Tag Archives: FSMA

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part II)

By Frank Pisciotta, Spence Lane
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Food defense is the effort to protect food from intentional acts of adulteration where there is an intent to cause harm. Like counterterrorism laws for many industries, the IA rule, which established a compliance framework for regulated facilities, requires that these facilities prepare a security plan—in this case, a food defense plan—and conduct a vulnerability assessment (VA) to identify significant vulnerabilities that, if exploited, might cause widescale harm to public health, as defined by the FDA. Lessons learned during the conduct of food defense vulnerability and risk assessments and the preparation of the required food defense plan are detailed throughout this three-part series of articles. Part I of this series addressed the importance of a physical security expert, insider threat detection programs, actionable process steps (APS) and varying approaches to a VA. To further assist facilities with reviewing old or conducting new VAs, Part II will touch on access, subject matter experts, mitigation strategies and community drinking water through more lessons learned from assessments conducted for the largest and most complex global food and beverage facilities.

Lesson 6: Utilization of Card Access. The FDA costs of implementing electronic access control, as reported in the Regulatory Impact Analysis document (page 25) are shown in Table 1.

Average Cost Per Covered Facility Initial Recurring Total Annualized
Prohibit after hours key drop deliveries of raw materials $ $1070 $1070
Electronic access controls for employees $1122 $82 $242
Secured storage of finished products $1999 $– $285
Secured storage of raw materials $3571 $– $508
Cameras with video recording in storage rooms $3144 $– $448
Peer monitoring of access to exposed product (not used) $47 $1122 $1129
Physical inspection of cleaned equipment $– $303 $22
Prohibit staff from bringing personal equipment $157 $– $22
Total $9993 $1455 $2878
Table I. Costs of Mitigation

In our opinion, these costs may be underreported by a factor of five or more. A more realistic number for implementing access control at an opening is $5,000 or more depending on whether the wire needs to be run in conduit, which it typically would. While there are wireless devices available, food and beverage organizations should be mindful that the use of wireless devices may in some cases result in the loss of up to 50% of electronic access control benefits. This happens because doors using this approach may not result in monitored-for-alarm conditions, such as when doors are held open too long or are forced open. Some wireless devices may be able to report these conditions, but not always as reliable as hardwired solutions. Using electronic access control without the door position monitoring capability is a mistake. From a cost standpoint, even a wireless access control device would likely be upwards of $2,000 per opening.

Lesson 7: In the interest of time, and in facilities with more complex processes (which increases the work associated with the VA), plan to have quality, food safety and physical security personnel present for the duration of the VA. But also bring in operational specialists to assess each point, step or procedure for the respective operational areas. You may wish to have a quick high-level briefing for each operational group when it’s their turn to deliberate on their portion of the manufacturing operation. Proper planning can get a hybrid style VA done in one-and-a-half to three days maximum for the most complex of operations.

Lesson 8: Conduct a thorough site tour during the assessment process; do not limit your vulnerability activity to a conference room. Both internal and external tours are important in the assessment process by all members of the team. The external tour is needed to evaluate existing measures and identify vulnerabilities by answering questions such as:

  • Is the perimeter maintained?
  • Are cameras pointed correctly?
  • Are doors secure?
  • Are vehicles screened?
  • Are guards and guard tours effective?
  • Internal tours are important to validate documented HACCP points, steps or procedures.A tour also helps to validate process steps that are in multiple parts and may need to be further assessed as a KAT, for public health impact, accessibility and feasibility or to identify issues that have become “invisible” to site employees which might serve a security purpose.
  • Properly conducted tours measure the effectiveness of a variety of potential internal controls such as:
    • Access control
    • Visitor controls
    • Use of identification measures
    • Use of GMP as a security measure (different colors, access to GMP equipment and clean rooms)
    • Effectiveness of buddy systems
    • Employee presence

Lesson 9: Do not forget the use of community drinking water in your processes. This is an easy way to introduce a variety of contaminants either in areas where water is being treated on site (even boiler rooms) or where water may sit in a bulk liquid tank with accessibility through ladders and ports. In our experience, water is listed on about half of the HACCP flow charts we assessed in the VA process.

Lesson 10: Some mitigation strategies may exist but may not be worth taking credit for in your food defense plan. Due to the record keeping requirements being modeled after HACCP, monitoring, corrective action and verification records are required for each mitigation strategy associated with an APS. This can often create more work than it is worth or result in a requirement to create a new form or record. Appropriate mitigation strategies should always be included in your food defense plan, but sometimes it produces diminishing returns if VA facilitators try to get too creative with mitigation strategies. Also, it is usually better to be able to modify an existing process or form than having to create a new one.

Lesson 11: In cases of multi-site assessments, teams at one plant may reach a different conclusion than another plant on whether an identical point, set or procedure is an APS. This is not necessarily a problem, as there may be different inherent conditions from one site to the next. However, we strongly suggest that there be a final overall review from a quality control standpoint to analyze such inconsistencies adjudicate accordingly where there is no basis for varying conclusions.

Lesson 12: If there is no person formally responsible for physical security at your site, you may have a potential gap in a critical subject matter area. Physical security measures will make at least a partial contribution to food defense. Over 30 years, we have seen many organizations deploy electronic access control, video surveillance and lock and key control systems ineffectively, which provides a false sense of security and results in unidentified vulnerability. It is as important to select the right physical security measures to deploy, but also critical to administer them in a manner that meets the intended outcome. Most companies do not have the luxury of a full-time security professional, but someone at the plant needs to be provided with a basic level of competency in physical security to optimize your food defense posture. We have developed several online training modules that can help someone who is new to security on key food defense processes and security system administration.

Lesson 13: As companies move into ongoing implementation and execution of the mitigation strategies, it is important to check that your mitigation strategies are working correctly. You will be required to have a monitoring component, correction action and verification intended for compliance assurance. However, one of the most effective programs we recommend for our clients’ food defense and physical security programs is the penetration test. The penetration test is intended to achieve continuous improvement when the program is regularly challenged. The Safe Quality Food (SQF) Institute may agree with this and now requires facilities that are SQF certified to challenge their food defense plan at least once annually. We believe that frequency should be higher. Simple challenge tests can be conducted in 10 minutes or less and provide substantial insight into whether your mitigation strategies are properly working or whether they represent food defense theater. For instance, if a stranger were sent through the plant, how long would it take for employees to recognize and either challenge or report the condition? Another test might include placing a sanitation chemical in the production area at the wrong time. Would employees recognize, remove and investigate that situation? Challenge tests are easy high impact activities; and regardless of the outcome, can be used to raise awareness and reinforce positive behaviors.

