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Food Safety
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The Food Safety Summit brings together the food safety community to learn more about today’s most crucial elements of food safety—from regulatory concerns and current industry trends to ongoing challenges and the latest technology and solutions.
This year’s Summit, held earlier in May, proved once again to be an engaging and informative meeting for those in attendance. Throughout the Summit, KTL’s food safety experts observed several common themes and challenges that the food industry is facing — challenges that your business may be encountering today. We sat down with KTL’s attendees—Roberto Bellavia, April Greene, Estefania Lopez, and Joe Tell—to get their key insights from the Summit.
What technical topics were covered at the Summit? What seemed to gain the most interest from participants (i.e., “hot topics”)?
The Summit covered a range of content, including food safety culture, artificial intelligence (AI), HACCP, collaborating with regulators, microbial process control and sanitary design, sustainability, root cause analysis, e-commerce, state laws and regulations, viruses and pathogens in foods, food code adoption/harmonization, software, produce safety, and women in food safety. Of these, there were two particularly hot topics we heard about time and again this year: food traceability and cannabis.
Food Traceability. The implementation date for the Food and Drug Administration (FDA) Food Safety Modernization Act (FSMA) Final Rule: Requirements for Additional Traceability Records for Certain Foods (Food Traceability Rule) is January 2026. Impending deadlines have a lot of people talking, as many companies are starting to realize that having multiple software solutions to handle their food safety information is going to make complying with the new traceability requirements a nightmare. Having a robust document/records management system is essential for maintaining the vast number of documents required by regulations and standards, particularly the Food Traceability Rule.
Cannabis. There have been multiple instances of cannabis-infused products with unlisted ingredients falling through the cracks of regulations, creating potential negative impacts on human health and significant reputational issues. This, coupled with the recent information asserting the Drug Enforcement Agency’s (DEA) plans to reschedule marijuana from Schedule I to Schedule III under the Controlled Substances Act (CSA), is pushing many states to protect consumers of food and beverages infused with cannabis in the absence of federal guidance. State regulatory agencies are essentially playing a game of “whack-a-mole” with cannabis companies as they try to navigate where cannabis products fall: Food? Drug? Dietary Supplement? One regulator at the Summit stated that cannabis regulation is a modern day wild, wild west.
Are there any *new* food safety trends you heard about that companies should have on their radar?
There were several talks focused on sustainability at the Summit this year. The FDA, U.S. Department of Agriculture (USDA), and Environmental Protection Agency (EPA) released a joint strategy for reducing food loss and waste for organics in December 2023. They are working to create multiple pathways to make it easier for restaurants, farms, and manufacturers to divert good, nutritious food from landfills to food banks. The strategy also focuses on educating consumers, so they understand how to handle food waste in their own homes.
In addition, there were multiple conversations regarding the significant impacts of global climate change on the food supply chain. ISO’s recent Climate Change Amendments, as well as the Securities Exchange Commission (SEC) Climate-Related Disclosure Rule (which was recently stayed on March 15, 2024) continue to emphasize the importance of accounting for and managing climate change impacts. Companies are at a pivotal point where they need to make decisions regarding their sustainability efforts and how they proceed to meet regulatory and supply chain drivers.
You talked to a lot of different people and companies. What are some of the biggest challenges they are currently facing?
There is a lot of frustration amongst companies, federal regulatory authorities (e.g., FDA, USDA), and state regulatory bodies regarding regulations and guidance for emerging issues like new contaminants (e.g., pathogens, viruses, etc.) and security concerns not being addressed quickly enough. One example brought up during the Town Hall: Real-Time Conversation with FDA, CDC, USDA, and AFDO was the new strain of avian flu being found in raw milk. Because it takes time for testing to be completed—and then subsequent guidance to be created—companies are left wondering what to do about this risk. Most companies cannot very well just stop production during this window of uncertainty without significant impacts. During the presentation, regulators said they are trying to figure out ways to keep up with the speed of change and the associated risks that are constantly present in the food industry.
Lack of support and resources for those managing food safety programs remains an ongoing challenge for many organizations. It is not uncommon for a company’s food safety and quality assurance (FSQA) team/department to comprise only one individual. And while companies seem willing to provide information technology (IT) tools to help manage food safety requirements, many attendees expressed frustration with the lack of harmonization between the various IT solutions, making them ineffective and inefficient to use. See more below.
KTL presented on using existing Microsoft solutions to develop a food safety management system (FSMS). What role do you see IT solutions playing in the food industry?
As stated above, we talked with many companies that have purchased various software solutions with the expectation they would work together; in reality, many of these tools operate independently. As a result, companies are getting frustrated because they have invested time, money, and effort in these tools but have not realized business efficiencies.
There are significant benefits to implementing IT tools that “talk” to each other versus these siloed systems. As our presentation demonstrated, KTL focuses on leveraging Microsoft 365—which most companies are already using—to create integrated systems with various apps/tools that address specific FSQA and operational needs. This approach allows companies to manage various compliance and certification requirements, enables staff to carry out daily tasks and manage operations, and supports operational decision making by tracking and trending data more effectively and efficiently.
Given what you heard, what should companies in the food industry be doing now to plan for the future?
We walked away from the Summit with some key takeaways in some key areas:
Traceability. Companies throughout the supply chain will be impacted by the Food Traceability Rule—potentially even if they don’t have products on the Food Traceability List (FTL). Take time to understand the Rule requirements and how they apply to your operations and to train employees at all levels so they understand their responsibilities. This is an excellent time to perform traceability exercises for everything to help identify gaps, test protocols and verify effectiveness, implement corrective actions, and ensure adequate traceability processes are in place before the January 2026 deadline. It will be especially important to begin or renew communication with contacts throughout the supply chain to facilitate documentation, information sharing, and collaboration. Investing in a good IT solution that integrates with your FSMS will help to further streamline the process.
Cannabis. Companies getting involved in the growing cannabis industry need to stay on top of the rapidly changing regulatory environment. Assess operations, determine what standards might be appropriate, identify gaps in existing programs, prepare for a new regulatory framework—state and/or federal—and begin implementing solutions to eliminate risks.
Food loss and waste. We have all heard reduce, reuse, recycle from the EPA. Now the USDA, FDA, and various food safety certification schemes are holding companies in the food industry accountable for reducing food waste and preventing food loss. Before this becomes mandatory, companies should begin the process of identifying targets and associated methods for reducing food loss and waste.
Food safety outbreaks and recalls. Food safety professionals should be continually monitoring information regarding foodborne illness outbreaks. Companies can reduce their risks by staying informed about emerging food safety threats, identifying and assessing vulnerabilities in their facilities, implementing protocols to help mitigate impacts to consumers, challenging food defense programs by conducting intrusion tests, and developing a comprehensive Crisis Management Plan to manage human health and reputational impacts.
Produce safety. In July 2022, FDA extended the compliance dates for the pre-harvest agricultural water requirements for non-sprout covered produce. Covered farms are subject to the requirements of 21 CFR Part 112 Subpart E if they use water during the growing, harvesting, packing, or holding of covered produce in a way that meets the definition of “agricultural water.” If you fall under this category, note the new compliance dates, which differ depending on farm size:
- January 26, 2025: Very small businesses.
- January 26, 2024: Small businesses.
- January 26, 2023: All other businesses.
Companies receiving produce need to establish the criteria for information that will be requested from the farm upon delivery of produce, such as Certificate of Analysis (CoA). If conducting supplier audits for farms, include the requirements of the Rule into audit criteria.
With all these challenges and trends simultaneously competing for attention—and with fewer resources to manage it all—companies need to assess priorities, needs, and requirements and create a plan for how to meet them.