Tag Archives: transparency

Kevin Payne, Zest Labs
FST Soapbox

2019 Food Safety and Transparency Trends

By Kevin Payne
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Kevin Payne, Zest Labs

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:

  1. 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.
  2. 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.
  3.  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.

Food Safety Vs. Blockchain: Who Wins?

By Maria Fontanazza
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The jury is still out on how (and if) blockchain can contribute to a safer food supply. Whether or not there is a clear understanding of the technology, and its potential and pitfalls, is up for debate as well. “What is blockchain? This is the number one question that people have,” said Darin Detwiler, director, regulatory affairs of food and food industry at Northeastern University, who led a panel of experts as they deliberated over this hot topic during the 2018 Food Safety Consortium.

“Blockchain levels the playing field where we can connect people, resources and organizations in ways we’ve never done before to harness new ways of extracting value,” said Nigel Gopie, global marketing leader, IBM Food Trust at IBM.

What Is Blockchain?

Gopie provided an introductory definition of blockchain: Simply put, it is a series of blocks of information attached together. Each block is a box of information that stores data elements, and this data could be almost anything. Each block has a digital fingerprint associated with it; this fingerprint allows you to know that the block is unique and can attach to other blocks. When new blocks come into the chain, each block has a new fingerprint—one that is unique to that block and of the block before it. This allows the connection to happen, and enables visibility into the origin of each block.

Blockchain enables one book of business and provides three important benefits, said Gopie:

  1. Digital transactions
  2. Distributed ledger with one version of truth throughout the network
  3. Data is immutable
Blockchain, IBM, Food Safety Consortium
IBM’s Nigel Gopie breaks down the basic meaning of blockchain for attendees at the 2018 Food Safety Consortium.

Although blockchain can help to start the process of solving food issues surrounding safety, freshness, reduced waste and sustainability, the technology is only the foundation. A series of other components are important as well, said Gopie, and the following are some insights that the expert panel shared during their discussion.

2018 Food Safety Supply Chain Conference, Blockchain
Is the Food Industry Ready for Blockchain? Check out a dynamic panel about the technology from the 2018 Food Safety Supply Chain Conference.

Can Blockchain Actually Impact Food Safety?

Jorge Hernandez, chief food safety officer at Wholesome International: “To me, it’s a fantastic new technology that would allow the food industry to do a much better job of finding, from seed to fork, all of the processes and things that happen to that product. And in the future, [it] allows us to identify problems first and solve [them]. My problem is it being sold to companies…and not able to deliver on the promise… It bothers me that we are looking at a future that may or may not be there.”

Angela Fernandez, vice president, retail grocery & foodservice at GS1 US: “We’ve been working on traceability and transparency for over a decade—you have to be capturing the data needed, [and] we’re still working on getting it right. We’re just not there yet. I think it’s a great place for us to strive to go towards, but we’re still early in the stages of accepting it as a community.”

David Howard, vice president of corporate strategy at Pavocoin: “Blockchain itself is simply a technology. We’re all here because we’re just trying figure out what application we can use in business. Blockchain is a technology that can help all of you improve operational efficiencies for your bottom line.”

Is Blockchain a Barrier or a Fast Lane to Heightened Liability Concerns?

Shawn Stevens, food industry lawyer and founder of Food Industry Counsel, LLC: “I think the starting point is to ask ourselves what makes food unsafe. It’s a lack of transparency…What blockchain can do is illuminate entire segments of the industry…From a reactive standpoint, blockchain can help us identify a problem [and] solve it. From a preventive standpoint, if I have access to all this information regarding attributes and quality of supplier, I can make better decisions that protect my company.”

“We want to know more and be better informed. Once you know more, you better react and do something. If you’re getting this line of sight and you don’t react to it, that’s what exposes you to liability.”

Darin Detwiler, director, regulatory affairs of food and food industry at Northeastern University: “We need to look at the balance between the reactive use of blockchain and the proactive use.”

2018 Food Safety Consortium on Blockchain. (left to right) David Howard, Pavocoin; Jorge Hernandez, Wholesome International; Nigel Gopie, IBM; Angela Fernandez GS1 US; and Shawn Stevens, Food Industry Counsel, LLC. Not pictured: Darin Detwiler, Northeastern University.

What Barriers Does Industry Need to Anticipate?

Fernandez: “The barrier of the standards and interoperability piece—that’s a big question our community is asking us. Scalability… standards are vital…I think that opens up a different discussion when talking about private versus public blockchain.”

Hernandez: “What is my ROI? The issue I have with blockchain is not only the investment in my organization, but I have to bring my entire supply chain with me if I want to get any benefit. There’s a good value proposition, but it requires you to get everyone on board. When you’re a large organization, it’s probably not that hard to do. But a small organization like mine where my suppliers are an Amish community that sells us cheese, that’s a huge mountain to climb. They don’t have the background [or] the technology, and even if they wanted to do it, it’s a big change for them. You’re asking me to make a change in my relationship with my suppliers.”

“Take a look at it from the business continuity [perspective]. What are the changes you’re going to have to make? And that changes that have to be made by everyone who works with you? We should not stay static. We should continue to look for things. If this is the technology that is going to move us forward, let’s start getting prepared.”

Food Safety Consortium

Making Your Supply Chain Smarter, Safer and More Sustainable

By Maria Fontanazza
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Food Safety Consortium

How to build a smarter, safer and more sustainable food supply chain: This was a big topic at the 2018 Food Safety Consortium last month. David McCarthy of IBM Food Trust led a panel of experts from the retail side of the industry in a Q&A session about their biggest challenges in the supply chain, the role of digital and how to achieve a higher level of transparency.

What are the main areas in the supply chain where there’s a major need for improvement?

