With the COVID-19 pandemic and businesses entering recovery — while still seeking to protect employees — the basics of food safety have become even more critical. What does this mean, what is being done in food plants, and what carryover do we expect in the “new normal”? Three articles discuss the basics of:
On April 30, 2019, FDA announced the development of a strategic blueprint for the future of food safety: New Era of Smarter Food Safety. With a goal to “leverage technology and other tools to create a more digital, traceable, and safer food system,” FDA solicited stakeholder input and held an all-day public meeting in October 2019 to help shape the blueprint. At just over a year since its introduction, where does the “New Era” stand?
Having worked on the blueprint since last year, said FDA Deputy Commissioner for Food Policy and Response Frank Yiannas, “We were on the verge of releasing it mid-March — then shifted because of the pandemic.” But, he said, the FDA teams have continued working on it. “New Era for Food Safety is a blueprint for a decade-long roadmap that we will release when the time is right, so we’re continuing to work on short- and long-term deliverables.”
In fact, he said, “Having gone through the pandemic, there are so many things we talked about that would have been beneficial if the pandemic had happened in the future,” such as the implementation of digital, technology-enabled remote surveillance and the importance of food safety culture. “So I’m confident that the ideas were the right ones.”
Additionally, although the COVID-19 pandemic has brought numerous challenges and disruptions for the food industry, its responses have moved technology and other areas forward in ways that will inform and benefit the blueprint. “An unfortunate positive has come out of the pandemic,” Yiannas said. “When the dust settles some best practices will emerge.”
NEW ERA LEARNINGS. In relation to the four core elements of the blueprint, Yiannas said the pandemic has brought new learnings in:
Tech-Enabled Traceability and Foodborne Outbreak Response. The pandemic has clearly shown the importance and strengthened the realization that traceability goes beyond food safety, he said. “Traceability is the foundation of transparency; having knowledge of where the foods are at any point of time is invaluable in situations like this.”
In the case of the pandemic, traceability could have more accurately pinpointed where excess food was to enable it to be diverted more quickly to where it was needed. It wasn’t that there was not enough food, he said, there was too much in the wrong places. If we had had a more digitized, interconnected food system, this could have been better handled, both then and in the long-term. However, he added, it needs to be digitized with appropriate standards, labeling requirements, etc., so the food system can become more interoperable.
When asked about the reference to blockchain by FDA Commissioner Stephen Hahn at a February NASDA Conference, Yiannas said blockchain is one of the technologies being discussed, but it’s not the only one. Internet of Things (IoT), artificial intelligence (AI), and other technology tools are also being discussed.
“I have no doubt that blockchain will be part of the new era,” as it is an emerging platform toward which the industry is migrating, Yiannas said. But he feels that FDA should be technologically agnostic. The agency is interested in any technology that will help with traceability, he said, “But it’s not about blockchain; it’s not about IA. It’s about the public health challenge we’re all trying to solve.”
Smarter Tools and Approaches for Prevention. With the travel and shelter-in-place restrictions of the pandemic, FDA as well as state and locally regulated inspections were brought to a halt. Because of that, some areas started conducting remote virtual inspections at retail. Those inspections and experiments in different states, and in other countries, are providing lessons that can be applied to the development of more remote monitoring and surveillance. It is an area the Food and Drug Administration had planned to develop, Yiannas said.
Adapting to New Business Models and Retail Food Safety Modernization. “The tsunami of buying online is changing retail,” Yiannas said. During the pandemic, there was a rush to get into e-commerce and online ordering. Prior to the pandemic, FDA had anticipated that 20% of groceries would be ordered online by 2023. “But we’re seeing that the conversion is happening much more quickly,” he said, and he doesn’t see the trend reversing when the crisis has passed. So FDA will look at what worked and what didn’t. There probably will not be one best way, rather they will be able to compile best practices.
