Tag Archives: Focus Article

Deirdre Schlunegger, CEO of STOP Foodborne Illness
Food Safety Culture Club

Motivating the Culture Shift

By Deirdre Schlunegger
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Deirdre Schlunegger, CEO of STOP Foodborne Illness

At the 2016 Food Safety Consortium, STOP Foodborne Illness will have a fundraiser to honor heroes in food safety. |December  6, 2016, 7–9 pm | LEARN MOREIn 2012 STOP Foodborne Illness established a relationship, which evolved into a partnership, with the California Leafy Green Marketing Agreement (LGMA) organization. On my first visit to LGMA, I met key staff members and observed a mock audit. We had good initial conversations. Scott Horsfall, CEO of LGMA, and I continued to talk and a second visit ensued, this time with individuals who had been ill with E-Coli from Leafy Greens. Everyone was a bit nervous, but it was a productive and even healing experience. We visited farms and processing plants, heard from farmers and shared a lovely meal outdoors with the farmers. On the last day, we sat in a room with tables configured in a large square and each person took turns introducing themselves, talking about why they were at the table, what roles they had in the leafy green business, and the visitors shared personal heart wrenching stories of illness and death from foodborne illness.  There was not a dry eye in the room during and after this encounter. Every farmer vowed to do everything possible to prevent pathogens from making their way into the market place. This was a profound experience for everyone involved.

The following year, Scott proposed that STOP Foodborne Illness and LGMA jointly create a video for training purposes. That project came to life in the summer of 2014. It is a video and a project that LGMA and STOP Foodborne Illness professionals are deeply proud of and love to share with others (the video comes in several versions and is available in Spanish). Scott and I continue to speak about the partnership and look for additional ways to collaborate.

Food safety is about collaboration and finding solutions and preventing illness and death from foodborne pathogens. This week I spoke with a mother whose daughter died a year ago from foodborne illness (not from produce). I told her that I so badly wish that we could have prevented her beautiful daughter’s death and vowed to continue this important work. We are not there yet: Each of us must be completely committed to getting to a place where we don’t hear these stories.  And we will get there by keeping the “why” at the forefront and continuing to develop critical strategies that reduce and work to eliminate the problem. Thank you to all who are dedicated to creating and sustaining a safe food supply and a special thanks to LGMA. You can see the LGMA video, “Video: The Why Behind Food Safety”, on our homepage.

Stephen Ostroff, FDA

Pathogens, Partnerships and FSMA: Where FDA Is Headed

By Maria Fontanazza
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Stephen Ostroff, FDA

This year is a big year for food safety at FDA. All seven of the FSMA rules have been finalized, and the first compliance date is right around the corner (compliance with the Preventive Controls for Human Food rule starts in September for large companies). Stephen Ostroff, M.D., just took the helm from Michael Taylor as the agency’s deputy commissioner for foods and veterinary medicine. And finally, FDA is taking a hard line in both improving the tools and methods used to detect outbreaks as well as working with the Department of Justice to prioritize enforcement actions against companies that introduce adulterated foods into the supply chain.

Yesterday Ostroff provided an update on FDA’s recent initiatives and its plan of action to achieve success in FSMA implementation and pathogen detection at the IAFP annual meeting in St. Louis. Ostroff highlighted several tenets of FSMA:

  • Keys to FSMA success will be dependent upon achieving high rates of compliance
  • Domestic and import parity
  • Education before and while regulating (establishment of training and education networks)
  • Taking a risk-based approach to inspection and planning
  • Partnerships are critical
Stephen Ostroff, FDA
FDA’s Stephen Ostroff will be the opening keynote at the 2016 Food Safety Consortium, December 7 in Schaumburg, IL. LEARN MORE

Industry can expect three more rulemakings as required by FSMA in the areas of lab accreditation, a reportable food registry and product tracing. In addition, FDA is working on guidances related to the preventive controls, produce, and foreign supplier verification program rules. “We’re tantalizingly close so stay tuned,” Ostroff said.

Expect to see more program alignment with the Office of Regulatory Affairs as well. The inspection and compliance staff will be trained as specialists and there will be horizontal integration of programs between field activity and agency headquarters. Although the next fiscal year will be a transition year, Ostroff is hopeful that changes that need to be made at the agency, along with program alignment, will be in place by fiscal year 2018.

