Tag Archives: training

Joy Dell'Aringa, bioMerieux
FST Soapbox

The Value of Industry Engagement in Professional Organizations

By Joy Dell’Aringa
4 Comments
Joy Dell'Aringa, bioMerieux

We moved to Chicago five years ago. A massive city, and an epicenter of the food industry. I was at once excited and overwhelmed—afloat in a great lake of network overload. Removed from my comfort zone, I searched for ways to meet people and integrate into this new community. Upon suggestion of a trusted friend and experienced networker, I decided to try my hand at volunteering at an event hosted by the Chicago Section of the Institute of Food Technologists (IFT). That singular decision launched one of the most fulfilling journeys in both my professional and personal life. Now, five years later, I have made countless meaningful and personal connections, developed long-term relationships, and made an impact in my professional community. What started out as a way to navigate the complex circuitry of the Chicago food landscape has turned into a personal voyage for industry advocacy, leadership and contribution.

I am not alone. I have the pleasure to work and serve with colleagues around the globe that have experienced similar fulfillment by engaging with various professional organizations. Similarly, the companies that we work for reap the benefits of our involvement. Here, we will explore the value of industry engagement through the lens of the individual and the employer.

Employee Value: Top 5 Reasons to Engage

1. Professional Development – Safe Ways to Stretch Into New Roles & Skill Sets

When Pam Coleman, vice president of research services at Merieux Nutrisciences and incoming president-elect for IFT first started volunteering early in her career as a bench chemist, she found opportunities to lead groups and committees. “I developed new skills in a really safe way. As a volunteer, you can try new things, test the waters, and get relatively diverse experiences to see what you enjoy, what you don’t, and where you want to develop and explore.” The wide range of opportunities in industry organizations can offer a glimpse into future career development, or offer a learning experience that rounds out your professional repertoire. For example, joining a finance committee can stretch you outside of your comfort zone, but prepare you with skills and perspectives for future management roles. Participating on a fundraising committee can sharpen your influencing and organizational skills. Leading a technical group can offer opportunities to deep dive into a technology or discipline that can spark a passion to develop expertise in a new area. These cross-functional opportunities may not be readily available in your company, but industry organizations are always looking for professionals to volunteer.

2. Develop Your Network & Identify Mentors

Industry organizations are wrought with peers and potential mentors. Networking at events and symposiums will bring you in contact with people doing the same things as you are, facing the same challenges. You also have the opportunity to interact with the regulatory sector to learn from them. “Early in my career, my former manager built relationships with regulatory technical leaders at the USDA through industry organization involvement, and it was a great advantage for us when we ran into analytical challenges in the lab—she was able to personally call them and get suggestions and insights. They developed a rapport. This was a big lesson for me as a young volunteer. Your network can be an analytical asset.” Mentor opportunities abound as well. I have personally found that the more I engage with my organizations, the more trust I built within my network, the more mentorship opportunities naturally develop. I’ve honed valuable professional and life skills through these relationships: Conflict resolution, contract negotiations, and 501(c)3 organization creation to name just a few of the arduous tasks my organizational mentors have helped and supported me with. Building relationships across technical disciplines also holds advantage. As a microbiologist, it is fascinating to work with product developers and learn where our challenges and opportunities intersect. Not only can you network with technical peers, but also industry partners, vendors, suppliers and competitors to bring a well rounded perspective to see the industry through a truly holistic lens.

3. Gain Industry Insights

What’s new in your industry? What emerging trends are on the horizon? Engaging within industry organizations can bring keen insights well before they are published in our industry magazines and keynote presentations. Educational learning opportunities through technical committees, short courses, and symposiums can bring key advantages to giving you and your company a jump on implementing new technologies and trends. Understanding regulatory changes, implications, and perhaps most important, insights on how regulators will interpret and enact changes can also be gleaned from organization engagement. You can also gain exposure and experience with new business models such as zero-based budgeting and account-based marketing, which can lead to additional opportunities and advantage for you and your company.

4. Create Your Personal Brand

Who are you in the Industry? What do you want to be known for? Through industry engagement you can develop your personal brand and carry that image into your career. Do you strive to be a facilitator and connector? Run for a leadership position. Do you want to be known as a technical leader and subject matter expert? Lead a technical committee or task force. Do you want to be seen as a reliable contributor? Offer to develop content for a technical newsletter, or volunteer for a marketing committee. Not sure what you want your personal brand to look like? Try multiple roles and opportunities to see what inspires and fulfills you, and then pursue that with gusto. “When I look back and think, ‘How did I go from a bench chemist to this?'”, reflects Coleman, “I am certain I wouldn’t be where I am in my career today if it weren’t for my experiences and opportunities in organizations like IFT.”