“There is a tremendous experiment going on as businesses have jumped into online,” Yiannas said, adding,“We have been very observant in talking to industry about best products and technologies being used.”
Food Safety Culture. Though he may not be the originator of the phrase, Yiannas has been the most prominent and prodigious driver of food safety culture through the industry. At the start, he said, it was difficult to get executives and food scientists to focus on the “soft stuff” of culture. But during the pandemic, at a time when regulators were not able to get to facilities, the idea that the food facility has the responsibility to produce safe food regardless of federal oversight is critically important. In fact, Yiannas said he found that those organizations with the strongest food safety culture were very quick to adopt worker safety measures. As such, he said, “An established and strong culture of food and occupational safety is critical to our future.”
PUBLIC/PRIVATE PARTNERSHIPS. In addition to the lessons the pandemic brought to the core components of the New Era blueprint, Yiannas said, it showed the importance of effective public/private partnerships.
When the COVID-19 pandemic hit, it caused a great deal of supply-chain disruption. But through close coordination between the public and private sectors, he said, they were able to work to get the food where it was needed.
It wasn’t that there wasn’t enough food, but that there was an imbalance, he said, explaining, “There was a lot of food, but it was in the wrong places.” Close coordination helped divert the food to be used, and temporary FDA policies allowed shipments to go to retail without full nutritional labeling, as long as they had clear ingredient labels and allergen listing. FDA also worked with FEMA to get face coverings to industry, he said. “I talked to folks in the private sector every day, multiple times a day,” Yiannas said. “They were an invaluable source of information.”
INDUSTRY RESILIENCY. Having been in the private sector for more than 30 years with executive food safety positions at Disney and Walmart, and now at FDA, Yiannas said, “I’ve always thought that the US food system was one of the best in the world. The crisis has tested the food system, but the reality is that there is a lot of positive. The system was tested harder than ever before, certainly than in the last 100 years, and the fact is that you can still walk into the grocery store and see tens of thousands of SKUs.”
As such, Yiannas said he has been impressed with the resiliency of the food industry during the pandemic, stating, “I have no doubt that we will learn lessons and create a stronger and more resilient food system.”
The author is Editor of QA magazine. She can be reached at email@example.com.
In 2019, the Asthma and Allergy Foundation of America (AAFA) conducted a three-part study on “My Life with Food Allergy.” In the first report from the study, parents and caregivers of a child with food allergy relayed the impacts that caring for that child has had on their family...
… SOCIALLY. “The hardest part for me is just never letting my guard down. There are no breaks from food allergies.” Because food is a fundamental part of many daily activities and social events, families that have a child with food allergies must be constantly vigilant to keep the child safe. The fear of an allergic reaction, particularly that of anaphylaxis (a severe, life-threatening allergic reaction), can take a heavy toll on children and their caregivers. Parents of children with food allergies can experience anxiety, depression, isolation, and stress associated with the risks of reaction and possible societal stigma.
… MENTALLY. “Food allergies are a hidden disability and the mental anguish can be overwhelming.” One of the most challenging activities to navigate is that of dining out; this is due largely to the lack of standard regulations and policies for labeling and staff training in restaurants and other establishments that serve food. For many parents and caregivers, the constant fear of accidental exposure to food allergens leads to a loss of normalcy and results in adjustments in decision-making and daily routines. Acute awareness at every meal and in every new environment can be stressful.
… FINANCIALLY. “Buying allergen-friendly foods for my son more than doubled my weekly grocery bill.” Nearly half (44%) of parents surveyed rated the financial impact as a 4 or 5 (on scale of 1 “no impact” to 5 “major impact”). And 44% said they or their spouse had to make a career choice (such as quitting or changing jobs) to care for their child with food allergy. That decision had a negative impact on the household finances for 84% of those, with 49% incurring increased debt, and 28% having to seek social assistance.
