Tag Archives: Focus Article

Judy Black, Rentokil
Bug Bytes

Impact of Climate Change on Pest Populations

By Judy Black
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Judy Black, Rentokil

As the effects of climate change continue to set in around the world, several threats to our daily lives and the way we do business have emerged in its wake. While impacts such as extreme weather events, regional droughts and rising sea levels frequently draw the most attention, there is another important and potentially devastating consequence to consider. As many pests are more prevalent in warmer climates, rising global temperatures exacerbate the risk they pose to both public health and food production.

A warmer overall climate accelerates insect population growth in a number of ways. Warmer global temperatures expand the habitats that support many types of insects. This is causing bug populations to spread poleward, both further north and further south than they’ve appeared historically. Longer summers allow insect populations to breed for a larger portion of year, allowing them to add more generations and multiply in greater numbers during each seasonal cycle. Higher temperatures also increase survival rates among these pests, as the natural predators that limit their numbers in their native habitat lag behind when they spread to a new habitat, allowing the population to grow without nature’s built-in safeguards on population growth. One example of a pest that has benefited from rising temperatures is the Asian Tiger Mosquito, which mainly affects humans by spreading diseases such as dengue virus, but can also harbor diseases affecting livestock that are part of the food supply chain. Although this pest is native to Southeast Asia, it is rapidly spreading throughout the world and is now found throughout the Asian continent, Australia, Europe, South America, parts of Africa and in North America, where they’re now present in 32 U.S. states.

The rising threat of pests accompanying climate change impacts the global food supply in some very direct ways. Some insects increase in size in warmer temperatures, and larger insects eat more food. This means that, in addition to existing in greater numbers, insect populations can have a more devastating effect on the crops they consume. In addition to the greater threat of insect pests, rodents multiply in greater numbers during warmer weather, posing a larger threat to both crops in the field and stored products in manufacturing and shipping facilities throughout the supply chain.

There are numerous examples of how these pests are negatively impacting crops, including the coffee berry borer, which is native to Africa but has spread to virtually every coffee-growing region in the world, including Hawaii, and now causes more than $500 million in damages to coffee plants each year. This beetle becomes 8.5% more infectious for every 1.8o F increase in temperature, meaning this problem will only get worse as the climate warms. The kudzu bug is a major problem for farmers throughout the Southeastern United States, where it feeds on soybeans and other legumes. The kudzu bug impacts soybean yield in a way resembles the stress placed on crops during a drought. This pest is suspected to originate in Asia, but it’s been on the rise in the United States since 2009, causing insecticide use on soybean crops to quadruple over the 10-year period from 2004–2014.

As climate change drives global temperatures higher and higher, its impact on pest populations means greater risks for both public health and industries that make up the global food supply chain. It also means a greater need for companies in these industries to know the specific risks pests pose to their products and to work closely with a pest management partner to develop a plan for mitigating those risks, identifying potential problems before they escalate and treating any outbreak quickly and effectively, before it can cause a major loss of product and impact the company’s bottom line.

Food Fraud

Food Fraud Requires Companies to Think Like a Criminal

By Juliani Kitakawa, Veronica Ramos
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Food Fraud

In a two-question format, the authors discuss pressing issues in food fraud.

1. Where are the current hot spots for food fraud?

Food fraud activities have been known for centuries. For example, in ancient Rome and Athens, there were rules regarding the adulteration of wines with flavors and colors. In mid-13th century England, there were guidelines prescribing a certain size and weight for each type of bread, as well as required ingredients and how much it should cost. In the United States, back in 1906, Congress passed both the Meat Inspection Act and the original Food and Drugs Act, prohibiting the manufacture and interstate shipment of adulterated and misbranded foods and drugs. However, evidence and records of actions taken over those events were not officially collected.

It was not until 1985, when the presence of diethylene glycol (DEG) was identified in white wines from Austria, that authorities, retailers and consumers started to have serious concerns about the adulteration of food and the severity of its impact on consumers. In addition, there was increased interest to regulate, investigate and apply efforts to enforce requirements.

Other examples include the following:

  • 2005: Chili powder adulterated with Sudan (India)
  • 2008: Dairy products adulterated with melamine (China)
  • 2013: Beef substituted with horsemeat (UK)
  • 2013: Manuka honey where it was known that bees were not feeding from pollen of the Manuka bush (New Zealand)
  • 2016: Dried oregano adulterated with other dried plants (Australia)

This list can go on and on.

Lately there have been more cases of food fraud. Fortunately, even limited international databases are helping to identify the raw material origins of products in the supply chain that could be more exposed to adulteration. Also, food manufacturers, brokers and agents are conducting assessments to ensure that they are buying ingredients and products from sources, where food fraud could be prevented. The following products are identified as having more adulteration notifications:

  • Olive oil
  • Fish
  • Vegetable products with claims of “Organic”
  • Milk
  • Grains
  • Honey and maple syrup
  • Coffee and tea
  • Spices
  • Wine
  • Fruit Juices

2. What can companies do to mitigate the risk?

Control measures to prevent food fraud activities include the adequate evaluation and selection of suppliers, as well as the ‘suppliers of the suppliers’. Typical risk matrices of likelihood of occurrence versus consequence can be used to measure risk—and determine priorities for assessing and putting control measures in place. Assessments can be focused on points of vulnerabilities such as food substitution, mislabeling, adulterations and/or counterfeiting, usually due to economic advantages for one or more tiers in food chain production.

Other food fraud activities include effective traceability systems, monitoring current worldwide news and notifications on food fraud using international databases (EU-RASFF, USA- EMA NCFPD and USP, etc.), and product testing.

