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What Makes a World Class Food Safety Company – Elements of a World Class Food Safety Company?
Friday, 03 September 2010 08:21

Elements of a world class food safety company differentiate safety performance and provide leadership to the industry.  These elements result in best practices that are important to the industry if improvements are sustained in the supply chain.

Food safety is an important issue and just when you think that you have heard about one nationwide recall another major situation is reported.  More and more these recalls include basic foods that have been safely provided to the market for many years, generations and even centuries.  What has changed?  Why can’t improvements be made to eliminate the issues that continue to occur?

In the current legislative climate Food Safety has gone from a priority to less of a concern when compared to the other issues being addressed.  What is amazing about this situation is that safety reform has across the board support including, the public, both houses of congress, industry and the administration?  It almost appears that the system has forgotten how to address something that is so well and mutually supported?  As time moves on industry appears to be waiting for confirmation on the new regulations so they can make the necessary plans to more effectively deal with the anticipated changes; however, nothing is happing.

If we look at the food industry and the various market leaders as measured by financial success you really do not see a measure for food safety that is apparent as part of the key measures indicating performance.  Food safety typically is implied and both the brand and the perceived level of food safety compliance provide the public with the confidence that the food they buy is safe; however, is this enough?  Also, is the push for lower cost lowering the bar for food safety?  Do not take this incorrectly.  Far and away nearly all food companies especially in the US are concerned and strive to only provide safe food, but this market continues to undergo rapid change.

There has been significant quality focus on cars, electronics and other manufactured equipment and, as a society, appear pretty content with quality in these industries.  Periodic problems that do occur appear on a much less frequent basis than food concerns that we face.  While, no other product impacts the safety of the population more than food and water, the concerns only appear to be growing.  Indications are that despite technological advances, food safety is becoming more difficult to manage.  To fuel this concern the sourcing and processing of our food supply is only becoming more complicated and difficult to manage and regulate.

With the highly visible food safety issues there is a major concern of the population as shown in various recent studies.   What appeared to be satisfactory control of food safety in the past appears to be less adequate than the results in current times.

The many changes in the global market and culture have led to more variability in sourcing, processing, handling and storage of food, raw materials and ingredients.  The “field to fork” equation has become much more complex in a short period of time making the problems that exist more difficult to understand.  Part of the complication is that more and more of our base food, raw materials, packaging and ingredients are imported from a growing number of foreign countries.

So what needs to be done to ensure safe food or food safety?

One approach for the companies that are part of the food supply chain is to assess their organizational infrastructure.   Hopefully, the companies and individual employees that comprise these companies clearly understand that the primary goal is to provide the consumer with safe food product while realizing the economic return based on the quality, nutritional value and taste of the product.  A key is that each of these individuals are qualified for their job and responsibility, fit for work and appropriately deployed and supervised.

A good question is where do we start to improve food safety today?  Do you start with a product, recipe, raw materials, processes or regulation?  This begs the question “what comes first the chicken or the egg.”  A key element of every facet of the food supply chain is the use of the human resources necessary to complete each level of activity in an effective manner.  As with any other process or requirement the effectiveness is always based on the capability and performance of the people (human resources) involved.  Considering this importance of food quality, if you are going to design or re-design an organization to provide food safe product and services where do you begin to make the necessary changes?

As has been proven over and over again the likely starting point is the organization.  An incapable or immature organization cannot ensure quality even from a well designed process; however, a capable organization can do what is necessary to provide process and product quality even with an imperfect process.  Some of the questions related to the organization that need to be asked and addressed include what are the key roles, the capability, the experience and the management requirements.  If we compare these elements of an organization it is very apparent that a weakness in any of these areas results in a weakness to the entire organization and the ability to provide a safe product.  You would not want to assume that a food company without well defined roles or proper experience can provide safe food if they are not fully aware of their specific responsibilities or have not experienced all the conditions that can affect food safety.

For a food company participant to succeed in any parts of the food supply chain it must provide safe food products and services and still achieve necessary levels of return on investment and value.  The elements of a successful food company require an organization that encompasses some basics including, leadership, involvement, participation, process controls, deployment, experience, training, human factors and human capital.

Elements of a world class food organization include a number of general and specific competencies that can be defined by the food company’s structure, leadership, investments, assets, processes, procedures and utilization of human capital.  The organizational structural design elements of a food safe company include:

  • A well defined organizational structure to best ensure both food safety and financial performance based on critical mass of industry experience, knowledge and communication skills
  • Engrained leadership, roles, successful human factor deployment  and responsibilities within the organization to assign specific responsibilities and interactions to achieve food safety as well as business performance
  • Experience in completing the role responsibilities including direct work experience, verified knowledge, reporting capability, technical training and education necessary to provide the results that are necessary from each functional position to achieve food safety and business performance.
  • Management and management systems which provide leadership, plans, expectations, processes, information technology, rules, compliance, measures, human factors and data to ensure safe food and overall integrity.
  • Succession planning to ensure qualified back-ups at all levels of the organization at all times.

