EDGARTOWN, MA, January 22, 2020 – Innovative Publishing Company Inc., publisher of Food Safety Tech, has announced that Frank Yiannas, deputy commissioner for food policy and response at FDA, will serve as the keynote speaker for the 2020 Food Safety Consortium Conference & Expo on October 21. The Consortium is the industry’s leading food safety event for networking and educational opportunities, and takes place October 21–23 in Schaumburg, IL (just outside Chicago).
“At last year’s Food Safety Consortium, Frank Yiannas spoke about the ‘sea change’ happening at FDA and the increased efforts on the part of the agency to drive more transparency and traceability. We look forward to his insights, as well as learning more about FDA’s progress on its initiatives, especially the New Era of Smarter Food Safety,” says Rick Biros, president of Innovative Publishing Co., Inc. and director of the Food Safety Consortium Conference & Expo.
This year’s Food Safety Consortium Conference & Expo features three breakout tracks: Food Safety, chaired by Angela Anandappa, Ph.D., founding director of the Alliance for Advanced Sanitation; Food Integrity, chaired by Steven Sklare, president of The Food Safety Academy; and Food Defense, chaired by Jason Bashura, senior manager, global food defense at PepsiCo.
Food Safety Tech publishes news, technology, trends, regulations, and expert opinions on food safety, food quality, food business and food sustainability. We also offer educational, career advancement and networking opportunities to the global food industry. This information exchange is facilitated through ePublishing, digital and live events.
About the Food Safety Consortium Conference and Expo
Food companies are concerned about protecting their customers, their brands and their own company’s financial bottom line. The term “Food Protection” requires a company-wide culture that incorporates food safety, food integrity and food defense into the company’s Food Protection strategy. The Food Safety Consortium Conference and Expo is an educational and networking event for Food Protection that has food safety, food integrity and food defense as the foundation of the educational content of the program. With a unique focus on science, technology and compliance, the “Consortium” enables attendees to engage in conversations that are critical for advancing careers and organizations alike. Delegates visit with exhibitors to learn about cutting-edge solutions, explore three high-level educational tracks for learning valuable industry trends, and network with industry executives to find solutions to improve quality, efficiency and cost effectiveness in the evolving food industry.
With the passage of the Farm Bill, there has been a great deal of interest from the food industry in cannabis-infused foods and beverages, which includes hemp and CBD. The Food Safety Consortium is co-located with The Cannabis Quality Conference & Expo, an educational and networking event for cannabis safety and quality solutions. Serving the Midwest market with a unique focus on science, technology and compliance, the Cannabis Quality Conference enables attendees to engage in conversations that are critical in finding solutions to improve regulatory compliance, quality, efficiency and cost effectiveness in a quickly evolving cannabis marketplace. Both conference programs run concurrently, thus, Food Safety Consortium registrants can attend any of the Cannabis Quality Conference presentations and vice versa. This year’s event takes place October 21–23 in Schaumburg, IL and is co-located with the Cannabis Quality Conference & Expo.
Last week’s seventh annual Food Safety Consortium brought together a variety of industry experts to discuss key topics around regulation, compliance, leadership, testing, foodborne illness, food defense and more. The following are just a few sound bytes from what we heard at the event. (Click on any photo to enlarge)
“The food system today, while it’s still impressive, it still has one Achilles heel—lack of traceability and transparency.” – Frank Yiannas, deputy commissioner for food policy & response, FDA. Read the full article on Yiannas’ keynote session
“A typical food company only has about 5% visibility into known supply chain threats.” – Ron Stakland, senior business development, FoodChain ID, Inc.
