The State of Food Safety: Regulation, Collaboration and the Advancement of a Globally Safe Food Supply
By Jorge A. Hernandez
Every day, millions of cases of food products are produced, distributed and served safely, without incident or mention. Feeding 300 million Americans, and 7 billion people across the globe, is no easy task. It requires a complex system of growers, sellers, distributors, operators and consumers, and there are opportunities for improper handling to occur at every step. Even with one of the most advanced and refined food safety infrastructures in the world, contamination, unfortunately, remains inevitable.
Recent foodborne illness outbreaks have caused some consumers to question the food they are purchasing. Many are condemning large-scale food producers, distributors and sellers, essentially swearing off the major food industry altogether. And while media attention focused on recalls raises consumer awareness of food safety, it also creates a myriad of problems for our industry, including loss of consumer trust, unwarranted regulatory concerns and the rapid spread of misinformation.
One recent food trend is the demand for locally and organically produced foods. Some consumers perceive these types of products to be safer than others because they do not travel long distances, reducing the risk of contamination, but “local” and “organic” are words that define where and how the food is produced, not whether it is safe. Terms such as “local,” “small farm” and “family-owned” are not synonymous with “safe.” As evidenced by Jensen Farms, the cantaloupe grower responsible for last year’s Listeria outbreak, local, family-owned operations do not necessarily equal safety.
Media-generated food safety and quality issues have recently drawn attention away from the legitimate concerns. One example is the recent consumer backlash over lean finely textured beef, dubbed “pink slime” by the media. The meat additive, commonly used in beef products and deemed safe by both industry professionals and government entities, has no real bearing on food safety. In fact, it’s very safe. Nonetheless, the issue grabbed headlines and increased a negative perception of the food industry as a whole. We took countless calls from concerned operators, consumers and even parents who were worried about their children eating unsafe products. It’s clear that more education is needed on the difference between legitimate food safety issues and media-generated ones.
This misinformation is only one of the challenges for food safety professionals. Progress as a whole is unlikely until the industry and its federal and state regulatory counterparts determine the real issues. And though the adoption of the Food Safety Modernization Act (FSMA) is aimed at preventing foodborne illness, food safety success will take more than regulation.
So how do we make food safer? What constitutes a safe food supply? And who is going to determine how successful we are? These are the questions that keep most of us in the food safety industry up at night. Here’s my proposed solution. The first step is ensuring that legislators and regulators have the proper tools to enforce food safety measures and enact policies that are mutually beneficial. Food safety professionals are the experts. We need to be an integral part in the decision making.
Then, leaders in the food industry need to come together and set the standard for food safety across the globe. There should be no trade secrets when it comes to food safety. It is up to the biggest and the best to not only change the perception of the food industry, but also help regulators, legislators, consumers and other food companies understand the importance of safety.
And, finally, food companies need to take a larger role in the direction of food safety. Too often, food safety is seen as something mandated by governing bodies. Safety needs to be addressed by those doing business in the industry; in addition to being financially beneficial, it is just the right thing to do.
The Role of Legislators and Regulators
In January 2011, President Barack Obama signed FSMA in an effort to shift the focus from responding to food contamination to preventing it. This paradigm change brings regulation in line with what many food companies have already implemented. Though many proactive companies and food safety professionals are far ahead of the new regulations, there is still room for more action, more learning and more collaboration. Many in the industry are waiting to see what the new legislation will require with regards to Hazard Analysis and Critical Control Points (HACCP) and preventive controls, a cornerstone of FSMA.
The role of the U.S. Food and Drug Administration (FDA) in shifting the focus from contamination response to prevention will be large, but the key is collaboration. The only way to develop attainable and realistic regulation is to work directly with the food industry.
Enacting widespread regulations without stepping foot on a farm, into a canning facility, onto a distribution truck or into a restaurant’s kitchen will only create policies and rules that are unrealistic, unnecessarily expensive and unmanageable. Growers, suppliers and distributors have vast reservoirs of knowledge that can help the government establish safe processes and procedures without burdensome or unneeded regulations (see “My Food Safety Philosophy: It’s Just the Right Thing to Do,”).