5. Personal Fulfillment – Increased Health & Happiness

Industry advocacy and engagement can bring an immense sense of personal fulfillment, especially when you are able to make a contribution and an impact to the organization. Not only that, it can make you feel better, too: A 2010 United healthcare/VolunteerMatch (UHVM) study found that volunteering has a positive influence on physical and emotional health. One of the common objections to engaged volunteering is time, or lack of it. However, the University of Pennsylvania’s Wharton School recently found that those who volunteer not only feel more accomplished, but they also found they could do even more, as “giving your time to others can make you feel more ‘time affluent’ and less time-constrained”. In the words of my trusted networker friend that set me off on my volunteering journey five years ago: “The more you do, the more you can do.”

Quick TIPS:

  • Be Clear on Your Time: No matter how many or few hours you can devote, be upfront with the organization about how much time you can commit and what your goals are.
  • Think Local: Don’t forget your regional sections and chapters. Your organization(s) of choice also may have specialty groups and divisions that match your expertise or an area you may want to explore.
  • Get Out of the Booth: For those of us accustomed to working the trade show floor, challenge yourself to one meeting a year where you are there to learn. Get out of the booth. Absorb technical insights and trends. Bring back your learnings to your team and help connect the dots.

Employer Value: Top 5 Reasons to Support Engagement

1. Gain Company Influence & Visibility

Paid sponsorship opportunities are always available (and appreciated) but are often limited to financial contribution, and the benefit of company logo and online web banner opportunities. Real value is in visibility of your brand through your people. Supporting your employees to lead and engage puts your brands’ voice in a position of influence and contribution. Imagine if your company could influence industry guidance on topics that matter most to your brand? Encouraging your employees to lead in trade and technical organizations puts them in a position to do just that.

2. Customer & Industry Insights

Engagement in industry organizations also brings ‘boot- on-the-ground’ insights on the voice and needs of your customers. This is where you will find what the real emerging needs and challenges are in our B2B world. Dave Goins, COO of Q Laboratories and a leading proponent of employee contribution to technical organizations agrees. “A key benefit Q Laboratories enjoys [of our scientists involvement]I s they get to ‘complete the picture’ when it comes to the importance to our clients on the testing we do for them, and the reasons why we approach our analytical business the way we do.” Instead of only relying on analytics, market trend reports, and legacy industry assumptions—encouraging your people to get out from behind their desks, or off the bench, and engaging with the customers and market directly will not only provide insight on their present needs, but can also give a peek into the proverbial crystal ball of needs to come and give your company a competitive edge.

3. Leadership Creation & Development

“Our employees gain valuable confirmation at these meetings” reflects Goins, “and as a result of their engagement and contributions we see careers, development and advancement accelerate for these individuals within Q Laboratories.” Putting forth employees to engage in industry organizations in leadership roles can help them develop from good to great. Not only does this provide leadership cultivation, but also opportunities to develop technical competencies at a more rapid pace with shared resources. Employees can hone soft skills too, such as emotional intelligence, conflict resolution, negotiation and collaborative skills that they will bring back to work.

4. Learn from the Industry & Contribute to Problem Solving

Industry engagement, especially from a technical perspective, allows your company and your people to collaborate and learn from others successes and mistakes. “Our people have the added benefit of having the opportunity to share experience and ideas with other highly qualified individuals who often face the same challenges our teams face every day,” says Goins. Your team can build on those insights to ensure your company’s continued success. Engagement also provides opportunity for your company to present itself as a market leader in setting policy and launching innovative solutions. With the right idea, the right platform, and the right audience, your company could be poised to be the champion and realize the success of the next “blockchain-like” revolution.

5. Your Competitors are Doing It

It goes without saying that we are all looking for that competitive edge, the premium exposure, and the increased market share for our brand and solutions. As industry organizations are recruiting members, volunteers and leaders, they are seeking engaged individuals who want to contribute and champion the organizations mission and vision. If it isn’t your people filling those roles, it will be your competition’s people. Your competitors will learn and connect in deep, meaningful ways and build relationships with your current and prospective customers. Research also shows that companies that encourage volunteering enjoy increased employee loyalty and increased employee retention. Bottom line: Supporting Industry organizations through employee engagement is good for your people, and good for business.

