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From: Food Quality & Safety magazine, December/January 2011

Regulations, Market up the Ante for Food Safety

Legislation lags behind, but manufacturers can influence it

by Jack Payne

If you subscribe to the U.S. Food & Drug Administration’s (FDA) Recalls, Market Withdrawals and Safety Alerts, you’re well aware that food recalls occur almost daily. Few of these product issues receive nationwide publicity like this summer’s recall of 380 million infected eggs or last year’s Salmonella-tainted peanut butter.

But even small and localized recalls, such as mislabeled products containing dairy or nuts, have a large impact on consumers and manufacturers. The safety regulations a local supplier must follow are the same for national suppliers, whose product recalls become ingrained in the minds of American consumers. In fact, safety has become such a major issue for consumers that the FDA has supplemented its e-mail recall alerts with a mobile phone application that allows shoppers to download current recalls for any product.

Following this year’s midterm elections in November, politicians approved the FDA Food Safety Modernization Act. The bill, if signed into law, would provide:

  • increased inspection of food manufacturing facilities, including annual inspections of high-risk facilities;
  • expanded FDA authority to order recalls; and
  • new standards similar to those set by the Global Food Safety Initiative (GFSI) and hazard analysis and critical control point (HACCP) systems.

There’s no question that the Food Safety & Modernization Act creates more stringent standards for food manufacturers, closer oversight of individual suppliers, and higher penalties. The Senate approved the bill November 30, and it will be sent to the House for action.

One thing the bill will not give anyone is a full-fledged commitment to tracking and tracing technology. The bill only calls for a pilot project to explore and evaluate methods to rapidly track and trace foods in order to identify the source of an outbreak and the recipients of the contaminated food. This pilot project includes methods that are applicable and appropriate for small businesses and technologies, including existing technologies that enhance trace-back and trace-forward. No later than 18 months following the end of the project, the Secretary of Health and Human Services is to report the results to Congress and must publish a notice of proposed rule making establishing standards for rapidly tracking and tracing a foodborne illness outbreak within three years of the bill’s enactment.

As technology professionals, my colleagues and I know that any technology viable today will most likely be obsolete in three years. And as consumers, we’re all concerned about potential future outbreaks that might occur in the three-year period prior to a notice of proposed standards, plus the additional time for the enactment of the proposal as law.

While the act itself may have good intentions, best practices call for companies to move forward today with track-and-trace methods and technology that gives them the power to track products back to the ingredients and sources and forward to their customers.

For instance, the FDA maintains certain rules about chicken processing but rarely, if ever, addresses the role technology can play in decreasing the likelihood of contamination. Consequently, while companies employing those technologies are not necessarily more compliant, they do leverage the investment in their marketing to take market share from competitors.

Some of the latest technologies helpful to producers and processors are software solutions that provide a visual “traceability map” that gets away from the conference room table approach of manual documents or spreadsheets. A traceability map doesn’t require time-consuming, deep analysis to figure out the source of ingredients and the destinations or recipients of lots containing these ingredients.

This speeds any potential recall process and reduces the time required to trace an ingredient from hours or days to minutes. This type of technology will become increasingly important as more retailers demand that their suppliers conduct mock recalls to prove that the organization can react quickly to a recall if necessary and can pinpoint recalls to only contaminated lots, minimizing exposure and protecting brand perception.

Increased Inspections on the Horizon

While pending legislation isn’t keeping up with consumer demand for track-and-trace methods and technology, it does contain language that will fund more government inspections. Many of us watched the attention the fishing industry received when the Gulf of Mexico was reopened to fishing and shrimping after the largest oil spill in U.S. history. The National Oceanic and Atmospheric Administration teamed up with the FDA to conduct tests and declare the seafood safe to eat.

In this case, it appeared to many people that the inspections were designed to get safe food into the system instead of keeping bad food out. This might be why many people took the inspection results with a grain of salt. But it was impressive to see the organizations work together in crisis mode to devote resources to inspections. And it set expectations with the public that the government needs to do more inspections than it has in the past.

