[AIB Looking Back] Common Threads

After nearly 30 years in the food industry, my career has come full circle. In 1980 I began my career as an AIB inspector. I covered 11 states and two Canadian provinces. After three years with AIB, I decided to make my mark in the industry and create change. After all, I had conducted hundreds of inspections in virtually every type of food plant, distribution center and warehouse available, and was certain that I could run these operations better than anyone with my varied experience.

It wasn’t long before I realized that I needed to achieve a higher level of authority if I was going to have any real influence on how things were run. Over nearly 20 years, my career went from plant sanitarian at a large flour mill, to food safety manager at a large international food company, to operations manager at a snack food plant, to general manager at a bakery, to vice president of supply chain at a large restaurant company. Then, I started my own consulting business and ran that for the next 10 years. Most recently, I returned to AIB International as director of food safety education with the opportunity to use my years of experience in the industry to help other food companies.

During my diverse career, I have learned a lot and have a unique perspective to share. I have seen the food industry from nearly every angle. I’ve worn every hat imaginable, from sanitarian, to manager, to decision-maker, to consultant, to inspector and now educator. One thing I have learned from my experiences is that there are common threads that are shared throughout the entire industry.

STATE OF THE FOOD INDUSTRY. When was the last time you went grocery shopping and looked at produce, meat, milk and even pet food without considering quality, nutrition, performance and potential illness? I was recently in the produce aisle at a grocery store and overheard a couple discussing which vegetables to purchase. One of them was trying to recall which product was announced in the most recent product safety alert. The other person said, “I don’t know. There have been so many!” Although this was probably said somewhat jokingly, I think it reflects the concerns that many consumers have. Numerous recent food recalls have eroded consumer confidence in the food industry’s ability to deliver safe food.

It would be interesting if a study was done to determine how much processed food that does not meet product specifications or regulatory requirements makes it to the packaging stage and is then caught and withheld from distribution. Even though we know some non-conforming food products reach the consumer, I think the public would be surprised and impressed with the steps and cost the food industry takes to maximize product safety and quality. This is only truly known by those of us who spend our careers in the food industry.

In spite of recent issues, the food industry deserves credit for implementing food protection and quality programs, procedures and follow-up activities that extend through the supply chain. Considering the volume of food that is processed, manufacturing complexities, the expanse of the global supply chain and natural disasters that occur, the United States’ food supply is still the safest. There have been significant advances in testing technology, process controls, program implementation, business assessment philosophies, lean manufacturing, risk assessments, corrective action plans and the adoption of certified audit schemes. With all of these advancements, the food supply should be improving, with longer gaps between product safety incidents, increased sustainability of quality attributes and greater consumer confidence. After all, aren’t these reasonable expectations if the improvements and monitoring processes are continually implemented? However, with the recent product safety incidents, it seems the opposite is happening.

The food industry faces significant challenges from many directions, including rising ingredient and packaging costs, increased fuel cost for transportation and facility operations, multilingual work forces, foreign competition and management of foreign suppliers. In the effort to make a profit and keep above the breaking point, many companies are adopting business strategies that were not standard practice 15-20 years ago. Some of these new approaches to reduce cost and improve quality and customer satisfaction have reduced or eliminated the very practices that brought success in the first place.

Serious product non-conformances would not happen as frequently if companies experiencing problems were continually and correctly doing what needs to be done. There are five common problem areas that many food companies face today.

SENIOR MANAGEMENT COMMITMENT. Over the past few decades, food production, warehouses and distribution centers have evolved from family-owned regional businesses to large global companies. Back in the day, family companies were operated and managed by the owners who were generally well-known and respected in their communities. Many times, they not only provided jobs, but also were instrumental figures in community development through philanthropic activities. They realized that success was based on satisfying their customers, whom they faced every day. Senior management commitment was demonstrated through product quality and safety, not by a quality statement displayed throughout the facility.

Senior managers at today’s large food companies often find it easy to separate themselves from their customer base. There have been many instances when I have asked senior management to describe their responsibility for product safety and quality and they reply that there is a quality assurance staff to handle that. The main problem is that most executive management members do not come from product safety or quality disciplines, have not spent time in the trenches of “product safety warfare”, and have little interest in the science.

