Tag Archives: Supply Chain

By Julie Holt

Known officially as The California Safe Drinking Water and Toxic Enforcement Act of 1986, California Proposition 65 reaches far beyond state boundaries and has potential regulatory implications for almost any company that manufactures, imports, and / or sells products containing listed chemicals in the state. California Prop 65 prohibits the sale of a product in California that knowingly and intentionally exposes an individual to a California Office of Environmental Health Hazard Assessment (OEHHA) listed chemical without a specific stated warning. For many food and supplement companies, the risk of opportunistic litigation based on California Prop 65 drives the need to monitor updates, new amendments and enforcement of the law.

Prop 65 Background

California Proposition 65, also known by the shortened name Prop 65, is not a ban on products or ingredients. The law is intended to inform consumers in California about exposure to a list of chemicals exceeding a defined level in products for sale, including product packaging. The regulation mandates a warning label for exposure to chemicals at a level that could cause cancer, birth defects or other reproductive harm. Guidance for upper limits (“Safe Harbor Level”) on chemicals is based on expected daily exposure. If no Safe Harbor Level exists for a chemical, the product containing a listed chemical must include a warning, unless the exposure level can be proven to not pose a significant risk of causing harm.

With the size of the California economy and the interconnected U.S. supply chain, the state law effectively reaches other states and U.S. importers. More recently, the Prop 65 requirements impact online and catalog sales, which have increased significantly during the global pandemic.

Know Your Suppliers

All companies need to proactively evaluate and document Prop 65 risks. Enforcement occurs primarily through civil litigation, resulting in specialized legal firms profiting from a company’s ignorance of the law’s extent. Even the threat of publicity from a lawsuit can cause targeted companies to settle a case.
At each point of manufacturing and distribution—supplier, manufacturer, packager, importer or distributor—regulatory teams should ask about Prop 65 compliance. The main point of responsibility is at the manufacturer, but a retailer can also be obligated for introducing a chemical at point-of-sale.

What’s New with Prop 65

The OEHHA issues notices regarding amendments to the California Code of Regulations Title 27, Article 6, covering “Clear and Reasonable Warnings”. Recently the OEHHA requested public comments on proposed amendments that would modify the content and methods for providing “short-form” warnings. The short form was originally intended for products with restricted label space.

The proposed rule would modify the existing short-form warning provisions to:

Only allow use of the short-form warning on products with five square inches or less of label space.
Eliminate use of short-form warnings for products sold via the Internet and catalogs.
Clarify how short-form warnings can be used for food products.
Require the name of at least one chemical be included in the short-form warning.

Bottomline: Know Your Business and Risk

As an advisor with more than 20 years of regulatory compliance experience in food and food ingredients, my guidance for business best practice on Prop 65 is to be proactive, maintain supply chain knowledge, and understand risk. Regulatory or legal staff, or consultant teams specializing in Prop 65, should regularly monitor for additions to the chemical list and rulemaking changes to the far-reaching law.

March 31, 2021

Reimagining Food Safety Through Transparency and Open Dialogue

By Maria Fontanazza

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Last year’s annual GFSI Conference was held in Seattle just weeks before the World Health Organization (WHO) declared COVID-19 a pandemic. This year’s event looked very different, as it joined the virtual event circuit—with hundreds of attendees gathering from across the globe, but from the comfort of their homes and offices. The 2021 GFSI Conference reflected on lessons learned over the past year, the fundamentals of building a better food system, and the idea that food safety is a collaborative effort that also encompasses training programs, effectively leveraging data and capacity building.

The pandemic provided the opportunity to reimagine safer, more resilient and sustainable food systems, said Dr. Naoki Yamamoto, universal health coverage, assistant director-general, UHC, Healthier populations at WHO. She also offered three clear messages that came out of the pandemic:

Food safety is a public health priority and a basic human right. Safe food is not a luxury.
Food safety is a shared responsibility. Everyone in the food chain must understand this responsibility and work towards a common goal.
Good public private partnership can bring new opportunities and innovative solutions for food safety. We need to seek more collaborative approaches when working across sectors to achieve foods safety.

During the session “Ready for Anything: How Resiliency and Technology Will Build Consumer Trust and Help Us Mitigate Disruption in the 21st Century”, industry leaders discussed how the pandemic reminded us that a crisis can come in many forms, and how applying the right strategy and technology can help us remain resilient and equipped to address the challenges, said Erica Sheward, GFSI director.

