Food safety in the news again – Purchasing failure or regulatory failure?

Two food headlines disappointed me the past two weeks; the first to grab my attention was “The Food and Drug Administration and the Centers of Disease Control and Prevention (CDC) and state and local officials are investigating an outbreak of Hepatitis A illnesses linked to raw scallops from the Philippines.” The second was “an outbreak of Hepatitis A caused by the imported frozen strawberries from Egypt has sickened 55 people in six states, the US Centers for Disease Control and Prevention said on Wednesday.”

In an interview with FoodQualityNews.com in 2013 and in an article in Food Safety magazine in 2014, I explained that not every container coming in to the US is inspected by the regulatory authorities. This means all food processors need to self-regulate their products. It is essential that the procurement team map and audit the supply chain on a frequent basis. As someone who has purchased seafood, it was necessary to visit the region, inspect the boats and factories. It was not uncommon to see modern stainless steel processing facilities with good manufacturing processes and sanitation protocol. It was also not uncommon to see old, rusty processing facilities with no protocol. It’s the same with the way the fish are handled on the boats. The unfortunate news is that not every buyer visits suppliers and limited audits occur.

In my consulting life, I have worked with many companies to build strategies for buying fruits, including frozen strawberries. The strawberry origins were Mexico and California. My advice was to visit the crop as it was growing and to be on hand when their products are being processed. In many cases the procurement team and their technical support intervened to assure the quality is achieved.

Too often low cost country sourced food materials provide attractive pricing, but they come with a big risk. It is never a good idea to source through third parties without building a map of the supply chain, auditing the supply chain and visiting the suppliers first hand. Many companies, unfortunately, will not fund such programs.

Since many food products are imported without regulatory checks, it’s up to the companies and procurement teams to self-regulate. The risks are many: reputation risk, creating illness and potential criminal charges if the company is known to have endangered lives.

Is it worth the risk?

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Lip Service and Promises don’t lead to Sustainability

Many corporations post in their news releases and annual reports that they embrace sustainability and corporate social responsibility. As responsible consumers, we invest in those corporations and buy their products. As we know, from companies like Chipotle, who truly think they are conscientious and are providing healthy food, if the investment in a sound chain of custody process and policy are not embedded, disaster may strike. A Bloomberg article on Chipotle highlights that the cost of building the right process will be very expensive and take a long time.

Monday, shares of Lumber Liquidators tumbled more than 19 percent after the CDC said people exposed to certain types of the company’s laminate flooring were more likely to get cancer than it previously predicted. The road to recovery will be very rocky for them for sure.

I have long said that companies need to implement a robust chain of custody process for their supply chains. To put it simply, the chain of custody is the unbroken path from the first stage of the supply chain to the end customer. The chain of custody is a key area were food and other supply chains lack process, focus, procedure, systems and audit capability. Without it, they can be inviting regulation, which is not a desired outcome from the company’s perspective. Because there is no traceability from point-of-origin to point-of-consumption, it takes regulators a long time to reverse track the chain of custody when there’s an incident involving personal injury, illness or harmful chemicals found in the product. The chart below identifies a simple six-step process that companies should consider to identify, maintain and track the chain of custody.

Chain of Custody Process

To learn more about the steps, there’s a description in this article I wrote for Food Safety magazine.

The end result is that chain of custody requires systems, processes, audits, training and additional people to manage and document the chain of custody. The pharmaceutical and aerospace industries have perfected this to assure regulatory compliance. If the food and other industries fail to self regulate, the government will step in. Sadly, most companies are not willing to make the investment before a catastrophic event causes negative publicity, tanked stock prices and lawsuits; then it may be too late for the business to recover.

The days of lip service to sustainability and social responsibility will catch up to companies that cannot track their products through the supply chain.

Isn’t it time to make that investment?

Food Safety – Not as Simple as it Sounds

The unfortunate truth is that safety in the food industry supply chain still has a long way to go. No one likes burdensome regulations, but it’s hard to argue against them when we hear about blunders such as these:

• The Associated Press reported that Foster Farms, a California chicken farm was closed Jan. 8 when inspectors found cockroaches on five separate occasions in various parts of the plant over four months. The company says no chicken product was affected.
• A release posted on Reuters stated that New Zeeland’s Fonterra announced on Jan. 13 a recall of products that had been contaminated with E.Coli. It affected 8,700 bottles of fresh cream marketed under their Anchor brand. There have been no reports of illnesses so far.
• The Associated Press reported Northern California’s Rancho Feeding Corporation of Petaluma, Calif. recalled 40,000 pounds of meat products because it was produced without a full federal inspection. As of now, there are no reports of illnesses.

The U.S Food and Drug Administration (FDA) announced back in January of 2013 its proposed new food supply chain safety rules under the Food Safety Modernization Act (FSMA). After considerable input from food producers and consumer advocates,  the FDA’s most recent statement Dec. 19, 2013 indicates that it expects to issue revised rules next summer. Although they might show a retreat from some of the most stringent provisions of the FDA’s first proposals, the final rules are likely to require significant changes in how we bring food from the farm to the table.

I believe that unless the food industry self regulates and builds lot-control chain of custody processes like the pharmaceutical industry’s, greater regulation of the food supply chains is very likely.