Food Safety Magazine Editorial Team – the Leading Media Brand in Food Safety for Over 20 Years

FSM101118pg1-2,67-68Final.indd 1 10/5/18 10:32 AM The Podcast for Food Safety Professionals

Produced by the Food Safety Magazine editorial team – the leading media brand in food safety for over 20 years. Each episode features news and trends, or another surprise segment, followed by a conversation with a food safety professional who shares their experiences and insights about the important job of safeguarding the world’s food supply.

The Biggest Issues Discussed by Some of the Biggest Names Best Practices • Blockchain • Culture • Environmental Monitoring • Food Safety Law • HACCP • FSMA (a lot!) • Foodservice • Audits • GFSI • Sanitation • Process Validation • Allergens • Process Control • Food Fraud • Norovirus • Produce • Lessons Learned from Outbreaks • Preparing for Inspections • Retail • and a lot more

• Dave Theno • Larry Keener • Lone Jespersen • Steve Taylor • John Spink • Joe Corby • Scott Brooks • Bill Sperber • Mike Taylor • David Acheson • Patricia Wester • Hal King • Will Daniels • Lee-Ann Jaykus • Mike Cramer • Bill Marler • Mike Robach • Bob Brackett • Sean Leighton • Dane Bernard • Frank Yiannas • Maple Leaf Foods • Shawn Stevens • John Butts 35+ Episodes available New episodes posted twice a month

Produced by Listen and subscribe on your favorite podcast player or visit our website: www.foodsafetymagazine.com/podcast

FSM101118pg1-2,67-68Final.indd 2 10/5/18 10:32 AM FSM101118pg3-9Final.indd 3 10/3/18 9:26 AM October/November 2018 Vol. 24, No. 5

FEATURES COLUMNS 10 Focus: COVER STORY: 46 Top Ten Misconceptions about Sanitation Moving from By Angela Anandappa, Ph.D. Uneasiness to Confidence 14 Poultry: under the Sanitary Transportation Rule Antibiotic-Free Production and Broiler Chicken Meat Safety By Pam Young By Dianna V. Bourassa, Ph.D., and Kim M. Wilson, Ph.D. 54 FOOD SAFETY CULTURE: The “A” in Culture: 18 Packaging: A Toolbox to Drive Positive Healthy Fresh Produce in a Sweet Wrap By Reza Tahergorabi, Ph.D. Food Safety Behaviors By Bertrand Emond, M.Sc., M.B.A., 22 Workforce: Julia Bradsher, Ph.D., M.B.A., and Effects of Millennials on Culinary Food Safety Laura Nelson By Douglas Davis, CP-FS

26 Sanitation for Produce: Disinfectants and Sanitizers Are Essential to Produce Safety DEPARTMENTS By Gina (Nicholson) Kramer, RS/REHS, and Megan Doran 6 Editor’s Letter 8 News Bites 28 Food Safety Insights: 31–45 Food Safety Insider: Rapid Micro Solutions The Uphill Path to FSMA Compliance 67 Advertisers Index By Bob Ferguson

Editorial Advisory Board Michael M. Cramer Tatjana Golikova, Ph.D. Hal King, Ph.D. Theodora Morille-Hinds, M.Sc. Ajinomoto Windsor National University of Food Public Health Innovations LLC The Kellogg Company Technologies Gary Ades, Ph.D. Will Daniels Jeffrey L. Kornacki, Ph.D. Robert Powitz, Ph.D., M.P.H., RS G&L Consulting Group IEH Laboratories & Consulting Kathy Gombas Kornacki Microbiology Solutions Inc. R.W. Powitz & Associates Group Food Safety Consultant Reginald W. Bennett Gina (Nicholson) Kramer, RS/REHS Thomas M. Sauer CFSAN, U.S. FDA Kurt E. Deibel, Ph.D. Margaret D. Hardin, Ph.D. Savour Food Safety International™ Food Safety Consultant Heinz North America IEH Laboratories & Consulting Group Robert E. Brackett, Ph.D. Sean Leighton, M.Sc., M.B.A. Tim Stubbs, CFS IIT, Institute for Food Safety and Jonathan W. DeVries, Ph.D. Craig Henry, Ph.D. Cargill Inc. Dairy Management Inc. Health General Mills/Medallion Labs Intro Inc. Huub L.M. Lelieveld Darryl Sullivan John N. Butts, Ph.D. William Fisher Lone Jespersen, Ph.D. Global Harmonization Initiative Eurofins Food Integrity and Land O’Frost GFTC, retired Cultivate Innovation Ann Marie McNamara, Ph.D. Brian Campbell Timothy A. Freier, Ph.D. Larry Keener, CFS, PCQI Target Corporation John G. Surak, Ph.D. Kroger Clackamas Bakery Mérieux NutriSciences Intl. Product Safety Consultants Surak and Associates Martin Mitchell Larry Cohen Veny Gapud Gillian Kelleher Certified Laboratories/RFA Wendy White, M.Sc. Treehouse Foods Food Safety Consultant Wegmans Food Markets Golden State Foods

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Ham on Wry CEO, The Target Group Inc. Don Meeker With thanks to Paul Heroux and apologies to Dr. Seuss: Publisher Stacy Atchison My Golfing Inspiration Bobby Meeker Editorial Director Barbara VanRenterghem, Ph.D. Will you produce safe eggs and ham? Director of Sales Adam Haas Or do you just not give a damn? Art Director/Production Craig Van Wechel Digital Editor Tiffany Maberry Would you clean the processing line? Circulation Manager Andrea Karges Administrative Manager Allison Demmert-Poland I would not clean the processing line. Publishing Office 1945 W. Mountain St. That cleaning job is just not mine. Glendale, CA 91201 Main 818.842.4777 And while I like safe eggs and ham, Fax 818.955.9504 My shift is done; it’s time to scram. [email protected] Production Office 1113 Ellis Street Would you clean the slicing blade? Ft. Collins, CO 80524 Phone 970.484.4488 Can’t you see that belt is frayed? [email protected] Editorial I would not clean the slicing blade. Barbara VanRenterghem, Ph.D. • 508.210.3149 That belt is fine; it just got sprayed. [email protected] It won’t adversely harm the food. Tiffany Maberry • 678.853.1062 [email protected] Bill’s not around, we won’t get sued. Advertising Sales And while I like safe food to eat, Bobby Meeker • 818.842.2829 My shift is done—go talk to Pete. [email protected] Adam Haas • 321.804.4319 Would you feed your kids this ham? [email protected] Or is food safety there a sham?

I would not feed my kids the ham. Food Safety Magazine (ISSN 1084-5984) is published bimonthly by I could not! It would be a scam. The Target Group Inc., 1945 W. Mountain St., Glendale, CA 91201; But I could clean the processing line. (818) 842-4777; Fax (818) 955-9504; E-mail info@foodsafetymagazine.com. Periodicals Postage Rate paid at Glendale, CA, and I could make that task all mine. additional mailing offices. Subscriptions: Free to qualified subscribers And I could clean the slicing blade. as defined on the subscription card; $85.00 per year for nonqualified subscribers. Back Issues: $10.00 per copy, prepaid. Change of Address: And fix that belt that is all frayed. Notices should be sent promptly; provide old mailing label as well as And then I’d feed my kids the ham. new address. Allow two months for change. Editorial Contributions: Unsolicited manuscripts should be submitted to: Barbara I guess I really give a damn! VanRenterghem, Ph.D., Editorial Director at: barbara@foodsafetymagazine.com. Notice—Every precaution is taken to ensure accuracy of content; however, the publishers cannot accept responsibility for Best Regards, the correctness of the information supplied or advertised or for any opinion expressed herein. Postmaster: Send address changes to Food Safety Magazine, 1945 W. Mountain St., Glendale, CA 91201. ©2018 by The Target Group Inc. All rights reserved. Reproduction in whole or part without written permission is strictly prohibited. The publishers Barbara VanRenterghem, Ph.D. do not warrant, either expressly or by implication, the factual accuracy Editorial Director of the articles or descriptions herein, nor do they so warrant any views or opinions offered by the authors of said articles and descriptions.

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Inadequate Cooking and Handling Partly to Blame for BizTracks Persistent Salmonella Illnesses in Canada GHI Issues Call for Over the past 16 months, the Public Health Agency of Canada Abstracts (PHAC) has reported that health officials in Canada have identi- The Global Harmoniza- fied hundreds of laboratory-confirmed human illnesses associ- tion Initiative (GHI) has ated with frozen raw breaded chicken products contaminated issued a call for abstracts for with Salmonella, due at least in part to inadequate cooking or the first GHI World Con- handling. During the same period, there were also food recalls issued for gress on Food Safety and seven different frozen raw breaded chicken products. Security to be held March PHAC says that the illnesses continue to occur despite warnings and efforts to educate the 24–28, 2019, in Leiden, The public on safe food handling practices. Canadians of all ages are becoming infected with Salmo- Netherlands. The aim is to nella because of “consumption of or exposure to improperly cooked frozen raw breaded chicken bring together leading scien- products.” tists, researchers, and research To help combat these ongoing illnesses, the government of Canada is partnering with the scholars from academia and food manufacturing industry and food retailers to reduce Salmonella in frozen raw breaded industry, decision makers chicken products produced on or after April 1, 2019, to below detectable amounts, thereby from international organiza- reducing the risk of illness for everyone who handles or consumes these types of products. tions, and the public from However, until April 1, 2019, and probably for up to a year after this date, frozen raw breaded across the globe to advance chicken products containing Salmonella will continue to be in the marketplace and in freezers the conversation about the across the country. vital role of modern science in food legislation and USDA Offers Food Safety Tips for Areas Affected by regulation within all relevant fields—from chemistry and Hurricanes microbiology to genetic toxi- The U.S. Department of Agriculture (USDA) Food Safety and Inspection cology and genomics—from Service (FSIS) is issuing food safety recommendations for those who may be farm to fork. For more impacted by hurricanes this season. information, visit Hurricanes present the possibility of power outages and flooding that can compromise ghiworldcongress.org. the safety of stored food. FSIS recommends that consumers take the following steps to reduce food waste and the risk of foodborne illness during severe weather events. Packaging Innovation Steps to follow if the power goes out: Awards • Keep the refrigerator and freezer doors closed as much as possible. A refrigerator will keep Dow Chemical Company food cold for about 4 hours if the door is kept closed. A full freezer will hold its tempera- has announced the winners ture for about 48 hours (24 hours if half-full). of the 2018 30th Awards for • Place meat and poultry to one side of the freezer or on a tray to prevent cross-contamina- Packaging Innovation, which tion from thawing juices. recognize the packaging • Use dry or block ice to keep the refrigerator as cold as possible during an extended power industry’s top achievements outage. Fifty pounds of dry ice should keep a fully stocked in innovative packaging 18-cubic-foot freezer cold for 2 days. ONLINE & designs, materials, technolo- Food safety after a flood: gies, and processes. Top • Do not eat any food that may have come into contact OF NOTE honors went to Procter with floodwater—this would include raw fruits and www.cdc.gov/disasters/foodwater/facts.html & Gamble for the vegetables, cartons of milk, or eggs. With hurricane season upon us, the U.S. Centers for company’s air-assist • Discard any food that is not in a waterproof con- Disease Control and Prevention communicate what to do liquid packaging tainer if there is any chance that it has come into after a disaster: Throw away food that may have come in technology. Other contact with floodwater. contact with flood- or storm water; perishable foods that notable mentions • Inspect canned foods and discard any food in have not been refrigerated properly due to power outages; include the Doritos damaged cans. Can damage is shown by swell- and those with an unusual odor, color, or texture. Do not Crunch Prism Pack ing, leakage, punctures, holes, fractures, extensive use water you suspect or have been told is contam- from PepsiCo Frito- deep rusting, or crushing/denting severe enough to inated to wash dishes, wash and prepare food, Lay and the KitKat prevent normal stacking or opening with a manual, wash your hands, or make ice. Fact Celebreak Box from wheel-type can opener. sheets are also available. CBA B+G.

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particles, ingredients, and defective product are parts of general cleanup. Top Ten Misconceptions But sanitation serves a much larger purpose critical to food safety. As a prerequisite program or preventive control, it about Sanitation is a fundamental program for mitigating food safety risks and preventing hazards from entering the product. The regulatory requirement for ensuring food produced is free of contamination (Title 21 C.F.R.) is simple in its intent yet demanding when it comes to everyday execution, particularly for facilities that do not pay attention to What sanitation really means organization. By “organization,” I mean planning, facility layouts, scheduling, hiring and training personnel, purchasing and operating the right types of equipment for the job, understanding the food being produced and what it takes to clean its production equipment, or many of the people with whom I’ve con- having a good knowledge of operating versed, the mere mention of the word “sanita- procedure for sanitation protocols (Sani- tion” conjures up images of garbage trucks, mop tation Standard Operating Procedures, buckets, janitors, the lack of clean water, and or SSOPs), etc. (Figure 1). toilets. The general public has little knowledge It is not uncommon to find facilities Fof sanitation as an operation or a field of work, and its that were designed for one operation deeply intertwined relationship with the food we eat and later producing an entirely differ- every day. ent product line, or equipment that has Sanitation is in fact the most important function that been modified to perform a different will happen in every single factory, packinghouse, deli, duty than originally planned. Good or restaurant every single day. It is the one safeguard overall design of a facility that helps the between food and contaminants. Sanitation, then, is the equipment function well, allowing em- entire set of activities, operations, and products used to ployees the room to work with, around, produce food hygienically. and sometimes inside equipment safely Similarly, there is an overwhelming impression that also greatly contributes to the overall using a sanitizer is all that’s needed to eliminate health level of hygiene. A facility where an em- risks. This, moreover, is a fallacy shared by more than ployee can comfortably perform their the general public. Even some workers in the food in- job of cleaning will be a cleaner facility. dustry have misconceptions about the purpose, proper A “Seven Steps of Sanitation” ap- use, and appropriateness of sanitizers. proach—Step 1. Secure, disassemble, and Let’s clear up some of these misunderstandings, shall dry-clean; Step 2. In sync, top down, we? pre-rinse; Step 3. Apply detergent and Here is a nonexhaustive list of some of the top mis- scrub; Step 4. Post-rinse, self-inspect; conceptions around sanitation. Step 5. Prepare for formal inspection; Step 6. Post-sanitation/pre-op inspec- 1. Sanitation is about keeping the facility looking clean tion; Step 7. Sanitize and assemble—can Everyone likes a pleasant, organized, and clean-look- be used in any food processing envi- ing facility. Picking up and disposing of unwanted items, ronment and also adapted for retail

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conditions, heat and humidity, slippery floors, confined spaces, high-pressure hoses, suds, cold rooms, and treacher- ous conditions that are encountered by many frontline sanitation workers are Using the not for the faint of heart. The average appropriate Proper sanitation professional often requires chemicals and handwashing physical strength combined with sharp tools observational skills and a keen problem- solving mentality to work with a team that can ensure that the proper plan- Good Appropriate ning, cleaning, and verification of a fa- hygiene procedures cility or work area is at the right level of (SSOPs) hygiene to be worthy of handling food. As facilities become more automated, sanitation jobs are far more akin to Dispensing Labeling and robotics, mechanical structure and en- and delivery storage of gineering, and data-interpretation jobs. of appropriate sanitation Sanitation professionals are directly or chemicals Appropriate supplies on a dotted-line basis related to mem- personal bers of the food safety team and are protective integral to product quality. equipment 4. Multi-purpose systems and tools reduce costs Since the broader adoption of closed-loop, clean-in-place (CIP) sys- Figure 1. Core Elements of Good Sanitation tems in the 1950s, they have played an use. This approach hinges on effective get of cleaning and sanitation programs. integral role in liquid-handling (espe- stepwise cleaning followed by decon- These biofilms are complexes of many cially dairy) facilities, allowing them to tamination using a sanitizer. All other species surrounded by an extracellular run more efficiently by reducing the details associated with these two major matrix of polysaccharides and proteins. steps and time required for cleaning. events or that are part of them must be They can often have many layers of liv- Since then, CIP is routinely used in adhered to with the utmost care. ing organisms and can protect a patho- numerous facilities with more designs gen like Listeria and allow it to persist. being sought for products of higher vis- 2. Sanitizers destroy all microorganisms So, cleaning activities should target cosity and even for dry facilities. How- Sanitizers are chemicals that are ap- biofilms so they can be removed or pre- ever, CIP systems are not appropriate propriate for use in the food industry vented completely. This is why cleaning for all types of products. When a CIP to significantly reduce harmful micro- is followed by sanitization. In an ideal system is connected to an open end, organisms of concern to food safety. world, once cleaning is complete, there the CIP is no longer a closed loop and These include a multitude of bacteria, will be no remaining microorganisms. should be treated as such. Open ends many species of viruses, many species The use of sanitizer is then necessary to allow the transfer of material from an of fungi, and even parasites; however, provide a higher level of security and to ingredient or an in-process or finished sanitizers do not destroy all of them. In complete the sanitation cycle. product into the system, providing a fact, viruses like norovirus and bacteria means for product contamination. Sim- like Clostridium difficile can survive even 3. Sanitation can be done by anyone; a beat- ilarly, tools used in facilities should be when sanitizers are properly used ac- ing heart is all you need matched with their hygienic zone and cording to label instructions. If you’ve worked in a food process- segregated with their own cleaning and Sanitizers also do not work on any ing facility, you know what sanitation management programs. Personal protec- microorganism that is part of a biofilm. is. Similarly, if you’re in production or tive equipment should also be handled Biofilms are communities of microor- in a quality assurance role, you know so it does not become a transportation ganisms that coexist and are present that your success or even your paycheck system for contaminants. Studies have ubiquitously. They are a real challenge may well be connected to how good of shown that boots used in the processing in the food industry and a primary tar- a job the sanitation crew does. The work zone could become contaminated with

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pathogens from raw or nonprocess- 6. Sanitize and go 8. Most humans practice good personal ing areas if they are not cleaned inside Due to product scheduling pres- hygiene and out using a full detergent clean sures, it is possible that the sanitation Sanitation in retail establishments and sanitizer protocol after each use. team may complete applying sanitizer is the ultimate test of good hygiene. Multi-purpose tools and certain reus- minutes before production starts up Good handwashing practices are crucial able items are an opportunity for cost again. The idea that applying sanitizer to preventing cross-contamination. reduction but should always be assessed (or, in the EU, rinsing off sanitizer) is While the flu virus can be killed using for risks that could lead to much larger the last step is a dangerous misconcep- hand sanitizer, foodborne viruses like liabilities, recalls, or tion. Many sanitizers norovirus and many others can only foodborne illness out- require several minutes be removed by effective handwashing. breaks. “Sanitizers are (often 10–30) of con- This is why food establishments and tact time to do their foodservice workers must be particularly 5. More is better chemicals that are job effectively. After aware of and properly trained in per- Sanitizers work this period, any resid- sonal hygiene. Most pathogens that are on bacterial cells, ual sanitizer should be harmful to humans and of economic viruses, molds, and appropriate for use allowed to completely concern to food safety are directly certain single-celled dissipate (at least visu- linked to fecal contamination. So, while or parasitic organisms. in the food industry ally) prior to starting fecal contamination of water, fertilizer, Commonly used com- up the production line. and harvesting or growing environments mercial-use sanitizers Putting into place safe- needs to be controlled, Good Manu- like quaternary am- to significantly guards such as inspec- facturing Practices (GMPs) should be monium compounds tions and sampling can adhered to all the way from the field to need a minimum reduce harmful be used as strategies to foodservice. Employee compliance with contact time that is allow sanitizers to fully proper handwashing practices includes specified in the direc- work. scrubbing under, around, and between tions provided by microorganisms of fingers, washing halfway up the lower each supplier of those 7. Dry facilities do not arm, applying soap, and scrubbing for chemicals. It is of concern to food safety.” harbor bacteria a full 20 seconds prior to rinsing. Being utmost importance to If the past year is conscientious of GMPs in the context use the exact amount any indication, dry of where the facility is located and of of chemical and mix as directed. More facilities that completely avoid the use cultural norms will allow practitioners or less sanitizer will make the sanitiza- of water need to take a hard look at to train employees on further details tion ineffective. Measured delivery their SSOPs in conjunction with their of personal hygiene and GMPs. For systems help avert this issue by allowing supplier program to ensure all risks for instance, employees need to wash hands exact amounts of solvents to be mixed pathogens have been considered. For ex- after sneezing, coughing, and touching for cleaning or sanitizing. All major ample, a dry-powder facility or a syrup body parts; properly use restrooms, tak- suppliers of sanitation supplies provide with a finished product water activity ing advantage of toilet paper or water to numerous products and services to help in the range of 0.75 that goes through prevent fecal contamination on hands, facilities with their sanitation programs. a continuous process will need to be clothes, or other parts; and have plenti- Deciding on the right mix of these monitored to ensure that Salmonella has ful access to soap, running water, and products can be challenging. In think- not found a cozy home. From cereal clean towels. Portable toilet facilities in ing through these options, keeping hy- to pet food and pancake mixes to whey fields provide minimal access to field gienic principles in mind can be help- powder, dry facilities have recalled thou- workers when it comes to preventing ful. This includes an understanding of sands of pounds of product due to Sal- human fecal contamination or exposure the chemical and its purpose based on monella contamination. A protocol for to sick employees. Additionally, a poor- the product. For example, a detergent dry cleaning that includes the removal ly maintained or poorly designed toilet intended for a heavily acidic food soil of all large and visible particles should facility can encourage poor personal like pasta sauce would not be appropri- be followed by ensuring allergens are hygiene or prevent employees from ate for a fresh-cut vegetable operation. cleaned, and then an alcohol-based sani- taking the time to fully clean up after Using the right amount of the right tizer should be applied to the cleaned, using the facility. A thorough hygiene type of detergent followed by the right dry surface. This process will prevent program will consider all aspects of con- amount of sanitizer will allow soils to any potential bacterial buildup or the tamination, including water quality and be removed swiftly and pathogens to be formation or a biofilm where pathogens employee wellness. eliminated. could take up residence. (continued on page 63)

