Keeping Food Safe in the C-Store Environment
By Food Safety Magazine
“Gas station sushi”: Most of us have heard someone use this term to summarize food offered at convenience stores (C-stores). The saying evokes thoughts of a cheaply priced, half-rotted, foul-smelling, and unsanitary product that will make a consumer immediately ill upon ingestion. However, modern C-store foodservice programs have shattered the notion of “gas station sushi” by focusing on providing consumers with high-quality offerings produced and served in a clean and sanitary environment. Today, a consumer can expect to find everything from fresh-cut produce to handmade premium sandwiches and artisanal coffee at their local C-store. In the 2019 State of the Industry report, the National Association of Convenience Stores noted that foodservice sales accounted for the second-largest contributor to in-store sales (22.6% as compared with leader tobacco, which accounted for 31%). Capitalizing on these statistics, C-stores have made the development of foodservice programs a key focus to drive in-store traffic and distinguish themselves in the competitive C-store market. For these programs to continue to be successful, the need for strong food safety systems and policies aimed at consumer and brand protection has become more important than ever. However, due to the relative newness of premium foodservice offerings, C-store food safety professionals struggle to find food safety-related resources aligned with the complex challenges unique to the C-store environment.
Given the great importance and contributions of C-stores in the food industry, Food Safety Magazine convened an expert panel, moderated by Jeremy Zenlea, director of food safety, Cumberland Farms, to address some of the more critical questions regarding the challenges surrounding the C-store food safety culture. Participating panelists were Charles McGuffey, retired head of global food safety and quality assurance at 7-Eleven Inc., International Division; Jay L. E. Ellingson, Ph.D., senior director of food protection and science operations, and Marty Putz, director of food protection – retail, Kwik Trip; Richard Sterling, director of food safety North America, Circle K Stores; Chirag Bhatt, food safety professional; and Steven Mandernach, J.D., executive director at the Association of Food and Drug Officials (AFDO).
Food Safety Magazine: How does the variety of food products sold in convenience stores complicate the creation of food safety management systems or policies within the establishment?
Charles McGuffey: A variety of products is not as much a problem as one might think. Minimizing basic risk factors (cross-contamination, time and temperature control, employee hygiene, and shelf life) after the items are delivered to the stores is critical and most challenging, however. Staff training and consistent/perpetual monitoring are critical in this high-employee-turnover industry and must be kept as simple as possible and practical. Minimizing in-store preparation and staff handling is key when developing products. The process must begin with the suppliers and continue through the delivery system. Working with suppliers to develop cate-gory- and product-specific equipment with automated fail-safe equipment and short shelf life for fresh products and ingredients for in-store prep items is key to minimizing risks and optimizing quality.
Jay L. E. Ellingson and Marty Putz: With the creation of a food safety management system, companies need to break the variety of food products into different categories. The obvious categories are refrigerated, frozen, and shelf stable, but within each of those categories there can be concerns. A C-store that has minimal food offerings, using pre-packaged products with a limited variety, does not have the same requirements for a food safety management system. Most food is reheated, maybe even by the customer themselves. The hot-holding and preparation is minimal. On the other side of the spectrum, a C-store that prepares a large variety of products needs to create a more robust food safety management system. Increases in food handling or custom-made orders can challenge food safety. Traditionally, C-stores are challenged with kitchen space and design; if the store has a smaller footprint, it can be a challenge for adequate prep or storage space. Segregating raw and ready-to-eat products throughout the store (storage and prep) and the introduction of process controls in small spaces are very challenging.
Jeremy Zenlea: Unlike in manufacturing, quick-serve or full-serve restaurants primarily focus on offering a specific line of products to a uniquely targeted consumer demographic. In contrast, a C-store focuses on targeting all consumer demographics by offering a wide variety of food and beverage options to be presented in multiple formats. Take bakery items, for example: C-stores offer bakery items in several different formats—grab and go (from a bakery case), heat and serve, or in a retail package. Each of these delivery methods for the same item means that we have to design and implement several different Standard Operating Procedures to cover that one type of product. Now multiply that by all of the other product types offered in a variety of formats, adding in limited food prep and storage space, and one can easily understand how complex the food safety management system at C-stores truly is.
