Tag Archives: food safety

Dave Premo, Birko Corp.
FST Soapbox

How to Maintain Food Safety and Protect Your Brand During Construction

By Dave Premo
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Dave Premo, Birko Corp.

If your food processing facility needs an expansion or update, construction can be a disruptive event. Throughout the process, a variety of food safety hazards can be present, potentially putting your products at risk. While the contractors you work with are skilled at their trade, protecting your brand is ultimately your responsibility.

Construction, food safety
Developing a thorough plan can keep products, the facility and your employees safe during construction. Images courtesy of Birko.

Extra precautions are needed to minimize the food safety risks during construction, but by developing a thorough plan and following it diligently, you can keep your products, facility and employees safe.

Preparation: The Important First Steps for Safety

Having an established environmental plan before construction starts will make the construction process go smoothly and help maintain safety. If the plan your staff is following needs changes or improvements, make updates in advance of construction and be sure that your staff is up to speed before the project begins.

First, remove any equipment that can be moved from the construction zone and cover all electrical panels, open conduit and electrical outlets to minimize areas that might harbor dust or bacteria during construction.

Next, taking steps to separate the construction and production areas is crucial. Installing heavy gauge plastic sheeting or even temporary walls to isolate the construction area will help prevent cross-contamination. Any doors or wall openings on the temporary barriers should be sealed on both sides, and the gaps between the base of the barriers and the floor should be adequately sealed to keep the surrounding production areas safe. Do whatever is necessary to minimize organisms from traveling by air outside of the construction zone.

The HVAC and air handling system in the construction area should also be evaluated for cross-contamination potential. Be sure to close off or divert the airflow to prevent air movement from the construction zone to any production areas. In addition, make sure the system will be able to accommodate additional areas or space after construction is complete and make any upgrades if necessary. Thoroughly clean the HVAC system and filters before the construction process starts.

Similarly, evaluate any drains that are present in the construction zone for cross-contamination potential and take precautions to keep pathogens from passing from the construction area to the food production areas.

Make Contractors Part of Your Plan

While contractors might have years of experience in their trade, they don’t know your food safety plan. Schedule a formal food safety training session with the contractor and all members of the construction staff. Don’t allow anyone to work in the facility before completing the training. Determine which protective clothing contractors and their team will need, such as frocks, boot covers or hairnets, and provide a separate bag or place to store them during the construction process.

Designating a single entrance for contractors and construction staff will minimize confusion and avoid mistaken entries into prohibited areas. Educate them on the appropriate traffic flow as they arrive, enter the facility, and conduct their work. Their entrance should be separate from those used by office and food production employees. Have quat or alcohol hand and tool sanitizers stationed at the designated contractor entrance, and require them to sanitize any tools, materials or equipment before entering the facility. Emphasize that no mud or other debris should be tracked into the facility. Provide the necessary guidance and monitor the entrance area to prevent that from happening.

Shoe coverings, food safety, construction
Effectively communicate safety plan with all contractors involved.

Construction staff and in-house food production staff should be separated at all times. To prevent cross-contamination, there shouldn’t be any direct paths from the construction area to the production area. No material from the construction area should ever be brought into the food production area. Contractors and construction staff should also be prohibited from using the break rooms or restrooms that are used by the facility employees. Because they won’t have access to other areas, temporary hand wash sinks may be needed for construction employees to follow frequent hand washing and sanitizing procedures.

Best Practices for Sanitation During Construction

Before demolishing and removing any walls during the construction process, apply a foam disinfectant at 800–1000 ppm without rinsing. If any equipment needs to be moved, or if there will be new equipment brought into the area, clean and disinfect it with quat at 800–1000 ppm without rinsing.

Quat should also be applied heavily on the floors around the designated construction team entrances. Foam or spray contractors’ walkways and the construction area floor every four hours at 800–1000 ppm. Allow contractors, forklifts, dollies or other wheeled carts to regularly travel through the disinfectant to keep their feet and wheels sanitized as they move throughout the construction area.

If your construction project involves new equipment installation, discuss the sanitation requirements and restrictions with a sanitation chemical provider before purchasing this equipment to ensure you have the right chemistry on hand. Any new equipment should be cleaned and sanitized, as well as the area where it will be installed, before bringing the equipment into the area. Make sure all the surfaces of the new equipment are compatible with your current cleaning chemistry and that the installation follows proper food safety guidelines. If necessary, upgrade your food safety process to accommodate the new equipment.