Quick TIPS:

  • Invest & Incentivize Engagement: Pay for memberships and meetings, and reward employee leadership and participation on committees, working groups and elected positions.
  • Formalize a Program: Partner with key industry organizations to create an ambassador program within your company to share happenings and opportunities. In the end, you will have a powerful group of engaged employees in various organizations making an impact and championing your brand.
  • Think Outside of the Lab: While encouraging technical employees to engage, also consider the less obvious team members to get involved: Sales, marketing, human resources, finance and executive-level teams. Often, industry organizations suffer from monoculture challenges and can use expertise from other professional backgrounds to improve. As a result, your team will gain exponential insights, influence and opportunities.
Ibidun Layi-Ojo, Prometric
FST Soapbox

Five Questions You Should Ask a Food Safety Assessment Provider

By Ibidun Layi-Ojo
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Ibidun Layi-Ojo, Prometric

It’s a given that the entire continuum of businesses providing food to the public must have an unwavering commitment to making certain that food is safe and wholesome. The linchpin of ensuring food safety is front-line employees, whether they work for a corner grocery store, restaurant or multi-state food wholesaler. Making sure these employees have the knowledge and credentials they need to keep the public safe is the responsibility of the employer, and that responsibility is too critical to be taken lightly, as incidences of foodborne illness can have a significant impact on a company’s reputation and profitability.

How can an employer ensure that its workers have the food safety skills they need? They can provide rigorous and continual skills assessments. Rigor is needed because food safety is a complex issue, and continual testing is important because local, state and federal regulations are modified and updated on a consistent basis.

The first step in making sure employees are equipped for their jobs is to partner with a food safety assessment provider devoted to quality and integrity throughout the examination development and delivery process.

To be certain exams are of the highest quality, a company should begin by asking a prospective assessment provider this question: Do you work with subject matter experts (SMEs) from the food safety industry to develop your exams? Discussions should continue only when it is confirmed that SMEs are heavily involved in the test development process.

There are several reasons why subject matter experts (SMEs) are critical to this process. Their real-world experience in food safety provides a wealth of knowledge from a variety of viewpoints. And applying that knowledge to developing exams means those exams will accurately assess employees’ ability to conscientiously use good food safety practices on the job. By working with SMEs on a continuing basis, the assessment provider also can make sure that the content of exams can be promptly and effectively updated as regulations and best practices evolve.

The right food safety assessment provider, however, does more than just solicit input from SMEs; it works side by side with them throughout the test creation process: Design, development, construction and analysis. As noted earlier, this collaboration also must be ongoing to make certain that exam questions stay current with advancements and amendments in the food safety regulatory landscape. By continually updating exam questions, exams don’t need to be recreated from “square one,” saving companies time and money, while also protecting the public.

The best food safety testing and assessment providers don’t rely solely on SMEs for expertise. Rather, they develop and refine their own knowledge and insights, and continually monitor and react to both developments in the food industry and changing requirements of the workforce in each industry sector. That way, exams for personnel in any industry segment can be thoroughly based on questions and challenges found on the job each day.

Another critical question for a prospective food safety assessment provider is whether the company’s work is in-line with accepted standards for designing, delivering and evaluating exams. The two most widely-accepted standards are those of the American National Standards Institute (ANSI) and Educational Testing Service (ETS). These organizations’ standards are designed to make sure exams meet precise criteria for measuring a test taker’s performance accurately and fairly.

Like any member of the food service industry, a food safety assessment provider also must maintain sufficient stock to serve the needs of its clients. That is, it must maintain a large inventory of exam questions for each exam it offers. Should questions become fixed, exam integrity could be compromised as test takers would then have the opportunity to share question content. A large inventory of exam questions enables the assessment provider to more precisely tailor questions to specific workplace scenarios.

In addition, just as employers must continuously evaluate on-the-job performance of their workforce, food safety assessment providers also must continually evaluate the performance of the questions on their exams. This evaluation should be performed both as exams are developed and after they are deployed. Such a before-and-after analysis is the only way to verify that an exam will provide an accurate measure of employee knowledge and their ability to apply that knowledge.

