Tag Archives: food safety

Beltway Beat

The Effectiveness of U.S. Food Laws Over Private Standards

By Sayed M Naim Khalid
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Introduction

The safety of our food supply is critical to public health, economic stability, and consumer confidence. The United States has developed a comprehensive regulatory framework for food safety that relies heavily on federal laws and oversight. This system involves multiple federal agencies, state and local governments, and numerous statutes designed to ensure food safety from farm to table. Private standards, such as those established by the Global Food Safety Initiative (GFSI), also play a role, but they are not a substitute for the regulatory power and public accountability inherent in U.S. food laws. This artilce argues that U.S. food laws are more effective than private standards and that businesses can achieve sufficient food safety by adhering to these laws without incurring additional costs associated with private standard implementation.

The Current U.S. Food Safety System

The U.S. food safety system is multifaceted, involving producers, processors, shippers, retailers, and consumers. The government, particularly through agencies like the FDA, USDA, EPA, and CDC, plays a critical role in establishing and enforcing food safety standards. These agencies work under numerous statutes and interagency agreements to ensure the safety of the food supply. The system, while complex and somewhat fragmented, is backed by legal enforcement, scientific research, and public accountability.

The Effectiveness of U.S. Food Safety Laws

The U.S. food safety regulatory system is extensive and multifaceted, involving numerous agencies with specialized roles. The Food and Drug Administration (FDA), the Food Safety and Inspection Service (FSIS) of the U.S. Department of Agriculture (USDA), the Environmental Protection Agency (EPA), and the National Marine Fisheries Service (NMFS) of the Department of Commerce all play crucial roles in ensuring food safety. These agencies operate under a framework of more than 35 statutes overseen by 28 Congressional committees, reflecting the complexity and thoroughness of the system.

The FDA, for instance, regulates domestic and imported foods, except for meat and poultry products, ensuring they are safe, sanitary, and properly labeled. The agency has regulatory authority over more than $1 trillion in products sold annually—about 25 cents of every dollar spent by consumers, including surveillance, risk assessment, research, inspection, and education. Similarly, the FSIS is responsible for ensuring the safety of meat and poultry products, employing roughly 7,400 inspectors to oversee 6,200 slaughtering and processing plants through continuous and daily inspections.

The statutory mandates for these agencies are comprehensive. For example, the FDA’s Center for Food Safety and Applied Nutrition (CFSAN) enforces tolerances for pesticide residues, approves food additives, and ensures that food processing plants adhere to safety standards. The FSIS, by law, must conduct carcass-by-carcass inspection during slaughter, ensuring that meat and poultry products are safe for consumption. USDA) announced in 2021 that government will invest more than US$4 billion to improve the food system.

Government Enforcement and Public Accountability

U.S. food laws are enforced by federal agencies with the authority to conduct inspections, enforce regulations, and impose penalties for non-compliance. This legal backing ensures a high level of adherence to food safety standards. For example, the FDA and USDA conduct regular inspections and surveillance to ensure compliance with food safety laws. This system of oversight provides a level of public accountability that is essential for maintaining consumer trust and preventing foodborne illnesses.

Scientific Basis and Comprehensive Coverage

U.S. food laws are grounded in scientific research and are regularly updated to reflect the latest food safety information. These laws cover a wide range of food products and hazards, including microbiological contaminants, pesticides, and additives. This comprehensive approach ensures that all potential risks are addressed, providing a higher level of protection for consumers.

Economic and Consumer Protection

Effective food safety regulations prevent large-scale foodborne illness outbreaks, reducing healthcare costs and economic losses. By ensuring that food products meet safety standards, the government protects consumers from the dangers of contaminated or unsafe food. This protection is crucial for maintaining public health and economic stability.

Limitations of Private Standards

While private standards like those established by GFSI can complement public regulations, they are not a substitute for the robust framework provided by U.S. food laws. Private standards are voluntary and lack the enforcement power of government regulations. They often require third-party audits, which can be costly and lead to inconsistent implementation due to variability in auditor competency and interpretation of standards.

Cost and Market Pressure

Certification and compliance with private standards can be expensive, particularly for small and medium-sized enterprises. These costs can create barriers to market entry and place unnecessary financial burdens on businesses. Moreover, companies may feel pressured to adopt private standards to remain competitive, regardless of whether these standards offer additional safety benefits over existing regulations.

Transparency and Accountability

Private standards are enforced through independent third-party audits, which may lack the transparency and public accountability of government inspections. The results of these audits are not always made public, and there is less oversight to ensure that auditors maintain high standards of integrity and competence.

Limited Scope and Inequality

Private standards may not cover all aspects of food safety, especially those specific to local contexts or emerging threats. Additionally, smaller companies and producers in developing countries may face significant barriers to accessing certification due to costs and resource constraints, leading to inequality in market access and potentially restricting trade opportunities.

The Case for Relying on U.S. Food Laws

Given the comprehensive and enforceable nature of U.S. food laws, businesses can achieve sufficient food safety by adhering to these regulations without incurring additional costs associated with private standards. The legal framework provided by U.S. food laws is designed to protect consumers and ensure food safety across the entire supply chain. By focusing on compliance with these laws, businesses can avoid the complexities and expenses of private certification while still maintaining high standards of food safety.

HACCP Systems and FSMA

The implementation of Hazard Analysis Critical Control Point (HACCP) systems and the Food Safety Modernization Act (FSMA) has strengthened the U.S. food safety framework. HACCP systems focus on preventing hazards at critical points in the production process, while FSMA emphasizes proactive measures to prevent food safety issues. These regulatory approaches are widely recognized as effective means of ensuring food safety and can be more cost-effective than adhering to multiple private standards.

