The following infographic is a snapshot of the hazard trends in poultry and poultry products from Q3 2019. The information has been pulled from the HorizonScan quarterly report, which summarizes recent global adulteration trends using data gathered from more than 120 reliable sources worldwide. Over the next several weeks, Food Safety Tech will provide readers with hazard trends from various food categories included in this report.
Despite manufacturers’ best intentions to provide safe products for consumers, notifications about recalled products appear in news headlines with increasing regularity. The CDC reports that each year, 48 million Americans experience foodborne illnesses, resulting in a reported 128,000 hospitalizations and 3,000 deaths. Behind these statistics are recall trends that can lead to operational and financial instability, and a loss of reputation for companies in the marketplace. Proactive measures and tools adopted by experienced food and beverage manufacturers can help mitigate the potentially harmful effects of these product recalls by establishing preparedness initiatives.
Recall Essential Facts
A recall is defined as a request for the return of a product from the market due to a defect or safety concern resulting from a variety of issues including improper labeling or contamination, which places the manufacturer at risk of legal action. Product recalls can be issued by either the manufacturer or a governmental agency, but it is the sole responsibility of the company to properly recall and notify consumers of unsafe products. Recalls are categorized as either voluntary or mandatory, with the majority falling under the voluntary classification. In the case of a voluntary recall, a manufacturer has greater control over the process with less stringent procedures, review and paperwork. While both have the same potential for negative effects and significant legal costs, a voluntary recall is preferred by manufacturers. Implementing an industry-specific ERP solution with a documented recall preparedness plan and mock recall capabilities provide the necessary tools for either scenario, as recalls are inevitable in today’s manufacturing environment.
In the USDA- and FDA-regulated markets, comparatively, there have been a slightly higher number of recall incidents in the beginning months of 2019 versus 2018. Mispackaging is identified as one of the primary recall issues, involving packaging a finished good into the wrong container. Another trending recall cause involves not properly identifying an ingredient on the packaging label. Both of these manufacturing errors resulted in the labels not providing an accurate reflection of the product, which could be potentially harmful to consumers if the undeclared ingredient(s) include one of the common allergens. Well-documented and properly executed internal manufacturing processes, in addition to an automated ERP solution, create checks and balances and assist in generating accurate, compliant packaging and nutrition fact panels to meet the requirements of consumers and regulatory bodies.
A third recall trend of 2019 is being driven by consumer complaints in regards to foreign materials such as metal fragments, plastics or rubber pieces in finished goods. This is caused by incomplete testing, lack of or faulty material detection equipment, including metal detectors, x-rays and other devices used during manufacturing. Due to an increasing number of these types of incidents, the USDA has issued a guidance document requiring manufacturers to maintain updated documentation of their internal procedures in their hazard analysis and critical control point (HACCP) plan. This guidance necessitates follow up with federal inspectors regarding any adjustments made to the plan. HACCP information recorded within an ERP solution helps to identify and control potential hazards before food safety is compromised—providing quality, consistent and safe consumables for the public.
Progress towards fewer FDA food and beverage recalls continues due to an increase in FDA inspections as well as manufacturers’ success in proactive measures to stay abreast of FDA requirements. However, bacterial pathogenic concerns including Listeria, Salmonella and E. coli continue to be prevalent recall culprits. This has resulted in the FDA utilizing the Whole Genome Sequencing (WGS) Program in an attempt to protect consumers from foodborne illness. By swabbing manufacturing environments and sending samples to WGS, the DNA strains are documented in a centralized public database—holding manufacturer’s accountable for processing and sanitation control. When an outbreak occurs, the database is able to locate possible matches that help health officials identify the source of contamination, and stop outbreaks more quickly, thereby avoiding additional widespread illnesses. As the database grows in size, so will the speed of investigations to determine the root causes of illnesses. This program has the potential to not only stop outbreaks from spreading but also includes proactive applications for increasing the safety of the food and beverage industry as a whole.
