From category to category and country to country, the problems that surface when food companies undergo audits of their food safety programs vary. Generally speaking, though, some non-conformities occur with greater frequency than others. Based on 17,113 site reviews conducted in 2014, the British Retail Consortium (BRC) identified the most common failings. The Top 10 infractions and the percentage of plants with deficiencies were:
- Documentation of cleaning procedures 18.3%
- Properly maintained doors & docks 14.1%
- Processes for control of chemicals 12.5%
- Proper design & placement of equipment 12.4%
- Documented glass/brittle material handling 12.1%
- Adequate raw-material identification 11%
- Proper wall maintenance 10.9%
- Up-to-date document control system 10.7%
- Properly maintained ceilings & overheads 9.9%
- Proper storage of finished goods 9.5%
Electronic records, systems-based prevention programs, staff training, environmental swab tests — there are many ways to upgrade a company’s approach to food safety. Collectively, they constitute industry best practices.
Final rules for the Food Safety Modernization Act (FSMA) are expected later this year, and while farmgate rules still are being sorted out, the shift to a preventive approach is consistent with international trends that have been building momentum for years. Food safety experts point to the independent third-party audits and certifications under the Global Food Safety Initiative (GFSI) as the embodiment of best practices. One of those standards, BRC, cites “a commitment to share best practice to improve food safety” as being “the heart of the program.”
Safety audits are nothing new, but unlike AIB, Cook and Thurber and other prescriptive approaches of the past, the new breed of certified standards has ushered in “a much more formal approach to your programs, and you're audited against your own particular program,” explains Kris Middleton, a former auditor who currently serves as the manager of the AuditReady consulting program at Steritech, Charlotte, N.C. As a result, “There’s much more buy-in and understanding your system, documenting it and reviewing the results.”
Mad cow disease outbreaks in the British Isles beginning in 1986 brought the need for higher operational standards to the fore. “Mad cow really drove the creation of FSMA and raised standards here” in the U.S., suggests Trish Meek, a biochemist and director of product strategy at Thermo Fisher Scientific in Philadelphia. “Today, there’s a much different expectation of how quickly a problem needs to be identified and action taken.”
Documentation remains the biggest challenge area in safety certification. Almost 20 percent of the 17,113 sites audited last year by BRC had nonconformities in documentation of cleaning procedures, easily the biggest area of deficiency. But it is a fundamental part of the process in elevating food safety from a basic checklist to a systems-based approach.
Doug Renfro, president of Renfro Foods Inc. in Fort Worth, Texas, credits a detail-oriented QA director for easing the documentation pain when his company sought certification under Safe Quality Food (SQF) Level 2, one of the GFSI-sanctioned standards. “We didn’t realize how much work it would involve, and it took a while to get up to speed,” Renfro recalls. Nonetheless, the three-year process helped elevate professionalism and improve the competitive position of the 75-year-old family firm.
Salsa and sauces are Renfro mainstays, with copacking accounting for 45 percent of its production of acidified, hot-filled products. One customer began nudging Renfro down the GFSI certification trail five years ago. Facility upgrades were the first priority, beginning with a drop down ceiling and much improved lighting in the 50,000-sq.-ft. building’s processing area. Rest room reconstruction, installation of stainless steel sinks and other upgrades brought capital costs to almost $400,000, Renfro estimates. Physical changes were merely preludes to more meaningful ones.
Improved morale and collaboration were unexpected benefits when Renfro Foods upgraded its food safety system with a third-party certification initiative. Photo: Renfro Foods
Creating a clean culture
After 70 years as a top-down organization, Renfro’s staff of 40 was skeptical when management signaled its intent to change the company culture. “We were moving from putting stuff in a jar and praying to [being] an organization that could meet the needs of more sophisticated copack clients,” Renfro half jokes. “It took about a year to get buy-in to a safety committee that’s really going to meet regularly.” Instead of delegating responsibility to a single person, it became a cross-functional mission, with maintenance, production and office staffers collaborating with QA.
Certification is paying off in competitive bidding situations. “Now that we have that in our quiver, it resonates with customers,” he maintains. “Competition ranges from people who are basically commercial kitchens all the way to giant food companies.” As more customers make stringent certification programs a prerequisite to order placement, the number of competitors who can bid a project is shrinking.
Higher morale and greater confidence were unexpected benefits. “A state health department inspector came in recently,” relates Renfro. “We weren’t nervous because we wouldn’t have done anything differently if no one was there.” Staff members now volunteer suggestions for process improvements and other upgrades. “Electronic records within five years is the logical next step,” he adds.
Records of various types — process time and temperature, product specifications, raw material data, training documentation, etc. — define today’s food production environment. The sheer volume is a compelling argument for paperless documentation, although the initial capital cost discourages many small and mid-sized manufacturers from making the transition.
