Tag Archives: Focus Article

product recall sheet

Effective Supplier/Retailer Communication Eases Pain of Food Recalls

By Holly Mockus
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product recall sheet

Food recalls are not 100% avoidable, and they are costly. The hit to an individual food company or retailer, on average, can run to tens of millions of dollars. Annually, millions of consumers become ill as a result of contaminated food products, and the dollar costs in terms of lost productivity, medical treatment and deaths run into the tens of billions.1 More than 20% of consumers have said that they would not purchase any brands from a company suffering a food recall.2 At best, damage to a company’s brand and reputation could take a long time to repair. Clearly, the need to prevent food contamination is obvious and should be the ultimate goal of all food safety professionals.

But despite the best industry efforts, recalls inevitably occur. And since they aren’t 100% avoidable, suppliers and retailers must continue to look for ways to minimize the safety and financial impact of the recall events that do occur. It’s good to begin that process by understanding some statistics surrounding the most common recalls. Globally, 46% of food recalls are for chemical hazards or the introduction of non-food-grade ingredients. 79% of these are due to undeclared allergens. 26% of recalls are for food-borne pathogens, and 8% are due to physical hazards (metal, glass, plastic, paper, wood, etc.). The remaining 20% are generally quality-based recalls and withdrawals.3

Head Off Recalls Before They Occur

Knowing the numbers helps suppliers and retailers home in on their most likely problem areas and get a leg up on potential product contamination problems. Since chemical hazards are the single biggest culprit, and because most of these instances are due to allergens, food companies should closely examine their cleaning and sanitation practices during production line changeovers. Keep in mind the potential role of contract service providers as sources of adulteration. Regarding pathogens, evaluate raw and ready-to-eat segregation procedures, staff access points, and  good manufacturing practices and employee traffic patterns.

Many companies focus their efforts on passing food safety certification audits, but faithful adherence to food safety measures just to pass an audit misses the point. Focus on the development and implementation of comprehensive food safety systems to guard against contamination and food safety incidents, and not just avoid non-conformances to certification codes. Preventing food safety incidents and recalls before they happen must be the priority.

Supplier Best Practice: The Mock Trace

Manufacturers, suppliers and certification bodies have evolved a set of best-practice recommendations that will go a long way toward reducing the number of food safety incidents and recalls. These include conducting regular internal audits of food safety plans and procedures, including approved supplier programs and environmental monitoring programs, both to re-evaluate their effectiveness and discover new or previously overlooked gaps.

Suppliers should consider taking things to the next level. SQFI’s LeAnn Chuboff suggests that suppliers “make their retailers happy” through the use of mock trace exercises.3 These “dry runs” are invaluable for reinforcing the close examination and evaluation of recall plans and to become intimately familiar with the necessary procedures in the event of an actual adulteration event. Mock trace exercises should be intensive: They are particularly effective in identifying gaps when they occur during off shifts. Making the exercise challenging rather than check-the-box easy helps companies reveal and close critical gaps. Conduct the mock trace in both directions, from raw materials to finished goods, and vice versa.

Include every department in the company. For mock trace exercises to be completely effective, review all documentation for errors or omissions. All employees should be interviewed to determine whether they fully understand food safety and documentation procedures. Review training modules and observe manufacturing procedures for evidence of knowledge or operational gaps. Examine bulk material receiving and storage, employee and material traffic patterns, packaging materials and procedures, and cleaning and maintenance chemicals.

Speed as well as accuracy and thoroughness are critical in the event of an actual recall event. Companies should practice rapid response. Take advantage of all the accumulated experiences from the mock exercise to improve every aspect of the company’s food contamination response tools and practices.

Food Fraud

Using Data to Prevent Food Fraud

By Maria Fontanazza
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Food Fraud

The FDA Food Safety Modernization Act (FSMA) Preventive Controls for Human Food rule is now final, and compliance dates for some businesses began in September 2016.  Economically Motivated Adulteration (EMA) or food fraud is a component in the Preventive Controls Rule.  As the global supply chain becomes more complex, preventing EMA and compliance to Preventive Controls for Human Food rule can be a challenging task.