Whether training a new security officer, reviewing existing security plans or preparing for an upcoming vulnerability assessment (due July 26, 2020), these lessons learned from experienced security consultants should help to focus efforts and eliminate unnecessary steps at your facility. The final installment in this series will address broad mitigation strategies, the “Three Element” approach and food defense plan unification.

Colleen Costello, VitalVio
FST Soapbox

Prevention Takes Center Stage to Address Food Recalls

By Colleen Costello
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Colleen Costello, VitalVio

In the complex food supply chain, a single product travels a long journey before reaching consumers’ plates. It’s no wonder that it has become so difficult to control the quality and safety of food. As food moves from trucks to conveyor belts and through grocery store shelves and shopping carts, the risk for harmful bacteria to contaminate products rises immensely. What’s worse is pinpointing the source of contamination can be nearly impossible, leaving food manufacturers scrambling to “fix” the error without even knowing the cause.

In recent recalls, processing plants completely shut down operations in an effort to resolve the issue and thoroughly sanitize their entire facilities. While this is good news for consumers, this type of reactive response will undoubtedly have a long-term, irreversible impact on the business—both financially and potentially for the brand’s reputation. Consumers remember the name of the company they heard on the evening news that had to pull thousands of pounds of products from shelves in their city or region. Then, when they make their weekly trip to the grocery store, they likely make sure to avoid that company’s products in fear of potential quality issues that could make them and their families sick. It’s a deadly cycle for consumers and public health, as well as business livelihood.

Product and consumer safety must continue to be the top priority for the food industry. The success of these companies literally depends on it. With so much on the line, the food industry must come together to spark a shift in how they operate to prevent food recalls rather than having to respond to them.

Stopping Recalls to Save Lives and Businesses

To move in the direction of mitigating pathogens from ever coming into contact with food and therefore preventing recalls altogether, processors must develop and deploy new strategies that keep facilities consistently clean. The U.S. government is stepping in with regulations such as FSMA that urge companies to shift from reactively responding to safety issues, to proactively working to prevent them. This is the fundamental shift that is needed across the food supply chain in order to protect consumers and food producing businesses.

Important new technologies have emerged in recent years that can add new layers of meaningful protection to continuously combat contamination across the supply chain. When coupled with existing disinfection and cleaning practices, these new technologies can help mitigate the introduction of harmful pathogens as food moves from point A to point B, with all the stops made in between.

One example is the advent of a new class of technology that incorporates antimicrobial LED lighting, which enables food processors to take an “always on” approach to keeping surfaces free of harmful pathogens. Since these lights meet international standards for unrestricted and continuous use around people, they’re able to irradiate large places and the smallest of spaces, all while workers are present.

However, simply deploying these new technologies isn’t enough. For new prevention strategies to be truly successful, food processors should consider the bigger picture. A large percentage of food processors focus primarily on bolstering their sanitation approaches in the areas that have the highest likelihood of coming into contact with food products. This is logical, as Zone 1 and Zone 2 are typically the highest risk for contracting and spreading harmful pathogens.

Environmental Safety Zones
Environmental safety zones. Figure courtesy of Vital Vio.

However, processors are leaving holes in their sanitation strategies by not taking measures to keep areas, such as Zone 3 and Zone 4, also well protected. To ensure food remains free of contaminants, plant managers must ensure the entire environment is fully protected, including the belts and vessels that the food touches, as well as the break rooms where employees rest and offices where management holds meetings. If these areas aren’t kept equally as clean, facilities are risking outside contaminants to enter Zone 1 that can ultimately compromise their food products.

Food recalls have become eerily common, putting a strain on public health and businesses. To stop what seems to be rising to crisis level, all companies involved in the food supply chain need to take a proactive stance toward prevention. This means deploying advanced technologies that continuously prevent harmful pathogens from taking root anywhere in their facilities. Simple yet thoughtful solutions, such as antimicrobial LED lighting, ensure food companies are one step closer to keeping all of us and their businesses safe.

Megan Nichols
FST Soapbox

How Will AR and VR Improve Safety in the Food Industry?

By Megan Ray Nichols
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Megan Nichols

The food and beverage sector is a huge presence in the U.S. economy. As of 2017, the industry employed 1.46 million people across 27,000 different establishments. Total food and beverage sales stand at around $1.4 trillion and add $164 billion in value to the economy as a whole.1 This presents significant opportunities and risks alike. Companies that trade in food products are held to some of the highest regulatory standards. With globalization ongoing and a higher demand than ever for variety and niche products, companies find they need to expand the mobility of their services. They must also broaden their product choices without missing a beat when it comes to quality.

Augmented reality (AR) and virtual reality (VR) have emerged as unlikely allies in that quest. These technologies are already having a positive impact on food and worker safety in the industry.

Improves New Employee Training

Onboarding and training new employees is a costly and time-consuming endeavor in any industry. Moreover, failure by companies to impart the necessary skills, and failure by employees to retain them, can have ghastly consequences. Errors on assembly lines may result in faulty products, recalls, worker and customer injuries, and worse.

The stakes in the food and beverage sector are just as high as they are in other labor- and detail-oriented industries. VR provides an entirely new kind of training experience for employees, whether they’re working on mastering their pizza cutting technique or brewing the perfect cappuccino. Other times, “getting it right” is about much more than aesthetic appeal and immediate customer satisfaction.

Animal slaughtering and processing facilities represent some of the more extreme examples of potentially dangerous workplaces in the larger food and beverage industry. Between 2011 and 2015, this U.S. sector experienced 73 fatal workplace injuries. Excepting poultry processing, 2015 saw 9,800 recordable incidents in animal processing, or 7.2 cases for every 100 full-time employees.

Some adopters of VR-based employee training claim that virtual reality yields up to an 80% retention rate one year after an employee has been trained. This compares extremely favorably to the estimated 20% retention rate of traditional training techniques.

Training via VR headset can help companies get new hires up to speed faster in a safe, detailed and immersive environment. Food processing and service are high-turnover employment sectors. The right training technology can help workers feel better prepared and more engaged with their work, potentially reducing employee churn.

Helps Eliminate Errors in Food Processing

Augmented reality is already demonstrating great promise in manufacturing, maintenance and other sectors. For instance, an AR headset can give an assembly line worker in an automotive plant detailed, step-by-step breakdowns of their task in their peripheral vision through a digital overlay.

