…to significantly minimize or prevent the significant vulnerability.” Simply stated, what is in place today for food safety, and the broad-based security measures in use, may or may not be enough when you consider an insider motivated to contaminate the product. The FDA’s mitigation strategies database may offer some insights into additional food defense measures to consider. Where additional mitigation strategies are identified, from the time of completion of the VA until a site’s regulatory compliance deadline arrives (next one is July 26, 2020), that change must be incorporated into the food defense plan and fully implemented. We recommend that a site make a list of new mitigation strategies after the VA is complete for tracking purposes during the implementation phase. No mitigation strategies should be included in the food defense plan that are not fully implemented and where records cannot be adequately produced.

Lesson 17: In the second installment of the guidance, the concept of partial ingredients was introduced. The key activity types (KAT) of secondary ingredients is now considered to include the storage of partially used, open containers of secondary ingredients where the tamper-evident packaging has been breached. Tamper evident tape looked to have promising benefits, but several of our clients have abandoned the use of this mitigation strategy, which has been proven repeatedly to be defeated without detection. It appears that using containers that can be secured with numbered seals might be a better option and even better if the seals would be metal detectable in the event one went astray in a product stream.

Lesson 18: Food defense plan unification. Facilities regulated under the IA rule are likely to already have a food defense plan for other initiates such as SQF or BRC. The IA Rule is not unlike other counter-terrorism regulations in potential to create challenges to meet voluntary and regulatory requirements without having multiple food defense plans. The IA Rule based on its modeling after HACCP creates some very specific requirements in terms of how data needs to be presented and records maintained. Sites may be doing other things to support food defense, and one strategy that might keep auditors in their lane would be to include any non-IA Rule food defense content (e.g., for SQF or BRC) in an appendix to the IA Rule Food Defense Plan.

Lesson 19: Under the VA method the FDA refers to as “the “Three Element” approach, suggestion is made in the guidance released in March 2019 that regulated facilities might consider creating stratified categories for each element of public health impact, degree of physical access and ability of the attacker to successfully contaminate product. This is asking regulated facilities to engineer their own vulnerability assessment methodology. It is our opinion that this is asking a lot from a food and beverage facility and that creating categories for each element (e.g., refer to Table 3 on page 54) will extend the time it takes to complete a vulnerability assessment, create a lot more uncertainty in the process and does not necessarily help companies to identify the areas where intentional adulteration risk is highest.

Conclusion

Organizations who have yet to execute vulnerability assessments (due July 26) or those who have already completed vulnerability assessments who may wish to reflect back on their existing VAs in an effort to eliminate unnecessary APS’s should find these strategies helpful in focusing limited resources to the areas where they can have the greatest effect. Since the initiation of this article series, the FDA has released its third installment of the guidance. Once we reflect on this new installment, we will address our thoughts in a future article.