Tag Archives: Focus Article

By R. Brett Madden

Bird droppings and nesting materials, if allowed to accumulate over time, can cause severe damage to building facades, ledges, loading docks, walkways, roofs and more. Building materials such as stone, wood and metal can be damaged due to the acidity of the bird droppings. And in extreme cases, a buildup of bird droppings can impact the structural integrity of a structure. Also, roof drains can become clogged, and fire hazards from packed nesting materials around electrical fixtures can develop. Not to mention all the possible diseases that can result from disturbing bird droppings! Rather than waiting until these bird problems develop and result in potentially expensive remediation, in most cases, it will be cheaper to consider bird prevention design elements beforehand—specifically, in the design-build stage (ideally) or the retrofit stage (alternatively).

Before we can review the building design elements, it is best to review the types of areas that birds prefer to land, roost and nest. This way, when considering a design element, considering the kinds of spaces they prefer to set up camp will make more sense.

90-Degree Ledges
- Building ledges
- Decorative elements
- Truck bay bumpers
Knee Walls (parapet ledges)
- Typical construction around most commercial buildings
- Roof structure types
- Flat based surface areas
Covered Overhangs
- Loading docks
- Building canopies
- Interior building structures
Roofing Equipment
- Under HVAC units
- Ductwork
- Roof equipment
Water Sources
- Retention ponds
- Decorative fountains
- Any water source (natural or otherwise)
Food Sources
- Fruit trees
- Trash removal
- Container practices
- Proximity to building
Light Fixtures and Electrical Items
- These items provide warmth
- These items provide elevated areas to survey area and avoid predators

In the design-build phase of the project, when we work with architects, we always recommend decreasing the number of 90-degree ledges or reducing the ledge depth surface area as much as possible. In those areas that we are not able to reduce or eliminate the ledge, we would recommend a landing-based deterrent product such as a bird spike, bird wire, ledge exclusion system or electrified shock-based bird control product. Each of these types of bird deterrent items has different pros and cons.

Bird Spikes

Bird spikes are a type of bird deterrent/and anti-roosting device that will make it hard for a bird to land on a leading ledge and close its wings as it walks onto the ledge surface. When a bird’s landing process is made more difficult, combined with a reduction of the surface landing area, the birds will be deterred from the leading ledge area. Most types of bird spikes have thin metal/plastic rods that are attached to a solid base that point in an upward direction. Bird spikes come in various widths depending upon the surface ledge width area. Bird spikes can be mounted to just about any ledge/surface. Bird spikes can be installed on numerous types of building ledge types and sizes. Bird spikes can be an effective deterrent on gutters, signs, rooflines, cameras, pipes, parapet/knee walls, and related building surfaces.

A con of using bird spikes is that bird spikes are primarily designed to deter larger birds like pigeons. Smaller birds such as sparrows or starlings will not be deterred with bird spikes. A smaller bird can move within and around the rods to use the rods to hold nesting materials within the strands of rods to hold their nesting materials within the bird spike to create a nest. Another con is that larger quantities of bird spikes are unappealing to the building aesthetics.

Bird wire

A bird wire system is a combination of stainless-steel posts that are either epoxied or tapped and drilled into the surface area (typically mortar lines/joints). After the stainless-steel post is mounted, a thin monofilament stainless steel wire is secured between the posts with a micro-spring. The wire is tensioned between the two posts. As pigeons or larger birds attempt to land on treated areas, they will not be able to close their wings and thus will be deterred from landing on treated areas.

A con of using bird wire is that it is typically only effective against larger birds.

Ledge Exclusion

The goal is to turn a 90-degree angle into a 45-degree angle. When you have a ledge that has a base landing area and a return wall area, this allows birds a great shelter area and an ability to survey surroundings. By creating a 45-degree angle, you take a bird’s ability to land and get a foothold and land on the surface. The product is effective for larger birds such as pigeons and smaller birds, too.

The only real con of the changing the ledge structure is matching the building finish. However, this is the best bird exclusion method that is effective against all bird species.

Shock Track

Shock track is a low-profile shock track system with a minimalist low profile, and virtually invisible solution to deter and prevent birds from landing, roosting or nesting on building ledge-based surfaces. The shock track system will deliver a mild/startling electric shock when the bird contacts the strip. Shock track systems are a great option when building/structural aesthetics are a key factor for the facility.

For larger areas such as loading docks, canopies, and related covered structures, netting is the main bird exclusion method.

