The vast majority of foodborne illnesses in the United States results from either a management system failure or human error. This supports our belief that all foodborne illnesses are preventable. With the introduction of FSMA, prevention has become a significant focus in the battle to eliminate foodborne illness.
STOP Foodborne Illness is collaborating with Intrinsic Leadership, LLC to offer a Food Safety Leadership program. The primary objective of this program is to equip leaders with the knowledge, skills and abilities to develop and sustain a culture of prevention relative to food safety.
Successful prevention requires more than just the introduction of new knowledge and skills for workers. Success requires the consistent and ongoing application of those skills.
We know that training can provide knowledge and skill. However, the most significant predictor of long-term success is the extent to which frontline managers actively support behavioral changes within the employee base. Experience shows that transforming an organization to produce superior results is much more than training programs, process improvement or new technology. While each of these elements are important, sustainable improvement occurs when we are able to shift the way people think about the business in a way that drives them to consistently act different then they did in the past. The role of leadership is to:
Frame the business opportunity in a way that inspires employees to seek a better outcome
Relentlessly pursue management system improvement
Represent, support and encourage a culture that aligns with improvement opportunities
Stories are powerful reminders and provide the “why” behind food safety. Below are two such stories.
Raw Milk – E. coli 0157:H7
It is the stories that create the urgency behind the importance of food safety. Christopher’s story is heart breaking—yet, he was one of the lucky ones, as he recovered from his illness.
Most industries face issues with breaking down silos and promoting cross-functional collaboration. For the next class of leaders to be well equipped to promote and practice a strong food safety culture, more work needs to be done on alignment within organizations and across industry. In part II of Food Safety Tech’s series on food safety culture, Brian Bedard, executive director of the GMA Science and Education Foundation and Lone Jespersen weigh in on leadership.
Food Safety Tech: Food Safety Culture requires strong professional leaders. How can industry work together to develop the leadership that is needed?
The GMA Science Forum takes place April 18–21, 2016 in Washington, DC | LEARN MORELone Jespersen: We start by acknowledging that we have an abundance of strong leaders in the food industry. We don’t need to build from the ground up or something new. We need to look at what makes [these leaders] strong. Why are some leaders more successful than others? Identify the companies that have strong food safety leaders that are not within food safety—those that come from finance, HR, procurement, and the CEO—and formally acknowledge their technical and leadership competencies.
I’m aware of three organizations that are actively looking at what constitutes a food safety professional and its competencies—IFPTI (International Food Protection Training Institute) in the United States, Safe Food Canada, and the International Union of Food Science and Technology. Alignment between the work conducted by each of these organizations is important to shorten the time between development and business impact. It’s really important to get this alignment. The more we keep working in small subgroups while not comparing notes and agreeing on those competencies, the more we’re going to see the cost of developing leaders going up. And we’ll have fewer strong leaders, because it will be hard for individuals to move on in their career if it is not clear what it means to be a competent, strong food safety leader.
There’s a very large group of food safety leaders, the ‘Malcolms-in-the-Middle’ who are excellent leaders and are one or two steps down from the head of food safety in an organization. Sometimes we forget that we have strong leaders at this level, and they have a much stronger handle on food safety culture because they’re the ones who have to make sure programs work for frontline associates, supervisors, and managers. Letting that level become more visible to what their competencies are or should be and making sure that they contribute and are heard in the conversations [is important].
Brian Bedard: We need to collaborate and get some alignment around what we think leaders need. Unfortunately, this is creating a competitive space among service providers and training entities that can work with leaders.
There are a couple of fundamental principles that need to be addressed:
The leaders at the top need to recognize and drive it down through their entire system so that everyone is responsible in terms of their annual work and development plans, including metrics and the deliverables in their annual evaluations
The ‘Malcolms-in-the-Middle’ who, in most cases, manage the budget. It’s critical to get them on board to ensure that, when making investments, they’re spending money on driving food safety culture throughout an organization
Several specific opportunities now exist to promote food safety culture leadership, including the Food Safety Leadership Workshop being offered by the GMA Science and Education Foundation at the upcoming GMA Science Forum (April 18, Washington, DC).