Transitioning from Construction to Safe Food Production
Once the construction project is complete, remove all construction materials, tools, debris, plastic sheeting and temporary walls. Seal any holes that might have occurred in the floors, walls and ceilings where equipment was moved, and repair or replace epoxy or other floor coverings. Inspect any forklifts or man lifts used during the construction, and clean and sanitize them.

Clean the HVAC and air handling system and return it to either its pre-construction settings or an updated configuration based on what the new area requires.

Continue cleaning everything in the construction area, from ceiling to floor, including lights, walls, drains, refrigeration units and all equipment following SSOPs. Note that different cleaning products containing solvents may be needed for the initial cleaning to remove cutting oil, welding flux residues, greases, and other elements from the construction process. Be sure to have those cleaning products on hand before you get to this step to avoid delays of a thorough sanitation process. Where necessary, passivate any stainless steel equipment.

Finally, test the environment. Collect a special set of swabs and monitor the results. Apply post-rinse sanitizer and then begin food production. Implement an enhanced environmental monitoring program in all areas disrupted by the construction until the data shows a return to the baseline levels. Revise your facility SSOPs in light of any changes based on the new construction.

Achieving Seamless Productivity

Expansion can mean new capabilities for your business, but lax food safety processes during construction can jeopardize the new opportunities your expansion brings. By having a strong plan in place, following it diligently, educating contractors on your plan, monitoring activity, and using effective sanitizing chemistry, you will be able to expand while protecting your brand and avoiding food safety issues.

Food Safety Consortium

2020 Food Safety Consortium Converted to Virtual Event Series

By Food Safety Tech Staff
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Food Safety Consortium

With the COVID-19 pandemic continuing to take a toll on live events, Innovative Publishing Company, Inc. has made the careful decision to convert the Food Safety Consortium, which historically has taken place in Schaumburg, IL, to a virtual conference. This move takes into consideration Illinois’ COVID-19 plan to reopen its economy, which is a Five-Phase Plan. Phase 5 occurs when groups larger than 50 (conferences and conventions specifically mentioned) will be allowed. The state enters Phase 5 only when a vaccine or an effective treatment is in place. The decision to take the Food Safety Consortium virtual is based on the Illinois reopening plan, along with considering the safety and well being of staff, attendees, speakers and sponsors.

Every Thursday, beginning on September 10 through November 12, the Food Safety Consortium Virtual Conference Series will host two presentations and two sponsored Tech Talks, followed by a panel discussion with attendees. Food Safety Tech is the media sponsor.

“This will be much more than a bunch of webinars. We are excited to offer a virtual platform that facilitates greater human interaction,” says Rick Biros, president of Innovative Publishing and director of the Food Safety Consortium. “Whether it’s a random connection in a hotel lobby, a stroll by a booth at a trade show, or a seat next to a new friend in a learning session, we recognize that human connection is important for events. That’s why we’ve invested in new tools for the FSC Conference Virtual Platform to ensure those discussions, discoveries and connections can go on whether our event is offline or online. The new platform provides attendees with a way to keep track of live sessions, connect with sponsors and engage with peers, all in a familiar way. It will also include an event App that offers interactive features.”

Frank Yiannas, FDA deputy commissioner for food policy and response, will remain a keynote speaker, with the new presentation date to be announced.

Call for Abstracts

We are accepting abstracts for participation in the Food Safety Consortium Virtual Series. On the Submit an Abstract page, select Food Safety Consortium 2020 in the drop-down menu.

Categories include:

  • Food safety
  • Food defense
  • Food integrity
  • Food safety supply chain management
  • Lessons learned COVID-19
  • Regulatory compliance
  • Facility design
  • C-suite executive forum

Tech Talk Sponsorship

Companies that are interested in sponsoring a 10-minute technical presentation during the series can also submit their abstract through the portal. For pricing information, contact IPC Sales Director RJ Palermo.

Innovative Publishing has also converted the Cannabis Quality Conference to a virtual event. More information is available at Cannabis Industry Journal.

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 live event)

Food companies are concerned about protecting their customers, their brands and their own company’s financial bottom line. The term “Food Protection” requires a company-wide culture that incorporates food safety, food integrity and food defense into the company’s Food Protection strategy.

The Food Safety Consortium is an educational and networking event for Food Protection that has food safety, food integrity and food defense as the foundation of the educational content of the program. With a unique focus on science, technology and compliance, the “Consortium” enables attendees to engage in conversations that are critical for advancing careers and organizations alike. Delegates visit with exhibitors to learn about cutting-edge solutions, explore three high-level educational tracks for learning valuable industry trends, and network with industry executives to find solutions to improve quality, efficiency and cost effectiveness in the evolving food industry.

