161 | Auditing Outcomes - a Lost Art? | Learnings from a Salmonella Outbreak | Competition Winner |
Plus, a sneak peak at the unfinished Codex draft guidance for food fraud
Winner of the Food Safety Escape Room competition;
The lost art of auditing outcomes;
Learnings from a Salmonella outbreak;
Food Safety News and Resources;
Worst fast food launches (just for fun);
Food fraud news, emerging issues and recent incidents.
Hello, lovely readers,
I had a lot of fun making the food safety escape room for last week’s issue so it was pleasing to hear that you enjoyed it too. Thank you for your entries.
Welcome to Issue 161. This week I share an opinion on how food safety standards have shifted from specifying outcomes to a more prescriptive approach, plus insights from a Salmonella outbreak investigation. And a selection of terrible fast foods.
And of course, I announce the winner of the competition.
In food fraud news, I have a copy of the unfinished Codex draft guidance on food fraud prevention for paying subscribers, plus news of honey and one of the weirdest food safety adulteration incidents ever.
Enjoy.
Karen
P.S. If you know someone who would like this newsletter, please share it with them and help grow our community of food safety champions.
Food Safety Escape Room Competition Winner
Thank you so much to everyone who entered the competition last week.
Big apologies to readers in Australia, New Zealand, Oceania and Asia who received their newsletters in the middle of the night and therefore didn’t have a fair chance of being the first correct entry. I’ll make it up to you in the next comp, I promise.
On a more positive note, I’m thrilled (relieved?) that everyone got the handwashing question correct! Overall, 65% of entries were correct, well done everyone.
The winner is Susan W of Indiana, who submitted her answer just fifteen minutes after the newsletter was sent. Congratulations, Susan! Susan wins an exclusive food safety champion mug and stickers.
The correct combination to unlock the door of the virtual kitchen was: yellow spoon, blue glove, red sticker, green scourer and purple clipboard.
A few people stumbled at the rangehood, where the question related to basketballers with gastroenteritis. Nate pointed out that the symptoms and incubation periods for Salmonella and norovirus overlap.
The correct answer was norovirus, which is more likely to hit a group at the same time, with an incubation period of 10 to 51 hours and a sudden onset of symptoms compared to Salmonella’s incubation period which lasts from 6 hours to 6 days. Fish curry, being cooked and eaten hot, is also less likely to cause a foodborne illness than salad.
Sorry, Nate, I’ll be more careful to choose answers with no overlap next time.
🍏 Get all the answers and explanations here: Food Safety Escape Room Solution 🍏
Auditing outcomes – a lost art?
How food safety culture requirements got into standards
When I started in food safety 17 years ago, food safety standards were all about outcomes - the end results of processes, programs and policies. Auditors would check outcomes – “are things being done correctly?” - to determine whether a food company was complying with food safety standards.
If things weren’t being done right, the food business would fail their audit. If things were being done right, the business would pass. Simple!
For example, if an auditor observed front-line workers ignoring work instructions, that would give rise to a non-conformance against the standard. It didn’t matter why the workers were ignoring instructions. The fact is that things weren’t being done correctly and that was all the auditor needed to know. To avoid the non-conformance, the food company had to make sure instructions were followed, and it wasn’t the auditor’s business to check how that was achieved.
Things have changed. In the mid-2010s standards owners started to add extra requirements to their food safety standards in an attempt to address the why of food safety practices, presumably to allow them better control of the root causes of common non-conformances.
For example, BRC (now BRCGS) added a requirement that food companies that wanted to be BRC certified had to own a copy of the BRC standard. If they didn’t, they received a non-conformance against the new clause.
This new requirement was not about outcomes but rather about root causes. If a business did not have access to a standard then they were going to experience all kinds of headaches when trying to pass audits to that standard – missing documents, incomplete systems, misunderstandings about certification processes, and so on.
To me, it seemed a no-brainer that a copy of the standard was something food businesses should have if they wanted to pass. If they didn’t have it, they would likely get many non-conformances. Adding it as an auditable element, however, didn’t seem necessary.
Getting the basics right is important if you want to pass a food safety audit. Basics like knowing the standard you are being audited to, training your workers properly and having a positive food safety culture are absolute must-haves for making safe food and for passing audits.
But do these basic building blocks have to be listed in a standard if their outcomes are observable?
In the mid-2010s, standards owners like BRC apparently decided these ‘root cause’ requirements were necessary inclusions in their standards. Whereas in the early days of food safety it was assumed that a food business would operate with appropriate foundations for an effective food safety program - such as training for workers - by the late 2010s, specific requirements for basic elements like training had been added to all major food safety standards.
