Tag Archives: Focus Article

Laura Nelson, Alchemy

Changing Consumer Preferences and Employee Compliance Training Driving Industry Evolution

By Maria Fontanazza
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Laura Nelson, Alchemy

The food industry is undergoing considerable change, especially as consumers become increasingly more vocal about their preferences and concerns, and as technology improvement and adoption plays a larger role in the conversation. In a recent Q&A with Food Safety Tech, Laura Dunn Nelson, vice president of food safety at Alchemy, shares her thoughts about current industry trends and how they are impacting food companies, where more help is needed, as well as ways in which companies can help advance food safety culture internally.

Food Safety Tech: The food industry is rapidly evolving. What are some of the trends you’re seeing and are these posing different challenges to food manufacturers?

Laura Dunn Nelson: The food industry is rapidly evolving in three key areas: Who produces our food, the variety of our food, and how consumers access our food.

As consumers continue to shift their food preferences toward an increase in healthy ingredients, locally sourced products, and clean labels, companies in turn continue to innovate and reformulate. Mergers and acquisitions continue as larger companies look to partner with niche companies that are focused on products marketed to the health-conscious consumer. Companies like Impossible Foods and Beyond Meat are expanding rapidly, reaching both vegans and meat eaters in the United States and expanding into international markets. Ever-changing consumer preferences create challenges for the industry to accelerate their research and development processes in order to remain competitive in the marketplace.

Changes in product formulas and increases in product lines create the need for new ingredient procurement, changes in production schedules, and new operating procedures. There has been a proliferation of start-up companies using CBD as an ingredient for food and beverages despite the lagging food safety regulations forcing some city and state regulators like New York City to create their own ban of CBD products. As the FDA explores future regulations, producers and consumers are left to determine the safety of these products.

Home delivery of food continues to be a hot trend as the market continues to grow for companies like UberEats, Grubhub, retailers and foodservice companies like Domino’s Pizza where you can Tweet your pizza order. The home delivery service area presents new considerations for food safety including monitoring appropriate product temperatures.

Finally, discussion around blockchain technology continues to gain prominence as companies work to develop transparency within their supply chain. For many companies, this will translate into a significant shift in technology adoption and a move away from disparate data sources and therefore an investment in not only the technology but in revising their procurement processes.

Laura Nelson, Alchemy
Laura Nelson is vice president of food safety at Alchemy and currently serves as the vice-chair of the Food Safety Culture Professional Development Group (PDG) for IAFP.

FST: What are the areas in which you feel companies need a bit more guidance?

Nelson: How we effectively train our employees to ensure learning and comprehension is paramount to our success in the future. IBM Institute for Business Value recently completed their study “The Enterprise Guide to Closing the Skills Gap,” and noted “120 million workers in the world’s biggest economies may need to be retrained as a result of artificial intelligence (AI) and automation in the workplace.” Reskilling will be the new norm as new technologies and automation of equipment disrupt the current state.

Deloitte noted that “reinventing the way people learn” was the number one trend in the 2019 Global Human Capital Trends Report. Many companies are focused almost exclusively on mandatory compliance training and conducting the training the same way they have for years. Typically, orientation food safety training is provided during the employee’s first week of work and annual refreshers are given every year. In the Global Food Safety Training Survey that Alchemy provides to the global industry with Campden BRI, we consistently find that 67% of responding QA managers report that employees do not follow their food safety programs, despite their food safety training. Unfortunately, the emphasis on food safety is often relegated to that one day a year of refresher training with little reinforcement the remaining 364 days of the year. The ‘noise’ of competing priorities of production and customer expectations often distracts employees from their food safety responsibilities.

Some companies still define training as classroom training when, in fact, employees are being trained each and every day by their supervisors and peers. Companies that put additional emphasis in not only their training but validation of training through observations of employees’ food safety behaviors achieve higher food safety compliance. The power of two-way conversations between the employee and the supervisor as a coach creates an environment of communication and trust.

Alchemy worked with independent researchers to determine the effect of active coaching with prescribed behavior feedback on the plant floor. The results were conclusive: every facility included in the study revealed a 38% improvement in aligned employee behaviors.

Ultimately, companies need to evaluate their current learning organization for effectiveness and focus on job competencies and their ongoing assessment of compliant employee behaviors.

FST: What maturity level are you seeing in the industry related to food safety culture and the related implementation of best practices?

Nelson: The food industry is still relatively new to the concept of a mature food safety culture, and even how to define that. The industry focus of this topic has largely been driven by efforts within the GFSI community, particularly with the publication of the position paper “A Culture of Food Safety.” Pioneers in food safety culture research, like Dr. Lone Jespersen, and emerging training assessment tools are working toward pushing these newer concepts to the mainstream of our industry.