Christine Charlotte Akselsen, Kezzler
FST Soapbox

Connecting the Dots for Food Safety at GFSI 2020

By Christine Charlotte Akselsen
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Christine Charlotte Akselsen, Kezzler

Representatives at this year’s GFSI conference hailed from 53 countries and spanned the food industry, academia, the public sector and beyond. They came together in Seattle, a city that has long stood at the cutting edge of technological innovation, and as such was a fitting host for this year’s theme: “One Connected World. One Safe Food Supply”.

Speakers at the forefront of their fields shared knowledge and showcased creative methods of delivering connectivity—interpersonal, technology-mediated and otherwise, all geared towards the ultimate goal of helping provide safer food for consumers everywhere.

Meanwhile, there were numerous opportunities to connect with representatives of industry giants such as Costa, Nestle, McDonald’s, Amazon and Starbucks, as well as regulatory agencies, certification & accreditation bodies, NGOs, academia and the media, at the various networking sessions.

Urgent Action Required

As the conference kicked off, it was Peter Freedman, the managing director of The Consumer Goods Forum (CGF), who set out the importance of the task at hand. His message was one of urgency in delivering positive change.

Freedman pointed to recent global events, such as the wildfires in Brazil, as examples of how the world could be at a tipping point. “Action is more urgent than ever”, he told delegates, stating that it is no longer just a matter of responding, but responding urgently. Freedman also pointed to E. coli outbreaks in 2017, 2018 and late 2019 to drive home to industry leaders gathered at the conference that food safety cannot be taken for granted.

The spirit of the event was, as usual, geared towards a collaborative approach. Delegates were asked to leave their commercial interests at the door and work purely towards “a world where all food is safe” for the duration of the event.

“This week is not about us as individuals, it’s about how we come together as a collective of brilliant minds to provide solutions,” GFSI Director Erica Sheward stated. She then invited the audience to stand in recognition of this commitment, and sure enough everyone in the packed auditorium took to their feet demonstrating their commitment to the shared mission.

GFSI’s New Benchmarking Requirements

The GFSI used the conference as a platform to launch its new Benchmarking Requirements Version 2020, which establish a new foundation for food safety. To close the opening session, Sheward joined Mike Robach, Chairman of the GFSI Board, Vice-Chairs Anita Scholte op Reimer and Gillian Kelleher and GFSI Senior Technical Manager Marie-Claude Quentin around a red ‘action button’ to mark their publication.

The requirements are geared towards enabling a common understanding and mutual trust in the supply chain that facilitates trade, improves efficiency and lends nameplate authority to operations certified to a GFSI-recognized program. They incorporate stakeholder input from public consultations and are regularly revised to reflect best practices and evolving needs in the industry.

GFSI positioned the new version as more than just an update, but a complete rethink “representing the beginning of a new generation of recognition”. The two primary objectives of Version 2020, are to achieve transparency and objectivity, with new and strengthened elements that include two new scopes focused on hygienic design, elements of food safety culture and reinforced impartiality of the auditing process and the monitoring of certification bodies.

Shark Tank Sessions

This year’s GFSI program also included a new format to help showcase how the latest technology is being used to further food safety. Leaders in innovation took part in a number of Shark Tank-style breakout sessions to pitch their technology solutions to the sharks and the attendees.

A total of nine cutting-edge companies took to the stage to pitch their concepts to a panel of experts—‘sharks’—who are well-placed to judge their value for the industry. The nine competitors were selected from a large pool of applicants based on their innovative spirit, disruptive potential and feasibility.

Each presenter had 12-minutes to outline the context in which their solution is utilized, the technology supporting it and how it is implemented. Following the pitches, each presenter came under the scrutiny of the sharks who were able to ask clarifying questions.

Kezzler was among the companies to take to the stage with CEO Christine Akselsen sharing insights from work with FrieslandCampina’s infant formula brand, FRISO. Referencing the grass-to-glass case study, she demonstrated how Kezzler’s technology works in practice, tracking information from farms in The Netherlands to consumers in China. Following the sessions an audience vote determined the winner of the competition, which was announced during the final plenary of the conference. Kezzler was also crowned as the first-ever GFSI Shark Tank champion.