A food company’s supply chain can be the weakest link in their food safety program. Learn strategies and how to mitigate risks at the Food Safety Supply Chain Conference | June 4–5, 2017 | Rockville, MD, LEARN MORELast year GMA and Battelle released EMAlert, a tool that enables quantitative evaluation of a company’s supply chain to economically motivated adulteration. USP also provides a platform to help companies with food fraud mitigation strategies. In a Q&A with Food Safety Tech, experts from the USP Food Program, Jeff Moore, Ph.D., science director and Karen Everstine, Ph.D., scientific liaison explain how the Food Fraud Database 2.0 works and how it can help companies with FSMA compliance.

Food Safety Tech:  How does the Food Fraud Database 2.0 assist food companies in identifying hazards and vulnerabilities?

Jeff Moore, Ph.D.: We reengineered the database [previously Food Fraud Database 1.0] from the ground up, including the structure of the data. Users wanted not just a source of high quality data to inform of risks and vulnerabilities that were related to food fraud but also some ability to analyze the information and get alerts and real-time information to figure out what to do in real time.

Karen Everstine, USP Food Program
Karen Everstine, Ph.D., USP Food Program

Karen Everstine, Ph.D.: Since it was reengineered, we’ve been able to include a lot of fields that allow food companies to tailor their results to information that is most applicable to them (i.e., geographic location). Automated analytics give a visual of what’s happening to see trends more quickly.

Moore: We have a team of dedicated analysts that are constantly scouting the public domain and looking for information globally to add to the database to make sure it’s the most comprehensive, up-to-date global database of food fraud information.

FST: What tools within FFD 2.0 can help companies with FSMA compliance?

Everstine: One of the things in the FSMA PC rule is the fact that food companies now have to identify potential hazards, whether they are intentional or unintentional, which includes food fraud-related hazards. One of the tools we built into the database is an EMA (Economically-Motivated Adulteration) hazard identification report. It allows users to input a list of their ingredients (those sourced and brought into the facility to create a finished food product), and then the report output identifies which ingredients are associated with potential hazards (i.e., adulterants that might pose a health threat to consumers). That’s the main tool we’ve built to target FSMA compliance.

Moore: One of the key parts of the PC rule as related to EMA is a question of whether the ingredient has a history of association with potentially hazardous adulterants. We put together an expert panel at USP and Karen [Everstine] was responsible for working with the panel to develop a classification system to identify adulterants that are potentially hazardous.

Maria Fontanazza, Zephyr Wilson, Food Safety Consortium

Encourage Employees to Find Listeria

By Food Safety Tech Staff
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Maria Fontanazza, Zephyr Wilson, Food Safety Consortium

Building the right food safety culture around environmental monitoring requires a realistic approach to your processes. “Culture starts with understanding your process,” Zephyr Wilson, product manager at Roka Bioscience told Food Safety Tech at the 2016 Food Safety Consortium. “You need to ask questions—a lot of questions.”

In the following video, Wilson talks about food safety culture in the context of environmental monitoring and how companies should approach environmental monitoring. “Understand all of your processes,” she said. “Take an honest look at your metrics and make sure you’re encouraging your employees to find the Listeria.”

She also reviews the steps a company should take when undergoing self-auditing, and encourages companies to work under the direction of an attorney to ensure that all results are confidential.

Peas, UV light

Controlling and Mitigating Pathogens Throughout Production

By Troy Smith
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Peas, UV light
Sampling
Product sampling

As the enforcement of rules, regulations and inspections get underway at food production facilities, we are faced with maintaining production rates while looking for infinitesimal pathogens and cleaning to non-detectible levels. This clearly sets demand on the plant for new and creative methods to control and mitigate pathogens pre-production, during production and post production.

