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ASI Food Safety
FST Soapbox

The Costs Of Food Safety: Correction vs. Prevention

By Matt Regusci
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ASI Food Safety

Every company that grows, produces, packs, processes, distributes and serves food has a food safety culture. In the food industry, when looking at food safety culture there are essentially two groups: The correction and the prevention groups. Basically, the prevention group is constantly improving their food safety practices to minimize foodborne illness while the correction group waits until there is an outbreak to make changes.

The correction group isn’t proactive and has a number of excuses that keep them from implementing a food safety program. Oftentimes owners or managers think, “The chances of my company being involved in a food safety outbreak are so rare, I just won’t worry about it.” Or they think, “The cost of having a food safety program is so prohibitive that I’d rather handle the consequences of an outbreak if it were to arise.” Also, sometimes there’s a lack of knowledge and some producers don’t even know about food safety programs and don’t have or want to take the time to learn about them.

If your food company is in the corrective group, you are not alone. Three years ago a private study was done to see how many food facilities could pass a basic Good Agriculture Practice (GAP) and/or Good Manufacturing Practice (GMP) audit. It was discovered that less than 20% of these companies would be able to pass the most basic food safety audit. This number is staggering and unfortunately the correction group is much larger than anyone thinks—it equals a majority of the facilities at around 80% of the food industry. This statistic is frightening and needs to be addressed to help reduce outbreaks.

What does the preventative group look like? Well it is more of an investment up front, but in the end helps reduce risk and costs. Companies that take on this responsibility go through an audit and implement procedures that prevent outbreaks. That is level one. The next level of protection involves applying and gaining a certification. All of these procedures help to give your organization a barrier against costs such as crisis management with a PR firm, a recall that leads to lost product and sales, and a thorough clean-up process.

Food safety prevention is an ongoing journey of understanding your many risks and implementing procedures and processes to minimize these risks. Prevention is not a one person job, but rather the whole company needs to join the common cause of protecting the brand and more importantly customers lives.

The cost though is always a huge consideration and can become a deterrent to implementation. Oftentimes owners or managers of facilities will say, “The cost of food safety prevention is so prohibitive that we can’t implement a program.” Yes, there is a cost to building, implementing, and maintaining a preventative food safety program. However, this cost pales in comparison to a corrective program.

Overall Cost of Correction: FDA – Lives – Individual Companies (Restaurants and Farms)

Just recently CDC posted that the economic impact of pathogenic food safety outbreaks is $17.6 billion which is $2 billion higher than 2013. The CDC calculates this based on medical expenses, productive decreases in wages, and ultimately loss of American lives. This large number and massive increase in economic cost has made headlines recently as a huge problem, but few in the media understand this number is small compared to the true cost of foodborne illness.

So what is the true cost annually of the collective in the corrective group to the food industry and America as a whole? To come up with that number we need to look at all the costs of an outbreak: Legal costs, fines, bankruptcies, decrease of overall commodity market share, decrease in public trust, and jail time. And let’s not forget, the real cost is that lives were lost due to lack of prevention.

To understand the cost, let’s look at a few examples, starting with Chipotle. Last year the company agreed to pay the largest fine in history of $25 million for its part in multiple outbreaks from 2015–1018 sickening more than 1,000 people. This fine is tiny in comparison to the stock market loss. In 2015 the stock went from $740 a share to a low of $250, and in fact Chipotle’s stock did not get back to $740 until July of 2019. That is billions of market opportunities lost.

Johns Hopkins Bloomberg School of Public Health did a study and concluded that foodborne illness costs the American food service industry $55.5 billion annually. On average each food safety outbreak costs the establishment between $6,330 to $2.1 million, depending on size of the operation and how widespread the outbreak is. Chipotle has a lot of resources to manage and recover from a crisis; many small and/or over-extended companies go bankrupt and are forced to close down.

There are plenty of examples on the supply chain side. The first example is the Salmonella outbreak of Peanut Corporation of America. The largest part of this tragedy is that 714 people got sick, about half of whom were kids, and nine people lost their lives. Due to this, three executives went to jail, not for a few months for decades. The economic cost is astounding; Peanut Corp of America had an annual revenue of around $25 million, but the cost of the outbreak was over $1 billion. This may seem like a very large number, but don’t forget peanuts are an ingredient in many other products. Kellogg’s estimates they lost $65–70 million in products they needed to recall from this one outbreak, and Kellogg’s is just one of many Peanut Corp of America customers.