Comparison with Private Standards

Private food safety schemes, like those endorsed by GFSI, offer standardized protocols for food safety management across global supply chains. These schemes are often seen as more stringent and market-driven, providing a competitive edge and reassurance to consumers and business partners. However, these private standards come at a cost. Businesses must pay for certification, ongoing compliance audits, and the implementation of specific protocols that may overlap with existing regulatory requirements.

Comparison of U.S. Food Laws vs. GFSI Standards

Pros and Cons of GFSI Standards

GFSI Standards

Pros

Cons
  1. Global Recognition: GFSI standards are recognized worldwide, facilitating international trade and ensuring global food safety.
  2. Flexibility: GFSI standards allow for flexibility and adaptability to new food safety practices and technologies.
  3. Market Competitiveness: Certification to GFSI standards can enhance a company’s reputation and market access.
  4. Private Sector Leadership: GFSI involves private sector stakeholders, fostering innovation and industry-driven solutions.
  5. Standard Harmonization: GFSI standards harmonize various private food safety schemes, reducing duplication and confusion.
  6. Risk-Based Approach: GFSI emphasizes a risk-based approach to food safety, focusing on critical control points and preventive measures.
  7. Continuous Improvement: The GFSI framework encourages continuous improvement and regular updates to standards.
  8. Third-Party Audits: Independent third-party audits provide an objective assessment of a company’s food safety practices.
  9. Training and Resources: GFSI offers extensive training and resources to help companies comply with standards.
  10. Consumer Confidence: Certification to GFSI standards can enhance consumer confidence in the safety and quality of food products.

 
  1. Cost: Certification and ongoing compliance with GFSI standards can be expensive, especially for small and medium-sized enterprises.
  2. Voluntary Nature: As a voluntary scheme, GFSI lacks the legal enforcement power of government regulations.
  3. Inconsistent Implementation: Variability in auditor competency and interpretation of standards can lead to inconsistent implementation.
  4. Complexity: The process of achieving and maintaining GFSI certification can be complex and resource-intensive.
  5. Overlap with Regulations: GFSI standards can overlap with existing government regulations, creating redundancy.
  6. Market Pressure: Companies may feel pressured to adopt GFSI standards to remain competitive, regardless of their actual necessity.
  7. Audit Fatigue: Frequent audits and certifications can lead to audit fatigue and a focus on passing audits rather than genuine food safety improvements.
  8. Limited Scope: GFSI standards may not cover all aspects of food safety, particularly those specific to local contexts or emerging threats.
  9. Transparency Issues: Private certification bodies may not be as transparent as government agencies in disclosing audit results and non-compliance.
  10. Access Inequality: Smaller companies, particularly in developing countries, may face barriers to accessing GFSI certification due to costs and resource constraints.

 

Pros and Cons of U.S. Food law

U.S. Food Laws

Pros

Cons
1.     Government Enforcement: U.S. food laws are enforced by federal agencies like the FDA and USDA, providing a robust and legally backed framework for food safety.

2.     Comprehensive Coverage: These laws cover a wide range of food products and hazards, including pesticides, additives, and microbiological contaminants.

3.     Public Accountability: Government agencies are accountable to the public, with transparent operations and public reporting of food safety issues.

4.     Standardization: U.S. food laws provide standardized regulations across the country, ensuring uniform food safety practices.

5.     Scientific Basis: The laws are based on scientific research and updated with the latest food safety information.

6.     Interagency Coordination: Multiple agencies collaborate, providing a multi-faceted approach to food safety.

7.     Consumer Protection: The primary goal is to protect consumers from foodborne illnesses and unsafe food products.

8.     Economic Impact: Government-regulated food safety can prevent large-scale foodborne illness outbreaks, reducing healthcare costs and economic losses.

9.     Legally Binding: Compliance is mandatory, with legal consequences for non-compliance, ensuring high levels of adherence.

10.   Educational Resources: Government agencies provide extensive educational resources and support to food businesses to help them comply with regulations.
  1. Bureaucracy: The complexity and fragmentation of the regulatory system can lead to inefficiencies and slow responses to emerging food safety issues.
  2. Resource Limitations: Federal and state agencies often face budget and staffing constraints, impacting their ability to perform inspections and enforce regulations.
  3. Inconsistencies: Variation in enforcement and standards across different states and localities can create inconsistencies in food safety practices.
  4. Regulatory Overlap: Overlapping jurisdictions between agencies can cause confusion and redundancy in regulatory efforts.
  5. Slow Adaptation: Government regulations can be slow to adapt to new food safety technologies and practices.
  6. Burden on Small Businesses: Compliance with complex regulations can be burdensome for small food businesses with limited resources.
  7. Limited Global Reach: U.S. laws apply primarily to domestic producers, potentially creating gaps in food safety for imported products.
  8. Focus on Compliance: The emphasis on regulatory compliance may sometimes overshadow the focus on innovative food safety improvements.
  9. Inspection Gaps: Resource limitations can lead to infrequent inspections, reducing the effectiveness of enforcement.
  10. Perceived Rigidity: Some stakeholders view government regulations as rigid and inflexible, stifling industry innovation.

 

Conclusion

While both U.S. food laws and GFSI standards have their strengths and weaknesses, their effectiveness depends on the specific context and needs of the food industry stakeholders. U.S. food laws provide a legally enforceable and standardized framework, ensuring a high level of consumer protection and public accountability. On the other hand, GFSI standards offer flexibility, global recognition, and industry-driven innovation, though they come with significant costs and may lack the enforcement power of government regulations.

The U.S. food safety system, despite its complexity and fragmentation, provides a robust and effective framework for ensuring the safety of the food supply. Federal regulations enforced by agencies like the FDA and USDA offer comprehensive coverage, scientific grounding, and legal enforcement, which are critical for protecting public health and consumer confidence. While private standards can play a supportive role, they cannot match the effectiveness and public accountability of government regulations. By adhering to U.S. food laws, businesses can achieve high standards of food safety without incurring the additional costs and complexities associated with private certification.

