Tag Archives: Focus Article

By John McPherson

End-to-end traceability technology across the food and beverage (F&B) supply chain has many benefits for companies at all nodes of the chain, not least of which is the ability to act to prevent problems such as irreversible damage, loss, and theft. For these technologies to best deliver on their promise, however, they need standardized and quality-assured data. F&B supply chain stakeholders need to take steps to achieve effective data management to truly take advantage of the benefits of traceability and real-time monitoring technologies.

Since FSMA was introduced in 2011, actors across the F&B supply chain have had to change their behavior. Prior to FSMA, companies tended to react to events; today, proactive and preemptive measures are the norm. This is in line with what the legislation was designed to do: Encourage the prevention of foodborne illness instead of responding after their occurrance.

F&B manufacturers and distributors rely on technology to help predict potential obstacles and mitigate issues along their supply chains. But expressing a desire to embrace technologies such as real-time monitoring solutions and predictive analytics isn’t enough to achieve ultimate supply chain efficiency. Only by taking the necessary steps can companies get on track to ensure results.

Any company that is thinking about deploying a traceability solution has a lot to consider. Foremost, data must be digitized and standardized. This might seem challenging, especially if you’re starting from scratch, but it can be done with appropriate planning.

Let’s examine what F&B companies stand to gain by adopting new, innovative technologies and how they can successfully maximize data to achieve end-to-end supply chain traceability.

New Technologies Hold Huge Potential for F&B Supply Chains

The advantages of adopting new technologies far outweigh the time and effort it takes to get up and running. To smooth the process, F&B companies should work with solution providers that offer advisory services and full-service implementation. The right provider will help define your user requirements and create a template for the solution that will help ensure product safety and compliance. Furthermore, the right provider will help you consider the immediate and long-term implications of implementation; they’ll show you how new technologies “future-proof” your operations because they can be designed to perform and adapt for decades to come.

Burgeoning technologies such as the Internet of Things (IoT), artificial intelligence (AI) and blockchain are driving end-to-end traceability solutions, bridging the gap between different systems and allowing information to move seamlessly through them.

For example, real-time tracking performed by IoT-enabled, item-level sensors allows companies to detect potential damage or negative events such as theft. These devices monitor and send updates about a product’s condition (e.g., temperature, humidity, pressure, motion and location) while it is in transit. They alert you as soon as something has gone wrong and give you the power to take action to mitigate further damage.

This is just one example of how data from a fully implemented real-time, end-to-end traceability platform can yield returns almost immediately by eliminating blind spots, identifying bottlenecks and threats, and validating sourcing requirements. Such rich data can also change outcomes by, for example, empowering you to respond to alerts, intercept suspect products, extend shelf life, and drive continuous improvement.

As for AI technologies, they use data to learn and predict outcomes without human intervention. Global supply chains are packed with diverse types of data (e.g., from shippers and suppliers, information about regulatory requirements and outcomes, and public data); when combined with a company’s internal data, the results can be very powerful. AI is able to identify patterns through self-learning and natural language, and contextualize a single incident to determine if a larger threat can be anticipated or to make decisions that increase potential. For example, AI can help automate common supply chain processes such as demand forecasting, determine optimal delivery routes, or eliminate unforeseeable threats.

Blockchain has garnered a lot of buzz this year. As a decentralized and distributed data network, it’s a technology that might help with “unknowns” in your supply chain. For example, raw materials and products pass through multiple trading partners, including suppliers, manufacturers, distributors, carriers and retailers, before they reach consumers, so it can be difficult to truly know—and trust—every partner involved in your supply chain. The immutable nature of blockchain data can build trust and secure your operations.

To date, many F&B companies have been hesitant to start a blockchain initiative because of the capital risks, complexity and time-to-value cost. However, you don’t have to dive in head-first. You can start with small pilot programs, working with just a few stakeholders and clearly defining pilot processes. If you choose the right solution provider, you can develop the right cultural shift, defining governance and business models to meet future demands.

To summarize, new technologies are not disruptive to the F&B industry. If you work with an experienced solution provider, they will be constructive for the future. Ultimately, it’s worth the investment.

