For consumers and brands alike, the damaging impact of mislabeling or neglecting to clearly outline an allergen can be colossal. Therefore, to prevent a health and business disaster, best practices around allergen labeling must be top of mind. Luckily, technology can help, and the farm-to-fork transparency provided by a centralized and digitized modern label management system can ensure organizations improve responsiveness and accuracy while reducing costs beyond those saved by mitigating recalls.
No one wants to face a recall, but have you done enough to prevent one from happening to you? More than 650 food products were recalled last year in the United States alone. And one of the leading causes might just be the easiest to prevent: Undeclared allergens.
According to the Q2 2019 Stericycle Recall Index, undeclared allergens are the leading cause of U.S. food recalls, accounting for 48.4% of food recalls from the FDA and 62.9% of food pounds recalled by the USDA. This statistic becomes more alarming considering that roughly 11% of US adults have a food allergy, according to JAMA.
Enacted in 2004, the Food Allergen Labeling and Consumer Protection Act (FALCPA) stipulates that all packaged food regulated under the Federal Food Drug and Cosmetic Act (FFD&C) comply by listing major food allergens. “Major allergens” refers to milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, and soybeans, and for nuts and shellfish, the species must be declared.
For brands, the damaging impact of mislabeling or neglecting to clearly outline an allergen can be colossal, resulting in costly recalls or litigation. However, the impact to consumers can be even greater when one small mistake can cause serious illness, or worse, death. To prevent a health and business nightmare, best practices around allergen labeling must be top of mind.
However, with constantly changing legislation, this can be easier said than done. For instance, in a move that outpaced the FDA, Illinois issued a state law requiring sesame labeling. And in the UK, Natasha’s Law was recently introduced, requiring companies to label all food ingredients on fresh pre-packaged food after 15-year-old Natasha Ednan-Laperouse died of a sesame allergy from a sandwich that didn’t list all the ingredients.
The need for optimal allergen labeling is clear, so how can organizations ensure allergens are clearly labeled on their products and meet existing standards while preparing for future requirements?
Though the underlying principle behind a clear label is simple, the process of designing such labels can be multifaceted and difficult to streamline—especially if labels are designed, printed and managed by separate users across a franchise or store network. And this challenge is multiplied further when products reach across international boundaries. But technology can help, and the farm-to-fork transparency provided by a centralized and digitized modern label management system can ensure organizations improve responsiveness and accuracy while reducing costs beyond those saved by mitigating recalls.
Disorganized Sprawl: A Major Hurdle to Effective Labeling
When implemented properly, modern label management can cost-effectively centralize labeling, reducing inefficiencies and human error. However, before this can happen, there are a few common roadblocks that may make standardizing the labeling process challenging.
One issue may be a sprawl of legacy equipment that is not integrated into a cohesive network. For instance, a legacy labeling system may only support certain label printers while certain manufacturers of direct marking equipment may only support their own propriety brand of printers. In another sense, a lack of standardization can also make it difficult to efficiently integrate labeling with other business solutions like manufacturing execution systems (MES) and enterprise resource planning (ERP) systems.
A damaging impact of sprawl is adoption of a wide range of different labeling applications across various facilities. This will result in inconsistent label formatting, the need to create the same label multiple times, and the need to accommodate different systems and printers. Consequences of this may be a lack of centralized storage when everything is saved locally, complex user training encompassing many software programs, an increased burden on IT, and a great deal of extra administration and human intervention to maintain and update labels.
Another problem with a disorganized ecosystem for labeling is that quality assurance inevitably suffers because tracing a label’s history or implementing standardized approval processes can be difficult or impossible. To accurately track labeling, it’s necessary to have a production log stating where and when labels were produced and who produced them. Having such a log and using it effectively requires centralization or else it can become difficult to track different versions or enforce universal approval processes for altering templates.
Implementing Modernized Labeling to Improve QA
Modern label management systems can help suppliers and manufacturers standardize and control marking packaging or label production across an entire organizational ecosystem. These solutions feature a central, web-based document management system and provide a reliable storage space for label templates and label history. This will enable changes and updates to be tracked centrally, so local facilities can access uniform and accurate templates to produce labels.
An ideal label management system can also interface with a multitude of direct marking and labeling printers, even if they are from different manufacturers, and it can integrate labeling and direct marking with a business system’s master data, which eliminates manual data entry errors. This decreases upfront capital expenditures in more costly efforts to standardize equipment, provides a system that is easy to integrate with partners, saves costs generated from having to discard product or rework labels, and increases a company’s ability to implement unified, organization-wide labeling processes.
Centralized Labeling is Easily Delivered Through Cloud
To many, the thought of migrating legacy labeling to a centralized system or investing a large sum of resources into centralizing labeling may seem inordinate or daunting. However, cloud technology makes migrating to a modern label management system feasible for organizations of all sizes.
With the cloud, designing labels and ensuring quality assurance becomes far more accessible. Additionally, the software-as-a-service (SaaS) model doesn’t require the capital investments or operations and maintenance upkeep associated with costly IT infrastructure and is easily scalable depending on business needs. This is a game changer for small to medium sized businesses who can now benefit from a centralized labeling system because of the cloud.
The Benefits of a “Single-source-of-truth”
In addition to other benefits, integrating a modern label management solution with other business systems allows users to access a “single-source-of-truth.” This allows for enforceable, specific user roles with logins for each user as well as traceability and transparency across all factories that produce products. The traceability from being able to monitor a “single-source-of-truth” is a critical component to farm-to-fork transparency because it can provide an accurate production log overviewing label versions and changes, so companies can pinpoint the locations and causes of labeling inaccuracies and fix them instantly.