… EMOTIONALLY. “The food labeling is so confusing — I’m a physician and my husband is an attorney, and it’s incredibly confusing.” Currently, the standard of care for food allergies requires strict avoidance of the allergen. This means that parents of children with food allergy must be able to accurately identify potential allergens in all foods and products. The lack of standardized regulation around precautionary allergen labeling leads to increased anxiety and fear among parents and makes it more challenging to navigate daily life. Precautionary allergen labels are voluntary, and manufacturers use non-standard phrases to warn consumers about possible cross contact with potential allergens due to shared equipment or shared facilities. Fear of cross-contact and accidental allergen exposure due to weak labeling laws necessitates significant time spent communicating with manufacturers to better understand the risk imposed by each product.
As reported in the study, 90% of respondents said their child had experienced a severe reaction at least once. Additionally, the symptoms experienced most commonly were:
85% – Skin redness, rashes, itching, and/or hives
59% – Mouth/tongue itching/tingling/burning
57% – Stomach pain, vomiting, or diarrhea
51% – Swelling of the lips, tongue or throat Itchy/red eyes, runny nose, sneezing
45% – Shortness of breath, trouble breathing, coughing, wheezingEven the accidental cross contact of an allergen with a non-allergenic food, or the inadvertent mislabeling of an undeclared allergen by a food plant worker can have significant impacts on a child with a food allergy — and their entire family. As one parent stated, “We just want to know if the product is safe.”
Source: Asthma and Allergy Foundation of America. (2019). My Life With Food Allergy: Parent Survey Report. (www.aafa.org/foodallergylife)
As befits the times, this issue of QA has a strong focus on the impacts of COVID-19 on the food industry, and its journey through the pandemic into recovery and the eventual “new normal.”
By the time you read the issue, however, it is likely that some of the information cited in the articles will already be obsolete. We conducted the interviews and wrote the articles as near to deadline as possible to be as relevant as possible; but since its first diagnosis in China, the coronavirus — and the knowledge of it — has evolved, frequently on a daily basis.
Despite the continuing research, investigations, and developments by scientists, epidemiologists, and public health experts worldwide, it quickly became apparent that what we knew and did yesterday is not what we know and are doing today. This has made it extremely difficult for businesses — as well as governments and individuals — to know how to best protect against the virus, and even how much protection is needed.
But, with that in mind, this issue provides a look at plant-floor best practices and expert guidance on managing business, protecting employees, and continuing to provide safe, quality food throughout the pandemic. And while none of us can know what tomorrow holds, the industry is doing its best to work through recovery and prepare for whatever the future may be.
Read what the industry and experts are saying and doing:
- Dr. David Acheson’s recommendations for Protections for Our New Normal.
- What food processors say about the impact of COVID-19 and their response in Reinvention Out of Necessity:
How FDA Deputy Commissioner for Food Policy and Response Frank Yiannas sees Pandemic Lessons To Inform the “New Era” Blueprint
- The Chef’s Garden
- Massimo Zanetti Beverage USA (MZB)
- Fat Bottom Brewing
- The Aladdin Baking Company
- Just the Cheese
- See’s Candies
- Hazelnut Growers of Oregon (HGO)
- How going Back to Basics has become increasingly important for Sanitation (page 32), Pest Management, and Allergen Risk Management (page 42).
- Abbott Nutrition’s focus on Building a Resilient Global Supply Chain to meet the challenges of the pandemic.
Just as what we knew and did yesterday is not what we know and do today; what we will know and do tomorrow is not what we know and are doing today. And just as the world and our understanding of it ever evolves, so will our understanding of COVID-19 and all that that entails. Thus, implementing best practices based on the knowledge we have is often the best we can do.
Lisa Lupo, Editor She can be reached at firstname.lastname@example.org.
Gone are the days when you only had to worry about what was happening in the four walls of your operation. Prior to the passage of the Food Safety Modernization Act (FSMA), many companies had supplier approval programs and many focused on financial and supply chain security. At that time, the emphasis on food safety requirements for suppliers varied between buyers, although third-party audits were commonly used to gain market access. Still, in some cases, buyers relied on a third-party audit of their supplier as a means to protect the purchasing company.