So how can the F&B industry start acting now?

How to Achieve End-to-End Traceability

Digitize Your Supply Chain. We live in a digital world. The modern supply chain is a digitized supply chain. To achieve end-to-end traceability, every stakeholder’s data must be digitized. It doesn’t matter how big your company is—a small operation or a global processor—if your data isn’t digitized, your supply chain will never reach peak performance.

If you haven’t begun transitioning to a digitalized supply chain, you should start now. Even though transforming processes can be a long journey, it’s worth the effort. You’ll have peace of mind knowing that your data is timely and accurate, and that you can utilize it to remain compliant with regulations, meet your customer’s demands, interact seamlessly with your trading partners, and be proactive about every aspect of your operations. And, of course, you’ll achieve true end-to-end supply chain traceability.

Standardize Your Data. As the needs of global F&B supply chains continue to expand and become more complex, the operations involved in managing relevant logistics also become more complicated. Companies are dealing with huge amounts of non-standardized data that must be standardized to yield transparency and security across all nodes of the supply chain.

Many things can cause inconsistencies with data. Data are often siloed or limited. Internal teams have their own initiatives and unique data needs; without a holistic approach, data can be missing, incomplete or exist in different systems. For example, a quality team may use one software solution to customize quality inspections and manage and monitor remediation or investigations, while a food safety team may look to a vendor management platform and a supply chain or operations team may pull reports from an enterprise resource planning (ERP) system to try and drive continuous improvement. Such conflict between data sources is problematic—even more so when it’s in a paper-based system.

Insights into your supply chain are only as good as the data that have informed them. If data (e.g., critical tracking events) aren’t standardized and quality-assured, companies cannot achieve the level and quality of information they need. Data standards coming from actors such as GS1 US, an organization that standardizes frameworks for easy adoption within food supply chains, can help with this.

There are many solutions to ensure data are standardized and can be shared among different supply chain stakeholders. With recent increases in recalls and contamination issues in the United States, the need for this level of supply chain visibility and information is even more critical.

Data Security. Data security is crucial for a successful digital supply chain with end-to-end traceability, so you must plan accordingly—and strategically. You must ensure that your data is safe 24/7. You must be certain you share your data with only people/organizations who you know and trust. You must be protected against hacks and disruptions. Working with the right solution provider is the best way to achieve data security.

Incentive Structures. Incentives to digitize and standardize data are still lacking across some parts of the F&B supply chain, increasing the chances for problems because all stakeholders are not on the same page.

Companies that continue to regard adopting traceability as a cost, not an investment in operations and brand security, will most likely do the minimum from both fiscal and regulatory standpoints. This is a strategic mistake, because the benefits of traceability are almost immediate and will only get bigger as consumers continue to demand more transparency and accuracy. Indeed, we should recognize that consumers are the driving force behind these needs.

Being able to gather rich, actionable data is the key to the future. Industry leaders that recognize this and act decisively will gain a competitive advantage; those that wait will find themselves playing catch-up, and they may never regain the positions they’ve lost. We can’t overstate the value of high-quality digitized and standardized data and the end-to-end traceability it fuels. If companies want to achieve full visibility and maximize their access to information across all nodes of their supply chains, they must embrace the available technologies and modernize their data capabilities. By doing so, they will reap the benefits of a proactive and predictive approach to the F&B supply chain.

November 7, 2019

The Value of a One Percent Improvement

By Food Safety Tech Staff

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During the past year, the headlines have been filled with stories of foodborne illness, product recalls, and consumers becoming sick from tainted food. In a Q&A with Food Safety Tech, Sean O’Leary, CEO at FoodLogiQ, talks food safety, traceability, and how small percentages can translate into big victories for the food industry and for the people they serve.

Food Safety Tech: From your perspective, what is the current sentiment of consumers with regard to food safety?

Sean O’Leary: Over the last few years, the consumer mindset has changed about food in general. We’ve watched fad diets come and go; however, the interest in healthy ingredients and the concern about where food comes from has graduated from a passing trend to a full shift into the public consciousness. Consumers are much more discerning about what they eat; they also demand to know where their food comes from, how it was produced, and how it got to their table. We are living in the age of transparency, and consumer expectations are high.