So, if you are actively looking for a food safety assessment provider, be sure to ask them the right questions:

  1. Do you work with SMEs from the food safety industry to develop your exams?
  2. Are the SMEs involved throughout exam development?
  3. Do your tests meet widely accepted standards for accuracy and fairness?
  4. Do you maintain a broad and deep inventory of exam items?
  5. Are your test items continuously evaluated?

Then, be sure you get the right answers.

Visit www.prometric.com/foodsafety to view a panel discussion from the 2017 Food Safety Consortium on creating the right food safety assessment. Part 2 of this series will include information on developing rigorous, reliable, and relatable items that are tested and continuous.

3M Food Safety

From Culture To Compliance: The Link Between Food Safety Culture & Audit Preparedness

3M Food Safety

On Tuesday, December 5th, 3M Food Safety and Neumann Risk Services will host the final part of a 4-part webinar series on the Food Safety Modernization Act (FSMA). A special panel discussion of food safety experts will provide insight into how a robust food safety culture can positively impact audit preparedness and signal a culture of compliance.

Attendees will learn what a strong food safety culture looks like and how it can help comply with FSMA and the Safe Quality Food (SQF) Code. The free webinar will be recorded at the 2017 SQF International Conference in Dallas on November 9. It will conclude with a live Q&A for attendees and be offered on-demand to webinar registrants.

The first three webinars are currently available for on-demand listening at the 3M Health Care Academy, and each presents the opportunity to learn about the challenges companies are facing in operationalizing FSMA rules. The webinars offer real-world insight into how companies streamline implementation and execution of food safety plans, supply chain programs and other FSMA-driven programs.

Melanie Neumann, Neumann Risk Services
Melanie Neumann Neumann Risk Services, LLC

Melanie Neumann, president, Neumann Risk Services, a Matrix Sciences Company, will be moderating the panel discussion. Panelists will include:

  • Bill McBride, principal and managing director of Foodlink Management Services and SQFI Asia Pacific representative
  • Dr. Lone Jespersen, principal and founder, Cultivate
  • Dr. Martin Wiedmann, Gellert Family professor in food safety, Cornell University
  • Dr. Jay Ellingson, corporate director of food safety and quality assurance, Kwik Trip, Inc.

The webinar will take place on Tuesday, December 5 at 1:00 p.m. Central Standard Time. To sign up for the webinar, click here.

FoodSafetyTech's Food Safety Training Calendar

FoodSafetyTech Introduces The Food Safety Training Calendar

By Food Safety Tech Staff
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FoodSafetyTech's Food Safety Training Calendar

FoodSafetyTech introduces the industry’s only Food Safety Training Calendar. This calendar is a comprehensive, user-friendly tool that will become invaluable for food industry professionals searching for training courses.

“The calendar is searchable by region, date and category,” says Rick Biros, President of Innovative Publishing Group. “Our primary reason to bring this to the marketplace is to help companies with the daunting task of finding training courses that meet specific criteria, such as the location, topic or timing.”

Calendar categories include:

  • Food Fraud & Food Defense
  • FSMA | PCQI | FSPCA | FSVP
  • GFSI Standards (BRC, FSSC 22000, SQF)
  • General Food Safety
  • Food Science
  • ISO Standards
  • Good Manufacturing Practices
  • HACCP | HARPC
  • Retail & Hospitality
  • Sanitation | Hygiene | Cleaning

Visit the calendar today at www.foodsafetytech.com/trainingcalendar.

If your organization is interested in listing courses in the calendar, please contact Marc Spector at 516-270-5344 or mspector@innovativepublishing.net.

Deirdre Schlunegger, Stop Foodborne Illness
Food Safety Culture Club

The Food Safety Culture Conversation

By Deirdre Schlunegger
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Deirdre Schlunegger, Stop Foodborne Illness

I learn and remember visually and I was recently thinking about the food safety world and culture; how the fabric of the culture is woven together with people who care about people. After all, that is what it comes down to, people who cultivate, grow, harvest, produce, distribute, deliver, store, prepare, serve and eat safe food. When there is a breakdown of the weave, people become ill and some die, families are devastated, business fails and trust is broken. The system fails.

It really comes down to each weaver, regardless of the level of responsibility performing their duty, knowing that they are the link between health and illness, success and failure, life and death. So, the question is how do we make sure that each person who comes in contact with food products is thoroughly educated, truly understands the impact and has a breadth of awareness of the importance of food safety?