In addition to the highly publicized Gulf of Mexico seafood inspections, the FDA announced new rules for egg producers. Although the new guidelines appeared to be in response to a series of nationwide egg recalls, the FDA enacted new rules in July 2010, just prior to the outbreaks. As a result of these new rules, investigators will team up with state and regional partners to inspect about 600 of the largest egg producers—those with 50,000 or more laying hens—to determine if their facilities are in compliance with new guidelines.

Professionals in the food industry will already be familiar with HACCP regulations and mandatory inspections in some industries. The seven principals of HACCP, from conducting a hazard analysis to establishing procedures for ensuring that the system works as intended, provide a common set of best practices for the prevention of food safety hazards. And when it comes to inspections, HACCP requires mandatory inspections in several industries. Again, technology and software solutions help companies ensure compliance and keep records through automated data entry instead of handwritten logs. Software vendors take standards such as HACCP and ISO22000 seriously and are writing requirements into their products.

Numerous technologies that allow manufacturers to ensure food safety are already in the marketplace. To meet consumer and retailer expectations, technologies for rapid and accurate trace-back to the source and trace-forward to recipients are continually improving.

Retail and the Wal-Mart Factor

In 2008, Wal-Mart became the first major retailer in the U.S. to adopt GFSI standards for suppliers of private label and other food products. The GFSI started its efforts in May 2000, with a vision of “safe food for consumers everywhere.” Its members require food suppliers to achieve factory audit certification against one of several recognized standards, which include Safe Quality Food (SQF), British Retail Consortium (BRC), or International Food Standard (IFS).

The GFSI, with nearly 400 members in over 150 countries, has four technical working groups: Guidance Document, Supply Chain, Global Markets, and Global Regulatory Affairs. North American companies representing food manufacturers, retailers, grocery chains, restaurants, and food service participate in the technical working groups. Wal-Mart’s adoption of food safety certification requirements for vendors was followed by many other U.S. grocery chains and food outlets. Today, achieving one of the GFSI standards is a goal for many private label manufacturers in the U.S.

Food Quality as a Competitive Advantage

As the U.S. government works to determine the right solution for managing food safety, other non-governmental organizations such as the GFSI, various trade associations, and even retail chains are pushing food manufacturers to ensure higher quality. Today, some food manufacturers are taking food safety above and beyond the requirements as a competitive differentiator in the marketplace.

For instance, the FDA maintains certain rules about chicken processing but rarely, if ever, addresses the role technology can play in decreasing the likelihood of contamination. Consequently, while companies employing those technologies are not necessarily more compliant, they do leverage the investment in their marketing to take market share from competitors.

One great example is a leading chicken producer that claims to be one of the first companies in the United States to use pure air-cooled systems instead of water-cooling or spray solutions to dramatically reduce the chances of cross-contamination. The company’s guarantee that no water is ever added to the chicken is marketed both as a safety precaution and as an improvement in the final taste of the chicken product.

Technology for the Future

While the U.S. is developing technology and legislation to protect farmers, consumers, and companies, it is neither the only player in the global food supply chain today nor the only country seeking to innovate in food safety. In early November 2010, for instance, Canada opened a new facility designed to validate emerging food safety technologies. The lab’s scientists will be using ultra high pressure, microwaves, ozone, and ultraviolet light to determine the impact of Escherichia coli, Salmonella, and other pathogens.

While legislators debate and take tentative steps toward stronger legislation governing food safety and the FDA, and the U.S. Department of Agriculture steps up inspections, the manufacturer or producer who waits for the government to lead the way will be left behind when it comes to best-in-class food safety practices, including trace-back and trace-forward methods and technologies.

Numerous technologies that allow manufacturers to ensure food safety are already in the marketplace. To meet consumer and retailer expectations, technologies for rapid and accurate trace-back to the source and trace-forward to recipients are continually improving. Because legislation is lagging behind market forces, manufacturers may best be served by watching and influencing legislation and regulations, as well as by taking steps to comply with customer and consumer demands above and beyond governmental guidelines.

Payne is vice president of enterprise solutions for CDC Software; reach him at jpayne@cdcsoftware.com.

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