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FSM101118pg10-30,63-65Final.indd 13 10/3/18 9:30 AM POULTRY By Dianna V. Bourassa, Ph.D., and Kim M. Wilson, Ph.D.

full-spectrum feeds decreased from 28 Antibiotic-Free Production to 12 percent. Impacts of NAE Production Changes in the use of antibiotics in and Broiler Chicken Meat poultry feeds can have major impacts on gut health, specifically with regards to coccidiosis and necrotic enteritis. Safety Coccidiosis is caused by intestinal infection of coccidia protozoan parasites (Eimeria), which are commonly found in fecally contaminated environments, such as chicken growout houses. In- fections can cause varying degrees of Does avoiding antibiotics raise inflammation, bleeding in the intestine, and damage to epithelial cells. A more the risk of contaminated raw severe infection has been associated with increases in Salmonella susceptibil- product? ity.2 Since the 1970s, coccidiosis has been controlled through the use of ionophores. Although ionophores are not used in human medicine, they are here is a significant amount of research re- classified as antibiotics and are thus garding the potential impact of the use of not used in NAE feeds. Non-antibiotic- antibiotics in animal feeds on the occurrence classified compounds or coccidia vac- of antibiotic resistance. However, there is little cines are now being used in place of information on how the use of antibiotic-free ionophores to control infection in NAE Tproduction systems impacts the levels and prevalence of birds.3 Some of the FDA-approved foodborne pathogens on raw meat products. compounds used to treat coccidiosis For many years, poultry feeds have contained sub- can include arsenic-based compounds.4 therapeutic levels of antibiotics, known as antibiotic While arsenic-based compounds have growth promoters (AGPs), to maximize the growth been shown to decrease the incidence of potential of broiler chickens. With increasing concerns Salmonella shedding in chickens,5 there regarding antibiotic resistance, the use of antibiotics in is some concern about potential pres- chicken feed has decreased. Antibiotic use in poultry ence of arsenic in meat.4 Live coccidial feed can be divided into three general categories: no vaccines have been in greater use to antibiotics ever (NAE), reduced use, or full spectrum. manage coccidiosis in the U.S.; how- The NAE category applies to birds that have never been ever, this may be a challenge in food fed any antibiotic during their lifetime, including those animals without antibiotics. Breakouts that are medically important and those that are not of Eimeria, even at low levels, can cause used in human medicine. The reduced-use antibiotic varying degrees of intestinal damage. It category does not allow the use of medically important has been suggested that with increased antibiotics but does allow the use of antibiotics not used intestinal damage, antibiotic-free birds in human medicine. Full spectrum allows any U.S. Food could be more likely to become suscep- and Drug Administration (FDA)-approved antibiotic to tible to necrotic enteritis,3 which occurs be used in chicken feed. In 2017, 40 percent of broiler typically as a secondary infection of the chicken feed was provided to chickens raised with NAE.1 intestinal epithelium with Clostridium This was increased from 20 percent in 2016. Reduced perfringens. C. perfringens is commonly antibiotic-use feeds increased from 18 to 29 percent and found in healthy animals and prolifer-

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ates in the intestine upward of 106 bac- Prebiotics such as MOS can work by biotics, or direct-fed microbials (DFMs), teria per gram of gut content. Although blocking binding sites on the intestinal on the other hand, are defined as live other predisposing conditions can oc- epithelium for pathogens, including Sal- microbial feed supplements, which can cur, such as issues with diet formulation monella Typhimurium.11 Feed additives benefit the bird by improving intestinal [large amounts of animal-origin protein such as organic acids, inorganic acids, microbial balance.13 Common DFMs or nonstarch polysaccharide (NSP) fermentation products, essential oils, include combinations of LABs includ- cereal base without enzymes to break and plant extracts can also be added to ing Lactobacillus and Bacillus strains with down NSP],6 changes in the immune the diet and/or drinking water to reduce particular lines of species that have been status caused by mycotoxins,7 or viral pathogens, including Salmonella.12 Pro- shown to reduce pathogens and poten- disease, the most common predisposing factor is coccidiosis.7 During coccidiosis infection, lesions are formed in the intestine, creating a suitable environment for C. perfringens to proliferate and produce toxins. This secondary infection further damages the intestine, leading to necrosis.8 Necrotic enteritis induced by coccidiosis can reduce short-term and overall body weight gain compared with healthy birds, limits digestion potential, and increases body-weight variability through market age.9 The implications of decreased uniformity within a flock due to necrotic enteritis and therefore carcass variability become important for mechanical efficiency during processing. Some work has been done assessing the presence of foodborne pathogens including Salmonella and Campylobacter in the intestines of broilers provided feed with or without antibiotics. A study looking at the presence or absence of bacitracin dimethyl salicylate (BMD) found no differences in cecal Salmonella or ileal Campylobacter prevalence but observed less ileal Salmonella and more cecal Campylobacter at processing age from birds fed with BMD antibiotic added.10 Alternative feed ingredients such as prebiotics and probiotics are being used as replacements for antibiotics. Prebiot- ics are feed ingredients that cannot be digested by the bird but instead selectively stimulate the growth of beneficial bacteria, thus improving bird health. Some of these include nondigestible oligosaccharides (manno-, fructo-, and galacto-oligosaccharides; MOS, FOS, GOS). The beneficial bacteria selected for stimulated growth or activity include Bifidobacteria and Lactobacillus spp., which fall into the category of lactic acid-producing bacteria (LAB).

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tially improve growth.14 Probiotics not antibiotic-resistant bacteria, the use of Impact of Intestinal Integrity on only affect the bacteria in the intestine therapeutic antibiotics increased during Food Safety but also benefit the bird by regulating the first year after AGPs were banned Bird health has a significant impact the immune response15,16 and enhancing in Denmark.19 Early intestinal develop- on processing factors directly relating to intestinal integrity. Regulating the bird ment is more critical than ever as a food safety. For example, broilers with immune response, including inflam- growth promotion method with the fu- airsacculitis have increased fecal con- mation, is a critical ture discontinued use tamination and increased cuts or tears energetic cost to the “With increasing of antibiotics. During of the digestive tract during processing bird. Currently, the the first week of life, (Figures 1 and 2).24 This is thought to precise modes of ac- the gut tissues undergo be due to variability in bird size due tion of probiotics are concerns regarding rapid development, to some birds not being as healthy as not clear due to the increasing the surface others. This size variability becomes a complexity of the antibiotic-resistant area necessary for problem because of the high levels of bacteria within the gut optimal absorption of automation necessary during commer- and a knowledge gap nutrients. Intestinal cial poultry processing. Each piece of on chicken-microbe bacteria, the use of improvements can be equipment is adjusted to operate based relationships. Without seen as increased villus on a specific bird size. When birds with understanding the mi- antibiotics in chicken length and lamina pro- smaller or larger body weights enter the crobial community in pria thickness.20 If vil- equipment, processes such as opening the chicken and tak- lus growth is impaired of the body cavity, viscera pack removal, ing into account the feed has decreased.” during the first 2 weeks and crop removal become less efficient 60 flock-to-flock variabil- of life, this can lead to and can lead to unintended cutting or ity, probiotic administration will remain a permanent limited digestive capacity, 5060 Healthy inconsistent, and breakouts of intestinal reducing growth potential. The early Health-Compromised Healthy disease affecting the final product will intestinal environment is aerobic, lacks 4050 continue. diversity, and contains mostly faculta- Health-Compromised tive anaerobic bacteria including enteric 3040 Links between Animal Health and bacteria (e.g., Salmonella, Escherichia coli, Food Safety Klebsiella) as well as Lactobacillus. Over 2030 The inclusion of AGPs in feed typi- the course of the first few days, bacterial cally results in the modulation of the density increases upward to 1011 bacte- 1020 intestinal microbial community present, ria per gram of gut content and includes including the suppression of bacterial strict anaerobic bacteria (e.g., Clos- 100 Fecal Contamination Digestive cuts/tears pathogens,17 although the mechanisms tridium) and different defined commu- 21 0 by which they work are not completely nities in each section of the gut. The Fecal Contamination Digestive cuts/tears clear. More importantly, AGPs reduce microbiome of an animal varies in both Figure 1. Percentage of Fecal-Contaminated intestinal disease severity, thus decreas- the density and species as well as in or Digestive Cuts/Tears from Healthy or ing mortality, while improving feed different sections of the intestine. The Health-Compromised Broiler Chickens24 18 conversion. In the absence or reduc- intestine at an early age is easily suscep- 5 tion of antibiotic use, there is a pressing tible to disease since there is limited 4.5 need to better understand the role of colonization resistance, and typically 5 Healthy 22 4 bacteria in the intestine as they pro- develops as an animal ages. The bal- 4.5 Health-Compromised Healthy mote health and overall performance. ance between bird, intestinal bacteria, 3.5 4 Health-Compromised A meta-analysis showed that the need and the environment is quite delicate, 3 to use AGPs is reduced when nutri- and imbalance can lead to impairments 3.5 2.5 tion, housing, and hygiene/biosecurity such as an overgrowth of nonspecific 3 19 23 2 are optimized. Intestinal health has intestinal bacteria, leading to enteritis. 2.5 been of increased interest as poultry Intestinal ballooning causing poor gut 1.5 nutritionists, veterinarians, and pro- integrity and malabsorption can lead to 2 1 ducers have attempted to implement wet litter and poor growth.23 Both poor 1.5 0 new approaches to be better equipped gut integrity and wet litter can impact 1 Campylobacter E. coli for the changes in live production processing efficiency and presence of Figure0 2. Campylobacter or Escherichia coli practices. Although withdrawing AGPs foodborne pathogens on processed Campylobacter E. coli log10 CFU/mL from Healthy or Health-Com- may reduce the risk of creating on-farm carcasses. promised Broiler Chickens24

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tearing of viscera. This allows for intes- Kim M. Wilson, Ph.D., recently completed her mals.” J Appl Bacteriol 66:365–378. tinal contents, which can contain high doctoral degree at Ohio State University. 14. Caly, DL, et al. 2015. “Alternatives to Anti- levels of foodborne pathogens, to come biotics to Prevent Necrotic Enteritis in Broiler into contact with carcasses on the pro- References Chickens: A Microbiologist’s Perspective.” Front 60 cessing line. In short, bird health im- 1. poultryhealthtoday.com/rennier-nae- Microbiol 6:1336. pacts flock uniformity, which then leads programs-represented-40-of-us-broiler-feeds- 15. Lyte, M. 2011. “Probiotics Function Mecha- 50 Healthy to potentialHealth-Compromised impacts on food safety. in-2017/. nistically as Delivery Vehicles for Neuroactive 40There are few comparisons between 2. Volkova, VV, et al. 2011. “Associations be- Compounds: Microbial Endocrinology in the raw products from chickens fed NAE tween Vaccinations against Protozoal and Viral Design and Use of Probiotics.” Bioessays and30 conventionally raised birds. When Infections and Salmonella in Broiler Flocks.” 33:574–581. retail chicken breasts were sampled for Epidemiol Infect 139:206–215. 16. Vanderpool, C, et al. 2008. “Mechanisms of Salmonella20 , Campylobacter, and coliforms, 3. Hofacre, CL, et al. 2018. “An Optimist’s View Probiotic Action: Implications for Therapeutic no differences in prevalence or antibi- on Limiting Necrotic Enteritis and Maintaining Applications in Inflammatory Bowel Diseases.” otic10 resistances were observed between Broiler Gut Health and Performance in Today’s Inflamm Bowel Dis 14:1585–1596. organic, antibiotic-free, or conventional Marketing, Food Safety, and Regulatory Cli- 17. Butaye, P, et al. 2003. “Antimicrobial Growth products0 (Figure 3).25 However, in this mate.” Poult Sci 97:1929–1933. Promoters Used in Animal Feed: Effects of Less Fecal Contamination Digestive cuts/tears study, chicken was purchased at a retail 4. Nachman, KE, et al. 2013. “Roxarsone, In- Well Known Antibiotics on Gram-Positive Bacte- market from a variety of sources. In organic Arsenic, and Other Arsenic Species in ria.” Clin Microbiol Rev 16:175–188. another study where chickens were all Chicken: A U.S.-Based Market Basket Sample.” 18. Dibner, JJ and JD Richards. 2005. “Antibiotic processed at the same plant, Salmonella Env Health Persp 121:818–824. Growth Promoters in Agriculture: History and was isolated more frequently from anti- 5. Hofacre, CL, et al. 2007. “Use of Bacitracin Mode of Action.” Poult Sci 84:634–643. biotic-free5 chicken than conventionally and Roxarsone to Reduce Salmonella Heidel- 19. Jensen, HH and DJ Hayes. 2014. “Impact of raised birds.26 A more comprehensive berg Shedding Following a Necrotic Enteritis Denmark’s Ban on Antimicrobials for Growth 4.5 analysis of Healthythe impact of NAE programs Challenge Model.” J Appl Poult Res 16:275–279. Promotion.” Curr Opin Microbiol 19:30–36. on4 the presenceHealth-Compromised of Salmonella and Cam- 6. Prescott, JF, et al. 2016. “Experimental Re- 20. Yu, Q, et al. 2012. “Lactobacillus amylophi- pylobacter3.5 on ready-to-cook poultry meat production of Necrotic Enteritis in Chickens: A lus D14 Protects Tight Junction from Entero- could3 potentially be done by assessing Review.” Avian Path 45:317–322. pathogenic Bacteria Damage in Caco-2 Cells.” J regulatory results from both NAE and 7. Antonissen, G, et al. 2015. “Fumonisins Affect Dairy Sci 95:5580–5587. 2.5 conventional programs. the Intestinal Microbial Homeostasis in Broiler 21. Solis de los Santos, F, et al. 2007. “Gastro- 2To minimize potential negative Chickens, Predisposing to Necrotic Enteritis.” intestinal Maturation Is Accelerated in Turkey food1.5 safety impacts of antibiotic-free Vet Res 46:98. Poults Supplemented with a Mannan-Oligosac- programs on ready-to-cook poultry 8. Van Immerseel, F, et al. 2004. “Clostridium charide Yeast Extract (Alphamune).” Poult Sci 1 products, poultry producers are working perfringens in Poultry: An Emerging Threat 86:921–930. 0 towardCampylobacter enhancing and maintainingE. coli opti- for Animal and Public Health.” Avian Path 22. Kamada, N, et al. 2013. “Control of Patho- mum bird health. n 33:537–549. gens and Pathobionts by the Gut Microbiota.” 9. Wilson, KM, et al. “Comparison of Multiple Nat Immuno 14:685–690. Dianna V. Bourassa, Ph.D., is an Assistant Professor/ Methods for Induction of Necrotic Enteritis in 23. Teirlynck, E, et al. 2011. “Morphometric Extension Specialist in poultry processing in the De- Broilers.” J Appl Poul Res in press. Evaluation of ‘Dysbacteriosis’ in Broilers.” Avian partment of Poultry Science at Auburn University. 10. Kumar, S, et al. 2018. “Effect of Antibiotic Path 40:139–144. 40 Withdrawal in Feed on Chicken Gut Microbial 24. Russell, SM. 2003. “The Effect of Airsacculitis Dynamics, Immunity, Growth Performance and on Bird Weights, Uniformity, Fecal Contamina- 35 Antibiotic Free Prevalence of Foodborne Pathogens.” PLOS tion, Processing Errors, and Populations of 30 Conventional ONE 13(2):e0192450. Campylobacter spp. and Escherichia coli.” Poult 11. Spring, P, et al. 2000. “The Effects of Dietary Sci 82:1326–1331. 25 Mannaoligosaccharides on Cecal Parameters 25. Mollenkopf, DF, et al. 2014. “Organic or 20 and the Concentrations of Enteric Bacteria in Antibiotic-Free Labeling Does Not Impact the the Ceca of Salmonella-Challenged Broiler Recovery of Enteric Pathogens and Antimicro- 15 Chicks.” Poult Sci 79:205–211. bial-Resistant Escherichia coli from Fresh Retail 10 12. Cerisuelo, A, et al. 2014. “The Impact of a Chicken.” Foodborne Pathog Dis 11:920–929. 5 Specific Blend of Essential Oil Components and 26. Park, JH, et al. 2017. “Comparison of the Sodium Butyrate in Feed on Growth Perfor- Isolation Rates and Characteristics of Sal- 0 Salmonella Campylobacter mance and Salmonella Counts in Experimental- monella Isolated from Antibiotic-Free and Figure 3. Pathogens Recovered from Retail ly Challenged Broilers.” Poult Sci 93: 599–606. Conventional Chicken Meat Samples.” Poult Sci Ready-to-Cook Chicken25 13. Fuller, R. 1989. “Probiotics in Man and Ani- 96:2831–2838.

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irrigation water, insects, inadequately composted manure, and wild or domes- Healthy Fresh Produce tic animals. Postharvest contamination relates to handling and preparation such as cutting, slicing, or peeling of produce in a Sweet Wrap that damages their tissues, releasing nutrients and facilitating growth of microorganisms. It is estimated that as much as 25 percent of all food produced is lost postharvest owing to microbial ac- Natural packaging alternatives tivity.4 Food Packaging Functions are available Since food contamination occurs mostly at the surface of food, food packaging plays an important role in preventing the growth of microorganisms, thus enhancing safety and maintaining quality of the packaged foods.5 llnesses due to the consumption of foods contami- The primary purpose of packaging is nated with pathogens have a huge economic and to protect foods from the environment public health impact worldwide.1 The U.S. Centers and maintain them in proper condi- for Disease Control and Prevention estimates that tion during shipping, distribution, and each year, 1 in 6 people in the U.S. gets sick, 128,000 storage. Food packaging also enables are hospitalized, and 3,000 die of foodborne illnesses foods to travel safely from their point I 2 (FBIs). The Economic Research Service of the U.S. De- of origin and still be wholesome at the partment of Agriculture reports that the annual cost of time of consumption.6 However, the medical care, loss of productivity, and premature deaths packaging must balance the protection due to FBIs is estimated to be $16.3 billion.3 Estimates of food with other issues such as impact from 2011 show that the main pathogens contribut- on the environment. The main types ing to domestically acquired FBIs resulting in death of packaging that are currently used are included Salmonella, Toxoplasma gondii, Listeria monocyto- derived from nonrenewable petroleum genes, norovirus, Campylobacter spp., and Escherichia coli resources, including nonbiodegradable O157:H7.2 Despite advances in food processing technol- plastic materials. The volume of plastics ogy, food handling, and food safety awareness, FBIs discarded annually creates a substan- remain common in the United States. tial waste disposal issue. There was a In the U.S., illnesses and cases associated with fresh 37 percent increase in municipal solid produce were larger than those involving seafood, poul- waste from 179.6 million tons in 1988 try, beef, pork, or eggs. An analysis of outbreak data to 245.7 million tons in 2005 due to in the U.S. from 1988 to 2008 showed an average of plastic packaging. Packaging made up 6.3–13.2 illness outbreaks each year caused by produce.1 the largest portion of waste generated For U.S.-grown leafy vegetables alone, more than 20 at 31.2 percent. Food packaging alone foodborne outbreaks have been linked to contamination accounts for almost two-thirds of total by E. coli O157:H7 since 1995, resulting in at least 600 packaging wastes by volume. Therefore, reported illnesses and five deaths. food packaging has become a focus of Since most fresh produce is eaten raw and receives waste reduction efforts because proper minimal processing, contamination with pathogens rep- waste management is important to resents a serious risk. The contamination can occur ei- protect human health and the environ- ther pre- or postharvest. Preharvest sources include soil, ment. Although some materials can be