“For most of us, our supply chain is a big black hole. Why are we so fearful of technology? Is it the implementation itself? What if technology could help us solve some of those perennial problems? There are resources available to help us get there.” – ¬ Jeremy Schneider, business development director, food safety and quality assurance, Controlant
“The records tell the story of how well the facility is being managed. It’s the first thing the regulators are going to look at.” – Glenn Black, Ph.D., associate director for research, CFSAN, FDA, on validation considerations and regulations for processing technologies in the food industry
“We’ll see more robotics enter the food space.” – Gina Nicholson Kramer, executive director, Savour Food Safety International
“Changes are happening; you can choose to face it or ignore it. We’re at least 10 years behind on technology. Automation/technology is not a new term in aerospace, etc., but to us [the food industry], it is. We will get there.” – Melody Ge, head of compliance, Corvium, Inc., on how industry should prepare for the data-driven transformation occurring in the smarter era of food safety
It’s okay to risk and fail, but how are going to remediate that with your employee? The more learners practice in different scenarios, the less they rely on specific examples. [They] become more adept with dealing with decision making.” – Kathryn Birmingham, Ph.D., VP for research and development, ImEpik, on employee training
“As a contract lab with the vision of testing for foodborne viruses for about 10 years—it wasn’t until about three or four years ago that we had the test kits to turn that into a reality. We also didn’t have a reference method.” – Erin Crowley, chief scientific officer, Q Laboratories, on the viral landscape of testing in the food industry
“You have to be strong and you have to believe in yourself before you get into any situation—especially as a food safety professional.” – Al Baroudi, Ph.D., vice president of quality assurance and food safety at The Cheesecake Factory, on what it takes to earn respect as a food safety professional
“’See something, say something’ is likely not enough. We recommend that companies develop a formal detection program that includes management buy-in, HR and governance, and policy documents, formal training and an awareness program…While FDA focuses on the insider threat, we feel that using a broader mitigation approach works best.” – R. Spencer Lane, senior security advisor, Business Protection Specialists, Inc. on lessons learned from food defense intentional adulteration vulnerability assessments
“Food safety is a profession, a vocation, [and] a way of life.” – Bob Pudlock, president of Gulf Stream Search
Attend the Food Defense Plenary Panel Discussion at the 2019 Food Safety Consortium | Tuesday, October 1, 2019Today FDA released an updated version of its Food Defense Plan Builder in efforts to help companies comply with the International Adulteration FSMA rule. Version 2.0 of the tool includes the following sections to help food facility owners and operators in developing a facility-specific food defense plan:
Food Defense Monitoring Procedures
Food Defense Corrective Action Procedures
Food Defense Verification Procedures
The tool is for use on a computer, and FDA states that it does not have access to any content or documents used with the tool, nor does it track or monitor how the tool is being used. The agency also emphasizes that use of this tool is not required by law and its use does not mean that a company’s food defense plan is FDA approved or compliant with the IA rule requirements.
The original version of this tool was released in 2013. FDA will be conducting a demonstration of the Food Defense Plan Builder v. 2.0 during a webinar on October 10.
The 2019 Food Safety Consortium Conference & Expo kicks off on Tuesday, October 1 and is packed with two-and-a-half days of informative sessions on a variety of topics that are critical to the food safety industry. We invite you to check out the full agenda on the event website, but below are several event highlights that you should plan on attending.
Opening Keynote: Frank Yiannas, Deputy Commissioner for Food Policy and Response, FDA
Recalls Panel Discussion: Led by Rob Mommsen, Director of Global Quality & Food Safety, Sabra Dipping Company
Food Defense Panel: Led by Steven Sklare, REHS, CP-FS, LEHP. Invited Panelists include Jason P. Bashura, MPH, RS, Sr. Mgr., Global Food Defense, PepsiCo and Jill Hoffman, Director, Global Quality Systems and Food Safety at McCormick & Company and Clint Fairow, M.S. Global Food Defense Manager, Archer Daniels Midland Company
“Validation Considerations and Regulations for Processing Technologies”: General Session presented by Glenn Black, Ph.D., Associate Director for Research, Division of Food Processing Science and Technology (DFPST), Office of Food Safety (OFS), CFSAN, FDA
“Food Safety Leadership: Earning respect – real-life examples of earning and maintaining influence as a Food Safety leader”: Panel Discussion moderated by Bob Pudlock, President, Gulf Stream Search
Supply Chain Transparency Panel Discussion: Led by Jeanne Duckett of Avery Dennison
Taking an Aggressive Approach to Sanitation: Planning for a Contamination Event: Presented by Elise Forward, President, Forward Food Safety
Three Breakout Tracks: Food Safety Leadership; Food Testing & Analysis and Sanitation and Operations
Register by September 13, 2019 for a special discount!