The same goes for food and beverage manufacturing. AR headsets can superimpose a list of inspection or processing tasks for workers to follow as they prepare food items in a manufacturing or distribution facility.

In 2018, there was an estimated 382 recalls involving food products. Augmented reality alone won’t bring that number down to zero. However, it does help reduce instances of line workers and inspectors missing critical steps in processing or packaging that might result in contamination or spoilage.

Eases the Learning Curve in Food Preparation

There are lots of food products in the culinary world that are downright dangerous if they’re not prepared properly and by following specific steps. Elderberries, various species of fish, multiple root vegetables, and even cashews and kidney beans can all induce illness and even death if the right steps aren’t taken to make them fit for consumption.

In early 2019, inspectors descended on a Michelin-starred and highly respected restaurant in Valencia, Spain. The problem? A total of 30 patrons reported falling ill after eating at El País, one of whom lost her life. Everyone reported symptoms similar to food poisoning.

The common element in each case appeared to be morel mushrooms. These are considered a luxury food item, but failure to cook them properly can result in gastric problems and worse. Augmented reality could greatly reduce the likelihood of incidents like this in the future by providing ongoing guidance and reminders to new and veteran chefs alike, without taking the bulk of their attention away from work.

Brings New Efficiencies to Warehousing and Pick-and-Pack

Consumers around the globe are getting used to ordering even highly perishable foodstuffs over the internet—and there’s no putting that genie back in the bottle. Amazon’s takeover of Whole Foods is an indicator of what’s to come: Hundreds of freezer-equipped and climate-controlled warehouses located within a stone’s throw from a majority of the American population.

Ensuring smooth operations in perishable food and beverage supply chains is a major and ongoing struggle. It’s not just a practical headache for companies—it’s something of a moral imperative, too. The World Health Organization finds that around 600 million individuals worldwide fall ill each year due to foodborne illnesses.

Augmented reality won’t completely solve this problem, but it may greatly reduce a major source of potential spoilage and contamination: Inefficiencies in picking and packing operations. Order pickers equipped with AR headsets can:

  • Receive visual prompts to quickly find their way to designated stow locations in refrigerated warehouses after receiving refrigerated freight.
  • Locate pick locations more efficiently while retrieving single items or when they already have a partial order of perishable goods picked.

In both cases, the visual cues provided by AR help employees navigate warehousing locations much more quickly and efficiently. This substantially lowers the likelihood that food products are stuck in limbo in unrefrigerated areas, potentially coming into contact with noncompliant temperatures or pathogens. The FDA recognizes mispackaged and mislabeled food products as a major public health risk.

For food and beverage companies, AR should be a welcome development and a worthy investment. FSMA recognized that 48 million Americans get sick each year from compromised foods. The act required these entities to be much more proactive in drawing up prevention plans for known sources of contamination and to be more deliberate in standardizing their processes for safety’s sake.

AR and VR Boost Food, Worker and Customer Safety

Augmented and virtual reality may seem like an unusual ally in an industry where most consumers are primarily focused on the aesthetic and sensory aspects of the experience. However, there’s a whole world that lives and dies according to the speed and attention to detail of employees and decision-makers alike. Augmented realities, and entirely new ones, point the way forward.

Reference

  1. Committee for Economic Development of The Conference Board. (March 2017). “Economic Contribution of the Food and Beverage Industry. Retrieved from https://www.ced.org/pdf/Economic_Contribution_of_the_Food_and_Beverage_Industry.pdf.
Susanne Kuehne, Decernis
Food Fraud Quick Bites

Keeping Food Safe, the U.S. Way

By Susanne Kuehne
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Susanne Kuehne, Decernis
Food fraud
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne.

In the United States, the FDA is responsible for regulations and recommendations to protect public health, which includes the prevention of any type of food adulteration (unintentional contamination, intentional adulteration, and food fraud – or “economically motivated adulteration”). FSMA (the Food Safety Modernization Act) resulted in new regulations and guidance with strategies to reduce all types of risks in food facilities. It was the most comprehensive reform of FDA’s food safety regulations in more than 70 years.

Resource

  1. FSMA Rules & Guidance for Industry.

 

Data protection, security

The Digital Transformation of Global Food Security

By Katie Evans
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Data protection, security

Modern food supply chains are inherently complex, with products typically passing through multiple suppliers and distributors, as well as countries and continents, before they end up on the supermarket shelf. While global supply chains offer consumers greater choice and convenience, they also make protecting the security of food products more challenging. With additional stakeholders between farm and fork, products are exposed to an elevated risk of biological or chemical contamination, as well as food counterfeiting and adulteration challenges—potentially putting consumer health and brand reputation in jeopardy.

Given the importance of maintaining the safety, quality and provenance of food products, global regulatory bodies are placing the integrity of supply chains under increased scrutiny. In the United States, for example, the adoption of FSMA moved the focus from responding to foodborne illnesses to preventing them by prioritizing comprehensive food testing measures, enforcing inspections and checks, and enabling authorities to react appropriately to safety issues through fines, recalls or permit suspensions.1 Similarly, China’s revised Food Safety Law (known as FSL 2015) is widely considered to be the strictest in the country’s history, and seeks to drive up quality standards by empowering regulators, and enhancing traceability and accountability through robust record-keeping. 2 The European Union continues to closely regulate and monitor food safety through its General Food Law, which is independently overseen by the European Food Safety Authority from a scientific perspective.

Achieving the Highest Standards of Food Security, Integrity and Traceability

For producers, manufacturers and distributors, the heightened regulatory focus on the security and integrity of the food supply chain has placed additional emphasis on accurate record-keeping, transparent accountability and end-to-end traceability. To meet the needs of the modern regulatory landscape, food chain stakeholders require robust systems and tools to manage their quality control (QC), environmental monitoring and chain of custody data. Despite this, many businesses still handle this information using paper-based approaches or localized spreadsheets, which can compromise operational efficiency and regulatory compliance.

The fundamental flaw of these traditional data management approaches is their reliance on manual data entry and transcription steps, leaving information vulnerable to human error. To ensure the accuracy of data, some companies implement resource-intensive verification or review checks. However, these steps inevitably extend workflows and delay decision-making, ultimately holding up the release of products at a high cost to businesses. Moreover, as paper and spreadsheet-based data management systems must be updated by hand, they often serve merely as a record of past events and are unable to provide insight into ongoing activities. The time lag associated with recording and accessing supply chain information means that vital insight is typically unavailable until the end of a process, and data cannot be used to optimize operations in real-time.