A modern label management system also enables organizations to nimbly respond to new regulatory requirements because alterations only need to be made in one location, new templates can be previewed before going to production, and nutrition and allergen functionality can be easily formatted so that it is clear and stands out to the consumer. This increases labeling consistency and accuracy, and saves time when rules change and when new products need to be incorporated during a merger or acquisition.
Futureproofing and Ensuring Consumer Safety with Allergen Labeling
In today’s world, food and beverage manufacturers must rise to the challenge of changing regulations while meeting the call of shifting customer demands and integrating themselves within greater business ecosystems and extended supply chains. In the case of allergen labeling, this may mean preparing labels for different countries, which have varying standards for labeling allergens like sesame, royal jelly, bee pollen, buckwheat and latex, or ensuring labels can be altered quickly when new products are rolled out or when bodies like the FDA revamp standards.
Companies that implement modern label management solutions position themselves to adapt to competition and regulations quickly, implement solutions that can easily be integrated with partners in a supply chain, and streamline quality control. This can help improve productivity, reduce labeling errors, increase collaboration, and prevent product recalls. But most importantly, it helps ensure the safety of consumers everywhere.
Last month, the FDA held a public meeting to discuss its New Era of Smarter Food Safety initiative, with a rallying call to create a more “digital, traceable and safer food system.”
FDA Deputy Commissioner for Food Policy and Response Frank Yiannas made it clear that the FDA is not replacing FSMA. Rather, the goal is to build on it, recognizing changes in the food industry over the last 10 years and the technologies available to tackle new challenges.
This isn’t surprising given continuing quality issues resulting in food recalls and shelf withdrawals. Last year, two major outbreaks of E. coli that were tied to consumption of romaine lettuce made a mark on industry perceptions, impacting customer trust, brand loyalty and the bottom line of companies involved were affected. Research by Allianz found recall costs could reach $10,000,000 for significant events.
To achieve the FDA’s goal of end-to-end traceability, the amount of information carried by every food item needs to increase, as will information about its location and condition in the supply chain. Grocers are at the sharp end of the food chain, meaning everything the FDA is proposing will impact them. As well as being merchandisers, they are brand-owners in their own right. They work directly with farmers and growers, they are directly involved in food safety, storage and distribution, and they feel the impact of recalls more than most. Unlike others in the food chain, they interact with consumers daily. This is important to note, since consumers are expecting communication on recalls immediately. In a recent study of more than 15,800 global consumers, 66% of respondents noted that they expect immediate notification of a product recall and another 28% stated they expect notification within a week.1 Furthermore, 88% said if a retailer immediately informed them of an issue, they would be more likely or slightly likely to trust them. The study also found that only 16% of consumers completely trust the product information provided to them from retailers today. In short, the impact of recalls extends far beyond the empty store shelf, and gives the industry even more reason to strive for safety.
High-Tech Next Steps
The FDA plans to publish a strategic blueprint early in 2020 of planned actions to meet its goal, but food brands and grocers need not wait to act. Proven technologies like brand compliance solutions, combined with emerging blockchain track and trace solutions and Internet of Things (IoT) sensors can add new depth and detail to traceability in the food supply chain, and these new technologies are already helping grocers and retailers keep consumers safe.
As retailers have sought a better means to track supply chain movements, blockchain technology has emerged as a potential way forward. Originally developed to manage financial transactions involving cryptocurrency, blockchain has proven to be capable of providing a verifiable record of the movement of goods through a supply chain. In fact, one major retailer has been piloting blockchain for more than a year and has already proven its value on produce items, cutting traceability times from more than a week to a matter of seconds. Some want to go even further and use IoT sensors to monitor the condition (e.g., temperature) of food products in the supply chain. Together, blockchain can help trace the path a product took through the supply chain and IoT can monitor the environmental conditions en route, providing a more cohesive picture of its supply chain journey.
But while supporting a few simple products with one ingredient and a one-step supply chain, such as fruits or vegetables, is one thing, scaling to address the needs of the average private brand retailer—now handling more than 10,000 active products from 2,000 production sites globally—is another. Managing the complexity of a product like tiramisu or a ready-made meal with dozens of ingredients, all coming from different sources, needs a different approach. To address the complexity, many are turning to brand compliance solutions—trusted, real-time repositories of information spanning the entire supply chain. For example, those using brand compliance solutions now have complete visibility of the ingredients in their private label products, helping them ensure labeling accuracy and transparency for consumers. Brand compliance tools also bring improved visibility of the food supply chain, enabling them to verify the status of manufacturing sites and respond quickly to food quality issues.
This combination of detailed product and supplier information makes brand compliance a foundational enabler for any blockchain/IoT-based initiative to improve supply chain visibility and traceability. For example, using brand compliance solutions, grocers can:
- Confirm the ethical compliance of the supply chain at the point of selection or review, while using blockchain/IoT to monitor the ongoing conformance to these standards
- Validate shelf life claims during formulation, while blockchain/IoT monitors logistical movement and environments to optimise products’ freshness
- Record products’ formulation and ingredients to ensure safety, legal compliance and labeling accuracy, with blockchain/IoT monitoring the ongoing conformance to these standards
- Rapidly identify potential risks across the entire formulation and supply chain, while tracking the affected batches to stores using blockchain and IoT
This convergence of static factual data (e.g., formulation, nutrition and allergens) linked to near real-time traceability and checking offers grocers confidence in the data and supports the consumer’s confidence of an actual product in their basket.