Food companies that seek to offer safe food and continue to improve their performance first need to review and understand the importance of a well developed organization and use of human capital if they are going to achieve 100% compliance and acceptable levels of performance and continued improvement.

How well positioned is your company’s organization and best use of human capital in all areas described and are there any weaknesses that could impact the safety of the food that you provide to the food market?  When unanticipated events occur can your organization provide the same food safe product as during normal operations?

At the time of this writing the US is currently faced with the largest “egg” recall in history of the US with more than 1500 people infected by Salmonella contaminated product.  Would better organizational deployment and management have made a difference to this company in providing safe food?  The obvious answer is yes; however, the industry and market need to change as well.  Food safety competition will drive food safe product.

Contact Kestrel Management if you or your company has any questions related to this information.  We support industry by reducing your enterprise risk in meeting safety within the food and food ingredient supply chain.  Our processes, dynaQ compliance system and human factors (HFit) will assist you in protecting the reputation and value of your company.  Kestrel Management is an industry leader and specializes in helping companies reduce risks, comply with regulations and maintain operating efficiencies.  Contact Kestrel Management at www.kestrelmanagement.com or the following email for more information.

Future blogs and articles will continue to expand on the key elements of a food safe company.

Bill Bremer, Principal of Food Safety, Kestrel Management Services, LLC @ This e-mail address is being protected from spambots. You need JavaScript enabled to view it

 
Recent Outbreaks and Recalls Perspective Related to Human Factors and Corrective Preventive Actions
Monday, 12 July 2010 00:00

In recent weeks contamination outbreaks and recalls by major US companies continue.  The companies are not named here; however, in these cases the companies represent some of the most trusted US companies in the Food Industry.  One is a fast food retailer with only the highest reputation for quality, another fast food retailer with the highest reputation for healthy food and the other the predominant producer of home prepared breakfasts.  In certain ways these companies represent the biggest and the best of the American and Global food industry.  These companies all are supported by supply chains going deep into the industry of suppliers from farm or factory to fork or consumption.  HOW CAN THIS BE HAPPENING?  And, what should the food industry take from these incidents to make improvements and reduce the potential of these situations?

These cases involve two interrelated issues.  One, Human Factors, affect every area of safety across all industries and many times are identified as a major cause of crisis situations (e.g. the plane crashed due to pilot error!).  Two, Preventive and Corrective Actions, which all organizations should practice and utilize to continually improve the safety and quality of operations and products.

The one fast food case did not involve a food product but did involve a “food contact” product that was offered in conjunction with food.  In this case the product was imported from China and included content that was susceptible to unsafe ingredients and known to be a “red-flag” in purchasing from China.  The company is known to have some of the best supply-chain and vendor controls in the industry and has practiced these supplier qualifications procedures since their founding and for more than 50 years.  What could have been done differently related to Human Factors and Preventive Actions?  It did not appear that the food contact product was subject to the same level of supplier and product approval as is applied to a food item.  Concerning Corrective and Preventive Action, the company should have initiated a corporate wide Corrective and Preventive Action based on the “red-flag” issues from China (heavy metal contamination of parts or inks) and revised its protective measures by updating policy and procedure to carefully validate supply and product content testing prior to approving the source and the particular product!

The other fast food case was a broad regional bacterial contamination causing illness over as many as 40 locations.  Again, assuming that the company has well established HACCP and testing plans for all fresh and prepared ingredients, what went wrong?  From a Human Factors standpoint the policies, procedures and control points used by a company are only as good as the people using them.  This includes internal personnel, suppliers and possibly consumers as well.  Concerning Human Factors, people in the food supply chain can become inattentive and not readily assume the responsibility of personal accountability.  For example, not paying attention and pushing the limits on temperature control throughout the supply chain can push fresh product to a point of high bacterial growth and a resulting outbreak.  This example might begin at the point of the washing, testing and passing of the food at the processing plant and subjecting temperature stress to the product in every step of the supply chain from the storage, shipping, consolidation to distribution.  All of the humans involved need to keep to the prescribed temperature and segregation controls if a safe food product is going to be delivered for final sale and consumption.  Concerning Corrective and Preventive Actions when dealing with fresh or prepared food, prevention needs to be well established throughout the supply chain to eliminate the assigned cause(s).  Vulnerabilities need to be determined and supply chain control points established.  With all of the current testing capabilities should and could the contaminated ingredient be subjected to low cost testing and approval prior to final distribution?  This could have helped to prevent distribution of a problem product.