Furthermore, using traditional data management approaches, gathering information in the event of an audit or food safety incident can be extremely challenging. Trawling through paperwork or requesting information contained in spreadsheets saved on local computers is time-consuming and resource-intensive. When it comes to establishing accountability for actions, these systems are often unable to provide a complete audit trail of events.

Digital Solutions Transform Food Security and Compliance

Given the limitations of traditional workflows, food supply chain stakeholders are increasingly seeking more robust data management solutions that will allow them to drive efficiency, while meeting the latest regulatory expectations. For many businesses, laboratory information management systems (LIMS) are proving to be a highly effective solution for collecting, storing and sharing their QC, environmental monitoring and chain of custody data.

One of the most significant advantages of managing data using LIMS is the way in which they bring together people, instruments, workflows and data in a single integrated system. When it comes to managing the receipt of raw materials, for example, LIMS can improve overall workflow visibility, and help to make processes faster and more efficient. By using barcodes, radiofrequency identification (RFID) tags or near-field communication, samples can be tracked by the system throughout various laboratory and storage locations. With LIMS tracking samples at every stage, ingredients and other materials can be automatically released into production as soon as the QC results have been authorized, streamlining processes and eliminating costly delays.

By storing the standard operating procedures (SOPs) used for raw material testing or QC centrally in a LIMS, worklists, protocols and instrument methods can be automatically downloaded directly to equipment. In this way, LIMS are able to eliminate time-consuming data entry steps, reducing the potential for human error and improving data integrity. When integrated with laboratory execution systems (LES), these solutions can even guide operators step-by-step through procedures, ensuring SOPs are executed consistently, and in a regulatory compliant manner. Not only can these integrated solutions improve the reliability and consistency of data by making sure tests are performed in a standardized way across multiple sites and testing teams, they can also boost operational efficiency by simplifying set-up procedures and accelerating the delivery of results. What’s more, because LIMS can provide a detailed audit trail of all user interactions within the system, this centralized approach to data management is a robust way of ensuring full traceability and accountability.

This high level of operational efficiency and usability also extends to the way in which data is processed, analyzed and reported. LIMS platforms can support multi-level parameter review and can rapidly perform calculations and check results against specifications for relevant customers. In this way, LIMS can ensure pathogens, pesticides and veterinary drug residues are within specifications for specific markets. With all data stored centrally, certificates of analysis can be automatically delivered to enterprise resource planning (ERP) software or process information management systems (PIMS) to facilitate rapid decision-making and batch release. Furthermore, the sophisticated data analysis tools built into the most advanced LIMS software enable users to monitor the way in which instruments are used and how they are performing, helping businesses to manage their assets more efficiently. Using predictive algorithms to warn users when principal QC instruments are showing early signs of deterioration, the latest LIMS can help companies take preventative action before small issues turn into much bigger problems. As a result, these powerful tools can help to reduce unplanned maintenance, keep supply chains moving, and better maintain the quality and integrity of goods.

While LIMS are very effective at building more resilient supply chains and preventing food security issues, they also make responding to potential threats much faster, easier and more efficient. With real-time access to QC, environmental monitoring and chain of custody data, food contamination or adulteration issues can be detected early, triggering the prompt isolation of affected batches before they are released. And in the event of a recall or audit, batch traceability in modern LIMS enables the rapid retrieval of relevant results and metadata associated with suspect products through all stages of production. This allows the determination of affected batches and swift action to be taken, which can be instrumental in protecting consumer safety as well as brand value.

Using LIMS to Protect Security and Integrity of the Food Supply Chain

Increasingly, LIMS are helping businesses transform food security by bringing people, instruments and workflows into a single integrated system. By simplifying and automating processes, providing end-to-end visibility across the food supply chain, and protecting the integrity of data at every stage, these robust digital solutions are not only helping food supply chain stakeholders to ensure full compliance with the latest regulations; they are enabling businesses to operate more efficiently, too.

References

  1. FDA. (2011). FDA Food Safety Modernization Act. Accessed October 3, 2019. Retrieved from https://www.fda.gov/food/food-safety-modernization-act-fsma/full-text-food-safety-modernization-act-fsma.
  2. Balzano, J. (2015). “Revised Food Safety Law In China Signals Many Changes And Some Surprises”. Forbes. Accessed October 3, 2019. Retrieved from https://www.forbes.com/sites/johnbalzano/2015/05/03/revised-food-safety-law-in-china-signals-many-changes-and-some-surprises/#624b72db6e59.
John McPherson, rfxcel
FST Soapbox

End-to-End Supply Chain Traceability Starts with High-Quality Data

By John McPherson
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John McPherson, rfxcel

End-to-end traceability technology across the food and beverage (F&B) supply chain has many benefits for companies at all nodes of the chain, not least of which is the ability to act to prevent problems such as irreversible damage, loss, and theft. For these technologies to best deliver on their promise, however, they need standardized and quality-assured data. F&B supply chain stakeholders need to take steps to achieve effective data management to truly take advantage of the benefits of traceability and real-time monitoring technologies.

Since FSMA was introduced in 2011, actors across the F&B supply chain have had to change their behavior. Prior to FSMA, companies tended to react to events; today, proactive and preemptive measures are the norm. This is in line with what the legislation was designed to do: Encourage the prevention of foodborne illness instead of responding after their occurrance.

F&B manufacturers and distributors rely on technology to help predict potential obstacles and mitigate issues along their supply chains. But expressing a desire to embrace technologies such as real-time monitoring solutions and predictive analytics isn’t enough to achieve ultimate supply chain efficiency. Only by taking the necessary steps can companies get on track to ensure results.

Any company that is thinking about deploying a traceability solution has a lot to consider. Foremost, data must be digitized and standardized. This might seem challenging, especially if you’re starting from scratch, but it can be done with appropriate planning.

Let’s examine what F&B companies stand to gain by adopting new, innovative technologies and how they can successfully maximize data to achieve end-to-end supply chain traceability.

New Technologies Hold Huge Potential for F&B Supply Chains

The advantages of adopting new technologies far outweigh the time and effort it takes to get up and running. To smooth the process, F&B companies should work with solution providers that offer advisory services and full-service implementation. The right provider will help define your user requirements and create a template for the solution that will help ensure product safety and compliance. Furthermore, the right provider will help you consider the immediate and long-term implications of implementation; they’ll show you how new technologies “future-proof” your operations because they can be designed to perform and adapt for decades to come.

