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.

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.

The recent tragic outbreak of listeria in cantaloupes underscores that what we’re doing in the Produce Traceabilty Initiative (PTI) continues to be relevant and timely for our industry. The importance of being able to trace back product is a generally accepted tenant in our industry, yet traceability without a common framework is of limited benefit. PTI presents just such a framework for helping the industry achieve supply chain wide traceability and enable faster and more surgical recalls. Increasingly, companies all along the supply chain are looking to PTI as a standard for their traceability requirements.

This year’s Fresh Summit seminar on PTI will showcase what specific companies have learned from their PTI pilot programs. We are pleased to welcome two retailers, Wal-Mart and Publix, and two grower/shippers, Alpine Fresh Inc. and Ippolito Fruit and Produce Limited, who will share their real-world experience of implementing PTI in their business. The panel will impart tips about what worked well and key learnings about what didn’t. Attendees can take home the insight of these PTI pioneers and be better prepared to face the challenges and potential pitfalls in implementing a traceability program. 

The final PTI milestones for grower shippers and the first milestones for receivers are only three months away and coming fast. So, I’ll be opening the session with an overview of the PTI and its requirements and timeline. After we hear from our panel, we’ll finish up the session with a panel discussion where attendees can ask any question of the four panelists or me. We expect it to be an incredibly interactive, constructive dialogue.

For anyone shipping or handling produce, this seminar will provide invaluable examination of PTI implementation. Those just starting the traceability journey will find the reality shared in this seminar facilitates the process as they glean information from those who’ve already walked the PTI road.  Companies with their own in-house traceability system will benefit by understanding what modifications may be needed to make their current system PTI compliant.

The future of the produce business demands PTI compliance – the consequences of not doing so is just too great. Very quickly PTI is evolving to be a marketplace requirement and an important step in ensuring our food safety for our consumers. For more information on registering for Fresh Summit, or any of the workshops, please log onto our website www.pma.com and look for the Fresh Summit link under Events and Conferences.