Tag Archives: food safety culture

Frank Yiannas, FDA, Food Safety Summit, Food Safety Tech

Can We Make Progress Before the Next Food Safety Crisis?

By Maria Fontanazza
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Frank Yiannas, FDA, Food Safety Summit, Food Safety Tech

A recall or outbreak occurs. Consumers stop buying the food. Industry responds with product innovation. Government enters the picture by establishing standards, initiatives, etc. “That’s my thesis about how changes happen,” said Michael Taylor, board co-chair of Stop Foodborne Illness during a keynote presentation at last week’s Food Safety Summit. Industry has seen a positive evolution over the past 25-plus years, but in order to continue to move forward in a productive direction of prevention, progress must be made without waiting for the next crisis, urged the former FDA commissioner for foods and veterinary medicine.

The strong foundation is there, Taylor added, but challenges persist, including:

  • FSMA. There’s still much work to be done in establishing accountability across the board, including throughout supplier networks.
  • Lack of technology adoption. The failure to use already available tools that can help achieve real-time traceability.
  • Geographic hazards. This is a reference to the contamination that occurred in the cattle feedlot associated with the romaine lettuce outbreak in Yuma, Arizona. “We’re dealing with a massive hazard…and trying to manage the scientific ignorance about the risk that exists,” said Taylor. In addition, in February FDA released its report on the November 2018 E.coli O157:H7 outbreak originating from the Central Coast growing region in California, also implicating contaminated water as a potential source. “There are still unresolved issues around leafy greens,” Taylor said. “What are we going to learn from this outbreak?”

Taylor went on to emphasize the main drivers of industry progress: Consumers and the government. Consumer expectations for transparency is rising, as is the level of awareness related to supply chain issues. Social media also plays a large role in bringing consumers closer to the food supply. And the government is finding more outbreaks then ever, thanks to tools such as whole genome sequencing. So how can food companies and their suppliers keep up with the pace? A focus on building a strong food safety culture remains a core foundation, as does technological innovation—especially in the area of software. Taylor believes one of the keys to staying ahead of the curve is aggregating analytics and successfully turning them into actionable insights.

Frank Yiannas, FDA, Food Safety Summit, Food Safety Tech
Frank Yiannas is the keynote speaker at the 2019 Food Safety Consortium | October 1, 2019 | Schaumburg, IL | He is pictured here during at town hall with Steven Mandernach (AFDO), Robert Tauxe (CDC), and Paul Kiecker (USDA)

FDA recently announced its intent to put technology innovation front and center as a priority with its New Era of Food Safety initiative. “This isn’t a tagline. It’s a pause and the need for us to once again to look to the future,” said Frank Yiannas, FDA’s deputy commissioner for food and policy response during an town hall at the Food Safety Summit. “The food system is changing around us dramatically. Everything is happening at an accelerated pace. The changes that are happening in the next 10 years will be so much more than [what happened] in the past 20 or 30 years…We have to try to keep up with the changes.” As part of this “new era”, the agency will focus on working with industry in the areas of digital technology in food traceability (“A lack of traceability is the Achilles heel of food,” said Yiannas), emerging technologies such as artificial intelligence and machine learning, and e-commerce. Yiannas said that FDA will be publishing a blueprint very soon to provide an idea of what areas will be the main focus of this initiative.

Adam Serfas, R.S. Quality
Food Safety Culture Club

Step Back and Assess Your Food Safety Culture

By Adam Serfas
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Adam Serfas, R.S. Quality

Fostering a strong food safety culture is one of the most important things those in leadership in the food manufacturing and processing industries can do. Whereas laws dictate the food safety regulations to which food manufacturers and processors should adhere, facility food safety and color-coding plans dictate how those regulations should be followed, and it is the inherent culture of the facility that ensures these guidelines and procedures will be followed. A facility’s culture is made up of the shared values of the company, the unwritten norms—good and bad—that ultimately influence the behavior of those in the company. It most often stems from those at the leadership level as they set the tone and expectations for the organization.

