Blog

14 Jul
Managing Food Safety Risks in Warehouse and Distribution Centers

Recent recalls tied to contaminated warehouse conditions show how quickly an outside storage or distribution failure can become a brand, consumer safety, and regulatory problem for any company whose products pass through that facility. Food safety and quality are not limited to food manufacturers. When a third-party logistics (3PL) provider, outside warehouse, wholesaler, or distribution center (DC) stores regulated products under unsanitary conditions, otherwise compliant products can become adulterated after they leave the manufacturer’s control.

The reality is that once products enter an outside warehouse, the product manufacturer still owns the consequences of how their products are stored, protected, and traced, which is why managing 3PLs, warehouses, and DCs like any other supplier is so important.

Why It Matters

Many companies treat warehousing and distribution as downstream logistics functions rather than as critical control points in the food safety supply chain system. But there are clear ramifications from doing so. Storage, handling, pest control, sanitation, segregation, temperature control, inventory rotation, and traceability can materially affect product safety and quality. A product that was manufactured safely can still become contaminated, damaged, misidentified, or rendered unsuitable for sale during storage or distribution.

Outsourcing logistics does not remove responsibility. Brand owners, manufacturers, importers, distributors, and retailers may still face recall costs, customer claims, regulatory scrutiny, reputational harm, and business interruption if a third-party facility fails. Many consumers and customers will associate a third-party facility recall with the product brand, not the warehouse or DC where the failure occurred.

Key Risks Created by Outside Warehouse and Distribution Suppliers

Outside warehouses and DCs can introduce risk in several ways. The most prevalent is exposure to unsanitary conditions from pests, standing water, damaged packaging, poor housekeeping, inadequate waste management, or commingled storage. However, the risk profile is broader than sanitation alone and can include the following:

  • Inadequate product traceability or lot-level visibility.
  • Weak recall support or slow access to records.
  • Inadequate temperature control and missing or incomplete temperature records.
  • Improper segregation of allergens, chemicals, or incompatible products.
  • Expired inventory, undocumented rework, or relabeling activity.
  • Poor contractor oversight and insufficient facility security controls.

The highest risk facilities tend to be those that handle mixed-product categories, high-inventory turnover, small-lot distribution, damaged or returned goods, and products from many unrelated manufacturers. In these environments, one sanitation failure can affect hundreds (or even thousands) of SKUs and create a complex recall that requires coordination across multiple brands, retailers, regulators, and consumers.

Material and Measurable Impacts

Like any recall event, the consequences associated with a contaminated warehouse event may be significant for the warehouse, but also for the brand owner and product manufacturer. A recall can trigger product holds, expanded traceability exercises, customer notifications, disposal costs, refund obligations, transportation expenses, legal review, insurance claims, and lost sales. It can also expose gaps in supplier approval programs, recall plans, and crisis communication procedures. If the company cannot quickly determine which lots were stored where, when, and under what conditions, the scope and potential impacts of the recall may quickly expand.

Key Controls for Reducing Recall Risk

Companies using 3PLs and outside storage and distribution suppliers need to employ active oversight; a simple, signed service agreement is not enough. The strongest programs qualify storage and distribution providers before use, define expectations in writing, verify controls onsite, monitor performance continuously, test recall readiness, escalate early, document decisions, and requalify when risk changes—just as they would any other supplier.

The following actions can help to reduce recall risks and create a robust program to maintain warehouse compliance:

  1. Treat warehouses and 3PLs as critical suppliers. Include outside warehouses, DCs, fulfillment centers, and cross-dock operations in a formal Supplier Approval Program. Risk-rank them based on product type, storage conditions, regulatory category, geography, history, volume, and whether they handle mixed-product categories.
  2. Conduct structured due diligence and onsite audits. Before onboarding a 3PL, evaluate regulatory status, inspection history, certifications, insurance coverage, facility conditions, sanitation and pest management records, temperature-control capabilities, recall history, subcontractor use, and ability to support lot-level traceability. Audits should verify conditions directly; desk reviews are not enough.
  3. Require documented pest prevention and sanitation controls. Service agreements should require pest control maps, service records, trend reports, sanitation schedules, inspection logs, corrective actions, and evidence that findings are investigated and closed. Recurring pest activity, unexplained droppings, damaged doors, open dock gaps, or poor housekeeping should trigger escalation.
  4. Strengthen traceability and lot-level visibility. Manufacturers need to know which products, lots, and dates were stored at each facility. Ensure warehouse management systems support rapid retrieval of receiving, storage, movement, shipping, hold, and destruction records. If the affected lots cannot be isolated quickly, recall scope and cost will increase.
  5. Build recall obligations into supplier agreements. Agreements should define notification timelines, record access, product hold authority, communication responsibilities, destruction documentation, refund or recovery provisions, and cooperation with regulators. Companies should test these requirements through mock recalls involving the 3PL or warehouse supplier.
  6. Monitor performance continuously. Regular supplier oversight should include audit performance, corrective action closure time, pest activity trends, sanitation findings, temperature deviations, damaged goods rates, inventory accuracy, customer complaints, shipping errors, product hold events, regulatory findings, and mock recall completion time. These indicators should drive supplier risk ratings, audit frequency, and escalation requirements.
  7. Re-evaluate suppliers and maintain alternatives. Reassess 3PLs annually and when they add facilities, change ownership, expand product categories, increase volume, add subcontractors, receive regulatory findings, or experience contamination, temperature, traceability, or security incidents. Prequalifying backup suppliers can help support faster recovery if a logistics partner fails.