Regulation alone will not ensure the safety of our food supply. Regulation will raise the floor for the entire industry, but the advancement of the industry depends wholly on its leaders raising the ceiling to create a new standard of safety. Those in the food industry that have yet to make food safety a business priority will be required to comply as the new regulations are implemented. This benefits everyone.
What does not benefit everyone is the exemptions the legislation provides for smaller producers. FSMA works against food safety protocol by selectively excluding farms and small processors depending on their size. When FSMA was planned, Congress worked hard to ensure that the new regulation did not come at the cost of burdening small farms with expensive food safety requirements, but in doing this, some of the most challenged facets of the food industry are being overlooked. It is those organizations that are too small to effectively manage their food safety systems that need the most help.
Role of Industry Leaders
Effective collaboration between industry leaders and regulatory agents will increase the safety of our food supply, and those in the food industry know that food safety does not stop at national borders. An increasing amount of the food we package and sell to our customers comes from outside the United States. In 1998, we imported $41 billion in food products. By 2007, that number had nearly doubled to $78 billion worth of food entering through over 300 ports. Nearly 15 percent of our food supply is imported, accounting for as much as 60 percent of fresh fruits and seafood. Working with international partners to ensure a safe nondomestic food supply is just as important as ensuring the safety of domestically grown and manufactured foods.
Americans tend to think that food in the United States is safer than in the rest of the world. It’s true that we may have one of the safest food infrastructures, but we also have more than 15 independent federal agencies enforcing food safety laws. Combine that with state agencies, public interest groups and the media, and you end up with a lot of different organizations trying to achieve the same goal but in different ways, which can cause some problems.
That’s why it’s essential that food industry leaders work together (see “Tom-a-to, Tom-ah-to: Sharing Differences for Global Safety,”). Part of working toward a safer global food supply includes working closely with those in the international food industry. We need to create and enforce internationally recognized accreditation and certification programs to verify that suppliers around the world are using the latest food safety standards and best practices. Unlike other areas of your business, there should be no trade secrets in food safety. Sharing best practices and technology is too important to the overall strength of the industry and safety of the public. Two great examples of collaborative organizations include Global Food Safety Initiative (GFSI) and GLOBALGAP.
The first of these, GFSI, pursues constant improvement in food safety management systems, cost efficiency in the supply chain and safe food for consumers worldwide. They work to scale existing food standards against food safety criteria and create mechanisms to exchange information in the supply chain, increase consumer knowledge and review existing food retail practices.
The second, GLOBALGAP, sets voluntary standards for farm certification worldwide. The GLOBALGAP standard is designed to reassure consumers about how food is produced on the farm, ensuring food safety and animal welfare, minimizing environmental impacts of farming operations and taking a responsible approach to worker health and safety.
These groups are creating and implementing the most advanced global food safety standards and practices available. To do this, they create a dynamic system that can continuously monitor and confirm the safety of food from farm to fork. These tactics also utilize processes already established and administered by the International Organization for Standardization and are accredited in the United States by the American National Standards Institute.
Outside of the industry, companies are working with regulators to collaborate on best practices. Tighter budgets have caused a reduction in FDA and U.S. Department of Agriculture staffing, affecting their bandwidth to learn about discrete industry segments and effectively develop food safety regulations. This makes it even more important that those of us in the food industry step in to help educate and assist regulators.
US Foods recently hosted FDA in our facilities to demonstrate our processes and illustrate how our industry segment executes food safety protocols. Efforts like this fill the gap created by constrained resources. The time and assets we invested in implementing and testing food safety protocols in our more than 60 locations have produced a streamlined process that can be replicated throughout the industry. As food safety experts, we can help FDA and regulators identify the best ways to reduce contamination through the supply chain (Figure 1).
Another agenda item for food industry leaders must be increased certification in coordination with international standards. In addition to an audit, a third-party certification increases accountability and helps reassure consumers that food safety protocol is being followed. In February 2012, US Foods announced that it expects to be the first in its industry to be certified in food safety and quality to the International Features Standard (IFS), a globally recognized yardstick for safety and quality. Meeting that standard is a key milestone because nothing is more important to us than the safety, quality and integrity of the food we deliver to customers.
