Safe Foods for Canadians

This is the second in our summary of the new Canadian Food legislation.

Here we will address one of the stated reasons for the passing of the Act.  From the CFIA’s (Canadian Food Inspection Agency) summary of the Act:

“Strengthened food traceability:  Current legislation does not require food manufacturers and other regulated parties to have traceability systems.  The legislation provides the CFIA with strengthened authorities to develop regulations related to tracing and recalling food, and the appropriate tools to take action on potentially unsafe food commodities.  This includes a prohibition against selling food commodities that have been recalled.”

Boy have we come a long way.  Not so long ago, MS Word would tell me that “traceability” was not a word (back when we were talking about it as a neat feature of our SPC systems.)  No longer!  Now we offer complete systems for traceability, not just an extra feature of another solution.

The provisions of the USA Bio-terrorism Act of 2002, USA FSMA, and now Safe Foods for Canadians, all consider traceability to be a major concern.  Not to mention that the big box companies have even more stringent requirements.  Many food companies think they have it nailed, but there are serious holes and issues in most paper based systems.  The first and foremost is of course the possibility of error, transcription, or illegibility.

If you manufacture your own products, under BTA you are allowed a maximum of 24 hours to produce a complete recall list with SKU # and location.   If you co-pack, or ship to the Walmarts and Costcos of this world, you may have less than 4 hours.

In a paper world, production batch sheets are usually sorted by shift and placed in envelopes with supporting documentation.  Although I have met people who swear they can do a mock recall in less than 4 hours purely on paper, I can’t conceive of how they can do so accurately and completely:  It is easy to recall all of production lot 2012076, (it may all have shipped to the same big box warehouse!) but to recall all SKUs that contain or may contain liquid sugar 211093882 that entered the tank on May 15 2013, and the tank hasn’t been cleaned since then – that would be a neat trick.

Even worse: What do you do with this if the recall is for any product delivered by driver John Smith?  Or all products of JS Company delivered between Jan 14 and Jan 19?  And what if somebody dropped the batch sheets into a vat?

Canada isn’t there yet, but between the Safe Foods for Canadians Act, and the CFIA stepping up to provide regulations, I don’t think Canadian food processors have a very long window… and besides, it is just smart business, good manufacturing practice, good corporate citizenship, and limits exposure if you do need to do a recall.  Lack of clear traceability by definition means that a recall can be orders of magnitude larger than it would be with contained traceability.

The Unseen Heroes – Food Safety Professionals

According to Merriam-Webster®, a hero is: 

  1. a mythological or legendary figure often of divine descent endowed with great strength or ability
  2. an illustrious warrior
  3. a man admired for his achievements and noble qualities
  4. one who shows great courage
  5.  the principal male character in a literary or dramatic work
  6. the central figure in an event, period, or movement
  7. an object of extreme admiration and devotion : idol

(Please forgive the gender… The dictionary distinguishes between Hero and Heroine.)

We all see the visible heroes – the men and women who serve in the armed forces; the first responders; the everyday people who perform acts of bravery to assist others.   Then there are the doctors and nurses in the ER.

But what about all the men and women who protect our food supply – the food safety professionals?

I just returned from the Food Safety Summit in Baltimore.  Our team was so impressed with the people we met.  These professionals work tirelessly to ensure that the food created in their facilities is produced using safe and certified ingredients and processes; tested for all know contaminants; and can be traced for swift recall if something goes wrong. In addition, they are often responsible for making sure that all of the processes are safe for those working in the factory.  These are the people who create the contingency plans so that disasters like Super-storm Sandy wreak as little havoc as possible.

They have to be up to date on ever changing regulations; work with multiple government and regulatory bureaucracies; and often are considered a necessary evil by their employers – after all they do not create any wealth and seem to always spend money.

So they spend long hours working with antiquated paper-based systems with one objective – protecting their friends, neighbours, and even enemies from all imaginable dangers in the food supply.

 

These too are heroes.

Is our Food safe?

The recent outbreak of Escherichia coli in meat shipped by XL Foods has raised food safety to new heights in the public eye.  Despite the significance of this mammoth recall, my experience in food plants over the past 20 years tells me that overall our food is getting safer, and food safety is achieving a higher priority in many food companies.  The problem is that big box stores, and food industry amalgamation means that when a problem occurs, it is no longer a local manufacturer and local stores – it is a continent, or more, with millions of people potentially affected.   The XL Foods recall represents over 2,948,00 pounds of product… perhaps not as much as the 25,000,000 pounds  in 1997 (Hudson Foods) or 21,700,000 pounds (Topps in 2007), but pretty big nevertheless.

According to the Centers for Disease Control in Atlanta, [Rangel JM, Sparling PH, Crowe C, Griffin PM, Swerdlow DL. Epidemiology of Escherichia coli O157:H7 (the most common strain of E.coli) outbreaks, United States, 1982–2002. Emerg Infect Dis [serial on the Internet]. 2004 Apr. Available from   http://wwwnc.cdc.gov/eid/article/11/4/04-0739.htm] e.coli 0157:H7 causes 73,000 illnesses in the US each year resulting in 61 deaths annually.  From 1982 – 2002, 49 states reported 350 outbreaks of which 52% were foodborne – 41% of which were from ground beef and 21% from produce.

It is important to note that “foodborne” does not necessarily refer the manufacturing channel – it includes restaurants (which may be manufacturer, handling, or restaurant caused).  A small number of ground beef related outbreaks were restaurant “associated”, while a majority of the produce related outbreaks were restaurant “associated”.  NO fast-food related hamburger outbreaks have been reported since 1995, which shows the impact of food safety awareness.  According to most sources, E.coli O157:H7 is killed by “properly” cooking meat, so the industry could say that preparation is everything; nevertheless the U.S.D.A. banned the sale of ground beef contaminated with the O157:H7 strain in 1994.

The number of e.coli outbreaks (or perhaps the reporting of outbreaks) rose from 1993 to 2000, and then started to recede.  The other good news is that the median outbreak size has declined over the entire time.  It would be interesting to know whether that decline is a result of faster reaction time, better containment, or better food safety. The authors of the study attribute the decreased outbreak size to increased reporting of less “clinically severe outbreaks”.  In layman’s language, more reporting of smaller outbreaks is essentially watering down the numbers.

I couldn’t find any empirical studies with statistics after 2002, but a review of media reports seems to indicate that incidence is on the rise again after 2007, but that may just be because of the huge size, or media exposure of recent recalls.

As the food industry goes through a similar transformation in quality as the automotive industry underwent in the eighties, we can hope that food safety continues to improve.  By showing HACCP points, GFSI data, Process Profiles, Test results and other information to operators in real time, reaction time is improved:  actions can be taken that can respond to potential food safety concerns before they materialize.

Nevertheless, I never ceased to be amazed at how many very large food companies are still using paper, or worse.  There is nothing wrong with paper systems, per se, but they certainly do not elevate alarms as quickly or as accurately as automated systems, properly deployed.

Food Safety is as much an attitude as it is a quality system.  Even if systems exist to drive sanitation, traceability, and testing, if concern for food safety is not ingrained into staff, then we can expect to see more outbreaks.  Having said that, the existence of, and investment in, food safety monitoring systems does send a message to employees that food safety is a priority for management.  I remain hopeful that our entire supply chain is getting safer every day.