In addition to Operations, Detection, Compliance and Supply Chain, this year’s call for abstracts for the Food Safety Consortium will include a new category: Cannabis quality. A series of presentations on the topic will address regulations, edibles manufacturing, cannabis safety and quality and laboratory testing.
The passage of FSMA sparked industry-wide tightening of food safety standards. Perhaps one industry that has been affected more than others is brewing. Prior to the passage of this sweeping legislation, brewers weren’t held to the same standards as other food manufacturers and food processors. The act’s new categorization for brewers as “food” means that the FDA now has some jurisdiction over the industry in conjunction with the Alcohol and Tobacco Tax and Trade Bureau (TTB).
This increased scrutiny, particularly in the event of a recall, has caused many brewers to look to color-coding as a measure to tighten up their quality assurance protocols. Fortunately for brewers, there are many benefits to incorporating color-coding, making the process a worthwhile one.
Perhaps the most immediate effect of incorporating color-coding in a facility is delighting any inspectors that may drop in. A color-coding plan is a documented method for evaluating potential hazards and implementing precautionary measures to preventing contamination—all things inspectors want to see. Failure to live up to these standards can result in follow up inspections and, in some cases, fines.
Proper Tool Usage
A color-coding plan indicates where and when a tool is to be used. While mistakes can still be made, a clear plan that is reflected in all tools and paired with adequate signage and training makes it much more likely that a tool will be used properly. Much of the equipment in a brewery is very expensive and can be easily damaged by using the wrong tool. For example, if an abrasive brush were to be used on a stainless steel tank, there can be irreparable damage.
Tools that are color-coded are generally made at a food-grade, FDA-approved quality. This means they are much less likely to leave behind bristles, a potential contaminant you wouldn’t want finding its way into the product. Additionally, many breweries make use of caustics and acids followed by sanitizers in the cleaning process. A low-quality tool will degrade at a much higher rate as a result of coming into contact with these chemicals than a higher quality tool will. Simply put, higher quality tools last longer, saving you money in the long run.
Less Tool Wandering
A color-coding plan should indicate where a tool is used and where it is stored when it is not being used. When tools have this designated storage area they are much less likely to be carelessly misplaced. And in the event of a lost tool, it becomes much easier to recognize these tool gaps and replace as necessary sooner rather than later to ensure that the proper tool is always used for the task at hand.
When protocols are in place for tool usage, time isn’t wasted finding the correct tool for the job. This may seem insignificant, but over time those lost minutes can add up.
Removal of Language Barriers
For facilities that employ foreign speakers, color-coding is extremely helpful in breaking down language barriers. A brewery production area can be a busy, fast-paced environment, so it is helpful to have a plan in place that is easily recognizable and understood by all employees.
It is however important to consider the fact that you may need to keep in mind the visibility of these colors for colorblind employees. It’s best to try to use high contrast colors in your plan.
Finally, in the unfortunate event of a recall, a color-coding plan helps add traceability potentially decreasing the amount of product that needs to be pulled from shelves. Certainly color-coding helps to prevent contamination issues that can cause a recall.
A well thought out color-coding plan that is carefully implemented can have numerous benefits in breweries both small and large. For questions related to drafting a color-coding plan from scratch or updating an existing plan, contacting a color-coding specialist is recommended.
Increasingly, we turn to technology to simplify tasks in our personal and business lives. Platforms like Facebook and Twitter allow us to connect, shop, advertise and publish with just a few clicks. LinkedIn is where people turn to prospect for new business, publish articles, discuss issues within industry groups, and look for a job. Need a ride? Apps like Uber and Lyft can usually get you where you’re going cheaper and more easily than a taxi. Devices like Google Home and Amazon Echo can listen to your voice commands to play music, manage your shopping list, adjust your lights, or tell a joke. And experiments are underway for driverless cars, which could make us the last car-owning generation.
With technology automating and solving so many tasks, how is it possible that food production is still dependent on paper-driven and manual processes?
