145 | 8 Food Safety Culture NCs (and how to avoid them) | A 'What-The?' moment with the US FDA |
145 | 8 Food Safety Culture NCs (and how to avoid them) | A 'What-The?' moment with the US FDA |
Plus, frothy milk fraud, peanut butter cups and a suspect salad
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(US) FDA’s comments regarding an ineffective recall of dangerous children’s food (what the?!);
Auditor perspective: Key non-conformances in food safety culture implementation (and how to prevent them);
Food Fraud Quick Bite: Frothy Milk;
Food Safety News and Resources;
How Reese’s Peanut Butter Cups are Made (just for fun);
Food fraud news, emerging issues and recent incidents
Hi everyone!
Welcome to Issue 145 of The Rotten Apple, where I explore the most common non-conformances in food safety culture implementation, complain about my tuna salad and ask ‘What-the?’ about the US FDA (again!).
Also this week, a small but perfectly-formed nugget of inside information about food fraud in milk, and a celebration of my favourite American candy, Reese’s Peanut Butter Cups.
This week’s food safety news and resources section is brimming with unusual outbreaks and strange recalls. This week’s food fraud news (for paying subscribers) has a detailed warning about a sometimes clandestine food treatment which is relatively new but is now reportedly widespread and an ‘open secret’ in the industry.
Thank you for being here,
Karen
P.S. If you love this newsletter, please consider upgrading to a paid subscription for just $10 per month. Subscription fees are vital to the future of this publication and help to keep it (blissfully) ad-free. Unsubscribe at any time.
Cover image: Milk seller in India. Image licensed from Bigstock
What the?! The US FDA and Dollar Tree Inc.
Comments regarding an ineffective recall of dangerous children’s food
The discount food retailer Dollar Tree, which distributed millions of units of lead-tainted cinnamon applesauce pouches to consumers in the USA, resulting in hundreds of cases of lead poisoning in children and adults, failed to completely remove the affected products from its shelves, says the FDA.
Public health officials in multiple states reported finding the lead-contaminated products available to purchase in Dollar Tree stores for “weeks and months” after the recall was initiated in October last year.
The FDA has issued a warning letter to Dollar Tree and provided a public update. Here’s what they said about the retailer’s failure to protect children from foods containing ‘extremely elevated’ levels of toxic heavy metals:
“Food safety is a shared responsibility that involves food producers, distributors, manufacturers, and retailers alike.”
… FDA’s much-too-gentle comment on Dollar Tree, Inc.’s failure to completely withdraw and recall dangerous food.
Right.
More on this incident:
Cinnamon-Apple-Lead Poisoning Update - The Rotten Apple,November 2023
Lead poisoning in children from (perhaps?) food fraud - November 2023
Other What-The moments from the past week
In more ‘What-the’ news, a company that makes confectionery containing undeclared psychoactive ingredients has been asked by the US FDA to recall some of their products after 23 consumers required hospital treatment. The company refused to recall the products.
“The FDA has asked the company to recall the implicated products, but the firm has refused.” - Food Safety News’ report on the outbreak
And an oversight office which reviewed the US FDA’s response to the 2022 infant formula Cronobacter disaster, in which at least two infants died, found “mission critical” failures and noted that “FDA did not have sufficient policies and procedures on how to initiate an infant formula recall under its FDA-required recall authority.”
Find more about these, plus links to all sources, in this week’s Food Safety News Roundup.
Auditor Perspective: 8 Key Non-conformances in Food Safety Culture Implementation
Food safety culture has become the source of many audit non-conformances since requirements for formal food safety culture systems were introduced to major food safety standards in recent years.
This post explores the sources of the eight most common food safety culture non-conformances and discusses strategies to avoid them.
1.Lack of understanding is the leading cause of non-conformances in food safety culture implementation. That is, the professionals responsible for the business’ food safety systems do not properly understand what is expected when it comes to food safety culture systems, and are unable to provide suitable evidence to show they are meeting the requirements of the standards.