Sean Leighton, vice president of food safety and quality, Cargill: One of the biggest challenges that I see from a supplier perspective is people’s assumptions around what is the supply chain—our mindsets, our ability to talk with each other on “what do you mean by ‘supply chain’”?

Cindy Jiang and Scott Horsfall at the 2018 Food Safety Consortium
Cindy Jiang and Scott Horsfall (all images credit: amybcreative)

What is food safety’s role in the supply chain?

Cindy Jiang, senior director of worldwide food safety, quality and nutrition, McDonald’s Corp.: The supply chain is a supply network; it’s not linear. The most fundamental thing is to ensure there’s no disruption—that the supply chain can provide goods and food product to your customers. When you’re looking at the supply chain, [there’s a] change between the traditional thinking and the digital demand. How do you provide information in an effective way to your customers?

Howard Popoola, vice president, corporate food technology and regulatory compliance, The Kroger Company: Our supply chain means nothing if we aren’t able to deliver safe foods to those consumers in the last mile. Consumers are thinking about the experience that they’re going to have with this product. They’re not thinking about whether it’s safe or not. They’re thinking about the meal they’re going to make at home with the ingredients that they purchased.

The biggest pain point from the retailer’s perspective, when you look at us as being the last in the chain, is in transparency [and] knowing where the products are coming from. Transparency is very big for us. And it takes more than the retailer to open that door of transparency to the consumer.

What are the challenges you’re seeing in providing transparency?

Scott Horsfall, CEO, California Leafy Greens Marketing Agreement: I think a big challenge right now and in the future is communication.

Leighton: I think the winners….are going to be the ones that try to achieve consumer trust. The future is no place for the three ring binders…it’s digital. Where does the data sit? How can you provide access to them through customers?

Howard Popoola, Sean Leighton, Food Safety Consortium
Howard Popoola and Sean Leighton

How does the digital transformation play into providing transparency?

Popoola: The consumers have already trusted the food industry. There are millions of people walking into retail stores buying product. If the trust isn’t there, they wouldn’t be doing that. We erode that trust when [a consumer] has a terrible experience with that product.

How are you seeing digital transformation across the supply chain?

Jiang: Digital is one of the top three initiatives of McDonalds; how do we connect with consumers? When serving 70 million customers each day, how can we get to the transparency to understand the supply—digital is one of the answers. From the supply chain standpoint, we’re looking at the analytics. We cannot think about only one solution. We have to have different solutions to get the end results.

Popoola: I think the food industry has to see itself as a big ecosystem. If we don’t see ourselves as an ecosystem that strives for the one thing,… digital is always going to be a mirage. We have to look at what is digital and understand the fact that [we have large and small companies]. It’s not going to be one size fits all.

How long will it take the food industry to get to a completely digital operation?

Jiang: Looking at the total industry digitized—the majority of the work can be done within the next five years, [by] looking at leading companies. But in terms of total digitalization of the ood network in the U.S., I think that will take another 10 to 20 years.

Food Safety Consortium
(left to right) Howard Poopola, Sean Leighton, Cindy Jiang, Scott Horsfall and David McCarthy discuss supply chain challenges during the 2018 Food Safety Consortium

Horsfall: I think there’s a challenge with much of the farm community to get to this point. There’s also this issue with how you transmit the information. [Horsfall predicts] 10-15 years for the industry.

Leighton: Even a 100% digitized food industry has limited value if the players in the industry can’t pull together to deliver meaningful insights from it all.

What are the most promising innovations solving transparency?

Jiang: When looking at innovation, not just technology (technology is an enabler)— the most impactful innovation is human innovation: How can we work together? The GFSI platform started 20 years ago, and now it’s so impactful around the globe. [Now we’re] looking at how to harmonize food safety standards.

How can we standardize and harmonize… for ingredient suppliers?
How [can we] use the GS1 platform, numbering system to track on where the ingredient is coming from and how that product is made for us—what’s in my product?

Think about the human collaboration and how to improve where we’re at.

Poopola: I would like to tackle this from a different perspective: When we built technologies (whether off-the-shelf or customized) 20 years ago, we thought [it would be around for] the next 100 years. It’s clear today that the technology you have in place might be obsolete in five years. We have to look at the technology we’re building and acquiring today: Will it be relevant in five years?

Leighton: It’s hard to wrap my head around…deep learning and AI [artificial intelligence]. The insights we can gain from machine learning and predictive analytics. Could AI be human’s last invention?

Horsfall: In produce industry, which hasn’t always been in the front, I think that’s changing. [We’re] trying to bring AI and new technology to bear.

PattyMcDermott, ThermoFisher Scientific
In the Food Lab

How Digital Solutions Support Supply Chain Transparency and Traceability

By Patricia McDermott
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PattyMcDermott, ThermoFisher Scientific

Ensuring the safety and authenticity of food is a key responsibility of growers, producers, manufacturers and suppliers. With so many partners involved in the journey from farm to fork, tracking chain of custody data and maintaining a clear, unbroken record are essential to safeguard the quality and provenance of products. However, without proper systems to maintain transparent supply chain audit trails, businesses operating within the food industry run the risk of being responsible for adverse events that could result in health, economic or even legal consequences.

One of the biggest challenges associated with maintaining a clear chain of custody is the need to monitor the flow of raw materials, ingredients and products across increasingly global distribution networks. To successfully track food products throughout the value chain, information on product movements and quality control data must be accessible to those who need it. These systems must also remain compliant with the latest regulations, as well as ensure stakeholders can achieve the highest levels of productivity to meet consumer demand.

For players within the food supply chain to achieve transparent processes and complete traceability, robust information exchange mechanisms and integrated data management systems are key. The latest digital solutions are ensuring the integrity of supply networks by capturing and making available data from any stage of this journey for regulatory or product quality assurance purposes.