Another example is the Jensen Farms Listeria outbreak that sickened 147 people and of those 33 died. The brothers, of this multiple generation farm, Eric and Ryan Jenson, went bankrupt and were sentenced to five years probation and six months of home detention; each had to pay a $150,000 fine. Again, this small family’s operations outbreak had massive ramifications for the cantaloupe industry, which suffered significant damage as a result. Walmart reached a settlement for an undisclosed amount in 23 lawsuits involving the Listeria outbreak linked to the cantaloupes

Overall Cost of Prevention: Internal Programs, Supplier Programs, Testing and Audits

The FDA has conducted a few studies on the industry cost of the many leafy greens outbreaks. One study showed the spinach industry alone lost more than $200 million just in retail sales and many more millions in opportunity sales from the 2006 E. coli outbreak. And a recent leafy green outbreak in 2018 cost the industry an estimated $350 million. With staggering numbers like these, the LGMA was created in 2007 to help raise the bar for food safety prevention in this high-risk product. The LGMA study found that their members, which are large leafy green marketers, including Dole, Taylor Farms and Ready Pack, increased their spending three times for true prevention measures.

What does it look like to go from the corrective group to the preventative group? First you have to make the decision of implementation and get buy-in from your entire team. If you are starting from zero, asking your clients and competitors what standards they are utilizing and being audited to, or should be audited to, is a good starting point. This will help in developing a plan of action.

Once you have the checklist, audit human resources. Do you have a Food Safety and/or QA person or team? Are they capable of guiding the executives on this journey? If not, hire a consultant to help you get started.

Once they are on the journey of prevention, people see their entire operation in a different way. They see risks where they never previously saw them—risks with people, equipment, products, building, and the surrounding area. This can get super overwhelming, but if they don’t panic they will be excited about the future. The paradigm will change and they can build, implement and maintain practices to minimize risks one by one, starting with the biggest risks.

In accounting for the physical costs of prevention, the largest will come from the human resources component. Hiring people to build, implement and manage your food safety program will be your largest expense. Another human resources cost is the continued training for the entire staff on food safety expectations. After that cost drops significantly, annual audits and microbiological testing come into play, and the cost will vary on the size of your operation and the risk of your products. For instance the LGMA study showed on average the cost of their members went from $200,000 to about $600,000 annually for prevention, but these are very large multiregional organizations with a very high risk product.

The most important things in life come with hard work and at a price. Every person who has climbed Mount Everest did so one step at a time. Food safety prevention is no different. Is there a cost in money, time, and stress? Yes. Is that cost less than sitting on the beach with your head in the sand of the correction camp? No doubt. But the choice of leaving the majority that are wrong to the minority that are right is yours. Hopefully, you make the right decision.

Michael Sperber, UL Everclean

Amid Labor Shortage, Restaurants and Grocery Stores Challenged to Focus on Sanitation and Employee Training

By Maria Fontanazza
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Michael Sperber, UL Everclean

The foodservice and retail industry has struggled to keep up with the curveballs thrown at it during this pandemic. “Whether reopening dining rooms after extended closures or finding their footing in a world of new omnichannel ordering, quick service restaurant and fast casual managers are grappling with evolving rules and regulations, changing diner preferences, while also welcoming an entirely new workforce,” says Michael Sperber, a global business manager for UL Everclean, a third-party retail food safety and sanitation audit program that helps retail foodservice businesses improve their food safety practices. In a Q&A with Food Safety Tech, Sperber discussed the evolving challenges in the foodservice and retail space over the past 15 months.

Food Safety Tech: On the issue of sanitation and cleanliness, what hurdles do restaurants and grocery stores have in the face of the pandemic and the subsequent labor shortage?

Michael Sperber: Trust in the safety and cleanliness of restaurants and grocery stores is one of the bigger concerns that must be addressed as consumers continue to navigate the pandemic. Consumers now have a higher expectation for their own health and well being, and expect establishments they visit to meet their needs and [doing so] while embracing heightened health and safety protocols.

FST: What steps should they be taking to identify and reduce potential health and safety risks?

Michael Sperber, UL Everclean
Michael Sperber, global business manager for UL Everclean

Sperber: Amidst new challenges, guidelines and expectations, restaurants continue to have the critical responsibility of offering sanitary eating spaces and food preparation practices that help prevent diners from getting foodborne illnesses. There are several ways that restaurants can do this including:

  1. Leveraging technology to support food safety best practices.
    • Hand washing monitors help guide employees in proper handwashing techniques.
    • Internet of Things (IoT) temperature devices can monitor hot and cold food holding and service areas, instantly alerting managers when temperatures fall outside an acceptable range.
    • Touchless technologies like digital displays in the back of the house reduce transmission risk from employees handling food.
  2. Auditing every location of one branded store can account for differences in employees and managers. Left unverified, the rigor of food safety practices may simply rest on the personal conviction of a single location manager, rendering it completely inconsistent across locations. It is critical that management audit each individual store for compliance with food safety best practices.
    iii. Having an emergency plan, and then training for and rehearsing the plan, can help with proper mitigation of the threats of potential contamination.

FST: Discuss the role of employee training in this process, and how organizations should move forward.

Sperber: Training employees in food safety and customer interaction is a vital step in protecting employees and guests from foodborne illnesses. Employees who recently started at a restaurant when it reopened might not be aware of the dangers of foodborne illnesses or basic food safety protocols.