Most importantly, however, is the understanding that culture is fluid. Be-cause it is not defined but rather just is, a culture can morph over time in a ripple effect manner. If those in leadership begin to place a higher emphasis on food safety, middle level managers will take note and those sentiments—consciously or unconsciously—will be echoed to those lower in the company’s organizational hierarchy.

At the same time, the reverse is equally and, perhaps, even more likely, true. It’s often harder to do the right thing when it comes to food safety; there are extra steps involved to ensure the environment and tools used are clean, to check and double check the quality of the product and to communicate any concerns that may be encountered along the way. It’s easy to look at someone who takes shortcuts—particularly someone at a higher level than you—and decide that’s an accepted behavior. This can lead to devastating results quickly in a food processing or manufacturing facility where everything from the profit margins to the ability to employ workers to the legal standing of the company hinges on quality assurance.

That said, it’s important that those at the leadership level prioritize foster-ing a positive food safety culture by leading by example. Additionally, it’s vital to regularly glean a quick read of the room to stay on top of culture shifts. The following are some questions you can use to guide that check-in and identify potential red flags long before those worst-case scenarios have a chance to play out.

Would you describe the company’s food safety expectations to be one-size-fits-all notions or, rather, clearly defined rules tailored to different teams and job roles?

If you would put your company in the first category, it’s important you take some time to consider the procedures and guidelines put in place in your facility. Whereas you want company-wide buy-in for overarching food safety priorities, the job role will look very different for, say, someone on the packaging line versus the janitorial team. Within those teams, there should be a shared vernacular and routine specifically related to the job role they need to carry out. It’s unfair and perhaps a bit risky to assume that employees will know how to best carry out their job if “best” is never properly defined for them in training procedures.

Is there clear and consistent messaging that stems from leadership about a commitment to food safety?

The actions and words of those at the highest level of an organizational hierarchy set expectations for the entire company. It’s not only important that they communicate the importance of food safety to the company, but that they return to that conversation often. It’s a good idea to reiterate the significance of food safety considerations in vision and mission statement documents but to also bring it up during staff meetings, company-wide emails and annual reports. Food safety trainings should be held regularly as the more of-ten you highlight these expectations, the more they are thought about across the company. That consideration is what ultimately leads to action.

Do members of leadership take on an active role during food safety training sessions?

Again, we cannot stress enough the importance of those at the top setting the tone for a positive food safety culture by not only talking the talk but also walking the walk. Employees will take note if those higher up in the company who take time out of their day to partake in food safety training. It sends the message that this is indeed important to the company and therefore should be important to the employees.

Are food safety expectations communicated to employees via multiple communication outlets?

Just as a teacher in grade school aims to consider the unique learning styles of students, you should be mindful of the ways in which you are communicating with your team. Some people retain information best through auditory exposure, some are more visual learners and, for some, recall is best after hands-on activities. Consider the ways in which your currently communicate food safety expectations to employees and take note of any additional approaches you might need to take to best reach all employees.

Along those same lines, you should be mindful of additional considerations that might be necessary depending on the makeup of your staff. We recommend working closely with human resources to identify whether or not you should incorporate multi-lingual training procedures and how to best accommodate any employees with disabilities.

Does your company have an obvious method in place for raising concerns about food safety?

The mistake a lot of facilities make is focusing too much on what it looks like for things to go as planned and to overlook procedures for when things don’t go according to plan. If you asked any member of your team, they should be able to tell you the preferred method for reporting any concerns related to food safety. We recommend polling a few employees across different job roles to see if that is the case. If not, it’s vital you establish a protocol and clearly communicate that protocol to all employees. The easier the protocol, the more likely employees are to remember it and to follow through when necessary.

Bob Pudlock, Gulf Stream Search
FST Soapbox

Architect the Perfect Food Safety Team: How to Assess the Candidate

By Bob Pudlock
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Bob Pudlock, Gulf Stream Search

If there’s anything to take away from our three-part series on Architecting the Perfect Food Safety Team, it’s to be thoughtful and cognizant of what behavior and end results you’re looking for from your team.