The current way of doing things in the food and beverage industry is outdated, labor intensive, and—most importantly—error-prone. Under FSMA, companies need to be able to justify their decisions and processes, and of course, document them. It’s not only critical for brand protection—it’s a regulatory requirement. Ignorance is not bliss. Now, senior management is obligated to demonstrate their commitment to food safety and they risk criminal prosecution if their operations don’t measure up. There’s too much at risk to keep doing things the same old way. The following are some signs that your quality department is still in the Dark Ages.
1. You’re using clipboards.
In defense of clipboards, they were a wonderful invention. They are quite well suited for gathering signatures on petitions to save the whales or signing up for a PTA bake sale. But if you’re still using clipboards to log temperatures or document sanitation procedures, then your food safety records are not as current and organized as they could be. Inputting data later is not an effective use of time. Processes like these not only take away from the core competencies of your quality team, but they also make staff spend more time analyzing everything manually, which could lead to costly mistakes or inaccuracies. Tablets and PCs have replaced paper-based logs and other quality recordkeeping. Why make your staff do a task twice? By digitizing these records, you can ensure that your records are up-to-date in real time and reduce the likelihood of errors made during transcription. Trust me, your staff will thank you for rescuing them from extra data entry. Plus, the modern workforce expects digital solutions.
2. You’re still using a physical filing cabinet to store food safety documentation.
If you’re putting your food safety plan, supplier documents and certificates of authenticity (COAs) in a filing cabinet, you have a transparency problem. Your department isn’t the only one that needs access to those critical documents. And if everyone has their own paper copy, then you are going to have problems with version control. Solve your transparency and version control problems by keeping critical documents in the cloud where the data can be extracted, analyzed and shared internally and externally across your supply chain.
3. Three-ring binders are for middle school, not food safety.
If your idea of ensuring compliance involves keeping COAs in a three-ring binder, you probably still have a flip phone, too. Seriously, 1980 called and they want their Trapper Keeper back. Whether your documents are in filing cabinets or binders, you still don’t have the transparency you need to efficiently share that information with your peers and other departments. Plus, your audits are sure to drag on longer than necessary if you are doing audits with stacks of three-ring binder instead of using an online platform where you can show the auditor any documentation they need with just a few clicks of a mouse.
4. Your suppliers send critical food safety documents to you via e-mail.
Email is a great way to communicate. It’s just not the best way to gather and manage supplier documents. Admit it; we all get behind on email, and sometimes things slip through the cracks. What happens if an out-of-spec allergen declaration gets buried under the 586 emails you receive each day? I can tell you, it’s certainly not good. The alternative is allowing your suppliers to upload those documents into a platform, so they are immediately available to you and anyone else in the company that you’ve given access to the system. Leveraging a platform, you also have access to a dashboard that can quickly show you which suppliers are in compliance and which ones have issues that need to be addressed. And if you have incoming certificates of authenticity (COAs), you can sit back and rely on software to read those documents for you and spot anything that doesn’t match your specifications or purchase order details. Isn’t it time that you not only collected supplier documents, but really use that data within the documents to better manage your incoming material to ensure food safety and quality?
5. You rely on file sharing to store your food safety and quality documentation.
SharePoint and other file sharing systems may look more modern than the paper alternative, but they weren’t designed specifically for vendor management or supply chain transparency. They can file and retrieve, but it’s not automated document management. Ask yourself how long do you or fellow employees spend searching for requested documents? Perhaps you need certain documentation for your GFSI/FDA audit, but different pieces of information are stored in various locations, either in a shared drive like SharePoint or a custom vendor portal. Every minute counts when it comes to document retrieval. These systems are often a little more than an electronic filing cabinet. They can store the information electronically, but unless it’s gathering, analyzing, validating and sharing that data across all departments, you still don’t have an automated system.
6. Spreadsheets are the main source of tracking your data.
While quality managers at competing companies are investing in the latest technology, other food companies are still inputting supplier lists and data in spreadsheets. Often, managers are reluctant to move their data to the cloud, opting instead to stick with what they know by using a spreadsheet that lacks a comprehensive system to track supplier performance in real time. This is a major disadvantage when different departments need one source of the truth about supplier performance and trend data about incoming material. Not only are spreadsheets hard to share and keep up-to-date, but the majority of them also contain errors.