Key Takeaways

Warehouse and distribution controls are product safety controls. Outsourcing logistics does not outsource responsibility for product safety, traceability, or recall readiness. One sanitation failure at a multi-brand warehouse can create a complex, expensive, and highly visible recall. As such, brand owners need to manage 3PLs with the same discipline applied to manufacturers, ingredient suppliers, and other critical suppliers. The most effective programs are proactive, documented, risk-based, and supported by evidence to remove recall risk before it becomes a liability.

13 Jul
Tech Corner: Electronic Standards Register

Functionality: What does it do?

Certification standards help assure customers, suppliers, regulators, and stakeholders that an organization’s products, services, and management systems meet recognized best practices. These standards are not static. Requirements continue to evolve as certification bodies respond to new risks, regulatory expectations, sustainability priorities, technology changes, and global benchmarking requirements. These updates can quickly create gaps if requirements are tracked manually or inconsistently, especially for companies certified to more than one overlapping scheme.

Recent and upcoming updates to SQF, FSSC 22000, ISO 14001, ISO 9001, and other ISO-based management system standards make it increasingly important for organizations to maintain a structured, current view of the requirements that apply to them. KTL’s electronic standards register organizes certification requirements into an online tool, allowing teams to track applicable clauses, map supporting documents, assign responsibilities, and monitor version changes across multiple standards.

Benefits: Why do you need it?

KTL’s electronic standards register is more than a document management tool. It provides the framework for monitoring change, assigning ownership, documenting implementation, and demonstrating that the organization has evaluated and responded to new or revised requirements in a timely, controlled manner. This is especially valuable during standards transitions to ensure the organization is complying with the most recent version.

An electronic standards register:

  • Maps the organization’s documents to specific certification standard requirements.
  • Identifies common requirements and allows documentation to be linked between standards, as needed.
  • Maintains version control by tracking the current standard, upcoming revisions, transition deadlines, and changes that may affect procedures, records, training, and audit evidence.
  • Supports proactive gap assessments when standards are revised, helping teams identify where policies, programs, forms, and responsibilities need to be updated before certification audits.
  • Reduces the risk of missed updates when an organization manages multiple certification schemes, sites, departments, or document owners.
  • Helps the internal audit team to complete and keep notes for the internal audit.
  • Supports management review, internal audit planning, corrective action tracking, and communication across functions.

Technology Used

  • Power Apps
  • SharePoint
29 Jun
Visit KTL at the 156th Congress of Correction

KTL will be exhibiting at the American Correctional Association’s 156th Congress of Correction in Pittsburgh, PA, July 30 – August 2, 2026. The Congress features a wide array of workshops and sessions focused on cutting-edge topics for correctional facilities. The educational workshops feature the best in the business, passing on critical knowledge and engaging in important discussions, while the expansive exhibit allows attendees to interact with hundreds of companies serving the correctional industry.

Be sure to stop by and visit KTL at Booth #1106. We’ll be sharing more about our EHS, food safety, and Microsoft 365 information management solutions. We look forward to connecting with you in Pittsburgh!

22 Jun
Increasing Federal Attention on Microplastics

Microplastics have been found in every ecosystem on the planet—in food, beverages, and human and animal tissue. While scientists still do not fully understand the impacts of microplastics on human health and aquatic life, federal attention to microplastics is increasing.

EPA and HHS: A Coordinated National Strategy

In April 2026, the U.S. Environmental Protection Agency (EPA) and Department of Health and Human Services (HHS) made a joint announcement describing microplastics contamination as “one of the most urgent and growing public health challenges facing Americans.” The release announced major actions to study microplastics in drinking water and the human body, as described below. Together, these developments point to closer scrutiny, better testing methods, and possible future regulatory action affecting food companies, manufacturers, and other industrial sectors.

Historic Recognition as a Priority Contaminant. For the first time, EPA has included microplastics as a priority contaminant group in its Draft Sixth Contaminant Candidate List (CCL 6). The CCL is published every five years and contains a list of substances designated by EPA as potentially warranting future regulation under the Safe Drinking Water Act (SDWA). CCL 6 identifies contaminants not yet regulated but known or anticipated to occur in public water systems. The draft list includes four chemical groups, including microplastics, per- and polyfluoroalkyl substances (PFAS), pharmaceuticals, and disinfection byproducts; nine microbes; and 75 chemicals.

The inclusion of microplastics in CCL 6 is historic. It signals that microplastics are no longer viewed solely as an environmental pollutant but as a potential human health threat requiring scientific scrutiny, regulatory planning, and industry accountability.

Systematic Targeting Of MicroPlastics (STOMP) Program. As part of the coordinated national strategy to address microplastics, HHS’s Advanced Research Projects Agency for Health (ARPA-H) has launched the STOMP program. This $144 million national initiative is intended to measure, map, and remove microplastics and nanoplastics from the human body.

The STOMP program is the first federal effort aimed not just at environmental monitoring but also at understanding microplastics inside human tissues. Researchers have already detected microplastics in lungs, arterial plaques, and even the brain, yet measurement methods remain inconsistent, making it difficult to assess risk or design interventions. STOMP aims to change that by:

  • Identifying which microplastics are most harmful and how they move through the body.
  • Developing gold-standard detection technologies for microplastics in water and human tissue.
  • Creating safe, scalable removal methods, especially for vulnerable populations such as children, pregnant women, and high-exposure workers.

Focus on Food Safety

The Food and Drug Administration (FDA) continues to work on improving how microplastics and nanoplastics are detected and assessed in food. FDA has included microplastics as a priority deliverable under its Human Foods Program chemical food safety focus area, indicating that planned actions include research to improve the agency’s ability to accurately detect, quantify, and characterize microplastics in human food.