Richard Sterling: The busy lifestyles of today’s consumers have driven them to demand the on-the-go convenience of snack and grab-and-go foods in place of meals, and they now look to C-stores as food destinations. Many C-stores have already transitioned over to food as a destination driver, and their offerings include a variety of fresh foods such as sandwiches, wraps, salads, and cut fruit, as well as ethnic, vegetarian, and gluten-free foods.
In addition to consumer demand for variety, there is also the expectation of quality and “freshness” from the C-store food offerings, typically manifested by the inclusion of produce and nontraditional ingredients and components in prepared foods.
The increasing amount and variety of food products prepared and served in C-stores, along with the food safety risks posed by many of these relatively high-risk items (such as produce ), requires that C-stores work collaboratively with—and place more accountability on—suppliers, broad-line distributors, and other supply chain participants to mitigate these food safety risks.
Although many provisions of FSMA [the Food Safety Modernization Act] do not apply to C-stores/foodservice, this legislation has put renewed pressure on C-store operators to fully implement preventive controls (such as consistent and reliable temperature monitoring for equipment and food) rather than relying on reactive processes after failures occur.
Chirag Bhatt: Having several areas where food handling occurs, active managerial control to manage the most common risk factors is very important. Suppliers and their food safety, proper holding temps, and personal hygiene (including adequate handwashing) are key factors. Critical Control Points must be addressed efficiently.
Steven Mandernach: Convenience stores have changed greatly in the last two decades from primarily pre-packaged foods, with a soda fountain and maybe a hot dog roller, to a full menu of foodservice products, coffee bars, and more. The greater the number of temperature-controlled-for-safety (TCS) items that are sold and prepared in the facility, the more likely it is for it to have issues with food safety. The product mix will determine the food safety controls necessary, and different types of items means different controls to handle. Some chains expanded their product lines, but they did not always recognize the increased need for food safety professionals and training, which resulted in challenges. More prepared products increase the amount of time to prepare the items and the amount of training time necessary. The large number of products the employee is trying to prepare and maintain can be overwhelming. This can lead to poor practices such as not taking temps and poor handwashing.
As chains consider expanding product lines, visiting with the regulatory agencies in the states in which they do business can help identify potential challenges in advance and avoid regulatory challenges in the field. More prepared products require a greater amount of employee training in food safety, which can be challenging to achieve in the C-store environment.
Further, the independent or small chains, in their effort to compete with the larger chains, are often making the expansions into prepared foods without the food safety knowledge, written policies, and infrastructure to support the expansion.
FSM: What resources are available to convenience stores in terms of food safety? Do you have to adapt what is available for other segments of the food industry or create your own?
CM: Utilizing basic food safety best practices, we developed our own category and product-specific procedures for sourcing, delivery, receiving, storing, prepping/handling, serving, and monitoring all products with a shelf life. Combining the expertise of our category management teams and food safety quality assurance team with our store training and development team, we created both hands-on and CBT (computer-based training) resources for new and ongoing store staff training. All training materials are easily accessed on our in-store computers from headquarters to every store for easy reference and follow-up “just in time” instructions as needed. (All company employees from management to store staff are required to complete initial and follow-up training.) Store cleanliness and staff health/hygiene procedures are developed and trained with a goal of “the easiest way being the right way”…more likely to be executed in the fast-paced, high-volume environment. For fresh food items, both “category” and “product-specific” procedures are a must. Standardized equipment, tools, supplies, recipes, and ingredients are critical in order to globalize consistency in quality and quantity.
JE/MP: There are not that many C-store industry-specific food safety references out there. Convenience stores must reference full-service or quick-service restaurants’ best practices; some C-stores are bridging the gap (producing their own resources) due to the variety and customization of food and beverage items previously mentioned. We utilize the ServSafe programs and materials. With ServSafe, you’ll get materials developed by foodservice industry leaders and supported by the National Restaurant Association. ServSafe training helps you understand food safety risks faced by operations. Having said all that, ServSafe covers a variety of “raw” products assuming they will be cooked using a grill/fryer/oven; many of these products don’t come in the raw state for convenience stores—again, not always a good resource for convenience stores. Sometimes, once again due to the smaller footprint, creativity can be necessary to ensure food safety in unique environments, creating a food safety management system to bridge the gap between food safety needs and business needs. Yes, we do have to adapt training materials (such as ServSafe) to fit the convenience store segment.
