Food Safety and Environmental Health Blog : Disease Prevention, Public Health, Sanitation Information & Analysis : Environ Health Associates

http://abcnews.go.com/US/mice-roaches-fda-inspecting-airline-food/story?id=17739284&page=4

I had the opportunity to help develop the above report, and review the findings of FDA inspections over the last few years at the nation's top air carrier caterers. The findings, as reported by ABC 20-20 are clearly indicative of lack of control over production environments, people and production processes, the very things food safety management systems are supposed to address.

The comments by industry are predictable. The "we didn't do it" philosophy, "head in the sand" approach is apparent, in spite of spin doctor statements. When you get caught with these types of issues, the public is not going to listen to the rhetoric about how great your food safety programs are, quite the contrary. Not one of these spokespersons would admit that their company had a problem or offer solutions, its all about denial. We see this again and again, especially after outbreaks.

The heads of these companies apparently are so disconnected from reality that they feel they can boast about how great their food safety programs are, even in the face of 1,500 FDA violations and many instances of gross sanitation conditions. Again, this is the same mantra we hear after an outbreak in FDA regulated facilities.

I lay much of the blame at the feet of FDA. This agency has the authority to stop such conditions and they opt time and again to walk away from problems and not take the tough stand that as consumers we expect, except in the most egregious of cases.

All we have to do is look at the poor record on FDA in the pharmaceutical compounding business or at Sunland (peanuts), or in the myriad of other outbreaks where the agency had performed inspections. No one is accepting responsibility, we get the same pathetic answers from FDA as from industry.

Taking a tough stand by inspectors is personally costly, it means confrontation, its perilous to careers and even to ones personal safety. I know this only too well, so I am very grateful to have an opportunity to again stand some ground against the food industry representatives who want to claim all is well in the face of mounting sanitation and health code violations and deceive themselves and the public.

This type of public confrontation is what we need to dispel the false sense of security the food industry and FDA has created for itself.

I applaud ABC 20-20 and all the other media who go to bat for the nation's consumers. This type of work is actually a preventive approach, as it pushes the issues in a way that compels both FDA and industry to respond, unlike third party audits and FDA inspections that occur behind closed doors.

I hope I have more opportunity to tell it like it is, and I hope the airline food industry is listening. I know they are hearing, but are they listening? Time will tell, but from the sound of their statements, I don't think so.

Despite that all of this has been said before, Bloomberg and the Today Show still think there is something to say about third party food safety audits, but they say nothing new. Of course, there are going to be outbreaks in facilities that have third party inspections. Just like there are outbreaks in facilities regulated by USDA, FDA and every county health department across the US. Why is that a surprise? Third party auditors are in almost every facility that should be inspected by FDA. Where is FDA? Do the agency and its inability to police the food industry share the blame for the situation? What about the thousands of facilities that do not have outbreaks THAT ARE AUDITED? It’s impossible to measure prevention…let’s see…show me the data on how many outbreaks didn’t happen? Hmmm.

All of these stories expose the weakness in the third party system, which I admit there is. As an auditor, I do not carry a badge, cannot stop production, and cannot close an establishment. I can even be constrained from taking pictures, samples and can be denied access to records and documents at the discretion of management.  I can only evaluate the questions on the audit template and only those that are in the so called scope of the audit.

Doug Powell asks for the data, and well he should, but he is not likely to get it since this data is proprietary. Audit companies are not going to publish the scores of auditees, and why should they? These audits are simply tools for the buying community to make purchasing decisions, not public health protection documents. If there is weakness in the system, it is that retailers will buy from anyone, and simply hide behind a smoke screen of due diligence, putting the burden of food safety on the supplier, while the buyers themselves are free to scour the markets for the best price and ignore food safety.

And forget the scores, there are so many questions that the points do not always indicate the real level of risk, but buyers and retailers do not read the reports, they simply go by scores. In my opinion, the buyers need to be educated because few if any of them really know how to interpret the findings from third party audits.

Left to its own devices, due to the inability of our public health agencies to afford us food protection, the food industry has created a system it can live with. Such is the case with third party audits. No retailer is going to make the system so strict that it constricts the supply, or God forbid causes a shortage and prices rise. And there is the profit motive, as this article brings out, and not just at AIB. Remember, FMI the billion dollar voice of the food industry owns the most recognized GFSI scheme called SQF, and they are not alone- all auditing companies work for the industry and adjust themselves to the prevailing powers that be- to make money, that is business and just what you would expect from an industry driven concept. It is so naïve to think any other way.

If you want independent auditors who are not beholden to someone, then we better fund a righteous FDA and keep the political honchos in Washington away from the inspectors. It can’t be done either-so there.

So now what?