In light of this, food and beverage manufacturing, processing, and packaging companies should anticipate increased scrutiny of microplastic contamination across the food chain. Key implications include the following:

  • Water used in food processing may face new regulatory limits for microplastics, requiring upgraded filtration or monitoring systems.
  • Packaging materials, especially plastics that degrade into micro- and nanoplastics, may be reevaluated for shedding risk.
  • Seafood, salt, bottled beverages, and processed foods that already known to contain microplastics may become targets for new testing requirements.
  • Hazard analysis frameworks (e.g., Hazard Analysis and Critical Control Points (HACCP)) may need to incorporate microplastics as an emerging contaminant category.

Implications for Industry

Manufacturers in every industry, but particularly those using plastics, solvents, or high-shear processes, should prepare for the following:

  1. New Monitoring and Reporting Requirements. EPA’s CCL 6 designation signals that microplastics may become regulated contaminants. Industries that discharge wastewater or rely on plastic-intensive processes may face:
    • Mandatory microplastic monitoring.
    • Stricter discharge permits.
    • Requirements for new filtration or capture technologies.
  2. Supply Chain and Material Redesign. As STOMP identifies the most harmful microplastics, regulators may target specific polymers or additives. Companies may need to:
    • Shift to alternative materials.
    • Redesign products to minimize shedding.
    • Improve durability to reduce particle generation.
  3. Increased Need for Environmental Services. To meet potential regulatory changes, many companies may need to implement advanced environment solutions, including:
    • Microplastic sampling and analysis.
    • Remediation technologies.
    • Regulatory compliance strategies.
  4. Worker Safety Considerations. Microplastics have been detected in human lungs and arterial plaques. Industrial environments with airborne plastic dust may face:
    • Updated Occupational Safety and Health Administration (OSHA) guidance.
    • New personal protective equipment (PPE) or ventilation requirements.
    • Exposure monitoring programs.

Proactively Adapting

Microplastics are likely to remain a growing focus for federal research and possible future regulation. As EPA, HHS, and FDA continue developing the science, companies should expect stronger scrutiny, better detection methods, and increasing pressure to understand where microplastics may enter operations, products, and supply chains. Organizations that proactively adapt by assessing potential exposure points, improving filtration, redesigning materials, and monitoring microplastic exposure will be better positioned if (or when) monitoring expectations, customer demands, or regulatory requirements expand.

11 May
The Future of Food Safety Inspections Under BRIDGE

On January 23, 2026, the Food and Drug Administration (FDA) released its 2026 priority deliverables to further advance the Human Foods Program’s (HFP) vision and mission. As KTL reported, food inspection coverage is a critical deliverable under the Microbiological Food Safety focus area. Central to achieving this goal is the Better Regulatory Inspections for Dynamic Government Efficiency (BRIDGE) Project, a major initiative to modernize how domestic food facility inspections are planned, conducted, and coordinated nationwide. 

The BRIDGE Project represents a significant step forward in the Agency’s vision for a more integrated, data-driven, and risk-based food safety oversight system. So what does this all mean, and how does it change your facility inspections?

What Is the BRIDGE Project?

According to FDA, BRIDGE is intended to improve how inspection, compliance, and risk data are shared and used, and to better align inspection planning toward higher risk areas.

Historically, food facility inspections have been carried out independently by federal and state agencies. While this approach has helped to ensure oversight, it has also resulted in duplication of effort, inconsistent coverage, and inefficient use of limited inspection resources. BRIDGE seeks to address these challenges by creating a more coordinated system that leverages FDA’s state, local, territorial, and tribal (SLTT) partners.

BRIDGE builds on the principles of Domestic Mutual Reliance (DMR), where FDA and SLTT partners rely on each other’s inspections, regulatory actions, and data when programs are comparable. The intent is to further the Food Safety Modernization Act’s (FSMA) goal of an Integrated Food Safety System (IFSS) that emphasizes collaboration and shared responsibility across regulatory partners to protect the food supply.

Objectives of the BRIDGE Project

FDA has outlined a comprehensive set of objectives for BRIDGE, all aimed at improving inspection coverage while maintaining strong public health protections. These objectives include the following:

  • Expanding data sharing across federal and SLTT food safety programs.
  • Modernizing digital systems to support interoperability and analytics.
  • Applying risk-based approaches to inspection frequency and scope.
  • Coordinating inspection planning to reduce duplication and close gaps.
  • Leveraging federal and state expertise and regulatory authorities.
  • Testing and scaling new oversight and inspection models.
  • Aligning workforce training, funding, and performance measures.
  • Establishing a sustainable federal-state partnership model.

Together, these goals support inspections that are more responsive, efficient, and capable of targeting food safety risks that pose the greatest threat to public health.

How BRIDGE Works

BRIDGE takes an evidence-driven approach that allows FDA and its partners to refine processes before incorporating them into routine inspections and oversight as part of FDA’s commitment to an IFSS. Under BRIDGE:

  • Inspection, compliance, and risk data are shared across agencies to improve oversight consistency and identify systemic risks.
  • Inspection planning is coordinated so that federal and SLTT regulators are not inspecting the same facilities unnecessarily.
  • Resources can be scaled and redirected to higher-risk facilities or emerging issues when warranted.
  • New inspection and data-sharing approaches are tested in real-world conditions before being expanded.

What BRIDGE Means for Food Facilities

For food manufacturers and processors, BRIDGE does not eliminate inspections; rather, it changes how inspections may look over time. Facilities may experience:

  • More risk-based inspections, with higher risk operations receiving greater scrutiny.
  • Fewer duplicative inspections from multiple regulatory agencies.
  • Greater reliance on SLTT-led inspections conducted under FDA-aligned standards.
  • Increased use of inspection data and past compliance history to determine inspection frequency and scope.

Facilities with strong compliance programs may see more predictable oversight, while those presenting higher risk may be inspected more frequently or in greater depth. Overall, FDA’s goal is to increase inspection coverage and efficiency without compromising public health protections.