As restaurants reopen, when more and more guests have safety at the top of their mind, they should completely reboot their food safety programs, beginning with basics of safe food handling and foodborne illness. Repetition is a good way to reinforce the importance of food safety, and it may be beneficial to provide multiple training videos, pose questions on food safety during the interview and training process and include food safety on periodic employee reviews. Infractions among employees should result in retraining. This level of repetition communicates the importance of the issue.

A focus on employee training will help lead to a culture of food safety where everyone from the corporate CEO to the manager and janitorial staff feels accountable and can understand the consequences of failure to follow proper protocols.

Angela Morgan, Aptar

Ask the Expert: Innovative Strategies for Mitigating Pathogen Risk in Minimally Processed Foods

Angela Morgan, Aptar

The COVID-19 pandemic has led to increased concern and awareness about health and safety across the spectrum. Though there is no evidence that the novel coronavirus can be transmitted through food, increased concern about food safety remains. Among other food items, outbreaks tied to various fresh and frozen produce are all too common, despite processors’ best efforts to mitigate risk of pathogen growth during harvesting and processing, including multiple intervention washes prior to product packaging.

Still, adverse issues have persisted, leaving the foodservice industry wondering what more can be done to make fresh produce safer. This is where material science innovations come into play. New technology can enable processors to continue to reduce pathogen growth after the package is sealed, providing a final intervention step to significantly reduce the risk of foodborne illness from minimally processed foods.

Q: How does material science technology work as a pathogen mitigation strategy for fresh produce?

Angela Morgan, Ph.D.: Innovations in material science technology have enabled a new class of polymer compounds that perform active functions within packaging material to protect products from environmental conditions that can adversely impact quality and safety. This is called active packaging technology.

My company, Aptar CSP Technologies, developed 3-Phase Activ-Polymer™ technology more than 25 years ago for use in the pharmaceuticals space. Now, this technology is being applied to provide food protection solutions, specifically for fresh and frozen produce, to help mitigate risk of foodborne illness outbreaks.

To understand how this technology works, you first need a basic grasp of 3-Phase Activ-Polymer™ technology. Essentially, this material science innovation has three parts: a base polymer that provides physical structure, an active particle or component that offers a protective function, such as absorbing liquids or emitting an antimicrobial agent, and a minority polymer or channeling agent that enables gas movement throughout the base polymer. This technology can be custom-formulated to accomplish a range of tasks, such as absorbing moisture, scavenging oxygen or volatile organic compounds (VOCs), emitting aromas or eliminating odors or, in the case of produce, dispersing an antimicrobial agent within a sealed package to mitigate pathogen growth.

The technology we are discussing here, InvisiShield™, is a specially-engineered antimicrobial delivery system that safely creates a controlled dosage of chlorine dioxide (ClO2) gas inside a sealed package to reduce pathogen growth – both bacterial and viral – while minimizing negative organoleptic properties. Extruded into a film, the technology is adhered to the lidding film of fresh produce immediately prior to sealing, providing a final intervention step that is currently lacking in today’s produce processing methods.

Once the package is sealed, the humidity inside the package triggers a controlled release of ClO2 into the environment surrounding the produce, reducing pathogens within a matter of hours and leaving no trace after treatment. Independent studies from researchers at NC State have validated the technology delivers approximately a 3 log or 99.9% reduction in pathogen growth with no negative impact to taste, appearance or texture. The technology has been shown to be effective on a range of bacteria and viruses such as pathogenic E. coli, Salmonella, Listeria monocytogenes, Human norovirus, Hepatitis A, Shigella, Campylobacter jejuni, Staphylococcus aureus, Yersinia enterocolitica, Vibrio vulnificus, Geotrichum candidum, Feline calicivirus, and Rotavirus.

Q: What are some of the benefits of adopting this technology?

Morgan: Aside from the obvious benefits of brand protection, keeping food safe for consumers, and reducing the likelihood of recalls due to foodborne pathogens, InvisiShield™ technology is an additional hurdle or mitigation step in a processor’s food safety plan or HACCP (Hazard Analysis Critical Control Point Plan). The HACCP is a management system endorsed by the FDA in which food safety is addressed through analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product. While currently voluntary for the produce industry, HACCP programs are also highly recommended across all food industries. Currently, to comply with food safety testing requirements, processors need to hold product for as long as three days to wait for testing results to assure the product is safe to distribute. However, the InvisiShield™ antimicrobial delivery system enables the processor to bypass those wait times, immediately distributing product upon packaging. This results in extended shelf life and reduced wastage, while also providing an additional intervention step to protect against all of the residual effects of having an outbreak such as negative impacts on brand image and the expense of recalls.

Currently, to comply with food safety testing requirements, processors need to hold product for as long as three days to wait for testing results to assure the product is safe to distribute. However, the InvisiShield™ antimicrobial delivery system enables the processor to bypass those wait times, immediately distributing product upon packaging because the final pathogen mitigation process occurs inside the sealed package during shipment.