Many companies are admirably deeply invested in food safety training. Organizations share food safety tips about safe food practices, including Stop Foodborne Illness. Stop Foodborne Illness employees and volunteers bring the stories of foodborne illness to light each time we speak, are present at conferences, participate in food safety trainings, deliver video messages and send out newsletters. We work with those impacted and pair them with others who have experienced the same thing and offer them an outlet to share their stories.

What more can we do? 3000 people in the US die each year, 128,000 are hospitalized and 48 million become ill. The numbers are much too high. Let’s keep the food safety culture conversation going and improvement in training and practices and ideas flowing. Here is one such story to start the conversation.

Tressa, Chloe, and Luke

 

Roslyn Stone

The Changing Landscape of a Foodborne Illness Outbreak Response

By Roslyn Stone, MPH
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Roslyn Stone

Recent high-profile foodborne illness outbreaks appear to have an enduring impact for the entire industry – from when and how health departments respond to alleged illness to how a single tweet wreaks havoc. The bar for when a comprehensive response is required is lower and the extent and nature of the required response has changed.

Here’s what we’ve learned:

Health departments are receiving more complaints from consumers. Although much of this is believed to be related to the high-profile outbreaks, some are a result of health department websites making it easier to report illness. A few years ago, guest illness reporting required calling the health department during business hours, working your way through complex voicemail options until you reached a recorded line to leave a message about your illness. Today, most health departments in large cities and many in smaller counties, have simple on line reporting systems available 24/7. So when someone isn’t feeling well at midnight, and is sure it’s from the last thing they ate, they go online and report the illness.

Health departments are now more often following up on single reports of illness and reports of illness that are inconsistent with most foodborne illness incubation periods. This is creating a large burden for already short-staffed departments, but in response to what the public now expects. In the past, they might have replied to the ill guest and explained that they’d received no other reports, that most foodborne illness has a longer incubation period and refer the illness to personal physicians if a follow up is clinically appropriate. But today, we’re finding many health departments dispatching inspectors for even a single complaint that doesn’t appear consistent with incubation periods for that meal.

There’s increasing pressure on health departments to go public with illness events – even if the illness is no longer ongoing or creating a public health risk. The foodborne illness legal community has made it clear that they believe the public has the right to know about any and every foodborne illness. And some health departments are responding to that pressure – without their being an on-going public health risk; which would have been the trigger in the past.

Guest complaints about illness are occurring more frequently. Every single one of our clients is reporting an on-going uptick in guest reports of illness. We’re not clear if it’s that consumers are more aware of illness, more concerned or more likely to associate it with a restaurant or food service provider. But the entire industry is seeing an increase in guest reports of illness. And every guest assumes it was the last meal they ate.

How you handle any guest complaint about illness is even more critical than it was a few months ago. Here’s why: if you don’t’ respond to the guest quickly and listen with authentic empathy, that guest is far more likely than ever before to tweet about you, write a bad review, post on social media or contact the media. You need to act quickly and it doesn’t matter if it’s a weekend or holiday. Waiting until Monday morning is not an option.

Noro season is year-round now… it’s no longer the winter vomiting disease like it is called in some places. Noro virus outbreaks continued in California (and elsewhere) until after the school year ended. We need to be alert to Noro all of the time.

Fourth of July
Fourth of July was an unusually quiet day in the restaurant, quieter than anticipated (meaning more prep done than needed). The next day, two employees called out sick. A day later, two guests (small parties) called the restaurant reporting illness and later that day, two more larger parties emailed their reports of illness through the corporate website. It took another 24 hours to match these multiple illness reports through three different channels. It didn’t trigger a full-blown response and implementation of the noro sanitizing protocol.
THE FINAL TALLY: 40+ guests reporting sickness and nearly half of the staff.
THE LESSON: Coordination of reporting mechanisms so that you see a potential problem and respond at the earliest point when you can have the greatest impact in minimizing risk.

Employees continue to work sick. There are so many reasons that employees work sick and it has little or nothing to do with paid sick time. They work sick because they’re not very sick, they don’t understand that any gastrointestinal upset may be a sign of foodborne illness, they don’t want to disappoint their manager or they don’t want to let their team down. They’re working sick for altruistic reasons without understanding the potential ramifications. We have a long way to go in educating managers and employees about what “sick” looks like, what can happen from working sick and why we need to work together long term to change this set of behaviors.

