KTL is excited to be joining the 2022 Midwest Environmental Compliance Conference (MECC) as a featured presenter live and in-person in Kansas City, Missouri. MECC examines the new environmental reality under the Biden Administration. The conference takes a fresh, regional approach to the increasingly difficult task of environmental compliance, permitting, enforcement, and other critical environmental issues that impact Midwest facilities and institutions.

KTL’s presentions are part of the workshop’s technical agenda:

City of Lincoln Transportation and Utilities Compliance Management System: A Demonstration
September 13, 2022 | 10:00-10:35 a.m.

See how the City of Lincoln, NE Transportation and Utilities Department is leveraging Microsoft 365® to build regulatory compliance management tools that help track permit requirements and other compliance obligations. Features include requirements database, workflows with email notifications, status tracking, document and records management, staff communication / collaboration tools, and management reporting.

EHS Information Management System using Microsoft 365 and SharePoint
September 13, 2022 | 3:40-4:15 p.m.

Effective information management is critical to complying with EHS regulations, but many organizations lack the resources to manage, maintain, and demonstrate compliance. This presentation will demonstrate how Microsoft 365® and SharePoint® can be used as tools to create organizational efficiency and meet regulatory compliance obligations. KTL and Southeast Missouri State University will share the university’s SharePoint site and demonstrate how they are using the system to effectively manage EHS programs, including chemical management, air quality, and refrigerant management. This session will walk through features of SharePoint, provide tips to keep tools remain simple yet effective, and highlight how SharePoint can be expanded into an effective technology platform to ensure ongoing compliance.

First published in 1998, the BRCGS Global Food Safety Standard “provides a framework to manage product safety, integrity, legality, and quality, and the operational controls for these criteria in the food and food ingredient manufacturing, processing, and packing industry.” BRCGS was the first standard to be benchmarked by the Global Food Safety Initiative (GFSI) and has been adopted by over 22,000 sites in 130 countries.

Over the past 24 years, the Global Food Safety Standard has been updated regularly to reflect the latest trends in food safety and to encourage more widespread adoption. The latest version—Issue 9—was recently launched on August 1, 2022. According to the Standard, the focus for the most recent issue has been on the following:

• Encouraging understanding and further development of product safety culture.
• Ensuring global applicability, compatibility with the Codex General Principles of Food Hygiene, and benchmarking to the GFSI requirements.
• Expanding audit options to include the use of information and communication technology through a blended option.
• Updating the requirements associated with core product safety activities, such as internal audits, root cause analysis, preventive actions, and incident management.
• Providing greater clarity for sites completing animal primary conversion and producing animal feed.

Of important note, Issue 9 emphasizes two core themes: building core competencies and developing food safety culture.

Core Competencies

According to BRCGS, approximately 30% of nonconformances identified in food safety audits are related to what BRCGS calls “core competencies”. Core competencies are the basic elements and day-to-day activities that form the foundation of any food safety program. As audit results have demonstrated, many food businesses still aren’t getting the basic functions right when it comes to their daily work practices.

At its core, Issue 9 calls for more to be done to reduce nonconformances across the industry. The Standard believes the best way to do that is to improve and optimize the fundamentals (i.e., the core competencies). The requirements the Standard has specifically deemed “fundamental” include the following:

• Senior management commitment and continual improvement (1.1)
• Food safety plan – Hazard Analysis and Critical Control Points (HACCP) (2)
• Internal audits (3.4)
• Management of suppliers of raw materials and packaging (3.5.1)
• Corrective and preventive actions (3.7)
• Traceability (3.9)
• Layout, product flow, and segregation (4.3)
• Housekeeping and hygiene (4.11)
• Management of allergens (5.3)
• Control of operations (6.1)
• Labeling and pack control (6.2)
• Training: raw material handling, preparation, processing, packing, and storage areas (7.1)

Core competencies must not just be established, but they must also receive ongoing attention and improvements to conform with the Global Food Safety Standard. These core competencies are critical to creating a strong food safety culture—the second core theme of Issue 9.