It seems clear that the food business is moving in the same direction as airlines and banks and becoming much more data driven. For grocers looking to keep pace, they will need to:
- Treat data as a core competency. This means hiring information experts, investing for the future, and using data to identify ways to deliver better, safer products.
- Create a customer-centric value promise. Grocers must go beyond regulatory compliance and use data to improve consumer transparency, support ethical sourcing initiatives, expand sustainable packaging and speed innovation.
- Go above and beyond. Rather than waiting for FDA direction or simply complying with requirements, brands should take matters into their own hands, hold themselves to high markers and get started now.
In the future, improving the way that we manage the food supply chain is not just about how well we work with trucks and warehouses; it’s about how use information. The FDA’s initiative makes a clear statement that now is the time to modernize our food supply chains. As we look ahead to a new decade, the industry can come together to improve food safety and protect consumers, and we need not wait for the FDA’s blueprint or even the new year to get started.
- Setting the Bar: Global Customer Experience Trends 2019. (2019). Oracle Retail. Retrieved from https://go.oracle.com/LP=86024.
Modern food supply chains are inherently complex, with products typically passing through multiple suppliers and distributors, as well as countries and continents, before they end up on the supermarket shelf. While global supply chains offer consumers greater choice and convenience, they also make protecting the security of food products more challenging. With additional stakeholders between farm and fork, products are exposed to an elevated risk of biological or chemical contamination, as well as food counterfeiting and adulteration challenges—potentially putting consumer health and brand reputation in jeopardy.
Given the importance of maintaining the safety, quality and provenance of food products, global regulatory bodies are placing the integrity of supply chains under increased scrutiny. In the United States, for example, the adoption of FSMA moved the focus from responding to foodborne illnesses to preventing them by prioritizing comprehensive food testing measures, enforcing inspections and checks, and enabling authorities to react appropriately to safety issues through fines, recalls or permit suspensions.1 Similarly, China’s revised Food Safety Law (known as FSL 2015) is widely considered to be the strictest in the country’s history, and seeks to drive up quality standards by empowering regulators, and enhancing traceability and accountability through robust record-keeping. 2 The European Union continues to closely regulate and monitor food safety through its General Food Law, which is independently overseen by the European Food Safety Authority from a scientific perspective.
Achieving the Highest Standards of Food Security, Integrity and Traceability
For producers, manufacturers and distributors, the heightened regulatory focus on the security and integrity of the food supply chain has placed additional emphasis on accurate record-keeping, transparent accountability and end-to-end traceability. To meet the needs of the modern regulatory landscape, food chain stakeholders require robust systems and tools to manage their quality control (QC), environmental monitoring and chain of custody data. Despite this, many businesses still handle this information using paper-based approaches or localized spreadsheets, which can compromise operational efficiency and regulatory compliance.
The fundamental flaw of these traditional data management approaches is their reliance on manual data entry and transcription steps, leaving information vulnerable to human error. To ensure the accuracy of data, some companies implement resource-intensive verification or review checks. However, these steps inevitably extend workflows and delay decision-making, ultimately holding up the release of products at a high cost to businesses. Moreover, as paper and spreadsheet-based data management systems must be updated by hand, they often serve merely as a record of past events and are unable to provide insight into ongoing activities. The time lag associated with recording and accessing supply chain information means that vital insight is typically unavailable until the end of a process, and data cannot be used to optimize operations in real-time.
Furthermore, using traditional data management approaches, gathering information in the event of an audit or food safety incident can be extremely challenging. Trawling through paperwork or requesting information contained in spreadsheets saved on local computers is time-consuming and resource-intensive. When it comes to establishing accountability for actions, these systems are often unable to provide a complete audit trail of events.
Digital Solutions Transform Food Security and Compliance
Given the limitations of traditional workflows, food supply chain stakeholders are increasingly seeking more robust data management solutions that will allow them to drive efficiency, while meeting the latest regulatory expectations. For many businesses, laboratory information management systems (LIMS) are proving to be a highly effective solution for collecting, storing and sharing their QC, environmental monitoring and chain of custody data.
One of the most significant advantages of managing data using LIMS is the way in which they bring together people, instruments, workflows and data in a single integrated system. When it comes to managing the receipt of raw materials, for example, LIMS can improve overall workflow visibility, and help to make processes faster and more efficient. By using barcodes, radiofrequency identification (RFID) tags or near-field communication, samples can be tracked by the system throughout various laboratory and storage locations. With LIMS tracking samples at every stage, ingredients and other materials can be automatically released into production as soon as the QC results have been authorized, streamlining processes and eliminating costly delays.
By storing the standard operating procedures (SOPs) used for raw material testing or QC centrally in a LIMS, worklists, protocols and instrument methods can be automatically downloaded directly to equipment. In this way, LIMS are able to eliminate time-consuming data entry steps, reducing the potential for human error and improving data integrity. When integrated with laboratory execution systems (LES), these solutions can even guide operators step-by-step through procedures, ensuring SOPs are executed consistently, and in a regulatory compliant manner. Not only can these integrated solutions improve the reliability and consistency of data by making sure tests are performed in a standardized way across multiple sites and testing teams, they can also boost operational efficiency by simplifying set-up procedures and accelerating the delivery of results. What’s more, because LIMS can provide a detailed audit trail of all user interactions within the system, this centralized approach to data management is a robust way of ensuring full traceability and accountability.