“When you think about business resiliency—it’s about our own, but most importantly, it’s about helping our customers become more resilient to those disruptions,” said Christophe Beck, president and CEO of Ecolab. He added that being able to predict disruptions, help customers respond to those disruptions, and provide real-time control to learn and prepare for the next pandemic or serious crisis is critical. Companies need to ensure their technology systems and contingency plans are ready to go, advised David Maclennan, chairman and CEO of Cargill. The key to a resilient food supply chain system is access and the ability to keep food moving across borders. And above all, whether dealing with a health crisis or a food safety crisis, consumers must always be front and center, said Natasa Matyasova, head of quality management at Nestle. “In short term, [it’s] first people, then business contingency, and then help the community as needed,” she said.

March 24, 2021

Day 1 of 2021 GFSI Conference Reflects on Leadership and Resilience

By Food Safety Tech Staff

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The 20th annual GFSI Conference convened yesterday, but instead of bringing together an international group of food industry stakeholders in one central location, the event was held online, streamed throughout offices and homes across the globe.

Day one kicked off with a welcome from Wai-Chan Chan, managing director of The Consumer Goods Forum, Qu Dongyu, Director-General of the Food and Agriculture Organisation of the United Nations, who addressed the humanitarian and consumer perspective of food safety. “We need a strong engagement of the private sector for our agrifood systems to become more efficient, more inclusive, more resilient and more sustainable,” Chan stated. The conversation about the global importance of sustainability continued with a conversation led by Erica Sheward, GFSI Director, and Howard Popoola, vice president, corporate food technology and regulatory compliance for The Kroger Company and Roy Kirby, global director, microbiology, food safety and toxicology for Mondelez International. They talked about GFSI’s program, Race to the Top, and the /global Markets Programme capability tool, which was established more than 10 years ago to help companies implement continuous improvement to develop an effective food safety management system, and its potential in developing markets. “Think about what this could do for farmers, think about what it could do for families in Africa, in those places described as countries of opportunity, producing niche products, who just need an opportunity to be able to sell their products into the world stage,” said Popoola, who is also a GFSI steering committee member.

During the course of the day, stakeholders also discussed pandemic-specific issues including supply chain disruptions, and the role of crisis communications and messaging to consumers related to the safety of the food supply.

More exclusive updates will be available from Food Safety Tech. Read GFSI’s full update on Day One of the conference.

March 9, 2021

Reset, Rethink, Recharge: First Virtual GFSI Conference to Address Urgent Topics in Food Safety

By Food Safety Tech Staff

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This year’s GFSI Conference will take place March 23–25 and bring together experts, decision makers and innovators in the food industry. With the theme of “rethink, reset, recharge”, the three-day virtual program includes online networking features to allow attendees to connect with professionals across the globe, and sessions that explore COVID-19; supply chain disruption and public health; building consumer trust and transparency; sharing best practices; and technologies shaping the future of food safety.

“Collaboration to ensure safe food for consumers everywhere and sustainable food systems has never been more critical – and this event provides a major opportunity to learn from an unprecedented period and move forwards in the best possible way. We’re excited by the chance to help colleagues across the industry build on the ingenuity, resilience and dedication shown by the food industry over the past 12 months,” said Erica Sheward, director of GFSI, in a press release. “With the conference taking place virtually for the first time, it’s easier than ever before for food industry professionals to get involved—and we’re urging people from all corners of the globe to ensure they’re part of this unique and collaborative forum. Food safety is everyone’s business, and we must continue to work together to build consumers’ trust in the food they buy.”

More information about the GFSI conference, along with registration, agenda and partner details, can be found on the event website.

GFSI is a partner organization for the 2021 Food Safety Consortium Virtual Conference Series.

February 22, 2021

FST Soapbox

Tracking an Outbreak: Creating a More Transparent Food Supply Chain with Blockchain

By Robert Galarza

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Despite what our parents told us, it’s not always healthy to eat our vegetables. In late 2020, 40 people contracted E. coli from leafy greens in the United States. By the time the outbreak was declared over, 20 victims had been hospitalized and four developed kidney failure. On top of the human cost, the food distribution businesses involved spent millions of dollars on public information as well as tracing the tainted vegetables and removing them from the market.

The USDA estimates that dealing with foodborne diseases cost $15.6 billion annually. Inefficient and painstaking guesswork is required with every incident, trying to find where the outbreak originated, and locate every shipment that may or may not have come into contact with that diseased strain which must then be recalled, as there’s no way to know for sure what has been affected. And by the time the original culprit is found, the malady may have spread so far that there is no choice but to recall and destroy tons of potentially wholesome products.