More outbreaks, more tragic deaths and more of the blame game; this nightmare is not going away just because the Today Show runs a story. The problem is that the microbes have become firmly entrenched in our environment and attack our food supply at will, and we seem to lack the ability to detect them or eradicate them. Our best hope is a huge infusion of scientists, science and technology into the food industry, but we are a generation away from seeing the beneficial effects, even if we start now.

So on we go with incompetent people running our food safety programs, basic hourly workers with no knowledge of chemistry or microbiology in charge of food safety in too many plants, coopted auditors, and poor little old FDA limping to the scene after some tragic event to tell us what went wrong. Pathetic.

Read on and try not to barf.

Show us the data, forget the faith; food sickens millions as company-paid checks find it safe

10.Oct.12

barfblog

Doug Powell

http://barfblog.com/show-us-the-data-forget-the-faith-food-sickens-millions-as-company-paid-checks-find-it-safe/

William Beach loved cantaloupe -- so much so that starting in June last year he ate it almost every day. By August, the 87-year-old retired tractor mechanic from Mustang, Oklahoma, was complaining to his family that he was fatigued, with pain everywhere in his body.

On Sept. 1, 2011, Beach got out of bed in the middle of the night, put his clothes on and walked into the living room. His wife, Monette, found him collapsed on the floor in the morning. At the hospital, blood poured from his mouth and nose, splattering sheets, bed rails and physicians.

He died that night, a victim of Listeria monocytogenes. Beach was one of 33 people killed by listeria that was later traced by the U.S. Food and Drug Administration and state officials to contaminated cantaloupes from one Colorado farm. It was the deadliest outbreak of foodborne disease in the U.S. in almost 100 years.

“He died in terror and pain,” says his daughter Debbie Frederick.

That’s how Stephanie Armour, John Lippert and Michael Smith begin their food safety and aduits and inspections opus for Bloomberg. The Today Show may run a version this morning, because I taped a bit for it at Brisbane’s Channel 7 studios last week.

About seven weeks after Beach started eating cantaloupes, a private, for-profit inspection company awarded a top safety rating to Jensen Farms, the Granada, Colorado, grower of his toxic fruit. The approval meant retailers such as Wal-Mart Stores Inc. (WMT) and Wegmans Food Markets Inc. could sell Jensen melons.

The FDA, a federal agency nominally responsible for overseeing most food safety, had never inspected Jensen.

During the past two decades, the food industry has taken over much of the FDA’s role in ensuring that what Americans eat is safe. The agency can’t come close to vetting its jurisdiction of $1.2 trillion in annual food sales.

In 2011, the FDA inspected 6 percent of domestic food producers and just 0.4 percent of importers. The FDA has had no rules for how often food producers must be inspected.

The food industry hires for-profit inspection companies -- known as third-party auditors -- who aren’t required by law to meet any federal standards and have no government supervision. Some of these monitors choose to follow guidelines from trade groups that include ConAgra Foods Inc. (CAG), Kraft Foods Inc. and Wal-Mart.

The private inspectors that companies select often check only those areas their clients ask them to review. That means they can miss deadly pathogens lurking in places they never examined.

What for-hire auditors do is cloaked in secrecy; they don’t have to make their findings public. Bloomberg Markets obtained four audit reports and three audit certificates through court cases, congressional investigations and company websites.

Six audits gave sterling marks to the cantaloupe farm, an egg producer, a peanut processor and a ground-turkey plant -- either before or right after they supplied toxic food.

Collectively, these growers and processors were responsible for tainted food that sickened 2,936 people and killed 43 in 50 states.

“The outbreaks we’re seeing are endless,” says Doug Powell, lead author of an Aug. 30, 2012, study on third-party monitors called “Audits and Inspections Are Never Enough.” Powell, a professor of food safety at Kansas State University, says Americans are at risk whenever they go to a supermarket.

“You need to be in a culture that takes food safety seriously,” Powell says. “Right now, what we have is hidden. The third-party auditor stickers and certificates are meaningless.”

In some cases, for-hire auditors have financial ties to executives at companies they’re reviewing. AIB International Inc., a Manhattan, Kansas, auditor that awarded top marks to producers that sold toxic food, has had board members who are top managers at companies that are clients.

Executives of Flowers Foods Inc. (FLO), which makes Tastykake, and Grupo Bimbo SAB in Mexico City, which makes Entenmann’s pastries, Sara Lee baked goods and Wonder Bread, serve or have served on AIB’s board.

“There’s a fundamental conflict,” says David Kessler, a lawyer and physician who was FDA commissioner from 1990 to 1997. “We all know about third-party audit conflicts. We’ve seen it play out in the financial world. You can’t be tied to your auditors. There has to be independence.”

As flawed as the inspection system is in the U.S., it’s more problematic with imported food, especially coming from countries with lower sanitary standards, says Michael Doyle, director of the University of Georgia’s Center for Food Safety. In some emerging markets, farms growing food for export to the U.S. aren’t inspected at all.