A report by Ray Panko, a professor of IT management at the University of Hawaii, found that 88% of spreadsheets contained errors.
Coopers & Lybrand found that 91% of spreadsheets with 150 rows or more produced results that were off by more than 5%.
In a sample of 22 spreadsheets, KPMG found that 91% contained serious errors.
If your executives think automated supplier, compliance and quality systems are a “nice-to-have,” chances are you are still operating in the Dark Ages. This final advice is true no matter what software your business is thinking of implementing. Whatever the aims of the system, you must choose a long-term partner. Make sure your vendor can solve these six problems and meet the needs of your business now and in the future.
How fresh is “fresh”? This is a question that is asked throughout the supply chain as it pertains to seafood. Determining the quality and freshness of seafood has long been an issue in the industry. A handheld screening and data collection device developed by Seafood Analytics uses electrical currents to generate the cellular quality of seafood products.
The CQR device measures how much the cells inside a fish species change over time. Real-time measurements can be taken in different conditions, from catch to freezing, or from catch to consumption. The device can be used throughout the supply chain, including by grocery chains, foodservice distributors, and harvesters and processors. By enabling users to evaluate the quality and freshness of seafood, the CQR device also helps reduce shrink loss, manage inventory, determine inbound supplier selection and set pricing based on quality.
Food safety and quality professionals are change agents and problem solvers. It is what we do. The manner in which people within an organization respond to change, problems and opportunities for improvement is a reflection of the food safety culture of the organization. Does your organization celebrate when someone correctly decides to shut production down or put a product on hold? Obviously, it is always best to prevent any issues before they arise, but stopping a line to prevent bad product from being produced or catching out-of-specification product before it leaves the facility is better than continuing to produce and ship bad product. These events are often viewed as negative occurrences, and, therefore, many do not see the value of the Food Safety/Quality Assurance department.
Elise Forward will be speaking at the 2016 Food Safety Consortium, December 6–7 in Schuamburg, IL | LEARN MOREHow can we change this viewpoint and positively affect the food safety and quality culture of the organization? A few key factors have a great impact on the culture of an organization. People, systems, access to resources and opportunities for growth are all integral pieces of a stellar food safety culture. In this column, the first of a two-part series, we will explore how people build, change and mold the culture.
First and foremost, people are the number one asset and provide the greatest impact to change. Not only are personnel the eyes and ears of an organization, but they also provide the logic required to make good decisions. Computer technology is amazing, but it cannot fully replace the human ability to process the information. People need to be used to their fullest potential in order to obtain the greatest impact. The following are some ways people can be used to boost the food safety culture of an organization.
Everyone is involved in food safety. A team is always stronger than individuals. Everyone, from the C-suite to the third-shift person in charge of the employee refrigerator and taking out the trash, to the office staff that answers the phones and opens the mail, needs to have responsibility for food safety. In addition, contractors and subcontractors are not immune to providing a significant role in protecting the food safety of your product. All relevant staff must have the appropriate training to understand that what they do affects the food safety of the product as well as the entire facility. Having everyone trained means that many then share the food safety mentality and, therefore, there are stopgaps in the system. As with many issues, it is not one breakdown of the system that leads to a failure but a culmination of many breakdowns. People are still the strongest asset to food safety, so having multiple stopgaps (i.e., people), involved in protecting the process will help ensure that the product remains safe.
Executive responsibility. The responsibility of the overall food safety of products leaving the facility now lies with the executives, as seen by the recent cases involving Peanut Corporation of America, DeCosters and Jensen brothers. Executives and decision makers are accountable for the presence of or lack of appropriate food safety measures. Therefore, when making changes, executives need to understand that these are personal decisions that could affect themselves and their family, in addition to customer confidence as well as profits and losses. Questions such as, “What happens if their name is plastered on the evening news?” and “How will your customers, investors, consumers react if the company has a problem?” should be asked.
Evaluate any decision for food safety consequences. Food safety and quality is directly related to profits and losses. Any issue or change that arises must be evaluated to determine if there are any impacts to food safety. For example, the purchasing department must understand that the items purchased and used on the production floor impact food safety. Therefore, food safety should be on every agenda and part of every decision. This can be as simple as adding to the bottom of every agenda the question, “Is there any way that food safety will be impacted?” The C-suite members should be included in management meetings where additional food safety discussions occur.