Role of Food Companies
As a food company, US Foods’ role is to demand the best products from suppliers and require that they utilize the best food safety practices. We need to continue our commitment to educating our customers, which includes restaurants, healthcare and hospitality facilities, government operations and educational institutions, on the best products, practices and certifications used to ensure the integrity of their products. Of course, we ensure the integrity of the products while in our custody, but when we sell them to a customer, we take it a step farther and educate them on how to prevent contamination in the kitchen.
Visually, the distributor’s role looks much like a pyramid. At the top, the distributor determines food quality requirements with their suppliers and receives similar requirements from their customers. As the gatekeeper of the products, it is our responsibility to make sure that integrity is being upheld throughout the entire supply chain.
In the rare instance that a food product needs to be recalled, it is essential to have proven technology available to trace and remove the recalled product. In 2010, US Foods invested in a new electronic recall management system called eRecall. The system automates the initial communication of the recall and recovery action in our distribution centers, tracks their response time and provides the centers with a list of customers who purchased the product of concern. When the recovery action is elevated to recall status, the system sends an initial communication to all affected customers via e-mail and voice message. It also tracks customer response to the messages and provides our staff with a list of customers who have not responded. We can then reach those customers directly by phone or in person, thus ensuring that all parties are properly informed.
As an industry-leading food company, we need to continually enhance recall technologies and ensure that if a bad product is delivered to a customer, it is removed promptly and effectively.
Just as our company is responsible for ensuring that a contaminated product is removed from the shelf, it is also our role to investigate the problem afterward and work to ensure that it does not happen again. Oftentimes, multiple parties are to blame for contamination. In this case, we demand accountability from suppliers who may have provided a bad product or the operator who may have mishandled it.
Creating a Food Safety Culture
Companies can have thorough, written HACCP plans and protocols, but without making constant implementation of those plans a business priority, they will fall short. Every food facility must create a food safety culture. At US Foods, we have worked to make food safety the first priority of our employees. Before an employee moves a single box of products, he or she must be properly trained.
We have expanded our training programs to focus on individual tasks each employee must perform as part of his or her job on a daily basis. We also have implemented a learning management system for the delivery of online training, through which we are able to identify training comprehension in key tasks areas by job or region.
Consider regular training sessions and implementing a system to measure knowledge retention. The information we gather lets us modify the training to ensure better comprehension by job, specific distribution center or region of the country. Further, when the training data are connected with the data from second- and third-party audits, we can measure the impact of training on actual food safety performance of the facility. This allows us to better identify specific ways to improve food safety performance at the employee level.
We also help our suppliers create a food safety culture. We regularly invite them to our facilities and provide education on our quality standards. Identifiers include the look, taste, color, weight and cut of the product. By hosting this training, we have seen a significant increase in the quality of the products we receive from our suppliers, and in some instances, we saw a 50 percent reduction in product rejections.
As a food company, much of our work is focused on certifying facilities and demanding suppliers get certifications and adhere to strict standards. In the long term, certification equals standardization. The certification process requires facilities to provide proof of safe processes. By standardizing food safety, the entire supply chain can confirm that a facility is up to par and will not put their business, and more importantly, their customers, at risk (see “Hot Trucks Investigation: Maintaining the Cold Chain,”). For this to work, we must create more awareness and engage in customer education campaigns about the importance of certification.
It is essential to note that a food safety culture for an operator is different than for a supplier. For example, an operator should be much more focused on inspecting products upon delivery, safe handling and preparation of food materials, while a supplier would focus more on proper certifications and processes to ensure safe products. Your specific food safety culture needs to be clearly communicated to employees and customers.
Putting the Pieces Together
Food companies cannot wait for regulators to catch up with the industry and technology. As food safety professionals, it is our job to stay ahead of regulations and do what is necessary because it is the right thing to do, not because we are told to do it. As food consumers, we must demand a safe food source.