The U.S. will import half of its food by 2030, up from 20 percent today, Doyle says. Bloomberg Markets visited growers in China, Mexico and Vietnam and found unsanitary conditions for produce, fruit and fish exported to the U.S.

Auditors evaluate their clients using standards selected by the companies that pay them, says Mansour Samadpour, owner of IEH Laboratories & Consulting Group in Lake Forest Park, Washington, which does testing for the FDA. The auditors sometimes follow a checklist that the company they’re inspecting has helped write.

“If you have a program for adding rat poison to a food, the auditor will ask, ‘Did you add as much as you intended?”’ Samadpour says. “Most won’t ask, ‘Why the hell are we adding poison?”’

Not only has the government outsourced auditing to the food industry; the auditors themselves often outsource their vetting to independent contractors -- people over whom they don’t have direct management control.

While Primus Labs declined to comment directly for this story, it did supply a response from its law firm, Kaufman Borgeest & Ryan LLP in New York. Auditors, the statement says, serve at the pleasure of their clients and cannot go beyond what they are asked to do.

“Third-party auditing will continue to be as effective as those requiring the audits (buyers/suppliers) and the audited suppliers make them,” the law firm writes. James Markus, a lawyer representing Jensen, didn’t return calls seeking comment.

From the outset, the FDA lacked the resources to inspect all of the country’s food producers.

The food industry moved to fill that vacuum with private auditors in the 1990s. Danone SA (BN), Kraft, Wal-Mart and other companies created the Paris-based Global Food Safety Initiative in 2000 to write guidelines for third-party auditors.

The program, whose vice chairman is Frank Yiannas, Wal- Mart’s vice president for safety, requires companies to be audited once a year. It doesn’t mandate testing for pathogens. In 60 manufacturing plants, Wal-Mart suppliers reported a third fewer recalls in the two years after adopting GFSI standards, Yiannas says.

In some cases, companies use their own auditors to check suppliers. In 2002 and 2006, Nestle USA, a subsidiary of Vevey, Switzerland-based Nestle SA (NESN), refused to use Peanut Corp. of America as a supplier. Nestle inspectors found rodent carcasses and pigeons in Peanut Corp.’s Plainview, Texas, plant.

Nestle’s rejection didn’t stop Lynchburg, Virginia-based Peanut Corp. from doing business with other customers or seeking approval from third-party auditors. In 2008, AIB International auditor Eugene Hatfield gave Peanut Corp.’s Blakely, Georgia, plant a “superior” rating.

And there’s a whole lot more. Our take on all this is below:

Food Control

D.A. Powell, S. Erdozain, C. Dodd, R. Costa, K. Morley, B.J. Chapman

http://www.sciencedirect.com/science/article/pii/S0956713512004409?v=s5

Abstract

Internal and external food safety audits are conducted to assess the safety and quality of food including on-farm production, manufacturing practices, sanitation, and hygiene. Some auditors are direct stakeholders that are employed by food establishments to conduct internal audits, while other auditors may represent the interests of a second-party purchaser or a third-party auditing agency. Some buyers conduct their own audits or additional testing, while some buyers trust the results of third-party audits or inspections. Third-party auditors, however, use various food safety audit standards and most do not have a vested interest in the products being sold. Audits are conducted under a proprietary standard, while food safety inspections are generally conducted within a legal framework. There have been many foodborne illness outbreaks linked to food processors that have passed third-party audits and inspections, raising questions about the utility of both. Supporters argue third-party audits are a way to ensure food safety in an era of dwindling economic resources. Critics contend that while external audits and inspections can be a valuable tool to help ensure safe food, such activities represent only a snapshot in time. This paper identifies limitations of food safety inspections and audits and provides recommendations for strengthening the system, based on developing a strong food safety culture, including risk-based verification steps, throughout the food safety system.

http://www.bloomberg.com/news/2012-10-11/food-sickens-millions-as-industry-paid-inspectors-find-it-safe.html

http://barfblog.com/losing-my-religion-faith-based-safety-has-to-go-audits-and-inspections-are-never-enough/

http://www.bloomberg.com/video/toxic-food-can-the-fda-keep-u-s-consumers-safe-yk~bX~hPRSupw33re4cGvQ.html

Whilst I value the commentary of my friend and colleague, Doug Powell and agree almost 99% with his theory and thought, I have to question this aside at the conclusion of the story below.

Do we ask "who was the inspector" every time we have an outbreak in a regulated restaurant or meat plant? How is that relevant? 

The auditor or inspector is not in charge of food safety. As a profession, we are there to evaluate either conformance with a prescribed set of rules written by a buyer (in the case of an auditor) or compliance with laws written and enacted by government.

