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.
While illnesses linked to Chipotle restaurants are grabbing headlines, the federal government recently took steps to improve how manufacturers and packagers process and handle food. Last year FDA released several final FSMA rules, giving food companies a roadmap for ensuring food safety. The proactive approach of the regulations can help companies avoid the hazards that lead to disease and allergen contaminations, and even legal troubles. Indeed, unsafe food handling can carry costly consequences from both a financial standpoint as well as in lives lost or harmed.
In 2011, the good intentions of a family-owned cantaloupe company produced tragic results. The company, seeking more natural melons, followed a consultant’s advice and discontinued the chlorine rinse used to wash off contaminants. A Listeria outbreak followed, killing 33 people and hospitalizing 147 more. Although prosecution is rare in foodborne disease outbreaks, the company owners were sentenced to probation, home detention, community service, and $150,000 each in restitution.
A more egregious case occurred in September 2015, when the former CEO of the Peanut Corporation of America was convicted of knowingly shipping Salmonella-tainted peanut butter, which had caused an outbreak that killed nine people and sickened hundreds more. Stewart Parnell was sentenced to 28 years in federal prison.
The new regulations require companies to undertake hazard analyses of their production, along with remedial steps. This scrutiny leads to the creation of a written plan that details the controls to prevent contamination and establish a schedule for periodic testing. This analysis and control system is called the Hazard Analysis Critical Control Point, or HACCP.
Adherence to regulations doesn’t necessarily protect a company from liability, but not adhering can sound a company’s death knell when there’s a problem. The following are five ways in which companies can protect themselves:
Put food safety first. The company culture must revolve around it. The message that the HACCP plan is to be followed must be relayed to all levels of the organization. Otherwise, companies can face severe consequences, based on the question, “Did the company behave badly enough to face strong punitive damages?”
Concentrate on internal communications. In many cases, food recalls happen because of a breakdown in the communication process.
Hire accredited consultants. Make sure that your consultants are qualified and have been accredited by an appropriate body such as the International HACCP Alliance or The Seafood HACCP Alliance.
Don’t overlook supplied products. Suppliers should adhere to strict contamination-prevention protocols, but don’t assume they follow guidelines completely or have flawless processes. Your contracts with them should require that they periodically audit their facilities and share the audit results with you.
Label clearly. Packaging language might state that a product is manufactured in facilities that also process allergens such as peanuts and tree nuts. These types of warnings allow consumers to make up their own minds. It is also a reminder that HACCP plans must address prevention of cross-contamination (i.e., putting cleaning protocols in place if products with and without allergens are processed on the same equipment).
Many problems involve internal slip-ups or problems with supplied ingredients that allow contaminated food to reach consumers. If the contamination becomes known—and it often is not, when victims don’t equate their illnesses with tainted food—the businesses involved often face strict liability, meaning they carry some blame even if they didn’t act in a negligent manner and cause the problem directly.
Keep in mind that liability isn’t the only consequence of non-compliance. A recall or outbreak can damage the reputation of the company and the product. The cantaloupe tragedy sent sales of the melons plummeting, even in states not linked to the outbreak.
To minimize the hit on sales, a recall team should be in place, with a plan modeled on crisis management principles. Team members should come from all divisions of the company, including transportation and distribution to track down products, and communications to manage messaging. Legal counsel should be on board to advise on the ramifications.
When it comes to foodborne outbreaks, it’s a matter of taking classic prevention and preparation steps. Do everything you can to keep it from happening, but be ready just in case it does.
Days are now shorter, and temperatures are slowly dropping in most parts of the country. It is the time of year when individuals look to spend a little more time indoors and a little less time outdoors. However, did you know we aren’t the only ones looking for relief from the cold?
Similarly to us, this is the time of year when certain pests look for a nice, warm home to spend the winter months. The downside for food facilities is that they offer everything pests need for survival—food, water and harborage.
In fact, food facilities can face numerous pest challenges during the colder months, including ants, cockroaches, stored product pests and flies. Additionally, the most common and challenging winter pests are rodents. Due to their ability to squeeze through small spaces and adapt to many different environments, they can be a facility’s worst nightmare.