If you watch the evening news or read the local newspaper, the chances are pretty good that you will read or see something about a food safety concern or incident.
While the American food supply is among the safest in the world, the Federal government estimates that there are about 48 million cases of foodborne illness annually—the equivalent of sickening 1 in 6 Americans each year, according to Foodsafety.gov. And each year these illnesses result in an estimated 128,000 hospitalizations and 3,000 deaths. Five types of organisms—Salmonella, Toxoplasma, Listeria, norovirus, and Campylobacter—account for 88% of the deaths for which the cause is known.
We watched from the sidelines when major retailers faced public scrutiny over their practices on safeguarding consumer credit card information when their websites were hacked. Today, consumer and regulatory interest in food safety are the new focus areas for the news media, especially in light of the Blue Bell Creameries Listeria and the Peanut Corporation of America (PCA) Salmonella outbreaks. Unlike consumer credit information, serious missteps in our industry can kill people, and in the case of PCA, can put you permanently out of business.
In 2008, peanut butter paste manufactured by PCA killed nine people and sickened 714 others, some critically, across 46 states and was one of the largest food recalls in American history, according to the CDC. Although still under appeal, PCA CEO Stewart Parnell was convicted and sentenced to a 28-year prison term for his role in knowingly shipping out salmonella-contaminated peanut butter. Parnell received one of the toughest punishments in U.S. history in a foodborne illness case.
In the Blue Bell case, a total of 10 people with Listeriosis related to this outbreak were reported from four states, with three deaths reported from Kansas, according to the CDC. Blue Bell pulled their products from store shelves on April 20, 2015. On May 7, the FDA released findings from inspections at the Blue Bell production facilities in Brenham, Texas, Broken Arrow, Oklahoma and Sylacauga, Alabama. The FDA reports highlighted serious problems across multiple sites.
Both cases shine a spotlight on what can happen if you don’t have an effective food safety management system (FSMS). So what makes up a good FSMS, and is it enough to keep you out of trouble? An effective FSMS is built on three elements: Good Manufacturing Practices (GMPs), Hazard Analysis Critical Control Points (HACCP) and a management system. Food safety issues are avoidable, and good processes and a strong culture within an organization make them more unlikely to occur.
Implementing a FSMS does not happen in a few months; it may take up to two years to establish one. No doubt, foundational activities need to be in place for factory operations. In addition to focusing on foundational elements such as making sure equipment is cleaned properly and procedures for allergens are implemented, the leadership team needs to make it clear that it is never acceptable under any circumstances to take shortcuts that could jeopardize food safety. This policy needs to be indoctrinated throughout the organization and thus does not happen overnight.
Underlying an effective FSMS are strong HACCP and GMPs, but food safety should always be the top priority for management and its employees, not share price, earnings or profit margin. Although financial performance is important, food safety must take precedence in the organization, and leadership at all levels needs to send that message loud and clear to all employees. In today’s environment, HACCP is pretty much mandatory from a regulatory standpoint and is an essential part of a FSMS. But the missing piece in many organizations is the support from the top—this is where culture becomes embedded in the organization.
The FSMS culture is the collective behavior from the organization around shared values and beliefs. The organization will follow the actions of leaders, not necessarily what they say—we all know actions speak louder than words. A good food safety culture is one where best practices are openly discussed, defined and rewarded. Food safety culture has become a buzz word and there needs to be a focus on making it come to life through a structured FSMS.
At this year’s Food Safety Consortium conference, Tim Ahn will discuss advancing food safety training and harmonization (November 19). LEARN MOREFood safety training is important not only for first line supervisors and operators, but also for senior managers and leadership, because they define the objectives and policies of the FSMS. What does it mean to conduct an effective management review? What does it mean to do an internal audit? What’s a good corrective action process? Training often misses the mark, because organizations fail to embed it correctly.
For FSMS to thrive, management must commit to the FSMS being a required way of doing things throughout the entire organization. A FSMS is most effective when it benchmarked against a proven standard and verified by an independent third party. Certification against a proven standard will reduce risk within your business.