The findings are useful for improving an operation, and the findings may point to risks inherent in a process or product or facility, but the inspection or audit process may not necessarily uncover every defect, hidden hazards or those of such a nature that they cannot be readily discerned through visual observation or records review. In any case, breakthrough events do not invalidate either inspections or audits, nor do they undermine their value or negate the need to continue such.

On the other hand, we have seen obvious defects and unsafe conditions left unchecked by an auditor or an inspector, and then a subsequent outbreak occur. We have to ask why that happens, and I believe that reporting and observational biases are a challenge for both inspectors and auditors. The biggest prejudices that such an expert has are lack of knowledge, time constraints, failure to see the entire operation, pressure from the operator, invalid audit or inspection protocol, faulty inspection report or method used to evaluate risks, politics, business concerns and self interest.

These flaws potentially exists in every inspection or audit process and the extent of which they manifest will invalidate the outcome.

Therefore, it is important to ask more than just who an inspector was; it is much more important to look at the whole auditing and inspection process. I believe these failures are not so much the result of "who was the auditor" but how well the audit process was able to uncover issues, and of course how well the operation cooperated with the auditor and responded to concerns.

 29 sick with Salmonella linked to Trader Joe’s peanut butter; why is Penn. going public and others aren’t?
21.sep.12
barfblog
Doug Powell
http://barfblog.com/29-sick-with-salmonella-linked-to-trader-joes-peanut-butter-why-is-penn-going-public-and-others-arent/
Now would be the usual time for some consumer education group to issue yet another jackass advisory, this time about how consumers should cook their peanut butter, or choose it with care, or something else they have no control over.
It is food safety education month, don’t ya know.
The Pennsylvania Department of Health today advised consumers that Trader Joe's Valencia Creamy Salted Peanut Butter made with sea salt may be related to a multi-state outbreak of salmonella.
The department is working with the Centers for Disease Control and Prevention and public health officials in several states to investigate the outbreak. Nationally, there have been 29 cases of illness with two cases reported in Pennsylvania.
Trader Joe's has voluntarily removed the product for sale from its stores; however, consumers who have the product in their homes should discard it and should also be aware that this product is sold online through other retail outlets.
Additionally, the department advises anyone who recently consumed Trader Joe's Valencia Creamy Salted Peanut Butter made with sea salt and then became ill to consult their healthcare provider, local health department, or call the Department of Health at 1-877-PA-HEALTH.
Where did this peanut butter originate? Does hipster fave Trader Joe’s audit their suppliers? Who was the auditor?
Nothing yet on the Trader Joe’s website.
http://news.yahoo.com/pennsylvania-department-health-warns-consumers-discard-trader-joes-220200445.html
http://www.traderjoes.com
 

One of the hallmarks of protecting the fresh produce supply is a concept known as “buyer-driven” food safety controls. In the absence of regulations, the produce industry has been working under private standards drafted by the major buyers of produce, meaning the large retailers-the major supermarket chains. While the need to satisfy the retailer that foods supplied to them are safe, retailers themselves have been less than effective in ensuring that the people they commission to buy for them, their own “buyers”, only deal with operations with acceptable food safety systems.

This means that many, if not most retailers, will buy produce from firms that have not been verified by competent third parties or by the retailers themselves (second party verification), when it is opportune for them to do so. For a revealing piece on this issue see The Perishable Pundit:

http://www.perishablepundit.com/index.php?article=2667

The sad truth is that when buyers can get produce from a vendor at a cheaper price, the requirements for safety take second place.

Even worse, buyers utilize the unapproved firm as a lever to get the operator with a food safety system, and subsequently higher production costs, to lower their price.

Even small operations may invest hundreds of thousands of dollars in satisfying the strict rules of the Global Food Safety Initiative (GFSI). Often, firms must hire food safety personnel due to the overwhelming amount of self-inspection and paperwork involved. Laboratories and auditors must be paid for. Many times there are requirements for structural improvements and maintenance, chemicals to clean and treat water and many other similar costs to be borne day in and day out by suppliers. Thanks to the attitude of the major retailers, these suppliers cannot typically charge more for their products, and must absorb the costs as best they can while trying to stay competitive.

It is unfair to say the least that buyers for the major retailers would use the lower priced unapproved supplier as leverage to keep down their costs. Instead of rewarding suppliers for diligent efforts that not only protect the retailer, but public health in general, they are causing animosity; many conscientious produce operators are indignant at the current double standard, but the fear of losing customers precludes most of them from expressing their exasperation.

http://barfblog.foodsafety.ksu.edu/blog/155900/12/08/23/less-rhetoric-more-data-market-cantaloupe-safety-retail-so-consumers-can-choose

"Food safety culture" is a much used phrase and one preached to the supply chain by many of the world’s largest retailers. Retailers should be reminded that food safety culture begins at home, and such talk becomes a mockery in the eyes of the producer when retailers say one thing and do another.

