Despite the
industry’s best efforts, foodborne illnesses and food recalls are regular
occurrences. These instances are not only dangerous to public health, but also
disastrous to business operations and brand reputations.
It is clear no
one is immune to the problem. Fast food chain Chipotle is the latest company to
garner national headlines for six outbreaks involving three different foodborne
illness: E.coli, Salmonella and norovirus. In the midst of the crisis, the
restaurant’s stock price has suffered. And while executives are working hard to
address the problem — going so far as to shut down all 2,000 locations Feb. 8
for an all-staff food safety refresher — it remains to be seen if customers
will return and if the business will truly recover.
Chipotle is just one cautionary tale among many. It is
apparent the industry as a whole must do more to properly secure our global
food chain.
The #Food_Safety_Modernization_Act (FSMA), which
President Obama signed into law in 2011, was a critical step forward. It
addresses the single biggest factor needed for food supply safety success — a
focus on proactive strategies to prevent recalls and illness outbreaks.
Industry best practices have now been turned into law, and it is time that we
work together to make it easy to implement the new regulations.
The FSMA furthers the push toward proactive food
safety measures — forcing the FDA to extend beyond its traditional reactive
role. For the first time, the FDA has the power to stop unsafe and possibly
contaminated food from entering the food supply.
While the FSMA is made up of five primary provisions,
the first, “Preventative Controls,” is the heart of the initiative as it
focuses on the proactive steps needed and provides a framework for a successful
food safety program. To best comply with these requirements, companies need to
consider implementing better visualization, documentation and communication
tools that can deliver better insight into food safety processes. Here are five
ways to leverage those technology tools based on the key tenants of the
Preventative Controls rule.
1. Analyze your hazard risk
Most companies have strong HACCP (Hazard Analysis and
Critical control Points) plans in place, taking into account food safety
hazards at all stages of their operations.
Risk assessment and risk management must be a key part
of the process and critical control points defined. To successfully manage this
moving forward, consider tools that enable visibility.
However, true visibility doesn’t stop with a one-time
snapshot view. Organizations need to have immediate access to both current and
historical situations at control points to easily see their proximity to each
other, as well as to other components in the plant.
2. Test
for preventive controls
Preventative controls, such as food allergen, supply
chain and sanitation controls, are also called out as part of the FSMA
requirements. This also includes recall plans.
Again, critical control points (CCPs) are they key to
make sure controls are effective. Consider indicator test points to stay
one step ahead.
Food safety leader John Butts routinely reminds
industry players that indicator test points are one or more steps removed from
the critical control points. Testing these areas allows companies to identify
possible risk areas before they even reach control points — allowing them to
address any potential issues proactively rather than reactively.
3. Keep a watchful eye
Each production, packing or distribution plant should
have a plan that includes written procedures for monitoring preventive
controls. The plan needs to specify how frequently preventive controls should
be checked.
The monitoring plan should take into account zone
coverage, randomization, test frequency, test timing and sampling order.
Depending on the business and regulatory rules of any given plant, testing
should include non-food contact and food contact surfaces.
Test point randomization is an important way to ensure
that testing is representative of the actual conditions in the plant. In
addition, test frequency and test timing should be defined. Companies should
seek tools that automate these business rules.
4. Hope for the best but plan for the
worst
If something does go wrong, what is your corrective
action plan? A written procedure for identifying and correcting a problem is an
absolute must.
For both the plant and for regulators, a clear record
of the plan and the steps that were followed to close out any issues is now a
requirement. Make sure that the team understands each component, including the
number of re-tests and any recall requirements.
Seek out tools that automatically alert relevant team
members to potential problem situations and track responses and testing. This
will make it easier to share details if an issue arises.
5. Plans mean nothing without results
Having a plan is only half the job. Trust, but always
verify. By using environmental and finished product testing programs to ensure
that controls and corrective actions are effective, organizations can
effectively put plans into action.
Rapid testing technologies can reduce time between
testing and results, while rapid communication of verification results keeps
the team coordinated.
Many companies fear that compliance with FSMA — or any
government regulation — will cause more problems, strain resources or create
more disruption than they are prepared to handle.
Compliance does not need to create a massive headache.
More preventative food safety procedures will ultimately help businesses and
guarantee that each organization is providing safe food for customers to
consume. Many food companies have been implementing these best practice
guidelines for years; FMSA simply offers the industry an easy-to-follow
checklist.
Living with the law
If we are to secure our food chain for today and
tomorrow, prevention is the key. To achieve it, the industry must
wholeheartedly embrace new regulations like FSMA.
Don’t stop at committing to comply, though. Renew your
dedication to leveraging the best tools and technologies to support food safety
strategies and rally your organization around the goals and objectives of a
proactive food safety program. Collectively, this combination of people,
processes and technology will serve as the lynchpin to make our food supply
safe and enable businesses to future-proof their operations against the impact
of an outbreak.
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