JZ: Foodservice operations and the need for robust food safety resources in the C-store industry is relatively new when compared to restaurants and food manufacturing. Therefore, most food safety-related resources and trade organizations are largely focused on and designed for those industries. This essentially means that there is no “book” or benchmark we can reference when implementing and designing a new program, so we are forced to get creative and actively work with vendors to customize their products or build a product from the ground up so that it works within the C-store space. These resources are more expensive than the out-of-the-box options, take longer to implement, and there is no guarantee that they will work as intended. This negatively impacts our ability to roll out new food programs in a timely and cost-effective manner as we will not introduce any new food items without a strong food safety program behind them.
RS: A major resource that has proven invaluable for food safety is my company’s intranet. Recent enhancements and capabilities have enabled the quality and food safety group to post and track required food safety education and training campaigns to targeted individuals at all levels of the organization.
Also, digital tools have proven to be a more efficient and cost-effective solution for our internal food safety audit process as compared to the usual pen-and-paper method often used in C-stores and foodservice sectors. Coming from a food processing background, I’m naturally inclined to adapting processes from that sector to my present C-store role, especially since food processors had many of these same challenges years ago and found viable solutions through emerging technologies.
We are actively exploring newer technologies that enhance quality and reduce foodborne illness risks such as (1) blockchain and other integrated technologies to facilitate product traceability and supplier management, (2) remote monitoring to automate aspects of our equipment and product temperature compliance, and (3) Internet-of-things technologies to monitor water filtering and flow in dispensed beverage equipment. External resources such as third-party food safety audits are being deployed to ensure compliance to our food safety operational methods and practices.
CB: Your typical food safety management system is universal, and if the specific protocol works for a restaurant or supermarket, it will work in a C-store. After all, it is not rocket science, just food science.
SM: From a regulatory perspective, most of the guidance documents and handouts developed for other types of retail establishments apply directly to convenience stores also. Further, many convenience store chains have recognized the additional food safety challenges in their sector and have joined other professional associations to leverage the learnings of other sectors.
FSM: How challenging is it to manage the frequent deliveries of refrigerated products and other items with limited shelf life? How do you ensure cold chain management?
CM: We developed our own fresh food daily-delivered commissaries and warehousing/distribution centers and complex picking and sorting logistics systems to meet this challenge. Suppliers delivered to our distribution centers, then store-specific customized orders are handpicked or through automated picking, and then delivered in one delivery each day…always scheduled so the store is properly staffed and ready to receive every delivery utilizing the standardized food-safe procedures. Automated records always kept and filed as standard procedures. This process also frees up customer parking space that would be blocked by multiple delivery vehicles.
JE/MP: Depends on the number of deliveries a single store will receive and where these deliveries are received from. If you’re shipping from a centralized warehouse that is part of your supply chain, there is much more control on the cold chain. If you’re utilizing a third party to distribute to stores, then you must ensure the cold chain is managed. Companies that operate their own fleet of trucks/trailers and self-distribute can control the cold chain. Regular deliveries of product can help maintain good shelf life/turns with these perishable products. In many cases, the cold and frozen sections of the trailers are monitored via fleet management systems. When delivered, products are moved quickly from the truck to the area they belong in order to maintain the cold chain (walk-in coolers or freezers). Any deviation from the above could mean temperature abuse with temp-sensitive products both refrigerated and frozen. Once delivered, it is the store’s responsibility to label, maintain, and stock the items per existing programs.
JZ: Regardless of the type of food industry you work in, managing the cold chain is going to be a challenge. Temperature monitoring—whether by a remote sensor, TempTale, or a person—is key throughout the entirety of the supply chain, including at store level. The challenge lies in the fact that we have to manage frequent, small deliveries within a short amount of time to stores that also have limited storage space. Thus, the temperature-controlled environments within the trailers are continuously being disrupted and their contents are being staged in non-temperature-controlled areas while waiting to be put away. To best maintain the cold chain during these interruptions, we rely on our greatest asset to food safety—the store team members. Our team members are trained so that they understand basic food safety principles, such as proper temperature storage. Using these principles, they implement receiving procedures and storage methods that enable them to receive food quickly and efficiently. Store design also plays a major role in maintaining the cold chain; for instance, coolers and freezers are located in close proximity to the receiving door and designed to quickly cool down to safe temperatures once the receiving process is complete.