Food Safety Culture

Food safety culture and its introduction into various certification schemes and regulations is a hot trend that continues to grow in importance. Artifacts of product safety culture have actually been included in the BRCGS standard since its inception in 1998, but food safety culture wasn’t added as a specific requirement until Issue 8. Issue 9 takes food safety culture to the next level with the requirement for organizations to put in place defined activities and behaviors—with defined timescales and measurements—to support the improvement of food safety and culture.

In Issue 9, food safety culture is now part of the fundamental section in 1.1 Management Commitment to ensure development and continuous improvement.  In addition, sites must have a Food Safety Culture Plan that requires, at a minimum:

• Clear and open communication on product safety
• Training
• Feedback from employees
• Behavior changes required to maintain and improve product safety processes
• Performance measurement on product safety, authenticity, legality, and quality-related activities

Next Steps

Sites currently certified globally to the BRCGS Global Food Safety Standard will have a transition period of six months to prepare their food safety systems to be audited against Issue 9’s requirements. Certification audits will commence February 1, 2023. In addition to the announced audit program (with mandatory unannounced audit every three years) and the unannounced audit program, which both remain largely unchanged since Issue 8, Issue 9 introduces a blended announced audit option that comprises a remote audit focused primarily on documented systems and records, followed by an onsite audit to review production, storage, and other onsite areas.

The next six months affords companies the time to assess current BRCGS Food Safety program elements; identify improvements that are internally desirable and required by the new Issue 9; and implement those updates that will create a strong food safety culture, improve core competencies, and reduce nonconformances with the BRCGS Food Safety Standard.

This can be done through a series of phases to ensure adoption throughout the organization.

• Phase 1: BRCGS Food Safety Internal Assessment – Review existing BRCGS food programs, processes, and procedures; document management systems; and employee training tools and programs to identify those need areas in need of updates, development, and/or implementation to meet the requirements of Issue 9.
• Phase 2: BRCGS Food Program Updates – Based on the assessment, develop a plan for updating the BRCGS Food Safety certification program, including major activities, key milestones, and expected outcomes. This may include updating/developing BRCGS Food programs, processes, procedures, and training with missing Issue 9 requirements and incorporating new food safety culture requirements (i.e., Food Safety Culture Plan).
• Phase 3: Training – To ensure staff are prepared to implement and sustain the updated BRCGS Food Safety program, staff must be trained on applicable requirements; specific plans, procedures, and good manufacturing practices (GMPs) developed to achieve compliance; and the certification roadmap to prepare for future assessments.

Following this plan now will help companies ensure they maintain their BRCGS Food Safety certification when assessments begin under Issue 9 in February 2023.

Safe + Sound Week

You have not had any injuries. You have an onsite safety professional. You don’t have any high hazard operations onsite. You have few employees. You mostly use contractors and temporary workers. Whatever your situation, you may think that having a third-party audit of your safety programs and operations is an added expense that provides no real value.

In reality, a third-party safety audit can provide a valuable means of supporting ongoing safety performance and compliance, even beyond what an internal audit might provide. A third-party safety audit has the following advantages:

• Objectivity: Enlisting a qualified outside firm to audit your safety program provides a fresh set of unbiased eyes to assess aspects of your program internal staff may not consider. Third-party auditors offer broad perspective and knowledge of best management practices from conducting audits across industries. They maintain ongoing, up-to-date awareness of current and pending regulatory requirements that the organization should consider.
• Customizable: The audits themselves can be customized to fit the needs and goals of the organization. A third-party auditor can provide more direct coverage to evaluate specific program effectiveness and allow for a more focused understanding of existing strengths and improvement areas. Whether there is a desire to prepare for unannounced regulatory agency visits, review plans and programs, or even verify applicability, third-party audits can be built to suit the organization’s identified concerns and risks.
• Efficiency: Audits performed internally can take resources away from normal business operations. Third-party auditors work with the resources (or lack thereof) allocated to them to conduct an audit in a timely manner that does not negatively impact business functions.
• Validation: Third-party auditors validate existing programs and identify areas where best practices can be implemented to further protect the company. They assist in identifying issues before they become violations and identify root causes of continuing issues—focusing on corrective actions to be implemented. They can also provide data and reports that can be shared internally with employees to improve safety performance or externally with communities or customers to bolster the company’s image.