When you enter the ASSESS phase, it’s important to arm yourself with questions that elicit responses that give you an indication of whether the person CAN perform well and who will thrive in your company’s culture.

Additionally, you want that behavior and end result to be synced and aligned against the broader organization’s mission.

As a director or VP, that’s an important distinction. A company that’s in M&A mode is much different than one that’s under pressure from a major customer to get in compliance with their supplier guidelines. The ideal candidate for one is not necessarily the best fit for the other.

Let’s say you’re a director or VP at a company who has just acquired a smaller company certified under a different GFSI scheme. For the next year to two, other integration efforts have been prioritized over folding the acquired company’s scheme into the parent company. For the foreseeable future, that means there will be a disconnect in some protocols, reporting and expectations between the parent and acquired company.

In this scenario, we brainstorm with our client and bring forward themes or dynamics that will be present.

  • Transition -> Change -> Ambiguity
  • Gray area -> Open loops not immediately resolved -> Discomfort
  • Acquisition / Integration -> power/influence/reporting structure transition -> Ambiguity

Two themes that come out of this brainstorm are “dealing with ambiguity” and managing discomfort associated with a GFSI certification or being downgraded as a priority while the company pushes other objectives forward.

For these themes, now we look to construct questions that elicit how one has behaved in past. We can also construct a hypothetical scenario to see how an individual would strategize and act moving forward.

As you look at potential hires into the organization at this stage, you’re going to be presented with a range of candidates that exhibit varying degrees of emotional flexibility.

Emotional flexibility is the ability to identify, assess and adjust responses to events, circumstances or triggers as they arise.

If a candidate in this scenario is rigid or exhibits a black and white “compliance or bust” mentality, that’s going to be a source of constant friction for the individual and those with whom they interact. During the integration efforts, that person is going to have a hard time calibrating their feeling of incompleteness or disconnect from the broader organization.

A candidate that exhibits a low degree of emotional flexibility will have a harder time “rolling with the punches” and will make those around them uncomfortable—they’ll push and work towards a set of expectations that is not consistent with the broader organization’s timeline. Now there is certainly an opportunity to manage that individual’s expectations, but the less we have to do that as leaders, the better—hence, the importance of accurately assessing and pegging the attributes early and often in the interview process.

So, how do we do that?

We advocate for what we call “layered” interview questions. In simple terms, it’s asking a question a number of different ways and in different contexts to elicit responses that offer an accurate prediction of how someone will react in the future.

The first question might be (one layer): How do you deal with ambiguity?

Another question would be: How have you dealt with a situation in the past where your boss was not on site but your plant manager took on day-to-day supervising and reporting? The hiring team can shade in specifics to make the scenario more realistic. The core of the question is to create an image of an ambiguous environment.

And yet another question would be (this is hypothetical): Let’s say you’re alone and have been put on the spot to solve this food safety problem. Your boss is not available for the next two days and you believe that there might be a disconnect between how the plant manager might solve the problem and how your boss would solve it. What would you do?

Asking a question three different ways will ferret out canned, stale answers. Additionally it will test a candidate’s ability to “connect the dots” between past experience and current/future challenges in the workplace. Asking these questions and observing the responses is a significant improvement over what’s typically done.

Taking it a step further will give you an even more accurate prediction of whether a candidate will thrive or perish in this environment. To test this, drill down further on the candidate’s responses to each layered question to the point where you determine what toll, if any, these situations took on them; in other words, how does ambiguity and discomfort in the workplace make them “feel”? Just because someone has experience in ambiguous climates or has managed “transitional” situations like a company’s M&A phase doesn’t mean they thrive on it. For some people, it’s a constant stressor, and if they’re not emotionally resilient, at some point they will break or wear down.

Drilling down to this level will give you a more accurate feel to how resilient and tolerant one will be in your company’s current and future culture. Additionally, you’ll determine whether or not their level of emotional flexibility will allow them to thrive or cause a constant stressor that will ultimately wear them down.