And who can blame them? CDC statistics tell us that approximately 48 million people get sick every year from foodborne illnesses—and that’s just in the United States; 128,000 of them end up in the hospital. When a person is admitted to the hospital, it affects more than just that one individual. If the patient is the sole breadwinner of their family, their illness affects the entire family. If the person who gets sick is a child, there can be long-term consequences that trickle down to his or her whole community. And when you consider that 3,000 people die every year from foodborne illness—that’s one 9/11 every year. That’s unacceptable, because this is a preventable issue, and unfortunately, these illnesses are an underreported public health problem.

My challenge to the food industry is simple: What if we made just a 1% improvement in the number of cases of foodborne illness? That seems like such a small percentage, but when you do that math, that’s 480,000 people who don’t get sick this year; 1,280 people who aren’t admitted to the hospital; and 30 people who don’t die. Those are significant numbers.

Sean O’Leary joined FoodLogiQ as CEO in January 2019 with more than 25 years of experience in the technology industry.

FST: To help shed additional light on this subject, FoodLogiQ conducted a national survey to tap into how U.S. consumers feel about issues related to food transparency. What did you learn from those consumer responses?

O’Leary: We polled more than 2,000 people to gauge their sentiment around food traceability and their expectations for food companies regarding foodborne illness and product recalls. The survey also posed questions around consumer preferences regarding their food sources and how they are identified on food labels and menus. The results were enlightening, to say the least.

We learned that a brand or restaurant will pay a high price in terms of customer loyalty if they experience a food recall due to consumer illness. And those customers have some strong opinions regarding how quickly the brand or restaurant should address a food safety issue.

35% of survey respondents told us they would avoid an affected brand or restaurant for a few months, and maybe they would return after the issue had been resolved. Meanwhile, nearly 25% admitted they would never use the brand or visit the restaurant again.
Of the respondents who say they care about the quality of the food they eat, 55% say they expect a recall to be executed within 24 to 48 hours.

In reality, it sometimes takes weeks for a product to be pulled from the store or restaurant. This is frequently due to communication issues, since everyone along the supply chain—the grower, supplier, packing and distribution centers, corporate office, and the retailer or restaurant—all must be notified, and a recall plan must be set in motion. Unfortunately, that communication process takes time. When that communication takes place via email or by phone call, the people responsible for pulling product may not have the information they need or may have received misinformation. This can result in lag time, and potentially unsafe product can still get into the hands of consumers.

The faster a food company can address a recall situation and return to business as usual, the faster customers will come back. But comprehensive supply chain transparency is needed to be able to make swift, accurate decisions during this time of crisis. By having a robust end-to-end traceability program and technology that provides real-time data and visibility, companies facing a recall can isolate and surgically withdraw the tainted product out of the supply chain without recalling more items than necessary. That limits the disruption and the waste of good food, which saves the company money.

FST: You recently attended the FDA’s “A New Era of Smarter Food Safety” public meeting in Maryland. What do you think this new campaign will mean for the food industry?

O’Leary: FoodLogiQ was honored to have the opportunity to share our intricate knowledge of the food supply chain, as well as best practices regarding whole chain traceability during this monumental meeting with the FDA with more than 250 food industry leaders.

In retrospect, one thing is clear—we’re in the midst of a pivotal time of change for the world’s food supply chain. In the United States, the food industry remained status quo for decades, but the introduction of FSMA has brought increased scrutiny and accountability; I think it’s made every food company pause and evaluate where they are with regard to food safety, and that’s a good thing. And now, with the launch of the “New Era” campaign, we’re coming together in a collaborative fashion to map out how technology tools, prevention measures, new business models, and an evolving culture of food safety can be merged as a framework for a long term food safety solution. I agree with the FDA; ‘Smarter Food Safety’ is people-led, FSMA-based, and technology-enabled. It will take all of us working together to reach that goal.