Capital availability is a nonfactor in a more important industry transition: the integration of food safety protocols and procedures with all manufacturing activities. Instead of treating safety as a discrete activity, processors are embracing a more holistic approach.
Both FSMA and the GFSI standards require root-cause analysis and possible corrective actions when a safety deficiency surfaces, points out Robert Rogers, senior advisor for food safety and regulation in the product inspection group of Mettler Toledo in Tampa, Fla. By involving personnel with diverse responsibilities, that analysis is more likely to produce changes that improve processes, reduce waste and result in greater confidence in the programs in place, he suggests.
Collaboration won’t happen unless senior management insists on it. Management commitment is fundamental to the GFSI and FSMA approaches. “Building a diverse group from maintenance, production and other areas provides a diversity of knowledge and a fresh set of outside eyes” when assessing program effectiveness, notes Rogers.
Above and beyond
More stringent inspections and certifications help raise industry-wide performance, but by definition, a standard establishes minimum expectations. Poultry processors are required to be certified under one of the GFSI standards in order to supply Walmart, for example, yet that didn’t prevent the retailer from unveiling in December “enhanced poultry safety measures” that those suppliers must meet by June 2016.
Fresh, uncooked products are the most vulnerable foods, and relatively high worker turnover in the meat and poultry sectors poses a particular challenge in executing safety procedures. Firms such as Tyson and JBS augment in-house education with external training specialists such as Alchemy Systems LP, an Austin, Texas, firm.
Multiple languages and as many as 20 dialects may be spoken by line workers in meat and poultry plants, observes Laura Nelson, Alchemy vice president, and “training needs to be at about a fifth or sixth grade level, and it needs to be visual.” But classroom training alone will not result in an effective safety program. Validation of behavior on the line is what she terms “closed-loop training” and constitutes a best practice.
Besides quizzing trainees to ensure they understand the preventive steps discussed in the class, trainers work closely with front-line supervisors so they can reinforce and validate proper behavior. For example, proper handwashing can be distilled into five steps; after observing workers, the supervisor is encouraged to provide positive feedback, such as, “Great, you scored 80 percent,” rather than berate them for a single misstep, Nelson advises.
“The group-based dynamic is very important to learning, and that reinforcement on the plant floor is a very important part of validation,” she says. “To engage an adult learner, you have to engage the auditory learners, the visual learners and the kinesthetic learners.”
Brand owners’ risk mitigation programs have made environmental testing a virtual standard operating procedure, with the number of swabs escalating along with the value of the brand. Those food companies, as well as retailers and foodservice operators, are pushing bacterial testing throughout the supply chain. While such tests may be regarded as a best practice, they definitely complicate life for suppliers who face more material handling costs and storage issues. Fortunately, the time needed to generate a test result is compressing, making this practice more practical.
Agar plates in which samples are incubated are “the gold standard,” according to Kevin Habas, director-global scientific marketing & education at 3M Food Safety, St. Paul, Minn. Reliability is high, but those tests require skilled technicians, scrupulous set-up and four or more days to produce results. Faster results and easier set-up is achievable with Petri-film plates, the technology 3M has focused on since 1991.
Improvements in recent years have cut result times in half, says Habas, including a 24-hour turnaround in aerobic plate counts. That test, along with a 48-hour test for yeast and mold detection, has been validated by AOAC International to meet or exceed the sensitivity and reliability of agar plates.
“You don’t want to pay microbiologists to prepare media instead of conducting more value-added work,” he says. Habas calculates the simplified protocol can free up 20 hours per week for those high-skill workers, while also freeing space in a plant’s product-hold area.
Environmental results often are appended to certificates of analysis (CoA), an assurance tool that is growing in application partly as a result of the explosion in global trade. Use of GFSI standards in Asia have not gained the traction they enjoy in Europe and North America, and the performance of food suppliers who have undergone the process is less than stellar.
With average scores of 92.8 percent, UK firms achieved the highest rate of A grades in BRC’s analysis, with the U.S. second. “China, however, performed worst in terms of A-grade ratings, where only 29.7 percent of sites were graded A,” the report states. Chemical control processes were faulted in almost a quarter of all Chinese audits.
“Globally, people are more concerned with the traceability of their food,” observes Thermo Fisher’s Meek. Much of the necessary information resides in a laboratory information management system (LIMS), but accessing it can be a challenge. Her firm attempts to address it with Informatics, an enhanced LIMS that maintains documentation such as CoA and issues alerts when discrepancies surface.
The sheer volume of CoAs, environmental tests and other documentation is making electronic records a necessity, if not a requirement, and Meek characterizes her program as “the ERP of the laboratory itself.” Relieving lab technicians of the tedium of data entry with a paperless record allows them to focus on the metrics of continuous improvement.
The complexity of the supply chain, the diversity of the organizations involved and the sensitivity of the products themselves make system breakdowns inevitable. Minimizing the number and severity of those breeches is the goal, and food safety best practices are helping to achieve it.