EDGARTOWN, MA, Feb. 27, 2019 – Innovative Publishing Co., Inc., publisher of Food Safety Tech, has entered into a reseller agreement with ImEpik, an online training company that serves food manufacturers globally. Food Safety Tech will serve as a reseller of ImEpik’s PCQI online training course as per training that is required under FSMA.
“I’m pleased to announce our partnership with ImEpik, as it allows us to expand our efforts in giving the industry access to resources that are critical to food safety education and training,” said Rick Biros, president of Innovative Publishing Co., Inc. and director of the Food Safety Consortium Conference and Expo.
“Our ten-module online training program ensures that Preventive Control Qualified Individuals are proficient in the standards that are required under FSMA,” said Laura Lombard, CEO of ImEpik. “Providing compliance training in an online capacity also saves our ‘students’ time and money, as they can take the course any time and anywhere, without having to travel away from their job.”
As part of the partnership, the training will be offered at a reduced rate for professionals who also register to attend the Food Safety Consortium Conference & Expo, an annual industry event held October 1–3 in Schaumburg, IL. Full conference registration that includes PCQI training starts at $845 with the early bird discount. After September 13, the cost of the full conference registration with PCQI training is $995.
About Food Safety Tech
Food Safety Tech publishes news, technology, trends, regulations, and expert opinions on food safety, food quality, food business and food sustainability. We also offer educational, career advancement and networking opportunities to the global food industry. This information exchange is facilitated through ePublishing, digital and live events.
About the Food Safety Consortium Conference and Expo
The Food Safety Consortium Conference and Expo is a premier educational and networking event for food safety solutions. Attracting the most influential minds in food safety, the Consortium enables attendees to engage conversations that are critical for advancing careers and organizations alike. Visit with exhibitors to learn about cutting edge solutions, explore diverse educational tracks for learning valuable industry trends, and network with industry executives to find solutions to improve quality, efficiency and cost effectiveness in an ever-changing, global food safety market. This year’s event takes place October 1–3 in Schaumburg, IL.
IMEPIK is a market-driven, and research-based online training company, facilitates food safety training for food manufacturers around the world. With an emphasis on accessible and innovative training, ImEpik offers a unique advantage in providing effective training for you, your employees, your association members, or your clients to ensure food safety compliance and best practices. We offer Preventive Controls courses that include the “standardized curriculum” recognized by the FDA.
After FDA delayed product inspections under FSMA to further prepare industry and ensure there was enough training and education, the agency is reminding farmers and other stakeholders in the produce industry that there are resources available to help them in preparing for the routine inspections—for large farms, these will start in the spring. The inspections will be conducted to verify compliance with the Produce Safety rule.
An FDA Voices blog by FDA Commissioner Scott Gottlieb, M.D., Deputy Commissioner for Food Policy and Response Frank Yiannas and Associate Commissioner of Regulatory Affairs Melinda Plaisier also discussed how the agency has been supporting industry work to comply with the rule, including:
Granting 46 states and one territory with more than $85 million through the State Produce Implementation Cooperative Agreement Program to aid in the development of state produce safety systems that offer education, outreach and technical assistance
With partners, supporting the training of more than 31,000 produce farmers globally on the Produce Safety rule requirements
With partners, the creation of a new inspection form that gives farms feedback and observations that occurred during the inspection, regardless of whether non-compliance issues were found, in an effort to help explain what they’re looking at and how observations apply to the produce rule
Building a supply chain verification program can be a complicated task. In the following exclusive video with Doug Marshall, Ph.D., chief scientific officer at Eurofins, we learn the top questions that should be asking their suppliers during the process. Marshall also gives his perspective on the integration of data into the supply chain and how it can mitigate risk, along with where he’s sees the future of food safety testing headed.
On-site rapid tests for allergens are an important part of any manufacturing facility’s allergen control plan. Several companies offer allergen test kits for day-to-day use, and it can be hard to tell the differences between them or determine which is the best fit for a given facility. What’s a busy QA professional to do?
One of the most overlooked factors when choosing an allergen test kit actually has almost nothing to do with the test kit itself. Instead, it’s much closer to home: The matrices being tested are just as—if not more—important to consider than the test kit itself.