RS: Frequent food deliveries are a fact of life for convenience store foodservice, primarily due to the relatively short shelf life of the food products and limited storage space for TCS foods. Store employees are required to (1) inspect food deliveries for condition, (2) measure and document incoming refrigerated and frozen food temperatures to verify they are within the specified parameters, and (3) quickly store the food in refrigerators and freezers within a specified time. When stores are faced with the inevitable delivery of food during peak customer hours, it can become very challenging for store employees to handle their other tasks (cash register, food prep and service, etc.) while maintaining [the] cold chain of this incoming product.
CB: To accommodate limited shelf life and limited storage space (in many cases), deliveries that are more frequent may be beneficial, and utilizing a reputable and food safety-compliant distribution company, this task can be managed.
SM: Many times, deliveries are occurring all day and they can sit unnoticed for long periods of time. Beer tends to go straight to the cooler and stocked by the drivers, but other items can be out of temperature control for extended periods. We are seeing more refrigerated products being delivered directly into the cooler, which limits the sitting of deliveries for long periods of time outside of refrigeration. The limited staffing to verify the temperatures of deliveries and ensure quick temperature control continues to be a challenge. When there is adequate staffing, there tends to be sufficient cold chain management.
FSM: What do you see as the outstanding needs for food professionals at convenience stores?
CM: Basic training and professional licensed certification, along with the dedicated staffing resources and commitment to “doing what is right” with or without supervision, is the greatest need for food professionals at convenience stores. Training resources are abundant.
JE/MP: For store teams: training and guidance! Today, companies have a number of options to address training: ServSafe, computer-based training, and hands-on training for all other coworkers. Constant coaching is needed to remind foodservice employees of what the expectations are and why they are necessary. Explaining the reasoning for food safety practices will often result in employee buy-in, and even peers keeping each other accountable in a respectful manner.
For corporate/management: true dedication and buy-in. When senior leadership and operations management understand the importance of food safety in developing food programs, you are already ahead of the curve. Having to work just to get resources, involvement, or consideration is an unnecessary obstacle that takes away from time that could be spent developing programs, researching/participating in share groups, and ultimately mitigating the same risk that could put an end to your food programs in a worst-case scenario.
JZ: C-store food professionals need more avenues to openly collaborate and share best practices. It is no secret that there is still a negative public perception of the quality and safety of food offered in C-stores. Because of this, consumers tend to equate any negative food-related experience they have with the industry as a whole rather than just the brand name of the store from where they bought the food item. This need can be satisfied if more of the existing food and convenience store trade organizations enact subgroups or committees focused on solving C-store-related food safety issues.
Another need for C-store food professionals is a food safety system benchmark or standard that we can reference or strive for. The only standards that are available focus on other segments of the food industry and thus are hard to apply to C-store foodservice operations. Take the certified food protection manager, for example, as part of the FDA Food Code: We are required to have certified food protection managers on staff. While this is a great idea and will result in decreased consumer risk, the certification schemes made available by trade organizations are designed for full- or quick-serve restaurants and thus contain a lot of information that is not value-added or relevant for C-store personnel. Creating a benchmark will elevate the level of food safety for all C-stores, leading to fewer outbreaks, recalls, and any other negative consumer food-related experiences. This will inevitably help change the negative public perception of C-store food and drive more traffic into our stores.
RS: Rather than being characterized as transactional and reactive, the efforts of food safety professionals at convenience stores must encompass the following:
Training: Food safety professionals should be empowered to drive consistent, regular, and ongoing food safety education/training programs for all levels of the organization (including annual refreshers) in order to create a food safety awareness culture.
Internal assessments: After food safety training programs are implemented, food safety professionals should be provided with the responsibility to require accountability through internal and/or third-party assessments that will identify nonconformances and gaps.
Corrective actions: Sustainable corrective actions can then be developed through collaboration of cross-functional teams and departments, and deployed, resulting in continuous food safety improvements over time.
Processes codified: Written food safety processes and practices should be revised (at least annually) to reflect the improvements and best practices.