Food Safety: A Global Responsibility

The global nature of modern supply networks can make ensuring the safety and quality of food challenging. From honey and juice to yogurt and cheese, tracking the lifecycle of food products is essential to combat food fraud and adulteration, as well as safeguard consumers from harmful food contaminants, such as pesticides and bacteria. Unscrupulous behavior from businesses operating within the supply chain can, for example, cause consumers to purchase products that are not what they claim to be, and even put customers’ health at risk through exposure to potentially unsafe batches.

Given the global expansion of the food supply chain, regulatory bodies are putting increased focus on ensuring that products that pass through multiple channels and regions comply with the same regulations. By focusing on enforcing standards through audits and reviews, it becomes possible to prevent and therefore reduce the potential for adverse events occurring.1 As a result, voluntary standards such as the ISO 22000 guidelines, and mandatory regulations such as FSMA and EU 178/2002, have been put in place to set clear benchmarks for stakeholders’ responsibilities and better enforce food quality and safety.

Regulations such as these require extensive record keeping, transparent audit trails and accountability for all processes. While end-to-end monitoring of one process may be relatively straightforward, ensuring visibility for every process within a complex food supply network can quickly become an overwhelming task. In order to achieve regulatory compliance across all aspects of a supply chain, businesses must be able to integrate their data management systems to achieve full oversight. Moreover, with effective data management tools in place, businesses can organize and incorporate data from all aspects of a food product lifecycle in a compliant manner, enabling them to expand globally.

Integrating Digital Solutions for Better Outcomes

To preserve consumer confidence and brand integrity, businesses operating within the food industry are recognizing the need for automated infrastructures that can manage data, streamline processes, and ensure traceability and accountability for every product. By integrating all monitoring processes into a single system and enabling access to this information via the cloud, the latest digital data management platforms are working to alleviate the challenges associated with operating global supply networks.

Manually organizing inventory management, standard operating procedure (SOP) use, and product traceability can be difficult and time-consuming, especially if operations are on a global scale. Setting up automated processes to manage fail points using a laboratory information management system (LIMS), where they can be itemized and protocols established for potential hazards and preventive measures, can boost speed and efficiency while ensuring the highest levels of data integrity.

Routine food safety testing requires the consistent replenishment of supplies, and the failure to keep on top of inventory use can cause operations to grind to an unexpected stop. Automatic supply level monitoring and automated ordering using a LIMS can eliminate inventory fail points and help to ensure uninterrupted productivity. Furthermore, introducing electronic SOPs as part of a LIMS can define and outline workflows to prevent unintended errors and ensure reliability. Additionally, tracking and logging products using barcode readers throughout their lifecycle gives stakeholders confidence in the products they handle, and can simplify quality control and regulatory review processes.

With the need to monitor so many processes across the food supply chain, there are large volumes of instrument data, workflows and records that must be maintained. Leveraging a LIMS to collect and manage disparate data from all aspects of every process can help stakeholders to streamline workflows. From evaluating potential hazards to eliminating possible issues, having procedures tracked automatically not only transforms processes, but also simplifies quality assessment.

The latest LIMS are able to aggregate all of this data in a single cloud-based system, making this information available at the tap of a tablet or smartphone. Integrating a LIMS with laboratory equipment across food safety testing protocols allows for automated data transfer and increased lab efficiency. Data can be captured from laboratory equipment using a connected scientific data management system (SDMS), which is generated using the approved methods and SOPs available from a laboratory execution system (LES). Interfacing to each instrument using the LES ensures there are no input or copying errors. Subsequently, as process results are entered into the system, any out of specification parameters can be flagged and reported automatically.

The value of an LES within a LIMS can be seen in food safety labs where global demand drives time to market and thus the need for high production efficiency. By giving lab managers control over method and protocol management from any location, the actions of users can be easily recalled for performance monitoring and accountability purposes. And with protocols, regulations and corrective actions defined through the LIMS, labs can achieve faster and more effective decision-making.

Digital solutions such as LIMS are enabling food safety scientists to perform analyses based on readily available SOPs using LES platforms, collect and store data in its original form using an SDMS, and evaluate how the data is being collected, transferred, stored and accessed from a centralized, cloud-based LIMS. These integrated digital solutions offer comprehensive support for the organization of chain of custody data, ensuring full traceability and compliance, and protecting consumer safety and food integrity.

Improved Traceability for Regulatory Compliance

Current regulations are enforcing the quality and safety of food products using well-defined standards for laboratory processes, ensuring the transparency of data handling processes, from raw materials to packaged products. ISO 22000 sets recommendations for food safety management systems and requires businesses to implement hazard analysis and critical control points (HACCP) to ensure the highest levels of quality control and assurance throughout the product lifecycle.

Regulations such as EU 178/2002 and FSMA include mandatory requirements for the traceability of food, feed and any other food-related substance or animal through identification and food tracking programs. Given the unfortunate growth of food fraud, traceability and authentication are becoming increasingly important. The latest regulations are helping the food industry to maintain optimal production practices to safeguard public health, maintain consumer confidence and preserve brand integrity.

Systems that are fully harmonized with these guidelines can be used to maintain data in organized archives, simplify audit trail recording for proof of compliance, and enable easy-access for users to review data. The latest LIMS can support HACCP compliance by automatically alerting users to deviations in expected processing parameters. In this way, issues can be quickly identified, and corrective action can be taken to prevent potentially dangerous products from reaching the consumer.

Digital lab and data management solutions are helping food supply chain stakeholders to simplify tracking, improve transparency and ensure the highest levels of accountability to protect both product authenticity and consumer safety. The integration and implementation of these systems helps to fulfill production demands as well as meet future challenges, allowing the food industry to expand and develop services and checks with the growing global market. Moreover, the potential for food fraud or adulteration is greatly minimized, giving consumers additional confidence in the products they purchase.