This is just one example of how to use a layered question. There may be three to four key themes that you want to dig into for each role in your organization. Pairing the layered questions (same question, multiple contexts) with eliciting feeling-based responses will give you an even more accurate predictor of who will thrive on your team. It will also isolate and disqualify individuals who have canned responses to interview questions and/or who can’t think on their feet, or struggle to tie past experiences to current state challenges.

This might “feel” like a lot of effort, but it’s an immense time and energy saver when you balance it against the aggravation, time and energy-suck you experience with a poor or mediocre hire.

Frank Yiannas, FDA, food safety

Frank Yiannas, FDA’s Deputy Commissioner for Food Policy and Response, to Speak at the 2019 Food Safety Consortium Conference & Expo

By Food Safety Tech Staff
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Frank Yiannas, FDA, food safety

EDGARTOWN, MA, Feb. 8, 2019 – Innovative Publishing Co., 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 to kick off the 2019 Food Safety Consortium Conference & Expo on October 1. The Consortium is the industry’s leading food safety event for networking and educational opportunities, and takes place October 1–3 in Schaumburg, IL (just outside Chicago).

What’s all the buzz about food safety culture? Watch the videoYiannas recently took the reins in FDA’s lead food safety role following the retirement of Stephen Ostroff, M.D. He was previously the vice president of food safety at Walmart and has been a strong proponent of elevating food safety standards within organizations and implementing a food safety culture.

This year’s Food Safety Consortium Conference & Expo features three breakout tracks: Cleaning & Sanitation, Food Safety Testing, and Food Safety Management. The call for abstracts is open until May 16.

About Food Safety Tech

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

The Food Safety Consortium Conference and Expo is a premier educational and networking event for food safety solutions. Attracting the most influential minds in food safety, the Consortium enables attendees to engage conversations that are critical for advancing careers and organizations alike. Visit with exhibitors to learn about cutting edge solutions, explore diverse educational tracks for learning valuable industry trends, and network with industry executives to find solutions to improve quality, efficiency and cost effectiveness in an ever-changing, global food safety market. This year’s event takes place October 1–3 in Schaumburg, IL.

Food Safety Tech, Food Safety Consortium Conference & Expo Announce Partnership with Alliance for Advanced Sanitation

Chipotle

Chipotle’s Aluminaries Project Focuses on Driving Change in Food Industry

By Food Safety Tech Staff
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Chipotle

Chipotle Mexican Grill has announced its first class of the company’s aluminaries project, which provides eight growth-stage ventures with resources to grow and drive positive change. Sponsored by non-profit organizations Chipotle Cultivate Foundation and Uncharted, each venture that is part of the seven-month accelerator program receives mentorship and coaching from industry leaders, and they participate in a five-day boot camp next month. Each member of the class of 2019 also receives free burritos for a year, and Chipotle will cater their office, according to a Chipotle press release.

The following ventures selected to participate in the Chipotle Aluminaries Project focus on a variety of areas in the food industry:

  • AdVoice
  • American Ostrich Farms
  • Asarasi
  • GrubTubs
  • ImpactVision
  • Novolyze
  • Rex Animal Health
  • Sophie’s Kitchen Plant-Based Seafood
Laura Lombard, IMEPIK
FST Soapbox

The Business Case for PCQI Training

By Laura Lombard
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Laura Lombard, IMEPIK

Beyond reducing liability or checking a regulatory box, investing in robust training can reap measurable business impact. The FSMA regulation requires that Preventive Control Qualified Individuals (PCQIs) “have successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or be otherwise qualified through job experience to develop and apply a food safety system,” as per Subpart C Section 117.180 (c) (1). Even if the person serving in the role of PCQI is qualified through job experience, FDA investigators will expect adherence to development and application of risk-based controls as contained in the standardized PCQI curriculum material or the alternative training allowed in the regulation.

Let’s face it: Our employees serving in the role of PCQI come from a spectrum of food safety plan experience. In addition, many are mentoring new members as Qualified Individuals on the food safety team. Others are building a whole new team from scratch. Team members may be specialized department heads or hold several titles and job duties within a manufacturing facility. Your PCQI is charged with overseeing the development and analysis of the food safety plan. The PCQI needs a team that has had consistent training in the language of the new rules and how to comply to support the PCQI’s charge.