November 6, 2019

Food Fraud Quick Bites

The Hellcat of Pet Food

By Susanne Kuehne

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

Pet food is a highly profitable business. Global pet food sales hit a record $90 billion in 2018, and adulterated or mislabeled feed is not uncommon. In the United States, the FDA ensures correct labeling and adherence to quality standards in pet food. Over the course of six years, a processing facility in Texas shipped low quality, mislabeled ingredients such as feathers and by-products, labeled as premium single ingredients, to pet food manufacturers and distributors. The guilty party had to pay $4.5 millions in restitution to the fraud victims, and the defendant is on a five year probation.

Resources

Department of Justice, U.S. Attorney’s Office, Western District of Missouri (October 24, 2019). “Texas Manager Pleads Guilty to Pet Food Fraud, Company Pays $4.5 Million Restitution”. Retrieved from The United States Department of Justice.

November 4, 2019

Q3 Hazard Beat: Meat and Meat Products Trends

By Food Safety Tech Staff

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The following infographic is a snapshot of the hazard trends in meat and meat products from Q3 2019. The information has been pulled from the HorizonScan quarterly report, which summarizes recent global adulteration trends using data gathered from more than 120 reliable sources worldwide. Over the next several weeks, Food Safety Tech will provide readers with hazard trends from various food categories included in this report.

HorizonScan, Meat hazards — 2019 Data from HorizonScan by FeraScience, Ltd.

View last week’s hazards in poultry.

November 1, 2019

President Trump to Nominate Stephen Hahn as Next FDA Commissioner

By Food Safety Tech Staff

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Today The White House issued a statement in which President Trump announced his plan to nominate Stephen Hahn, M.D. to the position of FDA commissioner. Hahn is a radiation and medical oncologist, and currently serves as the chief medical executive at The University of Texas MD Anderson Cancer Center in Houston.

According to The Washington Post, current Acting FDA Commissioner Ned Sharpless will return to his position as director of the National Cancer Institute while HHS official Brett Giroir will step in at FDA until Hahn is confirmed.
The Post reports that Sharpless’ term ends Friday, and it could only be extended if the White House named a successor—however, the White House cannot do so because paperwork has not been completed.

October 31, 2019

Food Fraud Quick Bites

Public Food Standards

By Karen Everstine, Ph.D., Steven M. Gendel, Ph.D.

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In 1995, a honey processing company was indicted on charges of adulterating industrial honey labeled “USDA Grade A” with corn syrup to increase profits. Ultimately, the jury found in favor of the honey processor, in part because there “weren’t enough regulations governing honey to make the charge stick.”

Honey is defined as “the natural sweet substance produced by honey bees” from the nectar of plants. However, there is not currently an FDA standard of identity for honey in the United States, which would further define and specify the allowed methods of producing, manufacturing and labeling honey (there is, however, a nonbinding guidance document for honey). Some of the details of honey production that a standard of identity might address include allowable timing and levels of supplemental feeding of bees with sugar syrups and the appropriate use of antibiotics for disease treatment.

In circumstances where strict regulatory standards for foods are not available, they may be created by other organizations.

What Is a Food Standard?

A food standard is “a set of criteria that a food must meet if it is to be suitable for human consumption, such as source, composition, appearance, freshness, permissible additives, and maximum bacterial content.”¹

To ensure quality, facilitate trade, and reduce fraud, everyone in the supply chain must have a shared expectation of what each food or ingredient should be. Public standards set those expectations and allow them to be shared. They help ensure that stakeholders have a common definition of quality and purity, as well as the test methods and specifications used to demonstrate that quality and purity. Public standards help ensure fair trade, quality and integrity in food supply chains.

How Is a Standard Different from a Method?

A method is generally an analytical technique to assess a particular property of the content or safety of a food or food ingredient. For example, methods for detection of nitrates in meat products or baby food, coliforms in nut products, or high fructose syrups in honey. Methods are an important component of food standards.

A food standard goes a step further and provides an integrated set of components to define a substance and enable verification of that substance. Standards generally include a description of the substance and its function, one or more identification tests and assays (along with acceptance criteria) to appropriately characterize the substance and ensure its quality, a description of possible impurities and limits for those impurities (if applicable), and other information as needed (see Figure 1).