ERP’s Role in Recall Preparedness
An industry-specific ERP’s real-time forward and backward lot traceability, detailed record keeping, allergen/attribute tracking and efficient, documented processes support end-to-end recall management functionality to maintain compliance. With preventative measures such as establishing supplier relationships, conducting quality control testing and documenting quarantine procedures, an ERP solution works to identify gaps and prevent future recalls. Accurate product labeling is one of the key factors of recall prevention and food and beverage ERP software handles the intricacies of packaging and label creation, such as ingredient and allergen statements, nutrient analysis, expiration dates and lot and batch numbers—creating an audit trail that allows items to be located promptly in the event of a recall. As part of a sound food safety plan, mock recalls conducted regularly encourages familiarity with internal recall processes, as well as allows for adjustments to be made as needed. With a comprehensive ERP to generate lot tracking reports, manufacturers are able to identify and locate contaminated products in order to notify clients, vendors, consumers and government agencies quickly in the event of a recall—helping to minimize harmful effects in the marketplace as well as legal action.
The trends identified in recent recalls issued by the FDA and the USDA, thus far in 2019, demonstrate that manufacturers need to be proactive in how they respond in order to mitigate the detrimental effects that recalls can have on companies and to public health. With the increasing scrutiny from the FDA and USDA, along with an aware consumer base, it’s important for forward-thinking businesses to address the eventuality of a product recall with sound food safety and HACCP plans and an industry-focused ERP software solution that promotes, supports and helps manage preparedness and responsive action, if needed.
Over the last two decades I have had the utmost privilege to work with food manufacturers from every sector. From dried goods, meats, poultry, school lunches programs, etcetera. I have seen almost everything. The leading trend I have seen over the last 20 years is the steady rise of beverage companies. Everyone likes a different type of beverage: Water, juice, cold coffee, teas, energy drinks, kombucha… the list goes on. The two most important things a small company entering the market needs to remember is to make sure that first, you can comply with the regulators, and second, that the people you are selling your products to also understand their market (buyers and retailers).
The marketplace loves new and innovative products. We need, as an industry, to continue to support innovation in the beverage industry. Healthcare trends, nutraceuticals, supplements, and “fresh” are some of the many things consumers are looking for in a product. We often have questions such as, “I have the perfect recipe for a new beverage product—how do we get it out into the market?” The first question to ask yourself is: Do you understand your product and its intended use? And, second: Do you understand how the physical properties of this product impact how it will need to be transported as well as stored and used by the final consumer? Both of these questions come back to—and can be answered by—food safety. Companies can have the greatest product ideas; however, if you do not have the ability to make sure it has a safety factor during transportation, as well as the ability to communicate your food safety plan, an entrepreneur can jeopardize the future of their company before it is even allowed to begin.
I have used the analogy that food safety best practices are like a sport—the more you train, practice and focus on the “basics done well,” the better your plan will be on a day-to-day basis. Bottom line: The focus is making the food supply safer. Please take note the transition to new practices does not mean that an existing HACCP plan (Hazard Analysis and Critical Control Points) is invalid! As a matter of fact, HACCP and Good Manufacturing Practices (GMP’s) should be looked at as the foundation of FSMA’s Preventive Controls for Human Food. Local departments of public health still rely on HACCP as their main line of defense for the food safety industry. We have seen so many small processors and restaurants that have inspections where HACCP is still the focus, even though Preventive Controls has some more advanced techniques for protection. Both HACCP and Preventive Controls focus on making sure you have good sanitation practices, employee training, and have done a hazard analysis for biological, chemical and physical hazards. I believe the lines are blurring a bit—companies, academics and regulators don’t often understand the differences between the two and, to be honest, the differences are not that substantial from a fundamental level. Ultimately, companies are responsible for their own food safety best practices.
As we trend toward new and innovative beverage concepts, we need to be partners with both our regulators and our customers. There is so much information across the United States and companies that are in emerging markets will only grow and develop if they have proper food safety plans as a foundation. Emerging companies should get connected early and learn from other companies and organizations, and become more proactively involved in the food safety element of their product.