Employee trust. Employees must be trusted to keep the product safe in order to safeguard the business and the products. It is human nature to take pride in the work that we are assigned and to strive for excellence. People feel rewarded when they are trusted and will continue to add value to the organization by striving for continuous improvement. This translates to greater attention to food safety and quality.
If an employee cannot be trusted, this person should not be on the payroll. The Food Defense rules specifically require a company to address intentional adulteration from an internal entity. To ensure quality, background checks should be completed on every employee, contractor or sub-contractor who has access to critical areas of the facility.
Food safety should be in every job description. Food safety is everyone’s job, so update job descriptions to include pertinent responsibilities to food safety. At a minimum, everyone should have the “See something, say something” responsibility in his or her job description, in addition to anything specifically related to his or her job. Likewise, it can be valuable to have an independent set of eyes to evaluate a system. Therefore, train and use all personnel that do not have a background in food safety and quality. Departments such as accounting, warehouse, maintenance and personnel should be trained to perform GMP and sanitation audits. Spread these tasks around and your systems will benefit. The people performing the tasks will take pride at being trusted with these important responsibilities and tasks.
While a company or organization may start in an undesirable situation, it is possible to change the environment. Remember, the people you work with are your greatest asset. Value these people; uplift, teach and coach them in the ways of food safety and quality. Your efforts will produce astounding results! In the second half of the discussion on food safety culture, we will discuss other facets that influence food safety culture.
Food businesses face a range of risks, from lack of consumer confidence to supply chain security. As FSMA regulations and issues such as climate change rise to the top of the list of priorities of global governments and regulators, food companies need to secure the reins on their businesses to ensure they can face these seven emerging risks in 2016 and beyond.
Research and development (R&D) is an essential starting point toward the creation or modification of new and exciting food products, processes and packaging. To ensure that a product is safe for consumption, food safety should be considered during the initial stages of a product’s lifecycle. Incorporating food safety into R&D can be tricky, as safety considerations may change the initial idea or concept of a new food product. For example, the idea of a freshly squeezed orange juice in every supermarket shelf is appealing; however, without pasteurization, that juice will not be safe for consumption, nor will it have the desired shelf life. Adding raw chopped garlic to a hummus product makes it taste great, but will it be safe for consumption after being on the shelf for a month?
To better understand how safety of new products is assured from concept to launch, I spoke with two R&D scientists about food safety considerations during new product development. The interviewees, Maria and Laura, work for the same large food manufacturer, which is located in the Midwest, in the snack foods and breakfast cereals categories, respectively. They both confirm that the R&D team follows a specific procedure during the product concept phase—one that places food safety at the forefront. The team starts by determining how the new product compares to food safety regimens already in place with other products that the company manufactures. If the product is a line extension with only a few changes to an existing formulation, the food safety concerns are likely to be low, and the food safety program already in place is adapted to meet the safety needs of the new product. However, if the product being developed is highly differentiated from other products manufactured by the company, food safety moves into a more central role throughout the development cycle.
According to Maria and Laura, the first step in ensuring food safety for a new product is for the development scientists to have in-depth discussions about the product’s formulation, ingredients and supply sources. These three aspects, along with the planned manufacturing process, are then evaluated through a hazard assessment. The hazard assessment is comprised of microbiological, quality, regulatory, stability and physical hazard assessments. Ingredients that pose food safety concerns without prior controls and process conditions are identified. The quality team determines controls for these ingredients and subsequently involves process engineers to verify that process conditions are attainable and will provide proper control for the hazards identified. A complete HAACP plan is put in place for the new product production, taking into consideration equipment cleanability and location, traffic control for ingredients and operators, and air handling systems. The hazard assessment is documented in detail and must be approved by the quality manager before production runs can begin and development can resume. Although the entire process is led by R&D, multiple other functions are involved and consulted throughout the process.