FCC Standard, USP — Figure 1. The Anatomy of an FCC Standard (Source: Food Science Program, Food Chemicals Codex, USP)

Figure 1. The Anatomy of an FCC Standard (Source: Food Science Program, Food Chemicals Codex, USP)

A standard defines both what a food or food ingredient should be and documents how to demonstrate compliance with that definition.

Public Standards and Food Fraud Prevention

Many of the foods prone to fraud are those that are not simple food ingredients, but agricultural products that can be more complex to characterize and identify (such as honey, extra virgin olive oil, spices, etc.). Milk products are an example of a commodity that is prone to fraud with a wide range of adulterants (for example, fluid cow’s milk is associated with 155 adulterants in the Food Fraud Database). Ensuring the quality and purity of a product link milk requires implementation of multiple analytical techniques or the development of non-targeted methods.

The creation of effective public standards with input by a range of stakeholders will be particularly important for ensuring the quality, safety and accurate labeling of these high value commodities in the future.

Reference

A Dictionary of Food and Nutrition 2005, Oxford University Press.

Resources

The Food Chemicals Codex is a source of public standards for foods and food ingredients. It was created by the U.S. FDA and the National Institute of Medicine in 1966 and is currently published by the nonprofit organization USP. The FCC contains 1250 standards for food ingredients, which are developed by expert volunteers and posted for public comment before publication.
The Decernis Food Fraud Database is a continuously updated collection of food fraud records curated specifically to support vulnerability assessments. Information is gathered from global sources and is searchable by ingredient, adulterant, country, and hazard classification. Decernis also partners with standards bodies to provide information about fraudulent adulterants to support standards development.

Alec Senese, Bayer Crop Science, Digital Pest Management

October 31, 2019

Bug Bytes

If You Think Plague Is a Thing of the Past, Think Again

By Alec Senese

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Rodents are vectors of more than 50 pathogens, including plague.1 While plague may be considered a problem of the past, according to the World Health Organization, between 2010 and 2015, there were 3,248 cases of reported plague worldwide and 584 deaths. While it is clearly not the 1300’s when the plague killed millions, the CDC confirms, “plague occurs in rural and semi-rural areas of the western United States, primarily in semi-arid upland forests and grasslands where many types of rodent species can be involved.” While the fact that plague is still lurking is a bit surprising, it should be no surprise that rodents can spread more than 50 diseases. Not the least of these diseases is Salmonella braenderup, the cause of recall of approximately 206,749,248 eggs in 2018. The good news: In the age of IoT, new technology can enable an immediate response to help prevent infestations from growing out of control.

With rodent populations on the rise due to climate change and the resultant public health issues in major cities across the United States, public health officials and pest managers face unimaginable challenges in staying ahead of rapidly growing and spreading rodent infestations. Earlier this year, Los Angeles had a typhus outbreak that resulted from a rat infestation near an encampment for those experiencing homelessness. The unsanitary conditions created a harborage for rats that spread the flea-borne illness. Cases of typhoid have doubled in the area since 2012. When and where will the next pathogen outbreak from rodent activity hit?

If that’s not frightening enough, it is important to highlight that once an infected, flea-carrying rodent enters a facility, eliminating the rodent does not always necessarily mean eliminating the presence of plague pathogens. The World Health Organization explains that once vectors have been introduced through rodents and their fleas, it is not enough to eliminate rodents. Vector control must take place before rodent control because “killing rodents before vectors will cause the fleas to jump to new hosts.”

Controlling the spread of pathogens via rodents is becoming increasingly important, particularly in sensitive environments like food processing and manufacturing facilities. Effective management begins with early and accurate detection and sustained through continuous monitoring. However, the traditional method of manual rodent inspection by its very nature cannot provide facility and pest managers with either early detection or continuous monitoring.

Thanks to IoT, monitoring systems can now be used in a wide variety of rodent monitoring devices inside and outside a facility. The systems transmit messages in real time over wireless networks and provide pest managers, facility management and public health officials with 24/7 visibility of rodent activity in a monitored location, which will enable more timely responses and help improve the effectiveness of mitigation efforts. Digital IoT technologies are rapidly becoming the modern proactive tool used to help predict and control rodent issues before they occur in an age when traditional, reactive methods are insufficient.