Reference

  1. Charlebois, S. Sterling, B. Haratifar, S. and Naing, S.K. (2014). “Comparison of Global Food Traceability Regulations and Requirements,” Compr. Rev. Food Sci. Food Saf., vol. 13, no. 5, pp. 1104–1123.
Blockchain, Food Safety Supply Chain Conference

Is the Food Industry Ready for Blockchain?

By Maria Fontanazza
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Blockchain, Food Safety Supply Chain Conference

Darin Detwiler will lead a plenary session titled, “Practical Use of Blockchain in Food Safety” at the 2018 Food Safety Consortium | Learn moreOn the heels of the deadly, widespread outbreak of E.coli O157:H7 illnesses linked to romaine lettuce—and 12 years after the infamous spinach outbreak of 2006—the food industry is struggling to find the solution to prevent these outbreaks. “I think it’s indicative that we need to do something different,” said Melanie Nuce, senior vice president, corporate development & innovation at GS1 US, during a panel discussion about blockchain at the 2018 Food Safety Supply Chain conference earlier this month. The panel, led by Darin Detwiler, assistant dean and director, regulatory affairs of food and food industry at Northeastern University, delved into the strengths and weaknesses of blockchain, along with industry readiness and acceptance.

In its most basic form, the technology would allow for the addition of information from every step of the supply chain, from manufacturing to packaging to distribution to retail, and would incorporate elements such as auditing, inspection, batch information, certification of auditors, preventive control plans, HACCP information, and allergen identification.

“Blockchain could be the death of the document.” Simon Batters, Lloyd’s Register

Strengths

The increased demand for transparency and traceability could be one of the biggest drivers for the adoption of blockchain. “[Blockchain] offers us the technology for traceability,” said Simon Batters, vice president of technology solutions at Lloyd’s Register. “It allows us to have an immutable record of a transaction; it won’t solve the food safety conundrum overnight—it’s part of the tool kit that we need.”

The fact that the food supply chain consists of millions of transactions, which could not be tampered with under blockchain, while the data could be used as reference points and for verification—those are strengths. However, Batters pointed out, there should be restrictions on who has permission to write the code and who has access to putting the information into a chain.

The technology would also enable smart contracts whereby shipments wouldn’t be finalized if they didn’t meet the conditions of a supplier, for example. “All parties to a transaction have a view to the entire chain at the same time,” said Nuce. “You have real time visibility. This democratizes that.”

Kathleen Wybourn, director, food safety solutions at DNV GL, calls blockchain “the birth certificate for food.” From a consumer standpoint, it would provide information on a product’s origin—and these days, consumers—especially millennials—are very interested in the story of food from farm to fork.

2018 Food Safety Supply Chain Conference, Blockchain
The blockchain panel, led by Darin Detwiler, Director: Regulatory Affairs of Food and Food Industry, Northeastern University featured (left to right) Kathy Wybourn, Director, Food Safety Solutions, DNV GL; Simon Batters,
Vice President of Technology Solutions, Lloyd’s Register and Melanie Nuce, Senior Vice President, Corporate Development & Innovation, GS1 US.

Weaknesses and Threats

The panel pointed out several areas of improvement (and unknowns that must be answered) before blockchain can be taken to the next level in the food industry.

  • Although the technology could aid in faster transaction times, as the size of the ledger gets larger, and it will become more difficult to manage.
  • Industry involvement: “If you don’t get 100% participation, it’s not going to be successful,” Nuce said. “To have true trace back, everyone has to participate.”
  • Blockchain platforms: Will they be able to interact and share data? What type of blockchain architecture is necessary for this?
  • Poor architecture
  • Need a better grasp on the type of data being used and how it delivers value
  • What impact will it have on the role of certification bodies?
  • Politics and the competitive element: Will certain parties seek to control this space?
  • Will the culture shift be a roadblock?
Melanie Nuce, GS1 US
Read Melanie Nuce’s column, Blockchain: Separating Fact from Fiction

Final Thoughts from the Panel

“Nobody can really tell where this is going to go in the future. I think it’s going to be part of food safety in their roles in one shape or form…I think we’ll see more of where this is headed within the next 12–18 months.” – Kathy Wybourn

“I think it’s going to be a fast-moving dynamic area.”– Simon Batters, who suggested that the organizations that embrace blockchain early may be the ones who show the way

“From an information/standards perspective, you have to have foundational business processes to support any type of technology. That’s what we’ve learned through the pilots.” – Melanie Nuce

“It’s not going to make a company any more ethical… a lot of what we need already exists out there; blockchain is just a tool out there. I keep warning people that this is not the only solution.” – Darin Detwiler

Megan Nichols
FST Soapbox

5 Ways to Manage Risk in the Global Food Supply Chain

By Megan Ray Nichols
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Megan Nichols

In 2017, the cost to import food, which has long been fairly predictable, rose by 6% over the previous year—and the number of possible risk factors has risen right alongside the higher price tag. There are several steps you can take to position yourself as an industry leader and manage risk simultaneously. First, though, it makes sense to better understand what’s at stake.

Why Take Steps to Reduce Risk?

Food has never been a more global market than it is today, and those who operate in the food supply chain are bound by the public’s trust in spoken and unspoken ways. Customers are used to taking for granted that they can walk into a supermarket and walk out with ethically sourced fish and eggs free from E. coli worries.