View the range of content associated with the Food Safety ConsortiumThe 2019 Food Safety Consortium Conference & Expo attracts some of the most influential stakeholders in the industry. This year’s event, which runs October 1–3, will not disappoint, with several features that provide a maximum networking and educational benefit to attendees.
The following is a snapshot of just a few of the benefits of attending this year’s Food Safety Consortium:
The Food Defense Consortium Meeting. This pre-conference workshop is open to all participants of the Food Safety Consortium
FSSC 22000 North American Information Day. This pre-conference workshop takes place on the morning of Tuesday, October 1 and is open to all Food Safety Consortium participants
A complimentary Sanitation Pre-conference Workshop (Tuesday, October 1)
Keynote Plenary Session by Frank Yiannas, FDA deputy commissioner for food policy and response
Recalls panel led by Rob Mommsen, director of global quality & food safety, Sabra Dipping Company
Food defense panel led by Steven Sklare, president of The Food Safety Academy; participants include Jason Bashura, senior manager of global food defense at PepsiCo
Focused breakout tracks on food safety leadership, food testing & analysis, and sanitation and operations
The end of the year is always a time of reflection. At Food Safety Tech, it is also a time when we like to share with you, our readers, the most popular articles over the last 12 months. Enjoy, and thank you to our loyal and new readers, as well as our contributors!
The FSMA Intentional Adulteration rule (Mitigation Strategies To Protect Food Against Intentional Adulteration) requires companies that fall under the rule to implement a written food defense plan, identity vulnerabilities and establish mitigation strategies based on those vulnerabilities. This is new territory for FDA as well as for many companies in the industry—and for this reason, the agency has established a longer compliance timeline. However, that doesn’t mean companies should wait—the time to prepare is now.
Christopher Snabes, senior manager, food safety at the The Acheson Group (TAG) and Jennifer van de Ligt, Ph.D., associate director at the Food Protection & Defense Institute (FPDI) sat down with Food Safety Tech to discuss some of the challenges they see industry facing related to intentional adulteration and food defense.
In addition, TAG and FPDI are interested in gauging the industry’s level of readiness in this area and have put together the survey, Intentional Adulteration & Food Defense Industry Preparedness. We encourage you to take the survey. And don’t miss subject matter experts from TAG and FPDI at this year’s Food Safety Consortium as they discuss Food Defense: Lessons Learned from Recent Incidents + Key Steps to Mitigating Risks.
Food Safety Tech: Given the subject matter of the survey, what do you feel is the current preparedness level regarding compliance with the FSMA Intentional Adulteration rule?
Christopher Snabes: I see this from a variety of fronts. Some companies established food defense solely on the events of 9/11, putting initial food defense plans in place [that involved] fences, installing security guards and gates, and locking the outside doors. Some companies we’ve worked with feel this is sufficient enough to meet the IA rule, and that’s not correct.
TAG has assessed several companies that are in the process of conducting food defense assessments, and they’re doing them based on best industry practices, and preparing for the inside attacker and/or a terrorist getting into key production areas.
TAG has worked with some companies that are fully waiting for the second and third guidance documents from FDA to come out before they do the full food defense plan. We’ve worked with some companies doing a mix of the above—they’re not waiting for the guidance but are actively testing their plans and having an outsider test their vulnerability, and then they’re rewriting plans based on the findings. They’ll also update their food defense plans, once the second and third FDA guidances are released to the public.