What if all this waste—not to mention dozens of infections—could be avoided? What if a foolproof, secure and constantly updating system could track the original tainted produce back to the farm it came from and confirm every employee, transport, and container it has been in contact with on the way? This technology exists today, ready to make food distribution not just safer but also more transparent, efficient and cost effective. It’s called blockchain.

Anyone with a passing familiarity with blockchain knows the technology was originally developed to track and safeguard cryptocurrency transactions. And while Bitcoin and its competitors definitely put the crypto in currency by being inscrutable to outsiders, it’s hard to call food supply chains a lot less complex. It is the vital importance of making that complexity accessible and understandable that makes blockchain the perfect way to futureproof distribution.

What Is Blockchain, Really?

Blockchain is a secure and decentralized ledger that tracks and records transactions. The keywords that indicate why this is an ideal solution for food supply businesses are “secure” and “decentralized.”

More than any other ledger system, blockchain is secure against tampering. Blockchain transactions can’t be altered or hidden, because every change is tracked and recorded and must be approved across the entire system. This system is also decentralized. Instead of one single ledger where a tiny mistake hidden on one obscure ledger could throw off an entire operation, blockchain distributes the whole ledger to all sources across a network, so anyone with the required permissions can see changes across the entire system in real time. When one person makes changes on their version of the ledger, all stakeholders across the network must confirm those changes, and the system remembers where and when they were made.

By distributing the records across different systems and always tracking changes, blockchain eliminates the guesswork and busywork of finding any individual item, when and how it was altered, and by whom. A simple search pinpoints any given item’s previous, current and future position in a supply chain. That search also reveals any other items with which it is shared space. Where once disease outbreaks meant painstaking searches and expensive purges of product, blockchain makes isolating infected produce easy and precise, saving capital and even lives, especially when time is a factor.

Transparency Is Time

When tracking products, blockchain’s unique advantages simply slice time off the process. By distributing its records, blockchain removes harmful lag between parties knowing when changes are made to a single master ledger. There is no need to wait for someone earlier on in the supply chain to update their documents, then for a central office to confirm and collate that update before the information can move further down the line. All stakeholders with the proper permissions can get a full view of inventory, finances, and concerns — all updated in real time the moment a change takes place.

Banks, suppliers, retailers and more can share immediate access to live changes in a system using blockchain. Keeping everyone updated becomes streamlined, tamper-proof and completely trustworthy. Suppliers and retailers can study trends in the ledger and see their partners taking out loans or expanding inventory space, allowing everyone to anticipate each others’ needs and react to crises like tainted produce much faster.

Everyone Knows Everything

In an emergency, the most important questions are often who knows what, where is the information that will lead to tracking down the problem, and more importantly, who has it? With blockchain, there’s no need to follow a trail of evidence in hopes of finding the original ledger where the problem appears, because the distributed network automatically upgrades universally across all systems.

Any mistake appears everywhere at once and can be caught by any number of parties, who are alerted in real time to every change. This creates redundant failsafes to prevent errors and catch problems. Not only are causes easier to track, but operational mistakes and execution errors are caught immediately. Partners can update schedules and adjust shipments, confident that everyone involved is automatically informed.

Way Beyond Bitcoin

Blockchain’s origins in cryptocurrency make it an ideal system for tracking and safeguarding transactional pipelines of all sorts, and this makes it uniquely suited to food supply chains. No other system seamlessly records countless transactions across multiple sources while keeping a clean record for all involved. This not only saves crucial time and money during a challenge like an E. coli outbreak, it smooths out longstanding problems in the food distribution industry by adding unprecedented access and redundancy.

Upon adopting this new technology, the food distribution industry will enter a new era of reliability and cooperation as tracking every product from farm to plate becomes the standard. Even without an outbreak to lock down, blockchain will improve every aspect of supply chain management, paving the way for a more efficient and collaborative industry. Our modern world relies on communication and authenticity, and blockchain can only make the truth clearer.

February 15, 2021

Ask the Expert: What Is Blockchain for the Food Supply Chain—Explained Simply

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Why do we need traceability solutions for the supply chain?