I believe 2019 will be an incredible year for the rise of food and beverage startups. We have already seen much growth in the knowledge of food supply due to easily accessible information about products. Keeping a transparent conversation with regulatory personnel and customers is key to the success of any food or beverage company.
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.
From countless recalls, to FSMA deadlines, to the rising demand for transparency, 2016 has been a monumental year in the food industry. With 2017 knocking, here are the top trends and predictions to watch out for in the food industry next year.
1. Moving Toward a Fully Digital, Connected Supply Chain
The food supply chain in many ways is still lagging behind in technology compared to other supply chains. In 2017, many companies will begin or continue on their journey to fully digitize their supply chain, whether that is simply getting their list of approved suppliers out of an Excel spreadsheet and into a supplier management software technology solution or fully capturing every step of their products along the journey from farm to fork.
The spectrum of digitization across the supply chain is quite broad. But bottom line, supply chain analytics will empower food companies to create useful KPIs, allow them to truly measure the ROI of their supply chain initiatives and give consumers the transparency that they demand. And systems that fully support the daily monitoring, sharing and interpretation of those analytics needed to help companies will experience tremendous growth in 2017.
Collaboration with your supply chain partners is an absolutely critical element, and we can expect to see more companies fully integrate throughout their network of suppliers and customers. Food companies that will succeed in 2017 will need a fully integrated supply chain network, with access to the same information, working towards a shared mission to deliver results and be ahead of their competitors. A connected supplier network will allow food companies to be agile when faced with an issue, responsive to recalls, as well as be flexible and efficient.
2. Recalls, Recalls, Recalls
We saw a high volume of recalls this year, and this trend is not going away anytime soon. As more and more advances in food testing are made, companies will have access to new technologies across their supply chain that will identify issues early. Consequently, more products will need to be pulled out of the supply chain because of that increased testing in order to maintain consumer sentiment.
The companies that are able to roll out these capabilities quickly and efficiently—armed with the data needed—will be well poised to manage their supply chain, potential recalls and the impact to their customers. With the knowledge that we can expect to see several recalls in the new year, food companies should be looking to mitigate risks and better manage their supply chain.
3. Full-force FSMA Is Here Whether You Like It or Not
FSMA focuses on amplifying preventive controls for food production in order to alleviate potential food contamination outbreaks, and the past two or more years have been focused on this preparation. This preparation will come to a pinnacle in 2017, the first full year of FSMA implementation worldwide, with the FDA starting audits for larger companies. This could lead to the FDA requesting required records, conducting audits and in the worst situation for food companies, shutting down operations if they feel it’s necessary.
FSMA will require detailed record keeping when a recall or outbreak occurs, with clearly defined corrective actions in place. Companies will see an increased need for technologies that help supply preventive processes such as food allergen and sanitation controls, as well a prepared recall and supply chain plan. Tracking and traceability will be the two key parameters that will offer manufacturers the ability to examine specific foods and trends to improve their overall process. In order to comply with these new FSMA regulations at every step of the process, food companies will increasingly look to utilize these technologies to account for full traceability of the supply chain.
4. Growth in Foodservice At the Consumer’s Doorstep
Brands like Starbucks and Panera have been testing the food home delivery waters, but more companies seem to be jumping onto the trend of bringing gourmet food directly to the consumer’s doorstep—Blue Apron, Plated, HelloFresh just to name a few.
FSMA is fostering a surge in technology solutions, analytical tools and training products marketed to the food industry in the name of achieving FSMA compliance. And while many of these products were available pre-FSMA (especially in other industries like the life sciences), FSMA’s momentum has fueled the adaptation of solutions to meet the specific needs of the food industry for achieving and maintaining regulatory compliance. This article is a summary of emerging trends in food safety management by producers, manufacturers, distributors and retailers through the application of technology, educational tools, monitoring and detection systems, and other support mechanisms.