Not all produce firms have had an opportunity to be qualified by third party accreditation under any private scheme, but the population of certified firms is growing, Part of the reason for the shortfall is that the auditing firms performing such audits are themselves overwhelmed and lack the necessary manpower.

In order to maintain pressure on the supply chain, the buyers for the major retailers have set deadlines for compliance, but then have to announce that another grace period or extension has been granted. Some relatively large producers of fruits and vegetables have just decided that the retail communities demands for conformance with third party food safety standards is a bluff and carry on business as usual; and they find most retailers are willing to buy their products anyway, on the basis of price and quality.

Lawsuits involving the produce industry cost retailers many millions, however, too many are seemingly willing to take a chance as long as the short term economic benefit is there.

I am sure the food safety experts at the nation’s leading retailers cringe when their buyers go outside the approved supplier list, yet the corporate decision makers do not always value a food safety department’s input.

Again, this is not “food safety culture”, when a firm puts short term profits over safety and public health; this is the antithesis-corporate greed.

Such business practices are undermining food safety efforts and causing many a bitter attitude among firms who have invested millions over the years to satisfy the demands of retailers, only to have their competitors flaunt such food safety efforts and prosper.
 

Fear Mongering or Facts, Plaintiff Attorneys and Social Media in Food Safety

The tort system has become the fulcrum for food safety in the absence of a credible public health response to foodborne illness. Nobody goes to jail in the US for even the worst food safety breaches, even those that result from gross negligence, but they do get sued, big time. FDA especially, has lacked the power to levy any meaningful penalties against offending firms, even ones that have released contaminated foods knowingly into commerce. The Parnells and De Costers rest in their immunity from prosecution after they poison thousands and killed innocent consumers with their tainted products, but they cannot escape the long arm of the plaintiff attorney. The complacency that has developed due to the liaise-fare attitude of government, turned to fear of lawsuits, has now hardened into an attack on plaintiff lawyers, the last recourse for injured parties.

With that as a backdrop, the story below reeks of a reactionary mentality. The suggestions that social media be used to spin food safety information and deter consumers from getting the facts they need during an outbreak will not get very far. The public is not so easily fooled.

I believe that firms that practice food safety and are committed to the principles of public health protection should tout their message.

But to play games with the access to factual information especially during an outbreak just reveals the shocking and desperate state the food industry is in.

Instead of manipulating social media, the food industry should be redoubling their efforts to stop the foodborne epidemic in this country and come clean with the American public.