As with many important constructs, the QA/QC team is typically tasked with introducing this concept to their organization, defining their company’s level of food safety culture maturity, and establishing a continuous improvement plan. This is a tough ask from individuals who typically have a technical education background with little experience in behavioral science. To address these challenges, there are a growing number of consultants, books, and resources to help define a company’s food safety culture maturity and establish improvement strategies.

To help frame the benefits of a mature culture, a recent publication by Lone Jespersen et al, “The Impact of Maturing Food Safety Culture and a Pathway to Economic Gain,” notes the value of a mature food safety culture in reducing the cost of poor quality and food safety risks. Research indicates that many companies are currently in mid-maturity of their food safety culture. Suggested best practices to help an organization mature their food safety culture include:

  1. Foster cross-company ownership of food safety.
  2. Move from compliance driven operations to risk reduction through continuous improvement.
  3. Improve engagement skills of technical staff.

The first step is an assessment to understand the company’s unique performance gaps, either through an internal review or an external assessment. Once the specific gaps are identified, companies can develop their food safety culture improvement plan and execute. It’s helpful to conduct a reassessment over time to ensure the established improvement strategies are successful.

The effort can be challenging but research confirms that a more mature food safety culture will deliver improved food safety performance of food safety behaviors, improved product quality, and a reduction in food safety risks.

Craig Powell, Natura Life ≠ Science
FST Soapbox

Standardization of the Cannabis Supply Chain Drives Product Safety and Consumer Trust

By Craig Powell
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Craig Powell, Natura Life ≠ Science

When it comes to mainstream consumer food brands, customers expect to receive the same product each time they buy it. That consistency brings consumers back to the same brands over and over again. Unfortunately, the same can’t be said about products sold in the cannabis industry. Consumers aren’t building long-term relationships with brands because consumers don’t have consistent product experiences and often take their business to other brands.

This inconsistency plaguing the cannabis industry can be attributed to an unreliable supply chain, which plays out in multiple ways.

First, cannabis companies are having difficulty meeting state regulations. This happens because the legal cannabis industry is still relatively young and there isn’t a substantial institutional knowledge about regulatory compliance, nor are there any standardized best practices in place. Regulation is expensive and requires human and financial capital that most cannabis companies don’t have in place. Complicating things further, regulations keep changing, making it more difficult for compliant businesses to keep up, even when they have the best intentions.

Second, testing of cannabis products has been complicated. Because cannabis isn’t federally legal, standardized testing guidelines have not been developed, leaving individual states in charge of dictating their own requirements and enforcement framework. There have been numerous reports in the past few years of labs in California either improperly reporting testing results, or worse, submitting fraudulent results.

Third, problems also arise on production end of the supply chain—not only with consistency, but also with consumer safety. According to an estimate from New Frontier Data, approximately 80% of sales are still conducted through the black market. Many growers are using banned pesticides in amounts way beyond recommended levels. In addition, as the recent vape issue has demonstrated, black market manufactured products are being adulterated with toxic substances that pose significant health hazards to consumers.

Given these consistency challenges, the standardization of the supply chain—especially compliance, testing and safety measures—should be a top priority for new cannabis brands. Luckily, many best practices and standardized procedures can be adopted from the food, agriculture and pharmaceutical industries, where companies have successfully developed protocols to ensure safe and reliable products.

In addition to standardization and best practices, cannabis companies should also utilize the following recent innovations in transaction technology to provide peace-of-mind to both new brands and consumers that cannabis products are tested and safe.

Modernized Retail POS systems. Common in other consumer packaged goods industries, such as food, wine, beverages and soft drinks, RFID tags can be used throughout the supply chain to track products from seed to sale. These tags, like the “chips” on credit cards, hold electronically stored information about a product that can be accessed to verify compliance and safety.

QR Codes. While QR codes are mostly used today as marketing gimmicks, they actually have potential to provide true value for curious customers. Batch-specific QR codes could be applied to cannabis products to show detailed information about when and where it was made, what strains of cannabis were used, and testing results. This technology could be used to increase transparency between companies and to consumers.

Data Informatics. A strong information technology infrastructure can be put in place to collect and store inventory and customer data. That data can then be run through algorithms, AI and machine learning systems to help cannabis brands make better decisions about how to optimize the production of their products and how to achieve better results on future batches.