For optimal food safety, a balanced approach that leverages the strengths of both systems may be the most effective solution. This hybrid strategy would combine the stringent, enforceable standards of U.S. food laws with the flexibility and global perspective of private standards like GFSI, ensuring comprehensive protection for consumers while promoting innovation and international trade.

Further reading:

  1. (2023, July 13). FSMA Final Rule on Accredited Third-Party Certification. Retrieved July 18, 2024, from US Food and Drug Administration: https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-final-rule-accredited-third-party-certification
  2. Foulis, D. (2024, Feb 14). Four benefits of gaining GFSI certification. Retrieved July 18, 2024, from Ideagen: https://www.ideagen.com/thought-leadership/blog/four-benefits-gfsi-certification
  3. (2011, March). Enhancing Food Safety Through Third Party Certifications. Retrieved July 18, 2024, from Mygfsi.com: https://mygfsi.com/wp-content/uploads/2019/09/Third-Party-Certification-GFSI-White-Paper.pdf
  4. Kaylegian, K. (2021, April 13). The Food Safety Modernization Act (FSMA). Retrieved July 18, 2024, from PennState Extension: https://extension.psu.edu/the-food-safety-modernization-act-fsma
  5. Loucks, S. (2024, May 31). Why Should My Business Become GFSI Certified? Retrieved July 18, 2024, from FoodReady: https://foodready.ai/blog/why-should-my-business-become-gfsi-certified/
  6. Scott, J. (2023, Nov 8). FDA FSMA: Providing value beyond compliance. Retrieved July 18, 2024, from IBM: https://www.ibm.com/blog/fda-fsma-providing-value-beyond-compliance/
  7. Ng S, Shao S, Ling N. Food safety risk-assessment systems utilized by China, Australia/New Zealand, Canada, and the United States. J Food Sci. 2022 Nov;87(11):4780-4795. doi: 10.1111/1750-3841.16334. Epub 2022 Oct 26. PMID: 36285586; PMCID: PMC9828015.
  8. Halabi, Sam. 2016. The Battle between Public and Private Food Safety Standards. Yale Journal of Regulations. https://www.yalejreg.com/nc/the-battle-between-public-and-private-food-safety-standards/ (access on 6/29/2024)
  9. Soon JM, Baines RN. Public and Private Food Safety Standards: Facilitating or Frustrating Fresh Produce Growers? Laws. 2013; 2(1):1-19. https://doi.org/10.3390/laws2010001
  10. National Research Council (US) Committee on the Review of Food and Drug Administration’s Role in Ensuring Safe Food; Wallace RB, Oria M, editors. Enhancing Food Safety: The Role of the Food and Drug Administration. Washington (DC): National Academies Press (US); 2010. 2, The Food Safety System: Context and Current Status. Available from: https://www.ncbi.nlm.nih.gov/books/NBK220410/
  11. Institute of Medicine (US) and National Research Council (US) Committee to Ensure Safe Food from Production to Consumption. Ensuring Safe Food: From Production to Consumption. Washington (DC): National Academies Press (US); 1998. 2, The Current US Food Safety System. Available from: https://www.ncbi.nlm.nih.gov/books/NBK209121/

 

Retail Food Safety Forum

Educating the Public on Food-Related Health Risks: The Critical Role of Nutritionists

By Ainsley Lawrence
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While most people think of nutritionists as general advisors who sit down with them one-on-one to create diet plans, their role goes far beyond that. Nutrition specialists play a critical role in educating the public with regard to food safety.

Some work with patients one-on-one, but they can also work in corporate settings, athletic facilities, food manufacturing centers, government organizations, hospitals, physician’s offices, schools, and more.

In this article, we will take a closer look at the connection between food safety and nutrition, including the important role nutritionists play in nutrition education, food safety, and mitigating food-related health risks.

The Connection Between Food Safety and Nutrition

Food safety and nutrition are inherently linked. Food safety refers to the prevention of food contamination, and for people to be healthy, they must have access to food that keeps them well-nourished and free from foodborne illnesses. In other words, to avoid food-related health risks, people must have consistent access to safe and healthy foods. Poor nutrition is one of the leading causes of illness in the United States. Without safe and equitable access to healthy foods, 600,000 Americans die each year.

By educating others on what to eat and where to get these foods, as well as helping organizations create better food safety and food security plans, nutritionists ensure people have access to the best foods possible for maintaining overall health and well-being.

What is a Nutritionist?

Before diving further into the role nutritionists play in food safety, it’s helpful to understand what they do exactly. Despite the connection between their work and the health of the public, nutritionists are not doctors.

Nutritionists can either be licensed or unlicensed, depending on their specific career goals and where they live, as licensure requirements can differ from one state to the next. When working with patients one-on-one out of a private practice, for example, a nutritionist might not need to be certified. However, if working with a hospital, a school, or a government organization, it is likely that they will be required to have a license — but again, this can depend on the specific requirements of the state they are working in.

However, doctors are often not routinely trained in nutrition. Thus, when a doctor does not have the knowledge needed to help a patient, they can refer them to a nutritionist for special guidance and support. If a patient is recovering from cancer or is dealing with diabetes, they may need to work with a larger medical team so they can learn to manage their condition and alleviate symptoms through a proper diet. In addition to educating patients on what foods to eat for their health, these specialists can also consider factors such as food allergies, dietary needs for athletes, personal tastes, and cultural and religious dietary needs.

What Role Do Nutritionists Play in Nutrition Education and Food Safety?