Food safety culture and its close relative senior management commitment are two requirements that used to be measured indirectly, by observing outcomes. For example, if senior management commitment was lacking, food safety systems would be under-resourced and auditors would observe failures in processes and documentation. If the food safety culture was weak, auditors would observe non-conformances like workers not complying with hygiene protocols.
These days, food companies are explicitly required to have formal systems for foundational aspects of food safety such as food safety culture – and have those systems audited – to be certified under food safety standards.
A company could have perfect outcomes from their systems –consistently safe food, good procedures and excellent compliance with internal protocols - but still fail to obtain certification because it lacks documentation for certain foundational aspects of food safety. We’ve moved from auditing outcomes to auditing root causes.
Is this a good thing? I don’t know. We do know that audits are getting longer and more expensive, with the costs impacting market access for small to medium food businesses. That can’t be a good thing.
On the other hand, global foodborne enteric diseases have declined significantly since 1990, which is fantastic. Unfortunately, it’s not possible to know how much of that decline can be attributed to improvements in companies with audited food safety systems.
We also know that GFSI-benchmarked certifications* result in a significant increase in labour costs for more than 80% of companies, as well as a significant capital cost in 50% of companies (Crandall, et. al. (2017)). At the same time, the number of food recalls has not decreased, since GFSI-benchmarked standards were introduced in 2000.
While I’m personally in favour of outcomes-based standards, rather than prescriptive standards, I acknowledge that prescriptive standards have benefits. For example, they can show food businesses and auditors what best practice looks like. They can also force businesses that might otherwise be tempted to cut corners to do the right thing, such as implementing basic requirements like training, and paying attention to formerly ‘invisible’ concepts like food safety culture.
Food safety culture is about attitudes, behaviours and priority given to food safety in an organisation. FSANZ
Food safety culture is one aspect of making food safely that used to be observed indirectly but is now measured directly in GFSI-benchmarked standards. Food safety culture systems now need to be formalised and documented for companies that wish to be certified.
This new requirement has been a pain in the neck for small and large businesses by increasing the documentation requirements of their food safety management system. Hopefully, it has also succeeded in making food safer for consumers.
Read more:
Crandall, P.G., Mauromoustakos, A., O’Bryan, C.A., Thompson, K.C., Yiannas, F., Bridges, K. and Francois, C. (2017). Impact of the Global Food Safety Initiative on Food Safety Worldwide: Statistical Analysis of a Survey of International Food Processors. Journal of Food Protection, 80(10), pp.1613–1622. doi: https://doi.org/10.4315/0362-028x.jfp-16-481 .
*GFSI-benchmarked certifications are certifications that confirm compliance to food safety management systems standards that meet certain requirements codified by the Global Food Safety Initiative, and which is a private organisation that represents the interests of a select network of 400 food retailers, manufacturers and “other stakeholders” from 70 countries.
In next week’s issue, I’ll share tips and tricks to help you create a food safety culture program that is both effective and successfully auditable.
Learnings from a Salmonella outbreak
An investigation report for a large Salmonella outbreak caused by contaminated bahn mi sandwiches in Vietnam was published recently.
I’m sharing it here because the reasons for the outbreak turned out to be entirely predictable, and absolutely confirm why basic hygiene principles like storing food correctly and hand washing are so important.
But more interestingly, the food outlet linked to the outbreak sells only one type of food and samples of the food were available for testing by the outbreak investigators. Because everyone who was sick had eaten the same thing, and because the remaining food had not yet been discarded, investigators were able to obtain more definite results than can be achieved in many outbreak investigations.
Background
A total of 547 people were included in the outbreak figures, with only hospitalised patients being included. Two patients had severe symptoms and one of those died.
All had eaten bahn mi, a type of sandwich, from a single outlet, a bakery in Dong Nai province. The bakery had been in business for more than 20 years, selling around 1,000 sandwiches every day, apparently without prior problems.
Banh mi is a Vietnamese speciality, made from a baguette bread roll filled with pate, Vietnamese pork roll, ham, pork, sauces and pickled vegetables. The pate, pickled vegetables and sauces were made on site. The other ingredients were purchased from a supplier.
The patients had symptoms including diarrhoea (90% of patients), abdominal pain (80%) and fever (65%). Approximately half of the 25 patient faecal samples contained species of Salmonella, and because symptoms and incubation times for the illnesses were characteristic of Salmonella, it was considered the causative agent for the illnesses.
Investigations at the food outlet
Investigators attended the food outlet, a bakery which sells only bahn mi, and discovered that raw and cooked foods were stored and handled in such a way that raw foods could contaminate cooked foods. They were prepared in adjacent areas.