We feel these are the most prepared facilities; there are not a lot of companies at this point, but they’re starting to pick up steam. At this point, I would say most companies are actively pursuing a food defense plan as well as beginning to test their vulnerability.
Jennifer van de Ligt: I agree with Chris and would add that in the past two years or so, there’s also been a shift in how the industry is viewing the Intentional Adulteration rule. Many companies currently have food defense plans based on the events of 9/11 and, for the first couple of years, as the new Intentional Adulteration rule was being written, there was still a heavy emphasis on “that should be enough.” I very rarely hear that now when discussing the Intentional Adulteration rule with our industry partners. I think companies are more prepared from an understanding perspective to move beyond perimeter security and guards to really think about the risks in the facilities that would come from people with legitimate access— what the rule defines as “insider attackers”. Although understanding is increasing, Chris is correct that different parts of industry are on different paths. Some just now understand that they have to do more, while others are well on the way on to looking at how they need to structure themselves internally and are already moving towards vulnerability assessments.
FST: Are you seeing company size play a role in the readiness level?
Join the Food Protection and Defense Institute and The Acheson Group (TAG) at the 2018 Food Safety Consortium for an interactive discussion as they explore recent food defense events, highlighting key components of the incidents relative to government interactions, FSMA regulations, brand reputation, financial interests, and public health response. van de Ligt: The larger companies thinking about a multi-international approach seem to be further along in the process. I think they started thinking about the vulnerability assessment, how they’re going to structure it in their company, and how they’re going to come to compliance because of the breadth and the scope that impacts them. But we’re also seeing, at least in our training, some of the mid-sized companies beginning to take action. I think again, they realize that even though they’re smaller, they’re going to need additional resources, and they might not have those resources in house, so it might take them a bit longer.
Snabes: In general I would agree with Jennifer. I think a lot of it is because they have additional resources, and they can leverage them across many facilities as needed. I don’t see as much action being taken outside the United States on the facilities that are importing into the United States. I think that’s just starting to ramp up. I’m also seeing very small businesses that aren’t required to follow the IA rule implementing this because they want to protect their brand.
FST: What challenges are you seeing companies experience in understanding food defense, IA, and the appropriate preventive actions they should be taking?
FSMA Checklist: Intentional Adulteration ruleSnabes: Just understanding how the rules can apply to the business. For some companies, that’s still a challenge. Other companies, like the large ones, get it. Other small- and mid-sized companies are still trying to figure out how it applies to them. After that, the challenge is realizing there are expenses involved. For example, they have to install key fobs, cameras in critical areas, etc. They also have to realize they can meet the IA rule by not spending an exorbitant amount of money. For example, within a budget there are things companies can do without having to spend a lot of money, such as food defense awareness training.
Another challenge is educating all workers in food defense; enforcing the food safety culture within the facility and the idea that their job can be at risk. They have to realize that if they don’t recognize an individual inside the premises, or if something is out of place in a critical area, they need to inform their supervisor. If they see something, they need to say something—and ensure that the intentional adulteration is not taking place.
Educating employees is the least expensive way to invest in food defense, and it is the most effective. However, this can be a challenge for the companies that, for example, have a high turnover rate—if you have a lot of employees coming in and out, that means constant training, enforcement and re-educating. We see quite a bit of companies with a large turnover rate.
van de Ligt: I agree with those points. In our training, we also talk about food defense culture and how it needs to be supported across the business, similar to the way food safety culture is already in many of our businesses, and how to incorporate food defense awareness training, and on-boarding and refresher training.
The other challenges I see is that once you get to the understanding of what needs to be done and you get the buy in, there are some logistical issues at some of the companies—from big to small. Some companies are struggling with understanding which part of the business should be responsible for this (the food safety group, the security group, etc). Because we are talking about legitimate access and who is responsible for putting the plan together: How do these groups that may not have worked closely within the bigger companies now create that shared collaborative environment?