Select your independent third-party verifier carefully. Do they have the resources and time, and do they know what they are doing? Do they add value to your organization? This is important since once you get certified, your journey starts and it doesn’t end. The value comes in two areas: Identifying risks and developing the appropriate control measures, and ensuring that the process drive continuous improvement in your organization. FSMS is focused on how continuous improvement applies to the management of risk and business operations.
The most effective way to establish an FSMS is to have leadership that recognizes its importance. The worst way is to have a recall or an incident, which draws attention to the fact that there is a problem and something needs to happen. In the case of Blue Bell, they probably understood the importance of food safety and thought they were taking the right actions. However, their management system led them to problems. FSMS must be independently verified against world-class standards to ensure effective performance.
Companies can develop blind spots where they cannot see their own bad practices, and they become institutionalized over time. Fortunately, experienced independent third-party assessors can shine a spotlight on those bad practices. That is the true value in bringing in outsiders to look at your operations and culture to uncover those blind spots.
At PCA, their poor culture and actions to the problem sealed their fate. In some ways, this criminal case presented a wake-up call to boardrooms across America and highlights how badly leadership mismanaged matters. This case came to light in the context of the public complaining to the regulators that they were not doing enough following several highly visible food poisoning cases. A FSMS would have prevented these problems because the structure would not allow such bad decisions to be made and would have been verified by an independent third party that would test and check everything. A reputable third-party verifier would not miss poor GMP/ HACCP processes.
A good assessor can help a company understand what is really important and what is not so important when it comes to findings (i.e., context). We don’t waste a client’s time with insignificant issues and that is where the experience and judgment of the auditor becomes critical. Last year I met with a client and said, “you need to be checking for Salmonella in your environment—how do you know it is not there?” I pushed them into checking because I understood the changing regulatory environment. I came back a year later, and they had confirmed that regulators were interested in their Salmonella monitoring program during a recent inspection. As an auditor, you have to be confident enough to provide advice and context to the client in a way that is understood and accepted, and that helps to build trust.
With FSMA, the government can now take specific actions against companies. If I am plant manager or CEO, how do I know for sure that I am in compliance with the requirements? How do I know that I don’t have any of these potential issues? The only way to know for sure is to have the FSMS assessed. Just like a bank or publicly traded company hires financial auditors to assure everything is done correctly, companies need to audit their FSMS to ensure compliance. Get a process audit and ensure they drill down deep into the organization—that is where we find issues and gaps. A thorough auditor will find your problems instead of looking the other way. It is important to call it the way you see it and not be too “soft” when getting an assessment.
If I am the CEO, I want to know where those problems exist. Independent third party assurance is the best way to find out how compliant you are with regulations. No CEO wants to deal with the inevitable lawsuits and lost business impacts. At least with an effective FSMS, you can show a level of due diligence when the regulators show up at your doorstep and the culture is such that you want to address any problems.
We have entered an important time for the food industry with FSMA implementation and other food safety regulatory requirements in the United States. These new rules place an emphasis on management accountability, risk assessment and control of supply chains. The bar for due diligence has been raised and it up to all us to show that we have done everything possible, and the best way is with an effective FSMS.
As the popular phrase goes, if you’re going to talk the talk, then you need to walk the walk. This expression really does ring true when discussing an effective food safety culture within an organization. Timothy Ahn, senior technical manager of food safety at LRQA sheds some light on the importance of management commitment as a foundation for success in implementing a food safety culture and how employee training fits into the picture.
Food Safety Tech: In your column on Food Safety Tech, “Tackling the ‘Why’ of Food Safety”, you touch on the point that food safety culture needs to start at the top. What are the issues in management today that prevents a food safety culture from flourishing within organizations?
Timothy Ahn: First, it’s important to define food safety culture. It can mean a lot of different things to people. The culture is the collective behavior from the organization around shared values and beliefs. From that perspective, it’s extremely important the leadership understands its beliefs and values. The collective behaviors of the leaders become really important, because we’re also talking about how the leadership sets management commitment and drives what’s important in the organization. The organization will follow whatever the leaders do and not necessarily what they say. That’s the issue—having the ability to get commitment from leadership that is demonstrated through their actions, which then transfers into rewards, objectives and consequences. What are the issues that are preventing the culture from embedding itself? Actions aren’t aligned with their words. You have a senior leadership group that will say one thing, but then their actions are different.