Brett Gray: Supply chains changed from a linear model to more like ecosystems. Raw materials and ingredients are traveling from multiple sources multiple times, and you are no longer relying on a single supplier, but, rather, on a large number of suppliers and an entire new network of people, who enable you to accomplish the objectives for your business. These new ecosystems have made things more complex, and forced companies to change their business models, forming multiple relationships, thus storing data in multiple locations. As a result, consumer trust has shifted from known brands to products. With multiple sourcing of raw materials or ingredients by [previously] trusted producers, consumers want to know, how these ingredients were grown, transported and stored. Consumers are looking now at the labels, rather than logos. While consumers are asking for proofs of origin, quality, social responsibility and sustainability, brands are struggling to share about all efforts and investments made into specific products, as well as create engaging for this or that group of consumers touch points.

So, how is this technology – blockchain – appeared to be best suitable to fulfill the current market requirements for the proof of products origins for the end consumer?

Gray: Blockchain is a decentralized (no single ownership), distributed ledger-like digital structure that allows a community to record, share and maintain information. The documents are like IDs we know: A passport or a driving license, except these are for products. These documents are protected by encryption from being modified and irreversibly time stamped. Each document in the blockchain is connected to the previously produced one and the one produced after, so it forms a chain of blocked documents. Blockchain technology acts as a perfect trust generator for different types of businesses. The authenticity of data in it renders trust among stakeholders previously unknown to each other.

DNV GL started developing its My Story blockchain based solution about a decade ago, when this technology was not well known. Now it enables companies to prove that their “marketing buzzwords” are, in fact, true, verified statements. For companies seriously investing in sustainable processes and value chains, it enables sharing about these efforts directly with the end consumer, setting such companies apart from less serious, greenwashing players.

About Brett Gray

As the Digital Transformation Manager at DNV, I oversee all digital projects, strategy, and solution for the entire region of North America, with the intention of bringing technology stacks and other emerging technologies like blockchain, AR/VR, artificial intelligence and big data analytics to change the way we interact with and provide services to our customers.

Content Sponsored by DNV.

January 22, 2021

FST Soapbox

Supply Chain Visibility and Transparency a Key Element of Change in 2021

By Niels Andersen

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It is safe to say that 2020 was a year unlike any other. The COVID-19 pandemic brought on significant changes to everyday life across the world. It also brought some significant challenges to businesses from retail, to restaurants and manufacturing. The supply chain industry faced a challenge like no other when shutdowns began and manufacturers were left scrambling to come up with a backup plan. Although these challenges were tough to handle, it gave the industry a much-needed eye opening to make the changes needed in order to avoid this from happening again.

The food manufacturing industry was hit particularly hard and required some intervention from the U.S. government. In order to protect food plant workers, the FDA and OSHA jointly issued a 16-page checklist for use by owners and operators of food production companies in mid-August. While it did not list any new regulations, it pulled existing guidance from the FDA, CDC, and OSHA. The main focus was on employee health and food safety. The main concern was offering guidance on how to deal with resuming operations, protecting healthy workers, as well as for dealing with sick employees and those exposed to them. One of the struggles we have is that the guidelines relate to how workers behave inside a plant.

These guidelines were just the tip of the iceberg as it forced the industry to take a deeper look into two main areas: Supply chain robustness, visibility and transparency, and traceability. Highly optimized modern supply chains depend on a high degree of predictability from all actors in the chain; they are lean in order to minimize costs and working capital.

Unfortunately, this optimization has made supply chains brittle—the models did not anticipate COVID-19 and the unexpected complexity that followed. Moving forward, manufacturers need to take a closer look at how this happened.

The traditional way to increase robustness in a supply chain is to increase inventory buffers so that any breakdowns can be smoothed out over time. Inventory buffers are expensive, tie up working capital, and increase risks, because a manufacturer may not be able to sell what they have in inventory. A more modern approach is to make supply chains more agile, so changes can be implemented quickly in case the unexpected happens. Agility requires visibility and transparency in order to understand what’s happening. The struggle in manufacturing is that agility must be combined with repeatability so that quality products can be created in a cost-effective way on a large scale. Repeatability also requires visibility and transparency. A famous quote from Lord Kelvin says, “you cannot improve what you cannot measure”. This rings as true today as it did more than 100 years ago. Another key element is repeatability to ensure that the manufacturing resources produce the requested production orders. This is why it is so important to provide transparency in what is going on in your supply chain to ensure processes are stable and repeatable.

The pandemic has brought a renewed focus for manufacturers in making sure they are becoming more transparent and agile within their supply chain processes. They are realizing thanks to this disruption that suppliers can’t always deliver and a backup plan is crucial to keep things moving. One option is to implement technology that helps track visibility and transparency to better assess what is needed and to offer alternative suppliers. Having supply chain transparency requires companies to know what is happening upstream in the supply chain and communicate this knowledge both internally and externally.