US: Four ways plaintiffs’ lawyers leverage Google to stir food-safety fears
11.sep.12
Fast Company
Richard S. Levick
http://www.fastcompany.com/3001180/four-ways-plaintiffs%E2%80%99-lawyers-leverage-google-stir-food-safety-fears
Despite the fact that America’s food safety infrastructure is the most efficient and effective in the world, the International Food Information Council Foundation’s 2012 Food and Health Survey found that only 20 percent of Americans are “very confident” in food supply safety. At the same time, one in six U.S. consumers has stopped buying a particular food or beverage brand because of safety concerns in the last twelve months.
Given the rash of high-profile food recalls we’ve seen since 2007, the figure is understandable, even if it isn’t backed up by hard facts. Spinach, tomatoes, peanuts, lettuce, ground beef, and a host of other kitchen table staples all experienced significant incidence of contamination in the last five years. The resulting consumer anxiety got so bad in 2009 that Americans actually put their food safety fears on par with worries about the War on Terror.
That’s a compelling statistic--and it ought to make farmers and food manufacturers wonder if there’s something else that is contributing to Americans’ fear of food. Even at the 2010 height of salmonella, listeria, and E. coli outbreaks, the U.S. Centers for Disease Control and Prevention released data showing that only one in every 125 million meals served in the U.S. had the potential to make a consumer fatally ill. Science supports a conclusion that the food we eat every day is, indeed, safe. So why don’t Americans feel that way?
The answer lies in the fact that statistics can’t compete with emotion when it comes to assuaging anxiety. Numbers don’t move people the way that human drama does--and there are no more dramatic events in the food industry than when a person dies after eating something she believed was safe.
This facet of human nature explains a large part of the equation; but not all of it. There is another factor at play, and it manifests itself in the efforts of those with skin in the food-fear game. Food industry adversaries--the plaintiffs’ bar chief among them--understand how emotion impacts the marketplace. Even more troubling for the food industry, they understand how to manipulate digital and social media strategies to ensure their emotional appeals ring out in the marketplace.
By way of example, when we look at the circumstances surrounding the recent salmonella outbreak that killed two people, sickened 150, and originated at an Indiana cantaloupe farm, we see just how effective their efforts are at controlling the flow of information on food safety issues. In other words, we see just how good they’ve gotten at controlling search results on Google, the venue more people turn to for information than any other (digital or otherwise).
1.Plaintiffs control the keywords. As of this writing, a Google search for the term “cantaloupe outbreak” lists a law firm as the top sponsored link. A search for “cantaloupe lawsuit” returns six plaintiffs’ firm sites on the first page. Industry messaging on safety issues is nowhere to be found on the first page of either of these searches. Bottom line--on virtually every food outbreak issue, the plaintiff’s bar is masterfully controlling the dialogue on Google.
2.Plaintiffs dominate the blogosphere. When users click those links mentioned above, they are most often directed to blog posts that outline how the industry failed to keep cantaloupe consumers safe. While the posts provide plaintiffs with an important messaging venue, the blogs themselves ensure high search rank for the posts because they are sources of the frequently-updated content that attracts the Google spiders.
3.Plaintiffs use online video. A Google Video search for “cantaloupe listeria lawsuit” features two plaintiff-produced videos in the top three results. Just like the blog posts mentioned above, these videos don’t paint the industry as a responsible steward of public health. And as Google increasingly emphasizes the spoken word over the written one, these videos further optimize plaintiffs’ messaging.
4.Plaintiffs geo-target. As mentioned above, a Google search for “cantaloupe lawsuit” returns one plaintiff-maintained link. At the same time, a Google search for “cantaloupe lawsuit Kentucky” (one of the hardest hit states during the outbreak) returns two sponsored links. That tells us that at least one firm is targeting its efforts to the geographic areas where its messages will resonate most.
What all of this means is that the plaintiffs’ bar is operating in a virtual information vacuum when contamination strikes the food and beverage industry. “Within the legal community, they are simply outworking and outsmarting the other side when it comes to online communication,” says Bob Hibbert, a partner at Morgan Lewis & Bockius who has worked on number of high-profile food safety issues. “It’s clearly in the best interest of the food industry, and of the people who represent it, to mount a more effective response to this challenge.”
Fortunately, leveling the playing field doesn’t require any great strategic leap. Food manufacturers need to understand that the same tactics driving high levels of consumer anxiety can be employed to diminish it as well. Specifically, food companies should:
1.Own their risk terms and keywords. Plaintiffs’ keyword dominance exists because food manufacturers don’t own the risk terms that their consumers use to find information on the latest safety crises. While they likely optimize their Web properties for terms related to their products (“tomato,” “spinach,” ”cantaloupe,” etc.), they don’t do the same for terms such as “foodborne illness,” “recall,” “lawsuit,” or “outbreak”--and that enables the plaintiffs’ bar and other adversarial voices to dominate the conversation. At the moment an instance of contamination is discovered, food companies need to engage in Search Engine Optimization (SEO) and Marketing (SEM) campaigns that rank their response messages at the top of the list when their risk terms are queried. Even better, food manufacturers that do the same in peacetime not only eliminate the need to scramble when trouble arises; they create a compelling safety narrative that plaintiffs will have to overcome.
2.Address the blogosphere. Plaintiffs’ attorneys maintain blogs as a means to provide a steady stream of optimized content that keeps their messages front and center on search engines. They know that if they are active all the time, the Google spiders will elevate their sites when a food recall hits and it comes time to troll for class action clients. By blogging about all the ways they work to diminish the possibility of contamination, food manufacturers can also create the salient, frequently-updated content that ranks on Google when consumers seek information on food safety.
3.Engage via video. Food manufacturers that reach out to consumers with engaging video content not only provide themselves a leg up on the SEO front; they establish the emotional connections needed to bridge the safety perception gap. Articulating food safety statistics such as those cited above merely tells people their food is safe. Video shows them why they should consume with confidence. With video content that highlights safety procedures and the men and women charged with carrying them out, food manufacturers can powerfully articulate a commitment to safety that sticks with their audience. By going a step further with how-to videos that outline healthy food preparation steps, they can themselves take on the identity of true consumer advocates.
4.Be where the fear is. When an outbreak does occur, the companies at the center the problem--as well as those whose brands may be tarnished by mere association--need to target their messages to affected populations. Not only does geo-targeting streamline their optimization efforts by focusing resources where they are need most; it enables companies to directly reach the very consumers most likely to change their buying and eating habits as a result of a contamination incident.
Google is the portal by which consumers gain or lose confidence in products and services. As such, it is too important a venue for food manufacturers to cede to their adversaries. At a time when more than half of Americans are concerned about the foodborne illness, the industry has a compelling safety story to share. With strategies that enhance Web optimization, they can help ensure that a captive audience is there to hear it.
Follow Richard Levick on Twitter and circle him on Google+, where he comments daily on the issues impacting corporate brands.
Richard Levick, Esq., President and CEO of LEVICK, represents countries and companies in the highest-stakes global communications matters--from the Wall Street crisis and the Gulf oil spill to Guantanamo Bay and the Catholic Church. Mr. Levick was honored for the past three years on NACD Directorship’s list of “The 100 Most Influential People in the Boardroom,” and has been named to multiple professional Halls of Fame for lifetime achievement. He is the co-author of three books, including The Communicators: Leadership in the Age of Crisis, and is a regular commentator on television, in print, and on the web.
 