The presence of rats and mice can lead to food contamination and can threaten your food safety audit scores, reputation and bottom line. Rodents are known carriers of deadly neurological and respiratory diseases like lymphocytic choriomeningitis virus (LCMV) and Hantavirus Pulmonary Syndrome. Ticks, mites and fleas can feed on infected rodents and transmit diseases like pox, plague and typhus indirectly to humans—putting not only employees in your facility at risk, but also customers.
Rodents can be tough to control and are very adaptable at living indoors. Some mice that take shelter inside due to weather can survive indefinitely as indoor mice. In fact, there is a possibility rodents may have already taken shelter by now, so it’s important to talk with your pest management professional about common areas where rodents may be hiding.
As you winterize your facility, it’s important to keep rodents and other pests in mind. A proactive approach to facility maintenance, as well as an effective Integrated Pest Management (IPM) program, can help keep pests out and your food product and business secure.
The following tips will help keep your facility off pests’ radars this winter.
Stay Vigilant in Monitoring for Pest Activity
Vigilant, ongoing monitoring is a cornerstone of an effective IPM program. With this strategy in place, there are many tactics you and your staff can use.
Identify “hot spots”. Work closely with your pest management professional to identify the most common places pests reside in around your property. These can include loading docks, utility rooms, employee break rooms, dumpsters and trash cans, storage rooms and behind any heavy, immobile pieces of equipment. By identifying these hot spots, you’ll be able to prevent pests from entering your facility.
Involve your employees. Educate your staff on the pests themselves, as well as the conditions that attract them, and encourage your employees to report any signs of problems. Utilize a reputable pest management company to provide your employees with this training—many providers offer training at no extra cost.
Strengthen Your Facility’s Perimeter
While certain pests can hitch a ride into your facility via shipments and even on people, the biggest pest threats start on the outside. With this in mind, you can take fight pests outside by strengthening your perimeter.
Look for and fill cracks and crevices. Crawling pests like to creep inside through small openings. Additionally, rodents can squeeze through holes the size of a quarter, mice through dime-sized openings that create gaps barely noticeable to the human eye. Regularly inspect the exterior of your facility for any cracks that may develop and pay close attention to openings that can form around pipes and utility penetrations. Don’t forget to seal any holes in exterior walls with water-resistant sealant and steel or metal mesh.
Eliminate clutter and attractants. Rodents may burrow or live up to 100 yards away from your structure, and flies, ants and cockroaches are also on the hunt for easy meals that can often be found on the property. Keep trash handling areas free of clutter, and clean up any uncovered garbage or standing water outside. Also, work with your waste management company to ensure they clean and switch out dumpsters regularly.
Keep landscaping off your building. Pests will often use vegetation as staging and feeding sites. Keep trees trimmed and plants at least 12 inches from your building, and remove leaves quickly so pests cannot use them for cover. As an extra step, consider installing a two-foot wide gravel strip around the perimeter of the building. Think of these exclusion techniques as digging a moat around your castle.
For rodents, bait stations can be set outside. Work with your pest management provider to place tamper-resistant bait stations around the exterior of the facility. However, do not place the stations near doors or entryways, as they can attract pests into the facility. Be sure to maintain an up-to-date map of bait stations and record activity at each station to determine the source of rodent pressure and target future treatments accordingly.
Reinforce Clean Conditions Inside
Once you set up an outside defense against pests, you can double down on your pest management efforts by taking a few proactive measures inside as well. The key to keeping pests from infesting your facility is removing incentives for them to go inside in the first place.
Inspect incoming shipments. When you are not receiving materials, keep loading bay doors closed—make sure the doors close securely so that pests cannot sneak under them. Inspect incoming raw materials, packaging and truck trailers for signs of infestation.
Reduce potential food sources inside your facility. Employee break rooms should be clear of any food remnants, and garbage cans with food and other waste need to be kept tightly sealed.
Monitor the plant floor. Sanitize drains and equipment with an organic cleaner to eliminate the residue that pests can feed on. With colder temperatures, pipes can break or crack, so ensure plumbing is also maintained properly to prevent leakage and property damage. Monitor for spills and clean them immediately, as pests only need a small amount of moisture to survive.
