Food Safety Priorities and Plans for 2020 – Part 2
By Bob Ferguson
In our last Food Safety Insights column, we discussed what processors told us about their project plans for 2020. We received responses from more than 200 processors from around the world across all types of food products.
From the responses that we received, and as we reported in the December 2019/January 2020 issue of Food Safety Magazine, it was clear that food safety professionals will have a lot on their plate this year. But even with the numerous issues they identified that need to be addressed, processors made it clear that issues related to microbiology, environmental monitoring and pathogen control, and employee training will be the leading issues of concern.
We wanted to find out more by talking directly to those who responded to the survey. We spoke with individuals from many different companies, including dairy, packaged foods, and retail, but heard most often from produce processors, especially of leafy greens.
What’s in Store for Leafy Greens?
Last year was undoubtedly a tough year for leafy greens, especially with the attention on romaine lettuce. We heard that finding out what is happening in the affected growing regions and solving the issue that is causing the contamination and high-profile recalls are certainly on everyone’s to-do list to solve as soon as possible.
Many, of course, believe that the root of the contamination in leafy greens is irrigation water. For this reason, many processors told us that they believe that the implementation of the Produce Safety rule and its water testing and control requirements will be a key measure in improving on-farm water control. In our interviews, many agreed that better control of irrigation and on-farm water will be an important area where we’ll see significant progress in the coming year. The people we spoke with, however, did add that the farms that they work with are already in compliance with the testing requirements, even though compliance has been delayed until 2022.
One interviewee mentioned that perhaps a more impactful change will be the requirement for a Preventive Controls-Qualified Individual (PCQI) at many of the packinghouses. According to this individual, many of the multi-farm packinghouses have not had this type of individual with formal training in the past. Having someone available with better knowledge and training will help tighten operational controls and contribute to improvements in the food safety culture at farms and packers. The requirement for a responsible person to oversee and implement the Produce Safety rule at single-grower sites and a PCQI downstream at multi-site packinghouses will help greatly in advancing the needed farm site improvements.
Certainly, not all the farms are complying; some, it seems, are even impeding the ongoing investigations needed to solve the underlying contamination issue. In our interviews, we heard reports that officials from the U.S. Centers for Disease Control and Prevention and the U.S. Food and Drug Administration (FDA) who are working on investigations of romaine contamination are getting resistance from some farmers who are reluctant to give them access. The resistance has been evident for the on-farm visits that are part of outbreak investigations and for the research needed to better understand the problem. While regulators should have more authority to gain access in cases of regulatory investigations, we were told it is easier to impede or delay an investigation for research purposes. In the News Bites (page 7) section of the December 2019/January 2020 issue of Food Safety Magazine, we reported that FDA is conducting a 1-year project to collect and analyze samples of raw agricultural products for foodborne pathogens. If this delaying tactic is as acute or as widespread as we have heard, one can imagine that this will become an issue that we will be hearing quite a bit about throughout 2020.
We also heard comments that once the root cause has been identified and a solution has been found, better processes for supply chain control from farm to fork will need to be implemented. One practice that was mentioned as an issue that may need to be revised is the “one-time buy” of agricultural products—that is, buying products lot by lot in what was described to us as an auction process. These lots of product are much more difficult to track and leave the buyer with little insight into controls at the farm level versus a more integrated, long-term relationship between a buyer and the farms supplying product.
One of the fruit and vegetable processors that we talked with also said that supply chain issues were impeding improvements of their environmental monitoring program. While they emphasized that they were confident that their program was effective at controlling pathogens, there were details of their program that nonetheless need improvement but were being delayed by the lack of progress by some of their suppliers. They reported that they worked with many small farmers who were struggling with elements of their own programs, especially wildlife control. Uncontrolled wildlife on farms can not only negatively impact the product itself, but the pallets, containers, packaging, and equipment used on the products can have impacts as well, and many of the smaller farmers lack the resources to effectively solve these types of problems. Again, while they reported that they have good control of their processing at the plant level, and their in-plant processing can compensate for shortcomings at the farm level, these issues with their suppliers are holding up their Safe Quality Food certification. This is a key issue that they would like to solve early in 2020 to achieve that certification.