About Angela Morgan, Ph.D

Angela Morgan, AptarAngela Morgan is Director of Business Development and Food Safety Solutions responsible for commercializing the portfolio of antimicrobial technologies at Aptar. She most recently worked at Sealed Air Corporation as the Director of America’s Legacy Food and Product Care Division, and previously worked at Turkey Hill Dairy and Campbell’s Soup Company. Morgan received her B.S and M.S. degrees in Food Science from Pennsylvania State University and her PhD. from Clemson University in Packaging Engineering. Finally, Morgan holds memberships in numerous professional and civic organizations and serves on the AIPIA advisory board.

Food Safety Consortium

FDA Focusing on Fostering Food Safety Culture, Truly Bending the Curve of Foodborne Illness

By Maria Fontanazza
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Food Safety Consortium

The past year has tested and stressed the food system, putting tremendous pressure on worker safety and supply chain resilience. Despite the challenges, the industry continued to work day in and day out to meet the needs of Americans. “Consumers could still go then and now to their favorite supermarket or online platform and have access to thousands of food SKUs that are available,” said Frank Yiannas, FDA deputy commissioner for food policy and response. “We have the people in the food and agriculture sector to thank, and that’s you.”

Last week Yiannas gave his third Food Safety Consortium keynote address as deputy commissioner, reflecting on the past year and recognizing the progress and the work ahead. “I appreciate the larger conversation that the Consortium facilitates on food safety.” The Spring program of the Food Safety Consortium Virtual Conference Series takes place every Thursday in May.

Since the Fall of 2020, FDA has made advances in several areas, all of which take steps to advance the agency’s New Era of Smarter Food Safety initiative. The goals set as part of the New Era aim to help the agency more efficiently and efficiently respond to outbreaks and contamination, and other food safety challenges. The intent is to go beyond creating food safety programs into fostering a culture of food safety and truly bending the curve of foodborne illness, said Yiannas. In September the FDA issued the proposed FSMA rule on food traceability with the intent on laying the groundwork for meaningful harmonization. Nearly 6200 comments were submitted to the docket on the Federal Register, and the agency held three public meetings about the proposed rule in the fall, hosting more than 1800 people virtually. Yiannas anticipates the final rule will be published in early 2022.

The pandemic has shown how enhanced traceability might have helped prevent supply chain disruptions during a public health emergency, and the FDA continues its efforts to establish greater transparency and traceability. It is supporting the development of low-cost traceability technology solutions that are accessible to companies of all sizes. The agency also continues to explore the role of predictive analytics via the use of artificial intelligence. It has moved its AI program involving imported seafood from proof of concept into the field. Based on the results, it is expected that AI will help the FDA better manage the ever-increasing amount of imported foods by targeting inspectional resources in a more informed manner.

Efforts to strengthen food safety culture within organizations include collaborating with partners, industry, academia and consumers to define food safety culture in a transparent way. The agency will also be developing and launching internal training modules for FDA inspectional staff to introduce them to important concepts such as behavioral sciences. “We want to make food safety culture part of the dialogue and part of the social norm,” said Yiannas.

The agency will also be proposing new agricultural water requirements, a move as a result of feedback that FDA received in response to the Produce Rule. “Produce safety is one of the last frontiers because of product being grown outside,” said Yiannas.

In addition, FDA continues to review and evaluate feedback from proposed lab accreditation rule. It is expected that the FDA will issue the final rule early next year.

“We just lived through a historic year and historic challenges. These have been the most difficult of times in my profession. We have been able to move forward nonetheless,” said Yiannas. “We’re going to get through this stronger and more resilient than ever.”

Food Safety Consortium

2020 FSC Episode 11 Preview: Supply Chain Management

By Food Safety Tech Staff
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Food Safety Consortium

This week’s episode of the 2020 Food Safety Consortium Virtual Conference Series will address how food companies can navigate supply chain complexities. The following are highlights for Thursday’s session:

  • Disruptions in the Supply Chain and the Government Response, with Brian Ravitch and Benjamin England, FDA Imports
  • Food Safety Risks and the Cold Supply Chain, with Jeremy Schneider, Controlant
  • A panel discussion on the Third-Party Certification Program, moderated by Trish Wester, AFSAP and featuring Doriliz De Leon and Clinton Priestly of FDA
  • TechTalk on How Restaurant Brands International has Digital Transformed Its Supply Chain to Ensure Food Safety, Quality & Consistency, with Jim Hardeman, CMX

The event begins at 12 pm ET on Thursday, November 19. Haven’t registered? Follow this link to the 2020 Food Safety Consortium Virtual Conference Series, which provides access to all the episodes featuring critical industry insights from leading subject matter experts! We look forward to your joining us virtually.