Bill Marler, arguably the leading legal mind in food safety today, is not pulling any punches when he points out the deficiencies at Jensen Farms.

www.marlerblog.com/lawyer-oped/should-brothers-ryan-and-eric-jensen-face-criminal-charges-will-producers-of-listeria-tainted-cantal/

The shocking truth is that the old ways of doing things in the produce industry must quickly come to an end. We cannot continue to hide from the truth. We should therefore be very worried about the future of the fresh produce industry, and do whatever we can to save it.

The following is my take on what it will require to satisfy any future due diligence defense, in the event that the unthinkable happens, again.

1.       Equipment design

All equipment that touches a produce item at any step of production must be stainless steel and NSF or UL approved, or equivalent, and otherwise meet the requirements for food contact surfaces as outlined by the USFDA Food Code. Any part of any piece of equipment that touches produce, whether the produce surface is part of the food, or is inedible, must be certified as safely designed. Existing equipment must meet the same requirements or must be dismantled and removed. This also applies to retail operations where produce is displayed handled and/or sold to the consumer.

Non-food contact surface of equipment shall pass equivalent qualifications based on a risk assessment.

2.       Facility design

Every facility that handles produce from the packing shed to the processor or cannery must be designed by a certified designer and pass a plan review process governed by a legal authority before construction. All such facilities must be inspected by a government entity and approved before operation. Existing designs must be brought up to standards immediately or cease operation. This also applies to the retailer.

3.       Potable water

Only water that has met the chemical, biological and radiological standards for potability may contact produce at any stage of the growing, harvesting, packing and processing chain. This includes the retail level. All water supplies used anywhere in the produce industry must be approved prior to construction. Existing systems must be immediately resigned or abandoned if they cannot meet such requirements

4.       Personal Hygiene

All persons handling produce at any step of the supply chain must be certified to be in good health on a frequent basis, and may not touch produce with bare hands. Adequate plumbed facilities that include approved waste disposal and hand washing must be provided anywhere produce is produced or handled.

5.       Food Safety Management Systems

Food safety management system that includes a hazard analysis of each step of production must be in place at any produce operation, with the controls verified and validated for effectiveness by a competent authority having jurisdiction. This applies to the retail level.

All produce must be treated to reduce pathogenic microorganisms to a safe level. Such treatments must be validated as safe and effective and included in an operations food safety management system. Such management systems must include a microbiological testing program for all water used, all surfaces touched by produce and the general environment, in process tests as well as end product tests to verify the effectiveness of controls, irregardless of the type of commodity. Such programs shall show the continuing absence of pathogenic microorganisms.  The application of the HACCP risk assessment concept as outlines by CODEX is mandatory to apply to all such testing program. Such risk assessments shall apply starting at the seed supplier level then proceed from the farm level through retail.

The retailer shall provide the same levels of safety controls and testing as his suppliers for products under his immediate control.

6.       Industry level food safety controls

No buyer shall purchase produce without first ensuring first-hand that the operation meets all the safety requirements as stated above. The use of third parties are only an option when the retailer pays for such service and the service is itself accredited by a competent legal authority who has enforcement power over both the third party and the buyer.

7.       Government level public health controls

No produce operation shall be allowed to operate without first obtaining an approval from a competent authority having jurisdiction. Such authority shall make frequent inspections of such operations as often as necessary to ensure compliance with laws and rules governing food safety and take the necessary action to protect the public when needed.

8.       Traceability

Every individual unit of produce shall bear an identifying code that at a minimum is traceable through every step of the supply chain. Such coding shall be maintained by the retailer so that in the event of a recall, the public will know exactly which producers and handlers are involved. This information shall be made immediately available to the consumer in the event of knowledge of a hazard or risk to public health.

9.       Transportation

Any means of conveyance of fresh produce shall be designed and operated according to these same requirements and under the control of a competent legal authority.

10.   Education and Training

No entity shall operate any produce type operation until all management level personnel can demonstrate knowledge of food safety, food safety management systems and HACCP through the taking of an accredited course of instruction and pass an accredited examination. No employee shall work with produce in any capacity without having taken and passed an approved food safety training program that includes the principles of HACCP.

11.    On farm risk assessment

No farming operation shall be used to grow produce for human consumption without first meeting the approval of a competent authority having jurisdiction. Such approval shall be based on a risk assessment that shows there is no reasonable threat to public health from any feature of the growing operation or surrounding environment

12.   Consumer Education

The produce industry shall fund, create and market the best practices methods for safe consumer handling of its products. The effort must be a national campaign and designed so that consumers know the unavoidable risks of eating fresh produce and the safety precautions they can take. Such campaigns will use current media, retailers shall make such educational materials available to consumers at the point of sale, and poll consumers to gauge the effectiveness of the outreach efforts and publish the results.

