Tag Archives: Supply Chain

October 23, 2015

Using Data to Ensure Food Chain Security

By Maria Fontanazza

Moving forward, if food manufacturers, suppliers and distributors want to be ahead of the game, they’ll need to have the ability to view their product throughout the supply chain. During a discussion with Food Safety Tech, Trish Meek, director of product strategy at Thermo Fisher Scientific, explains the importance of product traceability in the food chain, from both a consumer and food producer’s perspective.

Food Safety Tech: In your recent article about Integrated Informatics, you cite it as an ideal solution to modernizing a highly distributed food chain. What are the challenges you see companies facing in managing their global supply chain?

Trish Meek: We’ve seen the issues related to intentional adulteration documented throughout the media, and they extend to traceability. For example, what Tesco experienced during the horsemeat scandal wasn’t necessarily intentional adulteration, but rather a matter of not understanding the supply chain. Horsemeat was introduced in France as legitimate meat and then it ended up in the UK. In this case, you have a lack of traceability and thus a lack of understanding of what has happened to your product in its lifecycle.

Trish Meek, Thermo Fisher Scientific — “With consumer demand for foods that are free of gluten, GMOs and antibiotics, it’s becoming more important to customers that they understand everything that has happened to the animal and the food source.” –Trish Meek

In this complex world of suppliers, distributors and food producers, having the ability to pull in analytical data and manage it regardless of the source (whether it’s from the initial ingredient supplier or the final manufacturer) is a critical piece in understanding the overall lifecycle picture. An integrated informatics solution provides a single source of truth for that information: From the technician operating the lab process to the lab manager who is overseeing to the integration into the enterprise-level system. It provides a complete view on everything that has happened to your data, while also enabling the management of regional specifications.

FST: What are the biggest concerns in the area of food chain security?

Meek: Traceability is key, and the common denominator is food chain security: Ensuring that you’re providing security and with an understanding of everything that happened to your product, which leads to quality assurance and brand security.

FST: What are the concerns related to food chain security?

Meek: There are a few concerns:

Adulteration
Correct label claims. For example, 30% of the populous is trying to avoid gluten. While 1% is truly allergic to it, there’s a lot of gluten intolerance. Take, for example, recent commercials from Cheerios saying they are ensuring traceability and can say with confidence that their product no longer comes into contact with wheat in any part of the process. There’s an understanding that consumers want to believe what’s on the label, from both a health and allergy perspective as well as a concern in the public around unhealthy ingredients added or antibiotics used. As a food producer, you want to make sure you can honestly state what has happened to the food and that what you’ve put on your label is true. People are willing to pay a premium, and so there’s a drive towards the premium of being able to claim no GMOs on a label or an organic product.
From a food producer’s point of view, having traceability from all suppliers is key. They want to ensure that any raw materials have been handled and managed with all the same scrutiny and adherence to regulatory requirements as their own processes. With ingredients coming from all over the world, manufacturers are relying on multi-sourcing ingredients from places they don’t necessarily control, so they need to have the traceability before the ingredients appear in the final product.

Using an Integrated Informatics Platform

Trish Meek: Through an integrated informatics platform, users can manage the entire lab process and integrate it into the enterprise system. Having the ability to incorporate the lab data is critical to ensuring product safety, quality and traceability throughout the entire supply chain. Because the solution encompasses lab processes and required lab functionalities, it enables efficiency both in the laboratory as well as across the entire operation. The solution provides an opportunity not just to the top-tier food producers but also the regionally based middle-tier companies that want to set themselves up for future growth.

The reality of the regulations today is that you must look towards the future. Twenty years ago, we weren’t including information about what nuts were present in the labeling. Now there’s consumer awareness and a change in labeling. And five years from now, there could be a different allergy that needs to be documented in the labeling. Integrated informatics gives you the business agility to take on that next step of analysis and adapt to the marketplace.

Dr. David Acheson is the Founder and CEO of The Acheson Group

October 16, 2015

Beltway Beat

Get Ready to Align Your Supplier Program with New FSMA Rules

By Dr. David Acheson

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FSMA’s preventive controls rule mandates a supply-chain program to “provide assurance that a hazard requiring a supply-chain-applied control has been significantly minimized or prevented.” The rule defines a supply-chain-applied control as “a preventive control for a hazard in a raw material or other ingredient when the hazard in the raw material or other ingredient is controlled before its receipt.”