Other notable actions at FDA over the past year include:

  • In response to the OIG’s conclusion that FDA’s food recall program is not efficient or effective, the agency is ramping up its use of the strategic CORE (Coordinated Outbreak Response and Evaluation) network in order to examine recalls that might not be moving as smoothly or quickly as the agency prefers. FDA is also leveraging greater application of whole genome sequencing (WGS).
  • GenomeTrakr network and WGS. More than 50,000 genome sequences have been added to the database (largely Salmonella). Ostroff called WGS a game changer that holds the opportunity to more quickly identify problems and detect outbreaks while they’re still quite small. In partnership with the CDC, FDA set up a successful module for WGS of Listeria and the agency hopes to expand the model for use with other pathogens.
  • Nutrition (Not just what consumers are eating, but how much of it): The move that declared partially hydrogenated oils as no longer GRAS with compliance required by 2018.  The agency also issued a final guidance on menu and vending labeling in May, issued levels for arsenic in infant rice cereal, made determination for folic acid fortification in corn/masa, made revisions to nutrition facts labels that takes effect in 2018, issued a draft guidance on voluntary sodium reduction, and will continue to exam the terms “natural” and “healthy”.
  • Genetic engineering. FDA approval of GE salmon following one of the longest reviews in the history of FDA (20-year review), along with issuing voluntary labeling guidance.
  • Monitoring antimicrobial resistance through NARMS  (National Antimicrobial Resistance Monitoring System). FDA will be collecting antimicrobial sales by species and, in cooperation with USDA, hopes to release farm-based data about antimicrobial use at the farm level.

Ostroff emphasized FDA’s strategic 10-year plan, released this year, pointing to public health as a first priority, maintaining partnerships as a key to success (including re-establishing overseas offices), continuing research as a foundation, and maintaining transparently.

Elise Forward, Forward Food Solutions
FST Soapbox

How to Build, Change and Mold Food Safety Culture

By Elise Forward
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Elise Forward, Forward Food Solutions

Food safety and quality professionals are change agents and problem solvers. It is what we do. The manner in which people within an organization respond to change, problems and opportunities for improvement is a reflection of the food safety culture of the organization. Does your organization celebrate when someone correctly decides to shut production down or put a product on hold? Obviously, it is always best to prevent any issues before they arise, but stopping a line to prevent bad product from being produced or catching out-of-specification product before it leaves the facility is better than continuing to produce and ship bad product. These events are often viewed as negative occurrences, and, therefore, many do not see the value of the Food Safety/Quality Assurance department.

Elise Forward will be speaking at the 2016 Food Safety Consortium, December 6–7 in Schuamburg, IL | LEARN MOREHow can we change this viewpoint and positively affect the food safety and quality culture of the organization? A few key factors have a great impact on the culture of an organization. People, systems, access to resources and opportunities for growth are all integral pieces of a stellar food safety culture. In this column, the first of a two-part series, we will explore how people build, change and mold the culture.

First and foremost, people are the number one asset and provide the greatest impact to change. Not only are personnel the eyes and ears of an organization, but they also provide the logic required to make good decisions. Computer technology is amazing, but it cannot fully replace the human ability to process the information. People need to be used to their fullest potential in order to obtain the greatest impact. The following are some ways people can be used to boost the food safety culture of an organization.

Everyone is involved in food safety. A team is always stronger than individuals. Everyone, from the C-suite to the third-shift person in charge of the employee refrigerator and taking out the trash, to the office staff that answers the phones and opens the mail, needs to have responsibility for food safety. In addition, contractors and subcontractors are not immune to providing a significant role in protecting the food safety of your product. All relevant staff must have the appropriate training to understand that what they do affects the food safety of the product as well as the entire facility. Having everyone trained means that many then share the food safety mentality and, therefore, there are stopgaps in the system. As with many issues, it is not one breakdown of the system that leads to a failure but a culmination of many breakdowns. People are still the strongest asset to food safety, so having multiple stopgaps (i.e., people), involved in protecting the process will help ensure that the product remains safe.