There are numerous ways that nutritionists work to educate others on food safety. Many organizations and companies are responsible for providing nutritious meals, such as nursing homes, hospitals, and restaurants. These facilities will often hire nutrition experts to help them craft menus and create healthy and flavorful meal plans.

The government also partners with and hires nutritionists for various programs. The USDA Food and Nutrition Service (FNS), for example, is responsible for offering science-based nutrition education to the public. Nutrition professionals will then work with the FNS to create educational programs and even policies that support the health and well-being of communities, families, and individuals.

Nutritionists also use their knowledge and expertise to help back up nutrition claims and work with food manufacturers to create nutrition labels and other important dietary information on food packaging They also use analytical data to calculate things like protein quality or food category contributions and share this information to ensure people are choosing the right food products for their individual health and nutrition needs.

Overall, you can find these specialists working with a wide range of organizations to help educate and ensure food safety, including:

  • Federal and local health departments;
  • Hospitals;
  • Private practices;
  • Nursing homes;
  • Schools;
  • Research facilities;
  • Food distributors and retailers;
  • Hotels and resorts;
  • Athletic organizations.

Some of the specific examples of what they can do in these settings can include researching and developing recipes, creating menus and meal plans, educating clients on nutritional food choices, ensuring plans align with weight, health, and nutrition goals, and creating nutrition-related care plans.

In schools, for example, nutrition professionals are responsible for ensuring meals abide by nutrition regulations, meet the taste preferences of diverse student bodies, are prepared properly, address food allergies, and are affordable.

They can also work with local organizations to assist with food security issues, such as communities that are considered food deserts where people lack access to healthy foods. For example, they can work with food vendors and distributors to ensure certain communities and their local grocery stores and markets have a good selection of fresh and nutritious foods.

Furthermore, nutritionists also play a vital role in educating the public to help reduce food-related illness and disease. Cancer, for example, is one of the leading causes of death worldwide but can be mitigated with better food and nutrition education. Nutrition professionals can also help alert the public to contamination and assist with handling food testing and recalls.

Nutrition Education and The Fight Against Cancer

45% of cancer deaths in the United States are linked to things like poor diet and obesity, thus, nutritionists play an important role in helping mitigate cancer risks. There are a number of carcinogens in everyday food products that are linked to cancer, such as acrylamide, which is a chemical that forms in foods placed under high heat, and aflatoxins, which are produced by food molds.

Nutritionists can offer guidance on testing for food safety. For example, nitrosamines or N-nitroso compounds (NOCs) can be carcinogenic and are known to compromise food quality and safety. Unfortunately, there are many ways NOCs can make their way into the food chain, including crop protection processes, meat preservation processes, food drying processes, and even via the consumption of nitrates in vegetables that react with stomach bacteria and acids to form NOCs. With this knowledge, however, nutritionists can advise on nitrosamine testing to ensure proper food safety.

In Summary

Nutritionists are vital when it comes to educating the public and helping to provide access to safe, healthy, and nutritious foods. There are many organizations in our country that heavily rely on the support and guidance of these specialists to better serve and protect the health and well-being of individuals, families, and communities.

Nutritionists will forever play a critical role in helping people make more informed nutrition decisions. Whether working at a private practice, with schools, hospitals, the government, or other organizations, these food educators are key to reducing food-related health risks.

Produce Traceability: 4 Steps to Get Started

By Samantha Humphrey
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With the effective date for updated traceability recordkeeping approaching in January 2026, traceability is a top priority for most organizations working in the food industry. Produce companies are especially impacted by traceability requirements as the first step in the food supply chain.

On November 21, 2022, the Food and Drug Administration (FDA) published the Food Safety Modernization Act (FSMA) Final Rule: Requirements for Additional Traceability Records for Certain Foods (Food Traceability Rule). With the effective date for updated recordkeeping approaching in January 2026, traceability is a top priority for most organizations working in the food industry. Produce companies are especially impacted by traceability requirements as the first step in the food supply chain.

Most produce companies are no strangers to the importance of traceability. In fact, the Produce Traceability Initiative (PTI) was created over 15 years ago as a voluntary, industry-wide effort designed to help the industry maximize the effectiveness of current track and trace procedures, while developing a standardized industry approach to enhance the speed and efficiency of traceability systems for the future. The PTI has set dozens of companies throughout North America—ranging from small farms to international retailers—on the path to enhanced traceability and compliance with the FDA’s Food Traceability Rule.[i]

The following steps can help any produce company, whether it currently follows the PTI or not, prepare to meet FDA’s traceability requirements:

  1. Understand the Food Traceability Rule.

While the FDA has had traceability requirements in the past, the FSMA Food Traceability Rule is intended to enhance traceability recordkeeping for certain identified foods beyond a limited “one step forward, one step back” traceback approach. The objective of the Rule is to help the FDA rapidly and effectively identify recipients of those foods to prevent or mitigate foodborne illness outbreaks and address credible threats of serious adverse health consequences or death.[ii]

In comparing the FSMA Rule to the PTI, a recent PTI press release states that the requirements of the PTI for case-level traceability are aligned with the Final Rule and cover approximately 90-95% of the requirements, with major differences stemming from the Traceability Lot Code Source and Traceability Lot Code Source Reference.[iii]

The key elements of the FDA Rule are built into several acronyms:

  • FTL (Food Traceability List): This list identifies the categories of high-risk foods that require additional traceability records under the Food Traceability Rule. The FTL currently comprises the following produce commodities: cucumbers, fresh herbs, leafy greens, melons, peppers, sprouts, tomatoes, tropical tree fruits, and fresh cut fruits and vegetables. Other non-produce foods on the FTL include cheeses, shell eggs, nut butter, finfish, crustaceans, mollusks/bivalves, and ready-to-eat (RTE) deli salads.
  • TLC (Traceability Lot Code): This descriptor, often containing a combination of letters and numbers, is used as a unique identifier for product as it moves through the supply chain. The TLC is to be established by entities that originate, transform, or create food on the FTL. Once a food has been assigned a TLC, the TLC must be included in traceability program records collected at each Critical Tracking Event (CTE) and as a part of all Key Data Elements (KDEs) (see below). The TLC remains the same throughout the supply chain unless a transformation of the food occurs. The objective is to create linkages throughout the supply chain to help the FDA address key points in the supply chain more quickly in the event of an outbreak.
  • CTE (Critical Tracking Event): CTEs are the events in the food supply chain that require additional recordkeeping. These include harvesting, cooling before initial packing, packing, transforming, shipping, and receiving. At each CTE, the responsible entity must record the TLC.
  • KDE (Key Data Element): KDEs comprise the information associated with a CTE for which a record, including a TLC, must be maintained. Examples of KDEs include location description of the food being harvested; name of the field or growing area where the produce was harvested; date of harvest; quantity and unit of measure of the produce; date when the produce went from harvest, to cooling, to packing, to shipping, etc.
  1. Interpret the Rule and Determine its Applicability.

To determine the Rule’s applicability, it is important to first take an inventory of your operations and products:

  • Do you grow cucumbers, herbs, leafy greens, melons, peppers, sprouts, tomatoes, or tropical tree fruits?
  • Do you process fresh cut fruits, leafy greens, or vegetables other than leafy greens?
  • Do you manufacture a product that contains any of the foods listed above?

If the Rule applies (i.e., you answered yes to any of the three questions above), you must:

  • Maintain specific data records (i.e., KDEs) for at least two years.
  • Keep records of all CTEs.
  • Maintain an approved, updated Traceability Plan.
  • Ensure all data is easily accessible so it can be provided to the FDA within 24 hours of a request.

Note that there are a few nuanced exemptions that apply to farms, as noted on this FDA flow chart.[iv]

  1. Perform a Gap Assessment.

Most produce companies are likely capturing at least some of the information needed to comply with the Food Traceability Rule, particularly if they already implement the PTI requirements. Conducting a gap assessment will help identify missing elements that may be required for compliance with FDA’s Rule. The following questions can help guide this assessment:

  • Does your organization already capture data that may be considered a KDE? For example, do you apply lot codes to your products? Do you collect location information about where your product is harvested (e.g., farm site A, field 7)? Determine if there is any specific information or data points you are missing and how you can gather that data.
  • Do you have a sufficient Traceability Plan? Does it cover all the elements required in the Food Traceability Rule?
  • Are there upgrades you need to make to your recordkeeping system to solve your data collection pain points? Having a good document/records management system is essential for maintaining and sharing the data required by the Food Traceability Rule.
  • What collaborative activities can you and your suppliers/buyers perform to ensure that data is shared efficiently and encourage compliance?
  1. Create a Plan of Implementation.

The gap assessment will identify elements that you need to implement to help ensure compliance. Use that information to create a game plan, working backwards from the Rule’s January 20, 2026 effective date. Doing so now affords time to test solutions, see how they work in practice, problem solve, and find the right solutions for your organization.

At a minimum the implementation plan must include two key elements that will be vital for compliance:

  • Traceability Plan. Every organization must develop a new (or update an existing) Traceability Plan for collecting the KDEs that are required by the Rule, as outlined in the CFR[v] (see also the FDA example of a Traceability Plan for Farms[vi]). The Traceability Plan must be updated annually, and old plans must be maintained for at least two years. The Traceability Plan must include:
    • Description of the procedures used to maintain required records, as well as how to format and where to store those records.
    • Description of how TLCs are assigned.
    • Assignment of and contact information for a point person who can answer questions about the Traceability Plan and/or traceability records.
    • Map identifying the farms where FTL produce is grown.
  • Document/Records Management System. Produce companies who manufacture, process, pack, or hold foods on the FTL will need to implement a document/records management system to fulfill the Food Traceability Rule’s recordkeeping requirements. While hard copies in binders can work, an electronic document management system can create efficiencies and standardization, reduce human error, and improve accessibility when managing vast amounts of data.

As produce companies work through this process, it is important to remember the objective of the Food Traceability Rule. Ultimately, the Rule will allow the food industry to quickly remove potentially harmful foods from the supply chain and make the entire recall process more efficient. Even if the FTL list does not apply to all your products, your customers may still require that all produce they purchase meet the same requirements as foods listed on the FTL. Creating this end-to-end traceability will save time, money, and most importantly, human lives.

[i] Produce Traceability Initiative. The Produce Traceability Initiative: Working to achieve standardized, electronic (computerized) traceability across the supply chain. September 2011. https://producetraceability.org/wp-content/uploads/2022/03/PTI-Flyer_FNL_v2-2011-10-20.pdf.

[ii] Food and Drug Administration. What you need to know about the Food Traceability Rule: Recordkeeping Information for Produce Farms. June 2023. https://www.fda.gov/media/169510/download.

[iii] The Produce Traceability Initiative. Produce Traceability Initiative (PTI) Releases FSMA 204 Implementation Guidance. February 13, 2024. https://producetraceability.org/produce-traceability-initiative-pti-releases-fsma-204-implementation-guidance/.

[iv] Food and Drug Administration. Exemptions to the Food Traceability Rule. https://collaboration.fda.gov/tefcv13/.

[v] National Archives and Records Administration. CFR Title 21, Chapter I, Subchapter A, Part 1, Subpart S, Traceability Plan. May 21, 2024. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-A/part-1/subpart-S/subject-group-ECFRe6c9096adb572d4.

[vi] Food and Drug Administration. Traceability Plan Example for Farms (§1.1315). November 2023. https://www.fda.gov/media/174057/download?attachment.

