Product Testing, Part 3: Mapping Decisions About Product Testing
Julia Stewart:
Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob” with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker, where we’re talking about the challenges of pathogen testing of fresh produce. Bob, in our last post you highlighted how the perishable nature of our products and the need for speed in our industry really complicate our realistic ability to test our products. You laid out a lot of very complex issues, almost a chicken-and-egg situation. So, how can our listeners get a grasp on decisions regarding product testing?
Bob:
It is so important to completely understand what a testing program entails before you enter into one. I always tell people to map it out themselves. Set it up like a decision tree. Prior planning for both logistics and communications will save a lot of confusion and potential headaches.
For example, If you think you might be subject to FDA or USDA testing programs, how are you going to handle it when you are notified that they’ve in fact chosen your product for testing? Do you have all the contact numbers for your local FDA regional office and the FDA labs that handle the testing? How about the state labs that USDA tends to employ in its microbiological data testing program? Assuming you decide that you will need to place any products sampled by a government agency on hold, where are you going to store it until you get the data back?
How will you communicate with both internal and external customers that your products are being tested? Those conversations can be critical. I can’t tell you how many times I have seen mis-communications about a simple commonplace FDA test at the border. The information can be misconstrued, with customers mistakenly thinking that FDA is going to end up recalling product, when in fact it’s just a routine test that 999 times out of a thousand is negative.
Similarly, if you are setting up your own product testing program to meet a customer requirement or to use as a measure in your own food safety efforts, it’s important to know what type of tests you’ll use and their benefits and limitations. Is your testing lab certified? How are you going to confirm your results? What are the limitations and benefits of those confirmation tests? Where are you going to store products when they are on hold for testing so they don’t get shipped by accident? What are you going to do, if your product tests positive? Who do you call? What are you going to say? When do you have to notify the FDA? How will you dispose of product that tests positive? How will you use the incident to improve your food safety program? How and where are you going to store the data?
Julia:
Wow, you have raised some very important points here Bob. For example, as a communications person myself, I can understand the importance of related communications, and where the pitfalls might be. It’s clear that if you are subject to product testing, or setting up a testing program internally, you need to think through the process and understand what it will mean for you and how it can impact your business operations.
Bob:
Yes; and at the same time you need to look for ways to get the most meaningful results possible while balancing the need for speed. That shelf life clock is always ticking, so all of this has to be integrated into the industry focus on delivering fresh products.
Julia:
Thanks Bob. In our next post, I want to explore some points you raised on initial screening tests and confirmation tests, and their benefit and limitations. And, remember you can email Bob at AskDrBob@pma.com. Thanks for joining us.