2019 Food Safety Consortium, Glenn Black, CFSAN, FDA

Say What? Perspectives We Heard at the 2019 Food Safety Consortium

By Maria Fontanazza
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2019 Food Safety Consortium, Glenn Black, CFSAN, FDA

Last week’s seventh annual Food Safety Consortium brought together a variety of industry experts to discuss key topics around regulation, compliance, leadership, testing, foodborne illness, food defense and more. The following are just a few sound bytes from what we heard at the event. (Click on any photo to enlarge)

Food Safety Consortium, Frank Yiannas, FDA “The food system today, while it’s still impressive, it still has one Achilles heel—lack of traceability and transparency.” – Frank Yiannas, deputy commissioner for food policy & response, FDA. Read the full article on Yiannas’ keynote session

“A typical food company only has about 5% visibility into known supply chain threats.” – Ron Stakland, senior business development, FoodChain ID, Inc.

“For most of us, our supply chain is a big black hole. Why are we so fearful of technology? Is it the implementation itself? What if technology could help us solve some of those perennial problems? There are resources available to help us get there.” – ¬ Jeremy Schneider, business development director, food safety and quality assurance, Controlant

“The records tell the story of how well the facility is being managed. It’s the first thing the regulators are going to look at.” – Glenn Black, Ph.D., associate director for research, CFSAN, FDA, on validation considerations and regulations for processing technologies in the food industry 2019 Food Safety Consortium, Glenn Black, CFSAN, FDA

“We’ll see more robotics enter the food space.” – Gina Nicholson Kramer, executive director, Savour Food Safety International

Melody Ge, Corvium, 2019 Food Safety Consortium “Changes are happening; you can choose to face it or ignore it. We’re at least 10 years behind on technology. Automation/technology is not a new term in aerospace, etc., but to us [the food industry], it is. We will get there.” – Melody Ge, head of compliance, Corvium, Inc., on how industry should prepare for the data-driven transformation occurring in the smarter era of food safety

It’s okay to risk and fail, but how are going to remediate that with your employee? The more learners practice in different scenarios, the less they rely on specific examples. [They] become more adept with dealing with decision making.” – Kathryn Birmingham, Ph.D., VP for research and development, ImEpik, on employee training

“As a contract lab with the vision of testing for foodborne viruses for about 10 years—it wasn’t until about three or four years ago that we had the test kits to turn that into a reality. We also didn’t have a reference method.” – Erin Crowley, chief scientific officer, Q Laboratories, on the viral landscape of testing in the food industry

“You have to be strong and you have to believe in yourself before you get into any situation—especially as a food safety professional.” – Al Baroudi, Ph.D., vice president of quality assurance and food safety at The Cheesecake Factory, on what it takes to earn respect as a food safety professional Jorge Hernandez, Al Baroudi, Ph.D., 2019 Food Safety Consortium

“’See something, say something’ is likely not enough. We recommend that companies develop a formal detection program that includes management buy-in, HR and governance, and policy documents, formal training and an awareness program…While FDA focuses on the insider threat, we feel that using a broader mitigation approach works best.” – R. Spencer Lane, senior security advisor, Business Protection Specialists, Inc. on lessons learned from food defense intentional adulteration vulnerability assessments

“Food safety is a profession, a vocation, [and] a way of life.” – Bob Pudlock, president of Gulf Stream Search

Deirdre Schlunegger, Stop Foodborne Illness
Food Safety Culture Club

The Food Safety Culture Conversation

By Deirdre Schlunegger
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Deirdre Schlunegger, Stop Foodborne Illness

I learn and remember visually and I was recently thinking about the food safety world and culture; how the fabric of the culture is woven together with people who care about people. After all, that is what it comes down to, people who cultivate, grow, harvest, produce, distribute, deliver, store, prepare, serve and eat safe food. When there is a breakdown of the weave, people become ill and some die, families are devastated, business fails and trust is broken. The system fails.

It really comes down to each weaver, regardless of the level of responsibility performing their duty, knowing that they are the link between health and illness, success and failure, life and death. So, the question is how do we make sure that each person who comes in contact with food products is thoroughly educated, truly understands the impact and has a breadth of awareness of the importance of food safety?

Many companies are admirably deeply invested in food safety training. Organizations share food safety tips about safe food practices, including Stop Foodborne Illness. Stop Foodborne Illness employees and volunteers bring the stories of foodborne illness to light each time we speak, are present at conferences, participate in food safety trainings, deliver video messages and send out newsletters. We work with those impacted and pair them with others who have experienced the same thing and offer them an outlet to share their stories.