Every safety program needs to be continually reviewed and assessed to ensure it is meeting organizational goals and compliance requirements. Building a relationship with a third-party auditor is one way for organizations that are committed to a strong safety culture to:

• Take their safety program to the next level.
• Keep employees safe.
• Further protect the organization from a risk and compliance standpoint.

Safe + Sound Week

Ralph Waldo Emerson famously said, “Life is a journey, not a destination.” The same could be said for safety. Workplace safety does not have a designated endpoint; rather, it is an ongoing journey—one in which new information is constantly being input, new technologies and innovations are constantly evolving, and employees are holding employers more accountable for ensuring a safe work environment.

Levels of Safety

How do you know where your organization falls on your safety journey? A recent webinar conducted by the Board of Certified Safety Professionals (BCSP) suggests organizations fall into one of four safety level that indicate the maturity of their safety program:

1. Safety is not a major concern. Organizations on this level do not take an active role in the safety of their employees; instead, they are reactive to events that may occur. Their focus is generally on maximizing profits and minimizing costs. They are not future-looking, nor do they invest money in safety. This is typically the level where you see organizations with the most expensive fines and the most potential to cause serious damage to workers and/or their equipment.
2. We do what is necessary to meet minimum safety requirements. This organization is still more concerned about costs over safety, so it is not significantly safer than an organization at the first level. That being said, the organization is at least meeting the bare minimum requirements, though blindly follows regulations just to avoid penalties. At this level, the organization will have only the required documentation and will not have a strong safety management system.
3. We take a proactive approach to safety. The organization focuses on safety aspects that apply to their operations, is actively looking at other organizations in their industry for best practices, and utilizes leading indicators to drive safety improvements. These organizations understand that safety is an investment and, even more so, that the safety of their sites has direct impacts on their bottom line. These organizations go above the minimum requirements and show concern for the safety of their employees.
4. Behavior-Based Safety (BBS) is in our blood. At the ultimate level, the organization understands how to help employees take an active role in their safety and actively encourages employees to exercise their rights to a safe work environment. In these organizations, employees are given positive reinforcement for actions taken to make the organization safer and are encouraged by management to watch out for each other rather than leaving the burden solely on the safety professional. There is an increase in morale, as safety is an integral part of the organization’s culture.

Moving Along Your Journey

Understanding where your organization is on its safety journey is the first step in creating a culture that embraces safety. This starts with assessing your safety programs, procedures, and policies; reviewing your safety metrics; and even surveying your staff to understand their attitudes about workplace safety.

As organizations move along in this journey, it is important to remember that a solid safety culture does not happen overnight. It takes ongoing work to build a robust and mature safety program where all employees contribute to a strong safety culture. And it takes ongoing work to maintain this culture, but the benefits are worth it:

• Fewer accidents, losses, and disruptions by preventing workplace injuries and illnesses
• Engaged employees and improved morale
• Increased productivity and enhanced overall business operations
• Lower workers’ compensation and insurance claims
• Improved compliance with OSHA regulations
• Improved reputation to attract new customers and employees and retain existing ones
• Better brand and shareholder value that tie to social responsibility

Where does your organization fall when it comes to safety? Where do you want it to be? And how can you get there?

Safe + Sound Week

Workers’ compensation is tied directly to an organization’s safety program in that it provides medical and wage benefits to people who are injured or become ill at work. A strong safety program can reduce the likelihood of injuries and illnesses. When fewer work-related accidents and illnesses occur, workers’ compensation costs also become less expensive.

Getting Audit-Ready

The world of workers’ compensation is complex. Each state has different regulations that establish what is required of an organization and what premiums apply. One commonality across the board, however, is the workers’ compensation audit, which insurance companies conduct to make sure coverage and premiums match.

The following tips can help your organization prepare for a workers’ compensation audit and, in turn, improve your safety performance and save money over time.