Beyond meeting the regulation, companies should train at the PCQI level to safeguard a company’s product quality, brand and customer base. The fewer food safety-related claims you have, the more you save in costly recalls, loss of current or potential customers, and your brand’s reputation. A company with a robust safety culture has a competitive advantage over competitors who are more lax in their food safety and may suffer financially and reputationally from recalls and customer quality assurance complaints. In an era when customers are seeking more information about the food they consume, being a trusted food safety brand can make your company stand above the crowd.

In addition, consistent training can help with internal culture change and worker productivity. Working on hazard analysis and defining preventive controls requires that employees show critical thinking and problem-solving skills. Team members taking a curriculum with standardized material and consistent learning objectives can reflect together to identify and document gaps and corrections to practices or processes. They can quickly apply their learning for more accurate analysis of the components of the food safety plan. This is the true impact from investment in high quality instruction—motivating employees to learn updated food safety practices, change their behavior, and make more efficient and effective decisions to keep the quality and safety of your products. Well-trained food safety employees are a key factor in the protection of your customers, your company’s brand and the prevention of costly food recalls. The investment in training at the PCQI level is strategic on all fronts.

Doug Sutton, Steritech
Retail Food Safety Forum

What Attracts Customers to Your Restaurant, and What Could Keep Them Away Forever?

By Doug Sutton
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Doug Sutton, Steritech

The most recent numbers from Black Box Intelligence reflect what has been an ongoing trend for the last several months—improving same store sales. Sounds like great news, right? It could be, if another key metric wasn’t trending in the wrong direction.

Traffic numbers in restaurants are on a very steady down slope. In the third quarter, traffic was down 1.3%, and in October, traffic slowed down by another 2.2%.

The bottom line: Fewer people are dining out, but they’re spending more money.

For now.

Earlier this year, a survey of 500+ consumers asked them several questions about their preferences and experiences when dining out, as well as how they are making their decisions. The results could help restaurant operators adjust their customer experience to help bring more traffic through the door.

Despite Low Traffic Numbers, Americans Still Dine Out Frequently

Consumers have a lot of choice when purchasing a prepared meal these days: Restaurants or prepared foods from a grocery store? Dine in or take out? Fast food, fast casual, or full-service dining? The list goes on and on.

Sixty percent of the above-mentioned survey takers had dined at a restaurant, whether sit-in or delivery, once a week or more frequently. Another 25% reported doing the same two to three times a month.

But there is stiff competition.

Nearly 70% of the same group has purchased prepared foods (pre-made sushi, fried chicken, sandwiches, etc.) at a grocery or convenience store in the last month, indicating that the convenience of prepared foods is taking root in American life. This is an increase from a similar survey conducted in 2016, when slightly more than 65% of respondents said they had purchased a prepared meal from these sources.

What Are Customers Really Looking for in a Restaurant?

It should come as no surprise, that the driving factor for choosing a restaurant is the quality of the food. Respondents of this survey were provided a list of 10 areas of food safety and operational items to choose from and asked them to choose up to five that matter to them most when choosing a restaurant. Food quality and taste was the frontrunner by far, but restaurant cleanliness was second.

The third item on the list might surprise people. It wasn’t speed of service, or order accuracy, or service quality—while they all do matter to customers, it’s their previous experience with a location or chain that matters most.

When Customers Want Answers about a Restaurant, They Go Online

Social media and online reviews are playing an increasingly important role in how customers share their experiences with restaurants. The news about social media and online review sites is good for restaurants. If you’re doing a good job with your customer experience, your customers are willing to talk about it.

Respondents were extremely likely to use social media to share a restaurant experience on a social media platform such as Facebook, Twitter, or Instagram: 58%, said they would be very or somewhat likely to share a restaurant experience on social media. Even better news? Among those who fell into these two categories, nearly two-thirds say they are more likely to share a positive experience than a negative one.