Phased Implementation Timeline

The BRIDGE Project is being implemented in three phases:

  • Phase 1 (June–September 2025): Initial planning and assessment of inspection approaches and infrastructure.
  • Phase 2 (October 2025–December 2027): “Proof of process” phase. Currently underway, FDA and selected state partners and co-regulators are testing new inspection models, data-sharing methods, and system readiness to inform future decisions and broader rollout during Phase 3.
  • Phase 3 (January 2028–December 2030): Planned national implementation of approaches that demonstrate improved coordination, efficiency, and inspection coverage.

By 2030, FDA expects BRIDGE to support a coordinated, data-driven model for domestic food safety oversight nationwide.

What Food Facilities Should Do Now

Although the BRIDGE Project is still being tested and refined during Phase 2, food facilities can take proactive steps today to prepare for a more coordinated, data-driven inspection environment in the future:

  • Monitor BRIDGE developments. Stay informed about FDA communications related to BRIDGE and its inspection modernization efforts. Track guidance updates, pilot findings, or changes to inspection models as Phase 2 progresses.
  • Strengthen food safety and compliance programs. Ensure food safety plans, preventive controls, and standard operating procedures (SOPs) are current and fully implemented. Address recurring observations/findings, as inspection history will increasingly influence risk-based inspection planning, and verify that corrective actions are implemented and documented.
  • Improve documentation and data readiness. Maintain complete, organized, and easily accessible inspection records, audit reports, and compliance documentation. A compliance management system can help ensure records are accurate and consistent across internal systems. Prepare for inspectors to rely heavily on historical compliance data when determining inspection scope and frequency.
  • Be inspection-ready at any time. Conduct periodic internal audits to identify gaps in food safety programs and compliance. Train staff to interact with state and federal inspectors, including knowing where records are kept and who is authorized to respond to questions.
  • Recognize the importance of risk-based oversight. Understand how your facility’s risk profile (based on product type, process, compliance history, and food safety performance) may affect inspection frequency. Proactively manage higher risk processes and products to reduce regulatory scrutiny.
  • Foster a strong food safety culture. Reinforce food safety expectations at all levels of the organization and promote continuous improvement, not just inspection-driven compliance.

An Evolution in Oversight

FDA’s BRIDGE Project represents an evolution in food safety oversight toward a coordinated, integrated system that uses shared data and risk-based decision-making. For food facilities, this means inspections will become increasingly targeted, data-informed, and aligned across regulatory partners.

As BRIDGE continues through the Phase 2 testing period, food companies should remain focused on compliance, documentation, and food safety culture, as inspection outcomes and shared data will play a growing role in how oversight is planned in the years ahead.

01 Apr
KTL Talks Food Safety, IT & Supplier Programs at the Food Safety Summit

Join KTL at one of the premier events in the food industry–the 2026 Food Safety Summit. The Summit offers a unique opportunity for attendees to learn real-world solutions from leaders in food safety and stay informed on the latest food safety trends, innovations, emerging challenges, and more.

  • When: May 11-14, 2026
  • Where: Donald Stephens Convention Center, Rosemont, Illinois
  • Who: Retailers, food processors, distributors, food manufacturers, growers, food service, testing laboratories, importing/exporting, law firms, and other food safety professionals
  • Find KTL: Stop by our booth (#501) in the exhibit hall or attend our Tech Tent presentation (details below)!

Tech Tent Presentation

Be sure to update your agenda to attend KTL’s Tech Tent presentation on Thursday, May 14 at 10:45 am CT:

Supplier Audits: Strategies and Tools for Better Results

A wider reaching and more complex global supply chain exposes our food to increased risks. Supplier audits are essential for identifying and mitigating those risks. Managing audit data, corrective actions, and supplier performance across a large supplier network requires standardized processes and data management tools to effectively verify food safety compliance.

This presentation will highlight strategies for strengthening supplier programs, reducing risks, and improving performance using supplier audits and centralized data management systems.

Attendees will learn:

  • How data-driven tools improve supplier risk prioritization and program efficiency.
  • The value of onsite second-party supplier audits.
  • Common supplier audit findings and how to address them.
  • How supplier auditing tools streamline audit management.
  • Ways to centralize and analyze supplier audit data.
09 Mar
To Be Released: FSSC 22000 Version 7

Food Safety System Certification (FSSC) 22000 is a robust Global Food Safety Initiative (GFSI)-recognized food safety certification scheme based on ISO 22000 that is applicable across the food chain (i.e., food/feed manufacturing, packaging production, transport, and storage). FSSC 22000 comprises three elements:

  • ISO 22000 International Standard (2018) – Specifies requirements for a food safety management system (FSMS) in alignment with the ISO Harmonized Structure.
  • Sector-Specific Technical Specifications (TS) (2025) – Requires organizations to establish Prerequisite Programs (PRPs) for specific sectors:
    • ISO/TS 22002-1: Food Manufacturing
    • ISO/TS 22002-2: Catering
    • ISO/TS 22002-3: Farming
    • ISO 220002-4: Food Packaging
    • ISO/TS 22002-5: Transport and Storage
    • ISO/TS 220002-6: Feed and Animal Food Production
    • ISO/TS 220002-100: Common/General Requirements 
  • FSSC 22000 Scheme Additional Requirements (2024) – Provides comprehensive additional requirements that build on ISO 22000 and sector-specific PRPs.

In early May 2026, Foundation FSSC anticipates publishing Version 7 (V7) of the FSSC 22000 Scheme Additional Requirements. Certified organizations will have a 12-month transition period to allow for effective implementation of the new version once it is published. Until V7 is released, FSSC 22000 V6 remains valid and will continue to reference the existing ISO/TS 22002-X series.