A structural mistake that many companies make is to place quality assurance at lower levels of the organization, often reporting to senior managers that have little, if any, experience in QA. This does nothing more than place a muzzle over quality assurance until a problem occurs and then management relies on QA to take the lead and solve the problem in the quietest way possible. During my career, I remember an instance where a new director of quality assurance was promoted and I reported to him as a manager. During our first meeting, the director, who came from R&D, asked me to explain what I did. When I mentioned GMPs oversight, he asked what that acronym meant. I knew immediately what my role would be and what to expect in the way of support.

Senior management at all companies can demonstrate commitment to product safety and quality by personally participating in pertinent activities. The common practice of including product safety and quality in a mission statement is a good first step, but must be followed with personal involvement throughout the organization. Another strong message of commitment is to represent product safety and quality as a separate entity at the highest level of company management…not combine it into operations, supply chain, marketing or finance. After all, it is easier to teach QA managers business management skills than it is to teach business managers QA science.

Another way to demonstrate senior management commitment is to include product safety and quality objectives with performance metrics in annual strategy planning by ensuring that pertinent operations departments have vertically integrated supporting objectives and necessary support. It may also be beneficial to place product safety and quality department budgets and initiatives off-limits for reduction.

Senior management must realize that product safety and quality hazards do not occur on a schedule, are not sensitive to the economy, and will not wait until things slow down to occur! More often than not, they occur at the most inopportune times. That is why process surveillance programs, procedures and activities must be maintained at the level corresponding with the risk to consumers.

MANAGING FOREIGN SUPPLIERS. In recent years there has been a considerable increase in using foreign suppliers for ingredients and contract packaged products. Due to the travel expense of visiting these foreign suppliers, many companies rely on paper audits and supplier questionnaires for approval. In many cases, supplier visits are only made if there is a high risk, if the supplier is new, or if the visit can be done in the first quarter of a new budget year. However, it is critical that foreign suppliers are treated the same as domestic suppliers. If a supplier is new to a supply chain it is even more important for detailed scrutiny. The cost of risk assessment, product testing, inspection and follow-up is justified when you consider the long-term impact of non-conformance and possible consumer injury or illness.

The recent recalls due to melamine in pet food and milk products from China and peppers from Mexico should be enough evidence that supplier quality surveillance must not be relaxed. It is important to ensure that foreign suppliers have the same programs, procedures, practices and verifiable documentation to support and prove that materials are safe and meet your specifications.

It is also important to visit food handling locations and inspect them against a globally recognized format. This activity can be performed by third-party auditors if needed; however, be sure the company has product safety and quality knowledge about the food and process. Based on a risk assessment, the supplied food or packaging materials must be tested for critical attributes before receiving and on a reasonable frequency thereafter, essentially challenging specific aspects of the Certificate of Analysis (COA). The testing frequency can be reduced once performance information and risk assessments are reviewed.

TRAINING A MULTILINGUAL WORKFORCE. The increasing multilingual workforce presents several challenges to the food industry. Communication is the most important hurdle to overcome. Without accurate communication the basics of food protection and quality, namely instruction on GMPs, hygiene, and prerequisite and food safety procedures, cannot be achieved. In the United States, many employees who operate process equipment, handle unprotected ingredients and finished product, and perform critical control point checks cannot speak English. To make things worse, not all companies provide work instructions, procedures and operating documentation in the languages of the employees performing the tasks.

Management must be sensitive to and accept the fact that a multilingual workforce is a permanent reality and take the necessary measures to provide all pertinent policies, procedures, operating instructions and performance documentation in the languages spoken in their plants. Another step is to ensure there is at least one person on every shift who can interpret the languages spoken.

CERTIFICATION AUDITs. The food industry has recognized a shift away from the standard GMP inspection toward the various system audits that have been developed and implemented over the past 20 years. One interesting aspect of this shift is that there have been food safety recalls of historic magnitude in the same timeframe. A mistake that food facilities make by shifting totally to scheme audits is that they are placing all of their confidence in a conference room exercise with little regard for what is actually happening on the floor, which provides a false sense of security if certification is achieved.

There have been countless times where scheme audits are completed and then facility inspections reveal severe conditions that contaminate the product. During one AIB inspector’s recent visit to a food processor, senior management told him that their programs were outstanding and there was no problem in the facility that they were not aware of. Not surprisingly, their documentation supported that statement. In the plant, the inspector found the metal detector’s performance document to be completed as discussed and the employee was able to correctly explain the metal detector procedure. However, when the employees performed the actual check, the detector did not detect the test wand! The line was shutdown, product placed on hold, the detector was recalibrated, and product was retested. As luck would have it, when the detector was calibrated to detect the test wands, the reject mechanism was out of timing. Similar situations happen too often. It is critical to remember that documentation design, data accuracy, well-developed manuals and processes are important, but they do not take the place of visual verification.