Not every food product is, or can be, a global one. However, some of these domestic risk factors scale up, just as our businesses do. When the food supply chain crosses borders of any kind, the familiar health and food safety risks are joined by several others:

  • Product mislabeling
  • Unplanned-for natural disasters
  • Spoilage due to any number of unforeseen circumstances
  • Damage while in transit
  • Unpredictable politics and shifts in regulations

A food company’s supply chain can be the weakest link in their food safety program. Learn more at the Food Safety Supply Chain Conference | June 12–13 | Rockville, MDIn all honesty, no list will ever encompass the scope of the risk you take on as part of the global food supply chain. That’s not to say you can’t take steps to reduce your risk—sometimes several types of risk at once—as your operation grows. The following is a look at several practical suggestions, some of them more time-intensive and perhaps cost-prohibitive than others, but all worth a look as the world grapples with globalization in the food industry.

1. Don’t Take Company Culture or Employee Training for Granted

Working safely and conscientiously in a particular trade is not knowledge we’re born with. When you consider the fact that at some level every food product we bring into our homes was handled at one point by another human being, you get a sense of the role proper training and a healthy culture can play in the safety we expect of our food.

Among recently surveyed manufacturers in the global food space, 77% of them said globalization itself was a source of risk. It’s easy to see why. In 2015, a relatively small—though still deadly—Listeria outbreak was traced to just a few Blue Bell Ice Cream factories. The company was almost ruined by the three deaths, the illnesses and the nearly crushing reputational damage.

Some momentary lapse of judgment at one or perhaps two factories almost killed this company. Now scale this type of risk up to the global level and think about the possible worst-case scenarios.

We’ll talk more in a moment about ways to introduce transparency and traceability to the food supply chain, but this is a reminder of the stakes. Mindfulness and conscientiousness in the work we do— not to mention well-rested and satisfied workers—are just as vitally important to look after as profitability.

2. Use Predictive Sales Forecasts and Intelligent Logistics to Avoid Spoilage

Unnecessary food waste and spoilage emerged as a mainstream issue in recent years all across the globe. For example, citizens in the EU are forced to discard some 89 million tons of food each year due to overstocking, poor quality control and a lack of attention paid to consumer trends. The United States throws out 35 million tons of food for the same reasons—a problem that, billed collectively, carries a price tag of $165 billion each year in the United States alone.

The solution has arrived in the form of predictive analytics and more intelligent warehouse and inventory management systems. Domestic and global supply chain partners alike now have access to, in some cases, highly customizable software systems that can provide vital data, such as:

  • Ideal stock levels for perishable items
  • Constant checks on incoming versus outgoing products
  • Intelligent insights into customer behavior patterns and near-future buying patterns

These types of data are highly actionable. They don’t just shield you from monetary risks by cutting down on waste— they can also protect you from public health risks by ensuring spoiled products never make it as far as store shelves.

3. Take Your Packaging More Seriously

Many of us don’t give packaging a second thought. So long as it’s easy to get into, eye-catching and protects the product long enough for the consumer to get their hands on it, it’s good enough — right? Not quite. When manufacturers think about packaging as merely a branding matter rather than as a safety check, the price is sometimes human health and lives.

One obvious solution to make sure your products can travel as far as they need to is to invest in vacuum packaging, even for small-scale operations. Compressed air equipment is a highly affordable way to accomplish this. The USDA and CDC provide guidelines on modified atmosphere packaging (MAP) and controlled atmosphere packaging (CAP).

Packaging material requirements are a global concern as well as a domestic one. The EU provides guidelines for packaging materials that are detailed down to the type of ink used. Knowing about the laws in your sales territories and staying aware of new breakthroughs in material sciences can help you remain in compliance and ahead of the game.

In a global supply chain, high-quality packaging serves not just as a risk mitigator, but also as a possible value proposition for your customers. Having your brand stand out as an example of high-quality products in thoughtful, health-conscious packaging could put you in a unique position.

4. Stay Abreast of Changing Regulations

American politics might be volatile, but one thing that isn’t likely to change is that consumers tend to look toward institutions like the FDA to provide updated guidelines and to pursue strong, consumer-friendly legislation. That means compliance isn’t always a choice, but it also means you have the opportunity to anticipate change and mitigate risks faster than your peers.

A recent example is FSMA. It’s had a long rollout, with plenty of advance warning for the industries it touches, but now most of its rules have reached the implementation stage. This lead time has been advantageous given the scope of the anticipated laws because it’s given food processing companies time to prepare for compliance. In fact, globalization lies at the very heart of it.

FSMA will be challenging at times to enforce, but its ultimate goal is to hold domestic and foreign companies in the global food supply chain responsible for a common set of guidelines and best practices.

What does this mean? It means you have yet another opportunity to establish yourself as an industry leader. The intentions of FSMA are to make every part of the supply chain more agile and better able to respond to emerging health concerns and other sources of risk as they unfold.

5. Use Data to Build Greater Transparency

There has perhaps never been a more important time to take transparency seriously in the global food supply chain. As of this writing, a historically significant outbreak of E. coli among romaine lettuce products is closing in on an “all clear” from the CDC after two difficult months. By the time you read this article it’s entirely possible another outbreak of a different kind might be underway or that some product or another has found itself under a recall. The possibility of reputational damage is greater than ever.

The good news is, even when the unfortunate happens, it’s possible to greatly reduce risk to your brand and your customers’ health. However, you need the tools to help you move quickly in tracing the problem.

Some digital technologies of a more physical nature, such as QR codes or RFID chips, can elevate your supply chain transparency and tamp down risk even further by allowing far more granular traceability for your products as they move about. In some high-profile examples, we’re seeing this concept taken to a logical, if slightly extreme, endpoint: Edible QR codes on restaurant food that contain a full history of the meal’s constituent ingredients.

Even if you don’t take your own efforts this far, this level of traceability can help you react far more quickly to emerging situations such as recalls. You’ll be able to isolate shipments with greater ease and trace contaminated products back to their sources. Also, as The Guardian points out, this technology delivers ethical and perhaps legal peace of mind by assuring you that your partners are trading in ethically sourced goods.