A few cons for a shock system are that at times, you may have some arcing with heavy snow or water collection when connection area of the strips make contact, and this system is typically only effective against larger birds.

Bird Netting

Bird netting is an exclusion method of bird control. It is intended to be installed on buildings, loading docks, warehouses, airport hangers, transportation facilities, barns, food silos, over building exteriors, balconies, parking garages, rooftops, HVAC units, bridges, agricultural crop applications, ponds, and any other surface that netting hardware can be installed. Bird netting is the best method for excluding all pest bird types. Specifically, seagulls, pigeons, sparrows, starlings, and crows can all be excluded from bird netting.

Bird exclusion netting will prevent birds from gaining entry above any areas that are netted off. It excludes pest birds from roosting and nesting. There are various types of netting and mesh sizes. When selecting the type of netting and mesh size, it is critical to both the target pest bird and where the netting is being installed.

By far, bird netting the best bird exclusion method to control all bird species. The only con of bird netting is that depending upon the application, and the cost can be expensive.

In conclusion, when considering the design-build phase or a retrofit project, the aforesaid areas that are attractive to birds to land, roost and nest should be considered. In most cases, birds can be prevented with a bit of planning.

Remember to also consider surrounding areas (proximity of birds), acceptable pest bird threshold levels, reducing all food and water sources, and closing off all possible entry points. The goal is to not only prevent the birds from setting up shop on the building, but we want to try to keep them an acceptable distance away, too.

December 27, 2019

Almark Foods Expands Hard Boiled Egg Recall As Listeria Outbreak Continues

By Food Safety Tech Staff

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Today FDA provided an update about its outbreak investigation of Listeria monocytogenes linked to hard-boiled eggs manufactured by Almark Foods’ facility in Gainesville, Georgia. On December 23, Almark expanded its recall to include all eggs manufactured at the Gainesville plant. In addition, the company is not producing products at this facility.

Thus far, four companies have recalled products containing the eggs from Almark Foods, as they have the potential to be contaminated with Listeria monocytogenes:

Bakkavor Foods (Trader Joe’s Egg Salad and Potato Salad)
Diebergs Kitchen (Diebergs Market products)
Reichel Foods (Pro2Snax to the Max snack kits)
Great American Deli (egg salad sandwiches)

As of December 17, seven infections were reported, with four hospitalizations and one death across five states. The hard-boiled eggs were sold both in bulk pails to food processors, restaurants and retailers, as well as directly to consumers at the retail level, and have “Best If Used By Dates” through March 2, 2020.

FDA used whole genome sequencing to find a genetic match in the outbreak strain from samples collected at Almark’s facility during agency inspections in February and December of this year.

The agency investigation is ongoing.

December 23, 2019

2020 Priorities: Sanitation, Automation and Brand Transparency in Supply Chain

By Maria Fontanazza

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In a Q&A with Food Safety Tech, Eddie Hall, business development director and food safety expert at Vital Vio looks ahead to 2020 and how technology will be impacting food safety, the additional measures that the industry will be taking to protect consumers, and the critical emphasis on sanitation.

Food Safety Tech: What are some of the touch points for food safety innovation in the supply chain in 2020?

Eddie Hall, Vital Vio — Eddie Hall, business development director and food safety expert at Vital Vio

Eddie Hall: When we think of the supply chain, we often imagine food traveling during transportation—by road, rail and air. During transit, our food comes into contact with countless surfaces, hands, tools and bacteria that travels from the farm to the table. However, transit isn’t the only place for germ spread and bacteria growth. When food reaches the factory for processing and packaging, there are opportunities for contact with debris, mold and dust, along with un-sanitized machinery and employees. Not only does this negatively affect the health of our workers, but also the cleanliness and safety of the food that consumers are buying off the shelves. In food manufacturing plants, Zones 1 and 2 are the most obvious for safety innovation in the supply chain, given food is bound to come into contact with tools, conveyor belts, etc. However, processors must consider the touch points in Zones 3 and 4 as well—such as employee break rooms, bathrooms and offices around the plant that foster bacteria. If these areas are not cleaned, food manufacturers have a significantly higher chance of breeding bacteria in food production areas, even if the right protocols are put in place in those zones.

FST: How will the retail sector step up to the consumer demand for safer food?