Before you commit to any allergen test kit, you should talk to someone extensively about the types of products you plan to test. There are a variety of surprising and counterintuitive ways that your matrices can impact the functionality of a test, and you’ll save time and money by understanding information BEFORE you start testing. Below, we’ll review some of the most common matrix challenges.
High Fat Matrices
Let’s imagine a facility that makes ice cream and sorbet. Let’s assume they make a gourmet strawberry ice cream and a fat-free strawberry sorbet, both of which ought to be peanut-free—but since some of the ingredients come from a supplier who also works with peanuts, the QA team decides to run a rapid peanut test on the strawberry products.
Much to the team’s surprise, the sorbet tests positive for peanut but the ice cream does not. What could be happening? Of course, the simplest explanation is possible: The sorbet has peanut residue in it and the ice cream does not. However, there’s another, trickier possibility: They could have the same amount of peanut residue, but the full-fat ice cream could inhibit the test kit’s ability to detect the allergen.
In general, the higher the fat content of your matrices, the higher the detection limit on your test kit. It’s an imprecise spectrum: Using rapid tests to find traces of allergenic protein on an oil is nearly impossible, on fat-rich items like ice cream or cream-based soups it’s a challenge, on items with little or no fat it shouldn’t be an issue. That isn’t to say there couldn’t be other issues with low-fat items, as we’ll review below.
Matrices Processed with High Heat
Let’s say our ice cream facility starts making a peanut-butter-swirl flavor. Perhaps they will begin testing their rinsewater for peanut residue after running that flavor, to ensure satisfactory cleaning. The kit they use says it can detect peanut allergen to 5 ppm, and rinsewater is not a high-fat matrix, so they should be good, right?
In this exact example, it’s probably just fine. However, it’s important for the QA team to consider the temperature at which peanuts were roasted. While raw peanut might be detectable at 5 ppm, roasted peanuts could have a detection limit that is much higher. In fact, very strongly roasted peanuts could only be detectable at levels of 500 ppm or more. This doesn’t mean there is no reason to test—but it’s important to know that many antibody-based tests will respond differently to an allergen processed with high heat than one that is raw. The same detection challenge can sometimes be seen with canned or tinned items that are subjected to high heat in processing.
Fermented or Hydrolyzed Matrices
Two of the trickiest items when it comes to allergen detection are soy sauce and fish sauce. In both of these condiments—and many other common ingredients subjected to these types of processing—the allergenic material is subjected to heavy modification. As proteins get folded and broken in unpredictable ways, they become more challenging for antibody-based test kits to detect. In fact, soy sauce and fish sauce are nearly undetectable by most kits.
When validating a cleaning process after using one of these ingredients, often the safest thing to do is to test for a different allergen—formulated in a simpler way—that is also present. Sufficient cleaning after a product made with fish sauce and breadcrumbs, for example, could be proven with a gluten kit; that second allergen will be unaffected by the fermented allergens in the recipe.
Matrices without Multiple Proteins
Some kits look for a variety of proteins commonly found within one allergen. Other times, though, each test kit will be looking for one specific protein. It’s important to confirm that the allergenic protein your facility works with is in fact an allergenic protein that your test kit is trained to recognize.
Perhaps the most common FALCPA allergen where this plays a role is milk. While there are a number of proteins in milk, casein is the most common and accounts for approximately 80% of the protein in milk, making it a common target for allergen test kits (both rapid and ELISA). The remaining 20% of protein is comprised of various whey proteins, most commonly beta-lactoglobulin.
In the case of our ice cream and sorbet facility mentioned above, a kit that detects casein OR beta-lactoglobulin OR both proteins together could be suitable for confirming that the sorbet is truly milk-free. However, there are other types of product that contain only whey proteins, which are a popular way to increase protein content in a variety of foods and beverages. If a facility that works exclusively with whey proteins uses a kit that only detects casein, they will never have a true understanding of their allergen contamination risk.
Another challenging FALCPA allergen is fish, as there are many different species of fish with quite divergent protein structures. If you are testing for fish contamination, it’s important to understand which species of fish the test you are considering can detect, and which species may pose a problem. If there is a mismatch between kit and matrix, then you’ll need to find a different way to ensure safety.
How to Troubleshoot Your Matrices
If you are beginning an allergen testing program, find time to talk with the manufacturers of any allergen kits you are considering. You may also want to talk with the representatives of any labs that are doing third party testing for you. Some questions to ask include:
What matrices have you validated your tests for?