Key Updates

The updates to FSSC 22000 V7 are intended to better align the scheme with global requirements, improve clarity, and make food safety management more practical. Anticipated key changes include the following:

  1. Integrate with Updated ISO/TS 22002-x:2025 Series. FSSC 22000 V7 will incorporate the newly updated ISO/TS 22002-x:2025 series to ensure the FSSC scheme aligns with the most current global expectations for PRP implementation across food chain sectors. This includes a focus on taking a science-based approach to sanitation, hygiene, contamination prevention, and risk management.
  2. Align with GFSI Benchmarking Requirements. Aligning FSSC 22000 V7 with the latest GFSI benchmarking criteria will help to ensure FSSC certifications remain relevant and accepted across the global supply chain.
  3. Support United Nations Sustainable Development Goals (SDGs). FSSC 22000 V7’s strengthened requirements related to SDGs reflect growing industry-wide expectations related to sustainability, environmental responsibility, and social impacts. The scheme’s enhanced guidance is intended to help support organizations in their efforts to contribute to SDGs through responsible sourcing, reduced environmental impacts, and improved social responsibility.
  4. Create Clearer Food Chain Categories. FSSC V7 will implement a more defined and transparent structure for categorizing activities within the food chain to help organizations better understand which requirements apply to them, allow for more targeted implementation of food safety controls, and promote better compliance.
  5. Promote Continuous Improvement. Planned editorial updates will improve clarity and usability for certified organizations to make the FSMS more practical and easier to implement.

Planning for Change

For companies that are currently certified FSSC 22000 V6, now is the ideal time to assess current FSSC 22000 program elements, identify improvements that are internally desirable and required by the new standard, and implement those updates that will make the FSSC 22000 program more useful to the business and compliant with V7. This can be done through a series of phases to ensure adoption throughout the organization.

Phase 1: FSSC 22000 Assessment

An assessment should begin by reviewing the following:

  • Existing FSSC 22000 programs, processes, procedures, forms, and records.
  • Existing document management systems and document registers.
  • Employee training tools and programs.

This documentation review and program assessment will help to identify elements of the existing FSSC 22000 program that are acceptable, those that show opportunities for improvement, and those that may be missing, including those needed for development and implementation to meet the requirements of FSSC 22000 V7.

Phase 2: FSSC 22000 Program Updates

The assessment will inform a plan for updating the FSSC 22000 certification program, including major activities, key milestones, and expected outcomes. Development/update activities included on the plan may include the following:

  • Developing new or updating current FSSC 22000 programs, processes, and procedures with V7 requirements, including new procedures and PRPs to align with the ISO/TS 22002-x:2025 series.
  • Updating training programs with any new and additional requirements.
  • Revising document register to align with FSSC 22000 V7 numbering changes.
  • Updating records and forms with any new and additional requirements.

When implementing program updates, leveraging existing management system and certification program elements and utilizing proven approaches can greatly streamline the process.

Phase 3: Training

To ensure staff are prepared to implement and sustain the updated FSSC 22000 V7 program, training is important. This includes training for affected staff on applicable requirements; specific plans, procedures, and PRPs developed to achieve compliance; and the certification roadmap to prepare for future audits.

Following this plan now will help companies ensure they maintain their FSSC 22000 certification when audits begin under FSSC 22000 V7 to demonstrate their commitment to meeting customer and regulatory requirements, protecting the company brand, and keeping consumers safe.

23 Feb
Tech Corner Q&A: Supplier Management System

A wider reaching global supply chain exposes the products we consume—and those companies within the supply chain—to increased risk. A robust Supplier Management Program that leverages software, standardized tools, and data management practices can help organizations to more effectively audit, monitor, and manage supplier performance and program implementation and help ensure high-quality, safe, and consistent products.

We recently sat down with KTL’s Power Platform Team to talk about how organizations can leverage Microsoft 365 and the Power Platform to effectively manage supplier data and performance to improve overall operations. 

Q: What does a Supplier Management System do? What capabilities does it have?

Supplier management is about keeping vendors and suppliers organized and ensuring they meet organizational (i.e., internal), regulatory, and applicable third-party certification expectations. Supplier management may include supplier selection and approval, qualification review, contract negotiation, periodic evaluations, and documentation and records management.

KTL’s Supplier Management System is a custom tool built using Microsoft 365 and the Power Platform that streamlines how an organization approves and manages suppliers, helps control costs and reduce risk, and supports compliance with internal requirements and regulations (e.g., Food Safety Modernization Act (FSMA) Foreign Supplier Verification Program (FSVP) Rule).

KTL’s Supplier Management Systems:

  • Provide a checklist to ensure all vendors and suppliers meet required criteria (e.g., certifications, licenses, performance history).
  • Manage vendor and supplier-specific requirements.
  • Store and organize supplier documents and records; suppliers can upload their own documents in a secure folder (if external user access is allowed).
  • Enable facilities to conduct and manage supplier evaluations.
  • Provide verification procedures that close out evaluations and generate PDF reports.
  • Send email notifications of supplier-related compliance deadlines.

Q: What is KTL’s approach for designing and implementing a Supplier Management System? How do you work with clients?

We design every Supplier Management System with ease of use, compliance risk, and operational impact in mind, while being mindful of the organization’s pace and budget tolerance. We understand that every company works a little differently; as such, it is important that any Supplier Management System we design reflects how the organization operates in practice. Our goal is to create a system that fits the organization, fosters user adoption once implemented, and avoids the rigidity of one‑size‑fits‑all software.