This high level of operational efficiency and usability also extends to the way in which data is processed, analyzed and reported. LIMS platforms can support multi-level parameter review and can rapidly perform calculations and check results against specifications for relevant customers. In this way, LIMS can ensure pathogens, pesticides and veterinary drug residues are within specifications for specific markets. With all data stored centrally, certificates of analysis can be automatically delivered to enterprise resource planning (ERP) software or process information management systems (PIMS) to facilitate rapid decision-making and batch release. Furthermore, the sophisticated data analysis tools built into the most advanced LIMS software enable users to monitor the way in which instruments are used and how they are performing, helping businesses to manage their assets more efficiently. Using predictive algorithms to warn users when principal QC instruments are showing early signs of deterioration, the latest LIMS can help companies take preventative action before small issues turn into much bigger problems. As a result, these powerful tools can help to reduce unplanned maintenance, keep supply chains moving, and better maintain the quality and integrity of goods.
While LIMS are very effective at building more resilient supply chains and preventing food security issues, they also make responding to potential threats much faster, easier and more efficient. With real-time access to QC, environmental monitoring and chain of custody data, food contamination or adulteration issues can be detected early, triggering the prompt isolation of affected batches before they are released. And in the event of a recall or audit, batch traceability in modern LIMS enables the rapid retrieval of relevant results and metadata associated with suspect products through all stages of production. This allows the determination of affected batches and swift action to be taken, which can be instrumental in protecting consumer safety as well as brand value.
Using LIMS to Protect Security and Integrity of the Food Supply Chain
Increasingly, LIMS are helping businesses transform food security by bringing people, instruments and workflows into a single integrated system. By simplifying and automating processes, providing end-to-end visibility across the food supply chain, and protecting the integrity of data at every stage, these robust digital solutions are not only helping food supply chain stakeholders to ensure full compliance with the latest regulations; they are enabling businesses to operate more efficiently, too.
- FDA. (2011). FDA Food Safety Modernization Act. Accessed October 3, 2019. Retrieved from https://www.fda.gov/food/food-safety-modernization-act-fsma/full-text-food-safety-modernization-act-fsma.
- Balzano, J. (2015). “Revised Food Safety Law In China Signals Many Changes And Some Surprises”. Forbes. Accessed October 3, 2019. Retrieved from https://www.forbes.com/sites/johnbalzano/2015/05/03/revised-food-safety-law-in-china-signals-many-changes-and-some-surprises/#624b72db6e59.
During the past year, the headlines have been filled with stories of foodborne illness, product recalls, and consumers becoming sick from tainted food. In a Q&A with Food Safety Tech, Sean O’Leary, CEO at FoodLogiQ, talks food safety, traceability, and how small percentages can translate into big victories for the food industry and for the people they serve.
Food Safety Tech: From your perspective, what is the current sentiment of consumers with regard to food safety?
Sean O’Leary: Over the last few years, the consumer mindset has changed about food in general. We’ve watched fad diets come and go; however, the interest in healthy ingredients and the concern about where food comes from has graduated from a passing trend to a full shift into the public consciousness. Consumers are much more discerning about what they eat; they also demand to know where their food comes from, how it was produced, and how it got to their table. We are living in the age of transparency, and consumer expectations are high.
And who can blame them? CDC statistics tell us that approximately 48 million people get sick every year from foodborne illnesses—and that’s just in the United States; 128,000 of them end up in the hospital. When a person is admitted to the hospital, it affects more than just that one individual. If the patient is the sole breadwinner of their family, their illness affects the entire family. If the person who gets sick is a child, there can be long-term consequences that trickle down to his or her whole community. And when you consider that 3,000 people die every year from foodborne illness—that’s one 9/11 every year. That’s unacceptable, because this is a preventable issue, and unfortunately, these illnesses are an underreported public health problem.
My challenge to the food industry is simple: What if we made just a 1% improvement in the number of cases of foodborne illness? That seems like such a small percentage, but when you do that math, that’s 480,000 people who don’t get sick this year; 1,280 people who aren’t admitted to the hospital; and 30 people who don’t die. Those are significant numbers.
FST: To help shed additional light on this subject, FoodLogiQ conducted a national survey to tap into how U.S. consumers feel about issues related to food transparency. What did you learn from those consumer responses?
O’Leary: We polled more than 2,000 people to gauge their sentiment around food traceability and their expectations for food companies regarding foodborne illness and product recalls. The survey also posed questions around consumer preferences regarding their food sources and how they are identified on food labels and menus. The results were enlightening, to say the least.
We learned that a brand or restaurant will pay a high price in terms of customer loyalty if they experience a food recall due to consumer illness. And those customers have some strong opinions regarding how quickly the brand or restaurant should address a food safety issue.
- 35% of survey respondents told us they would avoid an affected brand or restaurant for a few months, and maybe they would return after the issue had been resolved. Meanwhile, nearly 25% admitted they would never use the brand or visit the restaurant again.
- Of the respondents who say they care about the quality of the food they eat, 55% say they expect a recall to be executed within 24 to 48 hours.
In reality, it sometimes takes weeks for a product to be pulled from the store or restaurant. This is frequently due to communication issues, since everyone along the supply chain—the grower, supplier, packing and distribution centers, corporate office, and the retailer or restaurant—all must be notified, and a recall plan must be set in motion. Unfortunately, that communication process takes time. When that communication takes place via email or by phone call, the people responsible for pulling product may not have the information they need or may have received misinformation. This can result in lag time, and potentially unsafe product can still get into the hands of consumers.