Solutions: Review the wording of the standard to which your business is audited. Create a food safety culture procedure (SOP) that addresses each of the requirements in the standard. Ensure the procedure includes activities to collect evidence to support each of the requirements. Find and follow the guidance published by food safety standards owners. Review the GFSI white paper on food safety culture. Seek advice from other food safety professionals and get clarity from auditors about their expectations.
🍏 View our Food Safety Culture Training Session and Resources Page (for paying subscribers)🍏
2.Insufficient leadership from senior management is the second source of non-conformances with food safety culture requirements. This type of non-conformance will be raised if an auditor observes widespread, systematic problems arising from a lack of resources to deliver appropriate food safety outcomes. Other evidence of poor senior management commitment includes:
not enough food safety team members;
team members not having enough time to meet food safety commitments;
front-line workers and production managers making decisions that are detrimental to food safety to meet the demands of senior management;
senior managers not cooperating during audits, or demonstrating behaviour that does not support food safety, such as not following personal hygiene protocols in production areas.
Solutions: Ideally, senior managers should develop a genuine commitment to food safety, and then demonstrate this commitment to everyone else in the business by setting policies that prioritise food safety and modelling behaviour that supports food safety. Consider organising food safety training that is designed specifically for C-suite level executives. Management review meetings must include a review of inputs related to food safety culture and action plans for improvements – make sure these are regular agenda items.
3.Disconnects between levels, departments and shifts within organisations also give rise to non-conformances. This could take the form of sales teams seeking to override hold-and-release protocols to ship products to customers or production teams cutting corners with allergen-cleaning protocols to meet production targets. Auditors may observe that day shift operators are conscientious about following procedures properly, but operators on other shifts may not be so careful.
Solutions: Getting different departments and shifts aligned with respect to their food safety behaviours is a job for senior management, who need to demonstrate leadership across all parts of the organisation, and hold every department and shift to account. Food safety culture measurement systems, such as surveys, assessments and observational studies must be deployed across all shifts and levels, and corrective actions applied where gaps are found. Food safety culture-related concepts should be included in inductions for new employees in all departments.
4.Ambiguous and poorly defined objectives for food safety and food safety culture also lead to non-conformances. Food safety culture systems should be anchored in a food safety policy and food safety objectives that include clearly defined and measurable objectives. Where these are not properly defined, businesses will struggle to meet audit expectations. Auditors need to see evidence that the food business:
knows what a ‘good’ food safety culture looks like – for example – that consumer complaints or recall numbers are below a certain threshold;
can keep track of measurements relevant to food safety culture;
is working to improve its food safety culture.
Solutions: Review food safety policies and amend if necessary. Add measurable objectives to food safety culture systems, such as pass/fail rates in observational studies, or acceptable limits for results of worker surveys.
5.Lack of measurement data is another source of non-conformances. Measurable and well-defined objectives are needed for an effective and auditable food safety culture system. Once the objectives have been properly defined, data that measures the business’s performance against these objectives is needed. Without data there will be insufficient evidence to show that the food safety culture is effective, and/or improving over time.
Solution: Set food safety culture objectives and definitions that include measurable outcomes, as discussed above, and then keep records related to those outcomes. For examples and downloadable templates, see our Food Safety Culture Resources Page (for paying subscribers).
6.Lack of actionable data also leads to non-conformances. This type of non-conformance may arise if a food business is collecting or reporting data that is not directly related to the effectiveness of the food safety culture, and that cannot be influenced by improving the food safety culture.
For example, data on handwashing compliance is actionable, because the number of workers washing their hands correctly can be measured and improved if needed. Data from job satisfaction surveys, on the other hand, is less actionable with respect to food safety culture, because job satisfaction may not be directly linked to food safety culture, and improving the food safety culture may not improve job satisfaction scores.