Employee Exclusion Policies need to be revisited. Someone is shedding the Noro virus for twenty-four hours prior to become symptomatic and then at very high levels for three days after symptoms end. Sick employees need to be excluded for much longer than they currently are in most restaurants and food service establishments to control Noro outbreaks.

Employee Illness on Days Off are as critical to crisis prevention and response as illness on work days. You need to know if an employee was sick on a scheduled work day or on a day off. As we discussed previously, they were shedding the Noro virus before they got sick and for days after. Your illness response plan needs to include a very robust tool for employee illness reporting – one that is as easy to use seven days a week and raises an alert to management when there are two or more sick employees.

It’s time to redraft and recommunicate the definition of a potential crisis in your organization. In the past, we previously used the following definitions of what defined a potential crisis for a restaurant or foodservice group:

  • Two or more employee illness reports (for same time period and symptoms)
  • Two or more guest complaints (from different parties for same time period)
  • One confirmed employee illness (with a communicable disease)

Your new definition must be broader and reflect the lower trigger points for action. It may include one guest complaint from a large party, illness in a neighboring school, social media buzz about illness from your location and / or a health inspection in response to a guest complaint of alleged illness.

The takeaway: the lessons learned continue to evolve and new ones emerge with each new outbreak. Making sure we identify and share these lessons across the industry and your organization is critical for being prepared to first identify and then quickly respond to the next threat that comes your way.

FSMA Brief: Industry Challenged by Training and Produce Safety Rule

By Maria Fontanazza
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With several FSMA compliance dates now in effect, much of the focus is on where companies need help. According to Kathy Gombas, former deputy director at CFSAN, the industry is struggling with FSMA training. Many companies don’t understand the FSMA rule exemptions and supply chain requirements, and they just don’t know where to start. “Industry needs affordable and timely resources,” said Gombas during a panel discussion at the Food Safety Summit earlier this month. “There are a lot of tools out there, but they’re costly.”

Efforts are underway to address these challenges. FDA has issued more than a dozen guidance documents pertaining to the rule. In addition, tools such as model plans and templates can help companies with their food safety plans, and the agency is almost ready to publish a web-based food safety plan builder that will be freely accessible on FDA’s website, according to Gombas. Several sources of technical assistance are available, including state and trade associations, academia, and the technical assistance network (TAN). However, when companies have inquiries, the key is to provide them with a response in a timely manner, said Gombas.

The Produce Safety rule is another hot spot for hurdles. Although 90% of it aligns with Good Agricultural Practices that have been in place for more than a decade, industry’s response to the rule remains one of fear and confusion, said David Gombas, former vice president of technical services for the United Fresh Produce Association. “Water testing is probably the most complicated aspect of the regulation,” he said. The rule calls for testing procedures that many produce companies never had to conduct before. Some testing must be done within a certain period of time, and the lower number of testing labs in rural areas of the United States will pose a problem for some producers, warned David Gombas.

There is also confusion among producers regarding whether they should follow the Produce Safety Rule or the Preventive Controls rule, which could significantly impact the steps they must take to be in compliance of either rule. To further complicate matters, Gombas pointed out that many foreign suppliers aren’t even aware that they have to be in compliance with the rule. Finally, the Produce Rule does provide a lot of room for flexibility, so Gombas predicts much of the responsibility will fall on the agency inspectors and how they expect rule to be met.

 

Vulnerability assessment

Protecting Food Against Intentional Adulteration: The Vulnerability Assessment (Part One)

By Debby L. Newslow
2 Comments
Vulnerability assessment

FDA, as part of FSMA, released its rule titled “Protecting Food Against Intentional Adulteration” on May 27, 2016. This rule was proposed in 2013. FDA received and responded to 200+ comments prior to its final release.