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recovered and recycled, many synthetic tively low cost, the benefits of natural improve its potential as food packag- polymer-based materials end up in land- polymerization, abundant availability ing.13 fills or in the environment. To address of raw materials, and fast biodegradabil- Biopolymer-clay nanocomposites some of these problems, considerable ity.9 Starches derived from potato, yam, are a new class of materials with poten- research has been undertaken to obtain corn, maize, wheat, rice, and cassava tially improved mechanical properties. environmentally friendly food packag- have been frequently investigated for These composites are prepared by the ing materials.7 the development and characterization addition of low amounts of nanoclay to In the last few years, this research of starch-based edible films.10 Sweet the biopolymer matrix. The addition of has aimed to develop materials derived potato (SP) (Ipomoea batatas Lam) is an nanoscale particles to starch can change from plants, whose main advantage is inexpensive and readily available veg- the crystallization kinetics, the crystal- that they are fully biodegradable. Bio- etable that is cultivated extensively for line morphology, the crystal forms, and degradable films have been proposed as its nutritious value across many regions the crystallite size. As a result, these par- alternative food packaging to improve of the world. In the past 15 years, the ticles may improve the mechanical and the quality and safety of food products. U.S. sweet potato industry has grown barrier properties of starch. Montmoril- This technology protects foods from significantly.11 In 2014, North Carolina lonite (MMT) is the most commonly dehydration and acts as a gas barrier produced 53 percent of all SP grown used natural clay and has been success- with the surrounding media, extending in the country.12 Technological applica- fully applied in numerous nanocompos- the shelf life of the foods.8 tions of starches revealed their limited ite systems.14 The popularity of MMT mechanical properties compared with nanoclays in food contact applications New Options for Food Packaging conventional synthetic polymers due to derives from their low cost, effective- Several studies showed the efficacy starch’s hydrophilic characteristic. On ness, and high stability.15 The nanoclays of starch for food packaging to preserve its own, starch is not a viable wide-scale have an average thickness of about 1 nm food quality against microorganisms. substitute for conventional packaging, and average lateral dimensions ranging Starch is the most commonly used raw but scientists are discovering ways to between a few tenths of a nanometer material in agriculture due to its rela- combine starch with novel materials to to several microns. The incorporation

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of MMT into starch matrices has been (a natural biopolymer extracted from life of the product. Furthermore, the used to enhance mechanical and barrier crustacean shells). However, nisin has a combined effect of MMT and TEO (up properties.16 In some studies, the safety limited spectrum of activity, does not to 4%) improved tensile strength (which of packaging materials made with nano- inhibit Gram-negative bacteria or fungi, is defined as extending the film at a clays was investigated. The main risk of and is effective only at low pH.20 There given rate upon breakage and registering consumer exposure to nanoclay packag- is a concern with allergenicity of chito- the strength versus time or distance), ing is through migration of nanopar- san incorporated into packaging. Thyme elongation (which is defined as the per- ticles or other substances from pack- essential oil (TEO) has been evaluated centage of elongation at the moment of ages into foods that are then ingested. and effectively exhibited antimicrobial rupture of the tested sample), and However, migration studies are few in activity against pathogenic microorgan- tristimulus color values. Also, our re- number. Avella et al.17 showed that veg- isms.9 sults showed that the incorporation etables in contact with Scientists at North of TEO into the film significantly clay/starch nanocom- “Biodegradable films Carolina A&T State reduced the population of E. coli and posite films exhibited University created a S. Typhimurium on fresh baby spinach no changes in their biodegradable nano- leaves below detectable levels within iron or magnesium have been proposed composite film for 5 days, whereas the control samples content. Their results food packaging that without essential oil maintained ap- demonstrated either as alternative food incorporates TEO and proximately 4.5-log CFU/g.22 Thymol no appreciable migra- biodegradable MMT and carvacrol are the most active com- tion of the constituent nanofillers into sweet ponents in TEO. It has been reported elements of the clay packaging to improve potato starch (SPS) to that TEO has inhibitory effects against nanoparticles into address issues of food microorganisms through the breakdown the food or migration the quality and safety safety, environmental of the outer membrane of the microor- within the limits set impact, and agricultur- ganism and leads to an excessive leakage forth by the current al sustainability. The of essential elements, causing bacterial food regulations. of food products.” physico-mechanical cell death. Also, the effects of TEO refer Furthermore, nano- and barrier properties to its ability to increase the permeability composite films are excellent vehicles of the film were characterized. Then the of the cell’s outer membrane, leading to for incorporating a wide variety of ad- antibacterial activity of the developed the release of lipopolysaccharides and ditives such as antioxidants and antimi- film was tested against two foodborne increased adenosine triphosphate loss.23 crobial agents. The effect of these addi- pathogens (Salmonella and E. coli) on Furthermore, the ratios of the major tives may result in improvement of food inoculated baby spinach leaves during 8 and minor components describe the quality and safety. The antibacterial days of refrigerated storage. To compre- chemical composition of the essential activities of the films are determined in hend consumer preferences, a sensory oils. The baby spinach samples wrapped part by the release rate of antibacterial test on uninoculated samples was con- in SPS films without TEO showed a agents—too slow of a release and micro- ducted as well. decrease in bacterial or yeast and mold bial growth is not inhibited sufficiently; The results showed that incorpo- populations. This might be due to supe- too fast of a release and inhibition is not rating MMT and TEO into SPS film rior oxygen barrier properties of starch- sustained.18 Nanoclay can potentially be greatly improved water solubility and based films, which limit the growth used to control the release rate of anti- water vapor permeability by more than of aerobic bacteria on the samples microbial agents from film materials. 50 percent.21 Water vapor permeability wrapped in the films.24 Films containing Currently, consumers are more is the time rate of water vapor transmis- 2 percent TEO showed lower numbers conscious about the potential health sion through a unit area of thickness of microorganisms compared with the risks associated with the consumption induced by a unit vapor pressure differ- control samples after storage at 4 °C for of synthetic additives in food products ence between two surfaces. Water vapor 2 and 8 days. However, when the baby for preservation and other applications. permeability is one of the most impor- spinach samples were wrapped in films Indeed, the shift toward the incorpora- tant parameters for biodegradable films. with 4 and 6 percent TEO, no bacterial tion of antimicrobial agents into pack- Since the main function of food packag- or yeast and mold growth was detected aging rather than directly adding them ing is to avoid or minimize moisture over the storage time. This indicates to food products has been a significant transfer between the food and the sur- that TEO incorporated into SPS/nano- focus of packaging research.19 Several rounding atmosphere, water vapor per- composite films could strongly inhibit natural antimicrobials have been in- meability should be as low as possible the growth of microorganisms. Sensory corporated into food packaging such as to optimize the food package environ- scores of spinach samples wrapped in plant essential oils, nisin, and chitosan ment and potentially increase the shelf films containing TEO were higher than

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those of controls. Overall, this study Food Process Technol 3(3):00073. hydrate Polymers 65(4):488–494. suggests that SPS incorporated with 13. Pelissari, FM, et al. 2009. “Antimicrobial, 19. Suppakul, P, et al. 2011. “Diffusion of Linalo- TEO may provide a viable solution to Mechanical, and Barrier Properties of Cas- ol and Ethylchavicol from Polyethylene-Based the waste disposal of plastic packaging sava Starch-Chitosan Films Incorporated with Antimicrobial Packaging Films.” LWT—Food Sci materials for foods and shows a strong Oregano Essential Oil.” J Agric Food Chem Technol 44(9):1888–1893. potential for use as active packaging. n 57(16):7499–7504. 20. Tiwari, BK, et al. 2009. “Application of 14. Paul, DR and LM Robeson. 2008. “Polymer Natural Antimicrobials for Food Preservation.” J Reza Tahergorabi, Ph.D., is a Research Assistant Pro- Nanotechnology: Nanocomposites.” Polymer Agric Food Chem 57(14):5987–6000. fessor in the Food and Nutritional Sciences Program at 49(15):3187–3204. 21. Issa, AT, et al. 2018. “Sweet Potato Starch North Carolina A&T State University. 15. Park, H, et al. 2003. “Environmentally Based Nanocomposites: Development, Charac- Friendly Polymer Hybrids. Part 1. Mechanical, terization and Biodegradability.” Starch Stärke. References Thermal and Barrier Properties of Thermoplas- 22. Issa A, et al. 2017. “Impact of Sweet Potato 1. www.fda.gov/food/guidancecompliance tic Starch/Clay Nanocomposites.” J Mater Sci Starch-Based Nanocomposite Films Activated regulatoryinformation/guidancedocuments/ 38(5):909–915. with Thyme Essential Oil on the Shelf-Life of produceandplanproducts/ucm064458. 16. McGlashan, SA and PJ Halley. 2003. “Prepa- Baby Spinach Leaves.” Foods 6:43. 2. www.cdc.gov/ecoli/2012/O157H7-11-12/ ration and Characterization of Biodegradable 23. Hosseini, MH, et al. 2009. “Antimicrobial, index.html. Starch-Based Nanocomposite Materials.” Poly- Physical and Mechanical Properties of Chitosan 3. www.ers.usda.gov/media/1204379/eib118.pdf. mer Int 52(11):1767–1773. Based Films Incorporated with Thyme, Clove 4. Campos, A, et al., “Use of Natural Preserva- 17. Avella, M, et al. 2005. “Biodegradable and Cinnamon Essential Oils.” J Food Process tives in Seafood,” in Novel Technologies in Food Starch/Clay Nano Composite Films for Preserv 33(6)727–743. Science: Their Impact on Products, Consumer Food Packaging Applications.” Food Chem 24. Chen, ZH, et al. 2003. “Starch Granule Size Trends and the Environment, eds. A McElhatton 93(3):467–474. Strongly Determines Starch Noodle Processing and PJ do Amaral Sobral (New York: Springer, 18. Li, B, et al. 2006. “Preparation and Perfor- and Noodle Quality.” J Food Sci 68:1584–1589. 2012), 325–360. mance Evaluation of Glucomannan-Chitosan- 5. Davidson, PM and MT Taylor, “Chemical Nisin Ternary Antimicrobial Blend Film.” Carbo- Preservatives and Natural Antimicrobial Com- pounds,” in Food Microbiology: Fundamentals and Frontiers, eds. P Doyle, LR Beuchat, and TJ Qlaboratories.com Montville (Washington, DC: American Society for Microbiology Press, 2007), 713–734. 6. Marsh, KS and B Bugusu. 2007. “Food Pack- aging—Roles, Materials and Environmental Is- sues.” J Food Sci 72(3):R39–R55. 7. Environmental Protection Agency, Municipal Solid Waste in the United States: 2005 Facts and Figures. EPA530-R-06-011 (Washington, DC: EPA, 2006). 8. Salmieri, S and M Lacroix. 2006. “Physico- chemical Properties of Alginate/Polycaprolac- tone-Based Films Containing Essential Oils.” J Agric Food Chem 54(26):10205–10214. 9. Mehdizadeh, T, et al. 2012. “Antibacterial, Antioxidant and Optical Properties of Edible Starch-Chitosan Composite Film Containing Thymus kotschyanus Essential Oil.” Vet Res Forum 3(3):167–173. ANALYTICAL CHEMISTRY, MICROBIOLOGY 10. Bourtoom, T and MS Chinnan. 2008. “Prep- AND RESEARCH & DEVELOPMENT aration and Properties of Rice Starch-Chitosan LABORATORY SERVICES Blend Biodegradable Film.” LWT—Food Sci Technol 41(9):1633–1641. World-Class Science With A Consultative Approach 11. www.fao.org/faostat/en/#home. Scientifically Accurate Results Your Business Can Absolutely Trust 12. Issa, A, et al. 2016. “Sweet Potato Starch/ Service Beyond Expectations Clay Nanocomposite Film: New Material for Emerging Biodegradable Food Packaging.” MOJ

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were safe and of the highest quality. The Hot Shoppes restaurant concept had to Effects of Millennials on learn to manage the potential risks associated with made-from-scratch food production. The fledgling company experi- Culinary Food Safety mented with food choices, with input from repeat diners, while maintaining a focus on food safety. Early recipe cards included safe food handling procedures. Fast-forward to the 1990s when Food safety management Marriott established its own food distribution system—Marriott Distribution must keep up with evolving Services (MDS). MDS had 13 facilities in the U.S., which performed broad- tastes line distribution for all of Marriott’s foodservice operations, and in 2000, it was awarded the distribution contract for Darden Restaurants. In 2001, Mar- ccording to the Pew Research Center, millen- riott, together with Hyatt, ClubCorp, nials are expected to overtake baby boomers and Fairmont, launched a procurement in the U.S. population in 2019.1 As a result, company called Avendra to serve the food and beverage trends will evolve U.S. hospitality market.3 The result was at a pace that has not been seen in decades. improved operational performance for AWhereas baby boomers want traditional and recogniz- hotels by reducing the burden of ven- able food and venues, millennials are seeking the ad- dor management, while bringing guests venturous and experiential while demanding affordable, more innovative food choices. healthy, and local food choices.2 Both MDS and Avendra had robust In response to this massive purchasing clout, the res- and comprehensive food safety man- taurant industry is innovating at a record pace in terms agement systems that included vendor of menu choices and business models. This puts a strain vetting, supply chain management, and on food safety management systems, as new risks must hotel-specific Sanitation Standard Oper- be assessed and interventions implemented in a large ating Procedures. When MDS was sold organization. Marriott International’s global food safety in 2002, their food safety management team is not immune to these growing pains. We realize system standards were required to be that innovation must be done responsibly to protect adopted in Marriott’s agreements with public health. new broad-line distributors. Marriott’s share in Avendra was sold to Aramark in Our Legacy 2017.4 Avendra’s highly skilled quality Since its founding in 1927 and the first Hot Shoppes assurance team continues to evolve as chain, Marriott International has aggressively pursued a crucial part of Aramark’s food safety food safety methods, which established a strong food prowess. Aramark has dedicated food safety culture. These early restaurants pioneered daily safety supervision on-site, serving nearly employee “stand up meetings,” in which topics of safe 2 billion meals every year globally. food and personal hygiene were discussed. Food safety Today, Marriott International has and taking care of the employee were early core values a mature food safety culture and is in the company. The founder, John Willard (JW) Mar- now the largest hotel company in the riott, understood that to achieve success, he would have world.5 Marriott delivers safe, high- to establish trust among his customers by establishing quality food under its 30 brands in over an inherent understanding that his food and beverages 10,000 restaurants, 6,500 hotels, and

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countless meetings and events around food safety team. This has proven to be eaten at home. According to this report, the world. Marriott’s global food safety a highly effective method of maintain- millennials eat in a restaurant or bar team continues the values of its founder ing food safety standards. around 30 percent more than any of the by ensuring “best in class” food safety The latest report from the U.S. older generations. This is good news for standards and prescriptive protocols. Department of Agriculture surveyed hotel restaurants. Our culinary team is diligent in seek- millennials’ food-buying habits.6 This ing out our guests’ food and beverage younger generation is buying a lot Are There Effects on Food Safety? preferences, evolving our understanding more prepared food, and the wealthier The very popular restaurant Court- of behaviors and beliefs that influence a household becomes, the less food is yard Bistro is an example of a restaurant food choices in today’s markets.

Today’s Customers Our current focus is, of course, millennials, as they are now the spotlight generation. Demographers define millennials as those born between the early 1980s and the mid-1990s to early 2000s. We know that millennials are today’s trendsetters, which means that whatever is trending in food and beverages, it cannot trend without them. Millen- nials see food as an adventure. They don’t observe traditional meal periods, so foods that were once exclusively for breakfast are now in demand late at night. And fresh foods must be available on demand, anytime. Millennials graze instead of eating large meals. More than any other generation, millennials are more savvy in understanding menu verbiage. French cooking tech- nique terminology is one example. The same can be said for their recognition of nonmainstream fruits, herbs, and vegetables, as well as ethnic spice blends. They help us market and spread the word of a hotel restaurant’s innovative offerings through social media. Plant-based diets are increasingly popular among this demographic, and Marriott expects this trend to gain greater traction in the future. For hamburg- ers, it’s not just ground chuck anymore. Beef primals like flank, brisket, and short loin are ground and combined to produce a more flavorful burger. These new cuts of meat and processing techniques raise the risk of contamination. Marriott’s brand standard mandates that all finished ground beef be tested for pathogens using a “test and hold” protocol. Our vendors are held to this standard, and quarterly laboratory analysis must be relayed to the global

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concept that is hyperfocused on the ensuring comprehension. Food safety evening social program called The Resi- modern customer’s tastes. There is an training for associates in these brands dence Inn Mix. Designed to appeal to ongoing cadence of menu updates to is typically via online classes. Distance millennial travelers, part of this engag- this brand’s food and beverage offer- learning is becoming much more widely ing experience is food trucks. Guests can ings. This concept provides fresh and used, and certifications and on-property get a sense of exciting local food choices healthy choices for travelers and locals food safety tools are increasingly au- in a casual atmosphere. alike. Marriott International’s 29 other tomated. The Marriott culinary team Residence Inn has also been identi- brands are also keenly aware that mil- develops these fresh choices but also fied by the food allergen community lennials will make up over half of their collaborates with specialized vendors as a destination for families with food- in-house guest population by 2020. New who provide innovative food choices. allergic travelers, including children brands like AC Hotels The global food with life-threatening issues.8 Marriott’s by Marriott and Moxy safety team has input cleaning and sanitizing standards ensure are designed to cater “Our current focus is, into issues such as that in-room hotel kitchens have safe to this demographic. shelf life, critical limits utensils and cooking equipment. We Both food and bever- of course, millennials, for cooking and re- audit extended-stay hotels for standards age concepts are de- heating, food allergens, as well. signed to be bespoke nutrient content, and and customizable, as they are now the other intrinsic risk fac- A Closer Look at Full-Service while telling a story tors. These new con- Hotels with the menu. spotlight generation.” cepts create new issues A food trends survey conducted in The reinvented in the areas of product 2018 by the National Restaurant As- Aloft brand features packaging and meet- sociation identified the “hyperlocal” an innovative “Breakfast Pots” concept ing U.S. Food and Drug Administration concept as the number one trend that as part of the food and beverage strategy (FDA) labeling requirements. The team chefs nationwide will be exploring.9 Hy- called Re F–uel, which allows guests to also provides guidelines and resources perlocal is a concept that includes grow- easily order their meals from a kiosk.7 to hotels that do things such as pack- ing produce on the premises in rooftop Millennials are looking for a frictionless age their own food or press fresh juices. gardens or indoor vertical farming, or experience, one that enables them to Additionally, ingredients must comply producing foods that are traditionally quickly get on with their day. Re F–uel’s with the company’s stated animal manufactured in a commercial facility. Breakfast Pots are customized creations welfare and “clean label” commitment Marriott’s food and beverage operators that are both trendy and portable, with goals. Providing cage-free eggs, meeting are also focusing on this trend, driven unique flavor profiles. This is a welcome trans fat prohibition regulations, and by millennials’ demand for variety and change from the traditional breakfast identifying genetically modified ingredi- their distrust of factory farms. Chef’s buffet-style outlets of many competi- ents in jurisdictions that have these laws gardens allow hotels to bring novel pro- tors. are some of the many efforts that occur duce and vegetables into the restaurant From a food safety perspective, the behind the scenes when developing new that would not normally be served by concept features items that are made food and beverage offerings. their competitors and are not available quickly in fast-cooking, state-of-the-art We must first be satisfied that prod- through normal produce distibutors. ovens. No hot food is held, and cold ucts are safe as presented, stored, and All these innovative practices must food components are used in multiple prepared. Operators are then trained to have prescriptive guidelines developed recipes, which reduces inventory. This ensure a sound food safety management and communicated to hotel operators concept not only exceeds guests’ ex- system that covers: to ensure brand protection by mitigat- pectations but also allows operators to • Retail items ing unsafe practices that can lead to focus on a limited number of Critical • Fresh packaged food and drinks foodborne illness. Some of these prac- Control Points (CCPs) that can easily • Fresh-made items tices that particularly appeal to milleni- be monitored and documented. • Prepared, cooled, and reheated sand- als include the following: The business model for select service wiches • Growing vegetables hotels features generalists who multi- Marriott believes that its model of • Raising food animals task, performing both front- and back- food and beverage offerings that are • Brewing beer of-the-house functions. It is therefore nutritious, trendy, and always accessible • Fermenting meat (charcuterie) crucial that this type of employee be is not a fad. • Producing probiotic-type beverages food safety trained and able to operate The millennial demographic is also • Beekeeping (for honey) in an efficient and unencumbered man- driving trends in experiential dining. • Generating water ner which maximizes their time, while Brands like Residence Inn offer an • Aging meat