Trust on the Line: Protecting Your Brand in a World of Food Safety Hazards – On Demand Webinar

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The recent recall of lead-contaminated applesauce and cinnamon products highlights the importance of proactive food safety risk management. It is critical for food companies to prevent food safety issues to ensure product safety, maintain consumer trust and protect brand reputation, but identifying and prioritizing these supply chain risks can be a challenge without the right strategy. Our webinar will reveal best practices and operational examples of food safety risk mitigation. Click on the headline to watch the recording of this webinar On Demand

Food Safety Consortium Conference & Expo

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The Food Safety Consortium Conference, presented by Food Safety Tech and The American Frozen Food Institute (AFFI) will take place October 20-22, 2024, at the Crystal Gateway Marriott, Arlington VA directly across the Potomac River from Washington, DC. The Program starts with several pre-conference workshops and training which leads into two full days of high-level panel discussions and educational presentations.

Francine Shaw
FST Soapbox

Food Safety Imagery in Social Media: Exploring the Positive and Negative Aspects

By Francine L. Shaw
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Francine Shaw

In today’s digital age, the use of imagery in social media, articles and marketing materials has become increasingly prevalent. Images can enhance (or distort) the messages conveyed through text, bringing about a range of positive and negative consequences. This article explores the multifaceted nature of imagery, focusing on its impact on accountability, brand reputation, liability, adherence to the FDA Food Code regulations, legal ramifications, and the concern of those who monitor these visuals.

Some important things to consider include:

Accountability of Site Owners. Using imagery in social media and on website is a significant responsibility for publishers and social media page managers. Visually appealing imagery can attract users and enhance engagement, leading to increased traffic and revenue. However, site owners must ensure that the images used are accurate, ethical and respectful. Failure to do so can result in misrepresentation, manipulation or dissemination of harmful content, leading to a loss of trust as well as accountability issues for the site owner or publisher.

Brand Reputation. Imagery plays a crucial role in shaping brand identity and reputation. Effective use of the proper visuals can help establish a strong brand identity and improve consumer perceptions of your products. The right imagery evokes emotions, creates connections and enhances brand recognition. However, a mismatch between the imagery and the brand’s values—or the use of misleading visuals—can damage an organization’s reputation, leading to public backlash and eroding trust.

Liability. Copyright infringement, invasion of privacy and/or the use of misleading or deceptive visual content can create liability concerns for brands and publishers. Content creators must understand and adhere to legal guidelines governing the use of images to avoid legal repercussions and potential damages. For instance, unauthorized use of copyrighted images can lead to legal claims and financial penalties. Additionally, manipulation or propagation of explicit, defamatory or offensive visuals may result in lawsuits and reputational damage. Content creators must be vigilant in obtaining proper permissions and ensuring their visuals comply with legal standards.

Compliance and Regulations. Images are widely used to market food products, services and brands, as well as to influence consumer choices. However, these images must align with the FDA Food Code and FD&C Act regulations, both of which require an accurate depiction of advertised food. Misleading visuals can result in false expectations and regulatory violations.

In addition, using imagery that visually represents U.S. regulations and industry standards for safe food handling and preparation is critical for businesses, as it assures consumers that your methods align with recognized food safety guidelines.

Who’s Watching 

In the digital age, the responsibility of policing imagery goes beyond site owners and extends to society as a whole. Users, consumers, regulatory agencies, insurance companies, attorneys, competitors and advocacy groups are pivotal in monitoring and holding accountable those who misuse or manipulate imagery. Vigilance from individuals and collective efforts to report inappropriate imagery can create an environment of shared responsibility, fostering greater accountability across social media, print publishing and the Internet.

Using images that are accurate and compliant with federal and state regulations can have multiple benefits, including:

  • Legal Compliance. Images that adhere to (or reflect) FDA Food Code requirements help businesses avoid potential legal issues and penalties that may arise from noncompliance and boost a brand’s reputation.
  • Health and Safety. The FDA Food Code is designed to ensure food safety and protect public health. Using compliant images can help promote and reinforce safe food handling, preparation and display of food, reducing the risk of foodborne illnesses.
  • Consumer Trust. Displaying food images that are compliant with U.S. regulations and industry best practices show a commitment to maintaining high standards of quality, safety and hygiene. This can help build trust with key audiences, including consumers, regulatory bodies, advocacy groups and influencers, leading to increased credibility and brand reputation.
  • Clear Communication. The FDA Food Code provides guidelines on proper labeling, disclosure of common allergens and accurate representation of food products. Compliant images enable effective and clear communication of important information to consumers, ensuring they have the necessary details to make informed choices.

Imagery in social media and printed articles holds immense potential to positively impact engagement, brand reputation and communication. However, it also brings forth challenges related to liability, accountability, adherence to legal and ethical standards, and the need for effective monitoring. Stakeholders must balance harnessing the power of visuals and ensuring their responsible use. As technology further evolves, the continuous improvement of content moderation systems and cooperation among platform owners, publishers and creators become crucial to mitigate the negative aspects associated with imagery and maximize its positive potential.

 

IFT logo

IFT Rebrands Quality Management Division to Highlight Food Safety Focus

By Food Safety Tech Staff
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The Institute of Food Technologists (IFT), a nonprofit scientific organization committed to advancing the science of food and its application across the global food system, has rebranded its Quality Management Division. The newly named Food Safety & Quality Management Division (FSQM)—announced on World Food Safety Day 2023—brings together more than 1,500 members from more than 60 countries to collaborate, network, and share ideas around food safety. IFT chose to rebrand the division to better reflect the overall responsibilities of its members who focus on assurance, quality control, food safety, and food wholesomeness.

IFT’s topical, interest-based groups, known as Divisions, support learning, collaboration, and innovation through the sharing of knowledge via webcasts and podcasts, online forums, and in-person events. In total, the organization hosts 25 Divisions spanning the science of food.

