For 30 years, Food Quality & Safety has chronicled some of the most significant advances in food safety, particularly in the field of microbiology. These advances took place in the lab, in the field or in the factory, and were led by some of the most knowledgeable people of the time. They faced previously unknown challenges, chased unseen threats, and worked feverously until they found answers. More than anything, a handful of leaders in the meat industry had the vision to establish food safety as a noncompetitive issue, a tenet followed by the entire food industry to this day.
New challenges will always test our food safety systems, and the leaders of the past taught us that the programs and policies that protect food safety must be flexible and readily adapted to meet them. Challenges such as a rapidly changing food supply chain during a pandemic or addressing infant formula shortages due to reduced production caused by bacterial contamination were covered in FSMA regulations or overcome by cooperation with FDA. That’s not to say we are now perfect, but we’re learning more and more how to apply the core principles in critical food safety situations.
All experts aren’t created equal
As we acknowledge the leaders who came before, we must also acknowledge the real heroes of food safety. They aren’t named. They aren’t remembered anywhere. They are the thousands of frontline workers that practice food safety every day. They are the essential workers who showed up every day during the peak of the pandemic. They are also the select few who stepped up to work on the food safety team. The hours are tough, the manufacturing conditions are often brutal, but they stick it out and do the job. They ensure that policies and procedures are followed and don’t hesitate to report when something goes wrong. They care about protecting consumers and take pride in product safety.
FDA officials investigating the Jensen event found four strains of Listeria on dirty, corroded equipment, recently purchased second hand on the recommendation of an “expert.” Previously used for potato farming, the “equipment’s past use may have played a role in the contamination” according to the government’s final report. There was no clear evidence it was even cleaned before it was placed in the line. The use of sanitizer in the wash water, a process in use before this renovation, had been discontinued for some unknown reason. The fruit wasn’t being precooled, creating humid, damp conditions in the cooler that supported Listeria growth. This hardly sounds like an operation under the management of a food safety expert.
Jensen Farms declared bankruptcy in 2012 and, in 2013, charges were filed against the owners, who pleaded guilty to six counts of adulteration of a food and aiding and abetting. The owners also filed suit for negligence against the auditor hired to look at safety standards at their operations, but the work was assigned to a subcontractor, creating a conflict of interest. Since the subcontractor was involved in the renovations and operational changes that contributed to the outbreak, they never should have conducted the verification audit.
Sherri McGarry, a senior FDA adviser at the time, said: “We’re going to take these lessons learned, share that with our partners and industries, CDC and the states, and what we want to do is we want to really prevent this from happening in the future.” FSMA was signed into law in November 2011.
The Jensen Farms case is an extraordinarily sad example of bad expert advice and misguided good intentions. Most would agree that bringing in an outside party to assess your food safety program is a good idea, just as most would agree that a third-party audit is a great way to confirm that your operation is in good shape. But the owners in this case either failed to understand the most fundamental food safety principles, such as preventing cross contamination, the proper use of sanitizer, and the danger of dirty standing water, or they simply chose to ignore them. Certainly, the staff, if properly trained, would have noticed what the experts and owners missed. Clearly, using an expert does not replace the need for well-trained staff, or retaining a senior management that understands and supports product safety.
What’s in a training
FSMA’s preventive controls (PC) rules recognized the need for better training than previously included in HACCP programs. HACCP required a trained HACCP manager that signs off on the HACCP plan, and that’s about it, although it has added some requirements and modified some terms since FSMA’s release. The PC rules now require all personnel to be qualified individuals (QIs) for their assigned roles and require additional training for the role of a Preventive Controls Qualified Individual (PCQI). Unlike the role of HACCP manager, the PCQI must also interact with senior management to ensure the Owner, Operator, or Agent in Charge signs off on the food safety plan. This seemingly small change makes senior management wholly responsible for the plan’s content and effectiveness, and that’s a big change. In short, with FSMA changes and USDA updates, both regulatory branches only require a one-time training course for the most senior food safety staff, while holding management ultimately responsible for the programs’ effectiveness.
It’s time to finally acknowledge what we all know: The required training alone is insufficient to prepare personnel for the job at hand, and the job at hand can be far tougher than just writing and following programs. We know that these jobs desperately need to be upgraded to acknowledge the true value of the critical thinking skills required to perform them effectively. In short, to build the leaders of the future, we need to create a true career path from entry-level food safety to advanced-level program management.
Once a PCQI training certificate is obtained, its applicable to any food sector, another potential gap our future food safety heroes must consider. From produce to candy to beverages, it’s all one course. It does include the requirement for a moderate amount of ongoing professional development, but this requirement is yet to be tested.
The necessary food safety knowledge to develop additional training for today’s food safety personnel is readily available. What is currently missing is the experience and knowledge in the science of teaching and learning. There are many methods for training development, delivery, and validating content retention. I’m not suggesting everyone rush off to write more in-house training plans; that would be wasteful and redundant. But there is an opportunity to increase training budgets when presenting the food safety plan for management’s signature.
To attract new talent, entry level personnel need standardized programs that can be delivered by modern web-based platforms easily accessible to the target audience—programs that can verify user participation and track an individual’s progress over time and portable achievements that follow the individual across job changes. Those that devote their time and energy to improving their work knowledge and skills should be recognized for their efforts through documentable achievements universally recognized.
We owe it to our future leaders to share the knowledge and core food safety principles of the last 30 years so they can benefit from our collective past experiences. The food safety leaders of tomorrow depend on the proper development of the new employees of today.