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What is The New Era of Food Safety? (Part 2 of 5)

by Eric Moore, Director of Food Safety & Industry Relations, Testo North America

Welcome back! In the last blog post, we set the stage for what the New Era of Smarter Food Safety is (new approach to protecting public health) and why it is a needed journey to reduce food related illness through modernization. It’s time to explore some of the specific activities FDA is planning to achieve the goal of a Smarter Food Safety system. I have decided to begin with looking at the New Business Models and Retail Modernization element of the plan for a specific reason. Unlike the last major FDA policy change (FSMA), Retail (grocery and foodservice) food safety has not been left out, and for good reason. As stated in the blueprint: “According to the Centers for Disease Control and Prevention (CDC), restaurants and other retail establishments remain the most common nexus of foodborne illness outbreaks”.

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The first part of this New Era Element focuses on New Business Models and how FDA can better support our rapidly changing environment of e-commerce, new delivery services, and emerging food ingredients and production innovations. In the short term (1-3 years), industry should anticipate more structure around time and temperature controls; tamper resistance packaging; and package level traceability information for meals/groceries purchased online and delivered directly to consumers. In the long term (say 3-5 years), FDA will be looking to streamline review and approval processes that will ensure product and consumer safety while not limiting industry innovations.

The second area of this New Era element; Modernization of Retail Food Safety Approaches focuses on adopting a new approach or “bending the curve” to reduce the number of foodborne illnesses. So, it makes sense that retail and foodservice are not left out since most food-related illnesses occur at this level. In the short-term, industry should anticipate changes to take shape as early as 2021 with the publication of the FDA Model Food Code. With the release of the New Era Blueprint and the 2018 release of findings from a multi-year FDA Retail Risk Factor Study, industry should be planning for the 2021 Food Code to include two key changes. One of these will be the addition of a Food Safety Management System to Chapter 2 – Management and Personal. Currently this concept is detailed in the 2017 FDA Food Code Annex 4 – Management of Food Safety Practices: Achieving Active Managerial Control of Foodborne Illness Risk Factors. A more user friendly version is also available in the FDA’s Managing Food Safety: A Manual for the Voluntary Use of HACCP Principals for Operations of Foodservice and Retail Establishments. This is also commonly referred to as Process HACCP, by which similar menu items are grouped into categories that all share the same control methods. Using this proven science-based food safety hazard control model then allows for more streamlined oversight of control points to encourage active managerial involvement. To briefly summarize the intent of this new requirement, it is easiest to summarize how Active Managerial Control (ACM) is defined. AMC is the purposeful incorporation of defined prevention-focused procedures into a business’s operating plan to control foodborne illness risk factors through monitoring and verification.

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Typical monitoring activities are broken into two basic categories: visual observations (e.g. pests) and measurements of physical parameters (e.g. temperature). Monitoring activities can also be completed intermittently or on a continuous basis, which FDA identifies as being preferred for monitoring a Critical Control Point (CCP) like temperature. Verification is the review of the monitoring activities to check that activities are being completed at correct times. In other words, it’s a written plan to control risk that includes defined limits and what actions are to be taken if/when those limits are not achieved.

This change will also support expanding the use of risk-based inspection processes. Businesses will need to submit a Food Safety Management Plan and inspectors will then use this information when inspecting the location. This will be somewhat of a change for portions of the industry that are accustomed to existing inspection processes that rely heavily on an inspector being on-site, making visual observations on processes and practices while also asking questions of managers and employees around key food safety procedures intended to be in place. Moving to a risk-based inspection process will enable the inspection process to be more efficient and effective, since the regulatory official will be able to better focus on verification of your defined control measures, monitoring activities and training processes.

All of this will provide a better picture to the regulatory official of the level of daily process controls. FDA will also be pushing industry (in some cases incentivizing digital adoption) to leverage digital tools and systems that automatically monitor key food safety risk factors (e.g. time and temperature, handwashing, health and hygiene, cleaning and sanitation). For example, a possible incentive to industry to adopt digital tools and systems could be a reduction in a location’s inspection frequency or risk ranking. There is still much work to be completed on this topic, but it seems to be a logical progression given the functionally of systems today that can effectively monitor and report on daily operational execution of established control measures as outlined previously for AMC of food safety risk factors. Be sure to tune into our next post where we will look at how FDA is planning to foster, support, strengthen and measure Food Safety Culture.
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