Do you anticipate any issues with my matrices?
How should I validate your tests for my products?
What factors impact the sensitivity of this kit?
Does the detection limit change based on the matrix?
Your kit manufacturer (or third-party testing lab) should make you feel confident that they understand the quirks of your specific matrices—and they should have ideas for how to troubleshoot any challenges that they foresee. If a supplier tells you that their kit will work equally well across all matrices and declines to offer proof that corresponds to your needs, beware (or at least be prepared to conduct rigorous validation on your own). Allergen detection is complicated, and as with so much of life: If it sounds too good to be true, it probably is.
Beyond reducing liability or checking a regulatory box, investing in robust training can reap measurable business impact. The FSMA regulation requires that Preventive Control Qualified Individuals (PCQIs) “have successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or be otherwise qualified through job experience to develop and apply a food safety system,” as per Subpart C Section 117.180 (c) (1). Even if the person serving in the role of PCQI is qualified through job experience, FDA investigators will expect adherence to development and application of risk-based controls as contained in the standardized PCQI curriculum material or the alternative training allowed in the regulation.
Let’s face it: Our employees serving in the role of PCQI come from a spectrum of food safety plan experience. In addition, many are mentoring new members as Qualified Individuals on the food safety team. Others are building a whole new team from scratch. Team members may be specialized department heads or hold several titles and job duties within a manufacturing facility. Your PCQI is charged with overseeing the development and analysis of the food safety plan. The PCQI needs a team that has had consistent training in the language of the new rules and how to comply to support the PCQI’s charge.
Beyond meeting the regulation, companies should train at the PCQI level to safeguard a company’s product quality, brand and customer base. The fewer food safety-related claims you have, the more you save in costly recalls, loss of current or potential customers, and your brand’s reputation. A company with a robust safety culture has a competitive advantage over competitors who are more lax in their food safety and may suffer financially and reputationally from recalls and customer quality assurance complaints. In an era when customers are seeking more information about the food they consume, being a trusted food safety brand can make your company stand above the crowd.
In addition, consistent training can help with internal culture change and worker productivity. Working on hazard analysis and defining preventive controls requires that employees show critical thinking and problem-solving skills. Team members taking a curriculum with standardized material and consistent learning objectives can reflect together to identify and document gaps and corrections to practices or processes. They can quickly apply their learning for more accurate analysis of the components of the food safety plan. This is the true impact from investment in high quality instruction—motivating employees to learn updated food safety practices, change their behavior, and make more efficient and effective decisions to keep the quality and safety of your products. Well-trained food safety employees are a key factor in the protection of your customers, your company’s brand and the prevention of costly food recalls. The investment in training at the PCQI level is strategic on all fronts.
This question has come up frequently in our FSMA Sanitary Transportation workshop. Just as with all the parts of FSMA, the focus of the Sanitary Transportation of Human and Animal Food regulation is on addressing hazards that may be present throughout the food chain and assigning responsibility (liability) for preventing those hazards. There are very few specific requirements—most of it is couched in very general language, for flexibility on both sides (FDA’s and industry’s).
While the regulation does not specifically address locks or seals on trailers, the FDA has stated publicly that they intend to enforce the adherence of industry to generally accepted best practices. Sometimes, as in the case of certain animal food applications, the FDA has stated they will accept mild steel transports instead of stainless (as would typically be required for hauling food) because it’s all about the risk, and mild steel is not a risk in those applications. What is the risk of an unlocked load to the food being hauled, and to the business being conducted? Maybe a seal or lock on an LTL can protect a significant investment from an identified hazard.
Generally, in most food hauling operations, seals or locks are required on trailers by businesses in order to protect their investments. They are also expected under GFSI-approved food safety management systems, used by most food manufacturers (which are private, voluntary standards, not regulatory). They are definitely required if you want to haul 100% juice under Juice HACCP and the JPA guidelines.
There are so few straightforward answers with FSMA. You must always look at your operation, your risks, and decide if controls are necessary. Document the basis for your decision, ensuring it is based on facts. If the FDA inquires, you must make your case for your decision. Do you feel comfortable defending it, all the way to a court of law if need be? If so, then stand by it.
If there are potential risks to food that is being hauled (don’t forget about defense-type risks as well, like the truck being stolen or misrepresented) then you must take reasonable, industry-standard precautions to prevent those hazards from occurring.