Vigilance and Technology in the Food Industry

The stakes in the food industry are high, as we’ve seen. However, with the right combination of a cultural approach to safety, a mindfulness of changing regulations and the sensible application of technology so you can act on the data you’re gathering, you’ll be in a prime position for global success in this quickly changing field.

Megan Nichols
FST Soapbox

Blockchain Improves Visibility In the Food Supply Chain

By Megan Ray Nichols
2 Comments
Megan Nichols

Cryptocurrency is a favorite topic in the business world currently, but it’s not the coins or currency that are the star of the show. Bitcoin in and of itself is exciting and promising from several perspectives. However, the foundation of what these technologies run on is much more important. You likely already know what we’re going to talk about next: Blockchain.

To understand why blockchain is considered so crucial, you first need to delve into the core components of the technology. It’s basically a digital ledger, except it has some incredibly useful properties that make it uniquely lucrative. For starters, it’s public and transparent, so anyone with access to the network can see what’s happening in the moment, or what has been happening while they were away. However, the parties involved in a transaction or entry remain private, as do the materials or items exchanging hands.

Finally, because of the nature of blockchain, it’s secured and valid. The ledger itself is thoroughly protected, and no one can alter data save the parties involved. Even then, the relevant parties only weigh in with pertinent information such as time and date of the transaction and the amount transferred.

Most of what we’re talking about here is in reference to currencies and more traditional transactions. But it’s important to remember that we’re merely scratching the surface. As we speak, various organizations are working to adapt this technology for alternate industries and applications.

Still, what does any of this have to do with your average food supply chain?

Blockchain May Evolve the Food Supply Chain As We Know It

Believe it or not, blockchain can help improve the transparency and management of the food supply chain. It’s definitely needed. The world’s population continues to grow, and it’s expected to reach 10 billion by 2050. In food requirements, that means we’ll need to be increasing food production by as much as 70% to keep up. This puts a demand on the food supply chain to evolve and become more efficient, more accurate and more reliable.

The following are several ways blockchain can help achieve better transparency in and management of the food supply chain.

Preventing Foodborne Outbreaks, Enabling Fresher Goods

IBM has teamed up with several major suppliers including Wal-Mart, Dole and Nestle to come up with a blockchain-powered system that can be used to track a product’s journey from farm to store shelves. The goal is to create a more transparent deployment and transportation process so that interested parties can see exactly when and where certain foods might become contaminated.

Tracking this information will achieve a couple of things. For starters, public health officials, suppliers and management teams can help limit and prevent contagions from spreading. After the detection of Salmonella, for instance, they could mark all related goods as a risk and stop both stores from selling them and consumers from buying faster than ever before.

Second, it will help identify problematic systems and processes, hopefully cutting down on the risk of contamination in the future. If they know certain foods are going bad in transport, they can discern that it’s something to do with how they’re handled or stored along that segment of the journey. This would further enable them to identify and fix or optimize the issue. In other words, suppliers and retailers will use blockchain to keep food fresh. This is especially important since FSMA calls for reliable hygiene and storage methods during transportation.

More Accurate Inventory Tracking for Distributors

Unexpected shortages pose significant challenges to the food supply chain. A variety of external factors can contribute to a supply block, including inclement weather, poor soil, insect infestations, equipment failures and much more. When this happens, distributors are left to pick up the slack, but sadly, they often can’t do much to fix the problem.

Blockchain technologies, however, make the supply chain more transparent, which helps distributors get the information they need to address shortages. Through the use of blockchain, they’ll know exactly how much supply is available and what they need to do to ramp up their offerings.

For example, in the event of a shortage, they might connect with local farmers to make up the difference. Gathering the information needed to find the right partner, however, can take a long time when using traditional methods. Through blockchain, though, distributors could easily see product types, farming practices, harvest dates and amounts, treatment info, fair-trade certifications and other information. This would allow them ample time to find a suitable replacement or additional partner.

Transparent Safety Protocols

The food supply chain is lengthy, includes a lot of different parties and involves a lot of metrics and details that need to be recorded and monitored. The problem with having so many factors is that it can muddy the waters. It’s hard to keep track of what every party is doing, where problems exist and what improvements can be made.

Many modern food supply providers are as transparent as they can be with partners and colleagues, but it’s not an element you would describe as streamlined or accessible to all. Blockchain can completely alter and disrupt this for the better.

Since food safety is an enormous concern for suppliers, distributors and retailers, blockchain can offer more than just peace of mind. It can help organizations perfect the entire process, improving safety for consumers and even enhancing the freshness or quality of the products provided. Improper storage or transport, for instance, can have a detrimental effect on quality, before the goods even reach store shelves. Blockchain will enable better tracking and monitoring, and make the resulting details much more accessible and transparent.

It’s Time for the Food Supply Chain to Evolve

The coming change is warranted and welcomed by many. A more transparent process means a much more accessible system. Suppliers can better communicate with farmers and food sources. Distributors and retailers can keep a close eye on the goods they’re acquiring and offering to consumers. Furthermore, safety, quality and quantity can be more accurately monitored and measured by everyone along the way. It’s time for the food supply chain to evolve in this way — it’s been a long time coming.

Jordan Anderson, PAR Technology Corp.
FST Soapbox

How the IoT Influences Restaurant Food Safety & Management

By Jordan Anderson
2 Comments
Jordan Anderson, PAR Technology Corp.

The Internet of Things (IoT) is changing the way restaurants do business in 2017. Today, business owners can trace products from point-of-purchase to their doorstep using IoT devices that monitor their location and more importantly, their temperature along the way. These devices are helping keep food safe, streamlining inventory management and giving owners the real-time information they need when managing multiple locations.

Monitoring Food Safety

Nothing gets the attention of a restaurant owner quicker than a foodborne illness outbreak. When it happens, they need to know which products were involved.