FDA states that this rule “is aimed at preventing intentional adulteration from acts intended to cause wide-scale harm to public health, including acts of terrorism targeting the food supply. Such acts, while not likely to occur, could cause illness, death, [and] economic disruption of the food supply absent mitigation strategies.”1

The rule requires a documented “Food Defense Plan” that at a minimum includes the following:

  • Vulnerability assessment
  • Mitigation strategies
  • Procedures for food defense monitoring
  • Food defense corrective action procedures
  • Food defense verification procedures
  • Records confirming implementation, maintenance and conformance to the defined requirements
  • Evidence of effective training

As a food safety professional with more than 30 years in the industry, reviewing this rule brought back many memories. These memories combined with information gained from a recently completed Food Defense/ Crisis Management workshop presented by Rod Wheeler really set my brain into motion.2

Years ago, industry focused on crisis management and product recall. Requirements included having a crisis management team that was led by associates representing both upper and middle management. In addition, most programs included the following:

  • Posted identification of the crisis management team (i.e., pictures, phone numbers, etc.)
  • Specific training for receptionist and guards
  • Mock crisis exercises (i.e., fire drills)
  • Planned crisis calls to the operation’s direct incoming phone numbers (i.e., receptionist and guards)
  • Mock recalls (from supplier through finished product and distribution)
  • Security inspections which may now be considered the pre-cursor to today’s “Vulnerability Assessment”

With the introduction of the GFSI approved schemes (FSSC 22000, BRC, SQF, GlobalG.A.P., Primus, etc.), requirements for crisis management, emergency preparedness, security programs, food defense training and continuity planning gained an increase focus. Do any or all of these programs meet the requirement for a “vulnerability assessment”?

In the 2013 publication, Food Safety Management Programs, this subject-matter chapter was titled “Security, Food Defense, Biovigilance, and Bioterrorism (chapter 14)”.3 An organization must identify the focus/requirements that are necessary for its operation. This decision may relate to many different parameters, including the organization’s size, design, location, food sectors represented, basic GMPs, contractor and visitor communication/access, traceability, receiving, and any other PRP programs related to ensuring the safety of your product and your facility. Requirements must be defined and associates educated to ensure that everyone has a strong and effective understanding of the requirements and what to do if a situation or event happens.

Confirming the security of a facility has always been a critical operational requirement. Many audits have been performed that included the following management statement: “Yes, of course, all the doors are locked. Security is achieved through key cards or limited distribution of door keys, thus no unwanted intruder can access our building.” This statement reminds me of a preliminary assessment that I did not too long after the shootings at a Pennsylvania manufacturer in September of 2010. The organization’s representor and myself were walking the external parameter of a food manufacturer at approximately 7:30 PM (still daylight). We found two doors (one in shipping and one accessing the main office), with the inside door latch taped so that the doors were not secure. The tape was not readily evident. The doorknob itself was locked, but a simple pull on knob opened the door. Our investigation found that a shipping office associate was waiting for his significant other to bring his dinner and was afraid that he would not be at his desk when she arrived. An office associate admitted that that door had been fixed to pull open without requiring a key several months earlier because associates frequently forgot their keys and could not gain access to start work.

Debby Newslow Debby Newslow will present ” Sanitary Transportation for Human & Animal Food – Meeting the new FDA Requirements” at the Food Safety Supply Chain Conference  | June 5–6, 2017 | Attend in Rockville, MD or via webcast | LEARN MORE

We also observed a large overhead door adjacent to the boiler room along the street side of the facility open, allowing direct access to the processing area by passing through the boiler room and then the maintenance shop. It was stated that the door had been opened earlier in the day waiting for the delivery of new equipment. No one at the time knew the status of the shipment or why the door was still open.

Finding open access to facilities is becoming more and more common. A formal vulnerability assessment is not necessary to identify unsecured doors (24/7) in our facilities. Education and due diligence are excellent tools for this purpose.

Another frequently identified weakness is with organization’s visitor and contractor sign-in prerequisite programs. What type of “vulnerability” are we creating for ourselves (false confidence) with these programs? Frequently these programs provide more questions than answers:

  • Does everyone really sign in?
  • What does signing the visitor log mean?
  • Are visitors required to show identification?
  • Are the IDs actually reviewed and if so, what does this review include?
  • Who is monitoring visitors and contractors and are they trained?
  • Do all contractors have to sign the log or are they allowed to access the building at different locations?
  • Do those contractors who make frequent or regular trips have their own badges and/or keys (keycards) so they don’t have to take the time to sign-in (i.e., pest control, uniform supplier vending services)?
  • How are contractor badges controlled?
  • Are visitors required to be accompanied during the visit or does it depend on the visitor and whom they are visiting?
  • Are visitors and contractors trained in company requirements?
  • Do visitors and contractors have an identifying item to alert your associates of their status (i.e., visitor badge, visitor name badge, specifically colored bump cap, colored smock, etc.)?
  • How are truck drivers monitored? Do they have a secured room for them or do they have complete access to the facility to access the restrooms and breakroom?
  • How are terminated associates or associates that have voluntarily left the company controlled?
    • Can these associates continue to access the facility with keys, access cards, or just through other associates (i.e., friends or associates that did not know that they were no longer an employee)?
  • How many more questions can there be?