Burgeoning technologies such as the Internet of Things (IoT), artificial intelligence (AI) and blockchain are driving end-to-end traceability solutions, bridging the gap between different systems and allowing information to move seamlessly through them.

For example, real-time tracking performed by IoT-enabled, item-level sensors allows companies to detect potential damage or negative events such as theft. These devices monitor and send updates about a product’s condition (e.g., temperature, humidity, pressure, motion and location) while it is in transit. They alert you as soon as something has gone wrong and give you the power to take action to mitigate further damage.

This is just one example of how data from a fully implemented real-time, end-to-end traceability platform can yield returns almost immediately by eliminating blind spots, identifying bottlenecks and threats, and validating sourcing requirements. Such rich data can also change outcomes by, for example, empowering you to respond to alerts, intercept suspect products, extend shelf life, and drive continuous improvement.

As for AI technologies, they use data to learn and predict outcomes without human intervention. Global supply chains are packed with diverse types of data (e.g., from shippers and suppliers, information about regulatory requirements and outcomes, and public data); when combined with a company’s internal data, the results can be very powerful. AI is able to identify patterns through self-learning and natural language, and contextualize a single incident to determine if a larger threat can be anticipated or to make decisions that increase potential. For example, AI can help automate common supply chain processes such as demand forecasting, determine optimal delivery routes, or eliminate unforeseeable threats.

Blockchain has garnered a lot of buzz this year. As a decentralized and distributed data network, it’s a technology that might help with “unknowns” in your supply chain. For example, raw materials and products pass through multiple trading partners, including suppliers, manufacturers, distributors, carriers and retailers, before they reach consumers, so it can be difficult to truly know—and trust—every partner involved in your supply chain. The immutable nature of blockchain data can build trust and secure your operations.

To date, many F&B companies have been hesitant to start a blockchain initiative because of the capital risks, complexity and time-to-value cost. However, you don’t have to dive in head-first. You can start with small pilot programs, working with just a few stakeholders and clearly defining pilot processes. If you choose the right solution provider, you can develop the right cultural shift, defining governance and business models to meet future demands.

To summarize, new technologies are not disruptive to the F&B industry. If you work with an experienced solution provider, they will be constructive for the future. Ultimately, it’s worth the investment.

So how can the F&B industry start acting now?

How to Achieve End-to-End Traceability

Digitize Your Supply Chain. We live in a digital world. The modern supply chain is a digitized supply chain. To achieve end-to-end traceability, every stakeholder’s data must be digitized. It doesn’t matter how big your company is—a small operation or a global processor—if your data isn’t digitized, your supply chain will never reach peak performance.

If you haven’t begun transitioning to a digitalized supply chain, you should start now. Even though transforming processes can be a long journey, it’s worth the effort. You’ll have peace of mind knowing that your data is timely and accurate, and that you can utilize it to remain compliant with regulations, meet your customer’s demands, interact seamlessly with your trading partners, and be proactive about every aspect of your operations. And, of course, you’ll achieve true end-to-end supply chain traceability.

Standardize Your Data. As the needs of global F&B supply chains continue to expand and become more complex, the operations involved in managing relevant logistics also become more complicated. Companies are dealing with huge amounts of non-standardized data that must be standardized to yield transparency and security across all nodes of the supply chain.

Many things can cause inconsistencies with data. Data are often siloed or limited. Internal teams have their own initiatives and unique data needs; without a holistic approach, data can be missing, incomplete or exist in different systems. For example, a quality team may use one software solution to customize quality inspections and manage and monitor remediation or investigations, while a food safety team may look to a vendor management platform and a supply chain or operations team may pull reports from an enterprise resource planning (ERP) system to try and drive continuous improvement. Such conflict between data sources is problematic—even more so when it’s in a paper-based system.

Insights into your supply chain are only as good as the data that have informed them. If data (e.g., critical tracking events) aren’t standardized and quality-assured, companies cannot achieve the level and quality of information they need. Data standards coming from actors such as GS1 US, an organization that standardizes frameworks for easy adoption within food supply chains, can help with this.

There are many solutions to ensure data are standardized and can be shared among different supply chain stakeholders. With recent increases in recalls and contamination issues in the United States, the need for this level of supply chain visibility and information is even more critical.

Data Security. Data security is crucial for a successful digital supply chain with end-to-end traceability, so you must plan accordingly—and strategically. You must ensure that your data is safe 24/7. You must be certain you share your data with only people/organizations who you know and trust. You must be protected against hacks and disruptions. Working with the right solution provider is the best way to achieve data security.

Incentive Structures. Incentives to digitize and standardize data are still lacking across some parts of the F&B supply chain, increasing the chances for problems because all stakeholders are not on the same page.

Companies that continue to regard adopting traceability as a cost, not an investment in operations and brand security, will most likely do the minimum from both fiscal and regulatory standpoints. This is a strategic mistake, because the benefits of traceability are almost immediate and will only get bigger as consumers continue to demand more transparency and accuracy. Indeed, we should recognize that consumers are the driving force behind these needs.

Being able to gather rich, actionable data is the key to the future. Industry leaders that recognize this and act decisively will gain a competitive advantage; those that wait will find themselves playing catch-up, and they may never regain the positions they’ve lost. We can’t overstate the value of high-quality digitized and standardized data and the end-to-end traceability it fuels. If companies want to achieve full visibility and maximize their access to information across all nodes of their supply chains, they must embrace the available technologies and modernize their data capabilities. By doing so, they will reap the benefits of a proactive and predictive approach to the F&B supply chain.

Sean O'Leary, FoodLogiQ

The Value of a One Percent Improvement

By Food Safety Tech Staff
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Sean O'Leary, FoodLogiQ

During the past year, the headlines have been filled with stories of foodborne illness, product recalls, and consumers becoming sick from tainted food. In a Q&A with Food Safety Tech, Sean O’Leary, CEO at FoodLogiQ, talks food safety, traceability, and how small percentages can translate into big victories for the food industry and for the people they serve.

Food Safety Tech: From your perspective, what is the current sentiment of consumers with regard to food safety?

