In July, FDA published its long-discussed Blueprint for the Future: New Era of Smarter Food Safety. The blueprint, focused on four core elements — Tech Enabled Traceability, Smarter Tools and Approaches for Prevention and Outbreak Response, New Business Models and Retail Modernization, and Food Safety Culture — held no real surprises for anyone who has been tracking with any of this since it was first announced in April 2019. As has been true since the beginning, the blueprint is intended to build on FSMA implementation while leveraging the use of new and emerging technologies.
As a “blueprint,” it includes no legislation or guidance — although, like guidance, it states that it “represents the thinking of FDA” along with other groups with which the agency consulted. Rather, it provides more detail on the directions FDA would like the industry to take, gives us some ideas of what FDA sees as critical to food safety for the next decade, and places a strong focus on traceability and the integration of technology and predictive analytics in all areas.
While 2020 has brought with it significant challenges, particularly for the management and essential personnel of the food industry, those challenges also are providing us with new learnings that are as applicable to issues of food safety as they are to the public health aspects of COVID-19. With the essential needs of both being the protection of people and prevention of outbreaks, the elements of the first two core elements of FDA’s blueprint, focused on traceability and outbreak prevention and response, are similarly applicable. And because of that, practices, processes, and technologies developed and implemented to reduce and/or predict the spread of the pandemic can be applied to food safety and traceability in the food supply chain as well.
Thus, while the pandemic was the cause of FDA’s delayed distribution of the blueprint, the lessons learned during the deferral were also the impetus for some of its new approaches. Like FDA, and likely many others in the industry, TAG has seen a similar light breaking out of the shadow of the pandemic.
Take, for example, the matrices that TAG developed to provide state-by-state predictive analytics on COVID-19 risk and trends. The matrices, which are updated weekly, illustrate the variabilities in state COVID-19 testing, compared with the percent of tests resulting in positive diagnoses, and show week over week trending. This trend analysis provides an assessment of where the greatest risks lie and the direction those risks are trending, thus enabling businesses to determine where the greatest protections were, and would be, needed.
In the same way, a similar matrices of foodborne illness outbreaks, associated foods, and risk-based trends can provide the industry with predictive analytics for the leading indicators of potential food safety issues, enabling preventive risk assessment and strategic action, as well as more responsive crisis management for the food supply chain.
It is just these types of learnings from both internal and external industry incidents and events to which FDA’s statement on Smarter Tools and Approaches for Prevention and Outbreak Response applies: “To fully realize a preventive controls system that rapidly incorporates new knowledge, it is important to ask how we can make processes and communications more effective, efficient, and in some cases, simpler.” This is particularly applicable in its further statement that it is essential to have “alternate approaches when traditional methods cannot be carried out during a public health crisis.”
While there were really no surprises in the blueprint, as stated, that is not a bad thing. FDA is following through on its original intent, while integrating lessons learned from an externally caused situation that has had significant repercussions for the industry. As the COVID-19 pandemic, and its mid-summer resurgence, has shown us, we need to get out in front of an issue before it develops into a nearly unmanageable problem — which may involve significant, widespread behavior change. And whether talking public health or food safety, we need to leverage all data that can be collected in ways that can help reduce and manage the risks.