KTL’s approach to building a Supplier Management System generally follows three main phases:

  • Planning: Our first step is to get a complete understanding of how the organization currently manages suppliers. We meet with key stakeholders to understand what’s working, what’s not, and what’s required to develop a robust Supplier Management System that meets organizational and compliance needs. Our team evaluates existing systems (if developed) and related processes, documents, and tools to identify gaps, understand needs, and establish priorities. Based on our initial assessment and evaluation, we work with the client to create a clear, customized roadmap for a Supplier Management System that will work within the context of the organization.
  • Development, Review, and Rework: Based on the priorities identified in the planning stage, our team establishes development milestones and timelines. We then begin building the system in stages, reviewing each milestone with the client as it is completed. This helps to ensure the Supplier Management System meets defined requirements, functions as desired, effectively supports supplier processes, and delivers organizational value every step along the way (e.g., improved efficiency, reduced risks, and enhanced compliance).
  • Turnover and Continued Support: Once KTL completes the development phase, we work closely with the client to coordinate the launch date and provide training to staff who will be using the system regularly to ensure they are comfortable with its functionality. We can also provide advanced user training to create internal “power users”, if desired. Importantly, our team remains available post-launch to provide ongoing support and to implement adjustments based on real‑world use. We are always available to expand the scope of development based on changing organizational needs to ensure the Supplier Management System remains a valuable tool.

Q: What are some of the most common integration challenges associated with a Supplier Management System and how do you address them?

For many companies, the biggest challenge is simply recognizing they need to develop, upgrade, or integrate a more robust Supplier Management System to meet organizational needs. Once that initial decision is made and development begins, there are several common integration challenges we encounter in the development process:

  • For many companies, the biggest challenge is simply recognizing they need to develop, upgrade, or integrate a more robust Supplier Management System to meet organizational needs. Once that initial decision is made and development begins, there are several common integration challenges we encounter in the development process:
  • Fragmented Inputs: The most common issue involves working with existing systems, data, and processes that are messy and don’t always align across the organization. This might include different teams in the same company using different, custom-built tools—none of which communicate with each other. These fragmented inputs create challenges figuring out how to combine various data sources and generate consolidated reports.  KTL’s data management professionals help evaluate these systems and processes to ensure they can be streamlined and integrated into a Supplier Management System.
  • Document and Evidence Management: Supplier Management Systems need to document, maintain, and store evidence of compliance. We find that many organizations do not have a common system for this documentation; rather, this evidence tends to “live” in different repositories without consistent version control or standards. Identifying the various repositories, determining the correct/most current versions of documents, and bringing everything together into a central repository can be challenging depending on past management practices. We support this process by helping organizations assess documentation gaps and establish structured document control frameworks within the Supplier Management System.
  • Compliance and Standards Mapping: Many organizations use their Supplier Management System as part of overall compliance programs to manage regulatory (e.g., Environmental Protection Agency (EPA), Food and Drug Administration (FDA), Occupational Safety and Health Administration (OSHA)) and/or third‑party certification (e.g., International Standards Organization (ISO), Global Food Safety Initiative (GFSI)) requirements. Translating these requirements into usable data fields, workflows, and reports can be complex—and can carry significant compliance consequences if done incorrectly. The challenge becomes even greater when the system must accommodate multiple regulations or standards at once. KTL’s environmental, health, and safety (EHS); food safety; and quality professionals provide technical insights to help ensure our Supplier Management Systems effectively meet compliance and certification requirements.

Q: How do you integrate the Supplier Management System with a company’s overall management system (e.g., food safety, quality, EHS)?

One of the things that differentiates KTL as an information technology (IT) solutions provider is that we aren’t a software vendor. Rather, we are a team of consultants who use our expertise in compliance management systems to build powerful, compliance‑ready solutions using Microsoft 365 and the Power Platform. We blend deep EHS, quality, and food safety experience with practical IT know‑how to build systems that function according to our clients’ operations and regulatory/certification requirements using the software most organizations already have (i.e., Microsoft 365).

Because of our team’s broader expertise, we’re able to effectively integrate Supplier Management Systems directly into organizational food safety, quality, and EHS programs. Supplier qualification, onboarding, audits, corrective actions, and reevaluations all flow seamlessly into existing management systems. Compliance and certification requirements are incorporated into every step in the supplier management process—from initial risk scoring through ongoing monitoring. The result is a Supplier Management System that is a natural extension of the overall management system, with connected workflows, shared data, increased consistency, reduced duplication of effort, and strengthened compliance across the organization.

19 Feb
FDA Human Foods Program 2026 Priorities

On October 1, 2024, the Food and Drug Administration (FDA) began implementing the largest reorganization in the Agency’s recent history, including launching a unified Human Foods Program (HFP) to oversee all activities related to food safety and nutrition. The HFP was designed to help ensure that the FDA-regulated food supply is safe by taking a systematic, risk management approach to implementing the preventive measures outlined in the Food Safety Modernization Act (FSMA) and responding to food-related emergencies. Specifically, the HFP’s mission is to protect and promote the health and wellness of all people through science-based approaches to prevent foodborne illness, reduce diet-related chronic disease, and ensure chemicals in food are safe.

Priority Deliverables

On January 23, 2026, FDA released its priority deliverables and guidance agenda for 2026 to further advance HFP’s vision and mission within the program’s three focus areas:

  • Food Chemical Safety focuses on ensuring exposure to chemicals and additives that occur in foods is safe.
  • Microbiological Food Safety focuses on the oversight of industry’s efforts to ensure the safety of the foods they produce and to prevent foodborne illness.
  • Nutrition promotes FDA’s Make America Health Again (MAHA) strategy and focuses on reducing chronic disease through better nutrition.

The table below outlines the 2026 priority deliverables for each of these areas. Several of these are also discussed in more detail in KTL’s recent article on 2026 Food Safety Trends to Watch.