7.Workers not following procedures consistently may also result in food safety culture non-conformances. In a business with a positive food safety culture, auditors expect to see consistent compliance with procedures such as record-keeping, PPE use and hand-washing.
“Despite our training efforts, we still have employees not following established protocols on the floor.” – Nearly three-quarters of respondents in an annual survey of more than 3,000 food and beverage companies and associated industries from around the world, agreed or strongly agreed with this statement.
Solution: Review any procedure that is not being followed and redesign it so it is easier to do. Ensure that workers not only know how to perform procedures correctly but also have the skills, tools and time to do so. Finally, explore whether workers have the motivation to follow procedures correctly each time, and if not, ensure they understand why it is important to follow the procedure correctly, by emphasising its role in food safety and the possible effects on consumers if the procedure is not followed correctly.
8.Lack of communication and/or feedback from employees to management gives rise to non-conformances because food safety culture is a two-way street and auditors expect to see evidence that employees are able to confidently share concerns and raise issues with management if needed.
Solution: Implement a system that allows employees to report food safety incidents, issues or concerns to management. Accompany that with a system for regularly collecting feedback such as a compulsory annual survey so that if there are no ad-hoc concerns, auditors can see that this is because such concerns do not exist, rather than not being reported.
Training: not the only solution
Finally, auditors report that many food businesses are stuck in a ‘training only’ mindset. That is, many companies think that more training will automatically lead to a better food safety culture.
It is not possible to improve food safety culture and pass food safety culture audits only by doing more training. Food safety culture needs to be modelled by senior management and appropriately resourced by the company. Workers also need to feel confident to work in a way that prioritises food safety, and feel safe in reporting and correcting food safety failures. It’s not just about knowing ‘how’ to make food safely, but understanding ‘why’, and being able to make the right food safety choices every day.
🍏With thanks to Jeff Chilton, VP Consulting for Intertek Alchemy, and FSSC 22000 Version 6: What the New Changes Mean to Your Organiszation (webinar), Intertek Alchemy (2024)🍏
Food Fraud Quick Bite: Frothy Milk
It’s one of the most common food frauds reported in (English language) international media: milk in India adulterated with detergent to make it look fresher and frothier.
Last week a former laundry detergent company executive gave us a rare insider’s glimpse into the practice of adding detergent to milk.
He recalled that he was told by his sales team that they would sell more detergent if it had a milder fragrance. The competitor’s product was selling better, they said, because it had a weaker aroma, making it more attractive to milk vendors who used it as an unauthorised additive in milk.
“Many years ago, I launched a new liquid detergent while working at a large company. One of the sales guys came up to me and said, he’d have sold lot more if the fragrance wasn’t so strong. I asked if he had got any consumer feedback on the fragrance. That was not the reason. He said a lot of people bought liquid detergents to add in milk. The optical brightener made the look whiter and the detergent added extra froth to the milk. The competitor had a product with a mild fragrance and was preferred by these people. I stopped consuming lassi, yoghurt from those markets after that.” Ram, entrepreneur, @ramprasad_c on X.com
Food Safety News and Resources
Our news and resources section has not-boring food safety news plus links to free webinars and guidance documents: no ads, no sponsored content, only resources that I believe will be genuinely helpful for you.
Heaps of stories in this week’s news, including a very unusual noodle recall and the suspension of GFSI endorsement for certain food standards.
Click the preview below to access it.
How Reese’s Peanut Butter Cups are Made
Like many non-Americans, I find a lot of American confectionery unappealing. One exception is Reese’s Peanut Butter Cups. Yummmm. Here’s how they are made:
Below for paying subscribers: Food fraud news and incident reports
📌 Food Fraud News 📌
In this week’s food fraud news:
📌 Beverage fraud modus operandi discussed;
📌 Fish fraud warnings (and a complaint about my salad)
📌 Horse meat alerts;
📌 Organic fraud, halal fraud and more.
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