As my recent article on Listeria in leafy greens1 shows food safety is constantly changing as there are always new outbreaks, new hazards, new foods. This is one of the reasons I love being a food safety consultant.
First, let’s look at how I define food safety:
Food safety is ensuring that our food does not harm consumers in the short term.
I use harm because this covers all three hazards that make food unsafe;
I write consumers because the discipline of food safety does not cover food worker safety;
I say short term because we focus on immediate harm rather than chronic illness.
Collectively we have decided that the hazards food contains, in particular foodborne illnesses such as E.coli, are the most important part of food that we must control.
American food regulations are a hot mess. Too many regulatory cooks have their fingers in the food safety pot as food is regulated at the local, state, AND federal level. This confusion isn’t helped by having two federal agencies responsible for food safety. As well as the FDA2, the Food Safety Inspection Service (FSIS)3 of the USDA inspects any meat and poultry facility and any product containing more than 2% cooked meat or poultry4.
Under both FDA and USDA regulations, food safety is managed by risk analysis and hazard identification, prevention, and control. This is achieved with demands for food safety programs, HACCP plans, monitoring key processing steps, and record keeping. Thus, many inspections and audits of food facilities are mostly desk audits confirming that manufacturers, suppliers, vendors, and distributors are checking boxes to manage food safety.
In 2020 to support their action to strengthen the food safety of the American food supply, the FDA published their New Era of Smarter Food Safety Blueprint5. This blueprint is centered around four key elements:
Smarter Tools and Approaches for Prevention and Outbreak Response
New Business Models and Retail Modernization
Food Safety Culture
These core elements work together to create a safe transparent food supply that can quickly trace the source of an outbreak and support new business models such as ghost kitchens and online grocery stores. To achieve this we need better records, improved technology, and more communication across the whole supply chain.
Currently many farmers and food business, if they keep records at all, keep them on paper which tend to stay with the producer rather than moving with the product. The FDA wants a system where the records stay with the ingredients and move from supplier to distributor to manufacturer to grocery store or restaurant so traceback, when necessary, is quick and reliable.
Food safety experts are limited by the data available when deciding how to control hazards when they write their food safety plans and set critical limits. We need data to predict where the next outbreak may occur and to help with root cause analysis when one does occur. While whole genome sequencing helps identify where food pathogens originated, it does not really explain how they got there. I argue that we know enough about leafy greens grown in Yuma AZ and Salinas Valley CA. However, we still don’t understand how onions or cut cantaloupe have salmonella. Additionally, the FDA’s Core Investigation Table6 shows that the source of many outbreaks are not identified.
New food supply chain business and models are popping up all the time. During the initial COVID pandemic we discovered the importance of online grocery shopping and home delivery of restaurant meals. I see on Facebook and Instagram many businesses offering home cooked meals and there is no guarantee of inspection. One local inspector at the Food Safety Summit on E-Commerce7 in Oct 2021 said they check social media for food facilities in their area and many listed aren’t licensed. How can we educate these businesses on the top five CDC food safety risk factors8?
There is a push for food business to build a strong food safety culture so all employees understand their role to make food safe and behave appropriately. Developing a food safety culture in big industrial facilities where there is a strong organizational hierarchy and where the workers are expendable is challenging. Poorly paid and treated employees workers do not feel ownership for the product they are making. To them, it is just a job to pay the bills and put, hopefully, food on their table. No one is going to point out risks if they lack have job security or cannot trust their supervisors to listen.
To grow a strong food safety culture requires trust and the feeling that what you do matters.
Are you doing your best to ensure that the products leaving your facility are safe? If you're not sure, grab a spot on my schedule so Food Safety Mid Atlantic can help and support you.