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• Distilling beverages county, and state environmental health food handlers. • Producing cold-pressed juices specialists as best practices. Food allergy/food intolerance train- Resources including Hazard Analysis ing is also required for all food manag- and Critical Control Points (HACCP) Training ers in response to our guests with special plan templates and other best practices The global food safety team man- dietary needs. There must be an empha- are made available to hotels via Marri- dates that each food handler has food sis on knowing ingredients that go into ott’s intranet. Many times, these innova- safety training and that each food menu selections and how to prevent tive chefs employ food safety methodol- manager obtains an American National cross-contact. Our third-party brand ogies that far exceed local jurisdictional Standards Institute-accredited food safe- standards audit ensures that hotels are requirements. ty certification. In addition to food han- complying with these training require- As our full-service North American dlers and food managers, general man- ments. hotels continue to push the envelope agers and assistant general managers, as on nontraditional food production well as hotel engineers, are required to Technology and procurement, take food safety train- Through social media, guests can call expanded preventive ing. All those who out improper food handling or unsani- controls are being “…hotels are guided prepare food, work on tary conditions in restaurants, frequent- initiated in the U.S. equipment, purchase ly in real time. Millennials account for as they are in other through the prevention, food, or manage those most of these postings. It is important parts of the world. who do these jobs for our hotel teams not to become Our hotels overseas must have a good un- defensive toward or dismissive of these are seeing increased management, derstanding of the risks observations, regardless of their validity. local jurisdictional associated with food- By using social media comments as a requirements in food and remediation service. These stake- vehicle to increase food safety awareness safety that go above holders are trained to and identify additional training needs, and beyond FDA Food not only prevent food- our operations become safer. Code guidelines. In of gastrointestinal borne illnesses but also As the hotel workforce continues to China, for instance, all how to identify guests evolve, and newer branded hotels are our hotels must have outbreaks among who may bring in staffed with younger people, antiquated a hygiene manager prolific infections like CCPs and manual monitoring methods by law. Throughout norovirus. As some of are increasingly questioned. Millennials Asia, the EU, and the guests and associates.” these pathogens can be have grown up with apps that assist in Middle East, random transmitted from per- everyday life, and having to handwrite food sample analysis and environmental son to person, nonfoodborne preven- temperature logs is not intuitive for sampling are routine. Food handler vac- tion measures also must be followed. them. The goal of the global food safety cinations and routine stool testing are In-house guests present a much more team has been and will continue to be common outside of the U.S. Some of significant risk than transient custom- the automation of all monitoring and these additional prerequisite programs ers in freestanding restaurants. This verification processes. We are converting are added to high-risk hotels’ HACCP captured population utilizes in-room many hotels to electronic monitoring plans in the U.S. as proactive interven- dining, transports food throughout with the help of younger associates. tions. the property, and stores leftovers in Seamless adoption of new technology Executive chefs are increasingly minibars. Contagious infections can be must be the new norm in hotel environ- becoming more educated and compe- transmitted to other guests by way of ca- ments, as we continue to leverage the tent in developing Good Agricultural sual common-room contact or in hotel Internet of Things, finding cloud-based Practices plans on their own, taking re- events and meetings. solutions for training, supply chain sponsibility for measures to address the Through the protocols authored by intelligence, and HACCP monitoring. risks of growing their own produce. The the global food safety team, hotels are This ensures accuracy and continuity global food safety team continuously guided through the prevention, man- and demonstrates our due diligence in tries to identify risks associated with agement, and remediation of gastro- active managerial control. these emerging practices and provide intestinal outbreaks among guests and solutions. There are many anecdotes in associates. Comprehensive cleaning and Public Trust which local food safety regulations have sanitizing protocols must be developed Group meeting planners, tour opera- evolved after learning of these special- and deployed that include mandated tors, and others who bring in blocs of ized activities. Hotel HACCP plans are disinfection products along with strict constituents are increasingly asking what shared with and often adopted by city, restriction/exclusion guidelines for ill food safety con- (continued on page 63)

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pathogens, so it is important to know about multiple cleaning agents and how Disinfectants and Sanitizers they work.

Factors Affecting Efficacy Are Essential to Produce Safety Before discussing specific sanitizers and disinfectants, it is important to note that several different environmental factors can play into an antimicrobial’s efficacy: • Potable Water: It is critical for the water to be potable and not contain Solutions for increasing the any debris, odor, or microorganisms. • Low Total Dissolved Solids (TDS): safety of fruits and vegetables TDS are mineral deposits in water that can encourage the survival of pathogenic bacteria or bind to the bactericidal ingredients of a sanitizer. Because of this, it is better to use soft n the past few decades, the majority of foodborne water instead of hard water. The pres- outbreaks have been associated with contaminated ence of soil hinders the ability of a fruits and vegetables. The last 7 years prior to 2018 sanitizer to do its job, so getting rid saw more than 20 outbreaks coming from produce of as much soil as possible is neces- in North America alone. Some of the pathogens sary for sanitation. Iinvolved are Salmonella spp., Escherichia coli O157:H7, • Water Temperature: It is essential to Listeria monocytogenes, hepatitis A, etc. Myriad produce maintain proper water temperature, types, such as cantaloupes, romaine lettuce, cucumbers, because sanitizers typically do not and even frozen produce, are responsible for these out- work as well if the water is too cold. breaks.1 This year, the United States experienced a mas- If the water is too hot, the sanitizer sive foodborne outbreak of E. coli O157:H7 in romaine can vaporize and release toxic gas lettuce. Although the recall is pretty much over, con- into the environment. Water tem- sumers, farmers, and retailers face a lot of repercussions. perature must also be considered As of May 30, 2018, more than 150 individuals have in maintaining the quality of the become ill, and several have died. In addition, farmers produce. Different types of produce have experienced extreme crop loss, retail sales have have different tolerance levels for plummeted, and restaurants are changing suppliers and water temperature. finding substitutes for romaine lettuce, which stops or • Water pH: Testing the water for pH slows down the supply chain flow.2 is critical because sanitizers have different optimal pH values. Water Alone Is NOT Enough • Contact Time: In addition to tem- In light of all these outbreaks, washing and rinsing perature and pH, it is important to the produce with water alone are not sufficient to elimi- consider the contact time, because if nate pathogens.1 The solution to this issue is the use of a sanitizer or disinfectant is not ap- disinfectants and sanitizers. Disinfectants and sanitizers plied long enough, sanitation will be are two different types of chemicals used in ensuring insufficient. If a sanitizer is applied food safety. A sanitizer is used to reduce the number of too long, it will be harder to clean bacteria on a surface to an acceptable level, whereas a off, may cause an off taste, and can disinfectant can eliminate a wider range of microorgan- cause a chemical hazard. isms.3 One cleaning agent cannot be effective against all • Produce Surface Texture: Since sani-

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tizers and disinfectants are usually applied to the surface, it is important to consider the surface texture. For example, a fruit with a lot of bruises or punctures will be much more difficult to clean than a fruit that is very smooth. There are many other factors to consider, but these are the six most basic factors. Considering all these factors will help SMART determine the right sanitizer or disinfectant to use on which fruit or vegetable and to kill a target pathogen.4

Types of Disinfectants and Sanitizers Specific sanitizers and disinfectants have unique character- DIGITAL istics that give them different functions and uses.

Chlorine The most popular disinfectants are made with chlorine, which kills bacteria by disallowing uptake of nutrients and WATER oxygen, which causes the denaturation of proteins.4 The ® chlorine-based sanitizers most commonly applied to fresh produce are pure chlorine gas, calcium (continued on page 64) Validation and Verification Procedures TESTING When choosing the proper sanitation program for produce, processors want to make sure the sanitation Safe, Simple, Certified program has been validated. Validation is “a collection of USEPA DIN, ISO scientific proof that a particular process involving chemi- Compliant For Free & Total Chlorine cal, physical, or biological inputs is consistently delivering Chlorine Dioxide a desired effect in” eliminating pathogens.10 For example, if a processor wanted to use aqueous ozone to sanitize blueberries, the processor would have to confirm that the

company supplying the ozone has scientific documenta- GET IT ON tion that demonstrates the ozone’s ability to kill micro- eXact iDip biological pathogens on blueberries. According to Will Daniels, president, produce division, IEH Laboratories and Consulting Group, one should remember that validation studies conducted by “sanitation and disinfectant companies” are typically benchtop laboratory studies. These studies are not specific validation studies performed to consider each processors’ specific needs, such as methods, equipment, environmental factors, type of product, etc. Produce processors should invest the time and money to conduct specific validation studies for any sanitizer and/ or disinfectant that they choose to use at their facility, with specific produce and processing methods. Verification and validation go hand in hand in ensuring SMART PHOTOMETER SYSTEM® PMA SMART METER SYSTEM food safety. Verification is defined as “the confirmation with BOOTH with that you are doing what you intended or planned to do 1574 and that it is effective.”10 For processors using aqueous ozone on their blueberries, verifying that the ozone is doing what it is supposed to do requires oxidation-reduction probes that are calibrated so that they can determine if the correct amount of ozone is applied every time. A review of monitoring records and a microbial analysis of the blueberries to get the appropriate log reduction are also good The Only Level 1 NSF®-50 Certified ways to verify the use of ozone. Basically, verification in- Water Testing System volves making sure that the validated study performed by the ozone company matches up with the results achieved SENSAFE by the blueberry producer. ITSSENSAFE

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7 in 10 U.S. and Canadian processors The Uphill Path to and about 50 percent of international companies are reporting that they are in compliance with a regulation that FSMA Compliance has been coming their way since 2011. In the August/September issue of Food Safety Magazine, where we convened an expert panel on FSMA implementation, John M. Ryan, Ph.D., PCQI, Ryan Systems Inc., made the excellent point that “FSMA regulations attempt to define a complex system-wide set of rules Many processors say they’re designed to move the food supply chain to improve over the next 50 years. Such on target for FSMA changes generally take a generation to effectively implement. Current deadlines for ‘full implementation’ are un- realistic.” With that backdrop, perhaps he fact that the Food Safety Modernization these are reasonable compliance rates. Act (FSMA) has been one of the biggest is- Ryan’s comments on the complexity Food Safety Insights is a sues for food processors in decades should of the supply chain were also echoed not be a surprise for anyone who reads Food in our latest survey. In the comments collaboration between Safety Magazine. FSMA has been called “the we received, it was clear that the supply chain presents the most pressing issues. Food Safety Magazine Tbiggest overhaul of the food safety laws in the U.S. in more than 70 years”; we believe that we will not get This was also reflected in our second and the food safety any arguments if we say that it has lived up to this question, where more than 20 percent claim. of the respondents in the U.S. and market experts at We checked in again with processors to find out Canada, with almost three times the more about how FSMA compliance has affected their mentions of the second most frequent Strategic Consulting Inc. operations, costs, and the biggest issues they say that answer, reported that issues related to they still face. We received answers from 280 proces- supplier compliance, or more specifical- to bring you the latest sors from around the world across a wide variety of ly Foreign Supplier Verification Program processing categories including protein, dairy, fruits (FSVP) compliance, were their area market research, insights, and vegetables, baking, processed foods, and confec- of top concern (Figure 1). Processors and trends in food tionary, including 224 processors from the U.S. and frequently offered comments about get- Canada, and another 56 from outside North America. ting their supply chain in compliance, safety, analytical testing, The first question we asked was “Do you consider saying, “We work with facilities all over your facility to be in compliance with FSMA?” For the world and many are still working diagnostics, laboratory processors in the U.S. and Canada, approximately 70 to understand their requirements and percent reported that they are confident that they are responsibilities and what they need to services, sanitation, and indeed in compliance with FSMA, with only about do…” and “We are still working with 3 percent reporting that they are not, and just under our supply chain partners to get them related topics in quality 27 percent said that they are still “working on it.” For trained in FSMA.” processors outside the U.S. and Canada, slightly more With the complexity and globaliza- and safety testing, and than 51 percent reported that they are confident that tion of most companies’ supply chains, assurance in the food they are in compliance, 15 percent reporting that they this task of supply chain control can be are not, and about 34 percent said they are also “work- overwhelming. This can be especially and beverage industry. ing on it.” true for smaller companies with more At first glance, perhaps it is surprising that only limited resources but nonetheless with

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29.1% of the respondents said they did not track their FSMA compliance costs. To Supplier Compliance/FSVP Food Fraud be fair, almost everyone who responded Documentation Training cited different investments that they Plan Development Sanitation had to make. Many cited one or more Allergens Environmental Monitoring employees who were hired solely for FSMA compliance activities, while others cited specific costs paid to training providers or consultants. Few, however, reported that they had a full accounting 10.8% 10.8% of their compliance costs. One person, who identified themselves as being in a 9.0% 8.5% 8.5% 7.6% corporate management function, may have captured some of the reasoning 5.4% behind these answers best when they added, “…It’s mandatory and not worth tracking costs.” 35.3% Figure 1. Top FSMA Issues: U.S./Canada (% of respondents indicating a top concern) a supply chain that still spans the globe. compliance as a supplier to FSMA-regu- <$20,000 One comment that we think will sound lated companies and that the companies $20,000–$50,000 very familiar to many was “…dealing meant that program, training, documen- $50,000–$100,00 with the supplier preventive control has tation, and similar compliance issues $100,000–$200,000 been especially difficult given our small were really their single top concern, and >$200,000 23.5% QA team and our large numbers of pre- these together outnumbered any other pared products.” concerns by better than two to one. Some of this is also reflected in the We also wanted to know more about answers we received from international the estimated costs of FSMA compli- 17.6% processors and suppliers. Although the ance. Prior to the survey, we had expect- number one issue that they cited (Figure ed that this would be a provocative is- 2) was allergen control, the next three sue, especially considering the financial 11.8% 11.8% most frequently cited issues were train- impact—in addition to the operational ing, documentation, and supplier com- impact—that FSMA must have on most pliance. It was clear from the comments processors. We have to say we were sur- that these concerns referred to their prised, however, when about 85 percent 19.6% Allergens 17.9% Training Figure 3. Has your facility tracked your investment in FSMA compliance? Of those 16.1% 16.1% Documentation responding yes, breakdown by investment 14.3% Supplier Compliance in U.S. dollars is shown (% of respondents Food Fraud indicating a top concern). Validation Of the 15 percent who did report Sanitation that they tracked costs, roughly 60 8.9% percent said their costs were less than $50,000, about 18 percent had costs between $50,000 and $100,000, and the remainder had costs greater than 5.4% $100,000 (Figure 3). While this small sample size makes it difficult to draw too many conclusions, a qualitative review of the responses indicates more of a direct correlation between a com- Figure 2. Top FSMA Issues: Rest of World (% of respondents indicating a top concern) pany’s size and (continued on page 66)

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dence but with ease as well. It has allowed the company to incorporate PCR into the Meeting the Need for Accurate microbiological methods used in the laboratory with assurance and efficiency. These products are based on the fast, Cannabis Microbial Testing sensitive, and proven technology of real- time PCR. The kit is intended for detect- ing Salmonella spp. and pathogenic E. coli in a large variety of food products. annabis is increasingly becoming legal at the state level in The kit uses an optimized system of prim- the U.S., for medical or recreational use. A central question is ers and probes to ensure high specific- how to ensure the safety of a new product that is not covered ity and eliminate cross-reactions. It is C under any existing federal safety guidelines. In the designed as a multiplex reaction that absence of such guidance, regulators in each state includes an internal amplification control have produced a unique set of rules and regulations that is co-amplified in parallel with the (if they have produced any at all) that are not typi- target DNA for a reliable result. The iQ- cally grounded in scientific research. The major safety Check protocol has been validated by threats to Cannabis products are bacterial pathogens several certification bodies. These valida- such as Salmonella and Shiga toxin-producing Esch- tion studies have shown that the kit is erichia coli (STEC), fungal and bacterial spores, and equivalent to or better than the various toxins. reference methods evaluated and pro- As a pioneer in Cannabis science, CW Analytical vides results in much less time. was one of the first laboratories of its kind to serve the Cannabis industry and tackle this lack of regula- A Perfect Partnership tory testing guidelines. The company was cofounded in 2009 by two When asked to describe the benefits scientists who noticed that the Cannabis industry in California was of using Bio-Rad’s products, Emily Sav- lacking the regulatory and quality assurance practices necessary to age, laboratory manager at CW Analytical, ensure the availability of clean, safe Cannabis products. CW Analyti- states that the products are easy to use, cal’s team of scientists and experts has been providing stakeholders the developed protocols are sufficiently in California with important information about the safety, quality, straightforward such that many indi- and potency of Cannabis products long before any state mandate. viduals can be easily trained to perform The company’s commitment to continuous innovation and technical them, the products are rapid and have development has led to the achievement of ISO/IEC 17025:2005 ac- incorporated accurate assays, and gold creditation, collaborative research, and the procurement of state-of- standard microbiological methodologies the-art analytical instruments to keep CW Analytical and their clients are utilized. She notes that Bio-Rad also at the forefront of regulatory compliance. provides excellent customer service. CW Analytical’s continued success is due to its commitment to pro- “Bio-Rad has provided excellent cus- viding clients with accurate, affordable data paired with unrivaled customer service with us throughout the tomer service. The company’s mission is to enable clients to better serve entire process. The training provided its customers and compete in the Cannabis marketplace with the safest, after we purchased the instrument was cleanest, and most consistent Cannabis products in California. extremely helpful. Since then, all of our When considering its testing needs, CW Analytical evaluated the interactions with Bio-Rad have remained California Cannabis requirements as well as additional quality as- positive. The assays we utilize in our surance measures it felt important to offer in the industry. As the laboratory are effective and streamlined company was utilizing culture-based methods for all Salmonella and into our routine laboratory workflow with STEC screening, it soon realized that a faster, validated method was ease. Lastly, we have fostered a mutually needed. The company decided to partner with Bio-Rad after evaluat- beneficial and collaborative relationship ing different pathogen detection options based on their utilization of with Bio-Rad that is appreciated by all at microbiological methodology (i.e., pre-enrichment for screening of CW Analytical.” pathogens), ease of use and throughput potential in the routine labo- As molecular methods for pathogen ratory, cost, and publication of validated methods. Bio-Rad products detection continue to improve, emerging fit all of these criteria for choosing a system to detectSalmonella and pathogens are being described around STEC in a routine laboratory. the world in molecular terms. The use of real-time PCR methods has the benefit of Taking the Lead automation, high sensitivity, high preci- Bio-Rad has taken a strong lead in pathogen testing, providing their sion, and accuracy, plus the flexibility to full portfolio of detection systems, including commercial PCR kits (iQ- simultaneously test for more than one Check) and instrumentation which can provide results in 24 hours. pathogen. With these advantages, CW CW Analytical currently uses the iQ-Check Salmonella II and STEC Analytical can offer better laboratory ser- VirX PCR kits, CFX96 Touch Deep Well thermal cycler, and CFX Manager vices to the Cannabis industry. IDE software to screen for Salmonella and STEC with not only confi- www.bio-rad.com/foodscience

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ment with each assay. These matrices ® included skim milk powder, bouillon BAX System Real-Time PCR powder with Mediterranean herbs, black tea, and cocoa powder. The inclusivity and exclusivity results Assay for Salmonella Excels in showed that the BAX system was one of three real-time Salmonella PCR kits that could not only correctly identify 49 Challenging Food Matrices Salmonella strains (from 39 serotypes) but also rule out 29 non-Salmonella strains. The remaining four systems had false positive rates of 3.1 to 15.6 percent. Even a small false-positive rate can mean olymerase chain reaction (PCR), a trusted molecular method in that invaluable time, labor, and other academia and industrial applications, has become a workhorse resources (including halting a food sup- for food safety service labs and even in processing facilities to ply line) can be wasted in an effort to Pdetect foodborne pathogens. Its popularity should be of no surprise: eradicate a nonexistent pathogen. It’s accurate, fast, and easy to use. Data from Difficult Matrices PCR’s excellent While all methods compared returned performance has made similar values for the limit of detection in it a valuable tool in milk powder and bouillon powder, the the markets that have BAX system demonstrated a limit of de- adopted it; however, not tection of less than one colony-forming all instrumentation is unit of Salmonella in 25 g of black tea alike, and the commer- and cocoa powder without inhibition. cial assays that are avail- These two food matrices mainly contain able can vary in quality polyphenols, known to be inhibitory for and design. Only a few PCR. commercial assays are Certain matrices are considered dif- truly capable of ruling ficult because they can contain food con- out nontarget organisms stituents or environmental compounds and performing across a that inhibit PCR. Such inhibition is a com- range of food matrices that can challenge molecular methods. Prov- mon reason for PCR failure, assuming ing that capability eludes nearly all but a select group of commercial an adequate number of DNA copies are instruments and tests. present. The BAX system has features such AFNOR Certification as internal amplification controls that The BAX® System Real-Time PCR Assay for Salmonella has been can verify that inhibition did not occur, certified according to International Organization for Standardization which other RT-PCR systems may lack. (ISO) 16140-2 (which specifies the technical protocol for validating In addition, it can detect Escherichia coli alternative methods of microbiological testing in the food chain) by O157:H7 specifically (not a range of non- AFNOR, a France-based European ISO certification organization that H7 strains), reducing the potential for the is widely recognized for the accreditation of food safety detection false identification of H7. methods, for the ability to both detect Salmonella spp. in all human foods, including dairy (except powdered milk) and chocolate food Conclusion categories, and to work with a shortened enrichment protocol for The BAX System Real-Time Salmo- raw meats and seafood. This certification also includes pet food nella Assay has been shown to accurately and production environmental samples (except primary production detect Salmonella spp., even in matrices environment). The real-time Salmonella assay is one of 10 existing that contain inhibitory compounds as BAX system assays (for real-time and traditional endpoint PCR) to be tested in this third-party-led study. Many certified by AFNOR. of these substances are naturally present in foods and can negatively impact Comparative Study Demonstrates Superior Performance PCR results. Therefore, choosing the right A study conducted by the Nestlé Research Centre and the Uni- assay that can identify pathogens in a versity of Zurich helps bolster the qualifications of the BAX system to variety of matrix types is essential for deliver accurate results, even in difficult matrices. The comparative maintaining microbiological standards for study evaluated seven commercial PCR assays for Salmonella with the food industry. regards to inclusivity, exclusivity, and limits of detection. To determine the limits of detection, four food products known to cause PCR inhibition were inoculated at various levels and tested after enrich- www.hygiena.com/foodsafety