1. Inform yourself. Workers’ compensation audits are generally conducted within 35 days of when a premium is due or within 60 days of policy expiration. These audits are not done at random—they are mandatory. An auditor will contact the organization to send notice of the audit, which may be conducted via mail/email, phone, or field (i.e., in-person). When setting up the audit, it is important to ask, “What exactly should I have prepared to ensure a smooth and timely audit?” Carriers will gladly provide this information so the audit as painless and efficient as possible for all parties. Maintaining documentation is key, as organizations must provide the auditor with the information they request (i.e., employee, payroll, job descriptions) and ensure it is accurate. Not doing so is considered fraudulent activity.
2. Project your payroll. While it is hard to see into the future, it is important to make sure your projected payroll is as accurate as possible to ensure you do not pay for additional exposure at a higher rate.
3. Understand and expand your safety program. It can’t be emphasized enough—a strong safety program can reduce the likelihood of injuries or illnesses. Safety personnel should take an active role in understanding the workers’ compensation process, as there are important aspects of the safety system that can save the organization money if implemented correctly. Some of the important items that will be considered during the workers’ compensation audit may include:
   • Personal protective equipment (PPE) program and availability
   • Ergonomic evaluations
   • Safety audits (i.e., frequency and type)
   • Safety training
   • Return-to-work programs
   • Hiring practices (e.g., pre-employment evaluations, drug testing)
   • Injury response protocols
   • Medical evaluation programs
4. Maintain contractor control. Having proper contractor control protects an organization from potential safety risks on many levels. For workers’ compensation, this involves ensuring all subcontractors and contractors have certificates of insurance, proper safety programs in place for the work that they will be doing, training for their employees, and supporting documentation for all these items.

Workers’ compensation audits can be a useful tool in an organization’s arsenal to identify gaps in your safety program that could create additional risk. Having your safety program and associated documentation in place will not only prepare the organization for a workers’ compensation audit, it should also improve overall safety performance and save money over time.

Safe + Sound Week

When an organization expresses the objective to have a strong safety culture, definitions can vary widely among top management as to what that actually means. According to the UK Health & Safety Commission, a safety culture is “the product of individual and group values, attitudes, perceptions, competencies, and patterns of behavior that determine the commitment to, and the style and proficiency of, an organization’s health and safety management.”

A strong safety culture has a number of characteristics in common. An organization’s safety culture is ultimately reflected in the way that safety is managed in the workplace, including the actionable steps that should be taken to reach the ultimate goal.

The Science of Behavior

Implementing a Behavior-Based Safety (BBS) approach is one way to create a robust safety culture. BBS involves applying the “science of behavior” to change real-world safety problems. Essentially, BBS aims to increase safe behavior while reducing hazards and risks by examining the motivation behind the underlying behaviors of workers. BBS relies on complete trust and cooperation between every employee—from top management to operation-level employees—to be successful.

Cooperation means working together to develop a strong safety program (e.g., management involving line workers in creating safety policies and procedures). It means that management seeks feedback from workers about safety issues—and uses that feedback to make improvements. And it means that there is no blame when incidents occur. Incident investigations focus on fact finding, not fault finding. Trust in the safety program, in senior management, and in each other is built when each of these characteristics is present and treated as a company-wide priority.

Creating a BBS Program

The hallmark of BBS programs is their aim to provide effective feedback, reinforcement, and recognition to the employees to improve safety conditions in the workplace and increase situational awareness based on behavioral observations. The Health and Safety Authority (HSA) recommends following these eight steps to create a BBS program:

1. Create a team that will initiate the BBS program.
2. List targeted behaviors that are deemed unsafe. These can be taken from safety audits, near miss reports, toolbox talks, etc.
3. Create a BBS checklist that any employee can fill out completely when they observe an unsafe behavior. Behaviors should be:
   • Observable (i.e., seen or heard)
   • Reliable (i.e., witnessed the same way by more than one person)
   • Something the employee can control
   • Described in a positive way (i.e., what should be done vs. what shouldn’t be done)
   • Objective (i.e., not based on opinions or interpretations)
4. Determine the measurement system that can count the frequency of safe and unsafe behaviors.
5. Conduct behavioral observations.
6. Provide appropriate feedback depending on the behavior of the employees. Positive verbal feedback is a powerful way to reinforce safe behavior and a cornerstone of effective BBS. 
7. Use the data gathered from observing employees and make necessary changes.
8. Work with employees determine which behavior(s) or process(es) needs improvement.