Product testing is becoming an important tool for the food industry to become confident in sourcing raw materials, ensuring the management of food fraud control measures, fulfilling applicable legal requirements, and ensuring the safety of consumers.

Product testing laboratories offer different kinds of testing methods depending on the required output; for example, if it is possible and requested, a targeted or non-targeted result.

Targeted analysis involves screening for pre-defined components in a sample:

  • Liquid chromatography
  • Gas chromatography
  • Mass spectrometry (LC-MS and GC-MS)
  • Nuclear magnetic resonance spectroscopy (NMR).
  • PCR technique

Non-targeted analysis aims to see any chemical present in the sample:

  • Isotopic measurement-determination of whether ethanol and vinegar and flavorings are natural or synthetic
  • Metabolomics: Maturation and shelf life
  • Proteomics: Testing for pork and beef additives in chicken, confectionery and desserts

Due to the importance of food fraud for a food safety management system, GFSI published Version 7.1 of Benchmarking Requirements, including subjects on food fraud, as vulnerability assessment. In 2018 all certification schemes have incorporated such requirements and started enforcing them.

Fraud cases threat consumer trust in products and services. Companies are learning to “think like a criminal” and put in place measures to prevent fraud and protect their products, their brands and their consumers.

Jordan Anderson, PAR Technology Corp.
FST Soapbox

Four Core Principles of Food Safety

By Jordan Anderson
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Jordan Anderson, PAR Technology Corp.

As winter ends and summer approaches, most of us will emerge from our houses and start enjoying the nice weather. Even better, hopefully we all will be hosting or attending numerous BBQ’s and get-togethers. Burgers, chicken, salads and the like will be readily available; however, how can we be sure we’re keeping our food and guests safe from a foodborne illness?

The more hands and foods involved, the higher the risk of contracting a foodborne illness. Fortunately, today, we know much more about proper hygiene, food handling and preparation to combat these harrowing outbreaks.

According to the CDC, one in six Americans become ill due to foodborne illness each year. As the fight to combat this issue wages on, there are specific measures we can take to protect ourselves daily. While foodborne illnesses will likely never be eradicated, utilizing the ‘Core 4’ principles of food safety remain a viable approach to limiting its prevalence. This column outlines these ‘Core 4’ principles.

Clean

Infectious bacteria can thrive anywhere within the kitchen. By placing an emphasis on hand, utensil and surface washing, we begin to reduce the risk of foodborne illness. The following are some easy-to-follow cleansing tips:

  • Wash your hands for at least 20 seconds with soap and warm running water before and after handling food or using the bathroom.
  • Wash the surfaces of cutting boards, counters, dishes and utensils after each use with warm, soapy water.
  • Use paper towels to clean counters or spills as they soak in potential contaminants, rather than spread them like cloth towels.
  • Rinse or blanch the surfaces of fresh fruits and vegetables to rid of any dirt or bacteria.

Separate

Even though we now wash our hands and surfaces consistently, we can still be exposed to dangerous illness-inducing bacteria by not properly separating raw meat, seafood, poultry and eggs. To avoid cross-contamination, we can follow these tips:

  • Avoid placing ready-to-eat food on a surface that previously held raw meat, seafood, poultry, or eggs. An example would be: Placing your now-grilled chicken on the same plate in which you carried it to the grill.
  • Use separate cutting boards when preparing fresh produce and uncooked meats. This eliminates the spread of any bacteria either may be carrying to the other.
  • Request or separate raw meat, seafood, poultry and eggs in your grocery bags. This eliminates the spread of bacteria in the event there is an unsealed package.
  • Always properly wash the surfaces exposed to these raw items under warm, soapy running water.

Cook

Regardless of how proactive we are with cleaning and separating, we still must ensure that we cook our food to the appropriate internal temperature. Undercooking may result in the survival of dangerous bacteria that could make us ill. Foodsafety.org recommends the following safe minimum temperatures:

  • Steak/Ground Beef: 160°F.
  • Chicken/Turkey: 165°F.
  • Seafood: 145°F.
  • Eggs: Until the yolk and white are firm; for egg dishes warm until 160°F.

Chill

Last yet not least, we must also learn to appropriately chill our food. Chilling is important because it decelerates the bacterial growth process. By mitigating this, it allows us to reduce the risk of contracting a foodborne illness. The following suggestions are encouraged:

  • For starters: Always keep your refrigerator at 40°F or below.
  • Do not over-pack your refrigerator. Proper airflow circulation is paramount.
  • Refrigerate any meats, egg, or perishables immediately upon return from the store.
  • Do not allow raw meats, egg, or fresh produce to sit out for more than two hours without refrigeration.

By taking these principles into consideration, you can ensure the protection of your friends, family and self, leading to better times and memories gained.

Resource

FoodSafety.gov. Food Poisoning. Retrieved from http://www.foodsafety.gov/poisoning/index.html

Compliance, food safety

Leveraging FSVP Compliance: Do Less, Get More

By Benjamin England, Nicole Trimmer
1 Comment
Compliance, food safety

With an ever-expanding international food trade and new government demands for food safety and supply chain transparency, the U.S. regulatory landscape is becoming increasingly more complex. FSMA (especially the Foreign Supplier Verification Program) aims to shift responsibilities for imported food safety from FDA to importers in an effort to reduce the regulatory burden on FDA. New regulations bring new burdens to food trade stakeholders, requiring significant investment. However, many of the data obligations of the FSVP rule dovetail with other agencies’ requirements.