Of course, you want to do this anyway because it is smart business.
We started this Q&A series earlier this year with a clear vision—to gather the success stories, best practices, hurdles and achievements from the best in our industry. Our hope is that as the series expands and evolves, food safety professionals everywhere will be informed and inspired by what the future holds.
Over the course of the year, I had the pleasure of interviewing three such experts: Bob Baker, corporate food safety science and capability director at Mars, Inc, Frank Yiannas, vice president of food safety at Walmart, and Mike Robach, vice president, corporate food safety, quality & regulatory for Cargill.
I encourage you to read the interviews for their unique perspectives, but here are a few of the biggest insights that we can all take with us into 2019.
The Continued Rise of New Technologies
Mike Robach: I am very excited about the application of new technology to our food safety programs. In-line, real-time testing gives an opportunity to manage our processes and make immediate adjustments to assure process control. This allows us to prevent product that is out of control from reaching the marketplace.
Frank Yiannas: The emergence of blockchain technology has also enabled food system stakeholders to imagine being able to have full end-to-end traceability at the speed of thought. The ongoing U.S.-wide romaine lettuce E.coli outbreak showed us, once again, that our traditional paper-based food tracking system is no longer adequate for the 21st century. An ability to deliver accurate, real-time information about food, how it’s produced, and how it flows from farm to table is a game-changer for food safety.
Blockchain has the potential to shine a light on all actors in the food system. This enhanced transparency will result in greater accountability, and greater accountability will cause the food system to self-regulate and comply with the safe and sustainable practices that we all desire.
The Most Exciting Shifts
Baker: What’s encouraging is we’re seeing is a willingness to share information. At Mars we often bring together world experts from across the globe to focus on food safety challenges. We continue to see great levels of knowledge sharing and collaboration.
There are also new tools and new technologies being developed and applied. Something we’re excited about is a trial of portable ‘in-field’ DNA sequencing technology on one of our production lines in China. This is an approach that could, with automated sampling, reduce test times.
Yiannas: While there is no doubt that there are numerous new and emerging challenges in food safety, the many advancements being made should give us hope that we can create a safer, more efficient and sustainable food system.
There is progress being made on many fronts: Whole genome sequencing is becoming more accessible; new tools are being developed for fraud detection; and FSMA is introducing stringent public-health surveillance measures that have dramatic implications for U.S. retailers and suppliers and our import partners.
Most importantly, consumers are now overwhelmingly interested in transparency. People today are further removed from how food is grown, produced and transported than at any other time in human history. Plus, they increasingly mistrust food and food companies due to the food outbreaks and scares we have faced in recent years.
Recalls and the Role of Regulation
Robach: I think FSMA implementation is going okay right now. There’s still a long way to go, and I am always concerned about making sure investigators are applying the rules and regulations in a consistent manner. I see the intentional adulteration rule as an upcoming challenge. It is one thing to conduct a vulnerability assessment and adjust your programs based on the results. It’s another to develop and implement a program that will prevent intentional adulteration as you would to reduce or prevent microbiological contamination.
I believe that food safety management programs are constantly improving and that our food is as safe as it has ever been. However, we still have a lot of work to do. At GFSI, we are continually improving our benchmarking requirements and increasing transparency in the process. We have better public health reporting and our ever-improving analytical technology allows us to detect contaminants at lower and lower levels. The industry is working collaboratively to share best practices and promote harmonized food safety management systems throughout the supply chain.
Baker: At Mars, quality is our first principle and we take it seriously—if we believe that a recall needs to be made in order to ensure the safety of our consumers, then we will do it. We also share lessons from recalls across our business to ensure that we learn from every experience.
Unfortunately, there does not seem to be a safe place for businesses to share such insights with each other. So although we are seeing more collaboration in the field of food safety generally, critical knowledge and experience from recalls is not being shared more broadly, which may be having an impact.
Baker: The food safety challenges facing us all are complex and evolving. Water and environmental contaminants are areas that industry and regulators are also looking at, but all of these challenges will take time to address. It’s about capturing and ensuring visibility to the right insights and prioritizing key challenges that we can tackle together through collaboration and knowledge sharing.
We’re looking forward to continuing our quest in the new year and already have a few exciting experts lined up. Stay tuned!