BBS is an effective tool for involving all employees in creating a strong safety culture—one that employees will not only buy into but embrace as the way the organization does business. Done effectively, BBS creates the positive reinforcement, non-judgmental feedback, leadership influence, and an environment of trust that are all key characteristics of a strong safety culture.

Does your organization rely on BBS to support its safety culture?

Safe + Sound Week

Safety programs work when employees actively participate in them. According to the U.S. Department of Labor, they tend to work even better when employees are involved in establishing, operating, evaluating, and improving them. That is because employees know and understand the potential hazards of doing their jobs.

Top of the List

Many different organizations have conducted surveys on the top safety concerns for workers. The identified concerns often vary by industry due to the types of job activities performed. And, not surprisingly, some concerns align with the Occupational Safety and Health Administration’s (OSHA’s) Top 10 Safety Violations (e.g., trips, slips, and falls).

Regardless industry, there are similarities in some of the health and safety concerns employees have, particularly in those organizations with barriers to effective safety communication. Some of the top health and safety issues that are often overlooked by employers—and ones that don’t necessarily hit OSHA’s Top 10— include the following:

• Stress and distractions. The National Institute for Occupational Safety and Health (NIOSH) defines job stress as “the harmful physical and emotional responses that occur when the requirements of the job do not match the capabilities, resources, or needs of the worker. Job stress can, in turn, lead to poor health and even injury.” Long days, increased workload, and increased competition for workers’ attention can lead to lower productivity, more physical and mental illnesses, and the inability to anticipate potential hazards.
• Poor ergonomics. According to the Bureau of Labor Statistics, one-third of worker injury and illness cases are musculoskeletal disorders resulting from poor ergonomics. Workers across all industries are at risk of musculoskeletal injuries from things like repetitive tasks, lifting heavy objects, or working at a desk for prolonged periods of time without proper breaks.
• Spread of illnesses. One positive outcome of the COVID-19 pandemic is the increased awareness of the risks associated with spreading illnesses in the workplace. Workers are more cognizant of those with illnesses around them and, subsequently, are becoming less hesitant to call off work if they are feeling under the weather.
• Working alone. While working alone is common in many industries, that does not make the practice inherently safe. Working alone and/or without proper surveillance means workers are at an increased risk of serious injury with no one to call for help or to provide medical attention in the event an incident occurs.
• Temporary workers. With staffing shortages impacting nearly every industry, temporary workers are becoming more common. Unfortunately, temporary workers are the most likely to perform dangerous tasks due to inadequate training on job-specific hazards. This lack of adequate training is not only a risk to the temporary worker, but also to any permanent workers who work along side them. Workers are aware of the lack of safety-specific training for temporary workers and feel the responsibility falls unduly on to them.

Addressing Concerns

Not every employee feels safe to bring up safety concerns with their company. It is important that organizations have many avenues available for employees to bring forward issues they see in a way that is comfortable for them and without retribution. These avenues can be weekly safety meetings as a team, a monitored company email address, or even something as simple as an anonymous suggestion box. Giving adequate time to listening to employee safety concerns increases trust between workers and the company, shows leadership consistency, and aids in employee retention.

Can your company bear the cost of your employees’ concerns falling on deaf ears?

According to the Occupational Safety and Health Administration (OSHA), “Safe workplaces are sound workplaces.” An organization’s safety culture is ultimately reflected in the way that safety is managed in the workplace, and having a strong safety and health program can help create:

• Fewer accidents, losses, and disruptions by preventing workplace injuries and illnesses
• Engaged employees and improved morale
• Increased productivity and enhanced overall business operations
• Lower workers’ compensation and insurance claims
• Improved compliance with OSHA regulations
• Improved reputation to attract new customers and employees and retain existing ones
• Better brand and shareholder value that tie to social responsibility

These benefits are precisely why the OSHA created Safe + Sound as a year-round campaign: to encourage every workplace to develop, implement, and maintain a safety and health program.

Safe + Sound Week

One week out of the year—August 15-21, 2022—OSHA promotes a nationwide “Safe + Sound Week” to recognize the successes of workplace health and safety programs, offer information and ideas on how to keep America’s workers safe, and encourage America’s workplaces to commit to workplace safety and health.