FDA made a few general updates in the final rule, including changing “supplier program” to “supply-chain program”, and it designated a subpart G with eight sections of regulatory text. Intended to improve clarity and readability, the language reflects its applicability to non-suppliers in a new requirement – that is, a supply-chain control can be applied and/or verified by a non-supplier (e.g., distributor, broker, aggregator). However, the receiving facility must verify the supply-chain-applied control itself or obtain documentation of the verification activity, review and assess the documentation, and document that review and assessment.

There are different compliance dates for the supply-chain program versus the entire rule, aligning compliance with the dates of FSVP rule and providing greater consistency. This also addresses comment concerns that a receiving facility would be required to comply with the supply-chain program provisions before its supplier must comply with applicable new FSMA food safety regulations.

Does your current program comply with the new rules? If not, how can you bring it in line?

The Supply Chain Program

The rule requires a supply chain program when the receiving facility has identified, through its hazard analysis, that there is a hazard requiring a supply-chain-applied control. The program should address hazards requiring a preventive control that may be intentionally introduced for purposes of economic gain, as well as those unintentionally introduced.

FDA specifies the basic content of a supply-chain program, but allows for some flexibility. The rule mandates that the supply-chain program include:

Written procedures for receiving raw materials and other ingredients
Preventive control management components that include corrective actions and corrections, review of records and reanalysis
Supplier approval and use of only approved suppliers, but FDA is considering the issuance of guidance for temporary use of unapproved suppliers
Determining appropriate supplier verification activities
Conducting supplier verification activities
Documenting supplier verification activities:
- Onsite audits
- Sampling and testing of the raw material or ingredient (by the supplier or receiving facility)
- Receiving facility review of the supplier’s relevant food safety records
- Other appropriate supplier verification activities based on the risk associated with supplier performance and the raw material or other ingredient

In supplier approval and determination of supplier verification activities, the receiving facility must consider:

The hazard analysis, including the nature of the hazard, applicable to the raw material and ingredients
Where the preventive controls for hazards are applied
The supplier’s procedures, processes and practices related to the safety of the raw material and ingredients
Applicable FDA food safety regulations and the supplier’s compliance with them
The supplier’s food safety performance history relevant to the applicable raw materials, including results from testing for hazards, food-safety audit results and corrective action.
Any other relevant factors, such as storage and transportation practices

Other key points of the rule:

There must not be any financial conflicts of interests that influence the results of the verification activities. Payment must not be related to results
Domestic inspection by representatives of other federal agencies or by representatives of state, local, tribal, or territorial agencies may substitute for an audit
The definition of “supplier” has been revised so that the grower remains the supplier when the harvester is under separate management. The “supplier” is the establishment that “grows” food rather than that which “harvests” food.
Foreign suppliers may provide documentation, when applicable, of a written assurance that the supplier is producing the raw material or other ingredient in compliance with relevant laws and regulations of a country whose food safety system FDA has officially recognized as comparable or has determined to be equivalent to that of the United States
The provisions for supplier verification in the FSVP rule have been aligned with the provisions for a supply-chain program, so importers and receiving facilities can consider compliance with both the supplier-chain-program rule and the forthcoming FSVP regulations, as to avoid duplication of verification activities
If the receiving facility is an importer in compliance with the FSVP requirements and has documentation of verification activities under FSVP, a supply-chain program is not required even if the receiving facility’s hazard analysis determines that a supply-chain-applied control is required

Robin Stombler, Auburn Health Strategies

October 13, 2015

In the Food Lab

Five Questions Food Facilities Should Ask About Testing

By Robin Stombler

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The FDA issued the first of several final regulations aimed at modernizing the food safety system through the use of hazard analysis and risk-based preventive controls. Inherent in this system are a number of requirements that eligible food facilities must follow, such as developing a written food safety plan, monitoring, corrective actions and verification. Laboratory testing is an essential component as well.

