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    What We Learned from the Fresh Connections Food Safety Series

    Monday, December 5th, 2011

    The 2011 Fresh Connections series on food safety is at an end. We accomplished six successful seminars covering major regions in the U.S. and I’ve gotten to meet and talk with dedicated industry professionals from all parts of the supply chain. As we draw this series to a close, it is important to reflect on what we learned from these six forums.

    First, let’s look at what we learned from the presenters and the importance of truly understanding how to handle internal and external communication. We addressed how to communicate effectively with the outside world and especially with customers, about the expectations related to food safety issues. The sessions highlighted the importance of communicating internally with all employees on food safety and putting practices in place to actually measure success. 

    We tackled the issue of communication and crisis management and the importance of having a crisis management plan in place. The role of people in sales, marketing and production was emphasized with respect to the worth they bring to support their company’s food safety objectives. People in the sales and marketing side are valuable tools to utilize when dealing with a food safety crisis.

    Traceability is an integral part of any comprehensive food safety program, and we had a constructive update on the issues involving traceability and the Produce Traceabilty Initiative (PTI). Ed Treacy, PMA’s vice president of supply chain efficiencies, shared the most current information about the industry’s efforts to develop a common language for product coding and encouraged companies to meet the traceability challenge head-on.

    However, perhaps even more valuable than the facts presented in the seminar was how the involvement of such a wide variety of people reflected our industry’s commitment to food safety. I was encouraged by the number of participants that attended these Fresh Connection events and those numbers reiterate the focus our industry has on taking food safety seriously.

    As I observed the people that attended, their enthusiasm and interest reflected a sincere desire to delve into the topic and rise to the challenge. The level of questions posed and the depth of discussion demonstrated how people in our industry are doing a lot of thinking about food safety. They’re taking responsibility, looking for and finding solutions, and listening to key collaborators. We welcomed retailers, foodservice distributors, regulatory officials, state health department representatives, and third party food safety solution providers to share their perspective and experiences.

    The participation from FDA and state officials was extremely beneficial. Anything we can do to increase exchange between the industry and those who regulate us is always positive. We had a chance to “look behind the curtain” and view things from a regulator’s perspective, including the challenges they face. That type of learning helps us better do our jobs. I’ve had a lot of positive response about the participation of these regulators and we’re very thankful that they are willing to take the time and engage with us.

    While these Fresh Connections events resulted in a fair amount of engagement, they are in many ways just step one. The events provided a formal forum to engage various people across the industry at various points along the supply chain. However, of even greater value is how these events result in further correspondence by email, phone and in some cases direct visits to discuss food safety programs and address specific issues some companies might have. Personally, I find the connection I make with people whose food safety thinking has been stimulated to be the true merit of such events.

    Although we’ve traveled this road for a while, the journey is really just starting. If you want to have an effective food safety program, you must be involved and educated. Our industry is fortunate to have available a wealth of resources including those from the Center for Produce Safety, agricultural extension, and local trade associations. You can also count on PMA for a variety of tools and information on food safety. If you’re interested in knowing more about what was presented at the Fresh Connections events, you can find my Fresh Connections food safety presentation on-line at the PMA Food Safety Resource Center. I look forward to even greater engagement with the industry as we continue to advance through this frontier of food safety.

    Implementing Supplier Controls

    Wednesday, November 2nd, 2011

    Food safety is a chain-wide responsibility and in our industry, this supply chain extends to all of the components and ingredients of our products. Often we may focus on only the fruit or vegetable that our company supplies, but it is imperative for suppliers to ensure all their inputs are safe. Suppliers must be able to demonstrate their adherence to their food safety programs, including any components “down the chain” from them.

    If your company is producing a blended salad, for example, that includes iceberg lettuce, carrot slices, croutons, chopped almonds and a salad dressing in a bag, then you have at least eight suppliers that you need to “qualify” as having produced those ingredients safely. In other words, you need to know that the romaine, carrots, croutons, almonds and salad dressing were produced by a supplier with a verified food safety program. You also want to be sure the manufacturer of the packaging materials, the cartons and the pallets follow written food safety programs. With that in mind, I’d like to share some considerations to be taken into account when looking to ensure raw materials and ingredients are safe for their intended use. 

    The first area to consider when looking at a supplier’s food safety exposure is to ensure they employ a risk-based food safety program. Processors that rely on growers to provide raw agricultural commodities need to be sure that these growers employ GAPs based on sound risk assessments specific to the crops they provide. Similarly, processors that use custom processed ingredients, such as ingredients in salads, need to account for the safe production, shipment and storage of those products prior to use.

    This philosophy also extends to other materials that contact the food. For example, sanitizers should be verified for content and strength. Film manufacturers, carton producers and other packaging suppliers where the materials contact food also need to follow risk-based food safety programs to ensure these materials do not provide a cross-contamination risk. It is entirely appropriate to ask your suppliers to provide documentation that demonstrates their commitment to food safety and for you to schedule visits to their facilities to see for yourself that these food safety programs are in place every day.

    The level of control required needs to be risk-based and take into consideration the intended use of the product. For example, sterile packing cartons should not be required for produce that is field packed as that product will likely be washed by consumers prior to consumption. However, it is a reasonable expectation that the carton be manufactured and stored prior to use so that it does not become an unexpected risk to the safety of the produce. On the other end of the spectrum, it should be expected that a custom sliced carrot ingredient in a bagged salad should be produced and packaged according to the provider’s HACCP-based food safety program and shipped and stored prior to use to maintain its food safety integrity.