OSHA recommends that every workplace have a safety and health program that includes the following three major areas:

• Management leadership. Management must provide the leadership, vision, and resources needed to implement an effective safety and health program. This means that business owners, managers, and supervisors commit to:
  • Making worker safety and health a core organizational value.
  • Eliminating hazards, protecting workers, and continuously improving workplace safety and health.
  • Providing sufficient resources to implement and maintain a strong safety culture.
  • Visibly demonstrating and communicating their ongoing commitment to safety and health.
• Worker participation. Engaging workers at all levels in establishing, implementing, evaluating, and improving safety and health in the workplace creates buy-in. Workers are a valuable partner in making the workplace safer, and maximizing participation (without risk of retaliation) allows everyone to feel invested in the program.
• Systematic approach to finding and fixing hazards. Finding and fixing hazards in the workplace is an ongoing process to better identify and control sources of potential injuries or illnesses. This can involve establishing procedures to collect and review information about known or potential hazards, investigating the root cause of those hazards, and prioritizing hazard controls. This continual process ensures that workers go home to their families safe and sound every night.

KTL’s Series on Investing in Safety

Throughout OSHA’s Safe + Sound Week (August 15-19), KTL will be featuring a series of articles and posts on our blog and social media (i.e., Facebook, LinkedIn, Twitter) reinforcing these concepts from OSHA and discussing why businesses should invest in safety. Topics will include the following:

• Where is your company on its safety journey?
• Top employee safety concerns and why they need to be heard
• Worker compensation audits, what to expect, and how you can save money
• Behavior-based safety – what is it?
• Benefits of a third-party safety audit

Watch for these articles! And for more information on Safe + Sound and what your organization can do to participate and promote a strong safety culture, visit https://www.osha.gov/safeandsound.

Get to know our KTL team! This month, we are catching up with KTL Marketing Director Stacey Pisani. Stacey has over 20 years of experience working as a communications professional exclusively in the areas of environmental, health & safety (EHS); food safety; and renewable energy. She has developed a comprehensive understanding of this subject matter that allows her to effectively add value to projects and turn technical information into meaningful content. She is based in our Madison, WI headquarters.

Tell us a little bit about your background—what are your areas of expertise?

I am originally from the Madison area and graduated from the University of Wisconsin-Eau Claire with a degree in communications and a minor in technical writing. While I do not have an environmental background, one of my first jobs after college was working for RMT, an environmental consulting firm. I found my niche and have remained in this industry for over 20 years.

I joined KTL in 2013 and currently serve as the company’s Marketing Director. My communications and marketing expertise spans all facets of internal and external marketing and communications, including executive communications, brand management, public relations, website design/management, digital marketing, social media, newsletter development, change communications, promotional campaigns, and copywriting/editing for various media. I also am heavily involved in developing proposals and working on a variety of training, reports, and deliverables for many of KTL’s clients.

What types of clients do you work with?

While a large portion of my time is spent working with KTL staff on marketing initiatives to grow KTL’s brand recognition and client base, I am fortunate to also work on projects for many of our clients in the areas of both EHS and food safety. This ranges from developing content for client publications, to writing procedures and policies, to creating training content, to reviewing various types of reports to ensure quality end products. I don’t interface with clients directly too often but enjoy those opportunities when I do!

What would you say is a highlight of your job?

I spend a good portion of my days writing, reviewing, and editing—all things I love to do. I enjoy the challenge of figuring out how to communicate most effectively some very technical and/or critical information. I am continually learning new things in my job, which is great after 20 years. And I get to work with most KTL staff on some level—I truly enjoy being able to interact with everyone in the office and in our remote locations.

What do you like to do in your free time?

My husband and I have two daughters who fill our calendar with lots of running around to gymnastics and dance. They keep us entertained! But when we aren’t in the car or at some sort of competition, I really enjoy working out, reading, theater, cooking/baking.

Read Stacey’s full bio.

Two years ago—on July 13, 2020—the Food & Drug Administration (FDA) published the New Era of Smarter Food Safety Blueprint, providing the roadmap FDA will follow to further food safety modernization under the Food Safety Modernization Act (FSMA). According to FDA, “Smarter food safety is about more than just technology. It’s also about simpler, more effective, and modern approaches and processes. It’s about leadership, creativity, and culture.”