Priority Deliverable HFP Actions
FOOD CHEMICAL SAFETY
Generally Recognized as Safe (GRAS) ReformPublish a proposed regulation requiring entities to submit GRAS notices for all new substances claimed to be GRAS before they are introduced into a human or animal food substance.
Post-Market Safety Reviews of Marketed Food ChemicalsContinue reassessing chemicals used in foods, starting with those most concerning to consumers; post a Systematic Post-Market Assessment process.
MicroplasticsConduct research to identify ways to accurately detect, quantify, and characterize microplastics in human food.
Closer to ZeroEstablish action levels for cadmium and inorganic arsenic in baby and toddler foods; issue guidance on preventive controls to minimize chemical hazards in all foods.
Natural Color AdditivesContinue phasing out petroleum-based food dyes and completing reviews of new natural alternatives.
Consumer Exposure to Contaminants in FoodContinue studying exposure to certain heavy metals, per- and polyfluoroalkyl substances (PFAS), and other contaminants in food.
Regulation of New Dietary IngredientsRelease final guidance regarding safety and identify information required for new dietary ingredient (NDI) notifications; develop methods to streamline FDA’s review of NDI notifications.
Dietary Supplement OversightEvaluate modernized approaches to support dietary supplement priorities with targeted enforcement strategies on violative products.
Guidelines for Caffeine LabelingPromote best industry practices for labeling added caffeine content in both packaged foods and beverages and those in retail and restaurant settings.
Allergen LabelingDevelop recommendations for transparency in disclosure of ingredients that impact certain health conditions and other established food allergens.
MICROBIOLOGICAL FOOD SAFETY
Food Inspection CoverageCreate Better Regulatory Inspections for Dynamic Government Efficiency (BRIDGE) by relying on state partners to carry out routine food safety systems inspections based on FDA’s national standards.
National Regulatory and Laboratory Training SystemBuild a sustainable training system and standards for all Integrated Food Safety System (IFSS) regulatory and laboratory professionals, including establishing the National Coordination Center to implement consistent training standards for federal and state regulatory and laboratory staff. 
Oversight and Safety of Imported FoodEnhance the ability to identify and act on violative products and ensure imported food meets the same food safety standards as food produced domestically; expand allocation of inspectional, laboratory, and other oversight resources to the foreign arena; enforce Import Certification and Foreign Supplier Verification Program (FSVP) requirements.
Imported Seafood SafetyContinue emphasis on sampling shrimp supply chains for compliance to ensure the safety of imported shrimp and complete development of a seafood fraud identification program.
Fresh and Processed Produce SafetyImprove the safety of fruits and vegetables through numerous activities including advancing training through the Produce Safety Alliance; new training for sprout producers; new cantaloupe, leafy greens, and cucumbers initiatives; and various studies of potential hazards in produce.
Dairy and Egg SafetyPromote contamination through enhanced training and education for dairy and egg producers.
Recall Process ModernizationExplore risk communication strategies to enhance public access to critical recall information; continue to improve the speed of recall classification through process improvements.
Food TraceabilityWork with entities to ensure they can comply with the Food Traceability Rule by the July 2028 compliance date, including facilitating tabletop exercises to test readiness and providing explanatory Q&As.
Food Code and Retail Program StandardsRelease an updated Food Code and Retail Program Standards Manual as models for local, state, and tribal regulators to update their food safety rules and programs.
Tech-enabled Advances in Risk ManagementIncrease the information and quality of data available to establish sound risk management strategies by developing a plan to use AI predictive models to analyze large datasets and examining the application of external third-party audit data to optimize FDA resources.
NUTRITION
Ultra-Processed Foods (UPFs)Develop a federal government definition of UPFs and work to better identify and reduce risks associated with high consumption of UPFs.
Infant Formula Safety (Operation Stork Speed)Begin implementing the plan to modernize infant formula nutrient requirements and expand options for safe, reliable, and nutritious infant formula.
Nutrition Regulatory Science ProgramWorking with the National Institute of Health (NIH), advance key research to guide food and nutrition policies to improve American’s diets and overall health (e.g., impacts of UPFs and food additives, role of maternal and infant dietary exposures on health outcomes).
Front-of-Package (FOP) Nutrition LabelingAdvance proposed regulation requiring food packages to display key information (e.g., added sugar, sodium levels) on the front of packages.
“Healthy” Claim ImplementationImplement the criteria finalized in 2025 that allows foods that meet certain standards to voluntarily use the “healthy” label claim and issue related guidance.
Food Standards of IdentityComplete an interim final rule, two new final rules, and several new proposed rules to continue eliminating 52 obsolete food standards of identity that describe in detail what a food must contain and what is optional in its formulation/production.
Added Sugar ReductionCreate an added sugar reduction strategy to encourage the food industry to lower added sugar in processed and prepared foods, including proposing a nutrient claim for added sugars and investigating ingredient and menu labeling requirements.
Sodium ReductionConduct a formal evaluation of Phase I voluntary targets under FDA’s voluntary sodium reduction initiative; encourage industry to reduce the sodium content of products.
Food Labeling for Online Grocery ShoppingIssue draft guidance on food labeling for online grocery shopping to increase transparency.
Guidelines on Direct Marketing of Certain Foods to ChildrenExplore development of potential industry guidelines to limit direct marketing of certain unhealthy foods to children.

HFP also intends to develop and/or revise guidance documents on a number of topics related to food chemical safety, microbiological safety, and nutrition.