Video Surveillance. Granted, this is a more ‘low-tech’ approach, but effective, nonetheless. Video cameras can go way beyond security purposes. Footage can be viewed and compared to collected data sets to gain a deeper understanding of product flows, personnel movement and logistics that might impact a company’s final product. Video can also be analyzed automatically using AI to provide important insight to help a company fine tune their business strategies.

Consumers want to know that the cannabis products they purchase are safe, compliant and tested. Consumers also have a right to know what they are buying and expect product consistency over time from companies they trust. Ensuring supply chain consistency is key to making this happen as the industry matures. An experienced and trusted supply chain partner can help companies across different cannabis sectors, ranging from medical to food, and ensure product safety and consumer trust today through standardization and consistency. Ultimately, cannabis businesses want to cultivate a culture of excitement, not fear or uncertainty, to help the market flourish and bring quality products to our customers.

Susanne Kuehne, Decernis
Food Fraud Quick Bites

Not in Good Spirits

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

Fake brandy based on corn distillate was purchased by a Spanish company based in Georgia and was exported to other EU countries with falsified documentation. Fortunately, this alcohol fraud did not pose a health hazard like many other alcohol fraud cases. However, the economic gain for the fraudulent brandy was going to be huge, since a volume of 4 million liters of “brandy” was exported. EU regulations state that brandy is supposed to be based on wine distillate only, which costs up to four times more than distillate made from corn.

Resources

  1. Herraiz, P. El Mundo (September 16, 2019). “La trama del brandy español falsificado exportó cuatro millones de litros ilegalmente”.
Megan Nichols
FST Soapbox

Tips to Train Employees and Maintain FSMA Compliance

By Megan Ray Nichols
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Megan Nichols

Eight years ago, the government passed FSMA. As a manufacturer, training new and existing employees to remain compliant with legislation is paramount. The goal isn’t to make life harder for business owners—it’s to protect American consumers from unsafe food handling and transportation practices.

The following are five tips to help warehouse managers train employees while maintaining FSMA compliance.

Understand FSMA Final Rules

It’s essential for everyone in the facility, from the CEO to the newest hire, to understand the FSMA rules. According to current Good Manufacturing Practices (cGMP), everyone who works in manufacturing, processing or packaging of food is required to train in food hygiene and safety. Managers can offer training in one of two ways—through on the job experience or via an FSMA-accredited classroom curriculum.

For individuals with specialized jobs, such as quality auditors or preventative controls qualified individuals (PCQI), the training option that allows compliance with FSMA rules is an accredited curriculum.

Utilize Warehouse Management Systems

FSMA gives the FDA authority to issue mandatory recalls for any food products if deemed necessary. To meet FSMA standards, record keeping and lot tracking is a necessity. If a product type is linked to a disease outbreak, the FDA wants to know where each product in that lot is within 24 hours. Having the ability to track and trace 100% of the products ensures that the company is FSMA compliant.

A warehouse management system (WMS) can track products, but only if you train employees in its use. While the average employee won’t be responsible for tracing a production lot in the event of a recall, each worker needs to know how to enter data into the system correctly, and how to retrieve the information if necessary. Include training in your WMS to ensure compliance.

Warehouse management systems, when paired with IoT sensors, can prevent recalls and ensure compliance by monitoring temperature fluctuations in climate-controlled areas. According to the Department of Agriculture, frozen food stored at temperatures at or below -0.4° F is always safe. A comprehensive WMS can monitor the temperature inside a facility’s freezers and alert workers or management if there are dramatic fluctuations that may result in a recall.

Seek Out Alliances

Warehouse managers are not alone when it comes to creating a compliant workplace. The FDA has established and funded three alliances—Produce Safety, Food Safety Preventative Controls, and Sprout Safety—each with their own standardized curriculum designed to help those who fall under FSMA rules.These alliances work for the majority of those in the food production industry, though they may not work for everyone.

Seek out the applicable food safety alliance and see if their training curriculums apply to your facility. Even if they don’t fit directly, these alliances can give managers an excellent place to start creating their training curriculum.

Create a Culture of Compliance

FSMA isn’t designed to make life harder for warehouse managers. Its goal is to keep people safe when buying their weekly groceries. Don’t just focus on training to meet FSMA standards. Instead, create a culture of compliance throughout the facility. Make FSMA everyone’s responsibility, and make it easier for employees to communicate with management if they notice a problem that normal channels don’t address.

As part of this culture of compliance, create incentives that reward employees for reporting problems, maintaining compliance levels and completing accredited training. Sometimes incentives can be the best way to motivate employees, whether you’re offering money, paid vacation or other benefits. Walk employees through the process of how to spot a problem and report it to management.