Hall: Consumers are increasingly demanding transparency around how food ends up on their plate, and prioritizing purchasing from brands that they trust to be safe. Food suppliers are being careful to remove harmful chemicals from the manufacturing process, along with displaying ingredients and supply chain information. For example, Bumble Bee Foods is using blockchain technology for its tuna fish, allowing consumers to access detailed information around the tuna’s origin, authenticity, freshness and sustainability by scanning the QR code on its packaging. Panera Bread has been consistent in offering customers ingredient transparency [by] providing calorie counts on menu items and removing antibiotic-treated animal proteins, as well as vocalizing recent efforts to perform safety audits throughout its supply chain. Not only does tracking technology and clarity meet consumers’ demands, but [it] also helps retailers pinpoint locations of outbreaks, foodborne illness and mislabeling. We’re already seeing retailers step up to meet the growing demand for safer food, but in 2020 we will see an uptick in brand transparency around supply chain information, safety programs and ingredient clarity within restaurants, fast food chains, processing companies and grocery stores.

FST: How will automation play a role in advancing food safety?

Hall: Food processing companies and retailers are implementing remote monitoring technologies that track data and help measure protocol, temperature controls, sanitation, record-keeping and food traceability. Automation can also help advance food safety through methods such as enhance sanitation and sterilization efforts. It is critical for food industry employees to maintain clean environments, but continuously cleaning every hour of every day can become labor-intensive, and sometimes fall off the to-do list. Automated technologies can take on some of these tedious tasks and work in our favor to heighten food safety. For example, Stop and Shop’s new robot, Marty, patrols the aisles to detect food on the floor, torn packaging, empty shelves and more. However, robots aren’t the only place we’re seeing automation in action. Vital Vio has found a way to automate killing bacteria through antimicrobial LED lighting technology, which continuously kills pathogens with the flick of a switch. Automated tech isn’t meant to replace workers, but to enhance their work around cleaning, sanitizing and meeting safety requirements. In 2020, automation is expected to explode and it’s important for leaders in the food and beverage industry to take advantage of safety tech innovations to advance food safety in 2020 and beyond.

FST: How will food companies continue to work towards reducing contamination issues and recalls?

Hall: The U.S. government has stepped in to tackle issues in the food industry by implementing new regulations, such as FSMA. This regulation urges food companies to shift from reactively responding to safety and contamination issues, to proactively working to prevent them. In an effort to reduce recalls, retail giant Walmart recently employed blockchain to track its lettuce supply chains all the way back to the grower. For food companies to reduce contamination, they must also implement more automated sanitation technologies along the supply chain. The most common food contaminants are usually invisible to the naked eye, such as mold, Listeria, Salmonella and E. coli. Sanitation automation tech—such as antimicrobial LED lighting—can continuously kill microscopic bacteria and prevent regrowth, ensuring clean food and equipment. Not only will food companies begin implementing more sanitization technologies, but also focus on other ways, like blockchain traceability, to prevent food recalls and bacteria growth that pose serious health risks to their customers.

FST: Any additional comments?

Hall: Our Dirty Truth report reveals disturbing stats around Americans’ cleaning habits, such as 1 in 4 (27%) do not sanitize their hands after traveling on public transportation. This means that factory or grocery employees that commute to work via bus, train, etc. are bringing bacteria and other germs with them. What’s worse, 1 in 6 Americans get sick and 3,000 die each year from consuming contaminated foods or beverages. This alarming rate can only be improved if we see effort from all sides of the industry—including food processors, manufacturers, workers throughout the supply chain and retailers. Continuous cleaning and sanitation measures can be labor-intensive and sometimes impossible to tackle throughout the day. Luckily, automated technology exists and is expected to address this growing issue of contamination, the spread of bacteria, recalls, and consumer demand for safety and transparency.

December 20, 2019

Taking Your Operations Digital? Bring in the Stakeholders Early

By Maria Fontanazza

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Going digital is a hot topic in the food industry, but making the investment can be a tough choice for organizations. Jeremy Schneider, business development director, food safety and quality assurance at Controlant, reviews some of the factors that food companies should consider when making the decision, along with the value that digital technologies can bring from the perspective of ROI and improving food safety culture.

Food Safety Tech: For businesses that have been historically paper-driven, where do they start on the technology adoption journey?

Jeremy Schneider, Controlant — Jeremy Schneider, business development director, food safety and quality assurance at Controlant

Schneider: There are a number of questions that firms, both small and large, should consider when deciding to move to a paperless operation. Have you considered what moving away from a paper-based system would mean for your enterprise? What are the perceived challenges to making this move? Or perhaps, what are the risks of not moving to digital? How would utilizing systems provide your organization with the ability to access data in transformative ways?