The faster a food company can address a recall situation and return to business as usual, the faster customers will come back. But comprehensive supply chain transparency is needed to be able to make swift, accurate decisions during this time of crisis. By having a robust end-to-end traceability program and technology that provides real-time data and visibility, companies facing a recall can isolate and surgically withdraw the tainted product out of the supply chain without recalling more items than necessary. That limits the disruption and the waste of good food, which saves the company money.
FST: You recently attended the FDA’s “A New Era of Smarter Food Safety” public meeting in Maryland. What do you think this new campaign will mean for the food industry?
O’Leary: FoodLogiQ was honored to have the opportunity to share our intricate knowledge of the food supply chain, as well as best practices regarding whole chain traceability during this monumental meeting with the FDA with more than 250 food industry leaders.
In retrospect, one thing is clear—we’re in the midst of a pivotal time of change for the world’s food supply chain. In the United States, the food industry remained status quo for decades, but the introduction of FSMA has brought increased scrutiny and accountability; I think it’s made every food company pause and evaluate where they are with regard to food safety, and that’s a good thing. And now, with the launch of the “New Era” campaign, we’re coming together in a collaborative fashion to map out how technology tools, prevention measures, new business models, and an evolving culture of food safety can be merged as a framework for a long term food safety solution. I agree with the FDA; ‘Smarter Food Safety’ is people-led, FSMA-based, and technology-enabled. It will take all of us working together to reach that goal.
When it comes to mainstream consumer food brands, customers expect to receive the same product each time they buy it. That consistency brings consumers back to the same brands over and over again. Unfortunately, the same can’t be said about products sold in the cannabis industry. Consumers aren’t building long-term relationships with brands because consumers don’t have consistent product experiences and often take their business to other brands.
This inconsistency plaguing the cannabis industry can be attributed to an unreliable supply chain, which plays out in multiple ways.
First, cannabis companies are having difficulty meeting state regulations. This happens because the legal cannabis industry is still relatively young and there isn’t a substantial institutional knowledge about regulatory compliance, nor are there any standardized best practices in place. Regulation is expensive and requires human and financial capital that most cannabis companies don’t have in place. Complicating things further, regulations keep changing, making it more difficult for compliant businesses to keep up, even when they have the best intentions.
Second, testing of cannabis products has been complicated. Because cannabis isn’t federally legal, standardized testing guidelines have not been developed, leaving individual states in charge of dictating their own requirements and enforcement framework. There have been numerous reports in the past few years of labs in California either improperly reporting testing results, or worse, submitting fraudulent results.
Third, problems also arise on production end of the supply chain—not only with consistency, but also with consumer safety. According to an estimate from New Frontier Data, approximately 80% of sales are still conducted through the black market. Many growers are using banned pesticides in amounts way beyond recommended levels. In addition, as the recent vape issue has demonstrated, black market manufactured products are being adulterated with toxic substances that pose significant health hazards to consumers.
Given these consistency challenges, the standardization of the supply chain—especially compliance, testing and safety measures—should be a top priority for new cannabis brands. Luckily, many best practices and standardized procedures can be adopted from the food, agriculture and pharmaceutical industries, where companies have successfully developed protocols to ensure safe and reliable products.
In addition to standardization and best practices, cannabis companies should also utilize the following recent innovations in transaction technology to provide peace-of-mind to both new brands and consumers that cannabis products are tested and safe.
Modernized Retail POS systems. Common in other consumer packaged goods industries, such as food, wine, beverages and soft drinks, RFID tags can be used throughout the supply chain to track products from seed to sale. These tags, like the “chips” on credit cards, hold electronically stored information about a product that can be accessed to verify compliance and safety.
QR Codes. While QR codes are mostly used today as marketing gimmicks, they actually have potential to provide true value for curious customers. Batch-specific QR codes could be applied to cannabis products to show detailed information about when and where it was made, what strains of cannabis were used, and testing results. This technology could be used to increase transparency between companies and to consumers.
Data Informatics. A strong information technology infrastructure can be put in place to collect and store inventory and customer data. That data can then be run through algorithms, AI and machine learning systems to help cannabis brands make better decisions about how to optimize the production of their products and how to achieve better results on future batches.
Video Surveillance. Granted, this is a more ‘low-tech’ approach, but effective, nonetheless. Video cameras can go way beyond security purposes. Footage can be viewed and compared to collected data sets to gain a deeper understanding of product flows, personnel movement and logistics that might impact a company’s final product. Video can also be analyzed automatically using AI to provide important insight to help a company fine tune their business strategies.
Consumers want to know that the cannabis products they purchase are safe, compliant and tested. Consumers also have a right to know what they are buying and expect product consistency over time from companies they trust. Ensuring supply chain consistency is key to making this happen as the industry matures. An experienced and trusted supply chain partner can help companies across different cannabis sectors, ranging from medical to food, and ensure product safety and consumer trust today through standardization and consistency. Ultimately, cannabis businesses want to cultivate a culture of excitement, not fear or uncertainty, to help the market flourish and bring quality products to our customers.
“As food safety leaders, it is our responsibility to actively investigate the newest technologies in the market with the goal of providing the highest level of safety for our customers. The regulatory environment is rapidly evolving from a position of hazard management to preventative control, which challenges the status quo while promoting innovation. In addition, we are actively working to build food safety cultures within our operations,” says Jeremy Schneider, business development director, food safety and quality assurance at Controlant. “On top of these mandates, we are consistently being challenged to find ways to improve quality, reduce waste, and assure supply. When taken as a collective mandate, this can be considered a challenge that allows the industry to solve previously unsolvable business problems in new and exciting ways. Utilizing the newest technologies for enhanced supply chain visibility is the solution to some of our most challenging industry-wide problems.”
