FSMA: The Movie

Leavitt Partners' Jennifer McEntire explains the recent FDA report on FSMA pilots in a short video...well worth the watch!

Leavitt Partners’ Jennifer McEntire explains the recent FDA report on FSMA pilots in a short video

Yesterday I blogged about the FDA’s new 334 page Food Safety Modernization Act Pilot Study Report that was written by the Institute of Food Technologists and Leavitt Partners.  After I published the blog post, I was corresponding with the very helpful Jennifer McEntire of Leavitt Partners who co-authored this report.  I was complimenting her on the report but said I would probably wait “until the movie version came out” (parroting the modern student’s refrain of “why read ‘Gone with the Wind’ when you can watch the movie much more quickly).

Much to my surprise, Jennifer immediately sent me back a link to a three and a half minute video she recorded explaining the report.  Sure, it doesn’t have all of the detail covered in the 334 page document but, for most of us, it’s a great “Cliff Notes” version.  You can watch the video here.

Thanks to Jennifer and Leavitt Partners for sharing this information with all of us.

PS: On March 7, Jennifer McEntire published another excellent newsletter/article on this topic which can be found here.  It also includes a link to an upcoming webinar on the topic.

Kevin Payne
Senior Director of Marketing

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Does the FSMA Have a Direct Impact on Retail Grocers?

Will the Food Safety Modernization Act (FSMA) have direct impact on the retail grocery industry? According to industry food safety expert Dr. John Ryan, the answer is an emphatic YES!  The FDA published the first two sets of proposed rules under the FSMA on January 4 of this year and the rules are available for public and industry review for 120 days.  At first glance, the two proposed rules would appear to focus on the grower and the supply chain, sparing the retail grocery industry the task of having to do anything.

FSMA Retail Ryan Thumbnail

But, in his new whitepaper, Dr. Ryan points out that there are three things that retail grocery executives should consider:

  1. Changes to one end of the food supply chain impacts the entire supply chain.
  2. The model the FDA will follow for subsequent rules has been established.
  3. Retailers have vicarious liability.

Because traceability and food safety are connected throughout the cold chain, what impacts one segment has implications for all of the other segments and vicarious liability represents a potentially huge risk for major brands. Dr. Ryan concludes his paper by making three recommendations that retailers should consider today:

  1. Be proactive.  Preventive planning is the name of the game.
  2. Consult with inspection agencies to determine how FSMA changes will impact retail inspection procedures.
  3. Consider there may be additional benefits, such as insurance reductions, that can result from addressing FSMA regulations.

FSMA is sure to be a complicated beast and, while it may take 1-3 years or more for it to be implemented in entirety, there are actions that retailers should take now.  You can download Dr. Ryan’s white paper here.

I would also add that the one step forward, one step back traceability requirements are part of FSMA. This is not a simple task and many retailers may find that their current monitoring and paper traceability tools aren’t up to the task.  Getting a holistic view of your cold chain as it relates to all of these issues sooner rather than later can provide the ability to turn potential liabilities into potential opportunities and advantages.

You can learn more about what Intelleflex can offer retail grocers and food service providers by clicking here.

Kevin Payne
Senior Director of Marketing

Peanut Butter Recall: FDA Shows Teeth Under the FSMA

You know it’s a big thing when our local newspaper finds space amongst all of the ads to print a story about food safety.  But there it was in yesterday’s morning paper: the FDA used new authority under the Food Safety Modernization Act (FSMA) to suspended the registration of a peanut butter production facility.  The details of the story relating to salmonella contaminated peanuts can be found here. The tainted products were sold through a number of retailers including  Trader Joe’s, Whole Foods, Kilwins Quality Confections, and Target.  It’s a tragedy and its great that the FDA stepped in and shut the place down until issues are resolved.

FDA Shuts Down Peanut Butter Factory Using FSMA Powers

There are two key take-aways:

  1. Because of the FSMA, the FDA now actually has the authority to shut the violator down as opposed to recommending voluntary recalls (which was it’s limitation of authority prior to the FSMA).
  2. Retailers should be as supportive as possible to do anything they can to improve food safety and managing recalls. It’s their brand on the line when customers get sick from eating foods purchased at their store. (You’ll remember the names Trader Joes, Whole Foods and Target a lot longer than SunLand (the peanut butter company) after you’ve read this article.) We need to trust our grocers and we need to know that they’re taking all possible measures to protect our safety.