Food Safety Consortium

2020 FSC Episode 7 Preview: Food Fraud

By Food Safety Tech Staff
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Food Safety Consortium

This week’s episode of the 2020 Food Safety Consortium Virtual Conference Series will focus on food integrity from the perspective of issues surrounding food fraud. The following are some highlights:

  • Food Fraud Vulnerability Assessment and Mitigation Plan, with Steve Sklare, Food Safety Academy; Karen Everstine, Ph.D., Decernis; and Peter Begg, Glanbia Nutritionals
  • Food Fraud Case History: Glanbia Nutritionals, with Peter Begg, Glanbia Nutritionals
  • Public Standards—Protecting the Integrity of the Food Supply Chain, with Steven Gendel, Ph.D., Food Chemicals Codex
  • Monitoring and Predicting Food Safety and Fraud Risks in Challenging Times, with Giannis Stoitsis, Agroknow

The event begins at 12 pm ET. Haven’t registered? Follow this link to the 2020 Food Safety Consortium Virtual Conference Series, which provides access to 14 episodes of critical industry insights from leading subject matter experts! We look forward to your joining us virtually.

Chocolate

Chocolate and Big Data: The Recipe for Food Safety Is Changing

By Steven Sklare
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Chocolate

Almost everybody loves chocolate, an ancient, basic, almost universal and primal source of pleasure. “The story of chocolate beings with cocoa trees that grew wild in the tropical rainforests of the Amazon basin and other areas in Central and South America for thousands of years… Christopher Columbus is said to have brought the first cocoa beans back to Europe from his fourth visit to the New World” between 1502 and 1504.1

Unfortunately, the production of chocolate and chocolate products today is as complex as any other global food product with supply chains that reach from one end of the world to the other. The complexity of the supply chain and production, along with the universal demand for the finished product, exposes chocolate to increasing pressure from numerous hazards, both unintentional and intentional. For example, we know that more than 70% of cocoa production takes place in West African countries, particularly the Ivory Coast and Ghana. These regions are politically unstable, and production is frequently disrupted by fighting. While production has started to expand into more stable regions, it has not yet become diversified enough to normalize the supply. About 17% of production takes place in the Americas (primarily South America) and 9% from Asia and Oceania.2

In today’s world of global commerce these pressures are not unique to chocolate. Food quality and safety experts should be armed with tools and innovations that can help them examine specific hazards and fraud pertaining to chocolate and chocolate products. In fact, the global nature of the chocolate market, requires fast reflexes that protect brand integrity and dynamic quality processes supported by informed decisions. Digital tools have become a necessity when a fast interpretation of dynamic data is needed. If a food organization is going to effectively protect the public’s health, protect their brand and comply with various governmental regulations and non-governmental standards such as GFSI, horizon scanning, along with the use of food safety intelligent digital tools, needs to be incorporated into food company’s core FSQA program.

This article pulls information from a recent industry report about chocolate products that presents an examination of the specific hazards and fraud pertaining to chocolate and chocolate products along with ways to utilize this information.

Cocoa and chocolate products rely on high quality ingredients and raw materials, strict supplier partnership schemes and conformity to clearly defined quality and safety standards. During the past 10 years there have been a significant number of food safety incidents associated with chocolate products. The presence of Salmonella enterica, Listeria monocytogenes, allergens and foreign materials in cocoa/chocolate products have been reported on a global scale. Today, information on food safety incidents and potential risks is quickly and widely available by way of the internet. However, because the pertinent data is frequently siloed, food safety professionals are unable to take full advantage of it.

Top Emerging Hazards: Chocolate Products (2013-2018)

Publicly available data, from sources such as European Union RASFF, Australian Competition and Consumer Commission, UK Food Standards Agency, FDA, Food Standards Australia New Zealand (FSANZ), shows a significant increase in identified food safety incidents for cocoa/chocolate products from 2013 to 2018. For this same time period, the top emerging hazards that were identified for chocolate products were the following:

  • Allergens: 51.60%
  • Biological: 16.49%
  • Foreign bodies: 13.83%
  • Chemical: 7.45%
  • Fraud: 6.38%
  • Food additives & flavorings: 4.26%
  • Other hazards: 2.66%

By using such information to identify critical food safety protection trends, which we define to include food safety (unintentional adulteration) and food fraud (intentional adulteration, inclusive of authenticity/intentional misrepresentation) we can better construct our food protection systems to focus on the areas that present the greatest threats to public health, brand protection and compliance.

A Data Driven Approach

Monitoring Incoming Raw Materials
Assessment and identification of potential food protection issues, including food safety and fraud, at the stage of incoming raw materials is of vital importance for food manufacturers. Knowledge of the associated risks and vulnerabilities allows for timely actions and appropriate measures that may ultimately prevent an incident from occurring.

Specifically, the efficient utilization of global food safety and fraud information should allow for:

  • Identification of prevalent, increasing and/or emerging risks and vulnerabilities associated with raw materials
  • Comparative evaluation of the risk profile for different raw materials’ origins
  • Critical evaluation and risk-based selection of raw materials’ suppliers

A comprehensive risk assessment must start with the consideration of the identified food safety incidents of the raw material, which include the inherent characteristics of the raw material. Next, the origin-related risks must be taken into account and then the supplier-related risks must be examined. The full risk assessment is driven by the appropriate food safety data, its analysis and application of risk assessment scientific models on top of the data.