Executive responsibility. The responsibility of the overall food safety of products leaving the facility now lies with the executives, as seen by the recent cases involving Peanut Corporation of America, DeCosters and Jensen brothers. Executives and decision makers are accountable for the presence of or lack of appropriate food safety measures. Therefore, when making changes, executives need to understand that these are personal decisions that could affect themselves and their family, in addition to customer confidence as well as profits and losses. Questions such as, “What happens if their name is plastered on the evening news?” and “How will your customers, investors, consumers react if the company has a problem?” should be asked.

Evaluate any decision for food safety consequences. Food safety and quality is directly related to profits and losses. Any issue or change that arises must be evaluated to determine if there are any impacts to food safety. For example, the purchasing department must understand that the items purchased and used on the production floor impact food safety. Therefore, food safety should be on every agenda and part of every decision. This can be as simple as adding to the bottom of every agenda the question, “Is there any way that food safety will be impacted?” The C-suite members should be included in management meetings where additional food safety discussions occur.

Employee trust. Employees must be trusted to keep the product safe in order to safeguard the business and the products. It is human nature to take pride in the work that we are assigned and to strive for excellence. People feel rewarded when they are trusted and will continue to add value to the organization by striving for continuous improvement. This translates to greater attention to food safety and quality.

If an employee cannot be trusted, this person should not be on the payroll. The Food Defense rules specifically require a company to address intentional adulteration from an internal entity. To ensure quality, background checks should be completed on every employee, contractor or sub-contractor who has access to critical areas of the facility.

Food safety should be in every job description. Food safety is everyone’s job, so update job descriptions to include pertinent responsibilities to food safety. At a minimum, everyone should have the “See something, say something” responsibility in his or her job description, in addition to anything specifically related to his or her job. Likewise, it can be valuable to have an independent set of eyes to evaluate a system. Therefore, train and use all personnel that do not have a background in food safety and quality. Departments such as accounting, warehouse, maintenance and personnel should be trained to perform GMP and sanitation audits. Spread these tasks around and your systems will benefit. The people performing the tasks will take pride at being trusted with these important responsibilities and tasks.

While a company or organization may start in an undesirable situation, it is possible to change the environment. Remember, the people you work with are your greatest asset. Value these people; uplift, teach and coach them in the ways of food safety and quality. Your efforts will produce astounding results! In the second half of the discussion on food safety culture, we will discuss other facets that influence food safety culture.

Bill Bremer is Principal, Food Safety Compliance at Kestrel Management LLC
FST Soapbox

Managing GFSI Certification a New FSMA Requirement

By Bill Bremer
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Bill Bremer is Principal, Food Safety Compliance at Kestrel Management LLC

Compliance to FSMA requires companies to meet existing program requirements and new ones being published or face regulatory consequences. A part of FSMA also requires that companies follow established food safety plans, which includes GFSI certification.

With these changes, GFSI-level programs must integrate into an aligned Food Safety Management System (FSMS) and strategy. Key considerations include sustainability, multi-year planning, effective organizational structures and expectations, well-defined roles and expectations, compliance, and business objectives.

The value of GFSI certification depends on how the company uses its organizational resources to maximize return on investment, while meeting the changing FDA requirements. Effective management of a GFSI-certified FSMS can have a significant impact on FDA/FSMA compliance. The risk of not meeting established programs while implementing new FSMA programs must be measured, and attention must be given to addressing FSMA compliance, while maintaining established programs.

Complying with FSMA Food Safety Programs
The implementation of FSMA-compliant programs requires having an established GFSI FSMS and demonstrating conformance with one’s own policies. Programs must be maintained and improved as the FSMA requirements are developed and implemented. Each of the GFSI schemes has been vetted to meet a significant level of FDA/FSMA requirements—a key benefit to these industry programs.

Developing a compliant FSMS with proper alignment of your existing programs to FSMA must be assessed. For example, companies with more than 500 employees must include requirements in their programs for the FSMA Preventive Controls rule, which is set for compliance September 19, 2016. In this regard, registered food facilities must evaluate and implement preventive control provisions and meet the requirements by the approaching deadline. This requires effectively updating current programs, establishing key imperatives including cGMPs (Section 117), identifying a Preventive Control Qualified Individual (PCQI), and implementing a Food Safety Plan.