The supply chain is a potentially weak and vulnerable part of a company’s food safety plan. The annual Food Safety Supply Chain Conference is months away and we are accepting abstracts for presentations. The conference takes place May 29–30, 2019 in Rockville, MD.
If you have expertise in the following areas, we invite you to submit an abstract to present at the conference:
In September 2015, the FSMA Preventive Controls for Human Food Rule was published, requiring affected companies to comply with all FDA timelines. The last of these deadlines required that all very small businesses (less than $1 million per year) be in compliance with the FSMA rule by September 17, 2018.
With most companies having implemented FSMA preventive controls at this point, what have we learned? What’s still not clear? What major challenges remain? This article shares some questions that could help more companies on their journey to FSMA compliance.
What Is the Preventive Controls (PC) for Human Food Rule?
In plain language, under FSMA’s preventive controls for human food, FDA asks companies to identify any known and foreseeable potential hazards to finished products, and then apply control measures to prevent those hazards from happening and to ensure companies produce safe products. This rule changes the mentality from reactive to proactive.
Let’s break the term preventive control apart:
What are we preventing? We are preventing any potential hazards that could occur. FDA identified four major categories of hazards. Food companies must look at their production processes and identify any foreseeable hazards within these categories:
Intentional adulteration for economic gain
What are we controlling? We are controlling the risks from all those hazards identified. Control measures should be identified for each risk from a particular hazard identified so they can be effectively applied.
A logical starting point involves understanding all hazards at your production facility. How can you ensure all hazards are assessed and evaluated? Consider mapping out the process line as one effective way. It is important to thoroughly understand your processes, as well as all raw materials, equipment, and personnel associated with each processing step. The more details gathered at the beginning, the easier it is to understand the hazards and risks as a foundation. A hazard can always be eliminated later if it is not applicable nor likely to occur.
Are All Control Measure or PRPs Considered Preventive Controls?
The short answer is not necessarily. Only those associated with a potential hazard will be considered a preventive control. For example, for an approved supplier program controlling incoming goods and suppliers, if an allergen is identified as a potential foreseeable hazard, the approved supplier program at the receiving step will be identified as a preventive control. Once a preventive control is determined, it must be evaluated to ensure it is proper and applicable to control and minimize the risks (117.420).
The same mentality should be applied for other control measures. Is there is a hazard and, if so, can this control measure actually control the risk? Once preventive controls are determined and identified, monitoring and validation are the next steps to ensure preventive controls are functioning effectively to control the risks as expected. If not, proper corrective actions should be identified.
Are Corrective Actions Always Required?
Not always—it depends! It is important to remember the intent of FSMA’s preventive controls, which is to prevent any potential hazards and control the risks to ensure safe products are produced. Per 117. 150, corrective action is a must when:
There is a potential pathogen threat in RTE products
There is a potential pathogen threat from the environmental monitoring program
A preventive control is not properly implemented and a corrective action procedure has not been established
A preventive control(s) or the food safety plan as a whole is not effective
Records are not completed after review
Other than the above-mentioned, corrections can be applied to address minor and isolated problems in a timely manner. As with all other food safety management systems (FSMS), once a corrective action is determined and implemented, a verification of its effectiveness shall be conducted. In addition, everything should be documented, as records are a vital component of the preventive control rule.
The FSMA Preventive Controls Rule is not scary. It is simply a series of requirements to assist the industry in proactively identifying the best control measure for operations. Foreseeable hazards must be controlled. As with all other management systems, knowledgeable and experienced personnel can help develop a valid food safety plan, including preventive controls, and ensure it is effectively implemented and maintained onsite.
Implementation of FSMA has prompted many organizations to take a closer look at sanitation practices, documentation of food safety plans and the traceability of materials and ingredients used to create food products.
Meanwhile, shifts in technology, such as cloud migration as well as the rise of big data and analytics platforms, present both opportunities and challenges in food manufacturing.
In many cases, digital transformation, including the adoption of a multi-cloud strategy, occurs as part of a roadmap set forth by a food company’s software vendors. Tech giants, including Microsoft, Oracle and SAP, are driving digital transformation through the modernization of ERP systems and dictating how food companies should utilize applications, data and software.
In those situations, digital transformation is not a choice, it’s a requirement. CIOs and IT professionals are seeking help. They are looking to understand the dynamics and characteristics of these new environments because they are compelled to change.