The same holds true for online restaurant review sites, such as Yelp! And OpenTable. While fewer customers say they are very or somewhat likely to share their experience on an online restaurant review site, 49% of those who use review sites once again say that a positive experience is more likely to garner a review than a negative one. A full 66% of those who would be likely to use an online review site are likely to post a positive experience over a negative one.

Especially in the case of online restaurant review sites, this is important. Why? Because nearly three-quarters of respondents sometimes or often use restaurant review sites to help select where they will dine. Among those respondents, the online review carries significant weight in making their decision. Nearly 25% say online reviews are extremely or very influential in their dining decisions, while another 41% qualified them as moderately influential.

Delivery Problems and Who Customers Blame

Most restaurant operators know that there are big dollars to be had in the delivery space. But, the results of this survey indicate that restaurants have a bit of work to do.

Well over half (58.9%) of those surveyed had ordered food for delivery in the six months before the survey. Of those, nearly 30% experienced a problem with their order: Food being cold, wrong food, took too long to deliver the food, etc.

Here’s the important takeaway for restaurants offering delivery: Whether you manage delivery yourself or use a third-party delivery service, customers that experience problems place the fault squarely on the restaurant. Among those that experienced a delivery problem, 79.55% say the restaurant was to blame. That’s important because with third-party delivery service, the restaurant does lose some control over time it takes to deliver, food security, and more.

Foodborne Illness Outbreaks Have a Long-term Effect on Revenue

A 2018 study from the Johns Hopkins Bloomberg School of Public Health put a price tag on foodborne illness outbreaks for restaurants: Anywhere from $4,000 up to $1.9 million wrapped up in “lost revenue, fines, lawsuits, legal fees, insurance premium increases, inspection costs and staff retraining.”

The survey results discussed in this article show that the effects of a foodborne illness outbreak could linger for much longer than anyone truly realizes.

Nearly 30% of respondents said they would never eat at that location if they knew a foodborne illness outbreak had happened there; 24% said they would stay away for between one to six months, and another 18% said they would stay away for six months to a year.

The responses get more dramatic when chain restaurants have foodborne illness incidents. When asked if they would avoid eating at other locations in the chain if a single location was involved in an outbreak, more than 31% said yes, and a whopping 50% say maybe. The majority of respondents would give the chain a second shot, however. Only 19% say they’d never eat at any location in the chain again; more than half (over 58%) report that they would only stay away for between one month and one year.

If multiple locations of a chain are involved, the percentage of respondents that would avoid eating at other locations in the chain more than doubled to more than 68%. The bulk of those who would stop eating at other locations in the chain (31%) say they’d never eat at the chain again, while another 18.5% would avoid the chain for longer than a year. Another 23% say they’d stay away for six months to one year.

Customer Experience Investments Can Reap Big Rewards

This survey revealed plenty of other details about what customers are looking for—what cleanliness factors drive them crazy, what they think of health department scores (and which groups are really paying attention), what really turns them off when they read it in a review—but the real takeaway is this: Restaurants willing to invest in customer experience and a culture of food safety will reap the rewards from customers.

Laura Bush, Mike Taylor
Food Safety Culture Club

Is FSMA Driving Food Safety Culture?

By Lauren Bush, Michael Taylor
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Laura Bush, Mike Taylor

We were asked if we think FSMA is driving strong food safety cultures. Our answer is: Yes, but there’s more to the story.

For the dozens of impacted families that advocated for years on behalf of the thousands of individuals who are sickened and die each year from foodborne illness, FSMA marked a sea change in accountability for preventing foodborne illness. And it demonstrated that the consumer voice can impact a Washington legislative process often perceived as impenetrable to the everyday citizen. It’s also true, however, that even before FSMA, leading companies had been implementing modern preventive measures in response to unacceptable illness outbreaks and consumer demands. And food safety thought leaders were writing about food safety culture and working to drive it. We thus see FSMA reinforcing the movement to strengthen food safety cultures rather than being the primary driver.