Continue Education Throughout Employment

FSMA compliance training isn’t something you should restrict to an employee’s onboarding. It’s something you should continue throughout their time at your facility. Make FSMA education a priority for every worker in your facility. While you want to start their training with onboarding, it shouldn’t stop there. Offer new training courses once a month or every three months—as often as you’d like without compromising productivity.

As the day-to-day grind continues, most workers forget about rules and regulations. Continuing education ensures FSMA compliance is at the forefront of everyone’s mind throughout their careers. Continuing your employee’s education is also shown to increase loyalty and reduce turnover, keeping things running smoothly and preventing warehouse managers from training new workers every quarter.

Looking Forward

The FDA oversees food safety and can issue a recall when a problem occurs. Yes, as a whole, it’s the responsibility of every single person working in the food production industry—from the highest-paid CEO to the newest employee on the production floor—to maintain compliance. It’s not enough to review guidelines with new employees during onboarding.

Training is essential to ensure everyone in a facility maintains the rules laid down by FSMA. Seek out assistance in the form of the FDA-funded alliances, continue employee education and make it a point to create a culture of compliance from the moment employees walk through the door. Offer continuous training opportunities and you’ll never have to worry about breaking FSMA rules.

Jeremy Schneider, Controlant

Using Technology for Traceability Adds Dimension to Supply Chain, Promises ROI

By Maria Fontanazza
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Jeremy Schneider, Controlant

“As food safety leaders, it is our responsibility to actively investigate the newest technologies in the market with the goal of providing the highest level of safety for our customers. The regulatory environment is rapidly evolving from a position of hazard management to preventative control, which challenges the status quo while promoting innovation. In addition, we are actively working to build food safety cultures within our operations,” says Jeremy Schneider, business development director, food safety and quality assurance at Controlant. “On top of these mandates, we are consistently being challenged to find ways to improve quality, reduce waste, and assure supply. When taken as a collective mandate, this can be considered a challenge that allows the industry to solve previously unsolvable business problems in new and exciting ways. Utilizing the newest technologies for enhanced supply chain visibility is the solution to some of our most challenging industry-wide problems.”

Schneider has more than 15 years of experience in the food quality, safety, and regulatory sector. His experience spans managing food safety and quality systems within several fast-casual restaurant chains as well as food manufacturing. In a Q&A with Food Safety Tech, Schneider discusses some of the issues that food companies are experiencing surrounding traceability in their supply chain.

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

Food Safety Tech: What challenges are food companies and retailers facing when it comes to real-time monitoring of their supply chain?

Jeremy Schneider: One of the biggest challenges that the industry faces when it comes to real-time monitoring of the supply chain is where to start. As you can imagine, implementing a program that allows for an organization to monitor all shipments, including those that are shipped internationally, by ship, air freight, over the road or by rail, can be daunting.

As with all food safety programs, it is advised to take a risk-based approach to the project. Begin with the highest-risk items within your supply chain and work to your second- and third-tier items or suppliers. When implemented by category over time, you will find implementation less challenging. It is important to remember that when you begin a real-time program, you will start to discover eye-opening information about your supply chain. It’s important that you develop strategies to deal effectively with these incidents.

Another primary concern for the food industry is the cost of implementation, as well as the return on investment. We have found that, by implementing a real-time monitoring solution, an organization is able to dramatically reduce shipping loss because of temperature abuse. Oftentimes, the program provides a net savings for the organization. When considering the cost of wasted food, freight, liability, lost sales and labor, a real-time supply chain visibility solution becomes a cost-effective program very quickly.

FST: Are there any lessons learned from recent outbreaks or recalls regarding traceability?

Schneider: Over the last several years, the industry has made real progress towards a transparent supply chain. However, it must be said that much work is needed to meet regulatory standards and consumer expectations when it comes to traceability. As we have become accustomed to having information that provides insights into all facets of our life, the same is becoming true of the supply chain.

Being able to have business-critical data immediately, such as real-time supply chain and traceability data, is revolutionizing the industry and is allowing enterprise-wide improvements. During a crisis situation, being able to have insights into your supply chain is paramount. Unfortunately, it has become all too common for organizations to take the ‘’out of an abundance of caution’’ approach and remove all products from the supply chain, regardless of lot code or other data, to ensure consumer safety.

The consequence of such an approach is that much more product is removed than necessary, which compounds the effects of the incident. Having had the appropriate traceability information allows organizations to take a precision-focused approach, allowing for organizations to minimize the impact as much as is safely possible.

To help organizations solve this dilemma, there are a variety of technology offerings available to help companies collect and transform data so that it can be easily used. In addition, layering rich data, such as that which is created from real-time Internet-of-Things (IoT) devices and cloud-enabled software technology, helps provide dimensional insights into your supply chain information.