IoT devices allow owners to track their food from the time they order to the time it arrives. Even in the back of a tractor-trailer rolling down the highway, owners can check to see the temperature of their food, and can obtain the data trail during its entire journey to see how it was handled, and to ensure safety standards were met.

This data is especially important since the U.S. Federal Government enacted the Food Safety Modernization Act (FSMA) in 2011, which intends to protect public health by reinforcing the U.S. food safety program. Food-based businesses are now required to establish preventative control systems modeled after HACCP (Hazard Analysis and Critical Control Points) guidelines and prove their compliance by maintaining at least two-years of documentation.

Traceability measures utilizing IoT efficiently gathers and manages this information, giving owners the peace of mind they need to ensure their food has been handled properly. Not only that, but they have the data to prove it.

Inventory Control and Management

IoT devices help manage the cost of inventory by providing the real-time data that owners need when ordering stock and forecasting needs based on their menu. The data collected by the IoT devices ensures the freshest ingredients are available for dishes, and expired products are disposed of properly.

Tracking inventory from farm-to-fork prevents food waste, deters in-house theft and helps manage the cost of inventory.

Other questions and action items that IoT devices can help manage include:

  • Who placed the order, authorized the purchase, and accepted the delivery?
  • What was ordered and what are the products’ proper temperature ranges?
  • When did the order take place and when did it arrive? When is its expiration date?
  • What is the origin of the product and how did it travel to get to you?

This can help specifically within the restaurant retail market where pick-up and deliveries are becoming more prevalent.

For example: If a customer changes their scheduled pick-up, or drop-off times, retailers must have technology in place that will monitor food safety best practices. Deli, produce and dairy related products could use pre-determined checklists that will verify items were picked correctly, bagged properly and temperatures are checked to FDA regulated standards. While FDA regulations pertaining to FSMA are stricter than ever, it has never been more important for food safety technology to be integrated within the adoption of omnichannel restaurant practices. The likes of digitalized checklist management, temperature control and traceability will have a tremendous impact on continued growth and service within the marketplace.

IoT Devices and Temperature Control

Utilizing the IoT is a critical aspect of quality control. These devices are equipped with a temperature probe, barcode scanner and RFID infrared temperature reader that monitors and tracks your food throughout its journey in the supply chain.

Here’s how it works:

  • The probe, infrared and RFID scanner track and measure the temperature of each product.
  • The IoT software prompts employees to complete checklists, including temperature checks on a regular basis.
  • Each time the data is collected, it is immediately uploaded to a secure cloud and is accessible anytime, from anywhere.
  • While in the cloud, you can customize, store, filter and analyze the information.
  • Users are alerted immediately if any steps are overlooked, like non-observed items, missed checklists and violations, in addition to any corrective actions that address temperature concerns.
  • Should an issue arise, you have the detailed, automated audit trail to prove your company followed proper food safety protocol.

IoT Devices Can Create Modern Dining Experiences

Aside from helping to streamline and manage day-to-day operations, IoT devices can create a unique dining experience for your customers.

For example, if you love seafood – some restaurants are using IoT devices to track where and when seafood is harvested. One example of this kind of initiative is the Boat-to-Plate project funded by a grant from the Mid-Coast Fishermen’s Association. This project developed an app for anglers to upload information regarding their catch. Restaurant owners are using IoT information like this to create unique dining experiences.

IoT and You

How do you plan to use IoT technology in 2017? Integrating IoT practices gives your business the food safety solution needed to help keep food safe, improve supply chain traceability, manage your inventory and gain better control over your bottom-line.

Julie McGill

Make Your Food Chain Recall Ready At The 2017 Food Safety Consortium

By Julie McGill
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Julie McGill

As we reflect back on 2017, food recalls continued to dominate our headlines even after the implementation of FSMA. Our industry has taken corrective actions to limit risk. We want to protect consumers as well as our brands, limiting the financial and reputational damage that a recall can inflict on a company. We, along with consumers, are also more aware and in tune with the news due to social media and the 24-hour news cycle. It may appear that there are more recalls, but I would argue that the industry is more proactive and more accountable by submitting itself to voluntary recalls. Without a doubt, the food industry is under increased pressure.

Looking forward to 2018, we are reminded that it was 25 years since the E. coli outbreak at Jack in the Box. It was a monumental turning point in food safety that sparked the industry to modernize and examine processes. Since then, the food industry as a whole has come a long way. During my 16 years at GS1 US, working on programs such as the Foodservice GS1 US Standards Initiative, I saw food companies embrace global standards to increase efficiencies and build a foundation for traceability and supply chain visibility. Now adding Blockchain, Smart Labels, and IoT data to the technology mix will continue to advance the modernization of the food industry.

The good news for our industry is that consumers are patronizing companies that are embracing transparency as a strategic business strategy and these are the companies who are winning the market share as a result.

As stewards of our industry, we will always review our processes, continue to train and educate our employees and adopt better ways of guarding the supply chain. One way to become better at protecting the food chain and the public is exchanging ideas with our peers. We are stronger together.

That is why I am excited to bring together a diverse group of industry leaders for this year’s Food Safety Consortium to discuss this very topic. Titled, Is Your Food Chain Recall Ready?, I will be joined on Thursday, November 30th at 2:30pm CST by Jessica Jones, sr. specialist of Supplier Quality & Safety at Chick-Fil-A; Barbara Hullick, senior director of Food Safety at Produce Alliance and Bryan Cohn, vice president of Operations at Seal the Seasons.

During this panel session, we will discuss:

  • Best practices for FSMA compliance before, during and after a recall.
  • Best practices to execute precise, data-driven and timely recalls and stock withdrawals.
  • Establish and execute a process for escalation and post-recall audit reporting.
  • Work and communicate with suppliers and distributors on “what if” scenarios and what they can expect when quality issues arise.
  • Create a food safety culture which works in concert with legal, marketing and other internal teams.