“Rebranding to Food Safety & Quality Management Division communicates to the food community that this Division is a home for those interested in food safety,” added Eric Ewert, Chair of IFT’s Food Safety & Quality Management Division.

 

 

FAO Graphic

United Nations FAO Sets Food Safety Priorities

By Food Safety Tech Staff
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The Food and Agriculture Organization of the United Nation (FAO) has published its Strategic Priorities for Food Safety 2022-2031. These priorities were developed collaboratively with FAO Members, international partner organizations (IAEA, WOAH, WTO/STDF, UNIDO, WHO), and FAO technical divisions and centers to “support members in continuing to improve food safety at all levels by providing scientific advice and strengthening their food safety capacities for efficient, inclusive, resilient and sustainable agrifood systems.”

The document, created at the request of the 27th session of the FAO Committee on Agriculture (COAG) and approved by the 171st session of FAO Council, is structured around four interconnected strategic outcomes focusing on governance, scientific advice, strengthening national food control systems and promoting public-private partnerships throughout the food chain.

The FAO noted that its goal is to encourage a more coherent integration of food safety into the development of sustainable and inclusive agrifood systems, food security, and nutrition policies as well as agricultural development strategies. “Our aspiration is that this document helps spur investments and secure adequate human and financial resources for FAO to successfully implement its food safety program,” said Corinna Hawkes, FAO Director of the Food Systems and Food Safety Division.

The four strategic outcomes include:
1. Intergovernmental and intersectoral coordination of food safety governance is reinforced at all levels.

2. Sound scientific advice and evidence are provided as the foundation for food safety decision-making.

3. National food control systems are further strengthened and are continuously improved by:

  • Providing technical support to FAO Members to evaluate their national food control systems, identify needs and design integrated capacity development programs
  • Supporting FAO Members and relevant stakeholders, particularly in developing and transition economy countries, where requested, to participate more actively in Codex Alimentarius work
  • Supporting FAO Members in developing and updating their food safety standards, legal frameworks and government policies, as well as operational level procedures and guidelines
  • Helping FAO Members generate relevant food safety data that reflects their national context/situation
  • Supporting FAO Members and relevant stakeholders to embrace relevant technological developments, including digital technologies, in food control and food safety management

4. Public and private stakeholder collaboration is promoted to ensure food safety management and controls throughout agrifood systems by:

  • Supporting both governments and food chain actors starting from primary production and including associated industries, academia, consumers and other stakeholders, in adopting gender responsive and inclusive programs of preventative food safety control and management
  • Providing the tools and resources for stakeholders to make informed choices and adopt food safety interventions that are specific to their countries’ priorities, safety risks and their constituents’ differentiated needs
  • Ensuring that lessons learned from national- and regional-level food safety control programs and initiatives can inform global level normative work and strengthen dialogues on food safety
  • Supporting initiatives aiming to create training programs and curricula that better reflect the complexity of food safety and the need for collaborations across disciplines

Download the full document here.

 

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FDA Releases List of 2023 Priority Guidance Topics for Foods Program

By Food Safety Tech Staff
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The FDA Center for Food Safety and Applied Nutrition (CFSAN) and Office of Food Policy and Response (OFPR) has released a list of draft and final guidance topics that are a priority for the FDA Foods Program to complete during the next 12 months.

The guidance documents do not impose legally enforceable requirements, but they can help stakeholders plan for potential changes that may impact their businesses and organizations. The agency anticipates it will publish many of the listed documents by January 2024.

The priority list of draft and final guidance topics include (by category):

Allergens

  • Questions and Answers Regarding Food Allergens, Including the Food Allergen Labeling and Consumer Protection Act of 2004 (Edition 5); Guidance for Industry
  • Compliance Policy Guide Sec. 555.250 Major Food Allergen Labeling and Cross-contact; Draft Guidance for FDA Staff
  • Evaluating the Public Health Importance of Food Allergens Other Than the Major Food Allergens Listed in the Federal Food, Drug, and Cosmetic Act; Guidance for FDA Staff and Stakeholders

Food Additives

  • Preparation of Premarket Submission for Food Contact Substances (Chemistry Recommendations): Draft Guidance for Industry
  • Premarket Consultation on Cultured Animal Cell Foods: Draft Guidance for Industry

Food Safety

  • Foods Derived from Plants Produced Using Genome Editing; Draft Guidance for Industry
  • Inorganic Arsenic in Apple Juice: Action Level; Draft Guidance for Industry
  • Detention Without Physical Examination (DWPE) of Fish and Fishery Products Due to the Appearance of Adulteration by Bacterial Pathogens, Unlawful Animal Drugs, Scombrotoxin (Histamine), or Decomposition – Evidence Recommended for Release of Goods Subject to DWPE and Removal of a Foreign Manufacturer’s Goods from DWPE; Draft Guidance for Industry
  • Compliance Policy Guide Sec. 555.320 Listeria monocytogenes in Human Food; Draft Guidance for FDA Staff

FSMA

  • Hazard Analysis and Risk-Based Preventive Controls for Human Food; Appendix 1: Potential Hazards for Foods and Processes; Draft Guidance for Industry
  • Hazard Analysis and Risk-Based Preventive Controls for Human Food; Chapter 11: Food Allergen Controls; Draft Guidance for Industry
  • Hazard Analysis and Risk-Based Preventive Controls for Human Food; Chapter 16: Validation of Process Controls; Draft Guidance for Industry
  • Hazard Analysis and Risk-Based Preventive Controls for Human Food; Chapter 17: Classifying Food as Ready-To-Eat or Not Ready- to-Eat; Draft Guidance for Industry
  • Hazard Analysis and Risk-Based Preventive Controls for Human Food; Chapter 18: Acidified Foods; Draft Guidance for Industry
  • Compliance with and Recommendations for Implementation of the Standards for the Growing, Harvesting, Packing, and Holding of Produce for Human Consumption for Sprout Operations: Guidance for Industry

Labeling

  • Labeling of Plant-Based Alternatives to Animal-Derived Foods; Draft Guidance for Industry
  • Questions and Answers About Dietary Guidance Statements in Food Labeling; Draft Guidance for Industry
  • Use of Nutrient Content Claims for Added Sugars in the Labeling of Human Food Products: Draft Guidance for Industry

Public comments on the list of guidance topics, including suggestions for alternatives or recommendations on the topics the FDA is considering, can be submitted to www.regulations.gov, using Docket ID: FDA-2021-N-0553.