The following areas are all included under the FSMA requirements:

  • cGMP, Controls and Preventive Controls. Must be identified, modified, and implemented to further minimize or prevent the occurrence of hazards based on Section 117 requirements.
  • Food Safety Plan, Hazard Analysis, and HACCP. Companies must identify and evaluate changes in their existing programs to include FSMA Preventive Controls.
  • Qualified Individual. Must be trained with authority to oversee Preventive Control program aspects, developments and impacts.
  • Written Programs and Documentation. Up-to-date GFSI-level FSMS provides documented programs, procedures, and records for meeting requirements under FDA/FSMA.
  • Management & Monitoring. All controls, including under FSMA and existing GFSI-level, must be monitored, validated, and verified for effectiveness.
  • Management of Corrective Actions. Procedures including traceability response for addressing failures of procedures, GMPs and controls must be under management review and confirmed for prevention of adulterated food from entering commerce.
  • Recordkeeping. Records must be complete and accurate for all food production and safety activities and kept for two years, including the testing level verification of all programs under FSMA and GFSI-level programs.

Self-Diagnostic Assessment Tool

The following self-diagnostic assessment tool can help organizations better determine their current state of planning when it comes to GFSI-level programs meeting FSMA. To complete your own planning assessment, review your progress compared to the questions in Table I.

FSMA, GFSI
Table I. Kestrel Management’s self-diagnostic tool can help a company assess its level of FSMS and GFSI preparedness for FSMA compliance.

Get Compliance-Ready

Companies must have their existing food compliance and GFSI programs in good standing to comply with FSMA or face possible violations, fines and penalties under FDA enforcement. The questions in Table I will help companies identify the areas in which they need to focus attention. Kestrel can also help answer questions, provide input on solutions, discuss how to better manage GFSI certification—and change “No” responses into “Yes” responses that promote best practices for FSMA compliance.

Randy Fields, Repositrak
FST Soapbox

Sanitary Transportation Rule: Ignore at Your Own Peril

By Randy Fields
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Randy Fields, Repositrak

FDA posted the FSMA rule on the Sanitary Transportation of Human and Animal Food in April. The majority of retailers, wholesalers, suppliers and carriers will have one year to comply with this new rule. The sanitary transportation rule sets out to prevent practices that would introduce contamination risk during the transportation of food through the supply chain.

For retailers, wholesalers, suppliers and carriers, the final rule is really the sleeper regulation among the new FSMA laws. You probably have your HAACP plans and preventative control procedures in place, but do you have the necessary documents in place with your carriers to meet the FDA’s requirements?  And, are those documents easily accessible?

Under FSMA, you must address all FDA record inquiries within 24 hours, and these inquiries can go back two years, plus 12 months beyond the expiration of related service agreements. Failure to respond to an FDA records inquiry is considered a “prohibited act” and can land you in hot water with both the FDA and Department of Justice, which acknowledged they will enforce FSMA through civil and criminal penalties. That’s a game changer.

You are now required to ensure that transportation equipment does not cause the food it is carrying to become unsafe. You must also maintain adequate temperatures throughout your portion of the supply chain and prevent cross contamination. And, you must train your personnel in sanitary practices. All of these factors—processes and procedures, agreements and formal training of personnel—must be documented and made available to the FDA. Put simply, compliance with FSMA is proven through documentation because according to the FDA, if it is not documented, it did not happen!

So what’s the best way to comply with the new rules? Having the information on paper in filing cabinets simply won’t do. Can you imagine searching for specific confirmation that an employee received the proper training in a bank of file cabinets? Even with an efficient system, that could be like looking for a needle in a haystack. Collecting the information in spreadsheets is only slightly better, as it simply digitizes the disorganization.

Retailers, wholesalers, suppliers and carriers need to start their compliance process by reviewing and understanding all of the FSMA rules, guidance procedures and responsibilities. You ignore them at your own peril.

Then, consider automating your recording keeping system.  It is really the only way to efficiently collect and manage the documentation needed to comply with the new law.  When reviewing technology options, make sure you choose a system that is not only easy to use by frontline workers, but also provides sophisticated reporting and alerts to point out potential problems in real time. And, if possible, the solution should do more than just report on food safety activities. As long as you’re investing in a technology to meet FSMA requirements, you might as well implement a system that can potentially save money in other areas such as managing business or training documentation, new vendor approvals, or carrier optimization.