This is a good sign that progress is being made on implementing the FSMA, which was signed into law in January of 2011. It’s a law which will benefit consumers and, we believe, also will improve business across the industry.  According to an article in Food Safety News, “The White House Office of Management and Budget (OMB) is still working “expeditiously” to implement major portions of the Food Safety Modernization Act.  We are working as expeditiously as possible to implement the food safety legislation we fought so hard for. When it comes to rules with this degree of importance and complexity, it is critical that we get it right.”

It is a complex law and it will take time to implement but many feel that, with the 2012 Presidential Election now behind us, things will pick up speed and producers, growers, shippers and retailers will need to focus more aggressively on addressing new traceability and food safety requirements.

The Food Safety News article explains that: The five major pillars of the FSMA will help pivot the nation’s food system from taking a more reactive to a more preventative approach to food safety. If they [the FDA] reduce foodborne illness rates by even a fraction, they have the potential to save Americans billions of dollars in healthcare costs every year.

Those five pillars — all still awaiting implementation — consist of the following:

– Preventive controls: FDA will require science-based preventive controls throughout the food system. This includes requiring food facilities to write preventive control plans, establishing minimum standards for safe production of fruits and vegetables and introducing regulation to help prevent intentional adulteration of food at vulnerable points in the food chain.

– Inspection and compliance: FDA has new authority to conduct inspections. FDA will inspect all high-risk domestic facilities every three years, have access to facility records and will establish a laboratory accreditation process for third-party testing laboratories.

– Response to violations: FDA will now have the authority to order food recalls – as opposed to recommending voluntary recalls as it does now – in cases of contamination. Farms will also be required to track their product and develop plans for how to issue recalls, though small farms that sell the majority of their product locally (within 275 miles) and sell less than $500,000 a year in product are exempt.

– Oversight of imports: Food importers must now verify that their facilities and preventive controls meet U.S. standards. FDA can now deny food from foreign facilities entry to the U.S. if the facility does not allow access to inspectors.

– Collaborative partnerships: Health agencies, both foreign and domestic, will work collaboratively to improve public health goals. FSMA provides FDA with a grant to develop state and local health agencies’ ability to improve food safety at a localized level. FDA will also develop a plan to help improve foreign industries’ ability to meet U.S. food safety requirements.

Addressing food safety regulations and traceability doesn’t have to be viewed as a cost of doing business but rather viewed as an opportunity. By combining a proactive approach to managing the supply chain – using pallet-level temperature monitoring – the industry can significantly reduce waste and generate more revenues and effectively get traceability for free.

If we work together, it can be a win-win. You can learn more about our solution for improving quality and traceability here.

Kevin Payne

Senior Director of Marketing

PS: If you’re interested in reading more about the FSMA, there’s a good summary here.

 

Thought for Food

Tomorrow’s Thanksgiving here in the USA.  If you’re able to read this blog, chances are that, like me, you’re pretty blessed and have much to be thankful for.  And, if you’re like me, you’ll be able to enjoy a wonderful meal with friends and family that includes a nice entree (I didn’t use the “T-word”), some vegetables and a wealth of other fresh food items. (Note that everyone’s favorite the Brussels Sprout is experiencing a renaissance in time for Thanksgiving! Find more about that here.**)

Who Wants Brussels Sprouts for Thanksgiving???

What you’re probably not thinking about is food safety but every year newspapers publish articles about how to make sure your turkey is properly cleaned, vegetables washed, food cooked  adequately and leftovers stored properly.  If you haven’t seen one of those articles, well, here you go! Read the Sacramento Bee article.

At Intelleflex, we think about food safety every day as food safety and quality is a main focus of our business. We work with growers, grocers and distribution companies to help them make sure that the food you buy at the store is fresh and of high quality. In fact, after you’ve worked at Intelleflex for a while, you can never look at things like a clamshell of strawberries or a bag of spinach the same way!  As the Food Safety Modernization Act begins to be implemented, we’ll see even more news about food safety in the year to come.

So, from all of us here at Intelleflex, a safe and happy Thanksgiving to you all.

Kevin Payne

Senior Director of Marketing

**I actually love Brussels Sprouts.  Just wash them thoroughly, peel the leaves off, saute with some bacon and toss in some chopped pecans and garlic.

Untangling the Food Safety Modernization Act

Well, after what seems like a hundred years of campaigning, election day has finally arrived.  Thank heavens!  That can only mean that the 2016 campaign begins tomorrow.