FST: How can companies leverage technology to be proactive in maintaining consistent tracking and tracing throughout the supply chain?

Schneider: As we enter an era of smarter food safety, each organization will be challenged to solve some of the most pressing concerns using state-of-the-art technology. The great thing about having actionable traceability data, beyond its uses to support food safety, is that it allows an organization the ability to gain insights into their supply chain at both the micro- and macro-levels.

As an example, when an organization implements a real-time temperature monitoring program, not only are they able to identify and resolve temperature deviations before they become food safety or quality incidents, logistics can then utilize the data to optimize the shipping lane to reduce costs, and purchasing is able to know exactly where a truck is located on its route. Being able to show the value that location traceability data provides across an enterprise helps to improve the organization at every level.

2019 Food Safety Consortium, Glenn Black, CFSAN, FDA

Say What? Perspectives We Heard at the 2019 Food Safety Consortium

By Maria Fontanazza
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2019 Food Safety Consortium, Glenn Black, CFSAN, FDA

Last week’s seventh annual Food Safety Consortium brought together a variety of industry experts to discuss key topics around regulation, compliance, leadership, testing, foodborne illness, food defense and more. The following are just a few sound bytes from what we heard at the event. (Click on any photo to enlarge)

Food Safety Consortium, Frank Yiannas, FDA “The food system today, while it’s still impressive, it still has one Achilles heel—lack of traceability and transparency.” – Frank Yiannas, deputy commissioner for food policy & response, FDA. Read the full article on Yiannas’ keynote session

“A typical food company only has about 5% visibility into known supply chain threats.” – Ron Stakland, senior business development, FoodChain ID, Inc.

“For most of us, our supply chain is a big black hole. Why are we so fearful of technology? Is it the implementation itself? What if technology could help us solve some of those perennial problems? There are resources available to help us get there.” – ¬ Jeremy Schneider, business development director, food safety and quality assurance, Controlant

“The records tell the story of how well the facility is being managed. It’s the first thing the regulators are going to look at.” – Glenn Black, Ph.D., associate director for research, CFSAN, FDA, on validation considerations and regulations for processing technologies in the food industry 2019 Food Safety Consortium, Glenn Black, CFSAN, FDA

“We’ll see more robotics enter the food space.” – Gina Nicholson Kramer, executive director, Savour Food Safety International

Melody Ge, Corvium, 2019 Food Safety Consortium “Changes are happening; you can choose to face it or ignore it. We’re at least 10 years behind on technology. Automation/technology is not a new term in aerospace, etc., but to us [the food industry], it is. We will get there.” – Melody Ge, head of compliance, Corvium, Inc., on how industry should prepare for the data-driven transformation occurring in the smarter era of food safety

It’s okay to risk and fail, but how are going to remediate that with your employee? The more learners practice in different scenarios, the less they rely on specific examples. [They] become more adept with dealing with decision making.” – Kathryn Birmingham, Ph.D., VP for research and development, ImEpik, on employee training

“As a contract lab with the vision of testing for foodborne viruses for about 10 years—it wasn’t until about three or four years ago that we had the test kits to turn that into a reality. We also didn’t have a reference method.” – Erin Crowley, chief scientific officer, Q Laboratories, on the viral landscape of testing in the food industry

“You have to be strong and you have to believe in yourself before you get into any situation—especially as a food safety professional.” – Al Baroudi, Ph.D., vice president of quality assurance and food safety at The Cheesecake Factory, on what it takes to earn respect as a food safety professional Jorge Hernandez, Al Baroudi, Ph.D., 2019 Food Safety Consortium

“’See something, say something’ is likely not enough. We recommend that companies develop a formal detection program that includes management buy-in, HR and governance, and policy documents, formal training and an awareness program…While FDA focuses on the insider threat, we feel that using a broader mitigation approach works best.” – R. Spencer Lane, senior security advisor, Business Protection Specialists, Inc. on lessons learned from food defense intentional adulteration vulnerability assessments

“Food safety is a profession, a vocation, [and] a way of life.” – Bob Pudlock, president of Gulf Stream Search

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

Food Safety Professionals: Earn Respect and Be True to Yourself

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

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

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

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

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

On Earning Respect

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

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

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

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

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

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

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

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

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

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

Susanne Kuehne, Decernis
Food Fraud Quick Bites

A Broken Record

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

Over the course of almost a full year, laboratory documents were falsified by the owner and the quality control officer of a Connecticut meat processing company. None of the reported beef samples were actually taken and tested for E. coli. The letterhead of a formerly utilized inspection laboratory was fraudulently used to falsify the test documents, an act that carries a maximum term of five years in prison. Fortunately, no illness was reported from consumers who purchased the meat products.