Want to learn more about FSMA trends and compliance? Attend the 2016 Food Safety Consortium in Schaumburg, IL | December 7–8 | LEARN MOREWhether by the spark of FSMA or because it makes practical sense (and most likely, a bit of both), businesses are integrating their food safety programs with enterprise initiatives and systems for managing compliance and risk to achieve increased visibility and harmonization across the organization. The most popular trends fueled by FSMA largely reflect technology solutions to achieve this integration.
Subsequently, solutions that support risk assessment, supply chain management, real-time monitoring, corrective action, self-assessment, traceability, and training management are most attractive and lucrative from an ROI perspective. And while it may be hard to find a one-size-fits-all technology solution depending upon the needs of the organization, technology service providers are quickly raising the bar to meet these growing needs as organizations strive to reduce risk and increase compliance. Other top trends at the periphery of technology solutions include the mobilization of food safety personnel and increased availability of on-demand training and detection tools to bring the FSMA movement full circle.
1. Software-as-a-service (SaaS) technology solutions quickly gained a following in the food industry in recent years to achieve an automated food safety and quality management system (FSQMS) solution.
The substantial management components and recordkeeping requirements of the FSMA rules has accelerated the food industry’s need for automated solutions to document program management, queue workflows and distribute notifications for corrective and preventive action (CAPA). Understanding this need, many SaaS providers evolved with FSMA to provide functionality that dovetails with new regulatory requirements.
2. Increased availability of risk and vulnerability assessment tools is of significant importance in meeting many requirements of FSMA’s rules.
The regulatory language of all FSMA rules is steeped in risk analysis to support the prevention of food safety hazards and threats. This creates a demand for user-friendly tools and training courses to help food businesses analyze and update their management systems within the context of these new requirements. Risk and vulnerability assessment tools currently available to the food industry are diverse in functionality and vary in scope and cost.
For example, FDA’s free online tool, FDA-iRISK 2.0, assesses chemical and microbiological hazards in foods through process models, which quantify risk across scenarios and predict the effectiveness of control strategies. Commercially available food hazard assessment tools based on HACCP/ HARPC principles include Safefood 360° and EtQ, which provide risk assessment modules as a part of their SaaS platform.
Universities, trade associations, and commercial risk management and consulting firms came together to produce two very different food fraud vulnerability tools to support the industry. SSAFE by the University of Wageningen RIKILT, Vrije Universiteit Amsterdam and PricewaterhouseCoopers (PwC) is a free online tool and mobile app, which guides users through a decision tree and assessment questionnaire to determine fraud opportunities, motivators and gaps in existing controls. EMAlert by the Grocery Manufacturers Association (GMA) and Battelle is a subscription-based online tool to assess vulnerability from economically motivated adulterants (EMA’s). Individuals conducting vulnerability assessments are recommended to periodically access food risk databases such as the U.S. Pharmacopeial Convention’s (USP) food fraud database to stay informed of historical and emerging threats to the supply chain.
And in support of FSMA’s Food Defense rule, the FDA developed a free food defense software tool, Food Defense Plan Builder (FDPB), to help food businesses identify vulnerability to intentional adulterants and terrorist attacks on the food supply chain.
3. SaaS platforms, app-friendly assessment tools and FSMA recordkeeping requirements are creating a natural pathway for the increased use of mobile devices and electronic recordkeeping and verification.
From supply chain management to effective traceability to regulatory compliance, efficient document management and on-demand data retrieval is a must have of the modern FSQMS. Food businesses recognize the inherent obstacles of paper-based systems and increasingly trend towards rugged mobile devices and electronic recordkeeping to make better use of personnel resources, technology solutions and data. FSMA is helping leverage this trend two-fold through increased requirements for documentation and verification of food safety management activities and by not requiring electronic records to additionally meet the provisions of 21 CFR part 11 (electronic recordkeeping).
4. An increased demand for more effective, frequent and accessible training must be met across an organization to maintain an adequately trained workforce responsible for implementing FSMA.