But, until then, the results of today’s election could impact the rollout and implementation of the Food Safety Modernization Act – the landmark legislation signed by President Obama in January of 2011.  There’s been a lot of speculation about how Obama or Romney will handle this after the election but I personally think it’s an important piece of legislation.  Today alone I spoke with two different journalists about this topic.  (You can listen to my conversation with The AME Food Testing Show on BlogTalkRadio here.)

Talking the FSMA and Other Topics on BlogTalkRadio

FSMA is a complicated law that addresses the complicated issue of domestic and international food safety.  United Fresh, among others, have done a lot to help explain it to their members.  If you’re a member of United Fresh, you can get a copy of their analysis here and United Fresh is also hosting a webinar on the topic on November 18.

I recently came across another overview of the legislation that was published in Food Logistics Magazine and the authors of the piece, Leavitt Partners and Eurofins, were kind enough to give me permission to post it on our website.  It’s a nice, easy-to-digest summary of key points in the law.  Worth the read and my thanks to the authors for letting us share it.  You can download a copy here.

Read the Leavitt Partners-Eurofins Article

Food safety and quality is something that we should all be invested in.  I’m optimistic that, with the election behind us, we’ll be able to focus time and resources on this important topic.

 

Kevin Payne

Senior Director of Marketing

 

FSMA: Threat or Opportunity

I’ve long been a proponent that the Food Safety Modernization Act is an opportunity for the industry, not a threat.  Katie Beissel, Global Industry Manager – Food and Beverage, GE Intelligent Platforms agrees.  In her article titled Planning for FSMA Compliance  posted on Manufacturing.net she writes:

FSMA and other regulations should be viewed as an opportunity for food manufacturers to adopt a more holistic approach to solving food quality and safety concerns. One of the many benefits of FSMA compliance will be increased visualization and control over the manufacturing processes and supply chain. This ability reaches far beyond compliance and can benefit many different aspects of food manufacturing by increasing productivity, improving lean manufacturing processes and developing automated control systems.

An Opportunity to Make Your Customers Happier

She encourages the industry to gain clarity on the new regulations and understand how they impact food safety, risk prevention and reporting and recommends that “Producers must have in-depth visualization of the entire supply chain with the ability to quickly identify and mitigate problems before or just after they occur.”

Accomplishing this requires better data about what is happening in the supply chain from harvest or manufacture through to the retailer. Knowing the condition and history of the product from field or factory to fork is essential and traditional monitoring techniques are quite simply lacking the chops to proactively address FSMA requirements – simply put, they’re inadequate, slow and cumbersome.

Beissel cites what I consider three “abilities” to focus on:

  • The ability to recall products from the market faster. The emphasis is on speed and accuracy of the notification of the FDA of a recall, which means manufacturers need to be able to quickly diagnose and act upon problems anywhere in the supply chain. Producers must, at a minimum, understand the size of the recall, what happened, where the product was produced and what steps to take.
  • The ability to prevent bad quality product from reaching the public. In line with the ability to recall products faster, food manufacturers are now required to follow current good manufacturing practices (cGMP) and use hazard analysis and critical control point processes (HACCP) when developing their food quality safety programs. These new requirements are an attempt to prevent bad quality products from reaching the public and must be readily available for FDA inspection and review at any time.
  • The ability to keep key quality records longer. Key quality data is now required to be kept on record for two years, allowing the FDA to review more of the process issues and the producers’ reactions to them. Previously, these key quality records were only required to be on file for 90 days.

Pallet-level temperature data loggers provide these abilities.  Data about the harvest, manufacture and condition of products can be collected and stored directly on the tag with the product as it moves through the supply chain.  Data can also seamlessly be shared via the cloud to speed recalls. Actionable data about the product’s condition can help prevent bad quality and reduce spoilage.  Data on the tags – and more importantly shared in the cloud or stored in ERP systems – makes it easier to store and access the data.

Sounds like a great opportunity to improve food quality and safety, address regulations and even improve profitability and customer satisfaction.

Kevin Payne

Senior Director of Marketing

Food Safety Audits – Impacts on Traceability

Lara Sowinski of Food Logistics magazine wrote a great article on Food Safety Audits that’s well worth the read.  In the article, she discusses how the impacts of the Food Safety Modernization Act (FSMA), increasing imports, growing recalls and supply chain complexity are pressuring the industry to maintain and improve food safety.