As this occurs, the term clean takes on new meaning: What is clean, and how clean is clean? Swab and plate counts are now critically important. What method is used at the plant, who is testing, what sampling procedure is used, and how do we use the results? As we look at the process from start to finish, we must keep several key questions in mind: What are harboring points in the process, and what are the touch-point considerations to the product? Let’s review the overall processing progression through the factory (see Figure 1).

Figure 1.
Figure 1. The progression of processing of a food product through a facility.

Now consider micro pathogen contamination to the product, as we look deeper in the process for contamination or critical control points as used in successful HACCP plans. Consider contamination and how it may travel or contact food product. It is understood through study and research of both pathogens and plant operations that contamination may be introduced to the plant by the front door, back door, pallet, product, or by a person. In many cases, each of these considerations leads to uncontrolled environments that create uncontrolled measurements throughout, which lead to cleaning procedures based on time rather than science. This is certainly not to say that creating a preventive maintenance schedule based on a calendar is a bad thing. Rather, the message is to consider a deeper look at the pathogens and how they live and replicate. From the regulatory and control measures this should be a clear message of what food-to-pathogen considerations should be taken at the plant level as well as measurement methods and acceptable levels (which is not an easy answer, as each product and environment can change this answer). A good example to consider is public schools and children. Health organizations work to help the schooling system understand what immunizations children should have based on the current health risk tolerance levels. In food production, the consideration is similar in an everchanging environment. As we see contamination levels change the methods, techniques and solutions to proper food production must account for the pathogens of concern.

Contamination, Risk tolerance, Opportunity for Growth

Contamination, risk tolerance, and opportunity for growth are the considerations when looking at a plant design or a plant modification. Modification to modernization should be a top-of-mind critical quality control measure. If there are a few things we know, it is how to produce food at high rates of speed, measure and value production rates, and delays or failures can be measured by equipment and personnel performance. In the case of quality control, we must review, comprehend, and protect process risk. From a management or non-technical viewpoint, quality control can be very difficult to understand. When discussing pathogens, our concerns are not visible to the human eye—we are beyond a dirty surface, weare looking at risk tolerance based on pathogen growth in logarithmic measurement. When combining quality control and production, the measurement control and mitigation measures complement the effort. The use of quality control is expected and should coordinate with production to ensure the product is produced at the expected quality level.

Stored product pest, Rentokil

Product Pests Hurt Your Business

By Food Safety Tech Staff
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Stored product pest, Rentokil

Stored product insects (SPI) can cause a revenue loss of 1–9%, according to recent research by the Centre for Economic and Business Research. The following infographic outlines the impact SPIs can have, which are the world’s most expensive pests, according to Rentokil.

Stored Product Pests
An infestation of stored product pests can also lead to foodborne illnesses. Infographic courtesy of Rentokil
Hank Lambert, Pure Bioscience

Antimicrobial Technology Mitigates Pathogen Risk Throughout Supply Chain

By Food Safety Tech Staff
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Hank Lambert, Pure Bioscience

Learn more about mitigate risks in the supply chain by attending the Food Safety Supply Chain Conference, June 5–6, 2017 in Rockville, MD | LEARN MOREEver heard of silver dihydrogen citrate (SDC)? The patented molecule is a new antimicrobial being used to kill potentially deadly pathogens in places from food processing facilities to restaurants. SDC is non-toxic and has an EPA toxicity rating of IV (the lowest category).

At the Food Safety Consortium last month, Hank Lambert, CEO of Pure Bioscience, talked about how the technology his company developed can help the food industry control pathogens (including Listeria mitigation), along with its differentiating characteristics versus other disinfectants. He also gave a preview of the applications in which the company will pursue FDA and USDA approval this year.

 

Trump Administration Puts Gag Order on Federal Agencies

By Food Safety Tech Staff
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After only a few days in office, President Trump and his administration have placed a gag order on federal agencies, including the USDA and EPA. Workers are barred from communicating with the press, the public or members of Congress, according to several outlets. A memo was reportedly sent to the EPA, instructing the agency not to publish any press releases, social media posts or blogs until told otherwise.