The bottom line is that the sanitary transportation rule will require that you devote additional resources to make the entire extended grocery channel more risk free for consumers and companies alike. And the best way to do that is to implement new technology that gives visibility to product transfers from point of production or processing to the point of purchase, and documents each step along the way.

Deirdre Schlunegger, CEO of STOP Foodborne Illness
Food Safety Culture Club

We Know the Why

By Deirdre Schlunegger
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Deirdre Schlunegger, CEO of STOP Foodborne Illness

Food safety culture is not just a catchy phrase or the right thing to say. It is the right thing to embrace and the right thing to implement. But how is it achieved? It is relevant to start with understanding “The Why” behind food safety. Why is it important?  Do people really get sick and die? Why does that happen, and what is our role in preventing it?  How do we integrate aspects of FSMA with a culture that embraces a robust food safety culture, and how do we create passion around the culture?  I continue to address this issue, because at nearly every meeting I attend, in committees in which I serve and in simple conversations with colleagues, I hear the frantic voices of those who have so much to do, results to produce, bosses to please, and staff to supervise, and the why behind food safety is rarely mentioned.

STOP Foodborne Illness, Why Behind Food Safety
We need to truly understand the “why: behind food safety.

I speak to and read about individuals daily who have been sick or lost children or parents to this preventable problem. I see the photos of their children and hear about their loving attributes, yet this aspect is often neglected in the equation of the busy lives of those involved in growing, producing and distributing our food. I get it—who wants to talk about the problem when there is a product to promote and sell? But in reality, the only reason any of us live this frantic life with a long to-do list is because people get sick and die from foodborne illnesses, and because it is our job to do what we can to prevent the illnesses. And while consumers can practice safe food handling, there is nothing they can do about Salmonella in peanut butter, or Listeria in ice cream, cantaloupe or caramel apples. Let’s start the conversation of HOW to change and sustain a strong food safety culture and include the why as our rationale in the conversation.  STOP Foodborne Illness is interested and will devote more time to the how, and I hope you will join us in this conversation and endeavor. I would love to hear your thoughts.

Next-Generation Sequencing Targets GMOs

By Maria Fontanazza
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As the movement among consumers for more information about the products they’re purchasing and consuming continues to grow, the food industry will experience persistent pressure from both advocacy groups and the government on disclosure of product safety information and ingredients. Top of mind as of late has been the debate over GMOs. “Given all of the attention on GMOs on the legislative side, there is huge demand from consumers to have visibility and transparency into whether products have been genetically modified or not,” says Mahni Ghorashi, co-founder of Clear Labs.

Mahni Ghorashi, Clear Labs
Mahni Ghorashi, co-founder of Clear Labs

Today Clear Labs announced the availability of its comprehensive next-generation sequencing (NGS)-based GMO test. The release comes at an opportune time, as the GMO labeling bill, which was passed by the U.S. House of Representatives last week, heads to the desk of President Obama.

Clear Labs touts the technology as the first scalable, accurate and affordable GMO test. NGS enables the ability to simultaneously screen for multiple genes at one time, which could companies save time and money. “The advantage and novelty of this new test or assay is the ability to screen for all possible GMO genes in a single universal test, which is a huge change from the way GMO testing is conducted today,” says Ghorashi.

The PCR test method is currently the industry standard for GMO screening, according to the Non-GMO Project. “PCR tests narrowly target an individual gene, and they’re extremely costly—between $150–$275 per gene, per sample,” says Ghorashi. “Next-generation sequencing is leaps and bounds above PCR testing.” Although he won’t specify the cost of the Clear Labs assay (the company uses a tiered pricing structure based on sample volume), Ghorashi says it’s a fraction of the cost of traditional PCR tests.

The new assay screens for 85% of approved GMOs worldwide and targets four major genes used in manufacturing GMOs (detection based on methods of trait introduction and selection, and detection based on common plant traits), allowing companies to determine the presence and amount of GMOs within products or ingredient samples. “We see this test as a definitive scientific validation,” says Ghorashi. The company’s tests integrate software analytics to enable customers to verify GMO-free claims, screen suppliers, and rank suppliers based on risk.

Clear Labs, GMO, testing
Screenshot of the Clear Labs GMO test, which is based on next-generation sequencing technology.