By putting proactive defenses into place, your facility can enjoy the winter seasons with a decreased likelihood of the appearance of unwanted visitors like rodents, ants, cockroaches, stored product pests and flies. Talk with your pest management professional about these steps and other tactics you can put in place to keep your facility safe against overwintering pests and relegate them to the cold.
FSMA isn’t about zero risk but rather minimizing the hazards, said Michael Taylor, FDA’s deputy commissioner for foods and veterinary medicine at the opening of the Food Safety Consortium conference yesterday. “We have hundreds of thousands of businesses that are subjected to something that they weren’t before,” said Taylor. “The reality is, we’re still going to have outbreaks this year and the next year.”
In his first public speech since three final FSMA rules (on produce safety, foreign supplier verification, and accredited third-party certification) were filed on the Federal Register last week, Taylor shared some of the highs of the formation of the regulation as well as the challenges that are to come with implementation. “Many of us who were involved in the process 20 years ago didn’t imagine we’d get here today,” he said.
Right now FDA is looking at the big picture challenge of preparing the agency and industry, and actually getting the work done. Taylor called the implementation challenge “enormous”, thanks to the significant scale of the food system, and said the import piece of the regulation will take the most hands on deck. The ultimate goal of FSMA is real-time prevention versus reaction, and the regulation will require a lot of change within FDA. According to Taylor, the agency is revamping its internal management processes, along with its training and orientation programs, which also includes food safety culture training. Other activities include restructuring the inspection and compliance approach by realigning its field force to have fully specialized teams of inspectors.
One of the challenges that industry sees is the mindset shift in investigators from a resolutions approach to a systematic approach in assessing systems. When asked how FDA will get investigators to this level, Taylor admitted he was a lot more worried about the issue than he is now. The district folks in the front line are enthusiastic about the new approach and feel empowered by FDA’s new mission, he said. And while he didn’t want to be a Pollyanna about the extent of the effort, FDA knows that the agency workforce will not be 100% aligned on day one of implementation and is managing the process with this awareness.
Voluntary compliance is key, and while the weight of ultimate accountability stands on the shoulders of food and beverage companies, success cannot happen without collaboration with FDA. “We are convinced we’ll get 90% of the job done by working with those who are committed to doing the right thing,” said Taylor. “When that fails, there are other ways to deal with that issue.”
In a meeting early this summer, I shared the story of a young girl who recently died from a foodborne illness and of the advocacy that her family has engaged in since that time. A person holding an important position in a food organization responded with assurance: “Well, we take a risk each time we walk outside.” This string of words has become a haunting refrain. The tearful words of the families with whom each of us at STOP Foodborne Illness have spoken resonate.
I wonder if the person who spoke communally understands why their position exists. Why do any of us have jobs in food safety? What happens in a food company when a senior employee subscribes to this philosophy? Maybe the belief is that it can’t happen to them? Does this organization need to experience it first-hand to understand it? Will a consumer die as result of this philosophy? Will the company suffer incredible financial losses? Will the cognitive dissonance finally dissipate? Will the company survive?
A comment like this is a reflection of a person and maybe of an organization that does not have a food safety culture. It’s a comment that is dismissive of food safety risks. When people eat food, they have a right to safe food. And companies have an obligation to manage risks—not simply be dismissive of them.
I know I am preaching to the choir to those of you reading this blog. You embrace, understand the importance of, and advocate for a food safety culture. You care deeply about your fellow human beings and about your company. But tell me, how would you respond to this comment? How do you broadcast the why behind food safety? How do you remember individuals who have been seriously ill, who live with long-term consequence, and who have died from foodborne illness? How do you help others understand that risks must be mitigated throughout the food chain?
Thanks for taking the time to think about these questions and how best to answer them. A true food safety culture understands that there are risks, and the organization adopts a mindset that most food safety risks and outbreaks can be PREVENTED.
Unfortunately, some people will only embrace food safety culture once they’ve had a catastrophic event.
Please join us at STOP Foodborne Illness as we work to help others to proactively adopt a food safety culture to prevent outbreaks—not as a response to outbreaks.
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