Yet, there are also organizations that would rather do more than simply follow the lead of their software vendors. Instead, they choose their own destiny in terms of IT modernization. They’re looking for opportunities by leveraging data to make better business decisions.
Before a food manufacturer can get to that point, however, there must be a strategy for gathering, storing, connecting and presenting different types of data across an organization as well as to external customers and business partners.
Managing the data required for FSMA compliance is an ideal example of the importance of pursuing digital transformation.
Food Safety Data and FSMA Compliance
A major component of FSMA involves having detailed documentation of a food safety plan and the ability to produce data proving adherence to that plan when the FDA shows up for a plant inspection. Food manufacturers need to show best practices are being followed, and that corrections are being made when concerns emerge. Otherwise, the FDA may impose fines or temporarily shut down production, which cuts into the bottom line.
Because of FSMA mandates such as the Sanitary Transportation Rule, your documented food safety plan needs to be communicated to key participants throughout the supply chain as responsibility for food safety problems typically falls back to the manufacturer.
For that reason, food processors need solutions allowing them to track and trace their product from the farm field to store shelves, or to any other final customer.
Imagine being a food manufacturer trying to document sanitation in a basic spreadsheet or even on paper. The extra work involved with specifying food safety tests, collecting and archiving results, and validating sanitation procedures would be overwhelming. Yet, just as perplexing of an issue is being a digitized food manufacturer with poor visibility and management of all the information that various IT systems and platforms provide.
Most companies acknowledge that the cloud is a necessity in today’s world. Organizations often need multiple cloud solutions to accomplish business objectives, from regulatory compliance to finances, inventory control and distribution.
CIOs, technology professionals and food safety/sanitation leaders should work with existing IT solutions partners or find consultants and experts who can ensure the following questions can be answered:
1. Is the location of your data known?
Data visibility in the cloud is the first step in the process, and it is a challenge for many organizations. You need to know where your data lives, that the right people have access to it and that it is secure. When you know where your data lives, you’ll better understand how to use and protect it.
2. Is your data in a location that allows for integration?
Can the different applications your company uses talk with each other, or is all the information siloed across different cloud providers and departments in the organization? Is it integrated? Can certain information, such as food safety plans, be communicated with partners including suppliers, distributors and your carrier network?
3. Can your data be put into a framework allowing it to be extracted, visualized and leveraged?
Data doesn’t help anyone if you’re unable to take that information and use it to make better business decisions. Whether it’s food safety, operational efficiency, forecasting needs or developing new ideas, the most successful food manufacturers will leverage integrated data to move the organization forward.
The Advantages of Pursuing Digital Transformation
If you were to go back about a decade and observed a small- to mid-sized food manufacturer using Microsoft as its data platform, that manufacturer would likely have been running applications for the business that created data while receiving little guidance pertaining to how the information should be interpreted and used. Fortunately, that has changed.
Today, companies like Microsoft, Oracle and SAP actively focus on the use of data rather than only data collection. The right IT solution, coupled with expert partners, allows you to eliminate the guesswork and leverage data to your advantage.
FSMA mandates are complicated, and compliance is crucial, but the pursuit of digital transformation supports the efforts of food manufacturers who are prepared to improve transparency and responsibility surrounding food safety.
Digital transformation represents change, which is never easy, but it will be worth the effort. Start by evaluating your organization’s technology needs as they relate to FSMA compliance as well as additional business objectives. Then, identify areas of internal strength and areas where improvements are needed.
Some food manufacturers partner with an IT solutions provider for support developing a cloud migration plan and a subsequent strategy for operating in multi-cloud environments. Others need managed services, helping them handle day-to-day IT needs through outsourcing so in-house resources can develop high-value solutions. Still, others are looking for consultative guidance to help them understand what changes in technology truly mean to their organization.
You want your people to focus on what they do best. Many food manufacturers are in locations where there’s a lack of technical resources for hire. That’s why they turn to IT consultants and service providers who understand their business, can provide expertise that fills the talent gap and are able to interpret business needs into technology solutions.
Digital transformation isn’t one big project, it’s an ongoing journey, a series of waves of new technologies and new ways to use applications and data. Make sure you find trustworthy allies to give you the guidance and solutions you need, not only for regulatory compliance but for growth and continued success.
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