Sean O’Leary: Over the last few years, the consumer mindset has changed about food in general. We’ve watched fad diets come and go; however, the interest in healthy ingredients and the concern about where food comes from has graduated from a passing trend to a full shift into the public consciousness. Consumers are much more discerning about what they eat; they also demand to know where their food comes from, how it was produced, and how it got to their table. We are living in the age of transparency, and consumer expectations are high.

And who can blame them? CDC statistics tell us that approximately 48 million people get sick every year from foodborne illnesses—and that’s just in the United States; 128,000 of them end up in the hospital. When a person is admitted to the hospital, it affects more than just that one individual. If the patient is the sole breadwinner of their family, their illness affects the entire family. If the person who gets sick is a child, there can be long-term consequences that trickle down to his or her whole community. And when you consider that 3,000 people die every year from foodborne illness—that’s one 9/11 every year. That’s unacceptable, because this is a preventable issue, and unfortunately, these illnesses are an underreported public health problem.

My challenge to the food industry is simple: What if we made just a 1% improvement in the number of cases of foodborne illness? That seems like such a small percentage, but when you do that math, that’s 480,000 people who don’t get sick this year; 1,280 people who aren’t admitted to the hospital; and 30 people who don’t die. Those are significant numbers.

Sean O'Leary, FoodLogiQ
Sean O’Leary joined FoodLogiQ as CEO in January 2019 with more than 25 years of experience in the technology industry.

FST: To help shed additional light on this subject, FoodLogiQ conducted a national survey to tap into how U.S. consumers feel about issues related to food transparency. What did you learn from those consumer responses?

O’Leary: We polled more than 2,000 people to gauge their sentiment around food traceability and their expectations for food companies regarding foodborne illness and product recalls. The survey also posed questions around consumer preferences regarding their food sources and how they are identified on food labels and menus. The results were enlightening, to say the least.

We learned that a brand or restaurant will pay a high price in terms of customer loyalty if they experience a food recall due to consumer illness. And those customers have some strong opinions regarding how quickly the brand or restaurant should address a food safety issue.

  • 35% of survey respondents told us they would avoid an affected brand or restaurant for a few months, and maybe they would return after the issue had been resolved. Meanwhile, nearly 25% admitted they would never use the brand or visit the restaurant again.
  • Of the respondents who say they care about the quality of the food they eat, 55% say they expect a recall to be executed within 24 to 48 hours.

In reality, it sometimes takes weeks for a product to be pulled from the store or restaurant. This is frequently due to communication issues, since everyone along the supply chain—the grower, supplier, packing and distribution centers, corporate office, and the retailer or restaurant—all must be notified, and a recall plan must be set in motion. Unfortunately, that communication process takes time. When that communication takes place via email or by phone call, the people responsible for pulling product may not have the information they need or may have received misinformation. This can result in lag time, and potentially unsafe product can still get into the hands of consumers.

The faster a food company can address a recall situation and return to business as usual, the faster customers will come back. But comprehensive supply chain transparency is needed to be able to make swift, accurate decisions during this time of crisis. By having a robust end-to-end traceability program and technology that provides real-time data and visibility, companies facing a recall can isolate and surgically withdraw the tainted product out of the supply chain without recalling more items than necessary. That limits the disruption and the waste of good food, which saves the company money.

FST: You recently attended the FDA’s “A New Era of Smarter Food Safety” public meeting in Maryland. What do you think this new campaign will mean for the food industry?

O’Leary: FoodLogiQ was honored to have the opportunity to share our intricate knowledge of the food supply chain, as well as best practices regarding whole chain traceability during this monumental meeting with the FDA with more than 250 food industry leaders.

In retrospect, one thing is clear—we’re in the midst of a pivotal time of change for the world’s food supply chain. In the United States, the food industry remained status quo for decades, but the introduction of FSMA has brought increased scrutiny and accountability; I think it’s made every food company pause and evaluate where they are with regard to food safety, and that’s a good thing. And now, with the launch of the “New Era” campaign, we’re coming together in a collaborative fashion to map out how technology tools, prevention measures, new business models, and an evolving culture of food safety can be merged as a framework for a long term food safety solution. I agree with the FDA; ‘Smarter Food Safety’ is people-led, FSMA-based, and technology-enabled. It will take all of us working together to reach that goal.

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part I)

By Frank Pisciotta, Spence Lane
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Food defense is the effort to protect food from intentional acts of adulteration where there is an intent to cause harm. Like counterterrorism laws for many industries, the IA rule, which established a compliance framework for regulated facilities, requires that these facilities prepare a security plan—in this case, a food defense plan—and conduct a vulnerability assessment (VA) to identify significant vulnerabilities that, if exploited, might cause widescale harm to public health, as defined by the FDA. Lessons learned during the conduct of food defense vulnerability and risk assessments and the preparation of the required food defense plan are detailed throughout this three-part series of articles. Part I of this series is intended to assist facilities that have not yet conducted vulnerability assessments or wish to review those already conducted, by leveraging lessons learned from assessments conducted for the largest and most complex global food and beverage facilities.

Lesson 1: VA outcomes are greatly enhanced if a physical security professional is consulted. In support of this contention, there are several physical security mitigation strategies, which can be employed to support a food defense program, that are frequently under-utilized and are not optimally managed by non-security staff. Also, the FDA seems to promote the use of cameras even though this equipment is unlikely to prevent an incident of intentional adulteration. For organizations that choose to use video surveillance, a competent security professional can help organizations engineer and operate video surveillance for maximum benefits and to meet challenging record-keeping requirements when this mitigation strategy is included in a food defense plan.

Lesson 2: Given the focus by the FDA on the insider, a formal insider threat detection program is highly recommended. Trying to promote the common, “See Something, Say Something” strategy may not be enough. For example, if employees are not clearly told what to look for in terms of uniform requirements, how to identify persons who do not belong or changes to a coworker’s baseline behavior, which may indicate moving toward a path to violence or sabotage, then “See Something, Say Something” may end up being no more than a catchy slogan.

A key element of an insider threat detection program is the completion of effective background checks for all persons who will be allowed in the facility unescorted. This includes temporary employees and contractors. A common theme in many of the recent, serious intentional adulteration incidents was that the person responsible was involved in some sort of grievance observable to coworkers and supervisors. In all insider threat detection programs, the grievance becomes an important trip wire. The Carnegie Mellon University Software Engineering Institute has published a document titled, “Common Sense Guide to Mitigating Insider Threats, Sixth Edition”. In this document is some particularly helpful guidance that can be used to stand up an insider threat detection program, but this is an effort that can take some time to fully implement.