    Many processors have written suppliers’ programs that include their expectations for food safety and verification for adherence to supplier food safety programs. Some conduct their own audits and may also require third-party audits. Often processors will provide food safety training to valued suppliers to help them comply with food safety requirements. It is important to note that supplier food safety programs should extend to being able to demonstrate where any specific food ingredient came from. Being able to trace the source and identify specific lots of ingredients can be vital to limiting the scope of finished product recalls when safety problems are discovered.

    Numerous firms have an internal supplier approval program and lot tracking system with clearly defined coding. Indeed, “supplier approval” programs are commonly part of any good food safety auditing scheme today. However, these supplier approval programs should extend beyond simple “letters of guarantee.”  There should be a comprehensive, risk-based supplier sourcing program that can be verified and documented via on-site visits and/or third-party audits.

    I encourage companies to develop and adopt supplier verification programs to help ensure the safety of produce. As always, these programs must be based on science and account for the factors raised in this section. Though many processors and packers do already have documented supplier verification programs, this is another area where our industry has a chance to shine in our dedication to the best food safety programs possible. Let me know your comments and questions on this topic by contacting me at AskDrBob@pma.

    Preventive Control Approaches for Small Growers

    Tuesday, October 25th, 2011

    PMA repeatedly emphasizes its commitment to bringing real-world solutions to our industry’s food safety needs. This applies to all industry members, large and small. We know local, smaller growers in particular can find it challenging to access the information and resources they need. But despite the challenges, it is important for operations of all sizes to have risk- and science-based food safety programs and preventive controls in place.

    From a food safety perspective, it doesn’t matter where the produce comes from; consumers do not expect to be injured in the consumption of a food product. In the eyes of the marketplace, small and local growers are expected to have effective and verifiable food safety programs. Retail and foodservice buyers are looking to support suppliers in their neighborhoods, yet these very same suppliers could find themselves at a market disadvantage if they do not have adequate risk and science based food safety programs.

    The good news is that food safety can be completely scalable to any size operation, large or small. It makes sense that a larger processor might have to expend proportionally more resources to manage a large, multi-production line processing plant with hundreds of employees manufacturing a half million pounds of product a day. Of course these expenses can be offset by proportionally larger pack-out volumes.  By way of contrast, a small processor with a handful of employees and who processes washes and packs a thousand pounds of cut fruit or vegetables in small operation could expect to spend considerably less than the large operation. However, the degree of sophistication employed may be much less which helps offset the costs.  Risk management practices and preventive controls can be designed to match the risk and the scale of the operation.
    Preventive control programs can seem overwhelming to someone who has not previously considered food safety as central part of their operations. Yet many preventive control approaches and practices, like wash water verification or supplier qualification controls, are practical for small and very small businesses to implement. My experience with smaller companies has been that once processors understand the concepts of hazard analysis and management, they come to see how simple practices that are not expensive to implement can be effective preventive controls.

    Often these controls are simply good operational or business practices. For example, a preventive control on wash water quality for a small processor’s wash system that uses single pass batch equipment might be as simple as a visual inspection of organic load through a portal in a flume tank, sanitizer and pH test strips, a tested water source and a verified sanitation program. These scale-appropriate preventive controls can be just as effective as more sophisticated continuous flow spectrophotometric methods for monitoring organic loads and state of the art electronic sanitizer probes that might be employed by a large processor to monitor multiple production lines in an automated system. The key factor is identifying the need for monitoring wash water quality and the importance of organic load as a risk factor, taking the responsibility to do so and having the freedom to develop preventive controls appropriate for the size of the operation to manage the risk.

    At the next level of preventive control, a microbial test to verify sanitation efficacy or a food safety audit to verify adherence to a food safety program is routine for many processors, yet many smaller processors not accustomed to applying these controls might fear the costs of these services. Again, to those not using these types of preventive controls, they can appear daunting, but they are rapidly becoming part of doing business. We have seen far too many instances where failures to provide adequate sanitation or adhere to a rigorous inspection program can lead to breakdowns in the safety of foods and cause illnesses among consumers.

    A company’s specific risk assessment/hazard analysis plan should serve as a guide as to which preventive controls should be employed to manage identified potential risks. No matter the size, basic measures such as providing training for worker hygiene, wash water sanitation, facility and equipment sanitation and supplier qualification apply to all operations and can help assure food safety. The liabilities associated with foodborne illnesses increasingly are requiring buyers to use only producers with risk-based food safety programs and verifiable preventive controls. Many buyers have worked with their smaller, local suppliers to explain their requirements, and several buyers offer specialized training and workshops in this area.

    PMA also offers training to help small growers understand how food safety programs can be incorporated into their operations, can be cost-effective, and can open or maintain market channels where buyers require effective food safety programs. PMA has conducted six local grower food safety worshops in 2011 to reach out to small growers and we already have several workshops planned for 2012. This local grower outreach is part of PMA’s overall food safety program, which also includes industry education, advocacy, knowledge generation and outreach.  

    For all of us in the industry it comes down to offering the consumer a healthy, safe product. Consumers want local food and our responsibility is to work together to ensure our entire supply chain can verifiably present effective food safety programs. If you would like to access any of PMA’s local grower food safety resources, please contact PMA’s Solution Center staff by telephone at (302) 738-7100, or by email at solutionctr@pma.com. As always, you can contact me via email at askdrbob@pma.com.