Supply Chain Challenge: Environmental Monitoring
A supplier of spices also said that issues of environmental monitoring in their supply chain were a top priority. As their supply chain is global, they deal with not only many small farms and suppliers, but also farms from around the world and in countries and regions that may have a limited understanding of Food Safety Modernization Act requirements and, in some cases, of pathogen controls. Spices are a difficult matrix to work with and, as we were told, “You need to really look for microbiological contamination and not just run a few tests or wait to respond to something that happens…this is a reality that is not well-understood around the world.” Again, we heard that larger companies were better at managing this than smaller ones, but “in the world of spices, you will inevitably find yourself dealing with many smaller companies—especially in a worldwide market.”
Keeping Up with Employee Training
The other prominent issue we heard about was training, especially finding better means to make training more effective. As we discussed in the last issue, respondents indicated that training was not only one of their key priorities in 2020 but also a foundational part of everything else they wanted to achieve.
One of the individuals we spoke with had a unique perspective. This person works in a high-volume foodservice operation serving more than 16,000 meals to more than 8,000 individuals every day. In this operation, similar to what we heard from processors, it was not the specifics of the training that will be their focus but finding better ways to ensure compliance with the training or, as we were told, to “get the training to stick.” In our interview, we heard, “We have all of the required and needed food safety training that one would expect in a well-run operation, but we need to use whatever better means we can to continue to reinforce the training. We use regular handouts, posters, and constant reminders to bolster the most important points of food safety in a foodservice application such as ours. We are planning on adding a special section in each employee meeting to address food safety issues, and this is an improvement we hope to add in 2020.”
A person with a large retail operation echoed these same thoughts about the importance of training. “We make sure that every person with food contact responsibility has a ‘food contact permit’ and is well-prepared for their job. We don’t assume that every 18-year-old foodservice employee automatically knows the right thing to do. We make sure that they do know and continually reinforce all of the practices they need to follow.” When asked for more detail, the respondent added, “Each of our regions is responsible for regular retraining programs, and they follow those up with unannounced spot audits to assure compliance.” This person also added that they reinforce food safety and compliance on a regular basis by making it a key part of all of their employee communications. “In our regular employee newsletter, we have a section for ‘Hot Topics’ that we frequently use for food safety topics. We not only emphasize best practices that they should be following to keep it top of mind, but we also show statistics on foodborne illness to emphasize the crucial nature of the work that they are doing and keep them thinking about the people that they are serving food to.”
More Eyes on Food Fraud
While food fraud was not one of the higher-ranked priorities in our survey, it was mentioned by a number of respondents and is a topic we have discussed many times here in Food Safety Insights. In the same interview with this retail professional, they emphasized that they are seeing the nature of food fraud changing, and it is increasingly becoming a priority on their list. “It is not the largest issue that we deal with, but we do see that food fraud is becoming a more difficult issue all the time,” they said. Another respondent with a global supply chain added, “We have found products with our brand name on the label coming in from Asia that were clearly not our regular product. We were able to show that the product (in this case, mixed nuts) in the can were counterfeit by sending them to a forensic food safety lab for DNA testing to prove the product was counterfeit.” They added that while they had seen issues of fraud as long ago as 20 years, the speed at which the counterfeiters are improving their methods and getting “very good” at reproducing labels and packaging is making fraudulent product more and more difficult to detect.
We would like to express our thanks to everyone who participated in our survey and especially those who agreed to be interviewed for this article.
And, as long as we are talking about goals for 2020, our goal here at Food Safety Insights for this year is to continue to follow these and other important issues in food safety. We will also continue to seek out what is actually happening “on the ground” in food processing companies, to listen to the viewpoints and ideas of food safety professionals from around the world, and to deliver that information to you.
Bob Ferguson is president of Strategic Consulting Inc. and can be reached at firstname.lastname@example.org or on Twitter at @SCI_Ferguson.