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Erika Miller
FST Soapbox

Employee Buy-in to Ensure FSMA Compliance

By Erika Miller
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Erika Miller

Getting employees on board can be one of the most difficult parts of any major change within a company. When things are operating just fine from the perspective of the employee, the cries of, “but we’ve always done it this way!” can be deafening. As a manager, it is our job to explain the new requirements in a way that encourages buy-in from employees at all levels of the organization, and to always present a united front with the company, even if we do not fully understand why a change is important. It is almost a guarantee a business would not spend money implementing a major change if there was not an impetus behind it. One crack in the façade can lead to an entire shift becoming demoralized and disheartened.

Compliance with FSMA is no exception. Although the aim of the act is to reduce food safety risks to the population of the United States, the added paperwork and regulatory requirements can seem onerous to the employees responsible for doing the work. I would encourage any managers who are experiencing some feelings of “why me?” to search YouTube for the videos made by families touched by major foodborne illness outbreaks. The pregnant mothers whose babies are infected with Listeria from deli meat sandwiches are particularly heartbreaking for those who have children.

Once a manager has convinced him or herself of the importance of compliance with the new food safety regulations, it’s time to get your employees on board as well. If you can, show them the same videos you saw to encourage their buy-in. Listeria is a danger in any plant handling a ready-to-eat product or one that could be improperly cooked by the end user. Remember, cooking instructions do not absolve the manufacturer of the responsibility to produce food free of hazards! With the internet, impactful videos are only a click away. Just remember to always fully vet the video before attempting an at-work viewing party—lots of people on the internet have senses of humor that may not translate well to the workplace.

Making the issue personal also works well. This is a great way to get the message home about allergens. In any group of associates, chances are good that at least one of them will have a close friend or family member who is affected by a food allergy. Ask people to raise their hands if they know anyone who is allergic to food. Ask them what that person must do to protect themselves. Frequently, the answer is that the allergic consumer can only read the label. This is a great teaching tool for the importance of proper labeling and can be used as a lead-in to the introduction of a new Allergen Preventive Control, if one is required. Ask the employees to visualize the people they know with food allergies when completing the required records, or performing the onerous tasks, and imagine themselves as the last line of defense.

Many companies employ the services of temporary agencies. These companies can offer a great solution for a company that is concerned about the exposure to litigation that can occur through employee separation. Some industries have high levels of turnover or seasonal operations, which can prove difficult to manage for busy HR departments. Turnover can lead to a loss of accountability as well, such as when an employee informs you that their training was deficient (leading to a major snafu). If their predecessor was not in the position long enough and the chain of training was broken, it can take a substantial investment of time and energy from a senior individual to train that relatively low-paid position back to base minimum level. Outsourcing some of the work to a temporary agency can seem like a godsend at first. They find them, they train them, and all the hiring company must do is eliminate downtime. Who wouldn’t?

However, over time, many companies find the time and money they saved at the outset comes back around to bite them in the end. Temp agencies often do not keep good records, and if you are relying on them to deliver crucial introductory food safety training before they send candidates to you to begin, you may end up in a bind when your auditor or FDA investigator asks to see your training records. The obvious solution is to bring all training back in-house, but that can partly defeat the purpose of having the temp agency in the first place.

FSMA

FDA Updates on FSMA Training

By Food Safety Tech Staff
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FSMA

Today FDA updated its FSMA training strategy to reflect the progress made during 2016. The program, which targets farmers, small food processors and small produce merchant wholesalers, includes the following updates:

  • Cooperative agreement for small and mid-size businesses involved in local food production awarded to the National Farmers Union Foundation
  • Cooperative agreement for preparing food producers in Native American tribes awarded to the University of Arkansas in Fayetteville
  • Federal grants awarded for establishing regional centers to facilitate training under FDA’s partnership with USA’s National Institute of Food and Agriculture