Both the Foreign Supplier Verification Programs (FSVP) and Preventive Controls rules explicitly require companies to ensure the safety of the food and ingredients they source. The rules recognize audits as a key tool to verify suppliers, but what if audits can’t be conducted — as the industry faced with COVID-19?
With respect to food safety audits and regulatory requirements, the inability to travel as a result of the pandemic clearly jeopardized the ability to conduct on-site food safety audits. Audit organizations responded, with the Global Food Safety Initiative (GFSI) providing guidance to allow for the extension of certificates by the Certified Program Owners. Similarly, FDA noted that it would postpone most domestic and foreign audits, limiting them to specific for-cause reasons (e.g., related to outbreaks or recalls) and even then, only if it were safe for inspectors to do so. In the absence of audits, how could food safety be assured?
First, we must remember that audits do not, or at least should not, drive food safety practices and procedures. Audits are intended to verify that a company has appropriately identified food safety risks and is actively managing those risks. There are many examples of outbreaks where the supplying firm was audited.
So, despite the continued reliance on audits, the better question is, “How can I feel confident that my supplier’s food is safe?” Then when audits as a tool are unavailable, the industry must look for other tools in the toolbox. The question becomes, are there other ways that food safety can be verified?
The answer is yes. FDA suggests that if the hazard to be controlled by a supplier meets the “serious adverse health consequence or death for humans or animals” standard (SAHCODHA), an annual on-site audit is the default verification tool. But, as FSVP lead instructors, the authors of this column have both had the opportunity to brainstorm approaches that can be used to assess the safety of food/ingredients being sourced. For example, a class participant once asked about alternatives, explaining that some suppliers were located in war zones where it was unsafe to conduct audits. There are other verification tools that can be used. Within the FSVP rule and related guidance, the review of food safety-related records (not the plans or SOPs, but actual records of implementation), as well as testing, can be elements of a program. So these, or other verification mechanisms identified by the importer, can be leaned upon more heavily in those circumstances where conducting an on-site audit is not possible.
When deciding how to construct a verification program in lieu of an audit, it is critical to articulate the food safety concerns that you’re trying to address. This should already have been done, as it is based on the hazard analysis for that food, considered in light of your evaluation of the supplier. For instance, if the product is ready-to-eat and the facility is older and/or has equipment commonly associated with Listeria harborages, such that Listeria is a main concern, it could be appropriate to ask to see results of the environmental monitoring program, as well as the details of the plan, to verify its likelihood to detect a potential issue. If the food is thermally processed, reviewing records of the time-temperature treatment could be useful. Finished product test results have their limitations, but in some instances, they could be used as long as the sampling plan, method, etc. are conveyed so the result can be interpreted properly.
Shortly after travel restrictions were enacted, limiting the ability for audits to be conducted, the Consumer Brands Association, working with its members, compiled suggestions for alternative food safety verification measures and some hypothetical scenarios.
One example of this is that of a receiving facility that obtains roasted pecans from a supplier when there is a delay in the annual on-site audit due to an emergency situation. The receiving facility could select the following combination of verification measures:
- Conduct enhanced sampling and testing for Salmonella for all lots during the period of time that the annual on-site audit is delayed; and
- Using a virtual platform, review the suppliers’ food safety records and document this review (e.g., records demonstrating the roasting of pecans occurred at a specified temperature and time period, supplier’s environmental monitoring records, and sanitation records for the post-lethality area).
Audits have become the default for the food industry, but if a company truly understands the types of hazards and degree of risk associated with the products they are purchasing, they may find that there are many additional verification tools in their food safety toolbox.
Jennifer McEntire Vice President of Food Safety, United Fresh Produce Association Betsy Booren Senior Vice President, Regulatory and Technical Affairs, Consumer Brands Association