At the smaller companies, where they may not have that breadth or resources, now you’re asking a specialist in one area to pick up a completely different expertise and discipline. With a food safety and quality person, part of their job may be supply chain and sourcing, and now they also have to learn food defense. How are they managing and balancing all the different FSMA rules in their portfolio—because you have one person actually thinking about the breadth of them all. This presents a challenge to the logistics of implementation.
The other challenge I see is that FDA has done a really good job in providing input, guidance and listening sessions, and has been open and available to answer questions—more so for this rule than any of the other rules that I’ve watched go through industry. However, with the guidance being published so close to the compliance date it presents a challenge—companies that are waiting on the guidance will have to comply very quickly without the best understanding on what FDA’s thoughts are—because they’re waiting on the pending guidance.
FST:What steps should companies take to mitigate the IA risk?
van de Ligt: I have three action items for every company to take.
Read the IA rule, including the preamble if they haven’t. There’s a lot of information there that will help them understand the mindset and how the IA rule came about.
Read the guidance document when it comes out. The first guidance contains many clarifying examples that will help understanding and implementation.
Train the key people who are going to be responsible for writing the food defense plan and all employees on food defense awareness.
There are resources out there, whether it’s talking with FDA or coming to a sponsored training, for folks to get assistance in understanding and interpretation, and it would be great for them to take advantage of it.
Snabes: I agree with those three points. In general—do an FDA food defense assessment of your facility. Look for and concentrate on the key activity types that are critical. At least get a list of what areas are going to be the ones you have to mitigate. For example: The offloading of liquids, open vats, hand applied additives, etc. The most important thing I suggest doing right away is food defense awareness training for not just the supervisors, but all the employees—everyone from receiving to shipping to supply chain, etc. Everyone should be aware of the importance of food defense training and how their job depends on it.
In general, with food defense or IA—the rule is a brand new concept to FDA. It’s something they never tackled before. Because of that, there is going to be a longer time of educating before regulating. FDA is going to bend over backwards to work with companies so they understand how this rule is going to be implemented.
Any company out there can have a “strong employee” who wants to cause intentional adulteration, so the time to plan for that is now. Don’t wait for the rule to come into effect before you start planning.
As we look to 2018, the need for food defense activity remains. Increased adulteration incidents in 2017, consumer purchasing trends and FSMA rules implementation drive this need and the work necessary to complete it in 2018.
Intentional Adulteration of Food. It was evident that intentional adulteration of food did not diminish over the past year and likely increased. Adulteration cases of spices with undeclared ingredients to extend the product or boost color were documented. Terrorists plans and food adulteration tests were uncovered and publicized. In Germany, a man threatened to put antifreeze in the nation’s baby formula supply chain. And disgruntled employees continued to adulterate food to get revenge on their employer or co-workers. Given the complexity of our food system and the limited transparency of supply chains from farm to fork, those willing and able to adulterate will continue to do so in 2018.
Consumer Demands. Look in your local grocery aisles and you will find an ever-increasing section of “freedom foods”. These are foods that claim to be free of something whether it be gluten, lactose, pesticides or GMOs. With increasing frequency consumers are also asking questions about the sustainability and agriculture practices of the food they buy. How have the oceans been fished? Are my eggs from cage-free chickens? Does the food I buy protect the environment. Based on current trends, consumers will continue to spend their food dollars on organic, free-of, and sustainability produced food. This means food defense needs to have a keen eye on where fraudsters could adulterate products representing these food trends.
Company Food Defense. Two things have increased in the requests we are getting from companies: New incidents and the nearing deadline for compliance of the FSMA Intentional Adulteration (IA) rule. First, adulteration incidents that affect your product or the ingredients you use changes the lens you see food defense through. Even an adulteration in an ingredient or product similar to yours makes you look twice at how protected you are. With the continued incidents, companies are taking a hard look at how they are affected. Second, food companies have completed their work to prepare for the early FSMA rules such as Preventive Controls and Foreign Supplier Verification moving their attention to the next rules. The IA rule compliance dates begin in July 2019, and we anticipate increased activities, questions and food defense efforts in 2018.
As you can see, there is a nexus of need to accomplish defense work in our food system. Perhaps 2018 will be “the” year of food defense where individually and collectively we close vulnerability gaps.
Agent detection to identify contamination of food products is required in food safety and defense programs. Detection typically involves laboratory methods or technologies, such as biosensors, that are used in close physical contact with food products. While the field of food protection has benefited from the development of novel agent detection methods in recent years, the challenge of determining which food products to test remains. The sheer volume of food produced within and traded across U.S. borders makes agent detection a daunting, time-consuming and expensive task. The decision of when to utilize detection methods depends on the risk of a particular product being contaminated. Contamination may be unintentional or intentional, including economically motivated adulteration (EMA).
The risk of contamination fluctuates over time and is a function of several factors. Risk depends on the biochemical makeup of the product, supply chain characteristics such as complexity and transport distance, and a wide range of natural or manmade events that may disrupt supply and potentially incentivize intentional adulteration. This is particularly true in the case of EMA. Events include but are not limited to natural disasters that destroy or reduce the usual supply of an ingredient, political instability that disrupts usual trade patterns, interruptions of routine food safety inspections, and market fluctuations that impact global prices. While data exists to monitor these risk factors of contamination, optimal use of this information by government and private industry is hindered by several challenges. For example, valuable data often exists across multiple data systems with data across systems appearing in inconsistent formats. In addition, the amount of data that must be reviewed to find a signal within the noise is frequently overwhelming.
To address finding signals within vast quantities of data sources and systems, the Food Protection and Defense Institute (FPDI) developed technology to curate and help make sense of this data. With support from both the FDA and the Department of Homeland Security, FPDI developed FIDES or Focused Integration of Data for Early Signals to perform “horizon scanning” of food system disruptions in support of food protection efforts, including agent detection. FIDES was designed to help users forecast, monitor and identify food system risk factors and adverse food events. The FIDES web application fuses multiple streams of data from disparate sources and displays information in the form of an online dashboard where users browse, search and layer both dynamic and reference data sets related to food system disruption events. Examples of data currently included in FIDES are import refusals, global disasters, animal health alerts, food defense incidents, historical food safety incidents, import data, price alerts and reference data on food production worldwide.
Events in recent years illustrate the value of gathering intelligence and utilizing data related to food system risks to inform decisions regarding product targeting. Tsunamis, crop failures and disease outbreaks in humans and animals around the globe have threatened supply of products such as shrimp, spices, cocoa and eggs. When supply is disrupted, companies are often forced to quickly identify new and sometimes previously unvetted suppliers, including spot market purchasing. Likewise, supply disruptions often lead to price increases. As prices increase in the absence of adequate supply, concerns about EMA also increase. In both of these instances, the risk of product contamination—both unintentional and intentional—may rise and an increase in product screening or a change in agent detection methods may be appropriate.
For example, the 2014–2016 Ebola outbreak had a significant impact on West Africa, the primary production region for the world’s cocoa supply. Disruptions from the outbreak, including border closures and other trade interference, led to uncertainty about supply availability and prices. This raised concern for EMA, particularly given that many cocoa products are sold as powders, butters and liquors— forms that are more vulnerable to EMA than raw ingredients. As a test case, FPDI reviewed FIDES data streams during the peak of the outbreak. Real-time data on the outbreak was layered with data on global cocoa production and import patterns. Import refusal data from multiple global systems was assessed to identify any concerning patterns. Historical food defense and food safety incidents were also reviewed to determine which cocoa products had been previously contaminated. A similar approach could be used by the food and agriculture sector to guide decisions about targeted inspections—which product(s) and region(s) to monitor, which method(s) to use and which contaminant(s) to test. FIDES could support targeted screening and enhanced awareness of product risk profile that would allow the food industry to assure continued supply of authentic and quality products.
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