Using food safety intelligent digital tools to analyze almost 400 unique, chocolate product related food safety incidents around the globe provides us with important, useful insights about cocoa as a raw material, as a raw material from a specific origin and as a raw material being provided by specific suppliers. The graph below represents the results of the analysis illustrating the trend of incidents reported between 2002 and 2018. It can be observed that after a significant rise between 2009 and 2010, the number of incidents approximately doubled and remained at that level for the rest of the evaluated period (i.e., from 2010 to 2018), compared to the period from 2002 to 2005.

Cocoa incidents, FOODAKAI
Graph from Case Study: Chocolate Products: lessons learned from global food safety and fraud data and the guidance it can provide to the food industry,
an industry report from FOODAKAI. Used with permission.

By further analyzing the data stemming from the 400 food safety incidents and breaking them down into more defined hazards, for incoming raw materials, we can clearly see that chemical hazards represent the major hazard category for cocoa.

  • Chemical: 73.46%
  • Biological: 16.49%
  • Organoleptic aspects: 5.93%
  • Other Hazards: 4.38%
  • Fraud: 2.32%
  • Foreign bodies: 2.06%
  • Food additives and flavorings: .77%
  • Allergens: .52%
  • Food contact materials: .52%

Using the appropriate analytical tools, someone can drill down into the data and identify the specific incidents within the different hazard categories. For example, within the “chemical hazard” category specific hazards such as organophosphates, neonicotinoids, pyrethroids and organochlorines were identified.

Comparative Evaluation of Risk Profiles for Different Origins of Raw Materials
The main regions of origin for cocoa globally are Africa, Asia and South America. After collecting and analyzing all relevant data from recalls and border rejections and the frequency of pertinent incidents, we can accurately identify the top hazards for cocoa by region.

The top five specific hazards for the regions under discussion are listed in Table I.

Africa South America Asia
1 Organophosphate 2,4-dinitrophenol (DNP) 2,4-dinitrophenol (DNP)
2 Molds Pyrethroid Poor or insufficient controls
3 Neonicotinoid Aflatoxin Aflatoxin
4 Pyrethroid Cadmium Spoilage
5 Organochlorine Anilinopyrimidine Salmonella
Table I.  Top Five Hazards By Region

After the first level of analysis, a further interpretation of the data using the appropriate data intelligence tools can help to reach to very specific information on the nature of the incidents. This provides additional detail that is helpful in understanding how the regional risk profiles compare. For example, the prevalence of chemical contamination, as either industrial contaminants or pesticides, has been a commonly observed pattern for all three of the regions in Table I. However, beyond the general hazard category level, there are also different trends with regard to specific hazards for the three different regions. One such example is the increased presence of mold in cocoa beans coming from Africa.

The primary hazard categories for cocoa, as a raw ingredient were identified and a comparison among the primary hazards for cocoa by region (origin-specific) should take place. The next step in a data-powered supplier assessment workflow would be to incorporate our use of global food safety data in evaluating the suppliers of the raw materials.

The Role of Global Food Safety Data

This article has been focused on chocolate products but has only touched the surface in terms of the information available in the complete report, which also includes specific information about key raw materials. Let’s also be clear, that the techniques and tools used to generate this information are applicable to all food products and ingredients. As we strive to produce food safely in the 21st Century and beyond, we must adapt our methods or be left behind.

The regulatory environment the food industry must operate in has never been more intense. The threats to an organization’s brand have never been greater. This is not going to change. What must change is the way in which food companies confront these challenges.

Global food safety data can contribute to the establishment of an adaptive food safety/QA process that will provide time savings and improve a quality team’s efficiency and performance.

Based on the continuous analysis of food recalls and rejections by key national and international food authorities, a food safety / quality assurance manager could establish an adaptive supplier verification process and risk assessment process by utilizing the knowledge provided by such data. In that way, QA, procurement, food safety and quality departments can be empowered with critical supplier data that will inform the internal procedures for incoming materials and ingredients (e.g., raw materials, packaging materials) and allow for adaptive laboratory testing routines and compliance protocols. Moreover, food safety systems can become adaptive, enabling quality assurance and safety professionals to quickly update points of critical control when needed, and intervene in important stages of the chocolate manufacturing process.

References

  1. Discovering Chocolate. The Great Chocolate Discovery. Cadbury website. Retrieved from https://www.cadbury.com.au/About-Chocolate/Discovering-Chocolate.aspx.
  2. Chocolate Industry Analysis 2020 – Cost & Trends. Retrieved from https://www.franchisehelp.com/industry-reports/chocolate-industry-analysis-2020-cost-trends/.
FST Soapbox

How SQF Certification Can Be a Contract Manufacturer’s Greatest Advantage

By Steve Wise
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SQF certification validates a contract manufacturer’s ability to produce safe, consistent, and high-quality products. It’s a mark of distinction, which can lead to more business. But to obtain SQF certification, a manufacturer must have effective quality and safety controls.

Well-known food and beverage brands will often turn to contract manufacturers to produce the quality products that their customers expect and enjoy. With their brand names on the line, these brand owners need assurance that their suppliers can deliver safe and high-quality goods and mitigate the looming threat of recalls.