Robin Stombler presented “Laboratory Oversight and FSMA: Why and When” at the Food Labs Conference in Atlanta, GA | March 7–8, 2016So, what should food facilities know about laboratory testing within the context of the preventive controls for human food final rule? First and foremost, the final rule states, “facilities have a responsibility to choose testing laboratories that will produce reliable and accurate test results.” While a future regulation is expected to address the need for accredited laboratories and model laboratory standards, the preventive controls rule adopts other requirements pertaining to testing. Here are five questions that food facilities should ask about testing and the preventive controls rule.

1. What is the difference between pathogens and microorganisms?

The final rule defines “pathogen” to mean a microorganism that is of public health significance. A microorganism is defined as “yeasts, molds, bacteria, viruses, protozoa and microscopic parasites, and includes species that are pathogens.” Microorganisms that are of public health significance and subject food to decomposition or indicate that the food is adulterated or is contaminated with filth are considered “undesirable.”

2. How must food facilities account for pathogens?

Food facilities must prepare and implement a written food safety plan. One component of the food safety plan must include a written hazard analysis. This analysis must identify known or reasonably foreseeable hazards. These hazards may be biological, which includes parasites, environmental pathogens and other pathogens.

In another example, the food safety plan must include written verification procedures. This is to demonstrate that the facility is verifying that its preventive controls are implemented consistently and are significantly minimizing or preventing the hazards. These verification procedures are intended to be appropriate to the particular food facility, the food in question, and the nature of the preventive control and its role within the facility’s food safety system. With this in mind, facilities must conduct activities such as product testing for a pathogen or an appropriate indicator organism or other hazard, and environmental monitoring.

3. Are there written procedures specific to product testing?

Yes. Procedures for product testing must be scientifically valid and must identify the test microorganisms or other analytes. The procedures for identifying samples, including their relationship to specific lots of products, must be written and implemented. The procedures for sampling, including the number of samples and the sampling frequency, must be outlined. The facility must recognize the laboratory conducting the testing as well as describe the tests that are performed and the analytical methods used. Corrective action steps must also be included.

4. What are the procedures for environmental monitoring?

Similar to product testing, these procedures must be scientifically valid, identify the test microorganisms, and be put in writing. For routine environmental monitoring, the location from which the samples are collected and the number of sites that are tested must be stated. The final rule indicates that the “number and location of sampling sites must be adequate to determine whether preventive controls are effective.” Written procedures must also identify the timing and frequency for collecting and testing samples. Again, similar to product testing, the laboratory conducting the testing and the tests and analytical methods used must be divulged. Corrective action procedures must also be included.

5. How does the supply-chain program incorporate testing?

A receiving facility is required to document a written supply chain program in its records. A component of that program includes documentation of sampling and testing performed as a supplier verification activity. The documentation must include identification of the raw material or other ingredient (including, if appropriate, lot number) and the number of samples tested. It also means that the tests conducted and the analytical methods used must be identified. The date the test is conducted as well as the date of the test report must be provided, and the identity of the laboratory performing the testing must be revealed. Any corrective actions that were taken in response to a hazard detection must also be reported.

This Q&A provides a glimpse into how the preventive controls final rule for human food incorporates laboratory testing. For more details, access the final rule.

October 12, 2015

FST Soapbox

Risk in Our Supply Chain: Where Do We Start?

By Traci Slowinski

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FSMA has arrived with the launch of the first two preventive control rules – Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Human and Animal Food (or cGMP and HARPC, for short). With these new FSMA rules, the food and beverage industry will now be held accountable for being more proactive versus reactive, and will be responsible for identifying and managing risk throughout their supply chain. Of course, this emphasis on risk can also be seen in other sectors of the industry (i.e., GFSI and ISO), and risk has become the focal point for a number of compliance initiatives.

Supply chain challenges in food safety (Click to enlarge)

These days a number of supply chain challenges are driving risk. Continued global expansion of the industry is resulting in more import and export activities. We are seeing consumer food trends shift toward riskier food/preparation options. Regulatory agencies continue to work on improving their food safety requirements. And the growing population is putting more demands on our current resources. All of these factors equates to great risk within all stages of the supply chain.