What more can we do? 3000 people in the US die each year, 128,000 are hospitalized and 48 million become ill. The numbers are much too high. Let’s keep the food safety culture conversation going and improvement in training and practices and ideas flowing. Here is one such story to start the conversation.

Tressa, Chloe, and Luke

 

Roslyn Stone

The Changing Landscape of a Foodborne Illness Outbreak Response

By Roslyn Stone, MPH
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Roslyn Stone

Recent high-profile foodborne illness outbreaks appear to have an enduring impact for the entire industry – from when and how health departments respond to alleged illness to how a single tweet wreaks havoc. The bar for when a comprehensive response is required is lower and the extent and nature of the required response has changed.

Here’s what we’ve learned:

Health departments are receiving more complaints from consumers. Although much of this is believed to be related to the high-profile outbreaks, some are a result of health department websites making it easier to report illness. A few years ago, guest illness reporting required calling the health department during business hours, working your way through complex voicemail options until you reached a recorded line to leave a message about your illness. Today, most health departments in large cities and many in smaller counties, have simple on line reporting systems available 24/7. So when someone isn’t feeling well at midnight, and is sure it’s from the last thing they ate, they go online and report the illness.

Health departments are now more often following up on single reports of illness and reports of illness that are inconsistent with most foodborne illness incubation periods. This is creating a large burden for already short-staffed departments, but in response to what the public now expects. In the past, they might have replied to the ill guest and explained that they’d received no other reports, that most foodborne illness has a longer incubation period and refer the illness to personal physicians if a follow up is clinically appropriate. But today, we’re finding many health departments dispatching inspectors for even a single complaint that doesn’t appear consistent with incubation periods for that meal.

There’s increasing pressure on health departments to go public with illness events – even if the illness is no longer ongoing or creating a public health risk. The foodborne illness legal community has made it clear that they believe the public has the right to know about any and every foodborne illness. And some health departments are responding to that pressure – without their being an on-going public health risk; which would have been the trigger in the past.

Guest complaints about illness are occurring more frequently. Every single one of our clients is reporting an on-going uptick in guest reports of illness. We’re not clear if it’s that consumers are more aware of illness, more concerned or more likely to associate it with a restaurant or food service provider. But the entire industry is seeing an increase in guest reports of illness. And every guest assumes it was the last meal they ate.

How you handle any guest complaint about illness is even more critical than it was a few months ago. Here’s why: if you don’t’ respond to the guest quickly and listen with authentic empathy, that guest is far more likely than ever before to tweet about you, write a bad review, post on social media or contact the media. You need to act quickly and it doesn’t matter if it’s a weekend or holiday. Waiting until Monday morning is not an option.

Noro season is year-round now… it’s no longer the winter vomiting disease like it is called in some places. Noro virus outbreaks continued in California (and elsewhere) until after the school year ended. We need to be alert to Noro all of the time.

Fourth of July
Fourth of July was an unusually quiet day in the restaurant, quieter than anticipated (meaning more prep done than needed). The next day, two employees called out sick. A day later, two guests (small parties) called the restaurant reporting illness and later that day, two more larger parties emailed their reports of illness through the corporate website. It took another 24 hours to match these multiple illness reports through three different channels. It didn’t trigger a full-blown response and implementation of the noro sanitizing protocol.
THE FINAL TALLY: 40+ guests reporting sickness and nearly half of the staff.
THE LESSON: Coordination of reporting mechanisms so that you see a potential problem and respond at the earliest point when you can have the greatest impact in minimizing risk.

Employees continue to work sick. There are so many reasons that employees work sick and it has little or nothing to do with paid sick time. They work sick because they’re not very sick, they don’t understand that any gastrointestinal upset may be a sign of foodborne illness, they don’t want to disappoint their manager or they don’t want to let their team down. They’re working sick for altruistic reasons without understanding the potential ramifications. We have a long way to go in educating managers and employees about what “sick” looks like, what can happen from working sick and why we need to work together long term to change this set of behaviors.

Employee Exclusion Policies need to be revisited. Someone is shedding the Noro virus for twenty-four hours prior to become symptomatic and then at very high levels for three days after symptoms end. Sick employees need to be excluded for much longer than they currently are in most restaurants and food service establishments to control Noro outbreaks.

Employee Illness on Days Off are as critical to crisis prevention and response as illness on work days. You need to know if an employee was sick on a scheduled work day or on a day off. As we discussed previously, they were shedding the Noro virus before they got sick and for days after. Your illness response plan needs to include a very robust tool for employee illness reporting – one that is as easy to use seven days a week and raises an alert to management when there are two or more sick employees.