Clear Labs isn’t targeting food manufacturers of a specific size or sector within the food industry but anticipates that a growing number of leading brands will be investing in GMO testing technology. “We expect to see adoption across the board in terms of company size, related more to what their stance is on food transparency and making that information readily available to their end consumers,” says Ghorashi.

David Chambliss, IBM Research
In the Food Lab

Scientific Breakthrough May Change Food Safety Forever

By David Chambliss
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David Chambliss, IBM Research

How safe is a raw diet? Could sterilizing our food actually make us more prone to sickness? Are vegans healthier than carnivores? In the last few decades, global food poisoning scares from beef to peanut butter have kept food scientists and researchers around the world asking these questions and searching for improved methods of handling and testing what we eat.

It’s been more than 150 years since Louis Pasteur introduced the idea of germ theory—that bacteria cause sickness—fundamentally changing the way we think about what makes our food safe to eat. While we’ve advanced in so many other industrial practices, we’re still using pasteurization as the standard for the global food industry today.

Although pasteurization effectively controls most organisms and keeps the food supply largely safe, we continue to have foodborne outbreaks despite additional testing and more sophisticated techniques. The potential health promise of genomics, and the gut microbiome genetics and bacterial ecosystems, could be the key to the next frontier in food safety.

The scientific community is once again at the cusp of a new era with the advent of metagenomics and its application to food safety.

What is metagenomics? Metagenomics is the study of the bacterial community using genetics by examining the entire DNA content at once. Whole genome sequencing of a single bacterium tells us about the DNA of a specific organism, whereas metagenomic testing tells us about the interaction of all the DNA of all the organisms within a sample or an environment. Think of the vast quantity of genetic material in the soil of a rice patty, a lettuce leaf, your hand, a chicken ready for cooking, or milk directly from a cow. All of them have thousands of bacteria that live together in a complex community called the microbiome that may contain bacteria that are sometimes harmful to humans—and possibly also other bacteria that help to keep the potentially harmful bacteria in check.

Metagenomics uses laboratory methods to break up cells and extract many millions of DNA molecular fragment, and sequencing instruments to measure the sequences of A’s, C’s, G’s, and T’s that represent the genetic information in each of those fragments. Then scientists use computer programs to take the information from millions or billions of fragments to determine from what bacteria they came. The process is a little like mixing up many jigsaws, grabbing some pieces from the mix, and figuring out what was in the original pictures. The “pictures” are the genomes of bacteria, which in some cases carry enough unique information to associate a given bacterium with a previously seen colony of the same species.

Genomics of single bacterial cultures, each from a single species, is well established as a way to connect samples of contaminated foods with reported cases of foodborne illnesses. With metagenomics, which essentially looks for all known species simultaneously, one hopes to do a better job of early detection and prevention. For example, if a machine malfunction causes pasteurization or cleaning to be incomplete, the metagenomics measurement will likely show compositional shifts in which bacterial phyla are abundant. This can make it possible to take remedial action even before there are signs of pathogens or spoilage that would have led to a costly recall.

Up until now, keeping food safe has meant limiting the amount of harmful bacteria in the community. That means using standard methods such as pasteurization, irradiation, sterilization, salt and cooking. To determine whether food is actually safe to eat, we test for the presence of a handful of specific dangerous organisms, including Listeria, E. coli, and Salmonella, to name a few. But what about all the “good” bacteria that is killed along with the “bad” bacteria in the process of making our food safe?

Nutritionists, doctors and food scientists understand that the human gut is well equipped to thrive unless threatened by particularly dangerous contaminants. The ability to determine the entire genetic makeup within a food could mean being able to know with certainty whether it contains any unwanted or unknown microbial hazards. Metagenomic testing of the food supply would usher in an entirely new approach to food safety—one in which we could detect the presence of all microbes in food, including previously unknown dangers. It could even mean less food processing that leaves more of the healthful bacteria intact.

More than 150 years ago, Pasteur pointed us in the right direction. Now the world’s brightest scientific minds are primed to take the food industry the next leap toward a safer food supply.

FDA

FDA Finalizes Rule on Food Facility Registration

By Food Safety Tech Staff
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FDA

As part of FSMA implementation, FDA has announced a final rule, effective today, that will better protect public health by improving accuracy of the food facility registration database. The Amendments to Registration of Food Facilities will also help the agency more efficiently use its resources to conduct inspections and aid in a faster response to food-related emergencies.