Therefore, it will be important that you understand what risk management entails and have the right tools to identify, assess and control the risks that you find throughout your supply chain.

So where do we start looking for risk? Here are a few examples of where your risk assessments should be performed:

External Partners. You need to build strategic relationships with your external partners (suppliers, contract manufacturers/co-packers, service providers, carriers, etc.) across the supply chain. Building trust through good communication and collaboration is essential to ensure that you can rely on your partners to do the right thing for both parties.

Raw Materials. Many hazards can be introduced into a facility through raw materials—whether we are talking about raw ingredients, packaging materials, chemicals, or other components used to produce your product. Some hazards to assess include pathogens, allergens, chemical residues, pests and foreign material.

Storage and Handling. When looking at risk during storage and handling, it is important to address several hazards including allergen control, temperature control, foreign material control, proper segregation and product flow.

Processing. A number of areas in processing can introduce hazards and therefore should be included in your risk assessment. These include improper sanitation, cross contamination/contact potential, foreign material contamination, critical control point deviations, pre-requisite program failures and mislabeling.

Shipping and Transport. Lastly, you must safeguard your shipping and transportation procedures in order to account for any potential risk once the product has left your facility. Areas to consider during your risk assessment include temperature control, condition and sanitation of truck and storage units, loading/unloading practices, security/tampering potential, accident/emergency recovery, and traceability.

For more information on risk management within the food and beverage supply chain, register to attend the free webinar “Supply Chain Management: Does What I Eat Put Me at Risk” on October 28, 2015. Speakers will discuss risk throughout the supply chain, focusing on supplier management and some of the new FSMA requirements. They will provide an overview of risk management and some of the tools that can be used to identify and assess risk. In addition, they will discuss how technology can help companies meet FSMA requirements.

Traceability in food manufacturing, Honeywell

October 1, 2015

Traceability Not a Trend. It’s a Reality.

By Maria Fontanazza

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Businesses throughout the food supply chain are using a variety of traceability tools to capture critical information during the path from the field to the consumer. Traceability has always been viewed as an important capability within the supply chain, but FSMA, coupled with retailer and consumer demand, is pushing it to the highest levels yet.

Technology solutions that provide continuous identification and verification include mobile computers, scanners, RFID and mobile printers. While growers, packers, wholesalers, distribution centers and retailers involved in the fresh produce, poultry, meat, and seafood segments are using these technologies, speculation continues about adequate adoption levels.

The larger food providers are embracing track and trace technologies, while smaller business have been much slower to adopt, according to Bruce Stubbs, director of industry marketing at Honeywell Sensing & Productivity Solutions. “It’s going to be difficult to convince the smaller growers to invest in the technology—a lot of them see it as a cost,” he says. “What’s helping is that the retailers are starting to push back and say they are going to require their suppliers to be compliant with [traceability] mandates and if not, they won’t do business with them.”

Out in the field, companies are leveraging scanning and printing technologies, including smart printing technology (essentially a PC with printing capability). The printer hosts data capture and traceability software, providing the tasks and traceability through the software to the scanning devices. It can capture and print the food traceability label, which contains the discreet information, at the point of harvest. At the transportation level, businesses are using mobile computers to scan and capture product information that tracks down to the details from what part of a field, or even which tree in an orchard, a product has been harvested. Traceability technologies are including sensors throughout the cold chain to monitor temperature and humidity as the product is transported from point A to B. All information moves forward into the production facility and the retailer’s distribution center. Once at the retail store level, grocers will be able to pinpoint, within potentially thousands of stores, the specific batches and lots, a key capability in the instance of product issues and recalls.

Traceability is a holistic process, and the potential for its continued growth within the food industry is high. “I see it becoming more prevalent as consumers demand it, and retailers and manufacturers must adapt. I also see them moving away from paper,” says Stubbs. “We’re close; it’s almost like there’s a trickle in the dam right now, but I really believe that over the next couple years, the dam will break and most [companies] will need to adopt [traceability solutions] or they won’t be able to effectively do business with a lot of the food retailers.”

Stubbs also anticipates an increased adoption of 2-D barcodes versus 1-D linear laser barcodes, as 2-D barcodes can contain far more information. “We are at the tip of those technologies—they exist. It’s just the integration of these systems and providing the information in a format at the supplier or food manufacturer level,” he says.

