Tag Archives: Focus Article

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.

Craig Reeds
FST Soapbox

Cybersecurity for Food and Beverage Operational Technology (OT) Environments

By Craig Reeds
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Craig Reeds

Much of the attention that cybersecurity gets is on the IT or office network side of things, but recently people have begun paying more attention to operational technology (OT) systems that make up the country’s critical infrastructure. When people think of critical infrastructure, they automatically think of oil and gas, power generation, and water. Many people don’t realize that there are actually 16 critical infrastructure industries:

  • Energy
  • Financial
  • Dams
  • Defense
  • Critical Manufacturing
  • Water and Wastewater
  • Food and Agriculture
  • Healthcare
  • Government Facilities
  • Commercial Facilities
  • Transportation
  • Emergency Services
  • Chemical
  • Communications
  • Nuclear
  • Information Technology

One of the easily forgotten, but perhaps most important, is food and beverage manufacturing. A cyber attack on a food and beverage company might not result in the lights going out or clouds of toxic gas, but they could result in explosions, or tainted food. We need to start paying more attention to cybersecurity in the food and beverage industry. What would happen if a hacker got into the control system at a frozen foods distribution facility? They could raise the temperature in the freezers, thaw the food and then refreeze it. This could result in food poisoning for hundreds or thousands of people. Bad actors can do a lot of harm by targeting this sector.

Many companies are pushing to combine their IT and OT departments, something they call IT/OT convergence. This can be done, but you need to first understand that IT and OT have differing goals.

It is important to review the organizational structure. You will typically find that both IT and OT report organizationally to the CEO level. We also find senior management believes IT owns the industrial control system (ICS) networks and security—mainly because IT owns support, maintenance & operational budget for network and security (basically letting OT off the hook).

IT’s primary goals are confidentiality, integrity and availability, the CIA triad. While working toward these objectives IT also tries to make it possible for users to access the network from any location from which they are working, using whatever computing device they have with them. The goal is to make it as easy to work from an airport, hotel room or coffee shop as it is to work in the office itself. Technology is updated and replaced often. Service packs are loaded, new software releases are loaded, and bugs are fixed.

OT’s primary goals are availability, integrity and confidentiality—a complete reversal of the CIA triad. They strive to keep production running, be it an electric utility, an oil rig or a pop-tart factory 24/7/365. OT is all about what works, a “We’ve always done it that way” mentality. OT will always be reluctant to make any change that might bring down the production line. Remember, they are graded on widgets per minute. There must be trust and open communication between IT and OT if things are going to work properly.

When we are talking about OT cybersecurity, we usually use terms like secure or prevent, when we really should be thinking about words like containment. Securing the network and preventing attacks is important, but at some point, an attack will get past your defenses. Then it is a matter of containment: How do we keep the problem from spreading to other networks?

One thing to definitely avoid is the desire by IT to have bi-directional communications between the IT and OT networks—this should never happen. Also, avoid the desire to connect the ICS to the Internet so that you can control the process remotely. There is no reason for the plant manager to be able to go home, have a couple beers and then log on to see if he can make things run better. If the control system is going to be connected to the corporate IT or the Internet, it should only have out-going uni-directional data transmission to allow monitoring of the system.

Building a good OT cybersecurity program, you need to do three things:

  • Get C-Level support and buy-in for the changes to be made.
  • Communicate with stakeholders and vendors.
  • Make decisions as a team, make sure all the stakeholders, IT, OT, engineering are all involved.

After you have set up the structure and started communicating, you need to begin cybersecurity awareness training for the OT staff. This training should be focused on educating plant personnel on what cybersecurity is, both at work and at home, and how to respond or escalate something that seems wrong. They need to be trained what needs to be dealt with immediately and what can wait. Consider doing tabletop exercises where you practice what to do when certain things occur. This can act as a stress test for your incident response plan and help find the holes in your plan and procedures. These tabletop exercises should involve C-suite individuals as well as people from the plant floor, so everyone understand their part in a cyber-attack response.

If these concepts are followed, you will be well on your way to creating a much more cyber-secure production environment.