Schneider has more than 15 years of experience in the food quality, safety, and regulatory sector. His experience spans managing food safety and quality systems within several fast-casual restaurant chains as well as food manufacturing. In a Q&A with Food Safety Tech, Schneider discusses some of the issues that food companies are experiencing surrounding traceability in their supply chain.
Food Safety Tech: What challenges are food companies and retailers facing when it comes to real-time monitoring of their supply chain?
Jeremy Schneider: One of the biggest challenges that the industry faces when it comes to real-time monitoring of the supply chain is where to start. As you can imagine, implementing a program that allows for an organization to monitor all shipments, including those that are shipped internationally, by ship, air freight, over the road or by rail, can be daunting.
As with all food safety programs, it is advised to take a risk-based approach to the project. Begin with the highest-risk items within your supply chain and work to your second- and third-tier items or suppliers. When implemented by category over time, you will find implementation less challenging. It is important to remember that when you begin a real-time program, you will start to discover eye-opening information about your supply chain. It’s important that you develop strategies to deal effectively with these incidents.
Another primary concern for the food industry is the cost of implementation, as well as the return on investment. We have found that, by implementing a real-time monitoring solution, an organization is able to dramatically reduce shipping loss because of temperature abuse. Oftentimes, the program provides a net savings for the organization. When considering the cost of wasted food, freight, liability, lost sales and labor, a real-time supply chain visibility solution becomes a cost-effective program very quickly.
FST: Are there any lessons learned from recent outbreaks or recalls regarding traceability?
Schneider: Over the last several years, the industry has made real progress towards a transparent supply chain. However, it must be said that much work is needed to meet regulatory standards and consumer expectations when it comes to traceability. As we have become accustomed to having information that provides insights into all facets of our life, the same is becoming true of the supply chain.
Being able to have business-critical data immediately, such as real-time supply chain and traceability data, is revolutionizing the industry and is allowing enterprise-wide improvements. During a crisis situation, being able to have insights into your supply chain is paramount. Unfortunately, it has become all too common for organizations to take the ‘’out of an abundance of caution’’ approach and remove all products from the supply chain, regardless of lot code or other data, to ensure consumer safety.
The consequence of such an approach is that much more product is removed than necessary, which compounds the effects of the incident. Having had the appropriate traceability information allows organizations to take a precision-focused approach, allowing for organizations to minimize the impact as much as is safely possible.
To help organizations solve this dilemma, there are a variety of technology offerings available to help companies collect and transform data so that it can be easily used. In addition, layering rich data, such as that which is created from real-time Internet-of-Things (IoT) devices and cloud-enabled software technology, helps provide dimensional insights into your supply chain information.
FST: How can companies leverage technology to be proactive in maintaining consistent tracking and tracing throughout the supply chain?
Schneider: As we enter an era of smarter food safety, each organization will be challenged to solve some of the most pressing concerns using state-of-the-art technology. The great thing about having actionable traceability data, beyond its uses to support food safety, is that it allows an organization the ability to gain insights into their supply chain at both the micro- and macro-levels.
As an example, when an organization implements a real-time temperature monitoring program, not only are they able to identify and resolve temperature deviations before they become food safety or quality incidents, logistics can then utilize the data to optimize the shipping lane to reduce costs, and purchasing is able to know exactly where a truck is located on its route. Being able to show the value that location traceability data provides across an enterprise helps to improve the organization at every level.
Last week’s seventh annual Food Safety Consortium brought together a variety of industry experts to discuss key topics around regulation, compliance, leadership, testing, foodborne illness, food defense and more. The following are just a few sound bytes from what we heard at the event. (Click on any photo to enlarge)
|“The food system today, while it’s still impressive, it still has one Achilles heel—lack of traceability and transparency.” – Frank Yiannas, deputy commissioner for food policy & response, FDA. Read the full article on Yiannas’ keynote session|
“A typical food company only has about 5% visibility into known supply chain threats.” – Ron Stakland, senior business development, FoodChain ID, Inc.
“For most of us, our supply chain is a big black hole. Why are we so fearful of technology? Is it the implementation itself? What if technology could help us solve some of those perennial problems? There are resources available to help us get there.” – ¬ Jeremy Schneider, business development director, food safety and quality assurance, Controlant
“We’ll see more robotics enter the food space.” – Gina Nicholson Kramer, executive director, Savour Food Safety International
|“Changes are happening; you can choose to face it or ignore it. We’re at least 10 years behind on technology. Automation/technology is not a new term in aerospace, etc., but to us [the food industry], it is. We will get there.” – Melody Ge, head of compliance, Corvium, Inc., on how industry should prepare for the data-driven transformation occurring in the smarter era of food safety|
It’s okay to risk and fail, but how are going to remediate that with your employee? The more learners practice in different scenarios, the less they rely on specific examples. [They] become more adept with dealing with decision making.” – Kathryn Birmingham, Ph.D., VP for research and development, ImEpik, on employee training
“As a contract lab with the vision of testing for foodborne viruses for about 10 years—it wasn’t until about three or four years ago that we had the test kits to turn that into a reality. We also didn’t have a reference method.” – Erin Crowley, chief scientific officer, Q Laboratories, on the viral landscape of testing in the food industry
|“You have to be strong and you have to believe in yourself before you get into any situation—especially as a food safety professional.” – Al Baroudi, Ph.D., vice president of quality assurance and food safety at The Cheesecake Factory, on what it takes to earn respect as a food safety professional|
“’See something, say something’ is likely not enough. We recommend that companies develop a formal detection program that includes management buy-in, HR and governance, and policy documents, formal training and an awareness program…While FDA focuses on the insider threat, we feel that using a broader mitigation approach works best.” – R. Spencer Lane, senior security advisor, Business Protection Specialists, Inc. on lessons learned from food defense intentional adulteration vulnerability assessments
“Food safety is a profession, a vocation, [and] a way of life.” – Bob Pudlock, president of Gulf Stream Search
Food is no longer a commodity. With an increase in special interest consumer groups, it’s taking on a more nuanced character. Consumers are increasingly seeking out specific attributes for their food. Whether the focus is on organic and natural, foods with superior eating quality, or simply a better price—consumers are more discerning than ever.