How is your company implementing traceability solutions? What challenges and benefits are occurring as a result?

September 10, 2015

FSMA Rules for Preventive Controls Finalized

By Maria Fontanazza

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More than a week after being submitted to the Federal Register, the rules for preventive controls for human food and animal feed have been finalized.

The Current Good Manufacturing Practice Hazard Analysis and Risk Based Preventive Controls for Human Food final rule includes the following key requirements:

Covered facilities must establish and implement a food safety system with a written food safety plan that includes hazard analysis, preventive controls, and the oversight and management of preventive controls (this encompasses monitoring, corrective actions and verification).
The “farm” definition has been clarified to include two types of farm operations, primary production farm and secondary activities farm. Such farms that conduct produce activities will also have to comply with the Produce Safety Rule (to be finalized at the end of October).
A more flexible supply chain program, with separate compliance dates.
Update and clarification to CGMPs.

This year’s Food Safety Consortium conference will feature first-hand perspectives from FDA and USDA on FSMA implementation and enforcement. REGISTER NOWCompliance dates range between one and three years depending on the size and type of business. Several guidance documents will be created by FDA in an effort to further help companies with compliance, including on hazard analysis and preventive controls, environmental monitoring, food allergen controls, and the validation of process controls.

The Federal Register will publish the 930-page document on September 17. In the meantime, the pre-publication version can be viewed here.

The Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls for Food for Animals final rule includes the below key requirements:

CGMPs established for the production of animal food, taking into account the diverse types of animal food facilities.
Covered facilities must establish and implement a food safety system with a written food safety plan that includes hazard analysis, preventive controls, the oversight and management of preventive controls (this encompasses monitoring, corrective actions and verification), and a recall plan.
A more flexible supply chain program, with separate compliance dates.
The “farm” definition has been clarified to include two types of farm operations, primary production farm and secondary activities farm.
Feed mills associated with farms (vertically integrated operations) are not covered.

As with the preventive controls for human food, FDA will be creating guidance documents that address CGMP requirements, hazard analysis and preventive controls, human food by-products for use as animal food, and a small-entity compliance guide.

The Federal Register will also publish this 666-page document on September 17. The pre-publication version can be viewed here.

At this year’s Food Safety Consortium Conference, the industry will have the opportunity to hear directly from FDA and USDA on what companies need to know to be FSMA compliant and how the agency will be enforcing the regulation. Michael Taylor, JD, deputy commissioner for foods and veterinary medicine at FDA, will delivery the opening plenary presentation, which will be followed by an “Ask the FDA” Q&A town hall meeting.

August 28, 2015

FST Soapbox

How to Button Up Your Supply Chain

By Randy Fields

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Donald Bowersox, a long-time business professor at Michigan State University and one of the progenitors of modern supply chain management, once said, “The job of supply chain is clearly a senior management challenge, and it’s one that sits right alongside the other C-level jobs in the corporation. We may call it something different going forward, but basically it will remain the stewardship of moving products from the material origin points all the way through the process of conversion to the end consumers efficiently, effectively, and relevantly. That challenge is a big one and will continue to be for a long time. So I don’t see a next organizational evolution. Instead, I see the supply chain manager becoming more deeply involved in the corporate strategic initiatives and being part of the C-team management.”

Applying this approach to food safety in the supply chain has become more critical during the last few years as a result of regulatory, market and consumer pressures. At the start of this century, only 15 years ago, the food safety director rarely, if ever, interacted with the CEO. Many retailers didn’t even have such a position, or it was combined with quality control or loss prevention.

Now, not only does the top food safety manager have the ear of the CEO, he or she is engaged with all senior executives. Part of this is the result of the Food Safety Modernization Act, which holds those officers personally liable for a wide variety of preventable incidents. Likely bigger causes for the shift are the changing market and the changing consumer, which both relate directly to the company’s brand reputation. And in the food business, everything starts and stops with the supply chain.