For organizations that are making the transition from paper documentation to digital, it is critical to develop a roadmap with tangible milestones and objectives. Although there are a variety of reasons to make the switch to digital, what is most important for your organization will determine what those are, as they will play a critical role in developing a roadmap of priorities. We often find that organizations identify a ‘’pain-point’’ in their current process, and this is a leading driver to wanting to make a change in their process. Perhaps this is the inability to easily access information in a timely manner, or the challenges with making sense of the data that you are currently collecting. Whatever your challenges may be, begin by developing a plan, and prioritize this, as it will provide you with early positive results that will keep you working towards the goal. As you experience these early benefits from going digital, you will begin to see the value that this will bring your organization at scale.

One significant issue that many organizations face when beginning this journey is not bringing the appropriate stakeholders into a program early enough. It is critical for the success of new supply chain programs to make sure you bring in members of purchasing, logistics, quality, finance, IT, and others as early as possible so that any questions or concerns are properly vetted early in the process. In addition to this, getting buy-in from these teams at the earliest phase of a project will allow others to vet the system in their own way, potentially helping them solve challenges they have been

FST: Talk about measuring the success of a technology: How do the metrics translate into ROI?

Schneider: A question that is often raised is how to measure the success of the technology. Simply put, does the program make your life easier and solve the problem you set out to, or not? Does it meet the concise objectives that you outlined in the beginning of the process, or does it fall short in some way? If your answer to any of these questions is yes, and it does meet the objectives, then you are well on your way to defining success of your program.

Read Food Safety Tech’s previous discussion with Schneider, Using Technology for Traceability Adds Dimension to Supply Chain, Promises ROIIt is critical that programs are able to show their value through their return on investment, but how do you measure this? If you have recently implemented a real-time supply chain temperature monitoring program, for instance, you may want to consider metrics such as reduced loss, spoilage, shortages, or restaurant-level outages as metrics of success. Or perhaps you would want to translate this into a dollar figure. For instance, in the previous year, your organization counted 10 rejected shipments due to suspected temperature abuse, at a loss of $500,000. In the year following your implementation, your new system was able to help the organization intervene and minimize that loss to just one rejected shipment at a cost of $50,000, thus leading to a reduced loss rate of $450,000.

In collaboration with other stakeholders in your organization, you may be able to identify additional metrics, such as reduced freight rates from optimized shipping lanes, reduced insurance premiums from reduced losses, or reduced quantities of on-hand inventories as you are able to truly manage a just-in-time supply chain. If your organization actively measures your Cost to Serve, savings within your supply chain would likely be an important data point to consider.
Beyond the identifiable money savings, consider some of the soft ROI attributes, such as enhanced collaboration with supply chain and supplier partners, improved customer loyalty, brand protection generally, and sustainability initiatives. Does your organization have goals to reduce food waste? If so, perhaps waste minimization is an important attribute to measure. When evaluated holistically, significant savings can be realized.

FST: How does technology facilitate a more effective food safety culture?

Schneider: Building an effective food safety culture is a process that requires commitment from every level of your organization. The ways that we promote food safety culture within each organization differs, from rewarding team members when they identify an unsafe practice, to actively promoting food safety throughout the organization, to encouraging quality assurance teams to identify state-of-the-art technologies and implementing them to improve the systems, programs, and processes throughout the company.

As food safety professionals, our toolboxes are filled with a variety of tools for the job, and technology as a tool is no exception. Technology should enable our organizations to be more efficient, allowing them to focus their attention on high-priority projects while minimizing work that can be automated. An example of this is setting parameters to allow organizations to work based on exception instead of requiring a review of all documentation.

As we enter the New Era of Smarter Food Safety, and the tenants of it being people-led, technology-enabled, and FSMA-based, we have a mandate to try new technologies to help solve previously unsolvable supply chain challenges. Organizations are actively pursuing real-time supply chain temperature monitoring as a way to provide insights into their cold chain and allowing them to move from reaction to a position of prevention.

Organizations are finding that investments in food safety technologies pay dividends in customer commitment over the long term. It is no longer acceptable to only meet regulatory standards. It is now an expectation that companies do anything possible within their power to assure customer safety and, per the FDA’s new mandate, to help create a more digital, traceable, and safer food system.