Automation Can Help with Supply Chain Visibility

Automation has wrongly been perceived as just a way to kill jobs. At the same time, the idea of “bringing manufacturing back to the United States” is less about bringing jobs back and more about adding value creation. For manufacturers to be effective today, they must automate. It’s not just about being efficient, it’s about enabling manufacturers to scale up with precision. Most importantly, it’s about survival. In order for manufacturers to survive, they need to automate. This is driving a much higher demand in sensors which play an essential role in automation.

Automation systems are unbiased, and don’t have bad day. This means manufacturers can operate with high levels of repeatability and precision. Without this level of automated precision, we would not be able to enjoy many of modern life’s necessities like the car you drive or the cell phone in your pocket.

Additionally, automation reduces errors, increases the efficiency of the labor, and results in higher output with lower labor costs. This helps manufacturers reduce waste, increase sustainability, lower their carbon footprint, and reduce their energy dependency.

2020 prompted many necessary changes to the food manufacturing industry and their interaction with suppliers. It is true that a crisis spurs innovation. The pandemic has forced manufacturers to think differently about how they are conducting business. One thing will be critical to move forward: The ability to have better visibility of your supply chain. Adding visibility, transparency and collaboration tools are going to bring on lasting changes that are to manage a disruption such as a future pandemic.

January 15, 2021

FST Soapbox

Food Insecurity Vs. Food Waste: Producers and Manufacturers Can Affect the Balance

By Stephen Dombroski

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As the population continues to grow and the effects of climate change, global warming, pollution and other factors impact humanity’s ability to grow and provide enough food for itself, the concern that the world could run out of food is increasing.. The COVID-19 pandemic has put more focus on how fragile the food supply chain is and how easy it is to disrupt the process of feeding the world. For years, it has been mostly a topic of discussion. But with so many disruptions, it is now an issue that needs to be acted on. Social groups, civic associations, government bodies and food manufacturers have taken notice of the problem and are attempting to get their hands around the issues. One of the key points in this discussion revolves around the amount of food and food sources that will be needed in the future. It always starts with the same question: “Will there be enough food?” Most people immediately say no. But is that 100% true? This is where the debate between food insecurity and food waste begins.

What is Food Insecurity?

According to the Office of Disease Prevention and Health Promotion, food insecurity is defined as “the disruption of food intake or eating patterns due to lack of money or other resources…Food insecurity does not necessarily cause hunger, but hunger is a possible outcome.” The debate about whether there is or isn’t enough food can get pretty contentious. There are many people in many countries that are “food insecure.” The problem in many cases, however, is due to affordability rather than availability. There are distinct issues and differences between availability and affordability. Go to any grocery store or purchasing venue in most developed countries and for the most part, the shelves are well stocked. The obvious conclusion is that there is enough food. However, can the entire population afford that food? Now, go to countries that are not as developed and you would be hard-pressed to find a grocery store that is as well stocked. Even if the population can afford to buy it, there simply is not enough food to buy. The difference between these two scenarios is where the debate begins. People talk about climate change making it challenging to produce enough food to meet the world’s needs, but store shelves in developed countries are full. All the while edible food is getting thrown away and destroyed in ridiculous amounts each day.

The world agrees that manufacturers, governments and consumers have a social responsibility to do their part to combat world hunger. Consumers are becoming more aware of food security and the threat that climate change poses. There are trends supporting sustainability in daily diets, with meals lower in environment impact and awareness of plate portions and food waste. Government agencies are working with manufacturers to resize portions and package sizes to align with scientific research on the necessary amount of food and nutrients needed in diets. Manufacturers and their customers (retail channels) are working more closely to create accurate and realistic “best by dates” to reduce the amount of food that is thrown out as “expired.”

World health organizations are increasing their focus as well. The U.N. World Food Program (WFP) is addressing hunger and emphasizing “food security.” WFP provides 15 billion meals to nearly 100 million people suffering from the effects of life-threatening hunger in over 80 countries. Manufacturers are expanding their participation in this area by increasing and improving donation programs, developing nutritional foods from new sources and incorporating limited perishability to make foods last longer and minimize food waste.