Reference

Meerburg, B.G., Singleton, G.R., and Kijlstra, A. (2009). “Rodent-borne Diseases and their Risk for Public Health”. Crit Rev Microbiol.

October 30, 2019

Food Fraud Quick Bites

Comparing Ceylon and Cassia

By Susanne Kuehne

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

Cinnamon is in high demand worldwide, with Ceylon cinnamon or true cinnamon (Cinnamon verum) the most sought-after and higher priced variety. It is therefore tempting to “cut” Ceylon cinnamon with cheaper cassia cinnamon. Previous detection methods for such adulterations included HPLC testing or DNA barcoding, which was time consuming and could only be applied by experts. New FT-NIR (Fourier transform near-infrared) and FTIR (Fourier transform infrared) spectroscopic methods in combination with multivariate analysis enable quick detection of cinnamon adulteration.

Resources

J. Yasmin, M.R. Ahmed, S. Lohumi, C. Wakholi, H. Lee, C. Mo, B.-K. Cho, Corresponding author: chobk@cnu.ac.kr, Quality Assurance and Safety of Crops & Foods: 11 (3)- Pages: 257 – 267 (25 April, 2019). “Rapid authentication measurement of cinnamon powder using FT-NIR and FT-IR spectroscopic techniques”. Retrieved from Wageningen Academic Publishers, wageningenacademic.com

October 29, 2019

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part I)

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 is intended to assist facilities that have not yet conducted vulnerability assessments or wish to review those already conducted, by leveraging lessons learned from assessments conducted for the largest and most complex global food and beverage facilities.

Lesson 1: VA outcomes are greatly enhanced if a physical security professional is consulted. In support of this contention, there are several physical security mitigation strategies, which can be employed to support a food defense program, that are frequently under-utilized and are not optimally managed by non-security staff. Also, the FDA seems to promote the use of cameras even though this equipment is unlikely to prevent an incident of intentional adulteration. For organizations that choose to use video surveillance, a competent security professional can help organizations engineer and operate video surveillance for maximum benefits and to meet challenging record-keeping requirements when this mitigation strategy is included in a food defense plan.

Lesson 2: Given the focus by the FDA on the insider, a formal insider threat detection program is highly recommended. Trying to promote the common, “See Something, Say Something” strategy may not be enough. For example, if employees are not clearly told what to look for in terms of uniform requirements, how to identify persons who do not belong or changes to a coworker’s baseline behavior, which may indicate moving toward a path to violence or sabotage, then “See Something, Say Something” may end up being no more than a catchy slogan.

A key element of an insider threat detection program is the completion of effective background checks for all persons who will be allowed in the facility unescorted. This includes temporary employees and contractors. A common theme in many of the recent, serious intentional adulteration incidents was that the person responsible was involved in some sort of grievance observable to coworkers and supervisors. In all insider threat detection programs, the grievance becomes an important trip wire. The Carnegie Mellon University Software Engineering Institute has published a document titled, “Common Sense Guide to Mitigating Insider Threats, Sixth Edition”. In this document is some particularly helpful guidance that can be used to stand up an insider threat detection program, but this is an effort that can take some time to fully implement.

Lesson 3: The FDA has made it abundantly clear that they believe the focus for the food and beverage industry should be the radicalized insider. A closer look at all the recently publicized contamination events suggests that there are other profiles that need to be considered. A good foundational model for building profiles of potential offenders can be found in the OSHA definitions for workplace violence offenders, which has been expanded to address ideologically based attacks. Table I applies those descriptions to the food and beverage industry, with an asterisk placed by those offender profiles that exist in recent incidents and discussed later in the text.