Why? Because the supply chain is ground zero for the failures that are responsible for causing food safety problems. And the supply chain is where food safety problems are prevented. It is the choke point or series of choke points that allow or prevent spoiled and tainted product from getting to the consumer. It is also the process by which that unsaleable product is reclaimed so as to ensure it never enters the marketplace.

It is critical for the food safety manager to work closely with the merchandisers and the store operations teams, as they have the relationships with suppliers and work to ensure that standards for everything from ingredients to production are met with every shipment. But it’s even more critical for those professionals to work closely with the supply chain team to determine weak links in the system and address those pressure points before they cause real damage. Without food safety-supply chain collaboration, the risks to a company’s reputation multiply. With it, the likelihood of a food safety incident reaching consumers diminishes tremendously.

It’s becoming clearer every day—if you don’t button up your supply chain, somebody else, namely the government or the consumer, will and the results won’t be pleasant.

Cristin Singer, assurance partner at McGladrey LLP

July 1, 2015

Security Risks, Protecting Reputation Among Concerns of Food & Beverage Companies

By Maria Fontanazza

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In a recent survey of food and beverage executives, nearly half of respondents named product quality as a major risk area and cited product recall capabilities as a priority. However, only about one-third of executives expressed confidence in their companies’ current safety and recall strategies.

“Mitigating [product] risks starts with tone at the top and leadership within a company,” says Cristin Singer, assurance partner with McGladrey, LLP. “Companies have a strong focus on the diligence associated with quality (especially among employees involved in testing) and building long-standing, trusted relationships with suppliers and vendors.” Many companies are also increasing their testing of imported products and making sure that their partners are familiar with the cultures of the regions from which they import goods as part of their risk mitigation strategy.

The Food and Beverage Industry survey, conducted by McGladrey, involved 179 executives, owners, and decision makers from food and beverage companies with annual revenues between $10 million and $1 billion.

Respondents consisted of retailers (51.1%), manufacturers and processors (34.8%), distributors (26.4%) and growers (6.7%). Figure courtesy of McGladrey.

Product Recalls. Some companies are basing their product recall strategy on where they actually fall within the supply chain. “I’ve found that when a company feels that they serve as a middle-man distributor, and depending on the contractual relationship with the co-packer, they look to the processor or co-packer to manage the recall process,” says Singer, who is also a member of McGladrey’s national consumer products team. In addition, Singer sees a focus on due diligence related to co-packers and suppliers to ensure they have proper certification, and processes and procedures in place to manage risks and recalls.

Wage and Labor. Food and beverage companies are also facing a variety of wage and labor issues. Larger companies expressed concern with increased labor costs and attracting technical talent; smaller companies are more worried about minimum wage legislation labor costs, and retaining skilled labor workers on the shop floor. Executives also cited that minimum wage legislation and the Affordable Care Act could pose challenges over the next year.

Data Security. As more companies adopt platforms that store sensitive data, the security of these systems is important. Yet only about 42% of executives are very confident that their data and systems are secure from authorized access (about 50% are “somewhat confident”). Improving employee security protocols and providing training, involving data security consultants, and conducting due diligence on vendor data security are among the actions that companies are taking to enhance the security of their platforms. “If there’s a data breach, a lot of sensitive information could be put out there, including product formulations, intellectual property, and employee data (social security numbers or healthcare data),” says Singer. “Initially a lot of companies on the retail side were focusing on data security. Now we’re educating our clients, especially those on the distribution, processing or manufacturing side. All levels of the supply chain are at risk.”

July 1, 2015

FST Soapbox

What Comes After FSMA?

By Randy Fields

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The initial deadlines for Food Safety Modernization Act implementation are upon us, and while it will be a year or more before companies must comply with the regulations, now is an appropriate time to consider the happens next with food safety in the United States. Packaging requirements, issues with imports, the move toward clean labels, updating facility auditing requirements, and a wide set of compliance issues will be near-term time-consuming issues for food safety directors and executives all the way up to the c-suite.

FSMA is the most impactful set of safety regulations to hit the grocery and restaurant industries since before World War II. But there are other elements of consumer protection that will quickly capture the attention of supermarket and foodservice executives after August, and smart companies are already looking ahead to ensure a competitive advantage.