Susanne Kuehne, Decernis
Food Fraud Quick Bites

What a Waste

By Susanne Kuehne
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Susanne Kuehne, Decernis
Schweinerei, 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 Netherlands Food and Consumer Product Safety Authority NVWA closed down an animal feed company that generated €4 million revenue selling contaminated feed with forged documents. Several thousand tons of waste, unsuitable to use in animal feed, was found at the facility, and three employees have been arrested.

Resources

  1. Byrne, J. (February 6, 2020). “Arrests in feed fraud cases in the Netherlands”. Feed Navigator.
  2. Also see Inval bij veevoederbedrijf in omgeving van Tilburg.
April Kates, EAS Consulting
Retail Food Safety Forum

Labeling Impact of FDA’s Nutrition Innovation Strategy

By April Kates
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April Kates, EAS Consulting

On March 29, 2018, FDA announced the Nutrition Innovation Strategy, which signaled their intention to take a fresh look at what can be done to “reduce the burden of chronic disease through improved public nutrition.” The agency wants to facilitate consumers making better food choices to improve their health. At the same time, FDA has acknowledged that in many cases, changes in food processing technology has rendered outdated certain provisions of the regulations once written to both inform and protect the public. Therefore, FDA has developed a plan to move ahead to update its policy toolkit.

This multi-pronged approach includes modernizing food labeling, including food standards, health claims policy, ingredient labeling requirements and continuing implementation of the updated nutrition facts label, menu labeling, and reducing sodium in processed food products.

In particular, in trying to gather information to help determine the best approach to revising food standards of identity, FDA held a public meeting on September 27, 2019. FDA is attempting to provide room in the regulations for industry to be able to use modern and hopefully more healthful manufacturing methods while at the same time retaining the traditional characteristics and nutritional value of standardized food products.

During the public meeting, consumer advocacy groups, food industry trade groups and medical associations expressed many points of view as to what FDA should do to make the more than 250 food standards of identity more applicable to the modern food supply. FDA also took comments on updating food ingredient labeling requirements, including simplifying terms for ingredients such as vitamins. Because each food standard of identity is a regulation, it will be no small effort for the agency to update, remove or add standards of identity as needed. This meeting was a way to get input to help guide their decisions and priority—making for food standards and ingredient labeling revisions.

Obviously, with such a broad-based effort, the revisions and changes will be incremental. But the thing to keep in mind is that it all points to an effort to improve public health through the food supply as well as an effort to impactfully modernize the regulations. What follows is a very brief summary of some of FDA’s recent actions in this regard.

On December 30, 2019, FDA announced the final guidance on Serving Sizes, Dual-Column Labeling, which provided additional information about when dual column labeling for nutrition is required and what exemptions are in place to provide relief for certain products or package sizes.

On December 27, 2019, FDA reopened the comment period on the use of ultrafiltered (UF) milk in certain cheeses. When the proposed rule for UF milk in cheeses originally published in 2005, FDA received many comments. Essentially, ultrafiltration was a means to enhance the speed of cheese production, and the standard of identity cheeses were written before this technology was common and did not permit this type of process. FDA seeks to modernize the cheese standards while keeping intact the nature of these cheeses, and so the agency is eager to learn about what can be done to accommodate the new technology without losing the essence of the standards that consumers have come to expect. Because of the time lapse since the previous comment period, FDA is seeking more information to inform their rulemaking.

On October 25, 2019, FDA released a final rule revising the type size for calorie declarations on front of pack labeling for glass-front vending machines. The 2014 rule establishing calorie labeling for products sold from vending machines had provisions that were difficult for certain products to meet. This new rule recognizes those challenges and was an attempt by the agency to provide a middle ground for the industry to meet the requirements of visible calorie labeling on small packages sold in vending machines.

On August 15, 2019, FDA announced final guidance on converting units of measure for Folate, Niacin, and Vitamins A, D and E on the nutrition and supplement facts labels. The guidance provides help to the industry in meeting the requirements of the revised nutrition facts label.

Regarding updating the “healthy” claim on food products, when this term was originally defined by the agency, saturated fat was the nutrient of focus for these claims. However, since then, there are new focuses on health, such as added sugar and calories. In September 2016, FDA sought to modernize the claim, and provided an interim policy to guide its use.