The Washington Post  reports that the chief of the USDA’s Agricultural Research Service (ARS) Sharon Drumm sent an email to staff stating, “Starting immediately and until further notice, ARS will not release any public-facing documents. This includes, but is not limited to, news releases, photos, fact sheets, news feeds, and social media content.” However, another memo sent out today by USDA Acting Deputy Administrator Michael Young said that he did not review the ARS guidance and would not have sent out such a draft. According to the Post, “his guidance does not place a gag order on publication to scientific journals, does not place a blanket freeze on press releases, or prohibit food safety announcements.”

Earlier this week, President Trump nominated Sonny Perdue, former governor of Georgia, to lead the USDA.

Jeff Rieger, Digi International
Retail Food Safety Forum

IoT a Key Ingredient for Food Safety

By Jeff Rieger
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Jeff Rieger, Digi International

The Internet of Things (IoT) is the concept that everything will one day be connected, similar to when computers became networked and connected with the internet. A sensor in a walk-in freezer is now smart enough to communicate directly with the smartphone in your pocket and a computer at the office, all in real-time. This is what IoT is all about, bringing more information to our fingertips in order to make faster, more informed decisions.

These new technologies are beginning to intersect and create new solutions to old problems, such as periodically monitoring the temperature of equipment in a restaurant or the trailer of a refrigerated truck. Savvy operators who understand changing food safety regulatory demands are driving the adoption of these technologies that ease the transition towards ongoing compliance. Food safety technology is changing, and what follows are a few of the driving forces.

Smartphones, Tablets and Cloud Computing Create Ready-made Environment

Apple launched the first iPhone in 2007 and within six years, 50% of the U.S. population was using a smartphone and/or tablet. Another market event that helped create the foundation for IoT was the growth of the “cloud” model where organizations could “rent” hardware, software and data storage. When coupled with new affordable wireless networking capabilities (WiFi, Bluetooth) and expanded cellular coverage at decreased cost rates for data, it became economically viable for nearly any size company operating in the foodservice industry to collect, store and access data.

Over the course of the last decade, we’ve become more comfortable living in a connected world and, as the technology has matured, businesses started to look at how smart devices could be used to improve operational efficiency and outdated food safety protocols. Instead of manually checking equipment temperatures, wireless sensors are now connecting refrigerators and other temperature controlled environments to the cloud. Any operator with a smartphone is now able to view these temperatures (or receive alerts) in real-time to ensure equipment and product temperatures meet company standards and local regulatory requirements.

Heightened Diligence by Oversight Agencies, Increased Consumer Activism and Brand Protection Concern

The responsibility for food safety spans both national (FDA/USDA/CDC) and local (state and county health department) organizations. FSMA has widened these responsibilities across the cold chain. With limited resources, operators are being asked to adopt new regulations and do their part to ensure the integrity of the product that is being stored and/or transported.

In addition, consumers have become increasingly self-aware regarding various food-related issues, including oversight and traceability (i.e.  labeling, processing, etc.). This same general trend can be seen where consumers are now expecting ongoing food safety inspections and access to inspection results online. This puts more pressure on operators to ensure guidelines are met and inspections are passed.

Finally, restaurants are becoming more proactive in protecting their brand. The idea of keeping any incidents limited to the awareness of only the few that were involved is a thing of the past. Forward-thinking restaurants realize that social media has changed the landscape, and what was once a single-store minor infraction can now cause franchise-wide problems. Additionally, food safety is just good business. Restaurants have moved beyond following procedures as a necessary hurdle to now actively following and implementing best practices and policies in order to achieve operational efficiency and elevate their brand reputation.