The third incident involved distribution of a product with odor issues.  Causes and contributing factors are still being examined; however, there are numerous Human Factor and Corrective and Preventive Action concerns surrounding this food safety situation.  Human Factors in this case involves the supply chain operatives both internal and external to the company; however, this appears to be more internal.  How can Human Factors affect a well established group of products?  Typically, cases like this are due to either direct or indirect odor contamination.  A variety of sources can range from previous batches to maintenance situations to odor contamination of produced work-in-process goods.  All along the routing of production the processing and storage need to prevent odor contamination issues.  When changes occur that can impact the manufacturing process or product quality there needs to be proper reporting and ultimately a Corrective and Preventive Action.  This type of change identification and reporting is a critical step.  When reported, the Corrective and Preventive Action process than can be implemented to correct the current problem and reduce future risk.

Kestrel Management is a leading consulting and business services company serving the food industry and one of the foremost experts in the analysis and implementation of Human Factors practices and Corrective and Preventive Actions for industry .  To learn more contact us through our website at www.kestrelmanagement.com.

 
UPDATE ON THE “PROTECTING AMERICA’S WORKERS ACT”
Thursday, 08 July 2010 00:00

The OSHA Reform Act of 2010, also known as the Protecting America’s Workers Act (PAWA), seems to be gaining momentum through its connection to the Miner Safety & Health Act (HR 5663).  HR 5663, which was introduced in the House on July 1, 2010, seeks to improve compliance with mine and occupational safety and health laws, empower workers to raise safety concerns, prevent future mine and other workplace tragedies, and establish the rights of families of victims of workplace accidents

It is being reported that the Protecting America’s Workers Act will likely be rolled into HR 5663 to help passage of the following PAWA provisions:

  • Strengthening of whistleblower protections
  • Increasing criminal penalties where workers are killed
  • Increasing penalties for willful violations
  • Updating civil penalties
  • Preventing litigation from delaying the correction of hazards
  • Providing greater rights for victims and their families

The House Committee on Education and Labor has scheduled a full hearing on the Miner Safety & Health Act for July 13, 2010.

For more information about using leading and lagging metrics to improve the performance of your safety programs, please contact  This e-mail address is being protected from spambots. You need JavaScript enabled to view it at Kestrel Management Services.

 
U.S. SENATE CALLS FOR BETTER OIL & GAS INDUSTRY SAFETY OVERSIGHT
Wednesday, 16 June 2010 09:17

The Senate Committee on Health Education Labor & Pensions held a hearing June 10, 2010 on process safety management in the oil and gas industry.  Senators heard testimony from OSHA Deputy Assistant Secretary Jordan Barab (see Process Safety – May 24, 2010) who stated that the refining industry has shown a “significant lack of compliance” and that the same violations are showing up over and over again during OSHA’s Refinery National Emphasis Program inspections.

Barab used his time at the podium to endorse the Protect America’s Workers Act (PAWA), which would increase penalties on companies that violate safety rules; improve whistleblower protections for workers who report safety violations; and expand OSHA’s oversight to include thousands of workers currently not covered by the agency’s protections.  In addition, it would force oil companies to correct inspector-cited safety hazards before sending workers back on the job, even if the companies appeal those citations.  According to Barab, OSHA cannot currently force a company to fix the problems if the violations have been contested.  Subcommittee hearings for PAWA began in March 2010.

For more information about improving your safety programs, please contact This e-mail address is being protected from spambots. You need JavaScript enabled to view it at Kestrel Management Services.

 
Food Safety Modernization Act Senate Debate Update
Friday, 28 May 2010 00:00

Insiders report that the Senate’s Food Safety Modernization Act should be on the Senate Floor for debate in the next two weeks and is expected to pass with bi-partisan support.  Once approved the bill will go to the White House for executive approval and if/when approved the rule making process will begin.  Some of the questions that industry might be asking related to Food Safety Modernization Act include what level of food establishment will be covered by the law and what exceptions may exist.  Currently the law covers all facilities offering food to the US market.  Will this include USDA inspected facilities as well as small food businesses?  This is yet to be known and will be a key point of interest by industry.

Other key points of interest in the content of the pending bill include the timing of the new enforcement responsibility to cancel or suspend food facilities’ registration to offer food to the market place and the quarantine responsibility for concerned foods of concern being distributed to the marketplace.

Current Update-Breaking News 5/24/2010

Recall Update-May 2010 (Complete FDA)

May 2010

 


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