In May 2019, FDA published a draft guidance to provide enforcement discretion for the use of the term “potassium chloride salt” on ingredient statements. In addition, in April 2019, FDA provided a draft guidance for the calculation of calories from a newer sweetener, Allulose.

As you can see, there are a lot of moving parts to FDA’s effort. What will be the impact on the food industry? Changes will most likely be gradual. Over time, there will be modifications to food standards of identity, and potentially claims, and both of these will cause label revisions. And, typically, there may be enforcement discretion by FDA to allow the industry time to revise their products and /or labeling as needed.

You will see FDA requests for information from the public and the industry on various related topics to the Nutrition Innovation Strategy, and guidance documents will be updated.

Alec Senese, Bayer Crop Science, Digital Pest Management
Bug Bytes

Did You Know a Cockroach Could Survive for a Month without Its Head?

By Alec Senese
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Alec Senese, Bayer Crop Science, Digital Pest Management

Like most insects, cockroaches have multiple nervous centers. When they lose their head, the rest of the body will continue to operate separately. In fact, a roach could live indefinitely without its heads if it didn’t need its mouth to eat and drink.

Register now for the complimentary webinar: New Technology’s Impact on Pest Management in the FSMA Regulated World | March 5, 2020 | 12 pm ETIn case you were curious, the following are five fun roach facts to keep in your back pocket for the holiday parties you’ll be attending this year. However, you may want to wait until after dinner has been served to bring these up in conversation…

  1. Roaches are incredibly fast little creatures, running about three miles per hour, or 50 times the distance of their bodies, in a single second. They are also the fastest in the animal kingdom at turning their body. They can make 25 turns per second!
  2. Cockroaches have been known to survive without important resources for much longer than most organisms. They can survive up to three months without food, a month without water, up to 45 minutes without air and can handle radiation levels up to 15 times higher than a human.
  3.  Not only do roaches spread multiple diseases that are dangerous to humans through their feces like Salmonella, shigellosis and hepatitis, they produce allergens that can trigger asthma attacks.
  4.  There’s a sci-fi like relationship between the cockroach and the jewel wasp. A jewel wasps sting can paralyze a cockroach long enough to administer a sting in the roach’s brain. This will give the wasp control over the roach’s escape reflex. The wasp then proceeds to drag the roach back to its nest, lay her eggs in the roach’s body and then allows her hatchlings to feed off the roach and build cocoons inside its body. Yikes. If there was ever a time to feel sorry for a roach, this is it.
  5. Ever heard of Louisiana’s cockroach tea? Cockroaches have been used for healing purposes in many areas of the world. They have been utilized for tetanus remedies in Louisiana, burn treatment and gastroenteritis alleviation in China.

The cockroach is currently being studied for potential uses in prosthetics, antibiotics and more.
The cockroach is an amazing creature, but they are less admirable when they inhabit areas where their presence can present risks to health and business.

Resources

  1. Smirnova, E. An Illustrated Guide to Cockroaches.
  2. How cockroaches could save lives”. (November 3, 2015). BBC News. Retrieved from https://www.bbc.com/news/magazine-34517443
Susanne Kuehne, Decernis
Food Fraud Quick Bites

An ‘Egg-stra’ Splash Of Color

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

Free-range country chicken eggs, often recognizable by their different color, fetch 30–40% more revenue than eggs from caged hens. Leghorns, a common type of chicken used for mass-production, lay white eggs. In this fraud case in India, leghorn eggs were colored by using water-based dyes, for example, made from tea. The eggs were confiscated and destroyed by the Food Safety and Standards Authority of India (FSSAI), and the vendors received a warning.