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® medium. Discrete aliquots are separately SimPlate , an Improved compartmentalized from each other in the 84 incubation wells of the device, where metabolism of viable microorgan- Counting Method isms is monitored in a liquid environment. Microorganisms are enumerated by counting the number of positive wells in the SimPlate device exhibiting a color ngoing occurrences of foodborne illness and spoilage have change (positive well) after incubation. heightened the awareness of food microbiology, particularly Simply note the background color (me- the need for rapid bacteriological tests. Total plate count dium + sample = background color) O(TPC) and yeast and mold are among the most frequently conducted prior to incubation. All wells that result in microbiology tests for quality as- a color change different from the back- surance, as the presence of these ground color are considered positive. For organisms reflects the quality of raw example, if there are seven positive wells, product and processing, handling, refer to the SimPlate Conversion Table and storage conditions. which shows that seven positive wells There is a recognized need for equals a population of 14. To determine more rapid enumeration systems for the number of total organisms, multiply these organisms that allow faster re- the population by the dilution factor. sponse times to potential food qual- The unique design of the SimPlate ity or food safety problems. Current device provides a counting range of 738 standard methods require 48- to 72- CFU vs. 300 bacteria or 150 fungi on hour incubation periods for TPC and traditional agar plates. This is more than 5–7 days for yeast and mold before double the counting range of agar meth- results are available. These methods ods. As a result, the number of dilutions come with inherent problems such and reruns caused by uncountable plates as overgrowth of bacterial colonies, is minimized, saving labor, time, and ma- making it difficult and often impossi- terial costs. ble to determine an accurate number of colony-forming units (CFU). Faster Time-to-Results Another key advantage of the Sim- Extensively Validated Plate system is faster result time. Sim- The SimPlate system from MilliporeSigma was developed to over- Plate YM-CI produces results in 56–72 come these limitations. Three assays from the SimPlate family are hours compared with 5 days required approved as AOAC Official Methods of Analysis: SimPlate for Yeast by traditional plating methods. Results and Mold Color Indicator (YM-CI: AOAC Official Method 2002.11), from SimPlate TPC-CI are available in 24 SimPlate for Total Plate Count-CI (TPC-CI; AOAC Official Method hours, while other methods require 48 2002.07), and SimPlate for Coliforms and E. coli (CEC-CI; AOAC Of- hours. Faster result time means faster ficial Method 2005.03). Both YM-CI and TPC-CI assays are also vali- response time to food quality or safety dated by MicroVal in accordance with ISO 16140. These tests offer a issues and allows products to be released validated solution for faster results without the inherent limitations of sooner, thus saving time and money. plating. The SimPlate family also includes tests SimPlate TPC-CI was extensively validated in a methods compari- for Campylobacter and Enterobacteria- son study conducted among 19 laboratories representing govern- ceae. For use with difficult matrices, there ments as well as private industry in Europe and North America. It are SimPlate media available for TPC and was validated against both BAM and ISO reference culture methods. yeast and mold, which use a fluorescent Results demonstrated that TPC-CI was equivalent to both culture media for enumeration. This method al- methods. Similarly, SimPlate YM-CI was validated in a methods com- lows for detection in matrices that are parison study and a collaborative study conducted among 17 labo- highly colored or dark products with a ratories. It was also validated against both BAM and ISO reference 366-nm UV light. culture methods and found to be equivalent to both. For all laboratories that routinely need a robust and easy-to-use quantita- Easy to Use tive method for quality assurance, the The SimPlate system consists of a patented SimPlate device and SimPlate system provides an easy-to-use, proprietary media. The system uses a proprietary detection method extensively validated, and robust method based on Binary Detection Technology™ (BDT). BDT is a unique for rapid enumeration. method for quantifying bacterial load. With the device, foodborne For more information, please visit microorganisms are suspended in a nutritionally defined growth sigmaaldrich.com www.sigmaaldrich.com

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Want to bring your HACCP and hygiene monitoring program to the next level? The MVP ICON® System is the solution to your hygiene and sanitation management needs.

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© 2018 Merck KGaA, Darmstadt, Germany and/or its affiliates. All Rights Reserved. MilliporeSigma, the vibrant M and MVP ICON are trademarks of Merck KGaA,Darmstadt, Germany or its affiliates. All other trademarks are the property of their respective owners. Detailed information on trademarks is available via publicly accessible resources.

The life science business of Merck KGaA, Darmstadt, Germany operates as MilliporeSigma in the U.S. and Canada.

FSM101118pg31-45Final.indd 37 10/3/18 3:45 PM FOOD SAFETY INSIDER: RAPID MICRO SOLUTIONS

Topper. “In under 60 minutes, an opera- ™ tor will be able to analyze a sample and Neogen’s Listeria Right Now quickly make the decision to hold or quarantine product, reclean an area, or move forward with production. Using Earns AOAC Approval, CFIA Listeria Right Now also means that companies no longer have to be concerned Innovation Award about the growth of potentially dangerous organisms in their facilities during the testing process, or store test cultures for potential follow-up testing.” After internal testing proved its ef- ne year after being launched to a skeptical food safety testing fectiveness, Neogen requested that NSF community, Neogen’s innovative 1-hour sample-to-results International perform an independent test for Listeria is gaining increasing usage and third-party validation study to evaluate the perfor- Oaccolades. mance of the Listeria Right Now assay for Neogen’s Listeria Right detection of Listeria spp. in environmen- Now™ test system detects tal swabs without enrichment. Listeria in environmental In the NSF study, surfaces of 4” x 4” samples in under 60 min- squares of food-grade stainless steel utes—with molecular-level were inoculated with different levels of accuracy and without the L. monocytogenes and a consortium of need to enrich samples. competing organisms, including Pseudo- In August 2018, the sys- monas aeruginosa, Bacillus subtilis, and tem’s accurate performance Enterococcus faecium. After allowing the was validated by the AOAC inoculum to partially dry, surface samples (license number #081802). were collected using semi-paired swabs. The AOAC’s approval fol- One swab was tested by the Listeria Right lowed the system’s earning Now assay, and the other swab was en- the 2018 CFIA innovation riched by the culture method. The swab trophy. The CFIA (Carrefour for the culture method was enriched des Fournisseurs de l’Industrie Agroalimentaire) is an annual agro- overnight at 37 °C in growth medium and food industry supplier fair that showcases the latest developments in an aliquot plated onto agar plates for de- food industry technology. Prior to its launch, the effectiveness of the tection on the following day. Listeria Right Now system was demonstrated by NSF International. In the Listeria Right Now test, the en- “This past year, we showed that the Listeria Right Now test sys- tire collected contents of the swab were tem enables food safety professionals to implement an immediate subjected to sample processing and test- remedial action, which could include improving sanitation efforts or ing on the same day. After expression of processes. It allows our customers to adopt the ‘seek and destroy’ the swab in the lysis buffer, one-half of approach to Listeria detection that the U.S. Food and Drug Admin- the volume was taken for the lysis incu- istration, the U.S. Department of Agriculture, and many auditors are bation steps. Next, a portion of the lysed promoting. We’ve heard customers also describe it as being ‘like ATP sample was transferred to a strip tube testing for Listeria,’” says Neogen’s James Topper. “The advanced containing lyophilized reagents. The tubes technology in Listeria Right Now truly has changed everything about were sealed and incubated at 56 °C in testing the environment for Listeria. Contamination of Listeria in the the Neogen reader. Results generated by environment can now be determined, and in the case of a positive, the reader were displayed in the assay’s recleaned or remediated as necessary, before food production begins software. and the quality and safety of a food product is compromised.” No false negatives, false positives, or Neogen’s test system detects all species of Listeria, including the invalids were observed during this study. pathogenic Listeria monocytogenes, in under 60 minutes through The evaluation determined that under the their ribosomal RNA (rRNA). The system’s effectiveness has been conditions employed in this study, the en- shown to detect low levels of Listeria in environmental samples with richment-free Listeria Right Now method greater sensitivity and speed than any other method available. is as sensitive as the enrichment-based The Listeria Right Now process starts with taking an environmen- culture reference method for detection tal sample to capture any Listeria present. The entire swab sample is of L. monocytogenes on a stainless steel placed in a tube that contains a lysis buffer that breaks up any bacte- surface. ria present and releases its rRNA. If Listeria is in the sample, the test’s For a copy of the NSF study or details reagents will amplify thousands of copies of its DNA—and make the on the assay, or specifics on the AOAC ap- Listeria easily detectable by the Listeria Right Now assay. proval, please contact Neogen. “Because of the ease of use of the new test system, facilities will

www.neogen.com be able to enhance their environmental monitoring programs,” says

38 F o o d S a f e t y M a g a z i n e

FSM101118pg31-45Final.indd 38 10/3/18 9:25 AM Find Listeria Faster with Listeria Right Now™

Listeria Right Now is an enrichment-free environmental monitoring tool 2018 Innovation that detects 6 spp. of Listeria in less than 60 minutes. Award Winner • Conduct investigations in near real-time after positives • Seek and destroy Listeria before it creates a problem • Works on many surface types To learn more, visit: foodsafety.neogen.com/en/listeria-right-now

800-234-5333 (USA/Canada) • 517-372-9200 • [email protected] foodsafety.neogen.com LICENSE NUMBER 081802

FSM101118pg31-45Final.indd 39 10/3/18 3:43 PM FOOD SAFETY INSIDER: RAPID MICRO SOLUTIONS

How the Colisure Test Works Colisure® also detects coliforms and Effortless Water Testing for E. coli but with the convenience of a long-read window and a definitive color change for both positive and negative Coliforms and Escherichia coli results. A distinct magenta color means ® ® there’s no mistaking a positive result. with Colilert and Colisure Results are definitive at 24 hours with a read window that lasts up to 48 hours and can be used for presence/absence or quantification testing with Quanti-Tray. olilert® is a one-step method for water quality and compliance “This technology is truly the gold stan- testing, giving results for total coliform and Escherichia coli in dard of rapid coliform in water testing,” 18 or 24 hours with less than 1 minute of hands-on time. Coli- according to Sharon Wilson, Weber Sci- Clert has a full range of regulatory approvals and has become the per- entific’s vice president of marketing and fect test for a wide variety of source water product development. The Colisure test applications, including required regulatory uses proprietary DST nutrient indicators compliance testing, bottled water testing, CPRG and MUG to detect total coliforms and for fresh-cut produce or fruit rinse wa- and E. coli. ter (before or after processing). Approvals and recognitions include: Automated Water Sample Handling • FDA/NCIMS/PMO for total coliform for for Coliform and E. coli Quantification plant and farm source waters; recog- The Quanti-Tray Sealer PLUS is the nized for use by certified milk laborato- next-generation sealer in the Quanti-Tray ries for negative and positive confirma- system. The sealer makes quantification tion for total coliform testing with Quanti-Tray and Quanti-Tray/2000 • USEPA, AOAC, and IBWA approved for possible while saving time and improving total coliforms and E. coli laboratory efficiency. • Accepted by APHA Standard Methods for the Examination of Wa- With Quanti-Tray, a 100-mL sample ter and Wastewater for total coliforms and E. coli is divided into 51 wells. Then the most- Colilert is pre-measured, unit dosed, and ready to use with clear, probable-number approach is used to easy-to-read colorimetric results. It detects a single viable coliform determine the number of bacteria in the or E. coli per sample. The sample collection, incubation, and reading original sample. Automation minimizes can all be done in the same vessel. Colilert can be used as a pres- hands-on time and maximizes through- ence/absence test for total coliforms and to specifically identify the put (up to four samples per minute). The presence or absence of E. coli through fluorescence with definitive relatively large number of wells provides results in 24–28 hours. Quanti-Tray® can be used for the added a high counting range of 1–200 (without benefit of quantification of results. An 18-hour version allows the dilutions) and very tight 95 percent confi- user to read afternoon samples the next morning—before the next dence limits. day’s samples arrive. “I’m thrilled to learn about this test!” is the most The Quanti-Tray/2000 is based on the common comment from new Colilert users, reports Weber Scientific same statistical model as the traditional sales manager Asif Rahman. 15-tube serial dilution. With the Quanti- Tray/2000, the sample is automatically How Colilert Works divided into the proper portions when The Colilert test uses proprietary Defined Substrate Technol- sealed by the Quanti-Tray Sealer PLUS. ogy (DST) to simultaneously detect total coliforms and E. coli. Two The system does not require the use of nutrient-indicators, ONPG and MUG, are the major sources of car- test tubes, Durham tubes, or any dilu- bon in Colilert and can be metabolized by the coliform enzyme tions. By automatically distributing the β-galactosidase and the E. coli enzyme β-glucuronidase, respectively. sample into 97 wells of two different As coliforms grow in the Colilert test, they use β-galactosidase to sizes, Quanti-Tray/2000 yields a counting metabolize ONPG and change the water color from colorless to range of 1–2,419 CFU/100 mL with a far yellow. E. coli use β-glucuronidase to metabolize MUG and create better 95 percent confidence limit than a fluorescence. Since most noncoliforms do not have these enzymes, 15-tube serial dilution. they are unable to grow and interfere. The few noncoliforms that do Weber Scientific is an authorized dis- have these enzymes are selectively suppressed by the Colilert test’s tributor of IDEXX products to the food specifically formulated matrix. and beverage industries in the U.S. and This approach is different from traditional media, which provide Canada. a nutrient-rich environment that supports the growth of both target organisms and nontargets. When nontargets grow and mimic target organisms, false positives occur. Growth of nontargets can also sup-

www.weberscientific.com press target organisms and give false negatives in traditional media.

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Testing for pathogens has been streamlined from the days when only Reduce Risk and Improve highly trained microbiologists could administer such tests. Rapid pathogen methods can now be run effectively by Efficiency with In-House team members with differing functions and various levels of scientific training. Environmental Monitoring There are many rapid pathogen detection methods available on the market. They vary in what they detect, time-to-results, number of steps, equipment needed to run the assay or interpret the result, lobalization of the food supply, changing consumer trends, and cost. Critical actions are taken in new regulatory requirements, and increased media attention response to test results, so the method are changing the way we think about food safety. Consumers a food manufacturer chooses must be Gare more aware of where their food comes from and are demanding robust, reliable, and fast. manufacturers produce products free from antibiotics, preservatives, Think about your current EMP and and additional additives. Consumers’ eating habits are changing, pathogen detection method. Ask your- and convenient ready-to-eat options are in demand. Consumers self: Is it efficient? How many steps are with healthy eating goals have begun actively to choose organic and there? How long do I have to wait? What gluten-free foods. In light of the increasing prevalence of food aller- impact does my EMP have on day-to-day gies, food manufacturers are under the magnifying glass to improve production efficiencies? With Romer Labs their allergen control and labeling programs. Highly publicized food RapidChek, there is no need for any extra recalls are putting more intense pressure on food manufacturers to equipment to interpret the results and streamline and secure their food safety procedures. therefore no need for substantial invest- This increased scrutiny has resulted in a shift in how food manu- ment. With our latest, all-in-one sam- facturers look at their food safety systems. The implementation of the pling device combined with pre-made U.S. Food and Drug Administration’s Food Safety Modernization Act RapidChek Listeria NextDay™ enrichment (FSMA) is changing the mindset to a preventive approach. This act media and lateral flow device, samples identifies three specific preventive controls, or PCs (allergen controls, taken at the processing plant require supplier verification, and sanitation) that together are intended to very little hands-on time in the labora- support other prerequisite programs and Good Manufacturing Prac- tory. Samples arrive and are immediately tices already in place to prevent contamination. placed into the incubator and tested after 24 hours of enrichment. The test time Pathogen Growth Niches: Seek and Destroy is only 10 minutes. This means acceler- Sanitation, one of the PCs required by FSMA, is critical in prevent- ated time-to-results and reduced waiting ing both biological and chemical contaminants. These contaminants times. With RapidChek, results can be can vary widely from chemicals (e.g., food allergens) to biological obtained faster and corrective actions can organisms (including pathogens, viruses, and parasites). The best be taken sooner to prevent pathogens Sanitation Standard Operating Procedures (SSOPs) include a recom- from making their way into the product: mended schedule for cleaning and sanitizing based on the design of This is how RapidChek can help you the equipment, the degree of product exposure during postlethal- reach your EMP goals and improve pro- ity handling, and the history of pathogens/allergens on a particular duction efficiencies. production line. How then do processors know if their SSOPs are Don’t overcomplicate this decision. effective? The answer is simple: by monitoring their processing envi- Get reliable results using the most ef- ronment (also known as environmental monitoring). fective method on the market. Simplify The processing environment is particularly susceptible to food environmental testing with RapidChek pathogens, making pathogen testing a crucial component of any by Romer Labs. Our lateral flow-based environmental monitoring program (EMP). Gone are the days when methods for Listeria and Salmonella manufacturers perform only finished product testing. EMPs allow a provide a rapid, reliable, and streamlined food manufacturer to find pathogen growth niches in the produc- workflow to perform environmental tion area and take action to eliminate risk before the food becomes testing without incurring a significant in- contaminated (i.e., “seek and destroy”). Testing for pathogens within crease in cost. Hundreds of samples can the processing environment provides vital information on areas that be tested in a single day without delays need extra attention. Quick corrective actions result in a safer pro- due to batch requirements on equip- duction environment, the ultimate goal of an effective EMP. ment-based methods. A state-of-the-art EMP is attainable. Take a moment to Effective, Efficient Listeria and Salmonella Control with Romer make your life easier and contact Romer Labs® RapidChek® Labs. www.romerlabs.com

42 F o o d S a f e t y M a g a z i n e

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Naturally ahead

FSM101118pg31-45Final.indd 43 10/3/18 9:25 AM FOOD SAFETY INSIDER: RAPID SOLUTIONS

possible. By specializing in food allergens, the company can offer rapid turnaround Allergen HACCP Program times, including same-day analysis, at no extra cost. Clients receive Certificates of Analysis for each sample as well as Case Study complete data reduction.

Partnering with You to Find the Best Solutions The Problem With so many ingredient, flavor, and The prevalence of allergic diseases in the industrialized world preservative combinations possible, has been on the rise for the last 50 years, according to the American food matrices can be very complex. Bia Academy of Allergy, Asthma & Immunology. The U.S. Centers for Diagnostics works closely with your team Disease Control and Prevention states that food allergies are a to develop a customized plan to meet growing food safety and public health concern that affects an your specific testing needs. This can estimated 4–6 percent of children in the United include evaluation and validation of the States. Coupled with the finalization of the Food method with each specific matrix that the Safety Modernization Act, monitoring of food safety assay would encounter in your facility, systems is more critical now than ever. thus ensuring the most accurate results In food manufacturing, cross-contamination and avoiding costly recalls. can be a major problem, especially for contract manufacturers who often have a wide variety of At the Service of Our Customers and allergens on-site. Most companies have tight control the Scientific Community of their ingredients, but even the best allergen Customer service is the keystone of Hazard Analysis and Critical Control Points (HACCP) Bia Diagnostics’s corporate mission. To program can’t eliminate all possible risk factors. that end, the company prides itself on providing fast and reliable responses The Investigation to client needs, including unparalleled A customer has an excellent allergen HACCP program in place service and the development of personal and regularly swabs equipment after cleaning, sending samples to relationships with all customers, third-party-certified labs for verification of their cleaning program as regardless of size. well as sending their final products for analysis. On one occasion, Bia Diagnostics strives to be a this customer was getting sporadic positives for total milk protein caring and active member of the in a batch of supposedly “milk-free” product. Working with the scientific community by conducting manufacturer, we developed a relevant sampling plan, and by independent and collaborative research scaling up the sample size of each analytical test portion, we were to further the understanding of food able to reduce the total number of analyses they had to perform allergen safety and of the community. to determine the extent and location of the contamination, By authoring scientific papers and while confirming the results with two different enzyme-linked presenting at scientific conferences such immunosorbent assay methods. as AOAC International, International Food Technology Association, and the The Results American Association of Cereal Chemists, Once the affected bags of product were identified, we helped Bia works each day to develop innovative the customer rule out various sources of the contamination and tools to help food manufacturers produce performed testing to determine that it was due to the transport of the safest products for even the most open containers of raw materials through areas close to where milk allergen-sensitive consumers. powder had been used in production. In the end, the offending bags And now, Bia Diagnostics has added were isolated and the remaining uncontaminated bags were able to real-time PCR testing for food authenticity be salvaged, saving the company thousands of dollars in unnecessary and detection of genetically modified waste. organisms to the services offered. The company is available to assist all The Expedited Expertise You Need organizations with their HACCP plans Bia Diagnostics is available to assist all organizations with their for food allergen screening and label HACCP plans for food allergen screening and label verification. Bia verification. Laboratory is ISO 17025 accredited and AOAC, Good Laboratory Practices, and Good Manufacturing Practices compliant. The company’s food diagnostics facility, located in beautiful Vermont, Bia Diagnostics brings over 50 years of laboratory experience and nearly 30 years of Leaders in Food Allergen Analysis food allergen testing expertise. Using state-of-the-art technologies Bia Diagnostics is your partner in in food analysis, Bia offers the most reliable, highest quality results product quality control! It is your lab! www.biadiagnostics.com

44 F o o d S a f e t y M a g a z i n e

FSM101118pg31-45Final.indd 44 10/3/18 9:25 AM Bia Diagnostics

LEADERS IN FOOD ALLERGEN ANALYSIS

We are your lab, working with you to create the highest standards of quality control for you and your company.