December 18, 2019

Food Fraud Quick Bites

Another Seafood Fraud: The Cephalopod Edition

By Susanne Kuehne

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

For more than three years, more than 100,000 pounds of giant squid from Peru was imported into the United States by a father-son duo who owned two Long Island food processing and distribution companies, and then marketed the squid as the more expensive octopus. The mislabeled seafood was worth over $1 million, and 10 grocery stores were defrauded during this time period. This kind of fraud carries steep fines and a possible five-year prison sentence.

Resource

The United States Department of Justice (November 25, 2019). “New York Food Processing and Distribution Companies and Owners Plead Guilty to Seafood Sales Fraud”. Retrieved from Department of Justice, Office of Public Affairs, Press Release Number 19-1307.

December 17, 2019

Farm-to-Fork Transparency: How Digitized Labeling Can Prevent a Major Allergen Recall

By Lee Patty

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For consumers and brands alike, the damaging impact of mislabeling or neglecting to clearly outline an allergen can be colossal. Therefore, to prevent a health and business disaster, best practices around allergen labeling must be top of mind. Luckily, technology can help, and the farm-to-fork transparency provided by a centralized and digitized modern label management system can ensure organizations improve responsiveness and accuracy while reducing costs beyond those saved by mitigating recalls.

No one wants to face a recall, but have you done enough to prevent one from happening to you? More than 650 food products were recalled last year in the United States alone. And one of the leading causes might just be the easiest to prevent: Undeclared allergens.

According to the Q2 2019 Stericycle Recall Index, undeclared allergens are the leading cause of U.S. food recalls, accounting for 48.4% of food recalls from the FDA and 62.9% of food pounds recalled by the USDA. This statistic becomes more alarming considering that roughly 11% of US adults have a food allergy, according to JAMA.

Enacted in 2004, the Food Allergen Labeling and Consumer Protection Act (FALCPA) stipulates that all packaged food regulated under the Federal Food Drug and Cosmetic Act (FFD&C) comply by listing major food allergens. “Major allergens” refers to milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, and soybeans, and for nuts and shellfish, the species must be declared.

For brands, the damaging impact of mislabeling or neglecting to clearly outline an allergen can be colossal, resulting in costly recalls or litigation. However, the impact to consumers can be even greater when one small mistake can cause serious illness, or worse, death. To prevent a health and business nightmare, best practices around allergen labeling must be top of mind.

However, with constantly changing legislation, this can be easier said than done. For instance, in a move that outpaced the FDA, Illinois issued a state law requiring sesame labeling. And in the UK, Natasha’s Law was recently introduced, requiring companies to label all food ingredients on fresh pre-packaged food after 15-year-old Natasha Ednan-Laperouse died of a sesame allergy from a sandwich that didn’t list all the ingredients.

The need for optimal allergen labeling is clear, so how can organizations ensure allergens are clearly labeled on their products and meet existing standards while preparing for future requirements?

Though the underlying principle behind a clear label is simple, the process of designing such labels can be multifaceted and difficult to streamline—especially if labels are designed, printed and managed by separate users across a franchise or store network. And this challenge is multiplied further when products reach across international boundaries. But technology can help, and the farm-to-fork transparency provided by a centralized and digitized modern label management system can ensure organizations improve responsiveness and accuracy while reducing costs beyond those saved by mitigating recalls.

Disorganized Sprawl: A Major Hurdle to Effective Labeling

When implemented properly, modern label management can cost-effectively centralize labeling, reducing inefficiencies and human error. However, before this can happen, there are a few common roadblocks that may make standardizing the labeling process challenging.

One issue may be a sprawl of legacy equipment that is not integrated into a cohesive network. For instance, a legacy labeling system may only support certain label printers while certain manufacturers of direct marking equipment may only support their own propriety brand of printers. In another sense, a lack of standardization can also make it difficult to efficiently integrate labeling with other business solutions like manufacturing execution systems (MES) and enterprise resource planning (ERP) systems.

A damaging impact of sprawl is adoption of a wide range of different labeling applications across various facilities. This will result in inconsistent label formatting, the need to create the same label multiple times, and the need to accommodate different systems and printers. Consequences of this may be a lack of centralized storage when everything is saved locally, complex user training encompassing many software programs, an increased burden on IT, and a great deal of extra administration and human intervention to maintain and update labels.