Senior management must realize that documentation audits, detailed facility inspections, visual verification of implementation and effective employee training must be integrated into a comprehensive food safety and quality program. If designed and implemented correctly, these programs will support and complement each other.

CORPORATE STRATEGIC GOALS. Unfortunately, corporate strategic goals and objectives rarely include product safety and quality assurance objectives with performance metrics. Operating budgets are developed around the strategic goals. When product safety and quality goals and objectives are buried inside other strategic goals, QA usually ends up struggling and competing for budgetary support since few understand the needs and operational logistics of quality management.

Hopefully, executive leaders affected by recent product recalls will realize that the failures were not related to sales, marketing, manufacturing, distribution or advertising, but rather to not performing product protection and supplier approval procedures. Create corporate goals and objectives with specific key performance indicators (KPIs) for reducing customer complaints and CCP check failures.

Consider a separate product safety and quality budget that is off limits to reduction. Establish the cost of non-conformance for your company and, as a KPI, compare and measure QA budget expenditures as a ratio to that cost. I guarantee the cost of quality, in relation to the cost of non-conformance, will be very low and money well spent. This can only be done with continual support for staffing and resources with a sufficient budget.

NEXT STEPS. There are some next steps that companies can take to improve their product safety and quality commitment:

Create a Visible Culture of Quality Commitment. Surveys that assess consumer confidence in the food industry are not flattering. We are in the shadows of recent issues and have the opportunity to regain lost ground. Executive leaders have the responsibility to step up and support the initiatives that will move the dial. A primary objective of food companies should be to do whatever is necessary to regain consumer confidence, which will have a considerable long term impact.

Consumers need to see demonstrated proof that the food industry is protecting their food before confidence is gained. We can only control this in our own companies, with cooperation from our employees, suppliers and service providers. Food companies that are truly dedicated to maintaining consumer confidence will need to implement and integrate unconventional and standard measures to overcome the perception. The measures must correspond to the changing and, in some instances, uncertain industry we face.

Consumers have the final say about your product. The entire supply chain, from farm to fork, shares the responsibility to provide consumer confidence.

Create or Enhance a Culture of Quality:

• Review your company mission statement to see if your commitment is clearly stated.
• Ensure all department statements include a product safety and quality statement that is vertically integrated to the corporate statement.
• Include a product safety and quality expert on the senior management team with the same level of importance as sales, marketing, operations, finance, human resources and legal representatives. The responsibility for safe and quality food is evaluated more often than other company functions by the customer.
• Create corporate strategic and tactical goals, objectives and performance metrics. Communicate them to the entire facility and review their performance on the same frequency as other important company performance indicators.
• Ensure operating departments have performance objectives related to product safety and quality that are vertically integrated and support corporate goals.
• Consider providing a separate budget for product safety and quality that is off-limits to reductions. Typically, these are the smallest company budgets so reductions are usually insignificant to the overall P&L. Also, the risk that this function manages (company reputation and solvency) is more significant than all budgets combined.

Manage Suppliers. Inspect supplier facilities and audit their systems as they are happening. Documentation audits and sample product evaluation are not enough because suppliers send their best to sample and will send documents that look nice, but may not represent what is actually happening.

Inspect the Facility. Continue using GMP inspections as part of the overall food protection program. Do not do away with GMP inspections and replace them with certification audits. Product safety and quality do not happen in the conference room or office, but in the facility.

Training and Operations Materials. Provide all operating instructions and training materials in the languages spoken by employees at the facility. Provide consistent training across the multi-cultural spectrum. Consider providing a risk assessment of the operating stations and ensure that positions with the highest risk are staffed with fully-trained employees with appropriate performance documentation and instructions.

The food industry has employees at all levels who are genuinely dedicated, highly educated and experienced. Along with our technological advances, industry think tanks and associations, there is no problem or challenge we cannot conquer. The downside to all of these assets is that we sometimes get caught up in the newness, and forget the basics and our primary mission to supply food that is safe, meets customer quality expectations, and satisfies government requirements. We must rise to the challenge to be responsible and never forget that we are the caretakers of the food we consume.

The author is Director, Food Safety Education, AIB International.