Manufacturing processes, formulation and market availability of ingredients drive the food safety of a new product, with manufacturing processes and formulation usually being the key drivers. “However, in cases like the recent shortage of eggs due to the avian flu crisis, finding substitutions for ingredients in shortage becomes an important driver for food safety,” says Maria. Laura says that at times, product formulations can change due the integrity of the ingredient or its source. In such cases, a similar ingredient from a credible source is chosen and the safety of the product is re-assessed. There are critical quality and food safety elements that must be considered in the product design phase to prevent issues later in development. When R&D professionals keep these elements top-of-mind when considering formulation and ingredient sourcing, everyone benefits—from the company to consumers.
Although consumer confidence in the safety of the U.S. food supply is slipping (11% said they were “very confident” in the safety of the food supply, down from 15% in 2013; 50% said they were “somewhat confident”, down from 55% in 2013, according to the International Food Information Council’s 2015 Food and Health Survey), the interview with Maria and Laura shows that manufacturers are putting significant effort into developing safe food products. It is equally as important for suppliers and vendors to have robust food safety programs to build strong relationships with manufacturers. Food companies have a lot to lose if a product they develop is, or becomes, unsafe for consumption. Not only can the average cost of a recall add up to $10 million in direct costs to a food company, lost sales and the impact to the company’s market value, brand reputation, and business relationships is major. Some companies never recover from the punch. Through taking the time to audit suppliers, screen new ingredients, and make robust prototypes, food companies can be more confident in the safety of their innovative new products as they go through the development process.
At the recent Food Safety Summit in Baltimore, the focus was on building an Integrated Food Safety System (IFSS) to aid in implementing FSMA and continued progress along the path of prevention vs. reaction, while at the International Forum on Food Safety (IFoFS) in Beijing, speakers emphasized colla boration for more effective and accurate communication of food safety risks.
In China, the media often over reports on food safety scandals that are actually food quality issues. Consumers are led to believe that food safety is a widespread problem across China and thus have developed a dis trust in the local food industry. At the heart of the matter is multi-stakeholder risk communication. The media is not solely to blame for this problem. Industry and regulators must be more proactive in communicating the true nature of food-related incidents in a way that is more accessible to consumers and the media.
The entrenched culture and government supremacy of China also contributes to the problem. The food industry typically does not communicate openly about food safety risks once the government has spoken out. However, at IFoFS, openness was a key focus, and I think we are at pivotal turning point. Chinese and other Asian companies, along with the Chinese FDA, have begun discussing the criticality and need for risk communication as it relates to food safety and food quality as a means to protect both consumers and food brands. One significant challenge involves instances in which errors in judgment are not quickly admitted when a regulator positions an incident as one of food safety when soon after it’s realized it is a quality issue. It’s safe to assume that regulators may not take the initiative to openly admit the misclassification, and speaking out against these issues may be perceived as openly challenging the government.
I also see the same phenomenon happening in the United States, but the over-reporting, is more so connected to the lawsuits against FDA and topical focus by consumer activist groups. For example, certain activist groups are over-amplifying the purported risks of GMOs, and we’re seeing over-reporting of the pressure and lawsuits against FDA related to FSMA deadlines. Similar to China, these issues are not food “safety” issues per se, but the media’s coverage exacerbates consumer misunderstanding and feeds a belief of widespread adverse food safety issues.
At the Food Safety Summit there was more focus on the integration and collaboration of federal, state, local, and regulatory bodies to implement FSMA. Michael Taylor, FDA’s Deputy Commissioner of Foods said that the publication of the final rules will meet the court-mandated deadlines, beginning in August. He added that there is an existing, established network between these groups, but FSMA elevates this association to a new level, because Congress has mandated it. The discussion of interaction and integration raised a question during a Town Hall on “integrating” the federal food agencies into a single agency. The general answer: If we were starting from scratch, we probably wouldn’t create separate agencies, but given that there are two today, there are more effective ways of integration versus completely disrupting the system to create a single-agency. (Sorry David—we know how much you would like a single food agency!)
The common thread? The U.S. and China are calling for increased relationship building and trust between all stakeholders. This common thread sews these two conferences, countries, and the global community together. But the question remains, with the media, consumers, regulators and industry seemingly still at odds with each other in both countries, how do we make this happen?
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