I hope you will join us in person at the Renaissance Schaumburg Convention Center Hotel for the entire conference but if not, join us virtually! Registration details can be found on the Food Safety Consortium website.

Melanie Neumann, Neumann Risk Services

Today’s Inspection and Audit Reality: The New Normal

By Melanie Neumann, JD, MS
2 Comments
Melanie Neumann, Neumann Risk Services

Food industry inspection and audit protocols are evolving at a rapid pace, and rightly so. This is not surprising given today’s regulatory, audit and ever-changing risk landscapes, which are driving further complexity and expansion of requirements to ensure the industry is, “audit ready, all the time.”

This evolution of inspections and audits has been primarily triggered by newer regulations such as FSMA and private standards, such as GFSI and its certification programme owners (CPO’s, fka Scheme Owners) like SQF, BRC, FSSC 22000, IFS, etc. Heightened customer demand and consumer visibility into food safety incidents –many thanks to mainstream and social media– and the resulting increased demand for information has also fueled this evolution, compelling industry to focus on higher levels of transparency, both internally and throughout the supply chain.

The changes above are driving the food industry to face a new reality. One where the following questions continue to rise to the surface:

  • How have “yesterday’s” inspection and audit expectations changed from what companies are experiencing today?
  • Based on this evolution, how will “tomorrow’s” inspection and audit expectations change?
  • In short, what does the new reality or the “new normal” look like now for inspection and audit readiness?

We will take a look at what some of the first inspections are shaping up to look like under the Preventive Controls for Human Food (PCHF) Rule and the Foreign Supplier Verification Program (FSVP) Rule. Some common themes and some tips to successfully manage regulatory inspections as well as audit readiness tips are set forth below.

More Inspectors

Roll out the welcome mat because more inspectors are coming to the party. We are seeing an average of three to upwards of six regulatory inspectors performing the inspections under the PCHF rule. This may cause an initial shock wave but when you stop to consider the rationale it has a certain level of reasonableness to it. Industry has invested in its personnel for nearly two years in updated training to meet new FSMA regulations such as preventive controls qualified individual (PCQI) training, updated current GMP training and perhaps qualified auditor training, if applicable. It makes sense that FDA needs to make a similar investment in its people to ensure its inspectors are prepared to knowledgeably perform FSMA-related inspections.

FDA has implemented a robust training program for its inspectors. Regarding PCHF inspections for example, only inspectors who have successfully completed the PCQI training plus FDA’s internal training will lead other inspectors through the facility inspections as an in-field training exercise. So, the good news is at least one inspector is fully trained under FDA’s training program standards. This said, with more inspectors, there are more eyes, and with more eyes, more opportunities to see risk through different perspectives. It’s best to be on your game, with a tested playbook so you have confidence you are prepared when the team of inspectors arrive at your facility. Conduct a mock inspection against your policies, procedures and food safety plan that have been updated for the new PCHF and other applicable FSMA requirements. You will be thankful you did.

Digging Deeper

Into Records: FSMA and the seven rules that comprise it requires more controls, monitoring and verification activities by the food industry, thus naturally giving inspectors more records to access and review. Further, FDA received expanded records access authority upon the signing of FSMA. FSMA allows FDA to access records relating to articles of food for which there is a reasonable probability that the use of, or exposure to, the article of food will cause serious adverse health consequences or death to humans or animals. Before FSMA the standard FDA had to meet to access records was “credible evidence”; now its “reasonable probability”—a standard that is far lower and subjective—allowing access to more types of records than before. Another new addition is FDA now may access records beyond those relating to the specific suspect food if the agency reasonably believes that other food articles are likely to be affected in a similar manner.

Example: If you have a potential problem on production line 1, and you firmly believe the issue is contained to line 1, but that line is in even arguably close physical proximity to line 2, depending on the issue an inspector may invoke this new authority and ask for all records associated with line 2 in addition to line 1 for the same time period to be sure that the situation indeed did not spread or otherwise impact line 2. (e.g. confirm no risk for cross contamination or allergen cross-contact).

This should not mean it’s open season on all your records, but it certainly means more records are open to review and scrutiny, so having a robust record retention and management system becomes mission-critical. How sound is yours? Record-keeping and document management have long been important to GFSI / CPO’s. However, many food companies do not have a certification from one of these entities, which begs the question whether the scope of your third-party audit, or that of a supplier you are currently evaluating for approval, adequately evaluates this important area.

Into your Hazard Analysis: Inspectors are spending significant time reviewing the adequacy of the hazard analysis performed as part of the requirement of the food safety plan under the PCHF Rule and as part of the foreign supplier verification plan requirement under the FSVP rule. If facilities do not identify all the hazards of concern that require a preventive control associated with their facility and foods they produce, then the rest of the food safety plan falls apart. If you work with peanuts to produce peanut butter and identify Salmonella as a hazard requiring a preventive control but not aflatoxin or peanut allergen you have likely missed the mark.You may not have the appropriate preventive controls, monitoring, verification activities, validations and corrective actions identified in your hazard analysis and food safety plan to control for the most significant hazards your facility / the finished food is facing from a food safety risk perspective. (note the identification of hazards requiring preventive controls is highly dependent on the food, facility, processing methods of the manufacturer, upstream supplier and will vary if products are RTE or nRTE)

How are auditors tackling this issue? Many third-party audit firms have invested in providing PCQI training for its auditors so they are better prepared to evaluate the sufficiency or gaps in the hazard analysis. It is a good idea to ask your audit firm what updated skills and training have been given to its auditors to ensure you are getting the assistance you need.

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