After all, a genuine food safety culture is as much about people and motivation as regulation. The people in food companies driving strong cultures are motivated at a personal level by knowing the severe harm deadly pathogens in food can inflict on illness victims and their families. And they are motivated at a business level by the realization that the success of a food company hinges on continuously meeting high consumer expectations for food safety. These personal and business motivations are the original and continuing drivers of strong food safety cultures.

The 2011 enactment of FSMA was made possible by the coming together of consumers, food safety experts, and industry leaders who agreed that application of the best available science to prevent problems is the responsibility of everyone. This agreement and the enactment of FSMA powerfully demonstrated how far our food safety culture had come since the uphill battles of 25 years ago over accountability for keeping E. coli O157H:7 out of ground beef and mandating HACCP for meat, poultry and seafood. There is now consensus that adoption of modern preventive controls is a basic responsibility of everyone producing food.

Food safety culture is about much more, however, than simply doing the basics of preventive controls. It’s about staying on top of change in the hazards that occur in our food system and in the means available to minimize them, and being committed to continuous improvement in response to these changes. FSMA took the breakthrough step of making continuous improvement a regulatory requirement by tying the definition of preventive controls to current expert knowledge about how to control hazards and requiring controls to be updated regularly as new knowledge emerges. In this way, FSMA reinforces the movement to strengthen food safety culture and makes it everyone’s responsibility.

But it all still comes back to motivation. Stop Foodborne Illness has long contributed to that motivation by sharing the stories of individuals and families who have experienced devastating loss and lasting harm from foodborne illness. Companies seeking to strengthen their cultures invite Stop constituents to tell their stories in employee training sessions and meetings with senior executives. In this new era of food safety, we see great opportunity to expand collaboration with food companies to help drive the widest possible implementation of best practices, continuous improvement and strong food safety cultures. In this effort, FSMA is our important ally.

Bush and Taylor co-chair the Board of Directors of Stop Foodborne Illness, a non-profit consumer organization that represents victim of foodborne illness and their families.

Leonard Steed, AIB International
FST Soapbox

Unannounced Audits: Are You Ready?

By Leonard Steed
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Leonard Steed, AIB International

Many industries are moving toward unannounced third-party certification audits and the food industry is no different. If regulatory audits are unannounced, why is the food industry reluctant to adopt unannounced third-party audits? There are a number of benefits to unannounced audits—most importantly is their positive impact on a company’s food safety culture and how they prepare facilities to face FDA inspections.

Unannounced audits for food are required for many third-party certification audits. Typically, regulatory audits are always unannounced. Unannounced audits help demonstrate compliance and provide confidence to all stakeholders that your manufacturing sites are operating on the same GMP level, day to day, shift to shift, for every day your organization is manufacturing and distributing food products. With announced audits, companies tend to prepare for them before they occur. However, if there is a significant amount of difference between your sanitary operations prior to and during an announced audit versus normal operating conditions, you are sending your employees the wrong message.

Although there are differences between certification schemes, the GFSI third-party unannounced audits usually have a 40- to 60-day window in which the audit must be completed to allow the certification body to complete technical reviews and review corrective actions so that the certificate does not lapse. If it is a surveillance audit, then the audit is more likely to be truly unannounced, but a company still has the option of using blackout dates and the auditor will verify that the request was necessary. The bottom line is most companies have a certain timeframe when they know unannounced audits will occur.

Leonard Steed will present “Unannounced Audits: Are You Ready?” on November 14 at the 2018 Food Safety ConsortiumThe biggest impact on third-party audits is when the audit score is directly related to financial incentives for employees. This situation motivates employees to pursue activities to achieve the maximum score, not directly related to food safety. Activities may include significant audit preparation to eliminate or reduce GMP deficiencies, reduce or control the auditor’s access to records or areas of known plant deficiencies, “auditor shopping”, and to appeal any audit finding that lowers the score. Switching auditors or appealing findings can be legitimate tools to correct a system when auditors make errors in judgement or behavior. The activities to achieve the highest score should be reasonably governed because they could take away from the primary goal to operate in a food safe mode.