Investments in one dataset can be leveraged to improve a company’s overall compliance related to international trade. The key is to integrate FSVP requirements into a strong regulatory compliance program without breaking the bank. This requires identifying data overlap, utilizing compliance integration to work smarter, not harder, leveraging the window of opportunity to collect more (and necessary) data from your foreign suppliers, and calling in the right help when needed.

TRUST…..BUT VERIFY: 2018 FSMA Focuses on Supplier Verification Activities | Learn more at the Food Safety Supply Chain Conference | June 12–13, 2018 | Rockville, MDToday’s International Supply Web

No longer can we reasonably talk about establishing, monitoring and maintaining a supply “chain” when importing anything. International trade in food and its ingredients is rarely bilateral—except for perhaps fresh produce, meat and seafood. Instead, food moves throughout a complex supply web of international transactions. Most processed food now contains ingredients from multiple countries, leading to food safety verification challenges and country of origin questions for finished goods.

The international supply web includes farms (land and aquaculture), agriculture cooperatives, food grade chemicals manufacturers, color and flavoring formulators and manufacturers, raw materials processors and fabricators, finished food processors & packers, warehouses, transportation companies, cooking, canning and irradiating facilities, shippers, exporters, product and commodities brokers, importers, wholesalers, retailers and e-tailers. Any (or all) of these players may be small operations located in different countries or multi-national conglomerates operating on several continents. There is very little food consumed in the United States that is not affected, in some way or another, by international commerce and trade.

Shift to a Preventive System

In 2011, Congress passed FSMA with the goal of moving U.S. food safety from a reactive to a preventive system, and integrating HACCP-like principles into the production of all food. Over the ensuing years, FDA issued seven major regulations that address various facets of food safety.

The Foreign Supplier Verification Program (FSVP) rule was included as a way to ensure that foods imported into the United States are produced in a manner that meets U.S. safety standards. FSVP requires that “importers,” which can be the distributors or retailers of products, verify and document the steps taken to ensure safe production of animal and human food. While the exact FSVP requirements vary depending on the commodity, the FSVP process often includes developing, maintaining and documenting a food safety plan and, as its name suggests, verifying that foreign suppliers are controlling for appropriate hazards. Developing and implementing these plans requires a wide variety of skills, including hazard analysis and risk assessment, establishing preventive controls, developing recall plans, and careful documentation of the process. FSVP also requires that verification activities be carried out by parties who have specific preventive control training, or “PCQIs” (Preventive Control Qualified Individuals).

Most importantly, FSMA and the FSVP rule shift the burden of safety from FDA to the importer. With increased interconnectedness, flaws in food safety documentation can become magnified throughout the system. Note that FSVP covers food safety only—not necessarily food traceability or food security defense—although there are opportunities for crossover ROIs. To achieve FSVP compliance, you need to know who is handling your food before it is imported, what they know about food safety, and how they apply food safety principles.

Cross-agency Data Usage

Approaching FSVP as a stand-alone regulatory compliance initiative is expensive and inefficient. Many activities and data elements that must be kept for other government agencies and their compliance programs should be linked together. The data your foreign suppliers must provide to international carriers for advanced notice to U.S. Customs and Border Protection (“CBP” or “Customs”) by importing carriers (airlines, trucking companies and vessel operators) is relevant to both Customs entry and FDA food safety compliance and documentation. This overlap presents an ideal opportunity to relieve the burden of the new FSVP requirements and kill two birds with one stone. And the overlap and leveraging opportunities are actually quite substantial—if one knows where and how to look for them.

For example, the USDA’s National Organic Program (NOP) regulations specify requirements for the processing, handling and labeling of raw materials and processed goods to meet organic standards. Organic labeling and marketing claims are affirmative assertions that the labeled food has not been exposed to processing steps, processing chemicals or particular substances (e.g., sewage sludge, ionizing radiation) that would cause it to fall out of the regulatory bounds of an organic food product. Where organic processing and handling crosses over to food safety, leveraging organic compliance documentation buttresses the safety of the resulting food—and the importer’s FSVP program.

Additionally, much of the information that the importer must know to properly classify their product under the Harmonized Tariff Schedule (HTS) is the same information that the importer needs for their FSVP plan; the importer must know the products, what they are made from, how they are processed, and how they are intended to be used to both properly classify and verify the safety of their product. Because FDA requires the importer to verify that its foreign supplier has a system that meets the domestic food safety standards, the foreign supplier must also be able to identify its own ingredient and raw material suppliers and their systems for food safety, as applicable. Therefore, the food importer’s FSVP process promotes documentation compliance with CBP’s and other government agencies’ requirements governing the country of origin of materials for applicability of preferential duty rates (e.g., under a free trade agreement) and country of origin labeling.

Another example of data overlap is the FSVP requirement for supplier verification and the responsibility to show correct valuation of your product for Customs. FSVP requires that you verify your suppliers and ensure your product is genuine, and Customs requires that you declare an appropriate valuation and identity for your shipment. If Customs investigates your shipment and determines your valuation is incorrect, it may trigger the Department of Commerce to investigate whether there are anti-dumping and countervailing issues going on with the product.

Issues with anti-dumping and countervailing duties are extremely time-consuming and expensive. In both 2008 and 2016, federal authorities investigated rumors of companies circumventing anti-dumping duties by transshipping food products through third countries (to conceal actual origin of the material). When Customs investigated a honey processing plant, they found evidence that the purported processor of Vietnamese honey was receiving finished product from China and relabeling it as originating from Vietnam. When importers declared imported Vietnamese honey, Customs determined from trace mineral testing that the honey was, as they suspected, Chinese. Customs seized the product. The lesson to learn from this is to know your suppliers and the actual supply web. In the case of country of origin violations, not verifying the country of origin can be costly. Where CBP finds negligence is involved, the agency can look back five years to recoup lost duty plus interest, and can even reopen old liquidated entries and assess monetary penalties. In completing your FSVP plan, requesting documentation demonstrating origin is a small additional step that furthers the strength of CBP-required documentation to support the origin declaration at entry. That’s leveraging.