 

Paul Damaren and Francine Shaw

The Return to Hospitality: How To Enhance Employee Onboarding

By Francine L. Shaw, Paul Damaren
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Paul Damaren and Francine Shaw

After restaurants nationwide experienced several years of a stressful, disruptive labor shortage, the leisure and hospitality industry has recently added 128,000 jobs, leading all sectors.

Hiring new employees is exciting, especially after years of being seriously understaffed. As you welcome new employees to your team, do not underestimate the importance of onboarding, as 69% of employees are more likely to stay with a company for three years if they were onboarded properly. Additionally, organizations with an official onboarding process experience 50% greater new-hire productivity.

When new hires are trained properly, they feel more confident in their roles and the companies they work for can maximize safety, quality, and compliance. To accomplish this, restaurants and other food businesses should:

Adopt Integrated Digital Solutions

Tech solutions can improve all aspects of your operations, making everything from budgeting to scheduling, forecasting, purchasing, and inspecting more efficient, accurate, and streamlined. Tech tools offer many significant benefits, helping your brand save time and money, reduce waste, and optimize operations.

What’s more, an integrated tech stack can help you get a holistic view of your entire enterprise, whether you have one location or dozens. Easy-to-understand reports provide critical information, allowing operators to make more informed, data-driven decisions.

Digital tools do require an investment, but they offer a tremendous ROI. These solutions help improve safety, efficiency, transparency, accuracy, and consistency. These positive changes boost key performance indicators, including increased sales, profits, customer loyalty, and employee retention.

Prioritize Safety, Quality, and Compliance

Each year, 48 million (1 in 6) Americans get sick from contaminated food or beverages. Don’t let food safety breaches happen at your business!

Prioritize a food safety culture, where all employees work together to maximize safety and minimize risks. Put food safety protocols in place and be certain that all employees are following them. Provide the proper tools for employees to ensure food safety, such as Bluetooth sensors that can tell when walk-in temperatures rise above safe temperatures, and state-of-the-art food thermometers that ensure foods are cooked to proper temps.

It’s not enough just to follow proper food safety protocols yourself, you must be sure that all your suppliers adhere to the strictest food safety standards, as well. If you are following all the right protocols, but a supplier delivers compromised products, your customers (and your business) are at risk.

Food safety and quality assurance must be followed from each product’s point of origin until it’s prepared and served to the consumer. Audit all suppliers regularly and be sure that they have proper, up-to-date safety certifications. When you have multiple suppliers—as most food businesses do—it can be overwhelming to track and organize these important safety certifications manually. Tech tools make this ongoing process easier and more accurate.

Modernize Training Efforts

Some food brands, particularly smaller companies, think that they don’t need a formal training or onboarding process, or they rely on antiquated training programs that have been in place for many years. Swap out your outdated (and/or informal) training programs in favor of something more modern, relevant, and tech driven.

Add more interactive tech elements to your training program, such as microlearning platforms and gamification, to make the information more engaging and memorable. Supplement online training efforts with a live trainer, who can spotlight best practices, answer questions, and role play with your employees to make the lessons stick.

Don’t just tell employees what to do but explain why the rules are so important. Employees are more likely to comply when they understand why the rules are in place.

Keep in mind that training never officially ends. Provide ongoing training opportunities so employees on all shifts can keep important information top-of-mind. Digital tools not only provide key information during initial onboarding, but are essential for reinforcing lessons, delivering updates, and sending reminders throughout each employee’s tenure.

Work to Retain Employees

Did you know that the average restaurant employee changes jobs every 56 days, and that losing a front-line employee costs a restaurant an average of $5,864?

Digital solutions can help you retain employees, as these technologies make their jobs much easier. Tech tools can streamline tedious administrative tasks, such as inspections and inventory, so your employees can spend more time doing the things they enjoy, such as cooking delicious meals and interacting with guests.

Offer competitive pay, appealing benefits, growth opportunities, mentorship, and a supportive culture. And don’t discount the “seemingly small” gestures that can be a big deal to your team. Thank your employees often and sincerely. Praise them in staff meetings for going above and beyond. Write thank you notes. Give bonuses and small gifts. Promote from within.

Get Inspired by Innovative Brands

It may sound like something out of a science fiction novel, but White Castle has a robot working its fryer. Dominos has delivered its first pizza by drone. KFC is using facial recognition technology that recognizes repeat visitors and tailors their experiences based on their past orders and meal preferences. And Panera Bread uses geofencing to track each customer’s location so employees can promptly bring their order to their vehicle.

Your organization may not yet be able to afford robotics in your kitchen or drone deliveries, and that’s OK. But, as tech solutions become more affordable, accessible, and user-friendly for food businesses of all sizes and budgets, it’s clear that technology is improving many aspects of our industry. Digital solutions are no longer “nice to have” luxury items. They’re necessities for brands that prioritize consistently excellent and safe experiences.

By investigating and integrating new technologies, you can provide better service, safer food, and a more convenient dining experience. All of which will help you better meet (and exceed) customer expectations.