It’s time to redraft and recommunicate the definition of a potential crisis in your organization. In the past, we previously used the following definitions of what defined a potential crisis for a restaurant or foodservice group:

  • Two or more employee illness reports (for same time period and symptoms)
  • Two or more guest complaints (from different parties for same time period)
  • One confirmed employee illness (with a communicable disease)

Your new definition must be broader and reflect the lower trigger points for action. It may include one guest complaint from a large party, illness in a neighboring school, social media buzz about illness from your location and / or a health inspection in response to a guest complaint of alleged illness.

The takeaway: the lessons learned continue to evolve and new ones emerge with each new outbreak. Making sure we identify and share these lessons across the industry and your organization is critical for being prepared to first identify and then quickly respond to the next threat that comes your way.

Question mark

Hiring and Training, Understanding FSMA Remain Big Industry Challenges

By Maria Fontanazza
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Question mark

A new industry survey is highlighting several issues facing food safety and quality assurance professionals, from employee retention to understanding the final FSMA rules. The 2016 Annual TraceGains Food Safety & Quality Assurance (FSQA) Professional Survey digs into the top priorities (FSMA compliance, audit readiness, supplier relationship management, etc.) of professionals and sheds light on some of the current challenges that companies are facing, especially in the area of compliance, FSMA readiness and supplier documentation.

“We’re seeing a recipe for stress in the food and beverage industry: Take one-part low margins, blend in one-part increased government regulation, one-part unannounced audits, one-part increasing customer demands, and one-part manual paperwork,” says Gary Nowacki, CEO of TraceGains. “Mix well, bake on high, then spread thinly with a limited pool of FSQA professionals.”

Anthony Arocha, TraceGains
Anthony Arocha, customer success consultant at TraceGains

Nearly 500 FSQA professionals participated in the survey. In a two-part Q&A with TraceGains, Anthony Arocha (customer success consultant), Rajan Gupta (vice president of customer success), and Jason Ulrich (customer success manager) explain what the results mean in to the broader industry.

Food Safety Tech: Were there any surprises with this year’s survey?

Anthony Arocha: FSMA compliance is across the board a top priority with staffing/training as one of the biggest obstacles to overcome. I would say this is a huge opportunity for automation to help reduce the risk and long-term costs incurred by the increasing demand for accurate documentation.

22% and 19% cited training and staffing respectively as a big challenge. Graphic courtesy of TraceGains.
22% and 19% cited training and staffing respectively as a big challenge. Graphic courtesy of TraceGains.

Rajan Gupta: I do not think there are any surprises but a very strong restatement that FSQA staff is difficult to hire/retain due to limited individual growth, low salaries, inadequate training, incentives, etc. All of these lead to the fact that most food companies look at food safety and quality as a nuisance that they must deal with versus as a function that is a necessity or a requirement with adequate funding.

Rajan Gupta, TraceGains
Rajan Gupta, vice president of customer success, TraceGains

FST: With FSMA being a top priority among survey respondents, are you finding that companies are concerned about any of the rules in particular?

Arocha: Honestly, it seems that most folks are trying very hard to get a handle on all the new rules and what their responsibility is for compliance. Not sure they have gotten to the point of having just one or two main concerns yet. There is more emphasis on creating strong relationships with the downstream and upstream customers and suppliers than ever before. Some of the rules seem vague, which will require an operation to be prepared to support how they meet a particular requirement or may be potentially exempt from it. These have been some of the concerns that seem to be popping up most.

FSQAStaff_TraceGains
Survey Question: What, if anything, hinders your company’s ability to on-board, recruit, and retain skilled FSQA staff? (Graphic courtesy of TraceGains)
Jason Ulrich, TraceGains
Jason Ulrich, customer success manager, TraceGains

Gupta: The main theme that we hear from our customers is that there is confusion. Companies have had to deal with many requirements in the past, some of which conflict each other. I think lack of a thorough understanding of food safety within an organization is a key limiting factor to truly determine what is needed at each organization to meet FSMA guidelines.

Jason Ulrich: Companies are concerned about FSMA. Most are concerned with FSMA as a whole. Many have taken steps to educate themselves, but the law is vague, especially for companies that are in multiple areas of food manufacturing.

Part two of the discussion will explore supplier documentation and automation.