Now Offering real-time PCR for GMO and Species ID testing utilizing technology

Same Day Allergen Analysis We specialize in food allergen testing and provide testing for label verification of the following allergen proteins utilizing the most robust, up to date ELISA methodologies: • Gluten • Casein • Fish • Egg • Coconut • Shrimp • Soy • Hazelnut • Mollusks • Total Milk • Macadamia • Histamine • Peanut • Pecan • Pistachio • Almond • Sesame • Mustard ISO17025 Certified Laboratory • β-Lactoglobulin • Walnut • Cashew • Shellfish

BIA_FSM_AD_032017-06.indd 1 3/21/17 4:47 PM FSM101118pg31-45Final.indd 45 10/3/18 9:25 AM By Pam Young

ost food companies have been diligent in developing and implementing food safety plans to ensure compliance with the MFood Safety Modernization Act (FSMA). And yet, when talking to people working in various management positions in these companies, it is not uncommon to hear them express concern about whether their plans are adequate to protect them if a problem should arise. And while the level of stress and strain that people are feeling over the uncertainty of compliance may vary, individuals holding executive positions are eagerly looking for a greater sense of confidence that their companies are truly compliant with FSMA requirements. One area that seems to be causing a great amount of uneasiness is food transportation. The ink on the U.S. Food and Drug Administration (FDA)’s Sanitary Transpor- tation rule (STR) has long dried, and while the specific requirements have been defined and discussed in countless webinars and food safety trainings, it seems as though there continues to be confusion about what compliance with the rule should actually look like in practice. Now well into the second year after its publication, it is time to drill down on the issues that have become barriers to full, satisfactory compliance with the STR.

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FSM101118pg46-62,66Final.indd 46 10/3/18 9:32 AM Now in the Same Corner—Mutual Compliance A primary contributing factor to this lack of clarity seems to be that in its effort to ensure food is safe and secure throughout the supply chain, FDA has created a critical relationship between two industry groups that, while historically coexisting in typical business arm’s-length professional transac- tions, must now work much more closely together toward mutual FSMA compliance. One group regulated under the STR consists of food industry members that grow, store, load, process, ship, and/or receive foods that are dry, fresh, and/or require temperature control for food safety. The other group that is now responsible for compliance under the rule is the trucking companies that actually transport the food. These are typically owner-operators, which range from those having a fleet size of fewer than five tractors and trailers to large carriers with fleet sizes in the thousands using employee drivers. Previously, food companies needed their products transported, and they did not get involved in the actual process of transportation other than to select a carrier and make sure that pertinent pick-up and delivery information was properly dispatched. FSMA compliance now essentially requires food companies to become liable partners with their carriers. Members of the food industry know that their products need to move, but the details and nuances of how that transportation happens are typically managed by one group in their company: the logistics department. Today, over a year since the rule became enforceable, there are employees in these logistics roles who have

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little to no knowledge of the STR. that if they have signed a contract, that Many people have asked whether the rule is actually being enforced, and if so, alone is proof that they have adequately what should a company expect if and when it is asked to produce proof of compli- complied with the rule. Actual compliance. While published reports of actual investigations relating specifically to the rule ance pieces, other than making sure are difficult to find, shippers and truck drivers have informally referred to instances their drivers have seen the 1-hour FDA when, during an inspection for FSMA or Department of Transportation (DOT) video, may or may not be written and compliance, an inspector informally asks questions specifically related to compli- implemented in their company’s safe ance with the STR. A closer look at enforcement is discussed later. food transportation plan. It seems that many carriers don’t The State of the Transportation Industry even have a food safety plan. In the transportation industry, knowledge of and compliance with the rule de- And worse for food companies, par- pend on the character of the company. Carriers that identify themselves as progres- ticularly shippers, if they do not have sive and/or innovative are typically the companies that have participated in a food a contract in place with a carrier or safety training, know the rule and its requirements, and have protocols that align haven’t implemented a safe food trans- with the rule’s requirements. But only about 25 percent of the largest fleets in the portation plan, the chances are real that nation would be part of this “progressive” group. the carriers supplying their company Many of these are contracted carriers for some of the largest foodservice, retail, with transportation for its food products and wholesale companies. Driving through fresh produce-growing regions, such as may not have any idea that the STR ex- California’s Salinas Valley, one can find quite a few of these fleets loading or wait- ists and that legally they are responsible ing for a pickup at a shipper’s facility that supplies these food companies. Often, for compliance (see “A ‘How-To’ Carrier when asked why compliance is not a priority within their organization, a carrier’s A “How-To” Carrier Guide response is that “no one,” meaning their customers, is requiring compliance yet. for a Food Safety Plan What does a carrier mean when it says While putting a food safety plan in place is necessary, it does not need to be no one is “requiring” it to comply with the complicated but does need to be completed. It does not need to be perfect, but it should STR? be a work in progress and will change as you start implementing your procedures. It will Typically this comment refers to a con- need to be prepared and performed. “Prepared” refers to the procedures that are planned tractual obligation with which a carrier has out, written with achievable outcomes, and focused on preventing problems that happen agreed as part of its transportation con- in transportation. “Performed” refers to the actual implementation of your plan. Build in tract. When the rule was first published methods, including documentation, that ensure that your employees and your company and food shippers began to understand partners (customers, suppliers) are able to consistently and completely comply. that FDA had placed primary responsibil- Here are three simple steps to start: ity for specifying food safety protocols 1. Assign a person to supervise and manage the process. This is the Competent on them, they contractually shifted the Supervisory Person (CSP) required in Section 1.908(a)(2) of the STR who should be burden for compliance onto the carriers’ skilled, knowledgeable, and experienced in all relevant areas like food safety and backs. In many cases, food safety person- transportation. nel relied on the company’s legal depart- 2. Make a bucket list. The “buckets” will help organize all the responsibilities required ment to create, via a contract, the compli- in the rule. Use the rule to make the buckets: CSP; Vehicles and Transportation ance required to meet FDA’s expectations. Equipment; Transportation Operations; Training; and Records. This shift was anticipated by FDA in 3. Under each bucket, start listing your company’s activities that fall into each group. the rule, as they made it clear that while Make a table or chart that can be helpful in knowing how your compliance is going the shipper knew best how to take care of and what you need to get done. In each group (e.g., Vehicles and Transportation its product, it was acceptable for the ship- Equipment), the rule has defined areas of responsibilities. Under each area, using per to specify how that should be done labels such as Doing, Not Doing, and To Do, write the activities that your company is and then require the carrier to bear the already doing and what you are missing: The latter becomes your To Do list, which shipper’s burden for FSMA compliance. should include dates and people responsible for making sure a task gets finished and The reality of the situation is that the moved to the Doing list. food companies that are depending on If you have signed a contract with a shipper or another party named in the rule for their food safety departments to ensure specific compliance requirements, those requirements become your bucket list. If and FDA compliance are assuming (or hop- when your customer asks for your compliance records to show you are meeting your ing) that this is happening on the basis of contractual obligations, your plan will be complete. contractual agreements. Unfortunately, Remember, cross your t’s and dot your i’s. It’s one thing to have a plan, but it is not these carriers are operating under a few of truly complete unless it is implemented. Your CSP is responsible for ensuring that the plan their own assumptions, such as the fact has moved from preparation to performance!

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Guide for a Food Safety Plan,” p. 48). Misunderstanding #1: The Rule Itself This apparent disconnect between Back in the early 1960s, Peggy Parish wrote a series of books for children about a the food and transportation industries is goofy housekeeper, Amelia Bedelia, who had a knack for misinterpreting common- a problem in that it exposes both groups sense instructions. Amelia managed to misconstrue tasks like planting lightbulbs in- to the risk of being noncompliant with stead of flower bulbs into clay pots and cutting holes in her boss’s dress when asked FSMA. to “remove the spots.” Interestingly enough, and somewhat similar to how people misunderstand the Achieving STR Compliance STR, Amelia routinely charged ahead down the wrong path without any misgivings One solution might be to dem- that something was amiss as a result of her actions. So too in the food and transpor- onstrate to the stakeholders in these tation industries, people are apparently confident in their choices related to food groups that they can each benefit from a mutually compliant alliance. This will help them see how their investment in the process will ultimately protect their companies from undesirable and poten- Wireless Monitoring! tially disastrous consequences that ac- company noncompliance with the STR. So, if a trucking company carries out HACCP Control Point its responsibilities under the rule, the Monitoring Via shipper and receiver who are depending on that carrier to pick up and deliver ● LAN the load both receive the benefit of the carrier’s compliance. Looking at it from ● Wi-Fi the shipper side, if a shipper, either in a ● Cellular written contract or in instructions stated on their bill of lading, requires a carrier to meet the shipper’s specifications, the carrier that fulfills those obligations will have also fulfilled its own compliance responsibilities. But merging interests alone will not ● Monitor Multiple Locations solve the overall compliance challenge. ● Walk-In Freezers and There is another issue that needs serious attention before the real work of Refrigerators meeting the STR’s requirements can get ● Automatic Record Keeping under way. At the core of this marginal compli- for HACCP Control Points ance lies some confusion about the ● E-Mail & Text Warnings rule so that not only do the parties lack significant appreciation for each other’s Without a PC roles under the STR, but there are also ● Reduce Waste & Spoilage some foundational questions about the rule’s requirements. Several of the “mis-” words that may apply in this situation may have slightly Data Loggers different meanings, but ultimately, they seem to end at the same place. Misinter- TANDD pretations, misunderstandings, and mis- from conceptions could all lead to misguided attempts at satisfactory compliance and perhaps even to costly mistakes. While this is not an exhaustive list of the misunderstandings at play, the following may be a few of the most signifi- TandD US, LLC. cant. [email protected] (518) 669-9227 www.tandd.com

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transportation. Some of these decisions are probably not what FDA envisioned as A simple approach to managing this “safe and secure,” and worse, these decisions may be contrary to what should make problem is to use the STR’s goal, con- sense. sistently stated throughout the text, as a Speaking of FDA, the writers of the STR intended that the rule be flexible and primary qualification in important deci- nonprescriptive. The reason for this method of rulemaking was that in the trans- sions. STR’s clear objective is to transportation segment of the supply chain, a vast number of companies grow or make port food in a way that does not make numerous types of products, and they need some flexibility to best move those the food unsafe. products as well as to accommodate the needs of their customers. Therefore, procedures regarding The rationale makes sense, but for the many companies that need to participate cleaning/sanitizing, preventing cross- in the supply chain to transport or receive product, there are that many different contamination, temperature control, interpretations of “safe and secure” transportation activities. Once the rule was pub- training, etc. all should have a “risk pre- lished and the reality of enforcement began, the questions ensued: What is “clean”? vention” evaluation process that serves Does our company’s “food” fall under this rule? Who is a shipper when there are as a guideline supporting the STR’s goal. more than two people involved in securing a truck to haul a load? What is a “mate- The procedures should be described and rial” deviation, and how will this affect cargo insurance? written into a company’s food safety STR Flight Plan The U.S. government has strict rules that govern planes, pilots, o Products are securely stowed with adequate numbers and and passengers. Anyone who travels via air knows that these correct positions of load locks Federal Aviation Administration rules are nonnegotiable. Just like air This is a critical food safety stage that is often compromised travel safety requires preparation and following a process, so too because a driver wants to get on the road. Many delivery problems must a driver navigate through the critical stages of food transport can be avoided or mitigated by careful attention to a checklist of by following a procedure that will help a carrier stay STR compliant. this type. These checklists are intended to be a guide only. Companies should work with their legal and food safety departments to develop Board-and-Go Stage: In-transit checklist checklists specific to their operations. Monitor and report o Deviations in prescribed temperature recordings in trailer to Reservation Stage: Pre-trip equipment status checklist specified food safety contact Trailer: Check that refrigeration unit, floor, walls, ceiling, doors, o Instructions given by shipper, receiver, or food safety contact and chute are regarding the temperature issue o Designed to properly haul the food described in the dispatch o Any delays that potentially threaten a scheduled delivery date o Inspected to ensure good condition (no holes, rips, tears) and/or time o Free of debris and odors, with completely clear floor grooves, a o Location updates if required and/or not available, other than refrigeration unit that has been tested and is working properly, driver communication and load locks that have been cleaned and made available o Any events that threaten the safety and/or security of the food before pickup begins product Plan for problems. In fact, a “Plan B” is critical to have in place o Problems with delivery appointment (discrepancy in purchase and practiced. Identify the person to contact and/or protocol to order, date, location, etc.) follow to engage the start of alternative compliance protocols. Arrival Stage: Destination and delivery checklist Security Stage: Pre-trip information and product status Confirm and/or document checklist o Load arrived as ordered per dispatch For food products, check that o BOLs are accurate and signed by the receiver (correct product o Compatibility is confirmed (temperature and ethylene sensitivity) count received) o Pickup and delivery purchase orders, locations, and times are o Correct temperature recording device is located and retrieved confirmed o Shipper is notified of delivery outcome: Either a “clean bill” or, if o Shipper’s precool specifications are confirmed and set a problem occurred, further instructions o Transit temperatures are specified on bills of lading (BOLs), Drivers should stay on-site until given a green light to leave, temp recording device locations noted on BOLs unless the shipper/dispatcher has communicated that “clean bills” o Transit temperatures are confirmed with a reliable pulp warrant permission to leave without further instructions. thermometer Documentation of these activities is like a boarding pass. An air o Product is segregated and protected from nonfood product passenger goes nowhere without one. The STR requires accurate o Cartons, boxes, packaging, etc. are confirmed in proper and thorough record keeping, and the ability to produce these condition (no tears, crushes, etc.) documents will prevent serious noncompliance issues. o Loading patterns are designed to maximize airflow

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transportation plan. have past cargo odors. In questions that are not “practice” Unless the carrier is contracted to wash out the trailer after every load or every related and more specific to a definition type of cargo, “clean” refers to making sure that visibly there is no dirt, substance, or in the rule, such as whether a company product/pallet pieces remaining on the floor or stuck to the walls. is in the shoes of a shipper, it is better Any bacterial material, invisible to the naked eye, could still be in the trailer. to assume that a company has a specific Washouts are not regulated, so some surfaces do not even get rinsed and at times can role. Write a protocol for that role rather be cross-contaminated because of the washout method used by a facility. than ignore the requirement. Definitely How does inadequate training affect the quality of a washout? Many companies have a company attorney review the tell their drivers to get washouts, but they do not necessarily give them instruc- food safety plan. tions on how a washout service provider should clean a trailer or how often a trailer

Misunderstanding #2: Best Practices Not only did FDA intend to incorporate flexibility into the STR, but it also relied on industry “best practices” to help provide the framework for transportation protocols and procedures. The assumption was that these accepted means of managing freight movement Protect and control are consistently incorporated and implemented by all parties specified in the your end-to-end rule, whether or not the practices are embodied in a written food safety plan. cold chain This too was a good idea, except that Temperature has one of the greatest impacts on food safety, in food transportation, a multi-faceted which makes cold chain safety paramount. Ensure food quality and historically ignored industry (in and safety from farm to fork, mitigate risks, and protect your relation to food safety rules), companies brand through our on-demand solutions and services. have been moving food products in patterns and with procedures that best accommodate their operations and customer needs. Safe food transportation Real-time temperature and product movement traceability may be a consideration but not always a priority. 24/7 proactive monitoring and response services The STR is activity-based, so FDA expects that stakeholders will know and Immediate cost savings and ROI actually practice these guidelines. How- ever, one of the criticisms of established best practices that has surfaced since the rule’s publication is that while they make sense on paper, the outcomes fall short when actually executed. This can happen because there is insufficient scientific support for the quality of a practice or because of inadequate training of the people responsible for understanding it. Here is an example that demonstrates both reasons. In regard to science, the STR requires transportation equipment to be “clean.” This means that when, for instance, a driver pulling a refrigerated trailer arrives Learn more or try a pilot. at a cooler, at a minimum, the trailer [email protected] — controlant.com should be free of debris and should not

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should be cleaned. held liable for actions of their employ- Many carriers that are hauling dry freight in a refrigerated trailer get a washout ees. only if they are contractually required to do so. Drivers and dispatchers tend to The question then becomes one of focus only on the type of prior cargo, which disregards other problems such as po- opportunity. What are some of the ways tential contamination from forklift wheels or loaders/lumpers who are moving in that FDA might investigate question- and out of a trailer without considering the cleanliness or sanitary condition of their able transportation practices? shoes. Coming from the produce trans- This “dirty” discussion will be broadened in the next section, but for now, it is portation industry, two common situ- important to use the “clean” equipment example as an area where best practices may ations, if improperly managed, could fall short of what the STR seeks to accomplish. lead to unwanted scrutiny. The first instance could happen with Misunderstanding #3: Focus on the Wrong Question a questionable delivery. This very topic As mentioned above, the issue of “clean and sanitary” may need some clarifica- could be lengthy and involved, so for tion. But this area is indicative of a larger potential point of contention that is fre- purposes of this article, it is probably quently raised during a discussion with both food and transportation industry mem- sufficient to say that it is a very short bers. A common objection from both sides is that there is not a published instance period before red flags start waving of a foodborne illness related to a food transportation incident. when a load arrives hot, cold, late, dam- The STR is designed to prevent practices that create food safety risks during trans- aged, and/or missing product. portation. The rule generally refers to types of risks, mostly in three areas, which are A second instance involves a DOT cleanliness of equipment, cross-contamination, and temperature abuse in foods that inspection. Carriers know that a small require temperature control to keep them safe. infraction can quickly roll into a seri- But outside the obvious risks such as visibly dirty trailers, extreme transit tem- ous problem. Something simple such peratures, or dangerous exposure of unprotected food to various sources, there is a as a malfunctioning light can attract very limited factual basis from which more substantive and thorough transportation the wrong kind of attention. In the rule practices can be defined and incorporated into food safety transportation rules. itself, FDA states (Response 19) that it Therefore, the question should be, “If there is a possibility of bacteria, an al- intends to follow up on DOT issues lergen, or even insects in a trailer due to prior cargo, an inadequate trailer washout, that suggest unsafe food transportation or because the doors of the trailer were left open for a time, what will we require to practices. ensure that this trailer is actually clean and sanitary?” The above question is specific to Section 1.906 in the STR, but the analysis and Sustainability and the Steps careful consideration of a company’s protocols and procedures are the same for each toward Compliance with STR section of the rule. A true best practice would be to encourage a company to ask the Driving along the foothills in the correct questions that apply to each section so that in the end, a company develops Salinas Valley, one sees signs posted at a reasonable and effective plan. the edges of the vineyards that say “SIP [Sustainability in Practice] Certified.” Misunderstanding #4: Risky Assumptions By being SIP certified, the growers and Amelia Bedelia seemed completely unaware of the potential consequences of her winemakers in this region have commit- actions, almost as though she was so certain that her choices were spot-on that she ted to a high level of business practices would ultimately be immune to unfortunate outcomes. Getting fired didn’t cross that ensure the best outcomes for their her mind, and some of her stunts were downright dangerous! people, their profits, and the land they It is interesting to talk to different company representatives from both the food depend on to produce quality wines. and transportation industries about the likelihood of strict enforcement and its sub- Wine consumers traveling these sequent consequences. In certain industries such as fresh produce, people are very country roads see these signs and know much aware of the seriousness of complying with the STR. In the transportation that SIP certified means that the wines sector, as mentioned previously, there are some companies that are investing time, they drink from that vineyard have money, and whatever else is necessary to make sure that all aspects of food safety are been produced by people who believe covered in their organizations. in the value of meaningful best prac- While published instances of STR enforcement are scant, similar to documented tices. cases of transportation causing foodborne illness outbreaks, this should not be the The STR produces mixed reactions basis for ignoring FDA’s express intent to ensure compliance. In Response 19 in the among its stakeholders, but more often text of the STR, FDA details its obligation and possible means of enforcement. than not, people who are now required The Department of Justice has also made public its intent to use criminal pros- to comply consider it a necessary evil ecutions in some instances to enforce regulations such as the STR to protect the rather than an opportunity to increase public from wrongdoing. It is common knowledge now that several large legal cases food safety and sustainability. have been heard and decided that individuals holding executive positions could be But what would happen if compa-

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nies began to view this regulation as Sometimes, a salesperson in a food company may not have had any transporta- one of their key paths to sustainability? tion experience, so it is important to train and support that individual in complying What would the effect be if the stake- with specific protocols. Or the situation could be turned the other way around, holders revised and improved their where a logistics person knows nothing about why a specific product should be best practices, so that consumers would transported a certain way. Everyone in the organization needs to understand how be assured and confident that food their job affects the overall food safety compliance of the company and those eating products were transported safely and the food they transport. securely? Actually, STR compliance should be integrated in all areas of all companies. Using the rule as another way to Sales, logistics, marketing, legal, and food safety are all part (continued on page 66) invest in their employees, improve their financial strength, and steward their SPONSORED CONTENT respective areas of natural resources, these businesses can turn something ISTOBAL’s HW’INTRAWASH: seemingly cumbersome into a true and lasting investment. Your New Fleet Cleaning and While the following are not new Sanitizing Solution ideas, applying them to STR compliance efforts may re-center current efforts The newest product offering in commercial washing is the in companies that are somewhat lost HW’INTRAWASH by ISTOBAL. Based on the growing need to au- in their implementation process, and tomate cleaning and sanitizing the inside of trailers and box con- perhaps these suggestions will encourage tainers, the others to get going on their plans. HW’INTRAWASH Communicate was designed to Have serious and open discussions allow operators with all the company’s employees. Insist to maximize ef- on candid conversations about what ficiency. Utilizing STR compliance is and what it should a high-pressure look like in practice. One common characteristic of orga- pumping system nizations that do not have food safety to deliver 33 gal- plans is that they have chosen the “os- lons per minute trich” route. Their heads are in the sand; at 1,100 PSI, the they are clearly comfortable with not unit provides knowing, sometimes willfully ignoring, cleaning that is how the rule applies to their company. And then there are a few companies unmatched by any system. When combined with the highly accurate that are telling the “emperor” that he is Venturi chemical system, this unit will dramatically decrease cleaning dressed and ready for a compliance in- time, water usage, and chemical usage. spection. It can be a challenge to point The HW’INTRAWASH can clean a 53’ trailer in as little as 3 min- out to the leaders of some companies utes, and clean and sanitize in 6 minutes. Its multiple programs can that serious gaps exist in food safety be customized for speed or cleaning, allowing each unit to receive plans. These leaders may be setting themselves up for exposure of the worst the washing program needed. Constructed of stainless steel, this kind if they choose not to give serious unit and its components are designed for harsh cleaning environ- attention to this regulation. ments. Its footprint is small, and the support equipment required is compact, so installation in an existing dock is possible. Culture The HW’INTRAWASH is evolving every day; many optional To facilitate the level of communica- features are available or under development that add to the tion discussed above, a change in the overall atmosphere of a company may HW’INTRAWASH’s already amazing efficiency and value. Currently be needed to achieve the best results. available are a static mounting platform, movable debris catcher with People need to know that it is OK to ask filtered drain and easy-open hopper, additional chemical options, questions, seek advice, and report prob- and a top cover. lems.