Wasted Food: An Understated and Complex Problem

If you think about it, the two largest consumers of food are garbage disposals and landfills. Both are well fed. Landfills receive both expired food that is not used and consumer food waste. Obviously, garbage disposals are used by consumers for cooked food that is not eaten or saved. I bring this up because it sparks the discussion of defining food waste. People use this term often and many times it is about food that consumers discard. But food waste has multiple categories and mirrors the supply chain. Food waste occurs at the following levels:

Growers/agricultural
Supplier
Primary producer/manufacturer
Distribution/transportation
Retail
Foodservice providers
The consumer

Approximately one-third of the total food produced globally—about 1.4 billion tons—is wasted. In addition to the loss of a great deal of edible food, there are other consequences to this waste. Food waste and food loss impact climate change, accounting for roughly 10% of the world’s greenhouse gas emissions. Human behavior is a significant contributor to climate change. Luckily, habits can be changed through education, like encouraging composting or recycling. Portion control at restaurants and in the home can make us healthier and also help to reduce food waste. Another trend in recent years is the migration for many consumers to healthier eating. This typically consists of using and consuming fresh ingredients with less processing and chemical additives. These ingredients, however, typically have shorter shelf lives and end up contributing to the growing amount of food waste. Over the last 10 years, food manufacturers, suppliers and the greater agricultural community have focused on efforts to reduce food and other wastes that fall into the sustainability category such as energy, water, materials used in packaging, etc. Food producers have figured out ways to repurpose unused ingredients, by-products and waste. Many sell to farms to be converted to feed and fertilizer. Some is sold to pet and animal feed producers to convert into sellable products. It is actually quite a profitable business for many manufacturers.

Balancing Between Food Insecurity and Food Waste

Analyzing both concepts requires a balancing act. On one hand, you can argue that if you recoup 1.4 billion tons of wasted food, or let’s say, even half of it, we might eliminate the hunger problem. But then consider the issue of food costs. When people go shopping for food, an often-heard comment is, “I can’t believe how much this food costs.” You have said it, and I have too. However, I have spent a significant amount of time in food manufacturing facilities of almost every vertical segment and I have a hard time not saying, “I can’t believe this only costs this much.” The entire process from field to fork for most food items is extraordinarily complex and comes with a wide array of costs. Most food manufacturing businesses are meager margin. They turn a profit but most feel the social responsibility to provide quality food at reasonable prices.

The industry is making significant progress, however, and more can be done. With new technology including IoT, Industry 4.0 and Smart Agriculture, resources such as land, water and space are being utilized much more efficiently to increase supply. This reduces costs. Through the use of technology, farmers are growing healthier more sustainable crops that minimize waste. Food and beverage manufacturers are now using business systems and processes to better communicate with suppliers. Adaptive ERP and integrated business planning are simplifying the supply chain, helping to maximize shelf lives and minimize food waste. As we move into 2021 and beyond, technology and integrated business systems and processes throughout the entire food supply and value chain will help minimize food waste and hopefully reduce costs. This should bridge the gap between food insecurity and food waste.

January 12, 2021

FST Soapbox

HACCP is the Past, Present and a Building Block for the Future

By Earl Arnold

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“Food safety plan” is a term often used in the food industry to define an operation’s plan to prevent or reduce potential food safety issues that can lead to a serious adverse health consequence or death to humans and animals to an acceptable level. However, depending on the facility, their customers, and or regulatory requirements, the definition and specific requirements for food safety plans can be very different. To ensure food safety, it’s important that the industry finds consensus in a plan that is vetted and has worked for decades.

One of the first true food safety plans was HACCP. Developed in 1959 for NASA with the assistance of the food industry, its goal was to ensure food produced for astronauts was safe and would not create illness or injury while they were in space. This type of food safety plan requires twelve steps, the first five of which are considered the preliminary tasks.

Assemble a HACCP team
Describe the finished product
Define intended use and consumer
Create process and flow diagram
Verify process and flow diagrams

This is followed by the seven principles of HACCP.

Conduct the hazard analysis
Identify critical control points
Establish critical limits
Establish monitoring requirements
Establish corrective actions for deviations
Procedures for verification of the HACCP plan
Record keeping documenting the HACCP system

HACCP is accompanied by several prerequisites that support the food safety plan, which can include a chemical control program, glass and brittle plastics program, Good Manufacturing Practices (GMPs), allergen control program, and many others. With these requirements and support, HACCP is the most utilized form of a food safety plan in the world.

When conducting the hazard analysis (the first principle of HACCP), facilities are required to assess all products and processing steps to identify known or potential biological, chemical and physical hazards. Once identified, if it is determined that the hazard has a likelihood of occurring and the severity of the hazard would be great, then facilities are required to implement Critical Control Points (CCP) to eliminate or significantly reduce that identified hazard. Once a CCP is implemented, it must be monitored, corrective actions developed if a deviation in the CCP is identified and each of these are required to be verified. Records then also need to be maintained to demonstrate the plan is being followed and that food safety issues are minimized and controlled.