IoT the Enabler of a Data-driven Business

Simply put, the internet has reshaped all businesses, so why not restaurants and the cold chain? With the availability of “ready-made tech”, sensors can connect to front-of-house and back-of-house environments to monitor temperature (frozen, refrigerated, ambient, hot-holding) in all types of equipment (walk-in refrigerators and freezers, under-counter coolers, showcase units and sandwich lines)  to continuously and wirelessly monitor temperature and send alerts if the proper temperature is not maintained.

Data gathering can also be extended to incorporate digital task management capabilities to replace traditional Hazard Analysis and Critical Control Points (HACCP) manual logbooks and simplify daily restaurant tasks. Organizations can streamline manual operational checklists and provide insight to managers on how well their teams are adhering to restaurant guidelines.

Restaurants now have an important tool to address the two sides of food safety—prevention and traceability. Additionally, through capturing larger data sets, restaurants can move from anecdotal guesswork to implementing data-based best practices. The ingredients are now in place for restaurants to offer the highest levels of food safety and quality that the industry has ever enjoyed.

Sonny Perdue, USDA

Trump Names Sonny Perdue to Head USDA

By Food Safety Tech Staff
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Sonny Perdue, USDA

This morning President-elect Donald Trump named Sonny Perdue, former governor of Georgia, to lead the USDA. The new agriculture secretary grew up on a farm in Georgia, has a doctorate in veterinary medicine, and owns the firm Perdue Partners, LLC, a global trading firm specializing in exporting U.S. goods.

His farming experience will be seen as a plus by many folks in the agriculture industry. However, the selection of Perdue also means there will be no Latinos in Trump’s Cabinet (this hasn’t happened since the Reagan administration).

Key issues in the agriculture sector that Trump’s administration will need to address include the 2018 farm bill, immigrant labor, the decline of farm income, and the Trans-Pacific Partnership.

FSMA, One Year Later: Top 5 Things We’ve Learned

By Erika Miller
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Now that the first of the FSMA compliance dates have passed, let’s look back at the past year of training new PCQIs, their questions and concerns from classes as well as the perspective from our FDA friends (yes, really!) who attended our workshops. We have learned so much, it is hard to narrow it down to only five things—but if we look at the issues that arose, the following five proved to be recurring themes throughout 2016.

5. Don’t Scrap Your Current Plan

Many clients have approached us and said they were planning to throw their current food safety and/or HACCP plan in the trash and start from scratch. Please don’t do this! Companies that care about quality and food safety already have effective quality management systems in place. It would be a disservice to the company and the general public for all these time-tested plans to go straight into the bin. It is more realistic to take a look at the current system in light of the new regulation and ask yourself if there are any gaps that can be addressed. This brings us to the next point.

4. Education Is Key

A compliant system cannot be developed without an understanding of the requirements. Although FSMA is derived from the basic principles of HACCP, there are key differences, and not all of them in the direction of less regulation. It is important to understand not only the updated Good Manufacturing Practices and Preventive Controls for both Human and Animal food, but also the Foreign Supplier Verification Program, Sanitary Transportation and the Produce Rule (if they apply). Although the FDA-recognized curriculum for some of these companion regulations have not yet been released, some independent training providers are offering workshops to help fill the gap while the FDA and FSPCA are working on the official curriculum. (Comment on this article for more information via email).

3. “You Must Evaluate If You Need It” Is Not the Same as “You Don’t Need It”

Some training providers have told their attendees that they can scrap many of their current systems because FSMA is less stringent than GFSI-approved schemes. Your certification body for FSSC 22000, SQF or BRC does not care one whit how stringent FSMA is (as long as you are compliant with its requirements, as local regulatory compliance is a key factor in GFSI approval). FSMA will not change expectations related to the GFSI-approved food safety schemes. It is also misleading to think that because FSMA is flexible, FDA regulators will not have expectations of excellence when they arrive at food processing facilities. This law gives regulators the power to take legal actions to address many infractions they have seen over the years but have been powerless to stop; the flexibility may well be a double-edged sword in that regard. Ensure that all decisions are based on data and records exist to validate any claims.