Their expectations around transparency and authenticity are growing as well.
According to Food Marketing Institute research, nearly 93% of consumers are more likely to be loyal to a brand when it commits to full transparency. Transparency and traceability go hand in hand. In a study conducted by SMS Research, traceability was at least somewhat important to 75% of participants and very important to 45%.* Animal welfare emerged as a contributing factor with 75% of consumers claiming they would be at least somewhat more likely to buy beef if they knew about the animal’s living conditions.
These are useful insights but challenging to make fully actionable in our commodity-focused infrastructure that’s simply not built for the nuance of our new reality. Successful companies will design a supply chain within the existing infrastructure and industry capabilities that meets customers’ unique needs and desired attributes.
Two major retailers are developing their own supply chains to control quality. Last year, Costco announced it is bringing chicken production in-house, largely driven by its rotisserie program, to ensure size specifications are met. In April, Walmart announced it is developing an end-to-end supply chain for Angus beef. Companies like Tyson are upgrading some of their supply chains with improved traceability systems using DNA technology. The use of this technology was pioneered in North America a decade ago in partnership with IdentiGEN, a global expert identifying and tracing food products with greater precision and accuracy.
Leveraging DNA Technology
DNA traceability was first developed nearly 20 years ago in Ireland by IdentiGEN to protect market access for Irish beef. The technology can serve as the backbone for a comprehensive set of origin, handling and processing practices that work together to guarantee quality. Beyond genetics, a company’s quality improvement program should consider standards for feeding, animal health, humane treatment, environmental impact and the processing of the animal. DNA technology can help uphold these standards throughout the supply chain, providing a cost-effective way of tracking product and establishing meaningful accountability.
Here’s how the technology works. At the slaughterhouse, a DNA sample is taken from the animal, and the ear tag is then scanned to create a digital link. With this information, the origin and handling of product throughout the supply chain is verifiable, even after disassembly and packing. From a safety standpoint, the technology can support recall mitigation efforts, allowing for swift and specific identification of the animals involved, helping protect consumers and limiting financial damages.
To create the most effective supply chain, companies should still supplement DNA testing with time-tested initiatives for quality improvement, such as customer feedback mechanisms and facility audits conducted both by internal groups as well as external partners and USDA-approved auditing companies. The data collected should not be siloed but rather correlated in some capacity to create a holistic view of all supply sources and the quality they deliver.
Building a Foundation for Success
There are many elements beyond technology that come together to make traceability and quality initiatives successful. One is a company’s big-picture, strategic view. It helps to look at these programs and systems as supporting an evolving process. Continuous improvement means creating and refining the right mix of methodologies, partners and technology—it’s about evaluating and eliminating anything that no longer adds value. Some companies have banned electric cattle prods, for example, because they cause stress on the animal that negatively impacts quality. As standards continue to strengthen and the supply chain is better organized, everything works together more cohesively, and it becomes easier to continue updating and adding new elements.
The foundation for any initiative of this type must be built on a shared vision, strategy and end goals, starting at the organizational level, and then with external partners. A supply chain should be organized for better production, but it also should be organized for mutual benefit, recognizing that everyone has different goals and interests. Structure your economic models so that every link in the supply chain is pulling in the same direction. Participating in the supply chain should mean doing at least a little bit better, however each partner defines it—enhanced financial performance, higher quality, lower shrinkage or improved safety and compliance. Farmers and packers will be willing to participate in the systems—and use tools like DNA technology—if they gain insights that help them achieve their goals, sell more product and improve their bottom line. It’s all about building a system that works for everyone involved.
Consumer demand for foods that offer greater choice and a wider variety of attributes will only continue to grow. Companies can successfully mature brands through a customized supply chain grounded in increased accountability and traceability. The potential to re-engineer supply chains and meet customer needs more effectively exists across many different product categories and attributes. It’s a valuable opportunity many companies may find well worth exploring.
* The survey was conducted by SMS Research on behalf of PFG among a sample of 2,001 general consumers in the U.S., weighted to census. This survey was live on March 28 – April 1st, 2019. All statistical tests were performed at a 5% risk level. PFG had no role in survey design, data collection, data analysis or data interpretation.
When it comes to addressing food safety, did the industry really make any progress in 2018? In 2019, what new approaches or technologies can be successfully applied to prevent problems before they occur and minimize the consumer risk, minimize the market impact, and speed up the identification, isolation and recall of contaminated products?