Maria Fontanazza, Editor-in-Chief, Innovative Publishing Co. LLC
From the Editor’s Desk

Who Will Carry the Food Safety Torch?

By Maria Fontanazza
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Maria Fontanazza, Editor-in-Chief, Innovative Publishing Co. LLC

Each and every business in the food industry is facing a growing and daunting task: not just succession planning but also preparing for what could be an absence of qualified millennials entering the food safety profession.

At this year’s IAFP conference, the concern over professional development in this industry was at the forefront. “If we’re going to fill our shoes, where are the shoes walking?” asked Brian Bedard, executive director of the Grocery Manufacturers Association’s Science and Education Foundation. “How do we get young people excited about this profession? What are the programs we can get involved in to expose young people to this at a very young age?”

The question of how we are going to find passionate people to work in the food safety space, especially regarding the recruitment and training of millennials, is a big one. We need to make sure we are prepared to have the resources that will help build future success in food safety. In order to recruit those resources, we need to create more enthusiasm surrounding the field and make it a profession that people aspire to be a part of when they “grow up”.

“If we’re talking about the future…we need to get to the core of where people are making their life decisions and not waiting,” said Bedard. Yes, we need people with a Masters of Science degree in food science or nutrition, or expertise in microbiology and the like, but we also need people who know how a manufacturing or processing plant operates; we need people with knowledge about sanitary engineering and sanitary design, pointed out Bedard. With the changing landscape that we will experience with FSMA implementation, do you think we are armed with the resources to handle this paradigm shift as we look to the future?

Are we being proactive enough? How is your company working to invigorate the younger generation to become involved in this industry?  

RFID tags on drying marijuana flowers

Marijuana Edibles: Update on a Rapidly Developing Market

By Aaron G. Biros
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RFID tags on drying marijuana flowers

A lot has changed since last year’s article, “Marijuana Edibles: A Regulatory Nightmare.” Marijuana has since catapulted into mainstream thinking via activism, state decriminalization, and medical reforms while investors and banks are beginning to trust the market more, further legitimizing the nascent industry. According to an article from the Washington Post, Colorado’s legal marijuana industry reached $700 million in 2014 and is expected to grow to $1 billion by 2016.

Innovators are beginning to analyze trends on a national level, looking toward federal rescheduling of the drug as a catalyst for more state reforms and wider legalization measures. Federal legalization is in the back of many minds, as the introduction of pivotal state and federal legislative reforms promises more access to banking services, medical research, and more state independence.

While a black market mentality remains prevalent, widespread state reforms, increased venture capital investment, and further legitimization of an industry with less barriers of entry have fostered a perceived reduction in risk. States like Oregon, Washington, and Colorado that have already legalized marijuana for recreational and medical sales are beginning to implement strict packaging rules, requirements for traceability, QA programs, testing and laboratory monitoring requirements, and other regulations that would suggest FDA oversight down the road.

marijuana buds drying in racks biotrackthc
Dried marijuana buds curing with RFID tags as part of the traceability system of BiotrackTHC

State regulatory bodies such as the Colorado Marijuana Enforcement Division (MED) have matured and expanded their oversight to include certifications and requirements for lab testing and analysis. Marijuana testing facilities can now be certified by the MED to test for residual solvents, poisons or toxins, harmful chemicals, dangerous molds, mildew or filth, harmful microbials such as E. coli or Salmonella, pesticides, and THC levels and Cannabinoid potency.

According to an article from theCannabist.com, edible marijuana took 45% of the market share in 2014 and continues to grow, proving that food manufacturers and processors will gain a bigger share of the market.

BioTrackTHC develops a seed-to-sale traceability system that is the state-mandated reporting system used by any business that touches the plant in compliance with Washington’s i502 regulations (The company also won the contract bid for New Mexico’s and New York’s state-run traceability systems). “From day one, all retail products under i502, including infused edibles, must have laboratory-submitted passing test results and data in the traceability system before it can be unlocked for shipment to retailers,” says Patrick Vo, CEO of BioTrackTHC.

RFID tags on drying marijuana flowers
RFID tags on drying marijuana flowers, from BioTrackTHC

Regulations, especially those addressing traceability, are crucial for advancing the industry and fighting the black market, performing recalls, and improving product quality and safety. Vo adds, “As more states adopt a centralized traceability system, food safety will improve as we see the industry grow.”

“Most of the marijuana edibles producers we advise are working comfortably within their state health department regulations versus a year ago when they were struggling to implement routine compliance,” says Stephen Goldner, CEO of Regulatory Affairs Associates.  “But there is a long way to go to make this new marketplace meet the standards routinely met by US food producers in other markets such as nutritional supplements and medical foods.”