Packaging requirements aren’t just limited to country of origin labeling. Consumers are demanding full transparency from manufacturers and the retailers from which they buy their food. Shoppers are demanding clear descriptions of what they’re eating and voicing their displeasure for companies that are not providing the details they want by buying competitive items. A quick look at the comparative sales of the big processed food companies during the last few years verifies this isn’t a fad.

Tainted imported food (for both humans and pets) nearly a decade ago was a key trigger for the legislation that ultimately became FSMA. While the act addresses record keeping and some elements of lab testing, there are still several issues to tackle, including third-party validation rules and the voluntary program for importers that provides for expedited review and entry of foods.

The move toward clean labels or reducing the number of ingredients in processed food is taking form in several different ways. For example, many manufacturers, particularly those that make products targeting young consumers, are eliminating high-fructose corn syrup from their product lines to address consumer concern about the impact the ingredient is having on obesity and other health issues.

Updating facility auditing requirements, at retail, foodservice and manufacturing operations, has been largely left to trade associations and the companies themselves. A single incident of foodborne illness or death linked to a store commissary, a restaurant or a processing facility is all it will take for consumers to demand government action to raise standards and increase inspections.

On compliance issues, FSMA requires companies to collect verification data of their supply chain’s adherence to regulations for up two years and have it accessible within 24 hours. Similar to Sarbanes-Oxley, CEOs are responsible for verifying the compliance of their supply chain under FSMA. Given these risks, companies have started to automate their management of compliance documentation. Now forward-thinking companies are applying the same technology to ensure that information supplied by trading partners on products such as gluten-free goods or items containing nuts is frequently updated to avoid lapses that could lead to lawsuits and worse.

There certainly are a few different visions of the future of food safety. One commonality is that consumers will continue to demand an even safer food supply chain. If companies don’t pursue this goal, legal action or governmental regulation will step in to encourage change.

May 18, 2015

FST Soapbox

The Silver Lining of FSMA Compliance: Leverage the Cloud to Mitigate Risk

By Randy Fields

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It may seem counter-intuitive that any government regulation could generate an opportunity for food industry manufacturers, processors and marketers. But that is exactly the case with the Food Safety Modernization Act (FSMA). Manufacturers as well as your suppliers and customers need to invest in and change some business practices to comply with FSMA regulations, and doing so will enable them to bolster other processes and technologies to further cut costs and help mitigate risks not directly associated with food safety.

FSMA requires food manufacturers and your trading partners (both upstream and downstream) to have the documentation for regulatory compliance readily accessible for government inspection, with specific records required for companies that transport food or are deemed to be the procurer of foreign products. When you add these records to the business relationship records that food manufacturers, your suppliers and customers should already be maintaining (such as indemnifications and certificates of insurance that help manage brand risk), the databases start to become very large, very quickly.

The easy part of FSMA compliance for food manufacturers is with your largest customers and suppliers, because they likely have the processes and technologies in place to ensure both companies have the proper documentation. It’s really the group of smaller customers and ingredient providers, which can represent thousands of companies, that may not have the sophistication to supply the data points required under the law. Collecting and managing the information from these firms can be costly and labor intensive.

The good news is that cloud-based technology now exists to help all trading partners in the food supply chain meet FSMA requirements while working to prevent outbreaks and quickly limiting situations when they occur. This technology goes beyond just storing digital copies of documents—it helps to manage compliance with exception-based alerts for expired, missing or inaccurate records. It can also be the basis of an approval process for new vendors that incorporate record compliance. By linking and automating the management of compliance documentation and new vendor approvals, companies save time and allow for redeployment of resources to more productive activities.

If you are serious about reducing brand risk, linking compliance management data with your purchase order system will swiftly and effectively accomplish that goal. Holding a purchase order for a non-compliant vendor protects the retailer, manufacturers and the consumer, and communicates a commitment to food safety within the entire supply chain.

So, complying with government regulations such as FSMA doesn’t have to represent a significant one-time investment in technology and ongoing upkeep. Look to cloud-based technology with an eye for streamlining current processes, reducing overhead and supporting new customer or regulatory requirements. And, being proactive to ensure the safety of your company and your customers will put you in a position to sell more and grow your market share.

The Supply Chain Program

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