Another problem with a disorganized ecosystem for labeling is that quality assurance inevitably suffers because tracing a label’s history or implementing standardized approval processes can be difficult or impossible. To accurately track labeling, it’s necessary to have a production log stating where and when labels were produced and who produced them. Having such a log and using it effectively requires centralization or else it can become difficult to track different versions or enforce universal approval processes for altering templates.

Implementing Modernized Labeling to Improve QA

Modern label management systems can help suppliers and manufacturers standardize and control marking packaging or label production across an entire organizational ecosystem. These solutions feature a central, web-based document management system and provide a reliable storage space for label templates and label history. This will enable changes and updates to be tracked centrally, so local facilities can access uniform and accurate templates to produce labels.

An ideal label management system can also interface with a multitude of direct marking and labeling printers, even if they are from different manufacturers, and it can integrate labeling and direct marking with a business system’s master data, which eliminates manual data entry errors. This decreases upfront capital expenditures in more costly efforts to standardize equipment, provides a system that is easy to integrate with partners, saves costs generated from having to discard product or rework labels, and increases a company’s ability to implement unified, organization-wide labeling processes.

Centralized Labeling is Easily Delivered Through Cloud

To many, the thought of migrating legacy labeling to a centralized system or investing a large sum of resources into centralizing labeling may seem inordinate or daunting. However, cloud technology makes migrating to a modern label management system feasible for organizations of all sizes.

With the cloud, designing labels and ensuring quality assurance becomes far more accessible. Additionally, the software-as-a-service (SaaS) model doesn’t require the capital investments or operations and maintenance upkeep associated with costly IT infrastructure and is easily scalable depending on business needs. This is a game changer for small to medium sized businesses who can now benefit from a centralized labeling system because of the cloud.

The Benefits of a “Single-source-of-truth”

In addition to other benefits, integrating a modern label management solution with other business systems allows users to access a “single-source-of-truth.” This allows for enforceable, specific user roles with logins for each user as well as traceability and transparency across all factories that produce products. The traceability from being able to monitor a “single-source-of-truth” is a critical component to farm-to-fork transparency because it can provide an accurate production log overviewing label versions and changes, so companies can pinpoint the locations and causes of labeling inaccuracies and fix them instantly.

A modern label management system also enables organizations to nimbly respond to new regulatory requirements because alterations only need to be made in one location, new templates can be previewed before going to production, and nutrition and allergen functionality can be easily formatted so that it is clear and stands out to the consumer. This increases labeling consistency and accuracy, and saves time when rules change and when new products need to be incorporated during a merger or acquisition.

Futureproofing and Ensuring Consumer Safety with Allergen Labeling

In today’s world, food and beverage manufacturers must rise to the challenge of changing regulations while meeting the call of shifting customer demands and integrating themselves within greater business ecosystems and extended supply chains. In the case of allergen labeling, this may mean preparing labels for different countries, which have varying standards for labeling allergens like sesame, royal jelly, bee pollen, buckwheat and latex, or ensuring labels can be altered quickly when new products are rolled out or when bodies like the FDA revamp standards.

Companies that implement modern label management solutions position themselves to adapt to competition and regulations quickly, implement solutions that can easily be integrated with partners in a supply chain, and streamline quality control. This can help improve productivity, reduce labeling errors, increase collaboration, and prevent product recalls. But most importantly, it helps ensure the safety of consumers everywhere.

December 13, 2019

Using Raman Spectroscopy to Evaluate Laminated Food Packaging Films

By Ellen Link, Gary Johnson, Ph.D.

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Laminated plastics are common and popular food packaging options. They are strong and flexible, making them ideal for both packing and presentation, and can be used for cooking, frozen foods, drink pouches, snack products and even pet food. Yet, unreliable plastics can create a problem for food packaging and the safety of a product.

If a grade of plastic is not what was promised or needed, there can be issues that lead to spoilage, spills and messes, crystallization, mold or other risks. Additionally, there may be concerns about how laminated films will interact with the product itself, as it could impact food safety or lifecycle. For these reasons, it is critical to have accurate information when evaluating the plastics films used in food packaging.

Raman Spectroscopy

Raman spectroscopy (RS) is a powerful method of identifying and characterizing chemical compounds based on light scattering by a sample. It can be used to identify layers in food packaging films to accurately understand the chemical makeup of the laminated plastic. The effect is named for its inventor, C.V. Raman, who was awarded the Nobel prize in physics for its discovery in 1930. It is a non-destructive method that uses an induced-dipole mechanism to probe the vibrations of the chemical bonds in a molecule. The Raman spectrum shows a pattern of molecular vibrations that represents a detailed chemical fingerprint of a material, providing insights into the product composition.