Resources

  1. The United States Attorney’s Office (September 23, 2019). “Quality Control Officer of Connecticut Meat Supplier Admits Fabricating E. Coli Test Results”. Department of Justice, U.S. Attorney’s Office, District of Connecticut.
Brett Madden, Aviaway
Bug Bytes

Bird Problems and Control Methods for Food Production Facilities

By R. Brett Madden
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Brett Madden, Aviaway

Various types of pest birds can impact food plant structures and facility surroundings. Even a single bird that finds its way into a food plant can trigger a host of concerns such as, failed audits, product contamination, plant closure, production stoppage, lost revenues, fines, structural damage, health hazards to occupants and fire hazards.

In most cases, a food plant operation has a bulletproof pest control plan; however, in most cases, birds are always an afterthought in most pest management plans. After inspecting and consulting numerous food plants, I hear the same story over and over: “I have a person in the warehouse that can chase them out” or, “are birds really a big deal?” or, “why do I have to be concerned about birds?” and on and on. Despite what you may think, birds are a big deal, and you should take them seriously!

Pest management, pigeon droppings HVAC
Larger birds, such as pigeons, can cause more problems around the exterior of a facility on HVAC units as seen here. (Image courtesy of Aviaway Bird Control Services & Consulting)

Since food processing plants contain areas that have very sensitive environments, birds can introduce various adulterants and harmful contaminants. Birds can cause potential harm to humans due to foodborne illness.

Pest Bird Species

There are four main pest birds: Pigeon, Starling, Sparrow and Seagull. Each one of these birds can cause a host of concerns and issues for food processing facilities. Just one bird can cause catastrophic damage. In most cases, small pest birds such as Sparrows and Starlings can gain access into a facility through a variety of ways:

  • Damaged bumpers around truck bay loading dock doors.
  • Open doors (seems obvious, but I always find doors wide open during audits).
  • General building deficiencies.

Larger birds, such as Pigeons and Seagulls, typically cause more problems around the exterior of a facility on ledges, rooftops, HVAC units, loading docks and related areas.

In either case, these various types of pest birds can cause significant problems on the interior and exterior of food plants.

Conducive Conditions

In most cases, facilities want to reduce as many conducive conditions as they can around and within the facility in a timely fashion. A conducive condition is one whereby due to a building condition, structural design, equipment operation, food or water source, or surrounding conditions (i.e., near a public landfill, raw materials mill or body of water) can attract pest birds to a facility. With each of these conditions, great care must be taken to reduce as many conducive conditions as possible.

Examples of Conducive Conditions

Structural Conditions

  • Loading docks/canopies with open beams and rafters
  • HVAC equipment
  • Pooling water (roof and landscaping)
  • Structural overhangs and ledges
  • Open access points
  • Landscaping (types of plantings)
  • Damaged truck bay bumpers
  • Gaps and opening around the structure
  • Doors with improper sealing

Human Conditions

  • Open dumpsters
  • Overflowing dumpsters
  • Dirty dumpsters
  • Product spillage
  • Employees feeding birds
  • Doors left open

All these conducive conditions, if left unresolved, can lead to significant bird problems. Reducing as many conducive conditions as possible will be the first step of any bird management program.

Bird Control Methods

From the start, your facility should have a bird management plan of action. For the most part, bird problems should not be left to be handled internally, unless your staff has been properly trained and has a bird management plan in place.
Most birds are protected by the Federal Migratory Bird Treaty Act of 1918. However, Pigeons, Sparrows, and Starlings are considered non-migratory birds and are not protected under this Act. Even though these three bird species are not protected, control methods still need to be humane. More specifically, your bird control program must also comply with is the American Veterinary Medical Association (“AVMA”) Guidelines for the Euthanasia of Animals if this is the control method selected. The AVMA considers the House Sparrows, Feral Pigeon, and the Common Starling “Free-Ranging Wildlife.” And Free-Ranging Wildlife may only be humanely euthanized by specifically proscribed methodology.

In addition to the above-mentioned regulations, various regulations regarding the relocation of birds/nests may also apply. I also always recommend checking with local and state agencies to ensure that there are no local regulations that may apply. Bottom line: Don’t rely on untrained internal practices; one misstep could result in heavy financial fines and penalties.