CB: For locations where adequate (and properly trained) staffing becomes an issue, food safety can be at risk as the team members may be multi-tasking, such as mopping the floor and turn around to make your pizza behind the counter. Let us keep our fingers crossed that the team member washed hands before getting that pizza in a box.
SM: Training continues to be a big challenge for C-store staff members. Many times, the staff have a high rate of turnover, and minimal investment is made to ensure they have the basic food safety knowledge needed for food workers. Further, staffing can be an ongoing challenge in this environment even more so than some of the other retail-type facilities. Staff are often repurposed to the most immediate challenge present. This can present a challenge in maintaining food safety by not having staff focused on this area.
Chains have often developed excellent procedures that if followed will maintain food safety but have not trained the staff members responsible for implementing these procedures adequately. They have a great system on paper, but it isn’t put into practice.
We also see hepatitis A as an area for ongoing concern in the C-store industry, similar to all retail. C-stores need to be very conscious of hep A and the potential for transmission in a food environment.
FSM: What would you say is the most difficult aspect of your job?
CM: Bottom line: Keeping stores staffed with dedicated food handling professionals was most difficult. Developing/instilling the food safety mentality (sometimes referred to as “second nature”) in every store staff member, compelling them to “do what’s right,” and exemplifying the same with colleagues is the greatest challenge and global goal—and praising/rewarding them for the same.
JE/MP: Trying to keep up with the pace that other company management moves at. New items, recipes, and processes are sometimes brainstormed, drafted, developed, and in place (with plenty of excitement surrounding them) before food safety has adequate time to assess the risk and develop a plan to handle it.
JZ: The most difficult—and exciting—aspect of my job is that in order to run an effective food safety system for a large C-store chain, one can never sit back and rest on their laurels. They must always be constantly studying and learning about all of the things that directly or indirectly affect the food safety of our food offerings. This includes ensuring that you have an expert-level understanding of different state, town, and federal regulations, latest food safety trends, all parts of the supply chain (manufacturing, storage, transportation, retail, etc.), and all the risks associated with the different categories of food produced in the commissary and offered in-store. Like other retail industries, C-stores are constantly evolving and changing to meet the demands of the consumer. Thus, it is important that your food safety systems can meet the demands of the company without compromising food safety.
RS: One of the most challenging is supporting different business units across the U.S. in their efforts to comply with local regulatory requirements. Although the majority of state health departments have adopted FDA’s Food Code (either the 2013 or current 2017), enforcement criteria of the various agencies can often be different among state and/or local health departments (e.g., a few states require that signage is posted in the C-store eating area, accessible to both employees and customers, detailing the steps to aid a choking victim). It is a rare week when I don’t have to review and interpret a local code in an effort to support a group of affected stores within a state or region.
CB: Food safety professionals at a convenience store—like many others—will be faced with the constant turnover issue and having to retrain the new team members. Training and refresher training becomes challenging due to limited resources. Best advice—get them trained before they touch any food item and refresh it every 2 years. Daily reminders about important topics can go a long way.
SM: Getting the establishment employees to understand the importance of food safety when they can barely keep up with their immediate duties; when there’s a line of customers waiting, the employees may not see taking a temperature or washing their hands to be a high priority. Periodically, chains operating in many jurisdictions may have policies or procedures that do not conform to an individual jurisdiction’s regulations.
Retail food companies are not only the final step in the food supply chain but are also the final defense against foodborne illness outbreaks. If retail food companies follow the five best preventive practices, they can manage food safety risk at a high level. These “Five Preventive Food Safety Risk Processes” require companies to:
• Use the best personal hygiene practices
• Cook food to the proper temperature
• Hold food at the proper temperature
• Use clean and sanitized equipment to prevent cross-contamination
• Purchase food from safe sources
To execute these practices, you need the right people, processes, equipment, and facilities. If you as a company can do this, you will be in a better place as you mature as a foodservice provider. It may not be easy or cheap, but creating a culture of food safety in your company from the top down will allow these practices to become part of your everyday process and help you succeed in your retail food safety program.
We would like to thank all the panelists for their insightful comments and engaging discussion. A special thanks to the staff at the Florida Department of Agriculture and Consumer Services and the Kansas Department of Agriculture for providing input into the AFDO answers.