Document, Document, Document

Under the Customs Modernization Act of 1993, the compliance watch-words for all importers (and customshouse brokers) are “record keeping,” “shared responsibility,” “reporting,” and “due diligence.” Anything that is required for a proper importation is subject to CBP review and audit—whether the requirement arises as supply chain and source data under the Seafood Import Monitoring Program (SIMP) under the National Marine Fisheries Service (NMFS), or organic labeling and compliance under USDA’s NOP regulations, or speciation documentation under the Lacey Act enforced by U.S. Fish and Wildlife (USFW), or FSVP implemented by FDA. Therefore, the engagement between food importer and foreign food supplier forced by FSVP opens the opportunity for the importer to clarify and shore up its documentation obligations for many other coexisting regulatory regimes.

A clear demonstration of this fact is borne out by the regular process that ensues when CBP issues to an importer of record a Customs Form 28 (or “CF28”). The CF28 is a CBP request for additional information relating to an imported shipment. The importer is usually required to respond within 30 days of its issuance. But ordinarily the CF28 is issued months (and sometimes years) after the importation occurred. Therefore, the CF28 process represents a significant challenge to the importer’s record keeping and compliance documentation systems, and legal liability to the importer’s bottom line.
Documents needed to respond adequately to a CF28 include contracts, purchase orders, packing lists, shipping documents, declarations to government authorities throughout the import process, powers of attorney, country of origin certifications, emails and other communications discussing any of these documents. CBP requests these documents to confirm the proper electronic data was submitted with the importation. And, of course, CBP is checking to see if the importer is attempting to circumvent U.S. import or export laws that may deprive the government of revenue.

The identity and location of an importer’s trading partners (including the foreign supplier and its suppliers), contracts between and among them (e.g., related to description, processing methods, equipment used, quality and condition of goods), origin documentation, proofs of packing and shipping, etc., are all subject to production via the CF28 process. Penalties for errors in the documentation that result in a regulatory or administrative action are imposed upon the importer (for failing to document or exercise due diligence in performing its function as an importer under U.S. law).

The FSVP regulation presents an ideal opportunity for the importer to establish and populate a compliance program that integrates its FDA import regulatory obligations with those of CBP and other regulatory agencies, as applicable. Failing to take this rare opportunity—at a time when foreign suppliers are expecting probing questions from their U.S. trading partners—is a mistake.

Because the government is more connected, it is essential to change how you prepare for and respond to issues that arise. Just as the FDA’s FSVP rule aims to move food safety from a reactionary to preventive system, coordinated proactive compliance with all government agency requirements will be necessary for the future. Further, with new regulations, your customs broker may not be equipped to deal with certain areas or when administrative matters escalate. But how do you prepare for any eventuality when the enforcement possibilities seem endless?

When preparing your FSVP plans, reviewing your Customs documentation, and reviewing other government agency requirements, it is critical that you think through all the potential issues that may arise with your product or its supply chain, and address them proactively in your documentation. What might an inspector or compliance officer think about the information provided? Is it thorough, clear, and logical? Does it tell a consistent narrative? What if another agency sees this information? Will they have further questions? The ultimate goal is accurate and thorough data for submissions to FDA, Customs and any other partner government agencies.

Key Steps to Prepare for the Worst-case Scenario

Lastly, let’s not forget that part of being prepared is preparing for the worst-case scenario. What happens when you are confronted by an issue? We recommend taking four key steps. First, marshal your resources (documents, documents). Second, ask, “Who are the key players in the story (e.g., which agencies are involved or could possibly be involved, and what are they requesting)?” The third question, a bit less straightforward, is, “How must I respond? (e.g., is the agency within its regulatory authority and required time constraints; are there conflicts of interest; what is the potential legal exposure to risk for different actions)?” Finally, do a gut check: Are the examinations subjective in nature or qualitative (rather than quantitative)? Is any required testing appropriate for the product? If you feel you cannot confidently answer these questions using current staff, we recommend you prepare for import issues by selecting professionals who have experience with integrated agency regulations and legal compliance requirements. The keys to expediting the process when working with multiple government regulatory agencies are integrating your compliance to ensure you have a true green-means-go light before you ship and being able to present a clear and consistent regulatory narrative to all agencies. This requires a clear understanding of how the government regulatory requirements actually intersect.

Melanie Nuce, GS1 US
FST Soapbox

Blockchain: Separating Fact from Fiction

By Melanie Nuce
2 Comments
Melanie Nuce, GS1 US

Over the course of the past two years, blockchain has shown promise across nearly every industry—far beyond the confines of its cryptocurrency origins. The food industry is no exception, with key stakeholders like Walmart, Cargill, Tyson, Coca-Cola and Starbucks all announcing pilot programs this year.

Although blockchain has tremendous potential to speed up food recalls and enable the information transparency that consumers demand, there are important building blocks that must be in place before planning a blockchain implementation. Test your blockchain knowledge with these statements below to see if you can separate fact from fiction. Armed with the right information, you’ll be able to better understand the value of blockchain and how it fits into an entire ecosystem of data sharing before jumping immediately to its application.