How do they know if they’re working with a reliable contract manufacturer? Well, many will look to see if they hold certifications from a reputable third-party organization, such as the Safe Quality Food Institute (SQFI). In fact, one in four companies today require that their suppliers have SQF certification, making it one of the most important certifications in contract manufacturing.

SQF certification demonstrates that a supplier has met benchmarked standards—set by the Global Food Safety Initiative (GFSI)—for upholding quality and controlling food safety risks. It’s a form of validation of an organization’s ability to consistently produce safe and high-quality products. Contract manufacturers that have SQF certification are more likely to win contracts and can bid for business on a national or global scale. Thus, it presents a clear competitive advantage to those certified in the various levels of SQF certification.

Certification Tiers
SQF is a three-level certification program, with each tier progressively more rigorous than the last.

  • Level 1: The SQF Safety Fundamentals Program is an introduction to food safety standards for small- to medium-sized food suppliers. Ideal for those with low-risk food products, the program doesn’t meet GFSI standards but establishes a foundation for doing so. Suppliers certified at this level typically sell their services to smaller, local purveyors.
  • Level 2: The SQF Food Safety Program follows GFSI-benchmarked food safety standards. It helps sites implement preventive food safety measures according to Hazard Analysis and Critical Control Points (HACCP) regulations, which ensure scientific analysis of microbiological, physical and chemical hazards are applied at each step of the supply chain. This level is ideal for businesses that would like to work with purveyors that require adherence to GFSI benchmarked standards.
  • Level 3: The SQF Food Safety and Quality Program shows an ability to not only contain safety risks through the HACCP system, but also monitor and control threats related to food quality. This highest level of certification is ideal for large-scale producers, manufacturers, food packaging facilities and distributors that have successfully deployed an SQF Food Safety Program and want to go above and beyond in their quality efforts.

While it’s the most demanding of the three, Level 3 certification is what most contract manufacturers should aspire to because it’s required by many of the world’s largest food and beverage brands. In order to attain this level of distinction, contract manufacturers need an effective way to demonstrably meet all GFSI benchmarked standards and readily access their quality data during an audit. This is where statistical process control (SPC) comes in.

The SPC Gamechanger

SPC is a proven methodology for monitoring and controlling quality during the manufacturing process. SPC enables manufacturers to chart real-time quality data against predefined control limits to identify unwanted trends and product or process variations. If there is an issue, timely alerts will notify responsible parties to take remedial action early on, preventing unsafe or poor-quality goods from entering the supply chain and triggering a recall. This establishes strong controls for food quality and safety in accordance with a Level 3 SQF Program. Audits also become a breeze, as all historical data are stored digitally in a centralized repository. Suppliers can thereby quickly and easily produce auditor-requested reports showing compliance with SQF requirements and GFSI standards.

Statistical process control, InfinityQS
Statistical process control (SPC) is a method for monitoring and controlling quality during the manufacturing process. Image courtesy of InfinityQS

But beyond quality monitoring and facilitating audits, SPC can deliver greater impact by providing suppliers with analytical tools useful for mining historical data for actionable insights. They can run comparative analyses of the performance of different lines, products, processes, or even sites, revealing where and how to further reduce risk, improve consistency, streamline operations, and lower production costs. In this way, SPC lends itself to a profit-positive business model—driving additional savings through process improvement while increasing new business opportunities through contracts won via SQF certification.

A Snacking Success

One contract manufacturer of savory and healthy snacks previously struggled with large variations in product quality. These inconsistencies often resulted in quality holds or process aborts that generated high waste and costs. By implementing SPC, the snack supplier was able to take advantage of a wide range of data—including incoming receiving tracking and quality inspection tracking—to finetune its production processes with effective controls for food quality and safety. In addition to a 30% reduction in customer complaints, SPC has helped the supplier realize a $1 million reduction in product waste and attain Level 3 SQF certification, the latter of which has generated continued new business from several well-known snack food brands.

This snack supplier is a clear example of SQF certification as a competitive differentiator. Working with such SQF-certified and SPC-powered contractors is important to food and beverage brands because they can protect their reputations and ensure continued customer retention by way of safe, consistent, high-quality products. Ultimately, it builds greater trust and integrity in the supply chain among companies and consumers alike.

Allison Kopf, Artemis

How Technologies for Cultivation Management Help Growers Avoid Food Safety Issues

By Maria Fontanazza
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Allison Kopf, Artemis

Visibility, accountability and traceability are paramount in the agriculture industry, says Allison Kopf, founder and CEO of Artemis. In a Q&A with Food Safety Tech, Kopf explains how growers can take advantage of cultivation management platforms to better arm them with the tools they need to help prevent food safety issues within their operations and maintain compliance.

Food Safety Tech: What are the key challenges and risks that growers face in managing their operations?

Allison Kopf: One of the easiest challenges for growers to overcome is how they collect and utilize data. I’ve spent my entire career in agriculture, and it’s been painful to watch operations track all of their farm data on clipboards and spreadsheets. By not digitizing processes, growers become bogged down by the process of logging information and sifting through old notebooks for usable insights—if they even choose to do that.