Resource

  1. Thomas, W. (February 3, 2020). “FSSAI destroys artificially coloured eggs”. The Hindu.
Ben Schreiber, ActiveSense
Bug Bytes

How ERM Can Simplify Pest Management

By Benjamin Schreiber
2 Comments
Ben Schreiber, ActiveSense

Whether you work in food manufacturing, distribution or retail, pests are both a fact of life as well as a regulatory disruption. At the same time, pest management solutions aren’t always clear-cut: While there are a variety of effective strategies employed by pest management professionals (PMPs) servicing the food industry, industry challenges—shifting regulatory standards, a lack of proper documentation and more—can complicate the process. For these reasons, short-term rodent problems can become long-term logistical nightmares, leaving food manufacturers in an undesirable situation when a third-party food plant auditor arrives.

Fortunately, emerging technologies in pest management practices are helping facility managers streamline their food and beverage quality assurance processes, reducing the risk of product loss, regulatory action, improper brand management and more. Specifically, electronic remote monitoring (ERM) allows PMPs to detect and monitor rodents in real time, providing you with important information to help reduce risk and increase audit compliance. As such, the value of food safety pest management strategies that incorporate ERM systems is only growing. Seeking out PMPs who use ERM allows you to invest in technologies that protect your margins, ensure the quality of your product and, ultimately, safeguard your most important asset—your reputation.

Modernizing Pest Management With ERM

At first glance, it might seem like pest management practices haven’t drastically changed since they were first implemented in the food manufacturing industry. Many rodent trapping systems remain similar to their original design: Devices designed to trap or kill that must be individually inspected and serviced by professional technicians. Technicians must then relay any risks to facility managers, who have to determine if additional resources are needed to avoid product loss or audit-based infractions.

Upon closer examination, it’s clear that while pests themselves have not significantly changed, both the pest management industry and the modern food supply chain have become increasingly complex. Food facility managers must contend with increasingly stringent food safety standards, and PMPs must rise to meet these needs with evolving pest management strategies.

In many ways, ERM technologies are the structural pest control industry’s response to these challenges, providing technicians with real-time notifications about rodent behavior and allowing them to make risk-based assessments that identify and treat problems before infestations occur. Unlike pest control strategies that rely on periodic service visits from technicians, PMPs who utilize ERM technology can monitor pest activity around the clock, 24/7/365, in virtually any environment. Instead of monitoring individual traps, PMPs can use ERM technology to know exactly when and where pest activity occurs, including in hard-to-monitor areas such as drop ceilings, crawlspaces, shelving undersides and other traditionally overlooked spaces. Technicians then receive valuable analytics from each trap they install, as well as documentation and reporting, that help managers achieve audit and regulatory compliance.

FSMA and ERM

In 2015, the FDA issued the final component of preventative control for human food under FSMA, officially enacting legislation that requires food safety plants to focus on risk-based pest prevention instead of reactive pest control strategies. As a result, quality assurance professionals and facility managers are often tasked with reallocating personnel toward proactive pest control activities in addition to their day-to-day responsibilities.

In many ways, ERM systems go hand-in-hand with FSMA and GFSI regulations. While preparing for a situation that hasn’t yet occurred can be a costly and time-consuming process, ERM has helped PMPs develop custom pest management strategies that assess and control situations in accordance with FSMA and other auditing firm guidelines. In many ways, ERM can provide all parties—PMPs, in-house auditors and third-party regulators—with a track record of pest history that all parties can cross-reference when assessing a facility.

From Risk-Averse to Risk-Based

When it comes to food safety rules and regulations, the only constant is change. In the structural pest control industry, auditors have historically implemented strict guidelines about trap placement that are frequently changing: For instance, traps should be placed every 10, 15, or 20 feet, regardless of facility susceptibility to various pest conditions. Failure to comply with regulations can result in point deductions on audits, even if the conditions that might lead to an infestation are not present. As such, food processing plants often choose to abide by the most stringent audit guidelines imposed upon them by other parties, such as retailers. By utilizing ERM technologies, food safety and quality assurance professionals can use additional pest monitoring analytics to focus on specific compliance issues, rather than spending additional time and money on other strategies.

Additionally, ERM allows PMPs to focus their efforts not only on weekly service visits and station checks, but also on important tasks, including assessing facility vulnerabilities, tracking rodent access points, and providing consultation and additional management strategies to their client—you.