The final rule adds provisions to the current regulations to codify certain provisions of FSMA that were self-implementing and effective upon enactment of the regulation, according to an FDA update. Provisions require:

  • Email address for registration
  • Registration renewal every two years
  • Registrations must have assurance that FDA will be allowed to inspect the facility at any time

Important dates:

  • Final rule effective July 14, 2016. Registrations must contain type of activity conducted at the facility for each food product category.
  • Requirement of electronic submission of facility registrations takes effect January 4, 2020.
  • As part of registration proves, food facilities must provide unique facility identifier (UFI) beginning October 1, 2020.

Go Beyond the Classroom to Improve Employee Performance

By Maria Fontanazza
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Employee training continues to be a hot topic as companies in the food industry gear up for FSMA compliance. Many are working with a much leaner staff and have several different generations of employees, many of whom absorb information in very different ways.

In a Q&A series with Food Safety Tech, Laura Nelson, vice president of business development at Alchemy Systems, discusses how training programs that may have historically been successful are no longer an effective means to educate today’s employees. “A vast majority of employees are doing what we ask and are doing it consistently. But the reality is that we have a subset of folks [who] aren’t doing that,” says Nelson. “I don’t think you can classroom train them to the point that they get it—I think some need that coaching and demonstration; they’re the kinesthetic learners that need to see you do it and then you watch them do it.”

Food Safety Tech: Where are the gaps in how food companies conduct employee education and training today?

Laura Nelson: It can be summarized in three areas.

1. Recognizing that the legacy training programs that food companies have is not effective. Companies are acknowledging that their historical training programs are not entirely effective in driving consistent behaviors. In [a recent] global food safety training [survey], we asked: “Despite our efforts in food safety classroom training, we still have employees not following our food safety program on the plant floor”. Over 60% said they agreed—yes, we still have employees not following our food safety programs. The survey involved 1200+ food safety professionals, so that’s a large number of folks acknowledging that their food safety training programs—largely classroom training—is not delivering the desired results and reducing inherent food safety risks.

There are so many things challenging the food industry and everyone is trying to manage these expanding expectations with their lean teams. The industry is changing dramatically—[from the perspective of] employee demographics, the business itself, pervasiveness of social media and exposure that it brings, and the different regulations—so a static food safety program established two, five or ten plus years ago is not going to address these changes.  But who has the time and resources to continually update content, embrace technology and apply the latest behavioral science to the instructional design of new training content?  Because of the lack of resources and time challenges, many in the industry are still trying to operate on their legacy training program. It might be old DVDs, PowerPoints, etc. —trainers are covering food safety, workplace safety and operational topics via PowerPoints in all-day sessions, sending around a sign-up sheet and ticking off their training compliance checkbox.  Training has to be improved and enhanced for many key reasons—whether it’s considering different cultures, updating languages, engaging millennials or focusing on those critical employee behaviors that present a risk to an individual operation.

2. Understanding that training expands beyond the classroom. The industry as a whole continues to think that classroom training is their training program and that once the classroom training is complete and [the employee is] on the operations floor, that the training and education job is done. The reality is, it’s not. There’s lots more training happening beyond the classroom. Understanding that we need to formalize the extension of the classroom training and manage the ‘plant floor’ training aspect is really important. The industry is starting to embrace this [concept]. Anywhere from formal coaching and mentoring by frontline supervisors to posters and digital signage and short reminders to monthly campaigns on key critical items around food safety. Companies are starting to embrace the power of this holistic approach to training, leveraging new and emerging technology and tools to optimize employee behaviors.

3. Most people are not making the connection between training effectiveness and the ROI, the return on the investment. They think they don’t have the time to make improvements—yet, if they carved out time routinely to assess and evaluate best training practices to make training more effective and implemented these new and proven strategies, then all of a sudden the time and resource question becomes less of an issue because now you’re delivering on things like a decrease in food quality issues or reducing [employees] turnover, decreased downtime, reduced GMP non compliances, etc. It takes some time to establish those related training metrics, but once you’ve done that and have ensured that your holistic training program is current and behaviors are being exhibited consistently, you start to have fewer operational issues, enhanced customer satisfaction and motivated, engaged employees.

In part II of this Q&A series, Nelson shares her insights on training strategies based on employee demographics.