This has remained the Administration’s focus as it has pushed its New Era of Food Safety forward to meet the Blueprint’s goals to:

• Enhance traceability
• Improve predictive analytics
• Respond more rapidly to outbreaks
• Address new business models
• Reduce contamination of food
• Foster the development of stronger food safety cultures

Progress to Date

For the past two years, FDA has focused on initiatives to support the four core elements identified in the Blueprint. Progress-to-date has included the following:

Core Element #1: Tech-Enabled Traceability. FDA has taken several actions to use technology to create food traceability advancements and reduce foodborne illness:

• The proposed Food Traceability Rule was published on September 23, 2020, as required under FSMA Section 204(d), to enhance traceability recordkeeping for certain identified foods beyond a limited “one-up, one-back” traceback approach. The final rule must be submitted by November 7, 2022.
• Twelve winning teams were selected in FDA’s Low- or No-Cost Tech-Enabled Traceability Challenge, which encouraged development of traceability systems that are cost-effective for food operations of all size. The winning entities are now working with FDA to disseminate their ideas to stakeholders.

Core Element # 2: Smart Tools for Outbreak Response. The Blueprint seeks to strengthen the use of data for root cause analyses and predictive analytics to prevent future outbreaks. Advancements in this area have included the following: 

• FDA conducted a pilot study designed to strengthen the ability to predict which shipments of imported seafood pose the greatest risk of violation. Results show that machine learning could increase the likelihood of identifying a shipment containing potentially contaminated products.
• FDA has increased the amount and quality of data through information sharing agreements with regulatory and public health partners, academic institutions, industry, and others. This includes domestic mutual reliance agreements signed with five states (i.e., California, Florida, Minnesota, Utah, and Wisconsin), which “provide opportunities for the FDA and state partners to lay a quality foundation for sharing information and working together on regulatory services and food protection that industry and consumers can trust.”
• In December 2021, FDA released its Foodborne Outbreak Response Improvement Plan, which sets the stage to “enhance the speed, effectiveness, coordination, and communication of foodborne outbreak investigations” through tech-enabled product traceback, root cause investigations, stronger analysis and dissemination of outbreak data, and operational improvements.

Core Element #3: New Business Models and Retail Food Modernization. As FDA has acknowledged, “The COVID-19 pandemic underscores the need for modern approaches as we respond to unique demands on our food system, from unprecedented imbalances in the marketplace, to changing consumer behaviors and a rise in e-commerce, to challenges to performing inspection and compliance work in FDA’s traditional manner.” Correspondingly, the Administration is considering how to address potential food safety vulnerabilities for foods ordered online and delivered directly to the consumer.

Core Element #4: Food Safety Culture. The improvements in food safety, foodborne illness, and outbreaks outlined above depend largely on food safety culture. Every action the FDA takes is intended to help create an atmosphere where organizations are aware of and help to prevent any process and/or operational issues and deviations that may impact the safety and/or quality of their food products. FDA also remains focused on consumer education regarding safe handling of food.

A Look Ahead

As FDA continues to push its New Era of Food Safety forward and new challenges surface, it is important to understand the current landscape, set priorities, and commit the appropriate resources to ensure long-term sustainability. Certainly, the COVID-19 pandemic has heightened a number of issues and unique demands on the food safety system.

As the Blueprint enters year three, FDA will continue to advance its core elements and goals. Companies that operate in the food industry should consider undertaking the following activities to align with FDA’s objectives:

• Implement a food safety compliance management system to help coordinate, organize, control, analyze, and visualize the information necessary to remain in compliance and operate efficiently.
• Conduct third-party assessments to provide an outside perspective of food safety systems and compliance/certification to identify gaps in programs that need development/updates.
• Explore technological advancements that allow for further digitization and promote more timely and accurate collection and management of important data.
• Gather/manage data and conduct root cause analysis, as needed, to identify underlying issues and ensure similar problems do not occur in the future.
• Build a strong food safety culture that focuses on changing from a reactionary to a preventive mindset that promotes safety and quality.