The goal of an internal audit program is to be compliant with regulatory inspections and third-party certification requirements and should therefore be risk-based. Determine what factors present the most risk to an organization and then align internal audits with those risks. At this point in time, being able to perform well on a regulatory audit should be a primary concern. Since the FDA and state regulatory agencies usually perform unannounced inspections, it would seem necessary to have your food safety plan, prerequisite programs and operations in a constant state of readiness to mitigate the risk of potentially unsafe food in commerce resulting in a recall.

One way to evaluate your food safety culture is to anonymously survey employees at all levels of the organization to gather information on attitudes and opinions about food safety and institute changes to improve your position. Another way is to initiate change by instituting unannounced audits on all manufacturing shifts and require participation by all departments in the audit function to move away from “QA-centric” food safety verification systems. The significant change is that all departments would be involved as an auditor and responsible for maintaining regulatory compliance. For some companies, the inclusion of all plant departments in the audit function has moved the needle in the goal to improve their food safety culture. To further define food safety culture in other terms, it could mean adhering to GMPs all the time, the importance of accurately completing and verifying food safety records, and fostering consensus between departments on the severity of food safety nonconformances requiring prompt corrective action.

Maintaining GFSI certification is an excellent way to achieve food safety requirements for compliance with FDA inspections. Although not specifically required by GFSI, another application of your internal audit program is to review your regulatory policy by performing a mock FDA inspection to identify any gaps in hazard analysis, identify preventive controls including the supply chain controls, accurately complete food safety records, and provide examples of corrective actions when preventive controls were not completed properly, and environmental corrective actions. If you decide to perform a mock FDA inspection of your facility, do not forget to include the FDA Guidance document criteria, as it is important to understand what the FDA expects to see when they are evaluating your implementation. Your internal audit program is a proactive program to note nonconformances before they become full blown problems, so don’t be afraid to use it to its fullest extent.

Deirdre Schlunegger, Stop Foodborne Illness
Food Safety Culture Club

How We Use the Word ‘Recall’ Matters

By Deirdre Schlunegger
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Deirdre Schlunegger, Stop Foodborne Illness

“Recalls”. This topic got me thinking, what is the literal meaning of recall? So, I looked it up:

Verb

  1. Bring (a fact, event or situation) back into one’s mind, especially so as to recount it to others, remember.
    “I can still vaguely recall being taken to the hospital”
  2. Officially order (someone) to return to a place
    “the Panamanian ambassador was recalled from Peru”

Noun

  1. An act or instance of officially recalling someone or something
    “the recall of the ambassador”
  2. The action or faculty of remembering something learned or experienced.
    “their recall of dreams”

Many people think of FDA when hearing the word “recall”, and many consumers believe that the FDA often or even always orders recalls. In fact, the FDA relies on responsible parties to voluntarily recall food products when a threat exists, but FSMA’s mandatory recall authority allows FDA to mandate a recall only when the criteria under section 423 of the FD&C Act are met.

For most, the word “recall” is all too familiar. We hear it so often that I wonder if we are becoming desensitized to it. Almost daily we hear this item or that item has been recalled due to XXX, allergy, Salmonella, Listeria, foreign matter, and the list goes on. I counted 45 human and three pet food-related recalls just since May 1, 2018—that’s in just 84 days as I write this. So, for consumers (and we are all consumers), how do we hear the word recall and what is our visceral reaction when we hear the word? What actions if any do we take? Does it become too overwhelming? Are we becoming immune from the word? We are required to eat for survival sake and we don’t know if there is a problem with the food we are eating until after it has been recalled. At Stop Foodborne Illness, we send out recall notices every time there is a recall announced, which is typically a few times a week. Recently, a friend asked, “So, do I just quit eating to avoid contamination?”

I wonder if we can start a conversation about the term, how we use it and how to use the word and related action effectively. What does it mean for consumers? Is it only meaningful after the fact? The word and action of the word “prevention” is so much more powerful. Just “food” for thought.