Lesson 3: The FDA has made it abundantly clear that they believe the focus for the food and beverage industry should be the radicalized insider. A closer look at all the recently publicized contamination events suggests that there are other profiles that need to be considered. A good foundational model for building profiles of potential offenders can be found in the OSHA definitions for workplace violence offenders, which has been expanded to address ideologically based attacks. Table I applies those descriptions to the food and beverage industry, with an asterisk placed by those offender profiles that exist in recent incidents and discussed later in the text.

Class OSHA Workplace Violence Offender Description Motivation Translated to the Food and Beverage Industry
1 The offender has no legitimate relationship to the business or its employee(s). Rather, the violence is incidental to another crime, such as robbery, shoplifting, trespassing or seeking social media fame. Behavioral Health Patient *
Social Media Fame Seeker *
Copycat *
Extortion *
Economic motivation *
2 The violent person has a legitimate relationship with the business—for example, the person is a customer, client, patient, student, or inmate—and becomes violent while being served by the business, violence falls into this category. My load isn’t ready, you are costing me money
3 The offender of this type of violence could be a current employee or past employee of the organization who attacks or threatens other employee(s) in the workplace. I am upset with a coworker and adulterate to create problems for that person *
I am upset with the company and adulterate as retribution and to harm the brand *
Youthful stupidity
I am not paid enough *
4 The offender may or may not have a relationship with the business but has a personal (or perceived personal) relationship with the victim. I am upset with an intimate partner/ coworker and adulterate to create problems for that person
5 Ideological workplace violence is directed at an organization, its people, and/or property for ideological, religious or political reasons. The violence is perpetrated by extremists and value-driven groups justified by their beliefs. Radicalized Insider
Table I. A description of OSHA workplace violence offenders and how it can be applied to the F&B industry.

A supermarket in Michigan recalled 1,700 lbs. of ground beef after 111 people fell ill with nicotine poisoning. The offender, an employee, mixed insecticide into the meat to get his supervisor in trouble. In Australia, the entire strawberry industry was brought to its knees after a disgruntled supervisor “spiked” strawberries with needles. There were more than 230 copycat incidents impacting many companies. A contract employee in Japan, apparently disgruntled over his low pay, sprayed pesticide on a frozen food processing line resulting in illnesses to more than 2,000 people. A contract worker upset with a union dispute with the company at a food manufacturing plant videoed himself urinating on the production line, then uploaded the video to the Internet. Be cognizant of any grievances in the workplace and increase monitoring or take other proactive steps to reduce the risk of intentional adulteration.

Lesson 4: The IA Rule requires that every point, step and procedure be analyzed to determine if it is an actionable process step (APS). The Hazard Analysis Critical Control Point flow charts are a good starting point to comply with this element of the law but cannot be counted on completely to achieve the standard of analyzing every point, step or procedure. Critical thinking and persons familiar with the production process need to be involved to ensure that no steps are missed. Oftentimes companies modify the HACCP flow diagrams after a VA.

Lesson 5: The FDA states in the second installment of guidance (here’s the full copy) to the industry that, “There are many possible approaches to conducting a VA. You may choose an approach based on considerations such as the time and resources available and the level of specificity desired. You have the flexibility to choose any VA approach, as long as your VA contains each required component (21 CFR 121.130).”

The FDA further states that the Key Activity Type, or KAT method, is an appropriate method for conducting a VA because it reflects consideration of the three required elements and the inside attacker. Using this methodology alone, however, can result in substantially more APS’s, which might otherwise be ruled out for practical purposes such as a lack of accessibility or a lack of feasibility to contaminate the product at a point, step or procedure. We have experienced up to a 90% decline in APS’s by utilizing another FDA recommended assessment approach, the hybrid approach, which assesses each point, step or procedure as first whether it is a KAT. Then to qualify as an APS, it must also trigger positively for public health impact, accessibility and feasibility to contaminate the product.

Organizations who have yet to execute vulnerability assessments (due July 26, 2020) or who may wish to reflect back on their existing VA’s in an effort to eliminate unnecessary APS’s should find these strategies helpful to focus limited resources to the areas where they can have the greatest effect. The next two articles in this series will cover more information on electronic access, the value of site tours, comparisons to drinking water security strategies, dealing with multi-site assessments and more. Read Part II of this series on intentional adulteration.

FDA

FDA Receives Record Turnout As Industry Eager to Discuss New Era of Smarter Food Safety

By Maria Fontanazza
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FDA

Industry from the public and private sector joined for a record turnout during the FDA public meeting yesterday to discuss the agency’s initiative, a new era of smarter food safety. The meeting, which was at maximum capacity for both in-person as well as webcast attendance, began with a call to action from FDA Deputy Commissioner, Office of Food Policy and Response, Frank Yiannas on the importance of all stakeholders in the industry to work together to drive the change. As Yiannas has previously commented, the food industry is in the midst of a revolution. The world is changing faster than ever, and the FDA is challenged with not just creating a safer, more technology-centric and traceable food system, but also getting there faster and more effectively. “I’ve always believed that words we use are important,” he said. As the day’s various discussions would be around the new era of smarter food safety, Yiannas gave the audience a definition to consider: “A new era is a memorable or important date or event, especially one that begins with a new period in our history.”

FDA held breakout sessions centered on areas critical to the initiative:

  • Tech-enabled traceability and outbreak response
  • Smarter tools and approaches for prevention
  • Adapting to new business models and retail modernization
  • Food safety culture

During each session, FDA facilitators asked the audience questions. The following are some key points brought out during the breakouts.