The verification of supplier food safety has emerged as a critical component of a retail operation’s Food Safety Management System (FSMS), but we continue to see Subway stress supplier safety while poor management of its own operations results in outbreaks of foodborne illness.

See Bill Marler's Food Safety News to learn how a Subway contributed to a community wide outbreak of norovirus gastroenteritis.

http://www.foodsafetynews.com/2012/07/sick-subway-employees-went-to-work-during-norovirus-outbreak/

In light of the costs borne by the supply chain to satisfy retail industries’ high standards for prevention, it is unfair for a firm as influential as Subway to have lax control over its own operations.  

It’s critical to have safe lettuce coming in the backdoor, but if an infected employee handles it, it negates all the costly prevention done upstream by suppliers. The revelation that this was allowed to happen creates animosity on the part of suppliers and undermines Subway’s own efforts at supplier control.

Subways’ food safety management system failed as the result of poor decision making; what we see here is the failure of food safety culture. Subway has an obligation to consumers who expect the company to be a supplier of safe wholesome food. Subway has an obligation to its suppliers to maintain the same vigilance over food safety they expect from them. By failing its obligations, Subway risks the reputation it has built, and the value of its brand.

As consumers, we should expect MUCH more of Subway. As food safety professionals, we should ask “what is the root cause of this failure” and “how best can Subway’s management solve the problem”.

To  post guest's articles, please contact rcosta1@cfl.rr.com

A Consumer Looks at Food Safety

 by Lauren Bailey

It’s a sad fact that many food safety hazards and issues are discovered by accident by a consumer. Consider any food safety scare from the last year: the Jensen Farm cantaloupes from Granada, Colorado, or the E. Coli outbreak in Europe, two huge stories that point to the overall fragility of consumer health and the hefty responsibilities of the food industry. Food safety is a chief concern among U.S. health officials precisely because it involves the entirety of the American people, and yet big mistakes seemingly occur every year.

As consumers, we largely have to assume that wholesale food producers know what they’re doing; we implicitly trust they are meeting regulation standards and that those standards are sufficient to ensure our safety. Every time we purchase of raw fruits and vegetables, when we pick up a cut of meat at the butcher’s, we do so on good faith that the food won’t harm us. But more and more often we hear stories that give us pause over our long-held faith in food. I think these popularized food safety issues are one of the greatest challenges facing the American consumer today.

Allow me to elaborate.

A New Headline Every Day

Whether it’s a story about “pink slime” in processed beef products or alarming BPA levels in canned goods, there’s always a new food scare driving the health section of popular media outlets. It’s enough to create a perpetual atmosphere of fear and distrust among many consumers. But the unfortunate truth is that these huge food scares usually revolve around a highly isolated incident—maybe a dozen people fall seriously ill over a certain contaminated good. But the backlash that follows the story will completely cripple any producer of that good, even if their facility was in no way involved in the food scare. People will understandably have a knee-jerk reaction to stories about potentially hazardous foods if they hear about it 24/7.

In the case of the Jensen Farms cantaloupe scare, with the ensuing listeria outbreak, people steered clear of anything having to do with the fruit for a good while. The infamous case of E. Coli and bagged spinach a few years ago severely hurt overall spinach sales, even though the outbreak was traced to specific producers and not to all spinach sellers. If consumers are told to be wary of a food, they’ll listen. But why is it that we get the most information about food safety from these isolated incidents, and not from the producers themselves?

More awareness in supermarkets

It seems to me that the first step to increase the average consumer’s awareness of food safety should be taken by food producers and distributors. Whenever you step into a supermarket, the only signs you’ll encounter will be those advertising the cheapest deals on goods. Or you’ll be met with a gaggle of products that exclaim their organic or whole grain components. Not enough grocery stores (nor the food items that they sell) warn consumers about the potential health risks of certain foods. The recent CDC report concerning the high sodium consumption of most Americans confirms as much, because the vast majority of us consume far more sodium than we would believe. We do this because it’s never completely clear how much sodium is in many processed or canned goods. We might be able to read the sodium levels on a product, but without a means to contextualize those numbers we won’t know what to do with them.

It’s the same case for any component of a food that’s detrimental in excess: fatty foods, sugary foods, highly processed foods all need to be much more clear about the health risks they pose to the average consumer. If the food industry doesn’t take steps to be more transparent about health benefits and risks of their products, then we can probably expect many more isolated food scares that probably could have been prevented.

By-line:

This guest post is contributed by Lauren Bailey, who regularly writes for accredited online colleges. She welcomes your comments at her email Id: blauren99 @gmail.com.