A Raman spectrum is obtained by illuminating the sample with a laser and collecting and measuring the scattered light with a spectrometer. The molecular vibrational modes vary depending on the geometry and electronic structure of the chemical compound present in the sample. By controlling the position of the laser focus point on a sample, a map of the composition can be created. This provides valuable information on the plastic film related to its composition, such as number of layers, thickness of each layer and overall make-up.

In the food packaging and safety industry, this technique can be used to evaluate laminated plastic films by examining polymers, minerals, and/or inorganic fillers and pigments present in the film. Specific food packaging products that can benefit from RS assessments include heat seals, containers, lids, films and wrappers both for durability and performance and for diffusion, permeation or other concerns.

Benefits and Limitations

There are numerous benefits to using the RS method. A major advantage is that there is virtually no sample preparation necessary; spectra can be obtained without direct contact, such as through the sides of glass vials or through windows in reaction cells. As a non-destructive technique, it allows an easy, highly accurate way to take a sample, create a chemical composition map and better understand films’ barrier properties, structural integrity and layers. It has broad applicability and works using conventional microscope optics.

There are, of course, limitations to the approach, as well. Fluorescent components or impurities in a sample can emit a photoluminescent background that overwhelms the Raman scattering. Samples can also be damaged by the laser if too much power is used, or the sample absorbs light at the laser wavelength. Samples that do fluoresce and samples that are photolabile act as common interferences for the RS method. In many cases, these interferences can be overcome with the proper choice of laser and sampling techniques. Additionally, while RS provides an accurate analysis of laminated films, the technique cannot be used on metals or metallic compounds (which can be assessed using scanning electron microscopy or light optical microscopy) or organic pigments or ink layers (which can be assessed with other infrared techniques).

Using RS for Food Packaging

RS can offer a variety of insights for food packaging films:

Failure analysis. If a plastic used for a heat seal in a fruit or yogurt cup fails, it could result in a mess for manufacturers, stores or the consumer. Exposure to air or elements could also lead to spoilage, particularly for refrigerated foods. Inconsistent plastic packaging could result in weak points that break, crack or puncture, which could also result in mold, mess or other spoilage concerns. If a manufacturer experiences a failure in a heat seal or packaging leading to leakage or spoilage, RS analysis can help determine why the failure occurred (was in the plastic film or something else) to help prevent future issues.
Supply chain validation. It is extremely important that the plastic films coming from suppliers are what they are promising and what the manufacturer needs. RS analysis can be used to determine the chemical make-up and morphology of packaging to confirm a supplier’s claims before proceeding with use of the film in food packaging and products.
Simple decision making. If a manufacturer is trying to decide which material to use, RS can provide answers. For example, if there is a need for moisture non-permeating films and there are multiple options available, an RS chemical map can illustrate what to expect with each option, aiding in the decision-making process when combined with other known factors such as cost or timing. If there is an additive in the food product that may diffuse into the film, RS can determine which material might best resist the potential problem.
Packaging appearance. If there is a swirl or haze in the packaging, RS can compare the area with the issue to a clear section to determine if the defect in the film is a foreign polymer or an inorganic pigment or filler, identifying the source of the problem.

RS analysis provides a wealth of information in a manner that is non-destructive. Giving a chemical fingerprint to identify composition with extremely good spatial resolution gives manufacturers valuable information that can be used to mitigate issues, correct problems or make important decisions. These actions in turn can help ensure food safety, which builds brand image and manufacturer equity. Ultimately, RS analysis can play an important role in the success of a product, a brand or a company.

December 11, 2019

Food Fraud Quick Bites

Sweet Things, Adulterated

By Susanne Kuehne

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

Honey is a popular item for adulteration, and honey with a specific botanical source is seen as a more valuable product. The Czech Agriculture and Food Inspection Authority took samples of organic Spanish lavender honey in a Czech supermarket, and analyzed the pollen. The analysis showed that the honey was from alternative botanical sources and certainly not lavender.

Resources

Czech Agriculture and Food Inspection Authority (May 2, 2019). “Med z mořské levandule BIO tekutý”.

December 10, 2019

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. Read the final installment of this series on Lessons Learned from Intentional Adulteration Vulnerability Assessments, Part III.

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