Tech-Enabled Traceability and Outbreak Response

  • FDA should consider all parts of the supply chain when thinking about traceability
  • Take into account considerations for sharing sensitive data along the supply chain
  • Speaking a common language and creating data standards, along with necessary minimum data elements for traceability is critical
  • Better communication related to data sharing as well as more meetings with FDA and stakeholders, especially during outbreaks
  • Show industry the ROI of the data
  • Provide a roadmap or recommendation for companies on where they can begin on their traceability journey
  • Request for unity across government agencies (i.e., FDA, USDA), as it would provide more clarity during an outbreak

Smarter Tools and Approaches for Prevention

  • Trust and transparency are key
  • Safeguards that address privacy concerns and liability
  • Data
    • Data sharing: Concern about retroactive investigations
    • Types of data: With the “treasure trove” of existing data out there, which is the most important and helpful in improving food safety?
  • Environmental assessments and root cause analysis—more dialogue between FDA and industry

Adapting to New Business Models and Retail Food Safety Modernization

  • More need for collaboration
  • Globalization and use of best practices
  • Establishing a common standard to level the playing field
  • Establish best practices for tamper resistance
  • The last mile: Food safety training for food delivery personnel as well as harmonization for last mile delivery
  • More consumer education

Food Safety Culture

  • Emphasis on behavior and humanizing the work: Focusing on what happens within organizations at all levels
  • Clarity and communication are important
  • Leveraging current food safety culture best practices as well as any relevant existing standards (i.e., ISO, Codex)
  • Partnerships are critical, finding the balance between compliance and collaboration

Other Factors FDA Must Consider

The FDA meeting also included panel discussions that drew out the realities FDA must consider in this rapidly changing environment. “These are exciting times and this initiative is recasting our thinking in a whole new light,” said CFSAN Director Susan Mayne, adding, “We need to get ahead of these challenges and not be in reactive mode.”

Consumer awareness and demands for healthy, locally sourced and minimally processed food, for example, are creating increased pressures on food companies and retailers. In addition, the digital savvy and diverse Generation Z (the population born between 1990 and 2010, which will comprise nearly 40% of the U.S. population by 2020) has buying habits and a strong desire for transparency that is shifting how food companies will need to do business, according to Mary Wagner, president of MX Wagner & Associates.

“Trust represents safety, quality and commitment on a much more personal level to our consumers,” said Dirk Herdes, senior vice president at the Nielsen Company, emphasizing the need to communicate with authenticity. “Consumers have never been more informed, but never have been more overwhelmed with information. It’s not data—it’s trust. Trust is the new currency with which we’ll operate.”

FDA and USDA also remain committed to building a stronger relationship between the agencies, said Mindy Brashears, Ph.D., deputy undersecretary for food safety at USDA. “As science moves forward, we have to allow our policies to move forward to keep consumers safe,” she added.

The comments shared during yesterday’s meeting, along with written and electronic comments (with a deadline of November 20), will be considered as FDA puts together its blueprint document for a new era of smarter food safety. More information about providing comments can be found on the Federal Register page.

Megan Nichols
FST Soapbox

Tips to Train Employees and Maintain FSMA Compliance

By Megan Ray Nichols
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Megan Nichols

Eight years ago, the government passed FSMA. As a manufacturer, training new and existing employees to remain compliant with legislation is paramount. The goal isn’t to make life harder for business owners—it’s to protect American consumers from unsafe food handling and transportation practices.

The following are five tips to help warehouse managers train employees while maintaining FSMA compliance.

Understand FSMA Final Rules

It’s essential for everyone in the facility, from the CEO to the newest hire, to understand the FSMA rules. According to current Good Manufacturing Practices (cGMP), everyone who works in manufacturing, processing or packaging of food is required to train in food hygiene and safety. Managers can offer training in one of two ways—through on the job experience or via an FSMA-accredited classroom curriculum.

For individuals with specialized jobs, such as quality auditors or preventative controls qualified individuals (PCQI), the training option that allows compliance with FSMA rules is an accredited curriculum.

Utilize Warehouse Management Systems

FSMA gives the FDA authority to issue mandatory recalls for any food products if deemed necessary. To meet FSMA standards, record keeping and lot tracking is a necessity. If a product type is linked to a disease outbreak, the FDA wants to know where each product in that lot is within 24 hours. Having the ability to track and trace 100% of the products ensures that the company is FSMA compliant.

A warehouse management system (WMS) can track products, but only if you train employees in its use. While the average employee won’t be responsible for tracing a production lot in the event of a recall, each worker needs to know how to enter data into the system correctly, and how to retrieve the information if necessary. Include training in your WMS to ensure compliance.

Warehouse management systems, when paired with IoT sensors, can prevent recalls and ensure compliance by monitoring temperature fluctuations in climate-controlled areas. According to the Department of Agriculture, frozen food stored at temperatures at or below -0.4° F is always safe. A comprehensive WMS can monitor the temperature inside a facility’s freezers and alert workers or management if there are dramatic fluctuations that may result in a recall.

Seek Out Alliances

Warehouse managers are not alone when it comes to creating a compliant workplace. The FDA has established and funded three alliances—Produce Safety, Food Safety Preventative Controls, and Sprout Safety—each with their own standardized curriculum designed to help those who fall under FSMA rules.These alliances work for the majority of those in the food production industry, though they may not work for everyone.

Seek out the applicable food safety alliance and see if their training curriculums apply to your facility. Even if they don’t fit directly, these alliances can give managers an excellent place to start creating their training curriculum.

Create a Culture of Compliance

FSMA isn’t designed to make life harder for warehouse managers. Its goal is to keep people safe when buying their weekly groceries. Don’t just focus on training to meet FSMA standards. Instead, create a culture of compliance throughout the facility. Make FSMA everyone’s responsibility, and make it easier for employees to communicate with management if they notice a problem that normal channels don’t address.

As part of this culture of compliance, create incentives that reward employees for reporting problems, maintaining compliance levels and completing accredited training. Sometimes incentives can be the best way to motivate employees, whether you’re offering money, paid vacation or other benefits. Walk employees through the process of how to spot a problem and report it to management.

Continue Education Throughout Employment

FSMA compliance training isn’t something you should restrict to an employee’s onboarding. It’s something you should continue throughout their time at your facility. Make FSMA education a priority for every worker in your facility. While you want to start their training with onboarding, it shouldn’t stop there. Offer new training courses once a month or every three months—as often as you’d like without compromising productivity.

As the day-to-day grind continues, most workers forget about rules and regulations. Continuing education ensures FSMA compliance is at the forefront of everyone’s mind throughout their careers. Continuing your employee’s education is also shown to increase loyalty and reduce turnover, keeping things running smoothly and preventing warehouse managers from training new workers every quarter.

Looking Forward

The FDA oversees food safety and can issue a recall when a problem occurs. Yes, as a whole, it’s the responsibility of every single person working in the food production industry—from the highest-paid CEO to the newest employee on the production floor—to maintain compliance. It’s not enough to review guidelines with new employees during onboarding.

Training is essential to ensure everyone in a facility maintains the rules laid down by FSMA. Seek out assistance in the form of the FDA-funded alliances, continue employee education and make it a point to create a culture of compliance from the moment employees walk through the door. Offer continuous training opportunities and you’ll never have to worry about breaking FSMA rules.