In addition, when cascading priorities are very different, food safety doesn’t get the right messages. It’s about growth, market share, profits—all of those financial measures are extremely important, because they have consequences and are also rewarded. Meanwhile, depending on the organization, the objectives around food safety culture may or may not be talked about, defined, or even rewarded. It’s really about making sure that the organization has cascading priorities.
FST: When taking a holistic approach to employee training, what are some of the challenges that companies can expect to encounter?
Ahn: I put food safety into three different buckets that build on top of each other.
At the bottom is the foundation. It’s around good manufacturing practices and all the foundational activities that need to be in place for factory operations. How often you clean your equipment? What do you do around allergens? Can you trace your materials from one end to the other? Do you have a pest control program?
Our food safety system: This includes things around HACCP: Do you have a HACCP plan in place? Do you understand what your hazards are? Have you defined your control measures?
The last bucket is around the management system that drives food safety. Have you defined your objectives? Do you have a policy? Do you conduct a management review? Do you have an internal audit?
The issue with training is many operations only focus on the foundation. You need to have people who know how to clean equipment; you have to make sure that the pest control is done; you need to have good allergen management. Those are all pretty well done. Now you’re starting to get more traction in the second bucket, which is around HACCP, because with FSMA, HACCP is no longer an option; you need to be able to do it.
But the missing piece in many organizations is at the top—the management systems. This is important, because when you talk about culture, that’s where it gets embedded within an organization—through implementation of the management system.
If you look at this holistically, you need to train across all of those areas, not just in the foundation. You can differentiate yourself from organizations that have effective food safety management systems (not just food safety systems) because they’re training across all those buckets.
The other part of training is management systems. Who do you train? Besides targeting first line employees and operators, you also need to train senior managers because these managers, along with leadership, need to better define the objectives and policies. What does it mean to conduct an effective management review? What does it mean to do an internal audit? What’s a good corrective action process? The training often falls apart because organizations haven’t embedded that very well.
FST: Do you see differences between implementing these practices in small versus large organizations?
Ahn: There are differences, but it’s not necessarily a function of the size of the company. It’s more around how they’ve approached developing and organizing their management system and in particular, their food safety management system.
FST: In reality, how long does it take a typical company to create an effective food safety culture?
Ahn: There are two parts to that question.
My belief is that if you want to implement a food safety culture, you need to create a food safety management system, otherwise it is just all words and talk. It’s what you do, not what you say. The way to do that is to embed a food safety management system within your organization.
The two questions are: How do you get to initiate it? And, how long does it take to execute once you decide to initiate?
To address the first question: How do you initiate it?
There are a couple of ways that it can happen. There’s nothing like a crisis to get the fire under somebody’s feet, whether it’s a recall or an incident, it will draw attention to the fact that there’s a problem and something needs to happen. But, that’s reactive and detrimental.
The other way to initiate is that if you have enlightened leadership—an owner or group of owners who understand where they want to go, where they need to go, what needs to be avoided and understands the importance of the organization’s culture in getting to the right place, etc.
Secondly, once you start this process, how long does it take to get this type of system running?
Based on my experience in implementing food safety management systems like FSSC 22000, it takes anywhere from 18 months to 2 years to get it established, and then probably another 18 months or so to actually fully implement. So it’s not something that happens in a couple of months. It takes some time to really get it implemented and embedded, because these are foundational elements you must put into place. There’s a lot of momentum involved, and it has to move throughout the organization.
The term food safety culture has gotten a lot of attention—it’s a buzzword. But what does it really mean and how do you make it come to life? That’s really where people need to start looking. You make it come to life through implementation of structured food safety management systems—ones that are verified, and independently verified. Put substance and real work around your food safety culture instead of using a lot of fluffy words to describe it.