HACCP is, for the most part, the standard food safety plan used to meet the Global Food Safety Initiative (GFSI) standards. This is utilized in various third-party audit and customer requirements such as FSSC 22000, SQF, BRC, IFS and others. These audit standards that many facilities use and comply with also require the development of a food safety management system, which includes a food safety plan.

Further, HACCP is often used to demonstrate that potential food safety issues are identified and addressed. FDA has adopted and requires a regulated HACCP plan for both 100% juice and seafood processing facilities. USDA also requires the regulated development of HACCP for meat processing and other types of facilities to minimize potential food safety issues.

For facilities required to register with the FDA—unless that facility is exempt or required to comply with regulated HACCP—there is a new type of food safety plan that is required. This type of plan builds upon HACCP principles and its steps but goes beyond what HACCP requires. Under 21 CFR 117, specific additions assist in identifying and controlling additional food safety hazards that are on the rise. This includes undeclared allergen recalls, which constituted 47% of recalls in the last reportable food registry report published by FDA.

Prior to developing this plan, FDA provided recommendations for preliminary steps that can be completed and are essential in development of a robust food safety plan but are not a regulatory requirement. The steps are very similar to the preliminary tasks required by HACCP, including the following:

Assemble a food safety team
Describe the product and its distribution
Describe the intended use and consumers of the food
Develop a flow diagram and describe the process
Verify the flow diagram on-site

Their recommended plan also requires a number of additional steps, including:

A written hazard analysis. Conducted by or overseen by a Preventive Controls Qualified Individual (PCQI). However, this hazard analysis requires assessing for any known or reasonably foreseeable biological, chemical, physical, radiological, or economically motivated adulteration (food fraud that historically leads to a food safety issue only). You may note that two additional hazards—radiological and EMA—have been added to what HACCP calls for in the assessment.
Written preventive controls if significant hazards are identified. However, similar preventive controls are different than a CCP. There are potentially four types of preventive controls that may be utilized for potential hazards, including Process Preventive Controls (the same as CCP), Allergen Preventive Controls, Sanitation Preventive Controls, Supply Chain Preventive Controls and Others if identified.
A written supply chain program if a Supply Chain Preventive Control is identified. This includes having an approved supplier program and verification process for that program.
A written recall plan if a facility identified a Preventive Control.
Written monitoring procedures for any identified Preventive Control that includes the frequency of the monitoring what is required to do and documenting that monitoring event.
Written corrective actions for identified Preventive Controls in case of deviations during monitoring. Corrective actions must be documented if they occur.
Written verification procedures as required. This could include how monitoring and corrective actions are verified, procedures themselves are verified, and calibration of equipment as required. Also required is training, including a Preventive Control Qualified Individual. Additional training is required for those individuals responsible for performing monitoring, implementing corrective actions, and verification of Preventive Controls. Further, all personnel need to have basic food safety training and all training needs to be documented.

While the term “food safety plan” is used widely, it’s important that operations don’t just use the term, but enact a plan that is vetted, proven to work, and encompasses the principles of HACCP. Doing so will help ensure that their facility is producing foods that customers and consumers will know is safe.

January 8, 2021

Food Fraud Quick Bites

Food Authenticity: 2020 in Review

By Karen Everstine, Ph.D.

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It is fair to say that 2020 was a challenging year with wide-ranging effects, including significant effects on our ongoing efforts to ensure food integrity and prevent fraud in the food system. COVID-19 caused major supply chain disruptions for foods and many other consumer products. It also highlighted challenges in effective tracking and standardization of food fraud-related data.

Let’s take a look at some of the notable food fraud occurrences in 2020:

Organic Products. The Spanish Guardia Civil investigated an organized crime group that sold pistachios with pesticide residues that were fraudulently labeled as organic, reportedly yielding €6 million in profit. USDA reported fraudulent organic certificates for products including winter squash, leafy greens, collagen peptides powder, blackberries, and avocados. Counterfeit wines with fraudulent DOG, PGI, and organic labels were discovered in Italy.
Herbs and Spices. Quite a few reports came out of India and Pakistan about adulteration and fraud in the local spice market. One of the most egregious involved the use of animal dung along with various other substances in the production of fraudulent chili powder, coriander powder, turmeric powder, and garam masala spice mix. Greece issued a notification for a turmeric recall following the detection of lead, chromium, and mercury in a sample of the product. Belgium recalled chili pepper for containing an “unauthorized coloring agent.” Reports of research conducted at Queen’s University Belfast also indicated that 25% of sage samples purchased from e-commerce or independent channels in the U.K. were adulterated with other leafy material.
Dairy Products. India and Pakistan have also reported quite a few incidents of fraud in local markets involving dairy products. These have included reports of counterfeit ghee and fraudulent ghee manufactured with animal fats as well as milk adulterated with a variety of fraudulent substances. The Czech Republic issued a report about Edam cheese that contained vegetable fat instead of milk fat.
Honey. Greece issued multiple alerts for honey containing sugar syrups and, in one case, caramel colors. Turkey reported a surveillance test that identified foreign sugars in honeycomb.
Meat and Fish. This European report concluded that the vulnerability to fraud in animal production networks was particularly high during to the COVID-19 pandemic due to the “most widely spread effects in terms of production, logistics, and demand.” Thousands of pounds of seafood were destroyed in Cambodia because they contained a gelatin-like substance. Fraudulent USDA marks of inspection were discovered on chicken imported to the United States from China. Soy protein far exceeding levels that could be expected from cross contamination were identified in sausage in the Czech Republic. In Colombia, a supplier of food for school children was accused of selling donkey and horse meat as beef. Decades of fraud involving halal beef was recently reported in in Malaysia.
Alcoholic Beverages. To date, our system has captured more than 30 separate incidents of fraud involving wine or other alcoholic beverages in 2020. Many of these involved illegally produced products, some of which contained toxic substances such as methanol. There were also multiple reports of counterfeit wines and whisky. Wines were also adulterated with sugar, flavors, colors and water.

We have currently captured about 70% of the number of incidents for 2020 as compared to 2019, although there are always lags in reporting and data capture, so we expect that number to rise over the coming weeks. These numbers do not appear to bear out predictions about the higher risk of food fraud cited by many groups resulting from the effects of COVID-19. This is likely due in part to reduced surveillance and reporting due to the effects of COVID lockdowns on regulatory and auditing programs. However, as noted in a recent article, we should take seriously food fraud reports that occur against this “backdrop of reduced regulatory oversight during the COVID-19 pandemic.” If public reports are just the tip of the iceburg, 2020 numbers that are close to those reported in 2019 may indeed indicate that the iceburg is actually larger.

Unfortunately, tracking food fraud reports and inferring trends is a difficult task. There is currently no globally standardized system for collection and reporting information on food fraud occurrences, or even standardized definitions for food fraud and the ways in which it happens. Media reports of fraud are challenging to verify and there can be many media reports related to one individual incident, which complicates tracking (especially by automated systems). Reports from official sources are not without their own challenges. Government agencies have varying priorities for their surveillance and testing programs, and these priorities have a direct effect on the data that is reported. Therefore, increases in reports for a particular commodity do not necessarily indicate a trend, they may just reflect an ongoing regulatory priority a particular country. Official sources are also not standardized with respect to how they report food safety or fraud incidents. Two RASFF notifications in 2008 following the discovery of melamine adulteration in milk illustrate this point (see Figure 1). In the first notification for a “milk drink” product, the hazard category was listed as “adulteration/fraud.” However, in the second notification for “chocolate and strawberry flavor body pen sets,” the hazard category was listed as “industrial contaminants,” even though the analytical result was higher.¹

RASFF, melamine detection — Figure 1. RASFF notifications for the detection of melamine in two products.¹

What does all of this mean for ensuring food authenticity into 2021? We need to continue efforts to align terminology, track food fraud risk data, and ensure transparency and evaluation of the data that is reported. Alignment and standardization of food fraud reporting would go a long way to improving our understanding of how much food fraud occurs and where. Renewed efforts by global authorities to strengthen food authenticity protections are important. Finally, consumers and industry must continue to demand and ensure authenticity in our food supply. While most food fraud may not have immediate health consequences for consumers, reduced controls can lead to systemic problems and have devastating effects.

Reference

Everstine, K., Popping, B., and Gendel, S.M. (2021). Food fraud mitigation: strategic approaches and tools. In R.S. Hellberg, K. Everstine, & S. Sklare (Eds.) Food Fraud – A Global Threat With Public Health and Economic Consequences (pp. 23-44). Elsevier. doi: 10.1016/B978-0-12-817242-1.00015-4

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