Blockchain is basically a shared database. This is true. While it’s no secret that shared databases have benefits, what makes blockchain special is that it is a distributed and immutable ledger. There is no single point of failure in a distributed ledger—it is a consensus of replicated and synchronized digital data geographically spread across multiple sites. This decentralized structure makes the data resilient to a technology or organizational failure.

Blockchain also supports “smart” supply chain contracts, meaning an automated execution of terms, conditions and business rules. Through this feature, trading partners can automatically enforce terms and conditions as previously defined, eliminating the errors and inefficiencies associated with the current manual processes based on legacy systems. A trading partner is prevented from writing a business transaction to the blockchain ledger that is outside of the rules specified in the smart contract. For retail grocery, this means far fewer item substitutions, more certainty around what is being shipped and when, and fewer discrepancies downstream.

GS1 US
Image courtesy of GS1 US

Blockchain will do for the supply chain what email did for communication. This is also true—but Rome wasn’t built in a day. It will take time for blockchain to become a ubiquitous technology on par with email, and it is likely another decade away. However, given the amount of pilot programs underway, and the commitment from technology providers like IBM, Microsoft, and SAP to develop blockchain enterprise programs, many industry analysts believe blockchain will breakthrough to start to solve business process challenges in the next three to five years.

Purchasing blockchain software is all you need to create a traceability program. This is completely false! Industry stakeholders already leverage GS1 Standards, which enable traceability by ensuring all trading partners communicate in a uniform manner. Standards ensure systems interoperability, and provide a singular approach to creating, sharing and maintaining product information that supports, at the very least, “one up/one down” visibility of the product’s movement through the distribution channel. The internal data and processes a company uses to track products is integrated into a larger system of external data exchange that takes place between trading partners. Blockchain represents an opportunity for traceability to move faster—smart contracts and immutable ledgers expedite the flow of data between supply chain partners.

Blockchain can reduce food recalls from weeks to minutes. This is true, but only with a food traceability program already in place. Traceability has been achievable without blockchain, and many leading retailers have a long history working with farmers, distributors and processors on effective food traceability programs in order to assure consumers of food safety. Product recalls are significantly faster with standards in place to help break down any barriers caused by proprietary numbering systems and manual business processes.

Ultimately, now is the time to stay educated on blockchain and follow its development closely to uncover its many opportunities.

Glen Ramsey, Orkin
Bug Bytes

Implementing Pest Management Changes for FSMA

By Glen Ramsey
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Glen Ramsey, Orkin

Preparation is the key to success for any ongoing endeavor. In an industry where your enemies are fighting for survival at the expense of your business, you must be ready for anything. Your opponents are crafty, adaptable and more prevalent than you think.

No, I’m not describing your competitors. I’m talking about pests—a major threat to the integrity of food products and a threat to any facility’s bottom line. Whether it’s stored product pests contaminating inventory or rodents spreading pathogens as they skitter across equipment, pests are a risk that should be minimized.

With FSMA in full effect, preparation is more important than ever. FSMA mandates a proactive approach to food safety, and by extension, pest management. It’s important that the pest management program is exhaustive and integrates seamlessly into the overarching food safety plan.

Most, if not all, food processing facilities currently use an integrated pest management (IPM) program to help minimize the chance of pest problems, but FSMA puts more emphasis on being proactive to keep pests far from products at all times. Naturally, this doesn’t mean that a pest sighting in a facility is the end of the world, but it means that it should be resolved quickly, investigated and documented to help prevent such an occurrence from happening again.

Specifically, FSMA has numerous stipulations that trickle down to pest management.

  1. Hazard analysis. First, a comprehensive inspection should be done to identify the high-risk areas in your facility where pests may take residence. Entry points, potential food and water sources and harborage areas should all be noted.
  2. Preventive controls. Include regular facility maintenance reviews and a strict sanitation regimen in your food safety plan to help minimize the use of chemical pest management treatments.
  3. Monitoring. Use devices and employees to keep tabs on pest activity and conducive conditions to ensure preventive controls are working and executed across the facility.
  4. Corrective actions. Implement and enforce pest management solutions such as exclusion strategies (e.g., weather-stripping, door sweeps, vinyl strip doors), traps (e.g. pheromone traps, insect light traps, bait boxes), air curtains and repellants to help manage pest activity.
  5. Verification. Schedule regular service visits with your pest management professional to verify corrective actions are working to reduce pest problems over time. These visits should include an annual facility assessment and pest trend analysis, both of which help determine potential areas of improvement over time.
    6. Record keeping and documentation. Document every action taken to prevent pests. That includes corrective actions and their results to prove that your written IPM and food safety plan has been implemented and is effective in helping to manage pests at the facility.

With these key components accounted for, it will be easier to be prepared for pests. But, even still, the real-world implementation of these tactics might not be abundantly clear. That being the case, let’s take a look at what food processing facility managers can start doing today to help protect their facilities and demonstrate a proactive approach to food safety.

So, what’s the best way to be more proactive in preventing pests?

Well, that question has a plethora of possible answers, but four of the most important are sanitation, exclusion, staff training and monitoring.

Sanitation

Perhaps the most important of all, sanitation helps to eliminate two key attractants—food and water—that draw pests inside a facility. Any spot where food particles or moisture is collecting, pests will be looking to find.

But sanitation shouldn’t seem daunting. Here are some actions you can start doing today to step up your sanitation program:

  • Wipe down equipment regularly to break down the buildup of organic materials.
  • Wipe off countertops and sweep floors in common areas where food is present, then sanitize with an organic cleaner afterwards to eliminate any remaining odors.
  • Take out the garbage at least daily, and keep dumpsters at least 50 feet away from the building to avoid giving pests a harborage location nearby with an easy path to get indoors. Make sure to cleanse garbage bins and dumpsters regularly, or they’ll become attractive to pests, too!