Field-packed produce offers a unique challenge to the fresh food supply chain, as it is not processed and is not required to adhere to an FDA mandated HACCP (Hazard Analysis and Critical Control Points) process. It has been a challenge for field-packed produce suppliers to proactively identify or prevent contaminated produce from entering the supply chain. As a result, during serious contamination incidents, the reaction is to pull and destroy all suspect product from store shelves and supply chain. Due to the lack of data isolating the source of the contamination, this is the safest approach, but it’s costing the industry millions of dollars. Ultimately, our inability to prevent or quickly isolate these events causes confusion among consumers who don’t know who to trust or what is safe to eat, resulting in a prolonged market impact.
In response to the latest E. coli outbreak involving romaine lettuce, the industry has proposed a voluntary item-level label that reflects the harvest location and date, to help identify safe product to the consumer. At best, this is a stop-gap solution, as it burdens the consumer to identify safe product.
I work in the fresh produce supply chain industry. When I go to the grocery store, I examine the produce, noting the brand and various other factors. I was aware of the romaine problem and the voluntary labeling program, so I knew what to look for. But I’m an exception. Most consumers don’t know romaine lettuce is grown during the summer and fall in northern California and further south during the winter in regions that include Arizona and Mexico. Most consumers don’t know what the “safe date” for harvest really means—nor should they be required to know this information. They look to the industry to manage this. If we buy a car or microwave oven that is found to be unsafe, the manufacturer and the government are responsible for identifying the problem and recalling the product. Yet, in the produce industry, that responsibility seems to be moving to the retailer and consumer.
It’s an unfair burden, as the retailer and consumer do not have the necessary information to make a definitive judgement regarding food safety. The responsibility needs to be shared across the entire fresh food supply chain. Records about the produce need to be shared and maintained from harvest to retail.
Will 2019 be the year that we realize we can address this challenge proactively to improve the safety of our fresh food?
We need a new approach that leverages innovative technology to provide a more reliable solution. For example, irrigation water is often identified as a culprit in spreading bacteria. Yet even with regular testing of irrigation water, the results do not currently guarantee food safety. We see emerging technology that will make regular testing more reliable, accurate and affordable to facilitate more proactive management of the water supply. This will be a critical part of an overall solution for proactive produce food safety.
Blockchain technology has been hailed as a savior of food safety and traceability. Early in 2018, it was all the rage, as various sources claimed that, by using blockchain, recall times could be cut from days or weeks to seconds. But was this an oversimplification? Perhaps so, as this early hype faded by the middle of the year amidst the various food safety outbreaks that went unresolved. Then last August, Gartner, a market analyst firm, declared that blockchain had moved into the “trough of disillusionment” on its 2018 Hype Cycle for Emerging Technologies as a result of over-hyped expectations. The firm predicts that the technology may reach the “plateau of productivity” within the next decade. Can we wait another 10 years before being able to benefit from it? Should we?
We expect that blockchain trials will continue in 2019. But, while blockchain has shown promise in terms of being a secure and immutable data exchange, questions remain. What data about the produce will be entered into the blockchain? How is that data collected? Is the data validated? Bad, inaccurate or incomplete data makes blockchain relatively useless, or worse, as it undermines a trusted platform. Further, without broad agreement and adoption of data collection, blockchain can’t be successful.
For proactive management of food safety, we will also need to address both forward and backward supply chain traceability. One of the challenges realized from recent outbreaks is that it takes time to figure out what is happening. Identifying the source of the illness/outbreak isn’t easy. Once we identify a source (or multiple sources) of the contamination, blockchain—assuming that all of the necessary data has been collected—only helps to more quickly trace back produce to its origin. But, for growers, quickly understanding where all product shipped from a specific location or date is just as critical in understanding and minimizing consumer impact. Tracing product forward enables a grower to proactively inform retailers and restaurants that their product should be recalled.
Blockchain currently does not directly support this forward tracing, but can be augmented to do so. But blockchain can maintain a food safety data item, or items, that could quickly and reliably communicate product status at the pallet-level, providing instant food safety status to the current product owner, even if they didn’t have direct contact with the grower. As such, a hybrid blockchain approach, as espoused by ChainLink Research, is optimal for forward and backward traceability.
Equally important, we need to fully digitize the supply chain to enable blockchain. To make comprehensive data collection feasible, we need to automate data collection by utilizing IoT sensors at the pallet level, to properly reflect how distribution takes place through the supply chain. We need reliable data collection to properly reflect the location and condition of product distributed through a multi-tier distribution network. That level of product data visibility enables proactive management for food safety as well as quality and freshness— well beyond the current trailer-level monitoring that only monitors transit temperatures with no benefit to managing food safety. Effective data capture will define the next generation of fresh food management, as it embraces proactive food safety, quality and freshness management.
Goals for This Year
For 2019, our goals should be to embrace new approaches and technology that:
- Identify food contamination at its source and prevent contaminated food from ever entering the supply chain. We need to focus on developing new technologies that make this feasible and cost effective.
- Accurately and consistently track product condition and authenticity of fresh produce from the time it is harvested until it is delivered. IoT sensors and proactive fresh food supply chain management solutions provide this capability.
- Make it cost-effective and practical for growers, suppliers and grocers to use solutions to improve the entire fresh food supply chain. If we make the process burdensome or without a reasonable ROI, implementation will lag, and the problems will persist. But if we demonstrate that these solutions offer value across the fresh food supply chain—through reduced waste and improved operational efficiency—growers, suppliers, shippers and grocers will embrace them.