Food safety audits will impact traceability requirements – RFID can help

The article quotes Melanie J. Neuman, an advisory manager who specializes in food safety issues for PricewaterhouseCooper’s retail and consumer practice who says that, when it comes to the impact of the FSMA, “companies are facing the most sweeping changes in food regulations in over 70 years.”

Neuman explains that the role of PwC is to advise its clients on best practices to meet and comply with regulations, not only for the FSMA, but for a host of food safety laws and regulations that are governed by the U.S. Department of Agriculture (USDA) and U.S. Food and Drug Administration (FDA).

“We really help clients integrate food safety into their culture and their daily operations,” says Neuman.  This is the first stage, she explains in the interview, but then they drill deeper with their clients.  Neuman continues that “The next step of the assessment starts to drill deeper into other categories, such as whether or not the company’s electronic traceability systems are robust enough to comply with the current regulations and their customers’ expectations for producing reports. We look at the company’s ability to track and trace products accurately and quickly, including the ability to identify all ingredients, including raw materials, all production and inventory records, and all distribution on an outbound basis, in order to quickly track product in the event of a food borne illness or other food safety risk.”

Neuman states that tracking and tracing capabilities are high on the list of items that an auditor will examine during an inspection and adds that “record keeping practices go hand in hand with tracking and tracing.”

RFID and intelligent pallets and returnable transport items can help deal with the complexities of the modern supply chain.  With all of the hand offs and issues associated with increasingly diverse and extensive supply chains, making it easier to capture, store and share electronic traceability information every step of the way will be critical.  To learn how, click here.

Kevin Payne

Senior Director of Marketing

Chinese Food and Free Traceability

I love Chinese food but this post isn’t about Cashew Chicken or Chow Mein.  An article in Western Farm Press (and reposted by Food Logistics Magazine) mentions that China is now the 4th largest importer of fresh vegetables into the USA.  Not surprising really. Half of the fresh fruit and one-fourth of the vegetables consumed in the U.S. are imported. It’s not just produce either as 86% of the many types of fish we eat comes from other countries. What does this mean for food safety?

The story in Western Farm Press references Dr. Juan Anciso, a Texas AgriLife Extension Service horticulturist and food safety expert, who says “Assuring safe food supplies is increasingly important for fresh fruits and vegetables as state and federal governments eye legislation to regulate safety issues, both domestically and internationally, because of past outbreaks.”

Reduce Waste. Improve Quality. Get Traceability.

Dr. Luis Ribera, an agricultural economist at the Texas AgriLife Research and Extension Center at Weslaco, suggests that an inexpensive labor force and good growing conditions in China and other countries can lead to increased risk of contaminated food.  He was recently in China to discuss the new Food Safety Modernization Act (FSMA), signed into law last year by President Obama. “What this law basically says about imported fresh produce is that the importer/broker who imports fresh produce from overseas into the U.S. is now liable for that produce once it’s in the U.S.,” according to Ribera.

The new FSMA law sets food safety standards on production, harvesting, handling and packaging on all produce, including imports, Ribera said. Until now, such standards had just been guidelines. Ribera is working on a project that to measure the impact of FSMA on fruit and vegetable production in the USA, as well as any impact on produce imports.  He concludes that he suspects the new rules – many of which are still in development by the government –  will likely increase the cost of production for fruits and vegetables, both domestically and overseas.

He could be right, but it doesn’t have to be that way.  In fact, you can essentially get traceability solutions for free.  How?

A significant portion of produce goes to waste each year (Forbes says it is $35 billion.  A GS1 article says IBM estimates it closer to $458 billion.)  This waste is due to spoilage, as much of half of which can be attributed to improper temperature management across the supply chain – a challenge made worse by the longer trips associated with importing food from Asia or other parts of the world that can increase the risk of spoilage or food safety problems.  By implementing pallet-level temperature monitoring and management solutions you can significantly reduce the amount of food wasted in the supply chain and generate more revenue…more than enough to rapidly recover the investment in the solutions.  One case study we published showed that the customer was able to pay for the solution in a single growing season.  The beauty of it is that, along with reducing waste and shrink, the solution also automatically provides you with  traceability data.  It doesn’t cost extra…it’s part of the solution’s benefits.

You can learn more about how this works by clicking here or you can email me.

Kevin Payne

Senior Director of Marketing