There was no table or food storage shelf for use during sandwich preparation with sandwich ingredients put on the floor or in one of two cold stores. Gloves were not worn for preparation activities. The outbreak occurred at the hottest time of the year for Dong Nai province, with daily average temperatures of 37°C to 38°C (98°F to 100°F).
Two-thirds of the food samples obtained at the site, which included the sandwich ingredients pate, pork, ham, pickled vegetables and chicken eggs, were positive for Salmonella species. Half the samples contained coliforms, one-third contained Staphylococcus aureus and 17% contained Bacillus cereus. Samples were also tested for Listeria monocytogenes, Staphylococcal enterotoxins or Clostridium perfringens but results were negative.
Conclusions
The high proportion of food samples that contained Salmonella species, combined with observations of poor food handling practices indicate that cross-contamination was occurring between raw and cooked foods. Contamination may have been exacerbated by storing at-risk foods in too-warm conditions and direct hand contact with food.
Faecal samples from workers at the outlet contained Salmonellae species of the same serogroup as the outbreak victims and investigators say the outbreak could have been caused by an asymptomatic Salmonella carrier among the staff, combined with poor food handling practices.
Comments
Eight patients were admitted to the hospital on 30th April with similar symptoms. A rapid response team began investigating the next morning and discovered that all patients had eaten bahn mi from the same food outlet. By that afternoon, the business had been informed and had suspended its operations.
This swift investigation and response limited the number of illnesses - only people who had purchased sandwiches on 30th April or 1st May were affected.
An added benefit of the swift response was that sandwich ingredients were still available to investigators when they attended the food site. This allowed them to match patient symptoms with pathogens found in the food.
Takeaways for food professionals
Separating raw and cooked foods, keeping at-risk foods cool, avoiding hand contact with ready-to-eat food and practising good hand hygiene are cornerstones of food safety. When these rules are not followed, food becomes contaminated and people get sick and die.
In short: 🍏 The investigation into a large outbreak discovered poor food handling practices and a possible Salmonella-carrying food handler were the likely causes of contamination of bahn mi sandwiches that caused 547 people to require hospitalisation in Vietnam in May 2024 🍏 Raw and cooked foods were not adequately separated, direct hand contact with foods was occurring, and there was no table or food storage shelf for use during sandwich preparation with sandwich ingredients put on the floor or in one of two cold stores 🍏 Swift actions by health authorities and a rapid response to the initial 8 illnesses limited the number of people affected and allowed investigators to obtain samples of food before it was discarded 🍏
Source:
Tinh Huu Ho, Phuong Hoai Hoang, Ngoc, T., Minh Nguyen Dinh, Dong Do Thanh, Viet Nguyen Dinh, O Phan Van, Nguyen, P., Thanh Nguyen Quoc, Dinh, L. and Chinh Van Dang (2024). Large-scale salmonella outbreak associated with banh mi, Viet Nam, 2024. Western Pacific surveillance response journal, [online] 15(3), pp.36–42. doi: https://doi.org/10.5365/wpsar.2024.15.3.1168. Available at https://ojs.wpro.who.int/ojs/index.php/wpsar/article/view/1168/1200
Food Safety News and Resources
My food safety news and resources posts have no fluff, no filler, no ads, no promos, no junk, just expertly hand-curated food safety news from around the globe, brought to you each week. This week: two free webinars, a mustard declaration regulatory update, recall stats from the USA and reference doses for allergens.
Click the preview below to read.
Worst fast food launches (just for fun)
From black hamburger buns that turn your poop green to sweet coffee with buffalo-wings-flavoured sauce to Krispy Kreme donuts filled with ground beef ‘sloppy joe,’ this video collection of fast food launches is both intriguing and quease-inducing. “Their ultimate decision to pull the burger in 2010 quite possibly saved lives although imitators remain as proof of the meat mountain’s ghastly existence” (On the Grilled Cheese Burger Melt by fast food chain Friendly’s)
Below for paying subscribers: Food fraud news, research and incident reports
📌 Food Fraud News 📌
In this week’s food fraud news:
📌 A copy of the Codex Alimentarius’ Draft Guidelines On The Prevention And Control Of Food Fraud;
📌 Honey fraud in Europe explored;
📌 Pork and horsemeat adulterants in beef and chicken;
📌 (Unusual) Adulteration of fresh whole potatoes.
Codex draft guidance on food fraud prevention
In Issue 159 I reported on the progress of the working group that is developing Codex Alimentarius’ guidance for food fraud prevention. At the time I wasn’t aware that the draft guidance had been made public. Thank you to 👏👏 Hernan from Argentina 👏👏 who sent me a copy. Because I couldn’t track down its published location, I have uploaded the document to a webpage. To access it,
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