Bird Management Strategies

First Line Defense

  • Stop any bird feeding around the facility immediately
    • Any bird management plan should have a clear policy prohibiting employees from feeding birds. Once birds have been accustomed to routine feeding, the birds will continue to return.
  • Eliminate Standing Water Sources
    • All standing or pooled water needs to be eliminated. Thus, routine roof inspections need to be conducted to ensure drains are working properly.
    • Landscape irrigation needs to be calibrated to ensure no puddling of water in areas of low sun exposure.
  • Proper Sanitation Practices
    • Ensure that dumpster lids are closed when not in use.
    • Trash removal frequency adequate.
    • Routine cleaning of trash receptacles.
    • Immediate removal of spilled food.
  • Eliminate Entry Points
  • Survey the facility to ensure that all holes are properly sealed.
    • Around truck bay bumpers and doors
  • Exhaust vents are properly screened.
  • Windows are closed and have screens when in use.

The most appropriate bird control strategy will be determined based on the severity of the bird pressure. For example, if the bird pressure is high (birds have nested), then in most cases, you will only be able to use bird exclusion methods. Whereas, if the bird pressure is light to moderate (birds have not nested), bird deterrent methods can be used. This is an important distinction. Bird exclusion is physically changing the area to permanently exclude said pest birds. Whereas, bird deterrent devices inhibit birds from landing on treated areas.

Bird Deterrent Methods

After the previously mentioned first-line strategies have been implemented, the next step would be to install bird deterrent products (birds have not nested).

  • Bird Spikes
  • Bird Wire
  • Electrified Shock Track
  • Bird Gel
  • Sonic & Ultra Sonic Devices
  • Lasers and Optical Deterrents
  • Hazing & Misting Devices
  • Pyrotechnics
  • Live Capture

Bird Exclusion Methods

If the birds have nested in or around the facility, the next step would be to install bird exclusion products (birds have nested).

  • Bird Netting
  • Ledge Exclusion (AviAngle)
  • Architectural modifying structural
  • Aggressive Harvesting (Targeting)

Prevention Strategies

The best prevention strategy is planning and knowledge. Conduct a bird audit and develop a bird management plan before birds get near or inside the facility. The key is to act quickly, as soon as an incident occurs. I find countless times when I am called in to consult or service a food plant, that the birds got into the facility and no one knew what to do, and as a result, the birds remained within the facility for an extended period, thus increasing the risk of exposure. It is always much easier to remove a bird when they are unfamiliar with their surroundings. Whereas, it is much more difficult to remove birds from a facility that has had a long-standing bird problem.

Once you have a plan, who oversees the bird management plan? Are thresholds determined and set for various areas of the facility? For example, a zero threshold in production areas? Threshold levels will be set based upon by location and sensitivity of the said location. What steps are going to be taken to remove the bird? For how long is each step conducted? These questions need to be answered and developed to stay ahead of bird problems.

Reduce as many conducive conditions as possible. The longer a conducive condition stays active, the more likely birds, as well as other wildlife or rodents, will be attracted to the site and find a way into the facility.

Pathogen Contamination & Hazards

Birds present a host of problems, whether they are inside or outside of a facility. Birds can roost by air vents, and the accumulation of bird feces can enter the facility air system. Bird droppings on walkways and related areas allow for the possibility of vectoring of said dropping when employees step on droppings. Thus, spreading fecal matter/spores and other contaminants to areas throughout the facility.

If birds are within the facility, droppings can spread on product lines, raw materials, stored products, equipment and more, thus, causing contamination. Because of a bird’s ability to fly, they are perfect creatures to spread various diseases, pathogens, ectoparasites and fungal materials. Diseases such as Histoplasmosis, Salmonella, Encephalitis, E-coli, Listeria, and more. Birds have been known to transmit more than 60 infectious diseases!

Besides the spread of potentially harmful contaminants throughout the facility, bird droppings and nesting materials can also create a host of additional problems:

  • The acidity in bird droppings can damage building finishes, façade signs, lighting and more.
  • Wet bird droppings can create a slip and fall hazard.
  • Bird nesting materials can create a fire hazard around façade signs, exit signs and light fixtures.
  • Bird nesting and debris can clog roof drains and cause roof leaks from standing water.
  • Introduction of ectoparasites into the facility such as bird mites, lice, fleas, ticks and more.

Conclusion

In summary, taking a proactive approach to bird control is the best practice. Reduce food, water and shelter sources (aka conducive conditions) promptly. Pest management programs need to implement a more in-depth section of the program for bird control. Like integrated pest management, bird control should be based upon an integrated method. Each facility will have its unique challenges. As such, each bird management plan needs to be tailored to the specific site. A well designed and balanced, integrated bird management program will provide long-term and cost-efficient bird control.