Approaching the Audit with ERM

Food plant managers and retailers alike know that auditor approval is everything. Because ERM is a fast-developing technology, many quality assurance managers and facility owners are curious to know if ERM is audit approved. In truth, there are many kinds of audits, each with different goals, assessment techniques and regulatory standards. When it comes to audits, the gold standard is not necessarily the assessment of the facility and production line itself, but rather how well the assessment matches records kept by the food production plant.

To this end, ERM might be the answer to a streamlined audit process. No matter what kind of audit a plant is currently undergoing, ERM allows PMPs to provide records auditors need to verify that all systems are working properly. ERM can mean the difference between a streamlined process and a laborious audit, acting as a documentation system that helps officials conduct a PMP-verified “second-check.” This kind of verification is invaluable in an industry where there are already more than enough regulatory categories to consider without having to further worry about potential pest infestations.

ERM-Oriented Solutions

Thanks to the many advantages they offer, ERM and other remote pest monitoring technologies are growing in popularity. Many facility managers appreciate that ERM allows them to assess pest activity, prevent infestations before they occur, gather data that helps them remain industry-compliant, and acquire and share information with additional parties. If you’re a facility manager, quality assurance professional or other food safety decision-maker interested in the opportunities ERM technologies provide, consider starting the conversation about your pest prevention system with your PMP and how ERM might help improve it.

Trust, But Verify

There is an overwhelming consensus in the pest control industry that technology should be developed to provide end-users with more information. ERM systems are a natural extension of this belief, providing each component of the food production and distribution supply chain—manufacturers, distributors, retailers, quality assurance officials, technicians and others—with more data about how pest control decisions are made. Without data, it can be difficult to ensure technician service visits end in greater transparency about the issues facility owners will face as they prepare for an audit.

Fortunately, ERM can help provide the level of trust and assurance plant managers need to feel confident in their day-to-day operations. ERM is an important step forward for manufacturer-regulator relations, which require a strong combination of data, trust and transparency to ensure that communication systems don’t break down. After all, there are many industries in which miscommunication can lead to catastrophic consequences, and food production is no exception.

While each manufacturing facility, processing plant, distribution center, storage warehouse and retail outlet is different, none are insusceptible to pest infestations, and none can avoid audits required to keep them compliant. Because rigorous oversight is crucial for food producers and consumers alike, working with your PMP to develop pest monitoring strategies that utilize ERM systems and other cutting-edge technologies should be part of your larger pest control consideration process.

In the end, the pest infestation that causes the least damage to your product, profit potential and industry reputation is the infestation that never occurs.

Karen Everstine, Decernis
Food Fraud Quick Bites

Fraud in Alcoholic Beverages

By Karen Everstine, Ph.D.
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Karen Everstine, Decernis

Recently, a group of researchers published a paper that documented unique chemical “fingerprints” left by whiskies after evaporation that could be used to identify the origin (specifically, American whiskeys in relation to Scotch and Irish whiskies.) Authentication of value-added label attributes in wine and spirits is important for protection of producers, brands and markets. Other examples include varietal fraud and geographic indication misrepresentation with wines and counterfeit production (intellectual property infringement) of a variety of spirits.

Food Fraud, wine
The Food Fraud Database has captured 220 incidents of fraud involving all alcoholic beverages and 63 specifically involving wines. (Source: Grape Wall of China)

Unfortunately, alcoholic beverages are also prone to fraud involving the addition of substances that can cause illness or death. This often happens at the local level, with the production of “moonshine” or other unlicensed spirits. Some of the substances used have included methanol, isopropyl alcohol and industrial-grade alcohol.
One notable incident from the 1980s had global implications and severe market effects. Diethylene glycol was added to Austrian wines, resulting in recalls around the world when the adulteration was detected. Fortunately, no illnesses or deaths were reported. Just a year later, methanol added to Italian wine caused both hospitalizations and deaths. More recently, incidents involving the addition of methanol to spirits have caused deaths in India, China and Malaysia.

Authentication and traceability for alcoholic beverages, and specifically wines, lend themselves to technology-enabled solutions such as blockchain. On a lighter note, take a look at some of the labels documented by reporters covering the wine market in China. In a high value marketplace such as the wine business, there is no end to creativity in labeling.