Exclusion

A big part of preventing pests from getting inside a facility is simply blocking them out using exclusion.

During an inspection, a pest management provider will walk around the interior and exterior of the facility and look for any potential entry points for pests. They should recommend you seal any cracks and crevices they notice, as many pests can fit through extremely tiny gaps. For example, mice can fit through a hole the size of a dime. Gaps should be sealed with a water-resistant sealant to keep pests and moisture out.

In addition, make sure to keep windows and doors closed as much as possible or use screens to block pests. Automatic doors can help in this way, especially when paired with an air curtain to blow flying pests away from entrances. Pests can often come in through the biggest gap of all: The front door!

Staff Training

It’s always better to have a team behind you. Training employees on the basics of an IPM program and what they can do to help will take some of the weight off your shoulders.

Many pest management providers offer free staff training sessions, which can help employees understand what to look for around their work areas and what to do in the case of a pest sighting. Consider creating your own pest sighting protocol to make it clear what employees should do if and when a pest is spotted. They’ll need to record when, where, how many and what kind of pest(s) were seen at the time to give your pest management provider the best chance to create a customized solution to resolve the issue. If you can catch one of the pests in a container for future identification, that’s even better.

Monitoring

While employees can help by keeping an eye out for pests, it’s important to have ongoing monitoring techniques to measure pest activity around the facility.

Monitoring devices are a great way to do this, and your pest management professional can help you place them strategically around the hot spots in your facility. Fly lights, bait stations, pheromone traps and more can capture pests and serve a dual purpose. First, they’ll reduce pest populations around the facility, and, second, they’ll allow you and your pest management provider to see how many pests are present in certain areas.

Over time, this will give you a feel for which pest issues have been resolved and which continue to be a problem. That can determine the corrective actions taken and the long-term food safety plan, which will demonstrate a commitment to constant improvement. That’s a great thing to have on your side, especially when an auditor happens to stop by.

Documentation

I know, I know—this wasn’t one of the four “answers” listed, but it’s still incredibly important! Documentation helps ensure you get credit for being so prepared.

It’s recommended that facility managers keep a few documents on hand to keep things simple. The food safety plan, annual assessments, sighting reports, a list of service changes over time, a list of monitoring devices and proof of your pest management professional’s certification are all important documents to keep updated and ready to go. That way, you can rest easy knowing you’re prepared at a moment’s notice.

It is never too early to start preparing. Pests aren’t going to stop searching for a food source anytime soon, so don’t stop your proactive efforts to keep them at bay. Your financial department will thank you.

Three Ways Sanitation Automation Helps Food Processors Reduce Costs

By Bob Ogren
No Comments

Sanitation in a food processing plant is a large-scale effort that many organizations see as an added cost of doing business. Yet, it’s essential and can have costly consequences if done improperly.

Because time is money and facilities want to avoid any necessary downtime, the window for completing proper sanitation procedures is small. Many food processors simply put more people on the job while requiring them to work third shift, hoping to get things done faster.

Automating certain sanitation procedures in your plant can provide real benefits, many of which will help reduce the costs associated with food safety and keeping your facility clean. Here’s a look at the three main ways food plants can save by implementing automated sanitation solutions.

1. Resource Management

When you invest in sanitation automation, one of the biggest advantages is the increased understanding of how resources are being used. This knowledge and improved visibility gives you control of how resources such as water and chemicals are used during sanitation.

Butcher cleaning the floor at meat factory. Image courtesy of Birko.

Perhaps the most significant area in which facilities experience savings is through reduction of water usage. Automated solutions improve the efficiency of rinse cycles while ensuring appropriate water pressure is being used. Every plant has unique water needs, but you should expect water savings between 30% and 50%, depending on the solutions that are applied.

Sanitation automation will also lead to a reduction in energy costs. Using less water means less energy is required to heat that water. Advancements in sanitation technology have made certain solutions more energy efficient. Features such as multi-stage pumps for full alternation, motors that allow pumps to ramp up and down as needed, and flow switches that send pumps into “hibernate” mode help reduce electricity usage.

Waste water from food processing also needs to be treated before it goes down the drain. Less water treatment means fewer chemicals are needed.

Food processors that introduce automated sanitation solutions will use cleaning chemicals more efficiently. Automation ensures chemicals are dispensed precisely where they are needed at the correct concentration, without any over spray. Again, while every situation is unique, most facilities can expect a 20–30% reduction in chemistry costs.

In the end, you will have a very clear picture of the amount of water and chemistry needed to complete sanitation, and you’ll know the amount of time it should take. That means you can plan for more uptime.

Overall, not only can automation help food processors make efficient use of resources, it also makes them more sustainable.

2. Labor Costs

Labor is yet another resource that can be more effectively managed when there’s an investment in sanitation automation. The labor market is tight, and it is becoming increasingly difficult to hire the people needed to carry out sanitation work.

Sanitation often involves menial and tedious tasks that also require attention to detail. It usually entails working overnight when production stops, and certain responsibilities can be dangerous. At the same time, minimum wage is rising, and many organizations are looking to reduce labor costs.

Introducing sanitation automation can certainly cut labor expenses and remove the need to hire more people, but more importantly, it can make the workers you do have more productive. Automation should be used to eliminate menial tasks from sanitation workers. For example, instead of a person standing in front of a conveyor belt and spraying it down with a hose for hours on end, the job could be easily automated.