The next article in this series takes a closer look at how to prepare an integrated bird management audit program.

Food Safety Consortium, Frank Yiannas, FDA

Industry in Midst of a Revolution, Tech Must Help Advance Food Safety, Says FDA

By Maria Fontanazza
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Food Safety Consortium, Frank Yiannas, FDA

The industry has evolved quite a bit since FSMA was passed eight years ago, and there’s been an overarching recognition that more modern methods to addressing food safety challenges—especially traceability—are essential. “The agency is at the threshold of a sea change in how we’re going to oversee food safety in the nation’s food supply,” said Frank Yiannas, deputy commissioner for food policy & response at FDA at the 2019 Food Safety Consortium. The first driver is the FDA’s new initiative announced earlier this year, coined the “New Era of Smarter Food Safety”. The agency will be looking at how new and emerging technologies can help advance food safety.

“I believe that we’re in the midst of a food revolution,” said Yiannas, pointing to the level of investment in food globally. “Products will be reformulated… new food sources and production approaches will be realized, and the food system will become increasingly digitized.” It will be the job of food safety professionals to adapt to this changing landscape and to ensure that innovation does in fact happen (and safely) in order to feed the growing population.

FDA is taking a new mindset that builds on the success of FSMA but also leverages a people-led, technology enabled method to get there. Just a few days ago the agency launched FDA-TRACK, a new food safety dashboard through which FDA intends to track and measure the performance of the seven FSMA rules—and these measurements will be publicized and available for all stakeholders. Initial available metrics will be tracking outcomes for the FSMA Preventive Controls and the Foreign Supplier Verification Program related to inspections and recalls.

The second driver of this sea change at the FDA involves a shift in its current approach to FSMA and the evolution of the regulation. While the agency continues to educate while it regulates, this past summer FDA took actions that are indicating a shift in its approach to FSMA compliance. On July 30, FDA issued its first warning letter using FSVP authorities to a tahini importer for lack of FSVP compliance. This was followed a month later by actions surrounding the most recent Salmonella outbreak linked to imported papaya. “If you pause and look back, there have been eight outbreaks in eight years,” said Yiannas. The outbreak involved 500 documented cases, 100 hospitalizations and two deaths. “I thought, enough is enough,” he added, and this prompted Acting FDA Commissioner Ned Sharpless, M.D. and Yiannas to issue a statement asking the papaya industry to do more—and urged them to work together to review their practices and make necessary changes to ensure that the papayas they’re offering to the public are safe. The FDA also issued a warning letter to the papaya importer, with the possibility of barring the company for the next five years. “When there’s a public health hazard, FDA will act decisively,” said Yiannas, stating that parity and oversight is important, and domestic and imported food must be safe. “We regulators, we’re going to strike the right balance, and are committed and as passionate as ever in trying to bend the foodborne illness curve.”

Yiannas added that over the next eight years, the trajectory of papaya-related illness will look very different from the last eight years, thanks to the adoption of better technologies—and that’s part of what the FDA’s New Era of Smarter Food Safety is about. “The food system today, while it’s still impressive, it still has one Achilles heel—lack of traceability and transparency,” said Yiannas. There’s a lack of knowledge in where food comes from, where it’s produced, and the fact that many companies simply don’t know as much about their supply chains as they think. With FSMA, Congress anticipated the need to track and trace food, and now the agency is exploring how new technology can enhance tracking and tracing. With regards to tracking foodborne illnesses, the food industry has been in a race between detection and prevention. “We’re getting so good at finding the needle in the haystack, but we can’t find the haystack,” said Yiannas. “We have to provide the same level of investment for technologies for trace backs….we will do that together.”

Food Safety Consortium, Frank Yiannas, FDA
Frank Yiannas, FDA deputy commissioner for food policy & response, addresses the ways that the public and private sector must work together as part of the agency’s initiative, the New Era of Smarter Food Safety during the 2019 Food Safety Consortium (Image Credit: amybcreative)

When looking at implementing smarter tools and approaches for prevention, the industry needs to work together at not just collecting the data but also converting this data into actionable information. Yiannas emphasized that the agency is not chasing the shiny object—new technology will not be a distraction; it will help solve industry problems and address the new issues that arise with the evolving food system (i.e., cell-cultured meat, plant-based meat, etc.). The agency is also holding a public meeting on October 21 to encourage discussion between the public and private sector, all surrounding this new initiative on smarter food safety.

“What’s become clear to me is [that] there’s so much we an do working together—the public and private sector… Think. Think about how you can do your work differently,” said Yiannas. “We’re all working for the same boss, the consumer. [We have the] same mission and they’re counting on us.”