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FSM101118pg46-62,66Final.indd 53 10/3/18 9:32 AM FOOD SAFETY CULTURE By Bertrand Emond, M.Sc., MBA, Julia Bradsher, Ph.D., M.B.A., and Laura Nelson

The “A” in Culture: A Toolbox to Drive Positive Food Safety Behaviors

Ensuring the safety of food products for con- Practices for extent to which all employees internalize and sumers is a key goal of a food safety culture, apply consistent food safety behaviors is influ- and food companies are increasingly chal- moving beyond enced by their own cultures, attitudes, values lenged to manage a robust food safety culture and beliefs, and training effectiveness, as well compliance to 2 Ethat consistently delivers safe food. as those of their peers and their business. Getting things wrong can have devastating These factors are examples that fit into what effects not only on the business but also on commitment is called the ABC model,3 which stands for consumers and society. Every day, new cases “antecedent, behavior, consequence” (Figure seem to be emerging. 1). It is a simple and powerful model when trying to under- Consider food recalls as a measure of food safety. In data stand and change behaviors, and it is a useful tool that can published by the U.S. Food and Drug Administration ex- be used to strengthen an organization’s food safety culture. amining the root cause of food recalls,1 about 26 percent of Ultimately, managing behaviors within the workplace will food recalls were the result of improperly following Standard reinforce and ensure the safety of the food being grown, trans- Operating Procedures (SOPs), and 32 percent were caused by ported, manufactured, or served. inadequate training. More recently, a global food safety train- An antecedent is something that comes before a behavior ing survey found that 67 percent of food safety respondents and is required for an individual to understand what is ex- agreed that “Despite our efforts, we still have employees not pected and how to perform a behavior. A practical example following our food safety program on the plant floor.” The could be a policy and procedure communicated to employees

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FSM101118pg46-62,66Final.indd 54 10/3/18 9:32 AM REFRIGERATED FOODS ASSOCIATION 2019ANNUAL CONFERENCE February 17 - 20, 2019 Marriott waterside hotel, Tampa, FL “Advancing and Safeguarding the Refrigerated Foods Industry”

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Networking Luncheon Technical Update by Martin Mitchell Keynote: Jim "The Rookie" Morris

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One-on-One CEO Sessions Photo: Visit Tampa Bay Photo: Marriott Waterside Hotel

Session Speakers and Topics Include: To successfully position your company in today’s • Keynote, Jim “The Rookie” Morris - “Remember Who You marketplace, it is imperative to stay ahead of current Are” market trends, food safety regulations and technical • Michael Hewett of Publix Supermarkets - Sustainability issues. Attend the Refrigerated Foods Association’s • Dick Finnegan, Author & CEO - Employee Rentention & 39th Annual Conference & Exhibition as we work Engagement toward “Advancing & Safeguarding the Refrigerated • Sarah Schmansky of Neilsen Fresh - Trends Foods Industry.” • Martin Mitchell, RFA Technical Director - Technical Update • Keith R. Schnieder and Douglas L. Archer, UFL - Food Conference highlights include One-on-One CEO Recall Manual • FDA Representative, Brett Podoski and Patricia Wester, Sessions, Exhibit Hall and Reception, Golf CEO, AFSAP - FSMA 101 Tournament, and many networking opportunities! • Mark Duffy, Universal Pure and Joyce Longfield, Good Foods/Cold Pressure Council - HPP Panel REGISTER NOW AT WWW.REFRIGERATEDFOODS.ORG

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iors expected for each job role. Antecedent Behaviors Consequences For case 2, “I do know what the right thing to do was…,” root causes could be “I was not physically able” or “I did not bother.” For each, there are again antecedents that would help drive the wanted behaviors. For example, are the tools for the job actually fit for purpose? Is there a rewards-and-recognition Feedback program specifically designed to motivate and inspire teams and individuals to behave in the expected manner? Figure 1. The ABC Model3 As illustrated, the root-cause analysis can lead you, potentially, to quite different root causes that would require com- on proper handwashing techniques. pletely different corrective actions. Traditional classroom train- A behavior is anything an individual does and is observing/retraining is not always the answer, and you must select able. A practical example could be washing hands using the your antecedents based on a detailed root-cause analysis and procedure that has been taught, all the time, every time. needs assessment. When selecting, designing, and implement- A consequence is something that follows and is caused by ing your antecedents, you should also consider in your needs the behavior. There is a feedback loop built into the behavior, assessment a couple of key factors: national cultures and the as what happened last time you behaved in a particular way impact of generations. will have an effect on how you will behave the next time. De- pending on the consequence, you will either sustain or change National cultures and impact on antecedents your behavior. A practical example of a consequence could be It is imperative to take into account the deep culture (na- positive feedback from a supervisor because you showed a col- tionality, where they were brought up, religious beliefs, ethics) league the right way to wash hands and why it is important. of your employees. Hofstede’s national cultural dimensions,4 In this article, we are focusing on the “A” or antecedent to the Lewis Model,5,6 and Meyer’s Culture Maps7 are very useful provide you with examples of how what we know drives what for the identification of some of the challenges you might face we do and how antecedents help us better understand what is when trying to improve the culture of your business. It will expected and how to deliver on these expected behaviors. also help you understand why an employee has behaved in a We need to do what we do better and smarter to optimize particular way: the return on investment and effort, and drive compliance. • Communication: Some deep cultures prefer precise, sim- We also want to share some specific challenges related to ple, and clear messages taken at face value (e.g., Germany training as an antecedent and how you can get more out of or U.S.); others prefer more nuanced messages and reading your training investments. between the lines (e.g., Japan or Korea). • Giving feedback: Some prefer direct and blunt feedback Importance of Managing the Antecedents (e.g., Netherlands); others prefer private, softer feedback Effectively (e.g., Japan). As part of this effective management, and to choose and set • Persuasion: Some prefer a practical approach with execu- the “right” and most effective antecedents for your company, tive summary and facts (e.g., U.S. or UK); others prefer to it is critical to undertake a robust root-cause analysis in a case cover the theory/concept first, then move to the facts (e.g., of poor performance or unacceptable behavior, or when need- France or Italy). ing to introduce a new behavior. • Leading: Some prefer a flat organization (e.g., Denmark or Sweden); others prefer a clear formal hierarchical structure Potential findings of your root-cause analysis (e.g., Japan or Korea). This would have an impact on the Typically, when analyzing why a group or person behaved level of autonomy and ownership felt by those working in a particular way, there are two generic cases: They did not for the company and their authority to deal with potential know what to do, or they knew what to do. For each case, food safety or quality problems; achieving “empowerment” there are several root causes. For case 1, I am not trained, and might be more challenging for some. I am new to the company; I was trained, but it was complex • Decision making: Some deep cultures prefer consensus and boring, and I lost interest. For such situations, antecedents that might take a while to achieve (e.g., Japan or Sweden); like dedicating time and scheduling training consistently for others prefer the decisions to be made by the boss—it can new hires or conducting a training needs analysis to better be much quicker, but then time will be needed to get every- understand the learning need, learners, etc. will help correct body else on board (e.g., China or India). wrong behaviors caused by “I did not know.” It is essential to • Scheduling: Some prefer clear, time-bound deadlines for perform a robust training needs analysis for each employee each activity (e.g., Germany or Switzerland); others prefer a based on the job they are expected to do and develop a com- more flexible multitasking approach (e.g., India or China). petency framework detailing the knowledge, skills, and behav- • Rewarding: Some prefer individual rewards and recognition

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(e.g., U.S. and UK); others prefer team rewards (e.g., China or Mexico).

Impact of generations on food safety culture and effectiveness of antecedents As already mentioned, antecedents like training should be designed by using a needs analysis to understand the learning objectives and the specific characteristics of the learner generations. The workforces of most sites now span four generations [baby boomers, Gen X, millennials (Generation Y), and the new Generation Z!]. The generations have different values, aspirations, attitudes, and behaviors. This has implications for managing a site’s culture. One antecedent might not have the same effect on all. Differences between the generations mean that interper- sonal relations, teamwork and collaboration, and effective communication can be affected. Different techniques might be required to drive engagement and loyalty for each group. For example, the millennials and Gen Z employees are true digital natives (addicted to their devices) with the ability to multi-task and embrace new technologies quickly; but they are often described as self-centered, impatient, immature (finding hard to manage others), and less focused; craving regular feedback and recognition, they seem to be more concerned about values and are more sensitive.

Antecedents: Your Toolbox! Antecedents need to address all the specific root causes that you uncovered in your analysis. This will increase the performance of your overall food safety plan and create a better con- nection between why the company sets expectations around food safety behaviors. We have listed some of our favorite antecedents for you to consider (Figure 2). We also strongly recommend that you have a look at your health and safety (H&S) activities and pick up useful tips from them. In fact, industry food safety leaders are partnering with their colleagues in H&S, operations, human resources (HR), maintenance, etc. to collectively determine the appropriate employee behaviors required to achieve the business goals and objectives. 1. Senior Leaders and Managers These individuals need to show their clear and consistent commitment to making safe food, which includes dedicating time and effort to train and educate staff, and ensure that all people involved in food production (e.g., staff, contractors, agencies) realize that they play a part in food safety and that they are accountable. This covers onboarding of new staff, agency staff, and contractors, and ensuring timely refreshers and relevant training following the installation of a new piece of equipment. 2. Trust and Openness The company needs to have a trusting and open environment that empowers employees to speak up if they feel that food safety is being compromised and corners are being cut for production’s sake.

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Senior Leaders Trust & Hazard & Risk Communications Simple The tasks to perform and the SOPs to follow should be as & Managers Openness Awareness & Messaging Procedures simple and easy as possible, and the amount of effort and time required to execute them should be optimized. For example, forms to complete should not be too long and complex. Con- sider use of pictures rather than text for instructions or specifi-

Decision Tools & cations. Making Measures Equipment Investment Time 6. Decision Making Consider creating an independent escalation path that allows the food safety team to report directly to senior leadership rather than senior operations staff, so that food safety is not compromised when the production and/or commercial Expectations Competency Training Confidence Reinforcement teams are under pressure and “cutting corners” is on the table and in conflict with business objectives. 7. Measures The key performance indicators used across the business should not drive the wrong behavior that might compromise Figure 2. The Antecedent Toolbox food safety. 3. Hazard and Risk Awareness 8. Tools and Equipment The company needs to be aware of all relevant hazards and Employees need to have fit-for-use/fit-for-purpose clothing risks that might have a food safety impact on its business and and equipment, and work in fit-for-purpose premises/build- communicate this to its staff in an effective manner, with regu- ings. lar updates. Consider applying some of the techniques used Have we provided each employee with the appropriate by the H&S team. environment to achieve success? For example, one company 4. Communications and Messaging had an employee in receiving who was inaccurately assessing Good communication ensures that a company’s food safe- produce condition. Only after a discussion and evaluation ty strategy and expectations are received consistently and un- was it discovered that the employee was color-blind and derstood by all employees within the organization. The goal physically unable to distinguish red from green produce. An- is to educate, inform, and raise awareness among all new and other employee’s job was to empty ingredients into a hopper existing employees of safe practices so they assume ownership without touching the edge of the hopper with the ingredient of their role in ensuring consumer safety and brand protec- box exterior. Her supervisor observed the employee routinely tion. leaning the ingredient box onto the hopper and would write It must occur regularly, be tailored to the organization’s up the employee for the behavior deficiency. Finally, after various audiences, accessible wherever the desired behavior some discussion with the employee, the supervisor realized should occur, and measured for effectiveness (e.g., via online the ingredient boxes were too heavy for the employee to con- surveys and employee focus groups). sistently meet this food safety procedure, and the process was Examples of available food safety communication channels reengineered. Companies intent on enhancing their food safe- include posters, meetings, briefings, videos, phone calls, con- ty culture understand the value in actively soliciting routine ferences, huddles, digital coaching, mentoring, feedback/sug- employee feedback to ensure the employees have the ability gestion processes, company intranet and message boards, cor- and the tools necessary to execute the appropriate food safety porate website, competitions, buddy program, gemba kaizen behaviors. circle meetings, awards and recognitions, and consequences, 9. Investment including disciplinary actions up to termination. The company needs to commit to a decision-making pro- Consider leveraging the functional expertise of industry ex- cess related to budget, capital expenditure, and investment perts and your colleagues in marketing to help to segment the that does not compromise food safety, thus ensuring the right workforce and develop targeted food safety messaging, taking level of resources and fit-for-purpose/use of equipment. into account deep culture, generations, job type, etc. Fonterra, 10. Time a large dairy cooperative in New Zealand, has been using this The company needs to ensure that employees have enough approach of “internal customers profiling” to great effect, as time to do their task properly and are not forced to take short- highlighted by Joanna Gilbert of Fonterra at a Campden BRI/ cuts to keep up. TSI Culture Excellence webinar in October 2016. 11. Expectations When a supervisor can have a two-way conversation with Employees should understand that they are accountable and an employee, bad habits, poor training, and misinformation responsible for ensuring food is safe; they should know the risks can be identified and corrected. and the right thing to do as a matter of course at all times. They 5. Simple Procedures should not be able to get away with unacceptable behaviors.

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This should be achieved via training and education but derstand the roles fully and get input from the jobholder, su- also reinforced by an effective reward system. Also consider a pervisors, and also and crucially HR. Your HR colleagues can buddy or team approach where one or several employees look provide support, expertise, and tools that will be invaluable. out for one another so no one can operate “in the dark” (e.g., 13. Training CCTV cameras); it is important to show desired behavior as Training is essential to ensure that the employee is com- the social norm. petent. It includes a range of learning opportunities, such as 12. Competency education, experience/on the job, coaching and mentoring, How do you define the knowledge, skills, abilities, and networking, workshops and conferences, job shadowing, and behaviors that workers need to perform their food safety roles standardization, not just the dreaded PowerPoint, classroom, effectively? How do you know if they are qualified and com- once-a-year talk! Consider using training needs analysis/cycle petent for the job/task? and competency-based learning systems. Make sure your HR You need to define a competency framework that includes team is fully engaged and supporting you. the set of competencies required for each role in your business 14. Confidence to be performed effectively. Benefits experienced include: Coaching and mentoring as well as having a buddy sys- • Employees are clearer on what is expected of them tem are good ways to improve confidence (assuming that the • Clearer accountability employee is competent and capable). It is vital to determine • More effective recruitment and new staff selection how well people both understand and have confidence in the • More effective performance evaluation training and education they receive. Only through complete • More efficient identification of skill and competency comprehension and confidence are they likely to implement gaps safe-food behaviors and influence others around them to do • Helps provide more customized training and profes- likewise. Having a structured approach to provide consistent sional development feedback, coaching, recognition, and corrective actions en- • More effective succession planning hance two-way communication. • More efficient change management processes Wrong fit: If all fails, the employee should be redeployed! When you develop these frameworks, make sure you un- 15. Reinforcement

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Reinforcement relates to the use of rewards, incentives, and ployee to address incorrect behaviors. Reasons mentioned why disincentives to shape and manage correct behaviors. Rewards, employees did not follow food safety programs consistently when paired with fair and transparent recognition programs, include bad habits (62%), preference for doing things the old can help management guide desired food safety behaviors. way (54%), and following other employees’ directions (34%).2 Such programs should be designed to accommodate cultural Lack of engagement (30%) was also cited as one reason differences and different personalities within the organization. employees do not consistently follow food safety protocols. Your HR colleagues should be able to provide you with valu- An astounding 51 percent of the American workforce is not “…the most mature organizations use approaches based on competency- based learning.”

able support to design effective reward systems. Clear account- engaged.8 Companies focused on improving their food safety ability and compliance foster commitment, empowerment, culture recognize this challenge and apply many different an- and ownership. Companies can use various incentives and tecedents to improve employee engagement, including food deterrents to achieve consistent compliance, including: safety communication campaigns using digital signage, super- • Positive and negative feedback visor huddle guides, posters, and incentive programs. These • Sharing best demonstrated practices different campaigns are all designed to keep food safety top of • Learnings from failures mind days, weeks, and months after the initial classroom train- • Recognition programs ing. This food safety reinforcement drives food safety aware- • Individual and team awards ness and indicates the continued importance of food safety • Corporate, peer, and self-recognition throughout the year. Green Valley Pecan Company, one of • Monetary and time compensation, praise the world’s largest growers and processors of pecans, deployed • Incentives to report failures and near misses a communication campaign and experienced a 17 percent • Promotion and demotion increase in knowledge retention across all employees and a 36 percent increase in correct knowledge recall among their em- When Training Is Needed, It Needs to Stick! ployees who needed it the most—those who did not initially As food safety professionals, we commonly focus and rely perform well in the knowledge pretest. Deborah Walden-Ralls, on food safety training as a key antecedent to drive the appro- co-owner and vice president of risk management for Green priate food safety behaviors we expect from our employees to Valley Pecan Company, noted that the program “helped us support our food safety protocols and procedures. Consider- improve the overall quality of our product.” able time and resources are devoted to food safety training Sometimes, training program shortcomings may not be each year, but we don’t often consider whether we are present- what training you are providing but how that training is pro- ing the right content, with an effective delivery, to achieve vided. Are you training employees on your allergen program measured, correct employee behaviors. do’s and don’ts, your critical control protocols, receiving pro- So, how are we executing on this key antecedent? Even cedures, personal protective equipment program, and the list though 83 percent of global companies reported positively on of Good Manufacturing Practices (GMPs) each January and their ability to drive consistent food safety behaviors, 67 per- then wonder why you see GMP violations by June? To aid our cent responded that despite their best efforts, they still have food safety culture, we must acknowledge that our employees, employees not following the food safety program on the plant many of them millennials, learn in short chunks and tailor floor.2 The question becomes “Have we just come to expect our training event in shorter time frames, 20 to 30 minutes, inconsistent employee behaviors as the norm?” throughout the year. Companies that are driving a strong food safety culture Are you conducting training at the end of 10-hour shifts, within their organizations have expanded the traditional class- before holidays, or on the weekends when employees are tired room training toolbox to include additional tools to more ef- and less engaged? Some companies found that moving their fectively drive consistent employee food safety behaviors. For training time to mornings or midweek, and recognizing those example, 46 percent verify that training is applied correctly on employees that demonstrate their comprehension of the train- the plant floor, while 36 percent of the innovative respondents ing, helps employees stay more focused and receptive to food acknowledged they were actively measuring employee perfor- safety education. mance or behaviors.2 A small but growing number of compa- Are you delivering training in English, even though over nies recognize the value of measuring employee behaviors to 50 percent of your workforce has English as their second the effectiveness of training so that corrective actions can be language? Bigelow Tea, a family-owned company, has 70–80 applied. Observing and assessing employee behaviors allow percent Spanish-speaking employees and wanted to make sure for a two-way conversation between a supervisor and an em- that all employees received the same quality of training. By