We worked with a brewer who was having two employees take as long as three hours to clean a filler. By automating that task, they turned it into a 45-minute job and allowed those employees to refocus their efforts. Plus, the before and after pictures of the equipment show a visible difference in cleanliness.

You can trust an automation solution to do a consistent job, and it will never call in sick.
Still, you’ll always need to have “boots on the ground” and human eyes evaluating sanitation. Automating certain sanitation practices will free up employees to work on more important duties that add value and keep them engaged in their work.

3. Mitigating Safety Risks

The most important thing sanitation automation provides is more peace of mind. No one wants to lose sleep worrying about a failed inspection or the potential for a worker injury. Automation reduces the risk of product contamination and lessens potentially dangerous situations for employees.

For instance, spiral freezers are particularly precarious areas to clean. Automating its cleaning process eliminates the need for a worker to maneuver through an unsafe space, reducing the likelihood of a workplace injury.

Human labor can also lead to human error. But, when sanitation tasks are automated, they become more consistent and easily repeatable. This is especially important for cleaning hard-to-reach problem spots that become harborage areas for bacteria. There may be a tendency among human workers to skip areas they can’t reach, or fail to clean them properly, but a machine cleans everything the same every time.

The monetary risk of contamination inside your facility is significant. For example, if Listeria were to take up residence in a plant, it could cost your business millions of dollars.

According to a study from the Food Marketing Institute and Grocery Manufacturers Association, the average food product recall will have direct costs of $10 million while indirect costs could reach into the hundreds of millions. That’s because you also need to consider the ongoing cost of a damaged brand reputation, not to mention lost productivity from business interruptions and lost profits from disposing of potentially contaminated product.

Sanitation Automation: The Future is Now

There are many reasons to start implementing automation into your food and beverage plant’s sanitation practices. Food processors in Europe have been quicker to adopt these solutions because many of the same issues U.S. manufacturers face, such as wages and resource scarcity, can be even more pronounced overseas.

As the labor market in the United States presents challenges for hiring managers, and drought conditions in some regions make water a scarce commodity, automation presents an opportunity to bring your facility into the future. Add to those concerns the increased regulations from FSMA, and there is even more reason to invest in dependable sanitation solutions.

Food processors need to find trusted advisors who can evaluate operations inside the plant and look for ways to implement automation in ways that make the largest impact.

While there is certainly an upfront cost in automating sanitation, the potential savings and added visibility these solutions provide won’t take long to pay for themselves. In most cases, facilities that invest in sanitation automation will see a return within a year to 18 months. If done properly, you can achieve impressive cost-saving results through automation.

Steven Burton, Icicle Technologies
FST Soapbox

Food Recall Strategies: What You’re Missing (And What You’re Risking)

By Steven Burton
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Steven Burton, Icicle Technologies

You’ve heard the horror stories of product recalls: The Peanut Corporation of America in 2009, Blue Bell ice cream in 2015, and Darwin’s Raw Pet Foods this year. Beyond the nightmare scenario, the truth is that food recalls are common—even for companies that take food safety seriously, train effectively and keep excellent records. Yet all of these things, when done properly and efficiently, go a long way to reduce the impact and severity of a recall.

Unfortunately, many food manufacturers, although required to have a written recall plan, aren’t ready for the challenge. Without the proper systems in place, businesses needlessly risk their customers, reputation, revenue and future.

Risks Of Inadequate Recall Strategies

Resolving a recall can take years and potentially millions of dollars in fines, product shipping and disposal cost, production line downtime, lawsuits, and lost market share as consumers lose trust in the company. But there are two strategic errors that can amplify these consequences—and they both have to deal with traceability.

The first problem we frequently see is lot codes not being specific enough. Rather than breaking up production into discrete lot codes so the scope of recalls can be as limited as possible, some facilities just run the same lot code for many production runs. The record we have seen so far is three years! When a recall occurs,this results in a recall of massive scope that can easily bankrupt a company.

The second problem that is even more common is a lack of dynamic documentation. Assembling transactions using disconnected records from different departments can be time-consuming and error-prone. When you’re under pressure from regulators or auditors to connect the dots between an ingredient and customers through complex, multi-stage production processes using such a record system, it can cause stress and potential audit failures.

These two missing pieces make recalls larger, more time-consuming, and more expensive than necessary due to a lack of precise traceability. Let’s take a look at the two ways you can fill these gaps in your system and mitigate the consequences of recalls.

Get Specific with Ingredients, Suppliers and Lot Codes

Streamlining your product lines and packaging options lists is a straightforward way to reduce potential headaches in the event of a recall. The more products and packaging options with which you work, the more complex it will be to pinpoint and resolve food safety failures. Anyway, this type of housekeeping is beneficial as far too many companies have large lines where only a small subset of their products sell well at decent margins. Larger, more mature organizations tend to thin down their lines to optimize for profitability, and smaller companies can often benefit from doing the same.

The next strategy you can employ to mitigate the consequences of a recall is by being ultra-precise when it comes to your records and lot codes. The more narrowly you refine your lot coding system, the fewer items you’ll have to recall. Let’s look at a specific example of how this could have saved two companies millions of dollars.

In 2010, Hillandale Farms and Wright County Egg recalled about 550,000,000 eggs, one of the largest recalls in the history of the United States. Although the company was able to resolve the specific dates and facilities where the contaminated product originated, they had 53 million hens laying, so this level of resolution may not have been adequate enough. Had they implement traceability lot codes down to the hen house level, they may have been able to contain the recall.