Allison Kopf, Artemis
Allison Kopf is the founder and CEO of Artemis, a cultivation management platform serving the fruit, vegetable, floriculture, cannabis, and hemp industries. She is also is an investment partner at XFactor Ventures and serves on the boards of Cornell University’s Controlled Environment Agriculture program and Santa Clara University’s College of Arts and Sciences.

I was visiting a farm the other day and the grower pulled out a big binder. The binder contained all of his standard operating procedures and growing specifications for the varieties he’s grown over the past 20 years. Then he pulled out a pile of black notebooks. If you’ve ever worked on a farm, you’d recognize grower notebooks anywhere. They’re used to log data points such as yield, quality and notes on production. These notebooks sit in filing cabinets with the hopeful promise of becoming useful at some point in the future—to stop production from falling into the same pitfalls or to mirror successful outcomes. However, in reality, the notebooks never see the light of day again. The grower talked about the pain of this process—when he goes on vacation, no one can fill his shoes; when he retires, so does the information in his head; when auditors come in, they’ll have to duplicate work to create proper documentation; and worse, it’s impossible to determine what resources are needed proactively based on anything other than gut. Here’s the bigger issue: All of the solutions are there; they’re just filed away in notebooks sitting in the filing cabinet.

Labor is the number one expense for commercial growing operations. Unless you’re a data analyst and don’t have the full-time responsibilities of managing a complex growing operation, spreadsheets and notebooks won’t give you the details needed to figure out when and where you’re over- or under-staffing. Guessing labor needs day-to-day is horribly inefficient and expensive.

Another challenge is managing food safety and compliance. Food contamination remains a huge issue within the agriculture industry. E. coli, Listeria and other outbreaks (usually linked to leafy greens, berries and other specialty crops) happen regularly. If crops are not tracked, it can take months to follow the contamination up the chain to its source. Once identified, growers might have to destroy entire batches of crops rather than the specific culprit if they don’t have appropriate tracking methods in place. This is a time-consuming and expensive waste.

Existing solutions that growers use like ERPs are great for tracking payroll, billing, inventory, logistics, etc., but the downside is that they’re expensive, difficult to implement, and most importantly aren’t specific to the agriculture industry. The result is that growers can manage some data digitally, but not everything, and certainly not in one place. This is where a cultivation management platform (CMP) comes into play.

FST: How are technologies helping address these issues?

Kopf: More and more solutions are coming online to enable commercial growers to detect, prevent and trace food safety issues, and stay compliant with regulations. The key is making sure growers are not just tracking data but also ensuring the data becomes accessible and functional. A CMP can offer growers what ERPs and other farm management software can’t: Detailed and complete visibility of operations, labor accountability and crop traceability.

A CMP enables better product safety by keeping crop data easily traceable across the supply chain. Rather than having to destroy entire batches in the event of contamination, growers can simply trace it to the source and pinpoint the problem. A CMP greatly decreases the time it takes to log food safety data, which also helps growers’ bottom line.

CMPs also help growers manage regulatory compliance. This is true within the food industry as well as the cannabis industry. Regulations surrounding legal pesticides are changing all the time. It’s difficult keeping up with constantly shifting regulatory environment. In cannabis this is especially true. By keeping crops easily traceable, growers can seamlessly manage standard operating procedures across the operation (GAP, HACCP, SQF, FSMA, etc.) and streamline audits of all their permits, licenses, records and logs, which can be digitized and organized in one place.

FST: Where is the future headed regarding the use of technology that generates actionable data for growers? How is this changing the game in sustainability?

Kopf: Technology such as artificial intelligence and the internet of things are changing just about every industry. This is true of agriculture as well. Some of these changes are already happening: Farmers use autonomous tractors, drones to monitor crops, and AI to optimize water usage.

As the agriculture industry becomes more connected, the more growers will be able to access meaningful and actionable information. Plugging into this data will be the key for growers who want to stay profitable. These technologies will give them up-to-the-second information about the health of their crops, but will also drive their pest, labor, and risk & compliance management strategies, all of which affect food safety.

When growers optimize their operations and production for profitability, naturally they are able to optimize for sustainability as well. More gain from fewer resources. It costs its customers less money, time and hassle to run their farms and it costs the planet less of its resources.

Technology innovation, including CMPs, enable cultivation that will provide food for a growing population despite decreasing resources. Technology that works both with outdoor and greenhouse growing operations will help fight food scarcity by keeping crops growing in areas where they might not be able to grow naturally. It also keeps production efficient, driving productivity as higher yields will be necessary.

Beyond scarcity, traceability capabilities enforce food security which is arguable the largest public health concern across the agricultural supply chain. More than 3,000 people die every year due to foodborne illness. By making a safer, traceable supply chain, new technology that enables growers to leverage their data will protect human life.

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part I)

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

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

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

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

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

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

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

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

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

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

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