Class	OSHA Workplace Violence Offender Description	Motivation Translated to the Food and Beverage Industry
1	The offender has no legitimate relationship to the business or its employee(s). Rather, the violence is incidental to another crime, such as robbery, shoplifting, trespassing or seeking social media fame.	Behavioral Health Patient * Social Media Fame Seeker * Copycat * Extortion * Economic motivation *
2	The violent person has a legitimate relationship with the business—for example, the person is a customer, client, patient, student, or inmate—and becomes violent while being served by the business, violence falls into this category.	My load isn’t ready, you are costing me money
3	The offender of this type of violence could be a current employee or past employee of the organization who attacks or threatens other employee(s) in the workplace.	I am upset with a coworker and adulterate to create problems for that person * I am upset with the company and adulterate as retribution and to harm the brand * Youthful stupidity I am not paid enough *
4	The offender may or may not have a relationship with the business but has a personal (or perceived personal) relationship with the victim.	I am upset with an intimate partner/ coworker and adulterate to create problems for that person
5	Ideological workplace violence is directed at an organization, its people, and/or property for ideological, religious or political reasons. The violence is perpetrated by extremists and value-driven groups justified by their beliefs.	Radicalized Insider
Table I. A description of OSHA workplace violence offenders and how it can be applied to the F&B industry.

A supermarket in Michigan recalled 1,700 lbs. of ground beef after 111 people fell ill with nicotine poisoning. The offender, an employee, mixed insecticide into the meat to get his supervisor in trouble. In Australia, the entire strawberry industry was brought to its knees after a disgruntled supervisor “spiked” strawberries with needles. There were more than 230 copycat incidents impacting many companies. A contract employee in Japan, apparently disgruntled over his low pay, sprayed pesticide on a frozen food processing line resulting in illnesses to more than 2,000 people. A contract worker upset with a union dispute with the company at a food manufacturing plant videoed himself urinating on the production line, then uploaded the video to the Internet. Be cognizant of any grievances in the workplace and increase monitoring or take other proactive steps to reduce the risk of intentional adulteration.

Lesson 4: The IA Rule requires that every point, step and procedure be analyzed to determine if it is an actionable process step (APS). The Hazard Analysis Critical Control Point flow charts are a good starting point to comply with this element of the law but cannot be counted on completely to achieve the standard of analyzing every point, step or procedure. Critical thinking and persons familiar with the production process need to be involved to ensure that no steps are missed. Oftentimes companies modify the HACCP flow diagrams after a VA.

Lesson 5: The FDA states in the second installment of guidance (here’s the full copy) to the industry that, “There are many possible approaches to conducting a VA. You may choose an approach based on considerations such as the time and resources available and the level of specificity desired. You have the flexibility to choose any VA approach, as long as your VA contains each required component (21 CFR 121.130).”

The FDA further states that the Key Activity Type, or KAT method, is an appropriate method for conducting a VA because it reflects consideration of the three required elements and the inside attacker. Using this methodology alone, however, can result in substantially more APS’s, which might otherwise be ruled out for practical purposes such as a lack of accessibility or a lack of feasibility to contaminate the product at a point, step or procedure. We have experienced up to a 90% decline in APS’s by utilizing another FDA recommended assessment approach, the hybrid approach, which assesses each point, step or procedure as first whether it is a KAT. Then to qualify as an APS, it must also trigger positively for public health impact, accessibility and feasibility to contaminate the product.

Organizations who have yet to execute vulnerability assessments (due July 26, 2020) or who may wish to reflect back on their existing VA’s in an effort to eliminate unnecessary APS’s should find these strategies helpful to focus limited resources to the areas where they can have the greatest effect. The next two articles in this series will cover more information on electronic access, the value of site tours, comparisons to drinking water security strategies, dealing with multi-site assessments and more. Read Part II of this series on intentional adulteration.

October 28, 2019

Q3 Hazard Beat: Poultry and Poultry Products Trends

By Food Safety Tech Staff

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The following infographic is a snapshot of the hazard trends in poultry and poultry products from Q3 2019. The information has been pulled from the HorizonScan quarterly report, which summarizes recent global adulteration trends using data gathered from more than 120 reliable sources worldwide. Over the next several weeks, Food Safety Tech will provide readers with hazard trends from various food categories included in this report.

New Technologies Hold Huge Potential for F&B Supply Chains

How to Achieve End-to-End Traceability

Resources

What Is a Food Standard?

How Is a Standard Different from a Method?

Public Standards and Food Fraud Prevention

Reference

Resources

Reference

Resources

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