Meeting FY2026 Priorities

As we move into 2026, it is important that facilities review and understand the HBP priorities and compliance expectations for FY2026 compared to internal programs, protocols, etc.—and then make any required updates to ensure alignment. This may include the following actions:

  • Educate staff to get a deeper understanding of products/operations and the associated regulatory changes and developments FDA has planned for FY2026.
  • Reassess regulatory exposure, strengthen internal systems, and ensure food safety programs are resilient, auditable, and aligned with broader business objectives in light of the FY 2026 HFP priorities.
  • Implement key actions, where possible, to meet impending requirements, for example:
    • Perform traceability exercises and mock recalls to help identify gaps in testing protocols, verification processes, corrective action implementation, and overall adequate traceability processes.
    • Inventory existing products and their ingredients to determine which products use synthetic dyes and reformulate with natural color alternatives.
    • Integrate environmental contaminant testing for lead, arsenic, cadmium, and mercury into existing product testing protocols, prioritizing high-risk categories.
    • Evaluate nutrition labels for required changes
  • Leverage partnerships with consulting partners with deep regulatory insight and practical implementation experience to help navigate the evolving regulatory landscape, protect against emerging risks, and position your organization to manage the HFP priorities for 2026 and beyond.
16 Feb
2026 Priorities: OSHA National, Regional, and Local Emphasis Programs

The Occupational Safety and Health Administration’s (OSHA) National Emphasis Programs (NEPs) are temporary programs that focus OSHA’s resources on particular hazards and/or high-hazard industries. OSHA identifies these programs by evaluating inspection data, injury and illness data, National Institute for Occupational Safety and Health (NIOSH) reports, peer-reviewed literature, inspection findings, and other available information sources.

Federal NEPs

OSHA currently has twelve active federal NEPs. In 2026, OSHA’s priorities concentrate on industries with high injury rates, severe hazards, or historically high non‑compliance. The table below highlights three NEPs that are on the top of OSHA’s list for 2026 and the most impacted industries under each.

NEPDescriptionMost Impacted Industries
Heat-Related HazardsThis NEP covering both indoor and outdoor heat hazards has been extended through April 8, 2026. OSHA inspectors are already evaluating heat risks and mitigation efforts (i.e., water, rest, shade, training) during site visits under existing OSHA regulations and will continue to target sites where the heat index is > 80°F.Agriculture, construction, warehousing, manufacturing, outdoor labor.
Warehousing and Distribution CentersThis three-year program, which runs through mid-2026, targets high-injury rate facilities, focusing on powered industrial vehicles, material handling, walking-working surfaces, and fire protection.Warehouses, distribution centers, logistics hubs.
Amputations in ManufacturingRenewed in 2025, this program continues to focus on machine guarding and lockout/tagout (LOTO) procedures.Iron foundries, plastics, metalworking, food manufacturing, machine‑intensive industries.

Regional and Local Emphasis Programs (REPs/LEPs): Focus on Food Manufacturing

Much like federal NEPs, REPs and LEPs are established at the regional or local (area office) level to target hazards or industries with specific risks to workers in that area. Essentially, while REPs have a broad application across a region, LEPs focus on addressing localized hazards or industry-specific risks. Although distinct from NEPs, REPs and LEPs influence OSHA inspection priorities.

While REPs/LEPs can focus on any industry, there are currently many that target food manufacturing, primarily related to high injury/amputation rates, machine guarding failures, LOTO/hazardous energy control issues, and cleaning/sanitation hazards. Generally speaking, these REPs/LEPs involve increased inspections, outreach, and enforcement to address risks to permanent and temporary workers, particularly in the following targeted industries:

  • Animal slaughtering and processing (NAICS 311611).
  • Animal food manufacturing (NAICS 311111).
  • Additional food processing operations, including cleaning and sanitation operations.

Preparing for NEPs/REPs/LEPs and OSHA Inspections

Companies in targeted industries (as outlined above) need to be aware of OSHA’s heightened focus areas for 2026, prepare for potential OSHA inspections, and build a solid foundation for compliance:

  • Strengthen Heat Illness Prevention Programs. Conduct heat surveys in indoor and outdoor areas to evaluate and understand heat-related concerns. Update and implement a Heat Illness Prevention Plan (HIPP) before peak summer months when the heat index is likely to climb > 80°F. Develop and implement practices to ensure workers have adequate water, rest, and shade, and verify and document training and monitoring processes.
  • Improve Machine Guarding and LOTO Programs. Conduct detailed reviews of machine guarding, including point‑of‑operation and interlocks, to ensure it meets requirements and adequately protects staff. Audit LOTO procedures to ensure they are compliant, documented, enforced, and understood. Regularly train all machinery operators on machine guarding and LOTO.
  • Conduct Internal Warehouse & Distribution Center Audits. Internal audits of warehouses, loading docks, and storage areas can help facilities identify problems—particularly related to OSHA’s focus areas—­and implement corrective actions before an OSHA inspection occurs.
  • Address REP/LEP Risks. Many regions—including Wisconsin, Illinois, and Ohio—have strong LEP/REP activity around food manufacturing, machine guarding, sanitation hazards, and LOTO. Food manufacturers should conduct regular internal audits of sanitation practices, machine guarding equipment, and energy control procedures. Importantly, employees must receive adequate training on both how to safely operate equipment in the food manufacturing environment and hazards related to the chemicals used for cleaning and sanitation purposes.
  • Anticipate More Unannounced Inspections. A second-party mock OSHA inspection is one of the best ways to identify hazards, areas of concern, and opportunities for improvement in operational practices and documentation requirements. A second-party auditor can provide an objective assessment of overall compliance status, so non-conformances don’t catch you off guard.
  • Reinforce Worker Training and Communication. Training is a consistent requirement across all NEPs/REPs/LEPs to meet compliance requirements and, more importantly, to ensure all employees have a clear understanding of safety procedures and expectations.
Sidebar: