Being recall ready goes beyond checking off the boxes for meeting traceability requirements, qualification standards, or meeting auditing requirements for certifications. “It’s really a discussion that needs to happen from a business continuity standpoint within an organization so that should there be an issue, the team has actually talked through different strategies and ways of technically executing a recall within the organization,” says Ryan Gooley, recall consultant at Stericycle ExpertSolutions. During an interactive workshop at next week’s Food Safety Consortium conference, Gooley will lead attendees through recall scenarios and help them create a recall plan to address global needs, communications strategies, resource allocation, and business continuity requirements. Gooley recently sat down with Food Safety Tech to discuss the importance of mock recalls within the food industry.
Food Safety Tech: What are the most common mistakes food companies make in preparing (or not preparing) for a recall?
Ryan Gooley: One of the mistakes companies make is not having the discussion internally about a recall and whether they are ready and able to respond to and support a recall. Although it’s becoming less of an issue, people still don’t want to talk about recalls—they’re afraid if they talk about it, it will happen to them.
They also take their industry partners, whether supply chain partners or existing vendors, for granted.
Ryan Gooley is leading a session, The Multiplier Effect: How One Ingredient Can Lead to Multiple Recalls, at the 2016 Food Safety Consortium conference on Thursday, December 8 | Learn More In addition, companies miss the amount of effort and resources it takes to properly support a recall once a communication goes out. This specifically relates to class I or class II recalls that go down to the consumer level and involve press releases and media exposure.
In any industry, your resources are geared toward producing product and getting it into the market; it’s not the reverse of managing take-backs and returns, and communicating to customers. A lot of it comes down to resource allocation.
FST: What are the most important elements of a recall plan in the food industry?
Gooley: Traceability is huge. Most companies have a pretty good understanding of traceability as it relates to where they receive ingredients, where the ingredients go within their processes, and ultimately where they are distributed. Traceability is important, because you can’t initiate a recall if you cannot identify where the suspect product went.
The other part of the recall plan is testing the plan. Going through your recall plan and testing it pulls together the different departments that are responsible for supporting the recall exercise and effort within the company. Having conversations about who is responsible for what, the information [that should be] pulled, and who needs that information is really important for building the team. [It ensures that] should a company need to initiate a recall, the team members who are engaged and responsible have actually talked through the process and practiced. With more practice comes more efficiency and less chance for error or oversights.
Another important element of a recall plan is understanding your communication plan and communication crisis management plan. A lot of people talk about recalls as just identifying the product and notifying downstream what to stop selling, etc., but a lot of what goes into the recall plan is business strategy—how are you going to manage not only retailer and customer calls, but consumer calls and media calls? Who is responsible for communicating what, when and where? Do you notify just your impacted customer or do you notify your non-impacted customers? What type of communication and messaging do you have? When companies have not done a mock recall exercise, oftentimes they have not had these conversations, and they really struggle on the communications piece, especially because it needs to be drafted, approved, and communicated in a very short period of time.
Accreditation, certification, certificates…the structure that supports the third-party audit system can be very confusing! Further, an audit company offers a menu of audits: An audit to their own private standard, audits to several GFSI benchmarked schemes, and perhaps in the future, an “FDA accredited” audit. How do you know which one you need? How do you know which best prepares you for FSMA?
Jennifer McEntire spoke during the session, “Staying Ahead of New USDA and FDA Mandates for Controlling Pathogens in Food Processing” at the Food Safety Consortium conference. LEARN MOREUntil the compliance dates for the Preventive Controls rules pass, food manufacturers really only need to be compliant with good manufacturing practices (GMPs), from a regulatory standpoint. There are some specific audits that evaluate adherence to GMPs, but many companies wanted to take their food safety programs to the next level by demonstrating that they were implementing effective food safety management systems. Certification to a GFSI-benchmarked audit scheme (BRC, SQF, FSSC22000, IFS, etc.) was a primary means to show a commitment to food safety and the demonstration of exemplary programs. With the finalization of the Preventive Controls Rules, FDA is catching up. So how do the FDA requirements compare with the main elements of the GFSI Guidance Document?
Let’s evaluate the extent to which the scope of GFSI aligns with FSMA. In September, the Preventive Controls for Human Food rule was finalized, and the areas addressed within that rule constitute the bulk (although not all) of the topics covered by GFSI (GFSI covers additional areas for which FDA has not yet finalized rules, such as food defense and traceability). The question on everyone’s mind is, “If I’m certified to a GFSI-benchmarked audit scheme, am I compliant with the rule?” The answer is, “You’re probably in way better shape than someone who is not certified.” The reason is, regardless of which GFSI benchmarked audit scheme you choose, your facility will need to demonstrate, through fairly exhaustive documentation, the nature and validity of the programs that are in place, and the proof that those programs are followed day in and day out. FDA is looking for the same thing.
The Preventive Controls rules go beyond strict HACCP in that they require facilities to consider what has historically been termed the HACCP system. This includes programs that may not be critical control points (CCP) per se, but are critical to the safety of the food product. FDA identifies elements of sanitation and allergen control, as well as a supplier program, in this category. If you’re familiar with FSSC 22000, you might call these “operational prerequisite programs”. FDA will want to see how each and every hazard is evaluated to determine if it needs a preventive control, whether that is a traditional CCP or another control. For the most part, this is aligned with the GFSI benchmarked schemes, although some of the language may differ.
When it comes to the implementation of a supplier program, facilities should be aware that FDA’s requirements of such a program are much more explicit than most of the GFSI-benchmarked schemes. Even if the result is the same at the end of the day, FDA inspectors may be looking for companies to follow a fairly structured approach compared to a GFSI auditor.
To further complicate matters, FDA will be finalizing a program for the accreditation of third-party auditors. If an effective private third-party audit system exists, why is FDA adding another layer with its own form of audits (separate from inspections)? The answer lies with Congress, not FDA, as it identified two specific circumstances in which a special regulatory audit would be necessary. One situation is when a facility (or their customer) wishes to participate in the forthcoming Voluntary Qualified Importer Program. The second is if FDA has determined that the food poses food safety risks such that a facility wishing to export that food needs a certification issued by an auditor under this program. In neither case will domestic facilities be audited under this program; this program only applies to foreign facilities and only in very limited instances.
Since the rule and accompanying guidance documents related to accreditation of third-party auditors hasn’t been issued by FDA, it is premature to comment on how these audits will compare to those in use by private industry today.
So with the implementation of new rules from FDA, is there still a market for audits? Absolutely. From a very practical standpoint, FDA won’t be inspecting most facilities on an annual basis, and many private audits are conducted on an annual schedule. Plus, industry typically pushes itself further than regulations, which lag behind. Regulations can be viewed as the floor for expectations, but not the ceiling. Moving forward, we expect audit standards and private audits to become even more stringent and aggressive in terms of promoting the very best food safety practices. But beware, as history has shown us, a certificate is not a guarantee or indication of the ongoing quality of a plant’s food safety system. This is why FDA will not blindly accept that a facility has a favorable audit; regardless of the audit certifications you hold, FDA will still inspect you. That said, depending on the audit, it can serve as a credible certification of a food safety system in a plant and demonstrate to your customers your level of food safety commitment. And poor performance during an audit can find its way to FDA too, since in some instances the agency will have access to the conclusions of the audit and corrective actions taken in response to significant deficiencies identified during the audit. FDA initially proposed that serious issues uncovered during consultative audits conducted as part of the third-party accreditation of auditor program would be shared with FDA, and when audits are used as part of supplier programs, FDA will see how serious deficiencies in audits have been addressed. Be clear on why you are pursuing a particular audit, and take the program seriously. Audits should reflect your food safety culture, not serve as your motivation.
No one can contest the power of social media these days. As of August 2015, there were 2.2. billion users of social networks globally, with Facebook still by far the largest social network platform, at nearly 1.5 billion active users. Even if you aren’t on Twitter or Instagram, you have most likely heard or read about topics on them through other media. The influence of social networks to reach so many people makes them perhaps the most powerful communications tool available.
When it comes to a food safety crisis—whether a product recall or a report that a consumer has found a foreign object in prepared food product—you have to assume that messages about it will show up on Facebook, Twitter, Instagram, and even YouTube. From there, it is likely to end up on TV through newscasts as well. If your company maintains silence on social media, the public is likely to assume that you have something to hide, that your company is out of touch with public concerns, or that you just don’t care.
For these reasons, it is important that your food safety program be integrated with a social media crisis communications plan. That does not mean that your food safety team has to create the plan or manage the communications. These responsibilities should fall to your designated communications and public relations personnel. But it does mean that when a food safety issue with potentially harmful effects on public health arises, your food safety team should be aware of the plan and coordinate with the public relations team in the overall response.
The Positive Side of Social Media in a Crisis
The most obvious benefits of using social networks for crisis communications are speed and the large number of people you can reach. In a situation with potential to impact a large number of people, getting accurate information out to the public quickly is important to lower the risk to public health.
Other benefits may not be as obvious. By presenting a consistent and accurate message to a broad audience, your communications can help prevent or counter misinformation. A well-crafted social media post should be clear and concise, and thus is less likely to be misunderstood. That clarity and concision may help to avoid your message being reported as a “sound bite” out of context. And your message is more likely to be transmitted and repeated accurately, as social media users can share it in full.
Studies have shown that frequent communications from a firm can increase consumers’ intentions to comply with a recall effort and, when well handled, actually enhance consumer perception of a company. Thus, a social media crisis communications plan can contribute to action on the part of consumers and to maintain your company’s reputation.
The Downside of Social Media in a Crisis
As with any communications platform, social network communications do have a downside. The social nature of the platforms means that anyone with an account can post a response, and the potential for inaccuracies and outright hostility is very real. How to respond appropriately, and when not to respond at all, takes training and experience. That is the reason that crisis communications need to be handled carefully by the communications experts in your organization.
However, even if you are not the one posting the communications, having an understanding of the plan will help you as you carry out your responsibilities as part of the coordinated response to a food safety incident.
The Basics of a Social Media Crisis Plan
Although each social media crisis communications plan should be tailored for the individual company, the following some common elements of a good plan:
Clear assignment of roles and responsibilities. Who should post/comment/tweet on behalf of the company? All others should avoid commenting about the situation, even if using their own accounts, to prevent confusion and promote consistency.
Identification of the primary social media channel to use during the crisis (and of secondary channels). For example, will you post all relevant information to the corporate website, on Twitter, or on the corporate Facebook page? Picking one channel helps control the messages and makes it possible to funnel users of other social networks to one central source.
Message templates. One template should be for an initial message, indicating that your company is aware of the situation and will be issuing an official statement shortly. Twitter is a good channel to use for this message, but it is also appropriate for your corporate Facebook page. It is also a good idea to include the platform you will be using as your primary channel for communications. For example, the initial message for a company intending to use Facebook as the primary social media communications channel could be “@Company is aware of the [brief description of the situation] and will be issuing an official response soon. For continuing updates, please visit our Facebook page [url].”
Internal contact information (including for after-hours). You should know whom to alert and how to contact them regardless of the time, and under what circumstances you should contact them. This is key information to include in your food safety plan.
Clear procedures and responsibility for cancelling scheduled social media posts. During a crisis, the company needs to prove that situation is their top priority. Pre-scheduled messages about products can send the wrong message.
Guidelines on the frequency and content of messages. For example, measures the company is undertaking and actions consumers can take to avoid the contaminated item(s) should be posted. However, prematurely stating that preliminary measures will completely address the problem should be avoided; otherwise, if you have to increase the scope of corrective measures, your company could lose consumer trust.
Message approval procedures. Identify any specific type of message that requires approval by senior management. However, be mindful that a lengthy approval process for all messages will defeat the purpose for communicating through social media. (That’s one reason why templates are an important part of the plan, as they can be vetted and approved ahead of time).
Message review procedures. On the other hand, all messages should be reviewed before being posted to verify technical accuracy and to ensure clarity and appropriateness. During a crisis situation, you must adhere to the highest standards of professionalism.
Procedures for coordination with regulatory agencies. In the case of a recall, the FDA, CDC and USDA post information on their consumer food safety site at FoodSafety.gov. It is critical that the information provided to these agencies is consistent with messages posted on your social network channel(s).
Coordinating Response and Communications
So what should a food safety professional do regarding a social media crisis plan? Here are some first steps to help with a coordinated response:
Review your food safety procedures to see if procedures for crisis communications are included.
If not, check with your corporate office to find out if there is already a social media crisis plan. Ask to see it, and then update your food safety procedures to include relevant steps to keep the designated contact information updated. If yes, be sure the information in your response plan is current.
Make sure everyone is familiar with the plan and of specific roles and responsibilities. Ensure that employees are trained on what they should expect, and what they should and should not do, regarding social regarding social media during a crisis. Employees should understand that if they post information related to the crisis using their own social media accounts, it can lead to confusion and undermine efforts to protect the public health, as well as affect the company’s credibility.
During a crisis, provide timely and accurate updates to the communications team as appropriate. Be sure to check the designated channels to remain aware of what the company is communicating publicly.
Can Social Listening Lead to Better Crisis Response?
Several major companies in the food industry have found that social listening—the monitoring of social networks for mention of their company and its products—can help them identify a potential problem early. If a consumer post describes finding a foreign object in a can of soda, for example, the manufacturer can quickly reach out to that person through social media to request that the individual contact the customer service department to provide details. That way, an investigation can get underway to determine the accuracy and extent of the potential issue, and the customer can have their situation addressed more quickly and appropriately.
Monitoring the company Facebook page, Twitter ID and hashtags for product names can be a component of proactive measures for averting a larger problem. Better that you find out that someone posted that they found a rat tail in their soup than for you to be blind-sided by a report about it in traditional media.
Public health agencies in New York City and Chicago are also studying the use of social media to identify potential outbreaks of foodborne illnesses in their jurisdictions. They are working to determine if searching restaurant reviews posted on Yelp can help them identify foodborne health issues that have a common source. Results suggest that online restaurant reviews might help to identify unreported outbreaks of foodborne illness and restaurants with deficiencies in food handling.
Don’t Wait Until a Crisis
It is better not to have to learn about the power of social media once a crisis has arisen. Having an understanding of social media’s role in communications and of how your company can use it effectively can help improve your crisis communications efforts.
If you want the public to trust what you say on social media during a food safety crisis, one of the best strategies is to build a reputation as a trustworthy source of food safety information before a crisis occurs. Consider a social campaign around food safety topics, such as how to prepare food products safely, the difference between a sell-by date, a best by date, and an expiration date, and other topics that tell the consumers that you are attuned to their concerns around food safety. If you are considered a trustworthy source of food safety information, your communications during a food safety crisis are more likely to be believed. As a result, you are more likely to be able to protect both public health and your reputation should a crisis arise.
In a future article, we will discuss specific ways to integrate a social media crisis communications plan into your food safety incident response plan.
The WDS Food Safety Team also contributed to this article.
Today FDA announced that it submitted the final FSMA rules for produce safety, foreign supplier verification and third-party accreditation rules. As we await final publication by the Federal Register, here’s a look back at some of Food Safety Tech’s recent coverage related to FSMA issues:
No experience in our lives prepares us for working in a food manufacturing plant. It’s noisy, cold, hot, dry, wet, dark, or extra bright. It has a variety of aromas that are beyond description. And it has more rules about how to dress, personal hygiene and traffic patterns than can be committed to memory. Every day, frontline food workers make individual decisions that impact food safety, workplace safety, product quality, and operations. So inspiring employees to learn, apply and retain knowledge requires multiple touch points.
At this month’s Food Safety Consortium conference, Holly Mockus will moderate the session, “Gathering Data to Gather Data: Don’t Learn the Hard Way!” LEARN MOREAt most plants, employee onboarding is usually done through formal classroom training. Group training is a great way to learn in a focused setting and interact with an instructor and co-workers. But ensuring that the training is clear and easy to understand can be a challenge. A recent survey of frontline food workers by the Center for Research and Public Policy, Mind of the Food Worker, reveals that 39% of employees say that training is sometimes too complicated or difficult to understand. Learning must be contextually accurate to resonate with the learner, and alignment with the diversity of today’s frontline worker requires new approaches.
Ensuring employees learn, apply and retain knowledge requires multiple touch points because attention spans are getting shorter. According to the National Center for Biotechnology Information, the average attention span is now just 8.3 seconds. Training content has to be presented through different channels in order to stick in the employee’s mind and drive the required behavior.
Companies are increasingly using digital signage to show relevant and eye-catching visuals to reinforce the formal training. The content is more impactful when played at strategic times throughout the production day—continuous or too infrequent may cause the retention level to wane. The content also needs to be changed periodically. Truly effective digital content display will be managed effectively to get the biggest bang for the effort.
The Mind of the Food Worker survey found that just 43.2% of food workers rarely or never receive coaching from manager/supervisor. Figure courtesy of Alchemy Systems
Leveraging the supervisor and employee interaction through shift change meetings is another important delivery channel for training reinforcement. According to the Mind of the Food Worker survey, only 56.8% of workers said they receive coaching from supervisors. By providing supervisors with scripted huddle guides, they can effectively and consistently reinforce key messages. In addition, supervisors and managers who observe and provide reinforcement or correction individually to employees have found a winning combination that will strengthen and drive culture so that everyone will know the right thing to do every day.
Supervisors are the hub of the wheel that keeps manufacturing on the road and pushes the industry forward every day. Anything that can make life easier for the frontline supervisor will have a high potential for return on investment. Tablets are increasingly being used by supervisors to complete tasks in real time, as it eliminates the need to spend hours deciphering and following up on notes after a shift ends. This in turn gives the supervisor more time to spend on the floor coaching and reinforcing employees. The bond between supervisor and employee is the absolute core of the culture of each manufacturing plant.
The survey, Mind of the Food Worker, was sponsored by Alchemy Systems.
Many small companies are working with limited resources and as a result, employees wear a variety of different hats. As they look to begin the process of selecting a GFSI scheme, the process can be daunting. Where should they start? Which scheme makes the most sense? In an interview with Rick Biros, publisher of Food Safety Tech, Claudio Bauza discusses where small food companies can begin their journey.
At this year’s Food Safety Consortiumconference, don’t miss the “Ask the Experts–You Are GFSI Compliant. Now What?” The session takes place Wednesday, November 18.
“Over a period of time, things have changed for the corner suite, and many CEOs and presidents of corporations understand that with the media today and the way that FDA has improved its ability to focus on contamination, something needed to happen,” said Robert Garfield, senior vice president at SQFI during the recent “SQF in the Age of FSMA” webinar. “It’s not everything that we wanted…but it’s a rule that brings the regulations up to where they need to be in this century.”
GFSI leaders will be available during the Food Safety Consortium conference. On Wednesday, November 18, don’t miss the session, “The Role of Technology in Ensuring Accessible, Actionable Data to Tackle FSMA Compliance”. LEARN MOREGarfield discussed the role of SQF certification in FSMA compliance during part one of the 2015 GFSI Leadership webcast series. Hot topics included:
Foreign supplier verification program alignment
Building a food safety plan, including HACCP to HARPC migration
Being audit ready and record keeping requirements
Environmental monitoring
“Farm-to-fork” and safety controls
SQF scheme changes to align with FSMA
How SQF fills in the gaps in FSMA requirements
The next webinar takes place Friday, October 30 and covers the alignment of BRC certification with FSMA. John Kukoly, director of BRC Americas, is the featured speaker. Register here for the complimentary webinar.
If you watch the evening news or read the local newspaper, the chances are pretty good that you will read or see something about a food safety concern or incident.
An estimated 1 in 6 Americans fall victim to a foodborne illness annually.
While the American food supply is among the safest in the world, the Federal government estimates that there are about 48 million cases of foodborne illness annually—the equivalent of sickening 1 in 6 Americans each year, according to Foodsafety.gov. And each year these illnesses result in an estimated 128,000 hospitalizations and 3,000 deaths. Five types of organisms—Salmonella, Toxoplasma, Listeria, norovirus, and Campylobacter—account for 88% of the deaths for which the cause is known.
We watched from the sidelines when major retailers faced public scrutiny over their practices on safeguarding consumer credit card information when their websites were hacked. Today, consumer and regulatory interest in food safety are the new focus areas for the news media, especially in light of the Blue Bell Creameries Listeria and the Peanut Corporation of America (PCA) Salmonella outbreaks. Unlike consumer credit information, serious missteps in our industry can kill people, and in the case of PCA, can put you permanently out of business.
In 2008, peanut butter paste manufactured by PCA killed nine people and sickened 714 others, some critically, across 46 states and was one of the largest food recalls in American history, according to the CDC. Although still under appeal, PCA CEO Stewart Parnell was convicted and sentenced to a 28-year prison term for his role in knowingly shipping out salmonella-contaminated peanut butter. Parnell received one of the toughest punishments in U.S. history in a foodborne illness case.
In the Blue Bell case, a total of 10 people with Listeriosis related to this outbreak were reported from four states, with three deaths reported from Kansas, according to the CDC. Blue Bell pulled their products from store shelves on April 20, 2015. On May 7, the FDA released findings from inspections at the Blue Bell production facilities in Brenham, Texas, Broken Arrow, Oklahoma and Sylacauga, Alabama. The FDA reports highlighted serious problems across multiple sites.
Both cases shine a spotlight on what can happen if you don’t have an effective food safety management system (FSMS). So what makes up a good FSMS, and is it enough to keep you out of trouble? An effective FSMS is built on three elements: Good Manufacturing Practices (GMPs), Hazard Analysis Critical Control Points (HACCP) and a management system. Food safety issues are avoidable, and good processes and a strong culture within an organization make them more unlikely to occur.
Does your leadership recognize the importance of your FSMS? An effective FSMS should be established before a product incident or recall occurs.
Implementing a FSMS does not happen in a few months; it may take up to two years to establish one. No doubt, foundational activities need to be in place for factory operations. In addition to focusing on foundational elements such as making sure equipment is cleaned properly and procedures for allergens are implemented, the leadership team needs to make it clear that it is never acceptable under any circumstances to take shortcuts that could jeopardize food safety. This policy needs to be indoctrinated throughout the organization and thus does not happen overnight.
Underlying an effective FSMS are strong HACCP and GMPs, but food safety should always be the top priority for management and its employees, not share price, earnings or profit margin. Although financial performance is important, food safety must take precedence in the organization, and leadership at all levels needs to send that message loud and clear to all employees. In today’s environment, HACCP is pretty much mandatory from a regulatory standpoint and is an essential part of a FSMS. But the missing piece in many organizations is the support from the top—this is where culture becomes embedded in the organization.
The FSMS culture is the collective behavior from the organization around shared values and beliefs. The organization will follow the actions of leaders, not necessarily what they say—we all know actions speak louder than words. A good food safety culture is one where best practices are openly discussed, defined and rewarded. Food safety culture has become a buzz word and there needs to be a focus on making it come to life through a structured FSMS.
At this year’s Food Safety Consortium conference, Tim Ahn will discuss advancing food safety training and harmonization (November 19). LEARN MOREFood safety training is important not only for first line supervisors and operators, but also for senior managers and leadership, because they define the objectives and policies of the FSMS. What does it mean to conduct an effective management review? What does it mean to do an internal audit? What’s a good corrective action process? Training often misses the mark, because organizations fail to embed it correctly.
For FSMS to thrive, management must commit to the FSMS being a required way of doing things throughout the entire organization. A FSMS is most effective when it benchmarked against a proven standard and verified by an independent third party. Certification against a proven standard will reduce risk within your business.
Select your independent third-party verifier carefully. Do they have the resources and time, and do they know what they are doing? Do they add value to your organization? This is important since once you get certified, your journey starts and it doesn’t end. The value comes in two areas: Identifying risks and developing the appropriate control measures, and ensuring that the process drive continuous improvement in your organization. FSMS is focused on how continuous improvement applies to the management of risk and business operations.
The most effective way to establish an FSMS is to have leadership that recognizes its importance. The worst way is to have a recall or an incident, which draws attention to the fact that there is a problem and something needs to happen. In the case of Blue Bell, they probably understood the importance of food safety and thought they were taking the right actions. However, their management system led them to problems. FSMS must be independently verified against world-class standards to ensure effective performance.
A thorough auditor won’t look the other way and will find the problems. Call it as you see it–don’t be too soft when getting an assessment.
Companies can develop blind spots where they cannot see their own bad practices, and they become institutionalized over time. Fortunately, experienced independent third-party assessors can shine a spotlight on those bad practices. That is the true value in bringing in outsiders to look at your operations and culture to uncover those blind spots.
At PCA, their poor culture and actions to the problem sealed their fate. In some ways, this criminal case presented a wake-up call to boardrooms across America and highlights how badly leadership mismanaged matters. This case came to light in the context of the public complaining to the regulators that they were not doing enough following several highly visible food poisoning cases. A FSMS would have prevented these problems because the structure would not allow such bad decisions to be made and would have been verified by an independent third party that would test and check everything. A reputable third-party verifier would not miss poor GMP/ HACCP processes.
A good assessor can help a company understand what is really important and what is not so important when it comes to findings (i.e., context). We don’t waste a client’s time with insignificant issues and that is where the experience and judgment of the auditor becomes critical. Last year I met with a client and said, “you need to be checking for Salmonella in your environment—how do you know it is not there?” I pushed them into checking because I understood the changing regulatory environment. I came back a year later, and they had confirmed that regulators were interested in their Salmonella monitoring program during a recent inspection. As an auditor, you have to be confident enough to provide advice and context to the client in a way that is understood and accepted, and that helps to build trust.
With FSMA, the government can now take specific actions against companies. If I am plant manager or CEO, how do I know for sure that I am in compliance with the requirements? How do I know that I don’t have any of these potential issues? The only way to know for sure is to have the FSMS assessed. Just like a bank or publicly traded company hires financial auditors to assure everything is done correctly, companies need to audit their FSMS to ensure compliance. Get a process audit and ensure they drill down deep into the organization—that is where we find issues and gaps. A thorough auditor will find your problems instead of looking the other way. It is important to call it the way you see it and not be too “soft” when getting an assessment.
If I am the CEO, I want to know where those problems exist. Independent third party assurance is the best way to find out how compliant you are with regulations. No CEO wants to deal with the inevitable lawsuits and lost business impacts. At least with an effective FSMS, you can show a level of due diligence when the regulators show up at your doorstep and the culture is such that you want to address any problems.
We have entered an important time for the food industry with FSMA implementation and other food safety regulatory requirements in the United States. These new rules place an emphasis on management accountability, risk assessment and control of supply chains. The bar for due diligence has been raised and it up to all us to show that we have done everything possible, and the best way is with an effective FSMS.
It’s that time of year again: A time when Americans, both young and old, enjoy decorating pumpkins, dressing up in outrageous costumes, visiting houses haunted with ghosts and goblins, and consuming way too much sugar. And then there’s the classic favorite, the caramel apple. I’ve never been a huge fan of the sticky treat, but many Americans just can’t get enough it.
This year’s Food Safety Consortium conference features “Preventing Listeria Workshop: A Practical Workshop on Food Safety Controls” on Tuesday, November 17. REGISTER HERE. Last year caramel apples received a huge amount of negative press as a result of a deadly Listeria outbreak that was traced back to prepackaged caramel apples from Bidart Bros (Bakersfield, CA). In February of this year, the CDC closed its investigation, and provided the final stats: 7 dead and 34 hospitalizations throughout 12 states.
Now here we are, at the height of the season for apples and sweet treats, and concerns over Listeria in caramel apples are back in the media. The good news is that industry is proceeding with caution. The Wall Street Journal reports that Kroger Co. is taking unrefrigerated caramel apples off its store shelves following a recent study that cited a higher likelihood of Listeria growth on the products when at room temperature versus under refrigeration. Published by the American Society of Microbiology, the study, “Growth of Listeria monocytogenes within a Caramel-Coated Apple Microenvironment”, found that “insertion of a stick into the apple accelerates the transfer of juice from the interior of the apple to its surface, creating a microenvironment at the apple-caramel interface where L. monocytogenes can rapidly grow to levels sufficient to cause disease when stored at room temperature”. The researchers also advise that consumers purchase refrigerated apples or eat them fresh.
Although representatives from Kroger said they think the risk of Listeria contamination is minimal, they decided to take a cautionary approach. It’s reassuring to see companies step up and take proactive tactics to mitigating risks, especially when it involves protecting consumers against another potentially deadly outbreak.
How will FDA enforce the new FSMA rules? It’s a question that has been circulating throughout industry over the past few months, and it will be answered at this year’s annual Food Safety Consortium conference next month. Michael Taylor, JD, deputy commissioner for foods and veterinary medicine at FDA will deliver the opening plenary presentation on November 18, which will be followed by an “Ask the FDA” interactive town hall meeting. During the afternoon,
Roberta Wagner, deputy director of regulatory affairs at CFSAN
Roberta Wagner, deputy director of regulatory affairs at CFSAN will discuss FSMA implementation and FDA’s strategies for gaining and maintaining industry compliance with the new rules. The agency will also be participating in several conference sessions dedicated to the FSMA rules that will be finalized by November, including:
Foreign Supplier Verification
Preventive Controls in Human Foods
Preventive Controls in Animal Foods
Produce Safety
Third-Party Auditing
Voluntary Qualified Importer Program
During the event, USDA’s Food Safety and Inspection Service (FSIS) will also be answering questions related to regulatory compliance and food safety issues at a Small Plant Help Desk.
Frank Yiannas, vice president of food safety at Walmart
Beyond FSMA-related topics, the Food Safety Consortium conference will feature several concurrent food safety and quality assurance tracks, workshops and training programs in compliance, food manufacturing and operations, supply chain management, food labs, and foodservice and retail. Food Safety Culture is an especially hot topic right now, and the conference will address the practical ways to actually measure behavior and start taking action. Frank Yiannas, vice president of food safety at Walmart will deliver a keynote presentation, “Food Safety = Behavior” on Wednesday, November 18.
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