Automate Your Traceability To Be Audit Ready, All The Time

The challenge of maintaining an overly broad product line or providing customized packages is that you create hundreds or thousands of variants in your products. When records are maintained manually, it becomes extremely difficult to manage recalls effectively. An Excel spreadsheet may keep a record of everything, but it’s certainly not dynamic or time-efficient when undertaking mass balance calculations.

The key here is to adopt software that you can incorporate into every department. Shipping, receiving, accounting, production—when all the records are kept in a central database, checking and updating those records becomes much easier. But the best systems don’t just centralize your collected data; they automate your data collection.

Dynamic documents automatically update each other. When a supplier changes, an ingredient lot gets swapped out, or products are shipped out, all the connected records for every department are automatically updated. No user mistakes, no failure to update the notes—just seamless, streamlined, auto-updating records.

There’s no better way to track complex production processes, control hazards, and collect all the necessary information necessary to breeze through audits than by using an automated system. With all your documentation interconnected, you don’t have to piece together the puzzle or play connect the dots—it’s all done for you, and that means you won’t waste millions on recalling products unnecessarily because you couldn’t pinpoint the exact path every ingredient took on the way to the customer.

Recalls are detrimental in every way, but they happen, so don’t get caught off guard. A little bit of proactive technology will go a long way in keeping your business afloat if you ever do face the nightmare of a recall.

Ibidun Layi-Ojo, Prometric
FST Soapbox

Effective Testing: Developing Rigorous, Reliable and Relatable Questions

By Ibidun Layi-Ojo
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Ibidun Layi-Ojo, Prometric

Success Factor 2: Develop rigorous, reliable and relatable exam questions (items) that are developed, tested and continuously evaluated to correlate with market needs and trends.

My previous column in Food Safety Tech outlined the single most important factor in ensuring that all employees have the proven ability to keep the public safe from foodborne illness: Education. Only rigorous, continually evaluated exams, designed for a company’s particular industry segment, can give employers the assurance that employees have the skills they need to make food safe.

Constructing and administering those exams starts with partnering with the right food safety assessment provider. Once that provider has been chosen, the next step is to develop questions—and ultimately an exam that exemplifies the three R’s: Rigorous, reliable and relatable.

Rigorousness begins with the process by which questions are created. This process must be a step-by-step effort to ensure that the final exam asks the right questions, based on the industry segment and the skills needed to be measured, and that the questions meet or exceed current industry standards. The ultimate aim is to give employees the opportunity to demonstrate their knowledge, which results in a sense of empowerment that makes them effective stewards of food safety every day.

To meet these goals, a company must work closely with its food safety assessment provider throughout the test development process, which begins with an analysis of the job (or jobs) for which the exam is being created (i.e., what are employees’ important tasks for which performance must be measured?). This analysis informs the development of precise specifications for the exam, and with those specifications established, the food safety assessment provider can begin collaborations with subject matter experts to formulate questions for the exam. Every question on the exam should dovetail with needs and trends in the marketplace, with emphasis on the client’s position in the marketplace.

The next step in the process—item review (question validation) —is key to making sure the exam is comprehensive. In effect, this is a ‘test of the test’ and should address the following:

  • Does the exam ask all the right questions?
  • Are the questions free of ambiguity that could lead to an inaccurate measurement of knowledge?
  • Are the questions in line with current industry standards?

Once every question has been subjected to validation, a passing score for the exam is set concurrent with best practice guidelines for making scoring decisions. Next the food safety assessment provider and the client collaborate on the best way to administer the examination (e.g., whether on paper or online, taken at work or home).
Only then is the test ready to be given, scored and analyzed.

It might seem, at this point, that the exam-creation cycle has been completed. On the contrary, the cycle must be a continuous process, with results from the initial test administration serving as a baseline for ongoing test maintenance and fine-tuning.

This continuity is critical, because standards and practices for food safety are always evolving. FSMA gave the FDA broad authority to prevent contamination of food in every step of the supply chain. In the seven years since then, regulations at the federal, state and local levels have been constantly amended and updated across the entire spectrum of the food industry, from growers, manufacturers and processors to grocers, retailers and even culinary schools. Only ongoing test maintenance—including the development and validation of new test items—can ensure that exams stay in lockstep with the FDA food code and safety guidelines.

Exam questions also must be aligned with the accreditation guidelines of the American National Standards Institute (ANSI), the private, nonprofit organization that, since 1918, has been the overseer of U.S. standards for consumer protection.

Developing and maintaining accurate, reliable food-safety exam content is complex and challenging, requiring a commitment to continuous validation and “testing of the test” to meet the needs of the marketplace and the requirements of federal, state and local regulators. Partnering with the right food safety assessment provider is crucial in meeting those needs and requirements, protecting the public, and ensuring a company’s reputation for providing safe, wholesome food.

Look for Part 3 of this series to learn more about how to create food safety exams that factor in a best-practices approach to properly assess the workforce.

Alert

CDC Expands Warning: Get Rid of All Lettuce from Yuma Region

By Food Safety Tech Staff
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Alert

 

Last week Food Safety Tech reported on a multi-agency investigation of an E.coli O157:H7 outbreak linked to chopped romaine lettuce from Yuma, Arizona.

Now the CDC is advising consumers, restaurants and retailers to get rid of all romaine lettuce—not just chopped romaine, but also whole heads and hearts of romaine, and salads and salad mixes containing the variety—if they cannot confirm the source. “Information collected to date indicates that romaine lettuce from the Yuma, Arizona growing region could be contaminated with E. coli O157:H7 and could make people sick,” the CDC states on its website.

The most current illness case count is 53, with illnesses reported in 16 states. There have been 31 hospitalizations thus far and no deaths, according to the CDC.