To keep up with this demand—as well as the training demand imparted by GFSI schemes and fact that a company’s FSQMS is only as good as those who develop and operate it—food businesses are turning to online and blended learning courses to increase training frequency and effectiveness. In Campden BRI’s 2016 Global Food Safety Training Survey, 70% of food processors and manufacturers responded that they received training deficiencies during audits as the result of a lack of refresher training and/or lack of employee understanding.
In an effort to help close this gap and meet new implementation requirements of FSMA, food safety training providers are increasing offerings of eLearning courses, which provide targeted content in shorter duration to meet users’ needs in an interactive (and often multilingual) format. Shorter and more frequent targeted training is proven to increase knowledge retention and job performance. E-Learning training solutions can be found through dedicated training service providers as well as universities, trade associations, regulatory agencies, scheme owners, certification bodies, and other compliance organizations.
Depending upon the training provider, online training may be distributed through a learning management system (LMS) to provide additional training tools, assess training effectiveness and manage the training activities and competencies of all participants.
5. Targeted monitoring and verification activities such as product testing, environmental monitoring or water quality testing are helping to increase the demand for pathogen testing and push the frontier of improved rapid pathogen detection methods.
In a recent Food Safety Tech article, Strategic Consulting, Inc. noted more than a 13% annual increase in pathogen testing by contract food laboratories as determined by a recent industry study conducted by the group. The study additionally identified turn-around-time as the second most important factor for suppliers when choosing a contract lab. Increased access to rapid pathogen testing—and in particular, detection without time-dependent cultural enrichment—are primary needs of food businesses as regulators and customers push for enhanced monitoring and verification via testing mechanisms.
Currently, there are numerous rapid methods based on DNA, immunological or biosensor techniques. These methods can detect foodborne pathogens in relatively short amounts of time ranging from a few minutes to a few hours. But they often require pre-processing strategies to reduce matrix interference or concentrate pathogens to meet the level of detection (LOD) of the assay.1 These strategies increase the overall time of the assay and are largely the next hurdle for improved rapid detection.
6. Food businesses are experiencing a wave of self-assessment followed by CAPA as organizations work to analyze and update their food safety systems and protocols within the context of applicable FSMA rules.
This trend has the potential to be the most beneficial to the supply chain and consumers as it provides a distinct opportunity for food businesses to reconsider previously overlooked hazards and vulnerabilities and upgrade food safety controls along with the management system. Seeing the FSQMS with fresh eyes—outside of the framework of a familiar standard—can lead to significant improvements in food safety management, product safety and quality, and even operational efficiency.
7. For many food businesses, heightened regulation has spurned the need for dedicated staff to support compliance efforts.
Many food businesses are subject to multiple rules—some of which require a dedicated individual such as the Preventive Controls Qualified Individual (PCQI) to assume responsibility for the implementation of various provisions. And food businesses are not exempt from the acute need for qualified individuals with a food safety skill set. Across the industry, from service providers to retailers and everyone in between or at the fringe, executives understand that it takes tireless leadership and knowledgeable staff to produce safe food.
8. More than any other trend, communication on FSMA, food safety and related topics is easily the most prevalent exhibiting exponential activity over the past five years.
Whether in support or contention with the proposed (now final) rules, FSMA promulgates constant dialogue about food safety, what it means and how it should be implemented. The constant flurry of communication provides both benefits and deterrents to understanding the new regulations and identifying effective solutions for compliance. This dichotomy creates a significant need for authoritative and easy-to-understand information from consolidated sources within the industry such as trade associations, risk management organizations and food safety schemes. The divide has also helped fuel the need for information hubs like the Global Food Safety Resource (GFSR) that aggregate critical regulatory information, food safety solutions and best practices to reach a global community.
- Wang, Y. and Salazar, J.K. Culture-Independent Rapid Detection Methods for Bacterial Pathogens and Toxins in Food Matrices. Comprehensive Reviews in Food Science and Food Safety. 2016; 15(1): 183-205.