Many edible producers are sadly mistaken to ignore FDA labeling and production regulations just because the producer only ships within their own state, according to Goldner. “Whenever FDA has found label or food safety violations of products, whether they are food, drugs or any other product, it has always acted quickly to seize the product, inspect the producer and insist that violative labeling or production practices be remedied,” he says, adding that it won’t be surprising to see FDA start to “seize marijuana-infused food products that make drug claims, especially from the leading current producers” as a way for the agency to insert itself into the inspection and compliance process. “These companies need to have FDA food GMP’s solidly in place and properly documented,” says Goldner.

“Those who have experienced the most consistent and long term success in this industry are those who play above board, those who take the extra effort and make the investment in effort, time, and money to treat their business as if it was already federally legal and had to adhere to standards that other industries must follow,” says Vo. He agrees with the view held by many that long term planning is vital in this industry. “Those who have implemented best practices, QA programs, and traceability software will succeed in the long run, and the bad actors will eventually, by their own poor practices, be filtered out by regulatory and market forces.”

In the near future, the industry will look to other states in regulatory experiments on opposite sides of the spectrum. “New York, which legalized medical marijuana in 2014, is handing out 5 licenses to operate 4 dispensaries each, and allowing licensees to have a grow facility to supply their respective dispensaries. The Commissioner of the New York State Department of Health will have authority on licensing, testing, and medical requirements for patients seeking treatment with medical marijuana,” says R. David Marquez, who operates a Long Island law firm focusing on the cannabis industry.

New York is implementing very strict rules regarding cultivating and processing the plant. California, on the other side of the spectrum, already operates a somewhat loosely regulated medical marijuana market and has been doing so since 1996. The bill to legalize marijuana recreationally in the state is widely expected to pass vote and be implemented in 2016. This would open up an enormous market potential and contribute to the growth of the industry on a national level.

Because marijuana edibles are theoretically both a food and a drug, it is only appropriate that the FDA should look to regulate the industry in the future. In the meantime “Those who have invested the time and money in staying compliant now will be far ahead of the game tomorrow,” says Patrick Vo, who is looking toward federal legalization.

It seems that manufacturers and processors at the forefront of quality and safety testing will succeed in the long run.

Footnote: This is a regulatory update on the cannabis industry with an emphasis on edible marijuana. CannabisIndustryJournal.com, the newest publication, will be launched in September of this year. CannabisIndustryJournal.com will educate the marketplace covering news, technology, business trends, safety, quality, and the regulatory environment, aiding in the advancement of an informed and safe market for the global cannabis industry. Stay tuned for more!

Deirdre Schlunegger, STOP Foodborne Illness
Food Safety Culture Club

Join the Club

By Deirdre Schlunegger
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Deirdre Schlunegger, STOP Foodborne Illness
 
Deirdre Schlunegger, CEO of STOP Foodborne Illness 

What is the Food Safety Culture Club and what does it mean?  Long before it was trending, STOP Foodborne Illness was talking about and cultivating food safety culture. We intimately know and share the compelling reasons, along with the “Why” behind food safety. Statistics without stories are not compelling. By hearing the stories and seeing the faces of those who have been ill or who have lost loved ones, the reason for a food safety culture is remembered—and these memories may translate into everyday food safety practices. Everyone has a role in food safety but for some, the only role was to become ill.  Think about cantaloupe, peanut butter, ice cream, pre-washed greens, candy apples and more.

Why should you care?  We are all consumers; we all have children, parents, friends and loved ones who we do not want to become ill from a preventable illness. No one wants for individuals to contract a foodborne illness.

So here we are, on a journey towards creating strong food safety culture in the lives of business leaders, the food industry, employees handling food, and in our schools and homes. I recently attended several conferences that had themes and program titles related to “A Food Safety Culture”. We know it is critical for leaders to embrace the culture, model safe and best practices, and we know it is important to share the reasons why.

In this column, I will talk about summer food safety, back to school food safety, the importance of hand washing, and many other Food Safety Culture Club topics.  

You are a significant contributor in keeping food safe; you make a difference.

STOP Foodborne Illness is a national nonprofit organization dedicated to preventing illness and death from foodborne illness by advocating for sound public policy, building public awareness, and assisting those impacted by foodborne illness. Contact STOP Foodborne Illness if you are interested in having one of the staff members or board members speak at your training.