Food safety is a commitment; it’s an investment of time and money, but a properly designed and executed food safety system will save you both in the long term. The first step is enacting rules and laws that are attainable and realistic.
Leaders in the food industry must set the standard for food safety across the globe. This can be done through collaboration, both domestically and internationally. A number of organizations are working to increase the safety of our food supply. Consider lending your expertise to any one of these groups.
Everyone in the food chain needs to take a larger role in the direction of our food safety practices and help shape where we are headed. Food safety cannot be something that’s regulated. It has to be sparked internally by food businesses. The best investment in food safety your company can make is in its people. While you cannot regulate your way to food safety, you can train your team to put food safety before all decisions and actions. That creates a culture, and that culture produces safe food for all.
Jorge A. Hernandez is the senior vice president, food safety & quality, at US Foods. He can be reached at 847.232.5959; firstname.lastname@example.org.
My Food Safety Philosophy: It’s Just the Right Thing to Do
I’ve been working in the food industry for more than 20 years. At US Foods, I’m responsible for setting the food safety, quality and supplier sustainability vision and standards for the company’s distribution centers, food processing facilities, logistics unit and private label products. In addition to my day job, I have a responsibility to the industry to help raise the floor for food safety.
I deliver presentations at food safety conferences, sit on panels at industry meetings and have contributed to more boards than I can remember. Not because it’s in my job description, but because sharing best practices and promoting food safety makes all of us better at our jobs, it makes the food my family eats safer and it protects us from repeating critical errors.
In all of my professional roles, there has been plenty of overlap, but perhaps the most important aspect of food safety I have learned is that it requires a great deal of collaboration. There are no trade secrets with food safety. It’s imperative that we work together to ensure the safest food supply in the world.
It’s not only the best thing for your business, both operationally and financially, but it’s just the right thing to do.
Tom-a-to, Tom-ah-to:Sharing Differences for Global Safety
Whenever a contamination or product recall occurs, it throws a spotlight on the food industry. It’s important to ensure that when a recall occurs, we take the time to determine why it happened and how to prevent it from happening again.
The Florida Tomato Exchange’s “Tomato Metrics” meeting in Maitland, FL, earlier this year focused on how well food safety standards for the fresh-tomato supply chain have spurred effective food safety systems for tomato production and handling.
Suppliers and distributors know the importance of implementing effective and preventative food safety protocols, and this meeting focuses on providing the fresh-tomato industry with analysis of recent recalls and future prevention strategies.
Discussions with food suppliers at the event provided context surrounding past recalls and what organizations in the fresh-tomato supply chain can do to streamline and improve their food safety programs. We reviewed previous outbreaks and determined what went wrong before proposing targeted and effective solutions for prevention.
One of the crucial aspects of a food company’s job is to act as the gatekeeper between the producer and the plate. By reviewing previous recalls and defining a specific set of food safety protocols for the fresh-tomato industry, we’ll be more effective at reducing the risk of contamination in the future.
For more information about the meeting, visit www.floridatomatoes.org.
Hot Trucks Investigation: Maintaining the Cold Chain
A recent news investigation in Indianapolis followed police and local health department officials as they stopped a number of local and regional food distribution trucks. They found temperatures exceeding legal and safe limits for refrigerated and frozen food products.
During the investigation, many drivers claimed they were unaware that the temperatures were not at a safe level. Some admitted that they knew, but were told by their company to keep the refrigerator off to reduce fuel expenses.
Through this investigation, health department officials were able to partner with state police to ensure that any products not properly cooled would be destroyed. Operations like this illustrate how police and health officials are working close together to increase the viability of inspection programs.
Food safety should be a top priority for every link in the food chain. Companies should utilize thermometers and time-temperature recorders to gather data that can be merged with GPS and IT systems to not only regulate temperatures of products in transit, but to also manage the cold chain during loading, unloading and delivering.
Transporting food at incorrect temperatures is not only unsafe, it’s also illegal. In fact, the recent investigation led to Indiana’s consideration of a new law that would create a state body to enforce food transportation law.