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H FOOD SAFETY CULTURE F

O R O E D N T SA R FET Y PA Anritsu • detectionprevention.com ...... 13 Visit our website adoptingAOAC • www.aoac.org a training platform ...... that provided training in multiple69 to learn more. languagesArt’s Way Scientific,and could Inc. be ...... customized for their different depart29- ments, 866.808.5609 Bigelow was• www.bestsanitizers.com/handtalk2 able to ensure “everyone knows how they areBest critical Sanitizers, to Bigelow’s Inc...... success,” per Bruce Ennis, vice presi9- dent 888.225.3267 of HR for Bigelow.• www.bestsanitizers.com/nextstep6 Bia Diagnostics, LLC • 802.540.0148 • www.biadiagnostics.com ...... 57 It is worth remembering and highlighting that “training” Bio-Rad Laboratories • www.bio-rad.com/info-foodsafety...... 43 A higher level of includesBioControl a muchSystems, larger Inc...... list of learning opportunities that hap31- pen 800.245.0113both inside • andwww.biocontrolsys.com outside of the training classroom, as listed food safety intelligence. earlier.bioMérieux An effective ...... “training cycle” follows a model much 47like the ABCwww.biomerieux-usa.com/industry/gene-up model with opportunities along the way for assess- Hitachi HiQ eSystems™ monitors mentsCarter andManufacturing performance Co...... improvement programs. 63 perishable assets to ensure safe, reliable, We616.842.8760 also find • thatwww.carterbearings.com the most mature organizations use ap- sanitary transportation and storage. proachesCopan Diagnostics based on Inc. competency-based • 800.216.4016 • www.copanusa.com learning. 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FSM6717pg1-2,75-76.inddFSM101118pg46-62,66Final.indd 75 61 6/1/1710/3/18 12:09 9:32 PMAM In the Food Industry, FOOD SAFETY CULTURE No One is Immune to Allergen Concerns functions, including: • H&S, to pick up on tips and techniques, as they have a lot of experience in behavior-based approaches to drive compliance. • Marketing, to help segment the workforce and develop targeted food safety messaging, taking into account deep culture, generations, job type, etc. • HR, to help with developing and managing the continuing professional development of each employee, the competency framework, and the various training and learning 3M Allergen Test Kits activities required. • HR, which usually has access to dedicated software pack- ages and tools, as opposed to battling your way through an Excel spreadsheet when you can squeeze it in your busy schedule. HR support is also valuable when designing an effective reward system to reinforce desired food safety behaviors. We need to do what we do better and smarter to optimize the return on investment and efforts. As Benjamin Franklin said, Call or visit our website by failing to prepare, you are preparing to fail. So, by getting the antecedents right, we are setting the optimum conditions to get for more information! things right the first time and be as efficient as possible. This is a continuous improvement journey; as the condi- 1-800-826-8302 • nelsonjameson.com foodsafe ad 3.375x4.875_Layout 1 7/21/15 9:52 AM Page 1 tions and antecedents adapt to changes in the business, the [email protected] toolbox provided in this article will be particularly useful. We are here to support you. Over to you! n

Bertrand Emond, M.Sc., M.B.A., is head of membership & training, Campden BRI. Julia Bradsher, Ph.D., M.B.A., is president and CEO, International Food Protection Training Institute. Laura Nelson is vice president, food safety and global alliances, Alchemy Systems.

References 1. U.S. Food and Drug Administration. Survey of Root Cause of Recalls (2009). Penguin 900 Boxer 800 2. www.campdenbri.co.uk/training/globalfoodsafetytrainingsurvey2017. Penguin 1000 pdf; www.alchemysystems.com/food-production/resources/research/ global-food-safety-training-survey/. 3. Braksick, LW. Unlock Behavior, Unleash Profits, vol. 2 (McGraw-Hill., 2007) Penguin 400 Swan 300 Fish 600 4. Hofstede, G. Culture’s Consequences – Comparing Values, Behaviors, Institutions and Organizations Across Nations (Thousand Oaks, CA: Sage Publications, 2001). Our Foodsafe product line has been 5. Hemmerich, K, R Lewis. Fish Can’t See Water. How National Culture developed specifically for all aspects Can Make or Break your Corporate Strategy (John Wiley & Sons, 2013). of the food service industry. 6. Lewis, R. When Cultures Collide (Nicholas Brealey Publishing, 1996). These safety knives have stainless steel 7. Meyer, E. The Culture Map (Perseus Books Group, 2014). blades, can be steamed/cleaned and are 8. news.gallup.com/topic/employee_engagement.aspx. metal detectable. NEW! 2018 Exclusive Food Safety Culture Collection Visit go.foodsafetymagazine.com/culture 314-645-3900 to download your copy today! [email protected] www.safetyknife.net

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9. Sanitation team members are easy to replace trols are in place. Food waste protocols and food sustainability When sanitation is thought of as an operational expense, it issues rank second and third. As more and more sensational is easy to view sanitation employees as new hires that can easi- headlines concerning foodborne outbreaks in popular restau- ly be replaced by another new hire. The majority of entry-level rants occur, Marriott remains steadfastly determined to miti- sanitation employees leave before they’ve passed the 3-month gate the risks associated with these new and innovative foods, mark, creating the need for more basic training on an ongoing procurement methods, and production techniques. basis. However, workers in sanitation doing their job well are A team of researchers from Johns Hopkins Bloomberg critical to producing safe food, making these employees im- School of Public Health recently simulated a number of types portant figures in the risk management equation. For example, of restaurant outbreaks, using common causes like norovirus, a restaurant chain like Chipotle has provided ample evidence Escherichia coli, and Salmonella.10 They sought to determine that poor hygiene at suppliers as well as at restaurants can di- how each would financially impact various restaurant catego- rectly affect stock value and pose a serious threat to customer ries. Depending on factors like outbreak severity, fines, law- loyalty. Employee training, retention, testing programs, and suits, legal fees, and number of employees affected, full-table- qualified oversight are all part of a larger food safety plan that service restaurants, like many hotels, would be financially dev- should include a healthy workplace culture and policies that astated by a single outbreak. The cost of such an outbreak can prevent sick employees from working, while providing ad- range between $8,030 and $2.2 million. Upscale restaurants equate financial safeguards. Sanitation workers in this scenario would see a cost between $8,273 and $2.6 million. are all employees who play a role in the hygienic conditions of the food. Conclusion Many food and beverage operations have made the fatal 10. Poor sanitation is the main cause of recalls mistake of putting profit above safety. By accepting compla- Recalls of any product, in either the U.S. Food and Drug cency instead of striving for excellence, they fail to continu- Administration’s or the U.S. Department of Agriculture’s ously evolve in addressing emerging risks. Marriott’s core jurisdiction, share some common threads of which “adultera- values dictate that our hotels improve the communities that tion” is the umbrella term used to classify a good number of we do business in. There is research that shows millennials recalls. While supply chain issues and mislabeling are large want to make the world a better place as well. We realize that contributors to recalls, allergen and pathogen contamination this generation has actually helped us improve food safety and are not always due to sanitation failure. However, sanitation protect public health by challenging us to continuously im- is only as successful as the integrity of the equipment and prove our methods so they can be proud to work, eat, drink, surfaces, the quality of incoming utilities including air and and thrive in Marriott hotels. Together, we can uphold what water, and the availability of the appropriate tools to be used our founder JW Marriott started, a vibrant culture of food in the sanitation program. When the root cause of the recalls safety wherein every associate is responsible for food protec- is linked to sanitation, it is often linked to operator failure. tion and public safety. n However, operator failure would not always be identified as a root cause if one were to critically look at the decisions made Douglas Davis, CP-FS, is the senior director, global food safety for Marriott in writing and implementing SSOPs, purchasing and making International. available tools that enable better sanitation, time and resource allocation, knowledge of the team responsible for the job, the References culture around decision making in the organization, reward 1. www.pewresearch.org/fact-tank/2018/03/01/millennials-overtake-baby- systems, and design principles applied to enhance personal hy- boomers/. giene and maintenance. In essence, poor sanitation decisions 2. wholesale.wf.com/food_for_thought/generational-preferences-impact- may be deterred by creating a better culture and reward system the-food-industry/. that fosters responsibility in hygiene. n 3. www.hospitalitynet.org/news/4007041.html. 4. news.marriott.com/2017/12/aramark-completes-purchase-avendra/. Angela Anandappa, Ph.D., is the executive director of the Alliance for Advanced 5. investor.shareholder.com/MAR/releasedetail.cfm?releaseid=39128. Sanitation and a research assistant professor with the Department of Food Science 6. www.ers.usda.gov/webdocs/publications/86401/eib-186.pdf?v=43097. and Technology at the University of Nebraska, Lincoln. She has been in the food 7. skift.com/2018/01/22/marriotts-revamp-of-aloft-and-element-points-to- industry for over 18 years and is experienced in food safety, molecular diagnostics, the-future-of-select-service-hotels/. and food microbiology. Her current work involves developing interdisciplinary re- 8. www.healthcentral.com/article/food-allergy-travel-tips-you-can-take-it- search and educational programs to address food safety issues and prevent them with-you. by addressing hygienic design and sanitation challenges. Prior to joining the alli- 9. www.foodandwine.com/news/menu-trends-2018. ance, she was section manager of supply chain safety assurance at the Kraft Heinz 10. www.cnbc.com/2018/04/17/heres-what-it-costs-restaurants-when-a- Company. foodborne-illness-outbreak-occurs.html.

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hypochlorite, sodium hypochlorite, and is cheap, is easy to prepare, and is fast UV light is also cheap, eliminates a chlorine dioxide.5 Chlorine-based sani- acting. This chemical must be used with wide variety of pathogens, and gives off tizers are easy to prepare, highly stable, caution due to its instability in water, little-to-no heat to maintain freshness. fast acting, effective on vegetative cells, high allergenicity, and loss of effective- This form of radiant energy works on and rather cheap.4 However, chlorine ness if not stored under the right condi- all fresh produce except for lettuce, as it can be very deadly if proper precautions tions. can destroy this vegetable’s quality.7 are not taken. Peracetic Acid Aqueous Ozone Organic Acids Peracetic acid’s bactericidal charac- Aqueous ozone, a natural, new Organic acids such as acetic, citric, teristics include disorganization of cell alternative sanitizer, does an excellent and lactic acids can slow the production structure through degradation of the job of mitigating the growth of bacte- of energy, denature proteins, and cause cell membrane’s lipids and proteins, as ria, molds, protozoa, and viruses. This cell lysis. These compounds are typical- well as cell lysis. This chemical has been compound does not require a large ly more natural ingredients on produce, shown to kill bacterial spores, is effec- concentration and is extremely environ- cannot stain or release odors, and are tive in a neutral pH environment, and mentally friendly, given that this world noncorrosive to stainless steel. On the is mostly noncorrosive. Unfortunately, is composed of ozone. Ozone has been downside, organic acids do not work as this compound can corrode if exposed shown to be effective on many varieties well at killing yeasts, molds, and Gram- to skin or high temperatures, has an of fruits and vegetables.8 positive bacteria as other sanitizers. uncomfortable aroma, and becomes less No matter what sanitizer one decides effective in the presence of metals.4 to use, one or more parameters will Hydrogen Peroxide have to be monitored. These parameters Hydrogen peroxide causes cells to UV Light may include, but are not limited to, die through the alteration of osmotic UV light, a more natural disinfec- temperature, time, pH, water quality, pressure that leads to loss of cell wall in- tant, can be applied to fresh produce and concentration. For example, one tegrity. This compound can kill spores, to damage a cell’s genetic material.6 may use chlorine, which “is most effective…at a pH between 6.0 and 7.5” and Statement of Ownership, Management and a concentration of 200 ppm for sanitiz- Circulation for Food Safety Magazine ing the actual produce. When construct- ing a written monitoring procedure, it October/November 2018 (Required by U.S.C. 3685) Food Safety Magazine is published is important to include the individual bi-monthly at 1945 W. Mountain St., Glendale, CA 91201. The names and addresses of the Publisher, Editor are: Publisher, Stacy Atchison, 1945 W. Mountain St., Glendale, CA responsible, the method of cleaning 91201; and Editor, Barbara VanRenterghem, 1945 W. Mountain St., Glendale, CA 91201. and sanitizing, the frequencies at which Owner: The Target Group Inc., 1945 W. Mountain St., Glendale, CA 91201; stockholders cleaning and sanitizing are performed, owning or holding 1% or more of the total amount of stock: Donald Meeker, 1945 W. and the product or area that needs to be Mountain St., Glendale, CA 91201; Roberta Meeker, 1945 W. Mountain St., Glendale, CA cleaned. A monitoring log should have 91201; Stacy Atchison, 1945 W. Mountain St., Glendale, CA 91201. places to record date, time, initials, test Average Actual No. results, whether the results are accept- No. of Copies of Copies able or unacceptable, and where the Total no. of copies printed 17,055 16.743 monitoring was applied.9 If test results Paid and/or requested circulation 13,907 14,028 are not acceptable, corrective action Other requested distribution outside the USPS 12,139 12,468 must be taken according to the manu- Requested Copies Distributed by Other Mail facturer’s guide. Classes Through the USPS 980 1,010 Total Paid and/or requested Circulation 27,026 27,506 Non-requested distribution by mail 1,389 1,470 Why Are There Still Foodborne Nonrequested Copies Distributed Through Illness Outbreaks Associated with the USPS by Other Classes of Mail 18 18 Fresh Produce? Nonrequested Copies Distributed Outside the Mail 592 25 Many processors are using the right Total non-requested distribution 1,999 1,513 sanitizer and/or disinfectants the right Total distribution 29,025 29,019 way, conducting in-plant processing Copies not distributed 169 192 validation studies, and have verification Total 29,194 29,211 and monitoring procedures that are % paid and/or requested distribution 93% 95% stellar; they may still have foodborne I certify that the statements made by me above are correct and complete. illness outbreaks (see “Validation and (Signed) Stacy Atchison Verification Procedures,” p. 2710). A

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recent study from the University of 6. www.sciencedaily.com/releases/2015/ cgi?referer=https://www.google.com/ Southampton11 may address this conun- 07/150728091741.htm. &httpsredir=1&article=1101&context=extension_ drum. Chlorine used to decontaminate 7. www.foodsafetynews.com/2014/01/ families_pubs. fresh produce could be ineffective, pasteurization-does-ultraviolet-mean- 10. www.qualityassurancemag.com/article/ because it may mask pathogens pres- ultrasafe/#.WxFoN_ZFzIV. aib0615-food-safety-validation-verification- ent on the fresh produce, making them 8. www.researchgate.net/publication/ methods/. undetectable. The study states findings 258128496_Use_of_ozone_in_sanitation_and_ 11. www.foodnavigator.com/Article/2018/04/23/ that using as little as 3 ppm chlorine as storage_of_fresh_fruits_and_vegetables. Chlorine-to-decontaminate-fresh-produce- a sanitizer causes pathogens (specifically 9. lib.dr.iastate.edu/cgi/viewcontent. could-be-ineffective. L. monocytogenes) to enter a viable-but- nonculturable (VBNC) state. When in a VBNC state, the pathogen cannot be cultured using standard laboratory culture techniques. This study looked specifically at Salmonella and L. monocytogenes in fresh leafy greens. This study brings to light the reality that traditional and new innovative pathogen testing methods must be examined using the VBNC state of several pathogens.

In Conclusion Consumer food trends are adding more fresh fruits and vegetables to daily diets. It is important for produce to be safe and delicious to benefit human health and sustain life. It is the responsibility of everyone in the farm to fork continuum to diligently make fresh produce safe for consumption. Disin- fectants and sanitizers have a key role to play in ensuring produce safety. n

Gina R. (Nicholson) Kramer, RS/REHS, is the executive director of Savour Food Safety International. Megan Doran is an Ohio State University student and summer intern at Savour Food Safety Internation- al. She will graduate in December 2018 with a B.Sc. in agriculture, food business management.

References 1. academic.oup.com/fqs/article/1/4/289/ 4735151. 2. amp-timeinc-net.cdn.ampproject.org/c/ amp.timeinc.net/fortune/2018/05/30/romaine- lettuce-e-coli-outbreak-impacts. 3. www.nycoproducts.com/news/whats-the- difference-between-sanitizers-and- disinfectants/. 4. store.extension.iastate.edu/Product/Guide- to-Liquid-Sanitizer-Washes-with-Fruit-and- Vegetables-PDF. 5. www.siphidaho.org/env/pdf/Chlorination_ of_fruits_and_veggies.PDF.

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its FSMA compliance costs of ensuring compliance throughout the com- way opens the door for other areas of non- than other factors such as the pany; creating an open and encouraging at- compliance. types of food it produces. mosphere will make employees more willing We mentioned that com- to contribute in valuable areas. Look Inside and Out panies cited allergen control In building a plan, a good starting point, (number four for U.S./ Partnerships especially for food safety personnel, is imple- Canada and number one for Some families or friends have code words menting what these folks are already good international companies) as to use when they are around each other in at, namely, using objective scientific testing one of their key compliance a difficult or uncomfortable situation. For in trailers, typical functions like employing issues. We anticipated this example, a husband or wife may say “parsley” audits and corrective actions, and for sure, response and, as part of this survey, we also asked detailed Many of these are contracted carriers for questions about how processors are changing their aller- some“ of the largest foodservice, retail, and gen control programs. We first asked, “Has wholesale companies. FSMA changed the way that you test or control for al- in a conversation when they see their spouse” putting to use all the food safety vocabulary lergens?” Roughly 30 percent with something scary in their front teeth that words so that your transportation food safety reported that FSMA had may be embarrassing if not removed. plans align with other areas of the company’s caused them to implement Companies that buy and sell from each food safety initiatives. specific changes. We then other in some capacity need to be willing to Carriers may need to work on understand- asked what these changes help their company’s partners avoid a prob- ing food safety language, but using that lan- were, and the most frequent lem. Ignoring something potentially risky is guage and applying it to the procedures that answer, with more than 40 not what good partners do. This starts with are working and align with the STR will help percent of the responses, was communication but should move quickly the transportation company write a solid, “more testing.” to collaboration so that both entities’ food complete plan that will satisfy their custom- We will expand further safety plans can withstand scrutiny. ers’ food safety departments. on this allergen program Dispatchers and drivers are often put in But perhaps just as useful for either a food data from the survey in our the hot seat when a problem arises at a cus- or transportation company is to look outside next edition of Food Safety tomer’s or supplier’s dock. For example, a their industry to learn how other transporta- Insights. We will report how driver may have been careful to get a trailer tion sectors accomplish compliance. much additional testing is cleaned and properly prepared, but once Examine maritime or aviation systems. being done and the analytical backed in and ready to start loading, the driv- Each of them has a high level of risk man- methods being used. Allergen er notices mud, debris, or sometimes blood agement because of the dangerous results of control is, of course, more on the forklift tires or on product boxes. Per- noncompliance (see “STR Flight Plan,” p. than just testing, so we will haps in a situation where a load that requires 50). also describe the changes in temperature control for safety, the product other program elements such has not been properly cooled to the correct Conclusion as segregation and labeling. shipping temperature. In closing, and speaking of the field of We asked what products or If this happens once or twice, it is prob- aviation, there is a retired colonel that told services processors would find ably not a serious risk. However, continuous his freshman class of aviation majors, “Taking most valuable to help them disregard for a customer’s or supplier’s re- off is optional, landing is mandatory.” This is improve their programs. We quests to use safe food transportation prac- a great summary of the responsibility the STR look forward to bringing tices might indicate that it is time to make has placed on the food and transportation those insights to you in the a change. Of course, this is easier said than industry members. If a company is involved next issue. n done, but it is a better alternative than hop- in the movement of food, compliance is ing that a lucrative relationship stays lucky mandatory. n Bob Ferguson is president of Strategic and does not lead to a fine, making someone Consulting Inc. and can be reached at ill, or something even worse for the CEO. Pam Young, of Pam Young & Company, is cofounder and [email protected] or on And those drivers and dispatchers stuck managing partner of Healthy Trailer LLC. She focuses on Twitter at @SCI_Ferguson. making the decisions about whether to load driver awareness and skill acquisition to best align compa- or not load? Insisting that they look the other nies’ compliance plans under the Sanitary Transportation rule.

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